Plots 9-14, Oldchurch Hospital, Romford

planning report PDU/0287g/02 14 July 2010 Plots 9-14, Oldchurch Hospital, Romford

in the London Borough of Havering planning application no. P1638.09

Strategic planning application stage II referral (new powers) Town & Country Planning Act 1990 (as amended); Greater London Authority Acts 1999 and 2007; Town & Country Planning (Mayor of London) Order 2008

The proposal Redevelopment of the former Oldchurch Hospital site to provide of 493 residential units, a local park, and an energy centre. The applicant The applicant is Taylor Wimpey East London, and the architect is PRP.

Strategic issues The proposal will continue the regeneration of a brownfield site to provide town centre housing although affordable housing provision will be minimal. The design is acceptable, and a new local park with play facilities will be created. Outstanding design, transport and sustainable development issues have been resolved.

Recommendation That Havering Council be advised that the Mayor is content for it to determine the case itself, subject to any action that the Secretary of State may take, and does not therefore wish to direct refusal or direct that he is to be the local planning authority.

Context

1 On 18 December 2009 the Mayor of London received documents from Havering Council notifying him of a planning application of potential strategic importance to develop the above site for the above uses. This was referred to the Mayor under Category 1A of the Schedule to the Order 2008: “Development which comprises or includes the provision of more than 150 houses, flats, or houses and flats.”

2 On 20 January 2010, the Mayor considered planning report PDU/0287g/01, and subsequently advised Havering Council that the application did not comply with the London Plan, for the reasons set out in paragraph 65 of the above-mentioned report; but that the possible remedies set out in paragraph 67 of that report could address these deficiencies.

3 A copy of the above-mentioned report is attached. The essentials of the case with regard to the proposal, the site, case history, strategic planning issues and relevant policies and guidance

page 1 are as set out therein, unless otherwise stated in this report. Since then, the application has been revised in response to the Mayor’s concerns (see below). On 17 June 2010, Havering Council decided that it was minded to grant planning permission, subject to the verification of a financial viability assessment and the applicant entering into a section 106 agreement for the revised application, and on 1 July 2010, it advised the Mayor of this decision. Under the provisions of Article 5 of the Town & Country Planning (Mayor of London) Order 2008 the Mayor may allow the draft decision to proceed unchanged, direct Havering Council under Article 6 to refuse the application or issue a direction to Havering Council under Article 7 that he is to act as the Local Planning Authority for the purposes of determining the application. The Mayor has until 21 July 2010 to notify the Council of his decision and to issue any direction.

4 The decision on this case, and the reasons will be made available on the GLA’s website www.london.gov.uk.

Update

5 At the consultation stage Havering Council was advised that the application did not comply with the London Plan, for the reasons set out in paragraph 65 of the above-mentioned report; but that the possible remedies set out in paragraph 67 of that report could address these deficiencies:

 Affordable housing: Potential for a review of affordable housing provision prior to the commencement of each build stage of the proposal.

 Urban design: Review of the elevational treatment used across the site to minimise repetitiveness across multiple buildings

 Access: Confirmation that the proposed disabled parking bays will be available to or reserved for disabled users.

 Transport: Additional assessment of the cumulative impact of development is required, as is work to identify local improvements in the pedestrian environment. Clarification of s106 issues relating to bus stop accessibility, land ownership for future transport improvements, and highway improvements.

 Sustainable development: The applicant should provide further information regarding district heating (in particular, the hospital and Swan Housing site), as well as the ways in which connections would be made. The applicant should also provide heat profiles to show that the size of the CHP has been optimised. The need and locations required for active cooling should be provided.

6 The application has been amended to address these comments. These amendments are described within the following sections.

Affordable housing

7 The consultation stage noted that although the scheme has low affordable housing provision, consideration of the scheme in conjunction with the provision across the wider outline site results in the provision of 31% of housing being affordable. This was acceptable, but the Council was requested to investigate the inclusion of a ‘clawback’ mechanism within the section 106 agreement, whereby affordable housing provision would be reviewed prior to each phase of construction, subject to prevailing economic conditions.

8 Following the consultation stage, the applicant submitted a viability assessment that demonstrated that the scheme has limited potential for the provision of additional housing. The present application is a response to the changed economic conditions resulting in the previous

page 2 scheme becoming unviable. The Council has made its approval of the scheme conditional on the independent verification of the viability assessment. It has declined to add a ‘clawback’ mechanism due to the limited viability. Given the evolving economic and political background, and the acceptable overall level of affordable housing provision, officers will not pursue the inclusion of a mechanism.

Urban design

9 The applicant has declined to revise the appearance of the buildings, citing their improved appearance when compared with the previously approved scheme. This improvement is not disputed, however at consultation stage, additional design details or variation were requested, to introduce visual breaks into the development where multiple buildings would be visible in long views, for example along Waterloo Road. Havering Council supports the original approach and notes that the design is “consistently good” throughout the development. Matters of appearance are often subjective and officers note that other features of the buildings, notably the scale and massing, are appropriate. As such, while officers still do not consider the buildings’ appearance to be wholly satisfactory, the overall design approach is generally sound.

