PLACE DEPARTMENT

Bernard Weatherill House 8 Mint Walk Croydon CR0 1EA

Tel : 020 8726 6000 Email: [email protected] Website: www.croydon.gov.uk Our ref: 17/02514/PRE Date: 26 July 2017

[Sent via email]

Dear Simon,

TOWN AND COUNTRY PLANNING ACT 1990 Ref: 17/03145/PRE Site: 56-58 Factory Lane, Croydon Proposal: Comprehensive redevelopment of the site to provide 4,000m2 B1/B8 employment space, up to 170 new homes with associated car parking and landscaping.

I write in response to your pre-application enquiry, submitted drawings and our meeting at Bernard Weatherill House on the 21st July 2017.

Background

Section 38 (6) the Planning and Compulsory Purchase Act 2004 states that, for the purposes of any area in Greater London the development plan is the spatial development strategy and the development plan documents which have been adopted or approved in relation to that area. It further elaborates that “If regard is to be had to the development plan for the purpose of any determination to be made under the Planning Acts the determination must be made in accordance with the plan unless material considerations indicate otherwise.”

The development plan for the London Borough of Croydon comprises the Croydon Replacement Unitary Development Plan (The Croydon Plan 2006) Saved Policies 2013, the Croydon Local Plan: Strategic Policies (CLP 1) (2013), the London Plan (consolidated with alterations since 2011) and where appropriate the Croydon Local Plan: Detailed Policies and Proposals (CLP2) and Croydon Local Plan: Strategic Policies Partial Review (CLP 1.1). Specific detail on the above documents is provided below.

The Croydon Local Plan: Strategic Policies (CLP1) The Croydon Local Plan: Strategic Policies (formerly the Core Strategy), was adopted on 22 April 2013. It seeks to provide the basis for the development of Croydon up to 2031, with particular reference to new homes and jobs together with the overall environment and is the principal local planning document. This document is currently subject to partial review.

The Croydon Local Plan: Detailed Policies and Proposals (CLP2) CLP2 proposes detailed policies for the determination of planning applications in London Borough of Croydon. Following two rounds in public consultation, the draft Croydon Local Plan: Detailed Policies and Proposals (CLP2) (Proposed Submission) and the Partial Review of CLP1 (CLP1.1) (Proposed Submission) were submitted to the Secretary of State on 3 February 2017.

Whilst the weight afforded to these draft documents increases as the Plan moves through the adoption process, the draft policies in CLP2 and CLP1.1 (Proposed Submission) have become material considerations due to their submission for an Examination in Public by PINS, held in May 2017. The draft policies are considered below where relevant. Both documents are available on the Council’s website, at https://www.croydon.gov.uk/planningandregeneration/framework/localplan/clpproposals and https://www.croydon.gov.uk/planningandregeneration/framework/localplan/clpreview.

London Plan The London Plan is the Spatial Development Strategy for Greater London. The latest version was published in July 2011 and has now been consolidated with subsequent amendments (Revised Early Minor Alterations to the London Plan 2013 and Further Alterations to the London Plan 2015). In March 2016, Minor Alterations to the London Plan (MALP) were also published. The alterations cover housing and car parking standards. The London Plan is available at http://www.london.gov.uk/priorities/planning/london-plan.

The following London Plan Supplementary Planning Guidance Notes are also relevant:  Accessible London  Housing  Affordable Housing (Draft)  Sustainable Design and Construction  Planning for Equality and Diversity in London  Land for Industry and Transport

They are all available online at: http://www.london.gov.uk/thelondonplan/spg-bpg.jsp.

Other documents With respect to the National Planning Policy Framework (NPPF), Central Government Guidance and other relevant documents, it is expected that any applicant should be familiar with such matters.

Planning History

The application has been the subject of previous planning applications, however, many relate to the existing industrial use of the site or the installation of telecommunication equipment therefore have little relevance to this proposal.

Site and Surroundings

The application site sits at the junction between existing industrial and residential neighbourhoods, west of the Croydon Central Opportunity Area. It is currently used for warehousing/ distribution and offices. The site is not situated within a designated conservation area but is identified as a Tier 1 employment site in the Croydon Local Plan: Strategic Policies. It is also situated within an Archaeological Priority Zone, Flood Zone 2 and in a Critical Surface Water Flood Risk Zone.

Proposal

The proposals comprise the redevelopment of the site including demolition of existing building and redevelopment to provide 4,000m2 B1/B8 employment space. Up to 170 new homes and associated parking.

Consideration

Principle

The Council in the Croydon Local Plan: Strategic Policies (CLP1) sets out in Policy SP3 a ‘4-tier’ approach to the retention and redevelopment of land and premises relating to industrial/employment activity. The site is designated as a Tier 1 employment site where the Council’s approach is a strong protection for industrial and warehousing activities with no loss of Class B floor space permitted. As a result the permitted uses on Tier 1 sites are Class B1b, B1c, B2 and B8 uses and employment generating sui-generis uses, no other uses are permitted1.