10 The applicant has also noted the improvements made to the scheme between the pre- application and consultation stages, notably the differentiation and improvement of the two east- west routes through the centre of the site.

Access

11 The applicant has prepared a plan showing that 10% of spaces are designed for disabled parking bays. These spaces will not be reserved at the outset; rather, a flexible approach will be adopted once the amount of disabled residents is established. Permanent visitor bays are encouraged. To ensure that an adequate disabled parking strategy is in place, the Council has recommended that a condition be placed on the decision notice, stating that disabled parking plans be submitted to and approved by the council upon the commencement of each phase of development.

Transport

12 During the consultation stage, Transport for London (TfL) requested that a construction logistics plan and delivery and servicing plan be secured for the site by condition and that the contributions and safeguarded strip of land, previously secured from the original application for the site, all be retained as part of these revised proposals. TfL additionally raised concerns in relation to the car parking and the quality of the travel plan, and suggested that the applicant provide additional electric vehicle charging points, alongside undertaking a pedestrian audit of the site, and its surrounding area.

13 Additional information has been submitted by the applicant to address the above concerns, and as a result, TfL is now satisfied that the issues raised at the consultation stage have been adequately dealt with. As such, TfL welcomes Havering Council’s committee report, dated 17 June 2010, which secures by condition the requirement for cycle parking provision, a construction logistics plan and delivery and servicing plan, the provision of electric vehicle charging points and a scheme for the proposed changes to the highway network, all to be submitted and approved by the local planning authority prior to commencement on site.

14 TfL also welcomes the transport aspects of draft section 106 heads of terms, which secures i) a £20,000 contribution towards the improvement of bus stops in the vicinity of the site, ii) a £200,000 contribution, payable to LB Havering, towards the provision of a surface level pedestrian crossing on Waterloo Road along the boundary of the site, or the improvement of pedestrian access between the site and Romford Town Centre and station, iii) the safeguarding of a strip of land adjacent to Oldchurch Road for the potential purposes of road widening and/or extension to

page 3 the existing bus lane, iv) the restriction of residents and their visitors from applying for parking permits within any controlled parking zone in the vicinity of the site, and v) the agreement and implementation of a travel plan for the development.

Sustainable development

15 The applicant has acknowledged that the 50kWe CHP unit size originally proposed was very small in relation to the thermal load of the proposed development. Without committing to a larger size at this stage, they have also indicated that a CHP size between 100kWe and 150kWe is likely to be pursued when implementation of the proposed development is progressed. A system of this size would be more in keeping with the likely heating demand profile for a development such as this. Given the relatively small scale of the development (for CHP purposes) and the applicant's recognition that a larger CHP system will be pursued at the construction stage, no additional information, beyond the applicant's existing commitment to use CHP to supply the site wide district heating, is required.

16 The applicant has investigated the possibility of linking with existing and proposed local networks. Investigations in linking with Queen’s Hospital revealed that there is no surplus capacity at the hospital that could be utilised by the proposed development. The applicant and Swan Housing, which is developing the site to the west of the application site, have agreed to investigate opportunities to develop a communal heating system, although provision of a scheme is not a definite commitment. Recognising this, the applicant has restated its commitment to connect to larger district heating infrastructure if this is forthcoming. The connection could be managed by the removal of the site’s CHP energy centre to boost the capacity/operating hours of a larger electricity and heat generator, the space in the energy centre designated for the CHP being taken over by the installation of a heat exchanger which would regulate the temperature from the larger system to match the requirement for the site’s buildings’ systems.

17 The applicant has stated that there is no need for active cooling within the development as dwellings will be designed to achieve comfort using passive design. This is acceptable to officers. Response to consultation

18 Of the 412 letters sent to local residents, Havering Council received one objection letter. The basis of the objection is the loss of views across the site, towards London. While this is unfortunate for the residents of the affected block, the loss of an existing view is not a material planning consideration.

19 The Gidea Park and District Civic Society advised the Council that it had no comments on the proposal.

20 Other external consultation responses were received by the Council and are summarised:

 Barking & Dagenham Council: Objects to the level of parking within the development, leading to concerns of ‘knock on’ parking effects on streets within the adjoining borough.  English Heritage: No objection on either conservation or archaeological grounds.  Environment Agency: No objection subject to the imposition of conditions regarding contamination, sound insulation, noise levels and construction hours.  London Fire and Emergency Planning Authority: Requested further information from the Council, to be able to judge whether the scheme is compliant with Building Regulations. No planning objections.  London Fire Brigade: Two hydrants to be provided.  National Grid: No objection, but a low pressure mains line crosses the site.

page 4  Natural England: While no specific objections were made, general advice was provided regarding the presence of a protected species (the Black Redstart) within the area, and the potential presence of local wildlife corridors. The applicant is encouraged to incorporate features within the scheme to aid biodiversity.  Network Rail: No comments or objections.  Thames Water: No objection, subject to an upgrade of the local waste water infrastructure (though a condition of approval) and provision of appropriate surface water drainage.

21 No new strategic concerns are raised by these representations. Article 7: Direction that the Mayor is to be the local planning authority

22 Under Article 7 of the Order the Mayor could take over this application provided the policy tests set out in that Article are met. In this instance the Council has resolved to grant permission with conditions, subject to the verification of a financial viability assessment and the applicant entering into a section 106 agreement, which satisfactorily addresses that matters raised at stage I, therefore there is no sound planning reason for the Mayor to take over this application. Legal considerations

23 Under the arrangements set out in Article 5 of the Town and Country Planning (Mayor of London) Order 2008 the Mayor has the power under Article 6 to direct the local planning authority to refuse permission for a planning application referred to him under Article 4 of the Order. He also has the power to issue a direction under Article 7 that he is to act as the local planning authority for the purpose of determining the application. The Mayor may also leave the decision to the local authority. In directing refusal the Mayor must have regard to the matters set out in Article 6(2) of the Order, including the principal purposes of the Greater London Authority, the effect on health and sustainable development, national policies and international obligations, regional planning guidance, and the use of the River Thames. The Mayor may direct refusal if he considers that to grant permission would be contrary to good strategic planning in Greater London. If he decides to direct refusal, the Mayor must set out his reasons, and the local planning authority must issue these with the refusal notice. If the Mayor decides to direct that he is to be the local planning authority, he must have regard to the matters set out in Article 7(3) and set out his reasons in the direction. The Mayor must also have regard to the guidance set out in GOL circular 1/2008 when deciding whether or not to issue a direction under Articles 6 or 7. Financial considerations

24 Should the Mayor direct refusal, he would be the principal party at any subsequent appeal hearing or public inquiry. Government guidance in Circular 03/2009 (‘Costs Awards in Appeals and Other Planning Proceedings’) emphasises that parties usually pay their own expenses arising from an appeal.

25 Following an inquiry caused by a direction to refuse, costs may be awarded against the Mayor if he has either directed refusal unreasonably; handled a referral from a planning authority unreasonably; or behaved unreasonably during the appeal. A major factor in deciding whether the Mayor has acted unreasonably will be the extent to which he has taken account of established planning policy.

26 Should the Mayor take over the application he would be responsible for holding a representation hearing and negotiating any planning obligation. He would also be responsible for determining any reserved matters applications (unless he directs the council to do so) and determining any approval of details (unless the council agrees to do so).

page 5 Conclusion

27 The matters raised within the consultation stage have been addressed within this report. Although the Council and the applicant could not wholly accommodate the comments made within the consultation stage, on balance the scheme is acceptable in principle and in compliance with the London Plan.

for further information, contact Planning Decisions Unit: Colin Wilson, Senior Manager – Planning Decisions 020 7983 4783 email [email protected] Justin Carr, Strategic Planning Manager (Development Decisions) 020 7983 4895 email [email protected] Glen Rollings, Case Officer 020 7983 4315 email [email protected]

page 6

planning report PDU/0287g/01 20 January 2010 Plots 9-14, Oldchurch Hospital, Romford

in the London Borough of Havering Planning application no. P1638.09

Strategic planning application stage 1 referral (new powers) Town & Country Planning Act 1990 (as amended); Greater London Authority Acts 1999 and 2007; Town & Country Planning (Mayor of London) Order 2008

Strategic issues The proposal will continue the regeneration of a brownfield site to provide town centre housing although affordable housing provision will be minimal. The design is mostly acceptable, and a new local park with play facilities will be created. There are some minor transport and sustainable development issues that will need further investigation, but parking and access are acceptable.

Recommendation That Havering Council be advised that while the application is generally acceptable in strategic planning terms the application does not comply with the London Plan, for the reasons set out in paragraph 65 of this report; but that the possible remedies set out in paragraph 67 of this report could address these deficiencies.

Context

28 On 18 December 2009 the Mayor of London received documents from Havering Council notifying him of a planning application of potential strategic importance to develop the above site for the above uses. Under the provisions of The Town & Country Planning (Mayor of London) Order 2008 the Mayor has until 28 January to provide the Council with a statement setting out whether he considers that the application complies with the London Plan, and his reasons for taking that view. The Mayor may also provide other comments. This report sets out information for the Mayor’s use in deciding what decision to make.

page 7 29 The application is referable under Category 1A of the Schedule to the Order 2008: “Development which comprises or includes the provision of more than 150 houses, flats, or houses and flats.”

30 Once Havering Council has resolved to determine the application, it is required to refer it back to the Mayor for his decision as to whether to direct refusal; take it over for his own determination; or allow the Council to determine it itself.