However, paragraph 4.33 of the Croydon Local Plan: Strategic Policies – Partial Review (CLP1.1) does state that the fringes of “some Tier 1 locations in the context of Policy SP 3.2 have the potential for transition through development that enables the locations to relate better to their surrounding uses and character. This transition could come in the form of both intensification of development or the introduction of a new mix of land uses”. Given the site’s location within the defined Tier 1 site on Factory Lane and proximity to the nearby residential development it is considered the approach outlined by paragraph 4.33 might be applied to this site.

For the Council to consider this approach to be acceptable, further work is necessary by the applicant to demonstrate that the re-provision of the existing industrial accommodation is usable, high quality and meets the needs of potential future occupiers2 and that residential accommodation can be provided on the site without impacting upon the effectiveness of the site (and nearby industrial sites) to provide industrial type activities. In particular, any B8 space would need to have full access to articulated HGVs including loading bays that allow a forklift to access the rear of the HGV without leaving the cover of the building. The space inside the building should have minimal interruption from cores leading to residential units. Any B1c space will need to be of sufficient height and individual units should be accessible to 7.5t vehicles, with the site as a whole being accessible to HGVs.

This view is also based on the Croydon Local Plan: Strategic Policies – Partial Review (CLP1.1) being adopted without modifications to paragraph 4.33. As the plan is currently in draft form only limited weight can be given to the specific policies, the Council expects to receive the Inspector’s response on main modifications to the Plan shortly and this could allow for the level of weight to be increased.

The comments of the Greater London Authority (GLA) will be important in considering the acceptability in principle of the proposal. The site is defined as a Strategic Industrial Location (SIL) in the London Plan ensuring strong protection for industrial activity on the site. The London Plan makes clear that “Development proposals within or adjacent to SILs should not compromise the integrity or effectiveness

1 Croydon Local Plan: Strategic Policies Partial Review (CLP1:1) extends the permitted uses to include Gypsy and Traveller pitches (for Gypsies and Travellers with a qualified connection to Croydon). 2 We discussed potential future occupiers in B1C and B8 use classes as being acceptable employment uses for the site. of these locations in accommodating industrial type activities”. It is therefore recommended that the GLA are consulted at pre-application stage as the proposal progresses.

Transportation Considerations

The site is located in an area with a PTAL of 2, which is considered poor. I have provided as an annex to this letter the full response of the Council’s Strategic Transport Officer but in summary the main points raised are:

A total of 111 parking spaces are proposed for the residential units, which includes 16 disabled spaces. In addition there are 4 car club spaces. A total of 15 car parking spaces are proposed for the B1/B8 use, which includes 2 disabled spaces. The car club spaces should be available for the use of the general public as well as the residents of the development. Disabled parking spaces should be conveniently located close to the Wheelchair Accessible units and pedestrian access points.

Given the poor accessibility of the site these levels of parking provision are considered acceptable. However, given the provision of the car club spaces the Strategic Transport Team would not object to there being some reduction in the level of residential car parking provided3. Electric Vehicle charging points should be provided in accordance with London Plan standards and 50% of the disabled and car club bays should have EVCP’s.

For the B1/B8 element of the proposed development a new vehicle crossover is proposed onto Factory Lane for vehicles entering the site and a one-way access road created providing parking and loading facilities for the units. Vehicles would exit via the existing access onto Factory Lane. This existing access is on a sharp bend and there are concerns in regard to vehicle sight lines to the east. These should be a minimum of 2.4 x 43m and will require the landscaped area to the front of the site to be designed to ensure that there are no obstructions over 0.6m in height within the visibility zone.

Vehicle swept path analysis is required for the junctions and movement within the site. Particularly, important is providing the analysis to demonstrate that the industrial accommodation can be provided with suitable access by HGV and loading bays to accommodate the likely needs of future occupiers.

A full application will need to be supported by a Transport Assessment, Travel Plan, Waste Management Plan, Delivery and Servicing Plan, and Demolition/Construction Logistics Plan. With the exception of the Transport Assessment the remainder of the documents could be secured by condition.

Design and Townscape

The London Plan Policy 7.4 Local Character states that development should provide a high quality design response that: a) Has regard to the pattern and grain of the existing spaces and streets in orientation, scale, proportion and mass.

3 Emerging Policy DM31 of CLP2 says that if there is reduced car parking below the maximum allowed then there should be increased car club provision above base minimum (which is 5% of spaces) at a rate of 1 car club space for every 20 ordinary spaces not provided. b) Contributes to a positive relationship between the urban structure and natural landscape features, including the underlying landform and topography of an area c) Is human in scale, ensuring buildings create a positive relationship with street level activity and people feel comfortable with their surroundings d) Allows existing buildings and structures that make a positive contribution to the character of a place to influence the future character of the area e) Is informed by the surrounding historic environment.