31 The Mayor of London’s statement on this case will be made available on the GLA website www.london.gov.uk. Site description

32 The site forms part of the Former Oldchurch Hospital site, located on the south-western edge of Romford town centre. Outline planning permission has previously been granted across the site, but this application concerns only plots 9 to 14 of that permission. The site has an area of approximately 1.44ha and is bordered by Waterloo Road to the east and Oldchurch Road to the south. To the north is an access road serving the previously constructed portion of the outline proposal. A further housing site is situated to the west, beyond which are operational gas holders.

33 The site has been cleared of all structures. Some border vegetation remains along the road edges; trees are protected by a Tree Preservation Order.

34 The site is located in close proximity to Romford town centre and is adjacent to the junction of the A125 Waterloo Road with Old Church Road/ Rom Valley Way, all of which form part of the Strategic Road Network (SRN). There are four different bus routes within an acceptable walking distance of the site, with the nearest stops located outside the site on Old Church Road. Romford railway station, which provides frequent services into central London and East Anglia, is also located within 700 metres of the site. As such, it has been demonstrated by the applicant that the site records a very good public transport accessibility level (PTAL) of 5/ 6, on a scale of 1-6, where 6 is classed as excellent.

Details of the proposal

35 The site can be considered as two distinct portions. The eastern portion would house 492 flats arranged in blocks around one north/south and two east/west internal routes. Buildings would be between six and ten storeys in height. The two larger buildings adjacent to the eastern boundary would have podium amenity areas above enclosed ground-level parking space, with other parking dispersed in the open areas throughout the development.

36 The western portion of the site would contain a park incorporating a ‘kickabout’ area, picnic and sheltered areas, a play area and areas for habitat creation. This portion of the site has an area of 1.1ha.

37 The proposal is similar in many respects to the extant outline permission, but is instead a full application and therefore not considered as part of the previous outline permission. Case history

38 A pre-application meeting on this scheme was held on 29 September 2009, and was attended by the applicant, agent, architect and a Havering Council officer.

page 8 39 The Mayor has previously considered applications on this, and other portions of the former Hospital Site. The cases relevant to this development are listed below:

 On 21 October 2009, the Mayor provided Stage 1 comments (report ref PDU/0287f/01) for a development of 463 residential units, on the western part of the site being developed by the Swan Housing Group (referred to in this report as the Swan Housing site);

 In July 2006, the former Mayor allowed Havering Council to approve a mental health facility on 2.19 hectares of the former hospital site (report ref PDU/0287d/01);

 In August 2005, the former Mayor allowed Havering Council to grant outline permission (report ref PDU/0287c/02) for residential development comprising 225 key worker and 495 open market housing units. The keyworker units were built, but the open market housing was not. Strategic planning issues and relevant policies and guidance

40 The relevant issues and corresponding policies are as follows:

 Housing London Plan; PPS3; Housing SPG; Providing for Children and Young People’s Play and Informal Recreation SPG, draft Housing Strategy; draft revised interim Housing SPG  Affordable housing London Plan; PPS3; Housing SPG, draft Housing Strategy; draft revised interim Housing SPG  Density London Plan; PPS3; Housing SPG; draft revised interim Housing SPG  Urban design London Plan; PPS1; draft Housing Design Guide  Parking London Plan; the Mayor’s Transport Strategy; PPG13  Transport London Plan; the Mayor’s Transport Strategy; PPG13; draft Transport Strategy  Access London Plan; PPS1; Accessible London: achieving an inclusive environment SPG; Planning and Access for Disabled People: a good practice guide (ODPM)  Sustainable development London Plan; PPS1, PPS3; PPG13; PPS22; the Mayor’s Energy Strategy; Sustainable Design and Construction SPG  Biodiversity London Plan; the Mayor’s Biodiversity Strategy; PPS9

41 For the purposes of Section 38(6) of the Planning and Compulsory Purchase Act 2004, the development plan in force for the area is the 2008 Core Strategy and Development Policies Document, the Romford Area Action Plan, and the London Plan (Consolidated with Alterations since 2004).

42 The draft replacement London Plan is also a relevant material consideration.

Housing

43 The quantum of housing is similar to that of previous outline proposal on the site. The mix of units is shown in the following table:

page 9

Open market Intermediate Social rented

One-bedroom flat 175 0 0

Two-bedroom flat 293 2 3

Three-bedroom flat / 14 1 5 maisonette

44 The mix is broadly similar to that of the outline scheme, but the percentage of family accommodation is slightly lower, by 5% (with a corresponding increase in the number of two- bedroom flats). The applicant has argued that the outline scheme is no longer viable and that the housing approved under this scheme will not be built. The applicant’s design and access statement states that the mix has been derived from local requirements. Likewise, the provision of a greater level of family housing is considered by the applicant to be unviable, and that there is no (current) demand for this form of accommodation in this location. The viability assessment submitted as part of the application supports the current position. The housing mix is generally appropriate for an edge of town centre site; however, given the proposed open space provision it is disappointing that a higher proportion of family housing could not be provided.

45 The applicant’s flood risk assessment demonstrates that the site is within an area with a zone 1 risk of flooding, meaning that there is a low risk of flooding, of less than 0.1% a year.

Children’s play space

46 Policy 3D .13 of the London Plan sets out that “the Mayor will and the boroughs should ensure developments that include housing make provision for play and informal recreation, based on the expected child population generated by the scheme and an assessment of future needs.” Using the methodology within the Mayor’s supplementary planning guidance ‘Providing for Children and Young People’s Play and Informal Recreation’ it is anticipated that there will be approximately 75 children within the development. The guidance sets a benchmark of 10 sq.m. of useable child playspace to be provided per child, with under-5 child playspace provided on-site. As such the development should make provision for 750 sq.m. of playspace.

47 This development provides 1805 sq.m of local area play (LAP) space, within the development, citing the podium areas and an area of linear landscaping along Waterloo Road (173.7 sq.m) although play space adjacent to a main road may not be appropriate. Nonetheless, the proposed development provides a level of play space in excess of requirements, and is supported by officers. 410 sq.m of local equipped area play (LEAP) space will be provided in the proposed park, which is also supported. Affordable housing

48 London Plan Policy 3A.10 requires borough councils to seek the maximum reasonable amount of affordable housing when negotiating on individual private residential and mix-use schemes. In doing so, each council should have regard to its own overall target for the amount of affordable housing provision. Policy 3A.9 states that such targets should be based on an assessment of regional and local housing need and a realistic assessment of supply, and should take account of the London Plan strategic target that 35% of housing should be social and 15% intermediate provision, and of the promotion of mixed and balanced communities. In addition, Policy 3A.10 encourages councils to have regard to the need to encourage rather than restrain

page 10 residential development, and to the individual circumstances of the site. Targets should be applied flexibly, taking account of individual site costs, the availability of public subsidy and other scheme requirements. Havering Council has an adopted policy with a borough-wide target of 50%.

49 Policy 3A.10 is supported by paragraph 3.52, which urges borough councils to take account of economic viability when estimating the appropriate amount of affordable provision. The ‘Three Dragons’ development control toolkit is recommended for this purpose. The results of a toolkit appraisal might need to be independently verified. The applicant has submitted an assessment based on the ‘Three Dragons’ model which is currently being assessed by Havering Council.

50 Only eleven affordable homes are proposed. This level has been derived from viability exercises carried out in relation to the previous outline scheme, and take account of the level of affordable housing across the entire site, including the intermediate housing that was built as part of the outline scheme. This housing was built partially to replace existing NHS worker accommodation on the former hospital site, and also meet other locally based demand.

51 The outline application was approved with an overall affordable housing level of 31%. This proposal provides only a negligible percentage of housing, but when considered in conjunction with the provision across the outline site, including the completed intermediate housing, there will be an affordable housing provision of 31%. Given this background and the viability information, this is acceptable to officers. However it is recommended that the Council investigate the option of including ‘clawback’ mechanism within the section 106 agreement, whereby affordable housing provision would be reviewed prior to each phase of construction, subject to prevailing economic conditions. This allows for a reconsideration of the level of provision should economic conditions improve.

52 The outline application was approved with a minimal level of social rented housing, instead including a high level of intermediate housing (which has subsequently been built). The GLA and Havering Council accepted the “exceptional circumstances” of the proposal to subsidise the costs associated with the redevelopment of the site, the construction of a new District General Hospital on Oldchurch Park to the south of the site, and the provision of a new public open space to compensate for the loss of Oldchurch Park to development. The applicant also points out that there are an estimated 500 social rented units on an estate within the vicinity of the site, including the estate to the north of the railway, and that additional provision would create housing management difficulties and a less balanced local community. Density

53 The proposed density of 144 units per hectare represents a slight decrease compared with previously proposed levels, and appears to be in response to design changes that include the revised massing of the buildings. The site is highly accessible on the edge of a town centre, close to a future Crossrail station; therefore the density is appropriate for this site. Urban design

54 The general arrangement of the proposal, including the layout and the location of podium amenity space, is supported. Additionally the reduction in block sizes, when compared with the outline proposal, is welcomed. The internal podium areas have an approximate width of 30 metres, which is considered to be sufficient for light access and privacy purposes.

55 Building heights are also in accordance with the previous outline plan and are similar to the existing buildings on the site. Heights are uniform across the site, but there is sufficient variation in the massing of the buildings to ensure that this will not become monotonous. The buildings

page 11 also provide a hard edge to the park and road edges, delineating the break between the public and private spaces. The scale and massing will suitably act as an entrance gateway to the town centre.

56 North-facing flats are dual-aspect. There is a good provision of active frontages around the site, and pre-application concerns by officers regarding front/back ambiguity have been resolved.

57 The internal street network is laid out logically. The creation of two east-west streets was initially questioned by officers, but was undertaken to reduce and create more variety in block size and grain. There were concerns that the two streets would have a near-identical treatment, and that opportunities to differentiate the street through landscaping could be taken, and as such the applicant has amended the scheme to design the southern street with a slightly less formal character in terms of hard and soft landscaping. Additionally there will be a slight reduction in on- street parking, aiding residents and visitors with site legibility and adding character to the scheme.