The London Plan Policy 7.6 Architecture states that development must not cause unacceptable harm to the amenity of surrounding land and buildings.

Saved Policy UD2 of the Croydon Plan seeks a high standard of design and layout and that all development respects the visual character of the area in which it is located in terms of scale and proportions. Saved Policy UD3 further reinforces the need for good design and the fact that new developments have to respect the height and proportions of surrounding buildings. Policy SP4.1 of the Croydon Local Plan: Strategic Policies (2013) states that development should be of a high quality which respects and enhances Croydon’s varied local character and contributes positively to public realm, landscape and townscape to create sustainable communities.

The design of the scheme is at an initial stage and further iterations are expected as the scheme progresses through the pre-application process. The following comments are therefore intended to inform this process;

 The approach taken to provide the terraced dwellings around the outside of the site is successful in providing a transition from the industrial to residential character of the area. The separation and building heights of this part of the proposal also work well in relation to the neighbouring residential;

 The relationship between the different elements on site is a concern to us, particularly around the general environment for the under croft car parking, private and communal amenity space and entrances to the residential blocks.

 The scheme should also pay better respect to the existing residential areas nearby and not appear as a ‘private island’ adjacent to the existing.

 The sloping roof approach of the residential blocks is not supported, it is considered breaking up the massing of the blocks and a reduction in height would improve the overall design (although the approach of building heights stepping up north to south across the site is supported). The height of the nearby Grafton Quarter provides a useful reference to building heights given the similar character of the sites being situated in the industrial/residential fringe;

 Reviewing the materiality of the proposal, we do not consider cladding to be acceptable in this location given the industrial aspect to the south of the site. Brick is considered to pay better respect to the mixed character of the area.

 The internal and external layout of the industrial unit(s) needs further work to demonstrate that they provide high quality accommodation for future occupiers;

 We would like to see further analysis of views into and from the site as the design evolves, particularly around improvements to the corners of the residential terraces as it is considered these are prominent within the local area. A character area appraisal would help to pick up key elements of the design of the surroundings that could be represented within the proposal.

It is considered this scheme should be taken to Croydon’s Place Review Panel for a design review to ensure that the highest quality development for the site is realised.

Amenity of future occupiers

The following concerns are provided for consideration in the next iteration of the scheme:

 The separation distances between the residential blocks and terraced dwellings– in relation to overlooking, overshadowing and outlook;

 The quality of the environment for the private amenity space overhanging the undercroft car parking;

 The general quality of the environment and interaction between uses for the reasons expressed above.

 There appears to be a number of single aspect units based on the indicative floor plan;

 Noise & Ventilation – the residential units must be able to accommodate the industrial character of the area and the potential for B2 type activities on neighbouring sites – this will mean that for the current design the southern elevation of the second block would need winter gardens rather than balconies.

Amenity of neighboring occupiers

Saved UDP Policy UD8 seeks to protect residential amenity when considering proposals for new development. It considers the form and layout of existing and adjacent buildings; privacy and amenity of adjoining occupiers; the provision of amenity space for residents; and maintenance of sunlight and daylight for adjacent occupiers.

London Plan Policy 7.1 states that proposed developments should respect the local context and communities. Saved UDP Policy UD8 states that regard should be had to protecting residential amenities. Development should not result in harm to the residential amenity of neighbouring properties by way of visual intrusion, loss of light, outlook or privacy. Any proposals need to ensure that they do not harm the amenity of neighbouring occupiers as a result of loss of light, outlook or overlooking, or the perception of being overlooked. Whilst it is considered the proposed use of the site would be represent an intensification, it would help to screen the existing residential area from the industrial activities. It is considered that the proposal is unlikely to impact detrimentally upon residential neighbouring amenity. For the reasons given above, the proposal must also consider its impact upon the existing commercial neighbours.

Environment and sustainability

At the heart of the National Planning Policy Framework is a presumption in favour of sustainable development. It states: ‘Planning plays a key role in helping shape places to secure radical reductions in greenhouse gas emissions, minimising vulnerability and providing resilience to the impacts of climate change, and supporting the delivery of renewable and low carbon energy and associated infrastructure’. In line with Policy 5.2 of the London Plan (Further Alterations to the London Plan 2015) Minimising Carbon Dioxide Emissions, the development proposals should make the fullest contribution to minimising carbon dioxide emissions. An energy statement will need to be submitted to demonstrate the development achieves the London Plan requirements in relation to carbon reduction.

We would expect the residential development to be Zero Carbon and the industrial accommodation to achieve BREEAM excellent. Therefore alongside a GLA compliant energy statement, a BREEAM pre- assessment is necessary to demonstrate this.