58 The retention of existing boundary trees is supported, as is the creation of the new route from the park to the Waterloo Road crossing and town centre.

59 Although there will be under-podium parking in the larger blocks, much of the parking will be on the new internal streets and in courtyards. Both hard and soft landscaping has been used to ‘break up’ the on-street parking areas and have improved during officer negotiations. Opportunities for parking outside marked bays will be limited. Although the courtyard parking is less successful, creating three rows of parking outside residential areas, it will be landscaped and on balance the public realm treatment is acceptable.

60 The internal layout is acceptable and although blocks have long corridors, they are frequently punctuated by cores. Dual-aspect flats comprise around 70% of the number of units, with deck access on upper floors in the larger blocks. Although some unit sizes are not in compliance with the draft replacement London Plan, they are only slightly under the draft suggested levels, and other features of the design, such as orientation and access to the new park, provide a balance to the unit sizes.

61 Building materials include light and dark brick (with bricks varying in colour within each palette to provide variety), and metal panel and cement board cladding. While there is sufficient variation in detail within each building, the treatment has been applied uniformly across all but one of the buildings on the site. While this approach ties all of the buildings together, making the scheme recognisable as a single development, officers would request some additional design details or variation to ‘break up’ the development where multiple buildings are visible in long views, for example along Waterloo Road.

The proposed park

62 The creation of the park in the proposed location is welcomed. It will provide an attractive setting for the retained locally listed building near its northern boundary (the mental health facility, outside the site boundary) and potentially for the proposed development. The park will be adopted by Havering Council, and therefore expected to be available to existing local residents.

63 The landscaping within the park has been co-ordinated to create routes between the development and the Swan Housing site to the west, as well as creating an appropriate setting for the retained building to the north. Different areas of the park will cater for different uses and users, and will include an area for games, play space, and habitat areas to encourage increased local biodiversity.

page 12 Parking

64 246 car parking spaces are being proposed for the site. This equates to a ratio of 0.50 spaces per residential unit, which is in accordance with the London Plan standards and therefore considered acceptable. Despite the lack of a formal controlled parking zone in the area, there are a number of parking restrictions in force that should help to prevent the risk of overspill parking. Transport for London would however recommend that a condition requiring the applicant to monitor parking conditions in the area and fund any necessary localised amendments, if needed, be considered. It is proposed that 20% of parking spaces will have electric vehicle charging points, and while this is welcomed, it should be noted that in accordance with Policy 6.13 ‘Parking’, of the draft revised London Plan, an additional 20% of spaces should also have passive provision. Transport

65 Transport for London (TfL) previously advised the applicant that, due to the proposed development planned at the western end of the site, which would take the total number of residential units on site to over 1000 dwellings, an assessment taking into account both developments would need to be undertaken. This is still outstanding. In addition, all trip generation figures should be given separately for each of the available public transport modes.

66 A contribution of £20,000 was secured for bus stop accessibility improvements on Oldchurch Rise as part of the previous application for this site, and TfL therefore requests that this be retained as part of these revised proposals. TfL would also recommend that an additional contribution is secured towards providing either accessibility improvements to the existing bus stops on Waterloo Road, or for the provision of two new accessible bus stops on Waterloo Road, south of the railway lines, in order to better serve the development by local bus.

67 The previously safeguarded strip of land that borders Oldchurch Road to the south of the site is to be retained as part of these revised proposals. This is welcomed and should be secured through the s106 agreement. This dedicated land will facilitate the implementation of an eastbound bus lane on Oldchurch Road, subsequently improving bus journey times to the site. As modifications to the timing of the existing pelican crossing on Oldchurch Road will be required in order to accommodate the widening of Oldchurch Road, TfL would also recommend that some of the £250,000 contribution previously secured towards highway improvements, is directed towards this work, along with some additional funding being diverted towards the cost of implementing the bus lane, in accordance with the London Plan policy 3C.14 ‘Enhanced bus priority, tram and busway transit schemes’ and draft revised London Plan policy 6.7 ‘Buses, bus transits, trams’.

68 In accordance with the London Plan policy 3C.21 ‘Improving conditions for walking’ and draft replacement London Plan policy 6.10 ‘Walking’, TfL recommends that the applicant undertake a Pedestrian Environment Review System (PERS) audit of the site and surroundings, to highlight any areas for improvement. This could potentially be undertaken in conjunction with the developer of the adjoining site to the east, and the cost of any identified improvements to be pooled between the two developments. TfL would also expect the proposals to include the provision of at least a 2 metre wide footway along the eastern boundary with Waterloo Road, for all existing crossings to be fully accessible to pedestrians with disabilities by complying with current standards and for a new well lit pedestrian link along the western kerb line of Waterloo Road, underneath the Railway lines. TfL is supportive of the applicant part funding a new pedestrian crossing along Waterloo Road, as secured as part of the previous s106 agreement for the site.

69 A total of 493 cycle spaces are being proposed onsite. This complies with TfL’s cycle parking standards and is therefore considered acceptable. As the site is well connected to the London Cycle Network (LCN) and the LCN+, TfL would also recommend that appropriate signage

page 13 and a direct link into the site should be provided in accordance with London Plan policy 3C.22 ‘Improving conditions for cycling’, and draft revised London Plan policy 6.9 ‘Cycling’.

70 While some areas of the travel plan are very good, there are some key points which are either weak or missing, as further detailed in TfL’s letter, which could result in the travel plan not being effective in bringing adequate travel management for the site. The travel plan should also aim to link into any future travel plan for the western end of the site, in order to ensure consistency of approach. The travel plan and its contents, including its targets, management, measures and monitoring programme should be secured via the s106 agreement.

71 In accordance with the London Plan policy 3C.25 ‘Freight strategy’, and draft revised London Plan policy 6.14 ‘Freight’, a construction logistics plan (CLP), and a delivery and servicing plan (DSP), should be secured for the site by condition. Further information on what these plans should contain is included in TfL’s letter.

72 In conclusion, while initial assessment would suggest that the development is unlikely to impact on the Transport for London road network, further discussions are however required in relation to the impact of the development on the bus infrastructure and pedestrian environment, and to subsequently confirm that the proposals are in general compliance with the London Plan policies 3C.14, 3C.21, 3C.22 and 3C.25 and draft revised London Plan polices 6.7, 6.9, 6.10 and 6.14. Access

73 The design of the proposal to meet ‘Lifetime Homes’ standards throughout, and the designation of 10% of units to be wheelchair adaptable is supported.

74 The proposal includes substantial areas of parking below buildings, as well as open courtyard and on-street parking. The applicant’s access statement notes that 10% of parking spaces have been designed as disabled bays, but does not mention whether these bays will be reserved for wheelchair users or visitors. This should be confirmed. Bays will be located close to cores.

Sustainable development

75 The development will achieve Code for Sustainable Homes Level 3. The sustainability strategy for the site includes features such as water efficient appliances fitted within homes, a sustainable drainage strategy across the site, energy efficient external and communal lighting, and design to maximise the use of natural heat and light and minimise summertime overheating.

Be lean: baseline carbon dioxide emissions and energy efficiency

76 Baseline emissions have been calculated using a suitable modelling tool (SAP2005 and BREDEM 12) and all energy usages have been considered and estimated to be 701 Tonnes CO2 per year for a building regulations 2006 part L compliant development (includes unregulated uses). The proposed development will include energy efficiency measures to achieve the target Code Level 3 for each dwelling. This is welcomed, and in relation to the energy element of the Code, the applicant should have the aspiration to achieve CSH 4 for all the dwellings throughout the development.

77 Energy efficiency and conservation measures are applied beyond that normally incorporated into a 2006 Building Regulations compliant design. This incorporates measures such as improved air permeability, solar shading, thermal mass, U-values and best practice passive building design. It

page 14 also includes a low energy internal and external lighting. The proposed scheme will outperform current building regulations by 28%.

78 Overall energy efficiency measures proposed for the whole development exceed Building Regulations, resulting in a total reduction in CO2 (kg/yr) emissions of approximately 8% compared to the baseline building.

Be clean: district heating, combined heat and power, cooling

79 The applicant has used the mapping system developed by the LDA to investigate the potential for connection to an existing scheme. This however showed no that no existing, or planned large-scale networks, exist within the immediate vicinity of the proposed development. The applicant has indicated that it has explored options to utilise excess heat from Queen’s Hospital facility located to the south of the site. However correspondence with the Building Manager at the Hospital suggest that they have well-sized systems with no surplus capacity that could be utilised by the proposed scheme. No evidence of correspondence or outcome has been included in the energy strategy. The applicant should provide this as part of the application.

80 There is potential to link the Swan Housing site’s network with the proposed site network. The energy report contains no reference of to any the Swan Housing development, as recommended in advice report. The applicant should provide some background information in these enquiries. It is acknowledged that such co-operation would be subject to third party agreements.

81 In relation to this particular scheme, the energy proposals should as a minimum demonstrate that a common district-heating network linking all apartments in the development would be used to supply the space heating and hot water requirements of the site. For that purpose the applicant should submit plans of an indicative heat network showing which spaces would be connected.

82 A 50kWe combined heat and power (CHP) engine will be installed as part of an energy centre located in block 9 on the northern edge of the proposed development site. The energy centre has been sized to accommodate circa three gas-fired boilers, associated pumps, expansion/pressurisation vessels, thermal storage, the CHP engine and its acoustic enclosure.

83 The proposal of CHP is welcomed. In order to support the sizing of the CHP unit, the applicant should provide heat profiles to show that the size of the CHP has been optimised. It should be optimised taking both heating and domestic hot water load into consideration. It is envisaged that part of the heating would be supplied and the proposals would include a larger CHP unit.