Flood Risk and Surface Water Drainage

The site is located within flood zone 2 and is identified as being an area at critical risk of surface water flooding resulting from heavy rainfall and surface water runoff4. Therefore, any planning application should be supported by a Flood Risk Assessment which sets out the risk of flooding from all sources and how this will be mitigated and which is proportionate to the scale of the proposal. Details on the content of an FRA can be found here: https://www.gov.uk/guidance/flood-risk-and-coastal-change#site-specific- flood-risk-assessment-all

The Flood Risk Assessment should include a Sequential Test to assess whether development can be directed to areas with the least flood risk. Details on when this is needed and what it should cover can be found here: https://www.gov.uk/guidance/flood-risk-assessment-local-planning-authorities

I have attached a detailed response from the Local Lead Flood Authority on their expectations for the information submitted to support any proposal on this site.

Contributions

Affordable Housing

The Council will negotiate to achieve up to 50% affordable housing with a 60:40 ratio between affordable rented homes and intermediate homes. A provision of less than 50% will have to be justified by a financial appraisal which will be assessed by an independent consultant on the LPA’s behalf at the applicants cost. In the event that justification is provided for a provision of less than 30%, the Council will include a review mechanism in the S106 agreement. Any provision less than 15% will not be acceptable and an application would be refused.

It is crucial that the provision of affordable housing is considered early in the development of the scheme.

Skills, Training and Employment

Croydon Council is committed to ensuring that all Croydon residents are supported to access the range of positive social, economic and environmental benefits derived from inward investment in the Borough. Therefore, the applicant will be expected to produce an Employment and Skills Plan for the Construction Phase and/or End-use Phase as appropriate, outlining the approach they will take to delivering employment, training and apprenticeship outcomes and engagement with schools and education

4 An interactive map of these areas is available online here: https://flood-warning-information.service.gov.uk/long-term- flood-risk/map. providers for the development. Alongside this a financial contribution will be sought, details can be found online.

Carbon Offsetting

The Croydon Local Plan requires residential and non-residential development to achieve carbon targets in line with those set out in the London Plan. The London Plan (Policy 5.2) states that where it is clearly demonstrated that the specific targets cannot be fully achieved on-site, any shortfall may be provided off- site or through cash in lieu contribution to the relevant borough to be ring fenced to secure delivery of carbon dioxide savings elsewhere in the Borough.

The Council has adopted the £46/tonne CO2 price (calculated over a 30 year period), to calculate any cash in lieu contribution where specific targets cannot be fully achieved on-site. The payment will be calculated based on the number of tonnes CO2 by which the proposed development will miss the required target reduction. All such contributions will be ring-fenced within a “Community Energy Fund” which will be used to deliver CO2 reduction projects across the local community in the Borough at the Council’s discretion.

Air Quality

Croydon has declared the whole of the borough as an Air Quality Management Area for nitrogen dioxide. The majority of emissions of nitrogen dioxide originate from road vehicles with goods vehicles, buses and taxis accounting for more than half of this. In line with Guidance from DEFRA 'Low Emissions Strategies - using the planning system to reduce transport emissions', Croydon are adopting the following formula: All residential schemes of 10 dwellings and above, and mixed use and commercial schemes of 500m2 and above should contribute £100 per dwelling and £100 per 500m2 unit.

Community Infrastructure Levy (CIL)

In accordance with London Plan Policy 8.3, the Mayor of London has introduced a London wide Community Infrastructure Levy (CIL). This will be paid on the commencement of new development in Greater London in relation to planning applications determined. The charge for Croydon is currently £25.94/m2 of additional floor space.

Planning obligations may be required for any site specific works to make the development acceptable in planning terms.

Archaeology

As the site is within an Archaeological Priority Zone, the application should provide evidence on the applicants approach to preserving any features of heritage interest.

Contamination

Given the former use of the site, a phase 1 land contamination assessment should be submitted as part of any application. In addition, details on how the development responds to the services on the site both under and over ground should be submitted to expedite consultation with the statutory consultees for these matters.

Conclusion & Next Steps

Further evidence is required to demonstrate the acceptability of the scheme in principle, it is suggested that this evidence should be provided prior to a second pre-application meeting. The comments expressed on the other relevant material considerations should also be taken into account in a revised scheme.

Following this second meeting, it may be appropriate for you to consider entering into a Planning Performance Agreement (PPA) with the Council to cover the cost associated with meetings, Place Review Panel, a Planning Committee presentation at pre-application and dedicated officer time. I would also recommend that the GLA are consulted separately following the next meeting.

I trust this gives you sufficient information to consider further. You will nevertheless appreciate that the above comments are an informal officer opinion only and made without prejudice to any final decision that the Council may wish to take in respect of any formal planning application that may be submitted.

Yours sincerely,

Matthew Carney Deputy Team Leader