84 The applicant has suggested that the scheme has been designed to be future ready, so that it may make best use of efficient distribution, with current and future technologies. The applicant has consented to providing the necessary infrastructure to link with other potential decentralised energy generation schemes coming forward in the vicinity, following completion of the development. Information on the ways in which the scheme would be able to connect to adjacent developments in the area should be supplied to the GLA, given that a joint approach has not yet been developed.

85 The applicant has suggested that the high proportion of dual aspect flats will enable the design of an effective natural ventilation design, which, alongside thermal mass, solar shading and solar control, will minimise overheating and will not require comfort cooling to be installed. The applicant should clarify where in the development there would be a need for active cooling and how this would be provided.

page 15 Be green: renewable energy

86 The development will include renewable energy technology in the form of a roof-mounted photovoltaic array. The development as a whole has 1,570m2 of roofspace, which could accommodate around 448 (1500 x 900 mm) panels with an estimate emission reduction of 5%. However the applicant has indicated that the cost and payback period would be prohibitive. Instead, a photovoltaic array designed for the development will be situated on Blocks 9, 10, 12 and 13 and will cover circa 350m2 (22% of available roof space) in plan and accommodate 120m2 of PV panels with an electrical offset of 9,000kWh/yr. This provides an annual emissions saving of 1% on baseline emissions. The applicant is requested to provide roof plans showing available space for photovoltaic panels as well as pointing out why the other areas are not available for this application. Biodiversity

87 The creation of habitat areas within the proposed park is supported. These will comprise insect and bird-friendly areas, meadow areas and floral diversity. Green roofs will also be provided on the two largest blocks within the development.

88 Retention of the existing boundary trees will ensure that species using these will not be displaced. The construction statement should provide measures to ensure minimal disturbance to resident species. Local planning authority’s position

89 It is understood that Havering Council officers support the principle of the application, including the level of affordable housing provision and general design. Investigations on housing viability are continuing. Legal considerations

90 Under the arrangements set out in Article 4 of the Town and Country Planning (Mayor of London) Order 2008 the Mayor is required to provide the local planning authority with a statement setting out whether he considers that the application complies with the London Plan, and his reasons for taking that view. Unless notified otherwise by the Mayor, the Council must consult the Mayor again under Article 5 of the Order if it subsequently resolves to make a draft decision on the application, in order that the Mayor may decide whether to allow the draft decision to proceed unchanged, or direct the Council under Article 6 of the Order to refuse the application, or issue a direction under Article 7 of the Order that he is to act as the local planning authority for the purpose of determining the application. There is no obligation at this present stage for the Mayor to indicate his intentions regarding a possible direction, and no such decision should be inferred from the Mayor’s statement and comments. Financial considerations

91 There are no financial considerations at this stage. Conclusion

92 London Plan policies on housing, affordable housing, density, urban design, transport, parking, access, sustainable development and biodiversity are relevant to this application. The application complies with some of these policies but not with others, for the following reasons:

page 16  Housing: Although there is a low level of family housing, the mix is appropriate for the sites location and responds to local need. Play space levels exceed minimum requirements  Affordable housing: The level of affordable housing to be provided is negligible, but the site-wide provision is in compliance with the site’s original outline approval. There may be future opportunities to review the level.  Density: The proposed level is appropriate to the site’s accessibility level, design and location.  Urban design: Generally acceptable, and the creation of the new park is supported. Some of the elevational detail may be overly repetitive across the development.  Parking: Provision is generally in compliance with the London Plan.  Transport: Subject to further information and minor improvements, the proposal will comply with the London Plan.  Access: 100% lifetime Homes provision and 10% wheelchair adapted or adaptable housing and parking to be provided, in compliance with London Plan policy.  Sustainable development: The proposals are acceptable in principle but require further studies regarding district heating,  Biodiversity: New habitat creation is supported.

93 Whilst the application is broadly acceptable in strategic planning terms, on balance, the application does not comply with the London Plan.

94 The following changes might, however, remedy the above-mentioned deficiencies, and could possibly lead to the application becoming compliant with the London Plan:

 Affordable housing: Potential for a review of affordable housing provision prior to the commencement of each build stage of the proposal.

 Urban design: Review of the elevational treatment used across the site to minimise repetitiveness across multiple buildings

 Access: Confirmation that the proposed disabled parking bays will be available to or reserved for disabled users.

 Sustainable development: The applicant should provide further information regarding district heating (in particular, the hospital and Swan Housing site) as listed in this report, as well as the ways in which connections would be made. The applicant should also provide heat profiles to show that the size of the CHP has been optimised. The need and locations required for active cooling should be provided.

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for further information, contact Planning Decisions Unit: Colin Wilson, Senior Manager - Planning Decisions 020 7983 4783 email [email protected] Justin Carr, Strategic Planning Manager (Development Decisions) 020 7983 4895 email [email protected] Glen Rollings, Case Officer 020 7983 4315 email [email protected]

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