Gosling Street Limited Planning Statement
Planning Statement
69A Albert Road, London, BR2 9PZ
Gosling Street Limited April 2021
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Contents
1. Introduction ...... 3
2. The Site………………………………………………………………………………………………….5
3. Proposed Development………………………………………………………………………………………6
4. Planning Policy Framework………………………………………………………………………………..….7
5. Planning Policy Assessment…………………………………………………………………………………..9
6. Planning Obligations………………………………………………………………………………………….16
7. Conclusions……………………………………………………………………………………………………..17
Prepared By: Ruth Beard Status: Final
For and on behalf of Innovate Planning Limited
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1. Introduction
1.0 This Planning Statement (the “Statement”) has been prepared by Innovate Planning Limited on behalf of Gosling Street Limited (the “Applicant”) in support of a planning application for residential development at 69A Albert Road, London, BR2 9PZ (the “Application Site”) submitted to LB Bromley (“the Council”).
1.1 This Statement sets out the planning case in support of this submission in the context of relevant planning policy.
1.2 This Statement will demonstrate that the proposed development complies with the overall objectives of national, regional and local policy guidance and in doing so, delivers a high quality, sustainable residential development which maximises the development potential of an accessible brownfield site.
Supporting Documents
1.3 This Statement should be read in conjunction with the drawings and documents included as part of the submission, particularly the Design and Access Statement (DAS) by TDO.
Pre-application Consultation
1.4 A significant amount of consultation with LB Bromley, local people and stakeholders has been undertaken on behalf of the applicant prior to the submission of this application.
1.5 In summary, two requests for pre application advice were submitted to Planning Officers at LB Bromley which provided detailed feedback on the acceptability of the proposals and the design and massing of the proposals has evolved as a result of this process, as set out in the DAS.
1.6 The pre application responses accepted the use of the existing employment site for residential use in principle. Some issues were raised in relation to the massing/detailed design of the proposals and this submission includes a number of revisions to the proposals which seek to address these points as set out in detail in the DAS and summarised in this document.
1.7 On 28th January 2021, an email summarising the proposals was sent to ward councillors. A site meeting was subsequently arranged on the site on 6th February 2021 with one of the Councillors
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to discuss the proposals in detail. As a result of these discussions some changes were made to the detailed design of the proposed windows.
1.8 In addition, a short leaflet setting out the proposals was sent to local residents/stakeholders on 5th March 2021 and a copy is enclosed within Appendix 1. An email account was set up to enable comments and queries to be provided.
1.9 4 residents had responded to the consultation leaflet at the date of this report. These included;
• Response dated 5/3/21 objecting to the design of the proposals, impact on traffic/congestion and local services;
• Response dated 6/3/21 - raising a number of concerns regarding massing/proximity and potential impacts including noise, traffic, sunlight and daylight;
• Response dated 7/3/21 – raising a number of queries regarding mitigation during construction, position of proposed windows, potential impact on services and need for mitigation regarding an underground river; and
• Response dated 19/03/21 – requesting additional details including proposed heights, distances to boundary and use of first floor green roofs. Raising issues in terms of impact on light and also impact on trees.
1.10 Responses to queries raised were provided and as a result, additional information regarding the massing of the proposals in relation to surrounding residential properties in the form of a sectional diagram and roof plan was provided. These diagrams have been included within the final DAS and a copy is enclosed within Appendix 2.
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2. The Site
2.0 The site is a 0.32 acres in size and is located to the rear of residential properties, with access provided off Albert Road, Bromley. The site falls within Flood Zone 1 and has a PTAL rating of 2 (poor).
2.1 There are currently various commercial buildings used as offices and for storage on the eastern part of the site, together with a covered vehicle storage area. The western part of the site is scrubland with some hardstanding. The surrounding area is predominately residential in nature.
2.2 We understand that the buildings have been owned and occupied by a company providing electrical services since the 1930s. The buildings on the site compromise offices, storage (Use Classes B1/B8) and vehicle parking together with various outbuildings. At the end of 2019 the owner retired, the site was purchased by our client and has been vacant since.
2.3 The existing historic employment buildings have reached the end of their useful life and clearly do not meet the standards required by modern businesses. As set out above, the existing use has ended and given the residential context of the site it is considered that a residential development would be the most appropriate long term use for the site.
Planning History
2.4 There are no online planning history records available for 69 or 69a Albert Road, however the first pre application response (15/5/20) advises that an application for a single storey extension for a toilet in was submitted in 1978.
2.5 There are no TPO’s or listed buildings on or adjacent to the site and it is not located within a Conservation Area.
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3. Proposed Development
3.0 Full details of the proposals are provided within the Design and Access Statement and planning application drawings and a summary is provided below.
3.1 The proposals involve the demolition of existing commercial buildings on the site and erection of six residential (Use Class C3), 3 bedroom dwellings on the site, with each property having private amenity space and also one allocated car parking space at ground floor level.
3.2 The proposed location and massing of the buildings reflects sunlight and daylight constraints and also the need to avoid overlooking to surrounding residential properties.
3.3 Vehicular access will be via the existing entrance off Albert Road, which the applicant has recently widened.
3.4 It is considered that the proposal responds to the significant opportunity to provide a high quality contextual residential development which maximises the development potential of an existing brownfield site while minimising the impacts on surrounding residential buildings and reflecting the massing and appearance of the existing context.
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4. Planning Policy Framework
4.0 The proposed development has been prepared in the context of relevant policy and guidance at the national, regional and local levels. This section of the Statement sets out the policy framework against which the proposals will be assessed.
Planning Policy Context
4.1 Section 38(6) of the Planning and Compulsory Purchase Act (2004) requires that decisions made under the Planning Acts are determined in accordance with the Development Plan unless other material considerations indicate otherwise.
4.2 The adopted Development Plan comprises the following;
• London Plan (1st February 2021)*
• Bromley Local Plan (2019)
* The Mayor recently received confirmation from the Secretary of State that he is content for the Publication London Plan to be published and as a result the Publication London Plan was adopted on 1st February 2021.
National Planning Policy and Guidance
4.3 The National Planning Policy Framework (NPPF), published on 19th February 2019, sets out Central Government planning policies for England and how these are expected to be applied. It is supported by National Planning Policy Guidance (NPPG), launched as an online resource on 6 March 2014, which seeks to provide further detail, clarification and guidance on national policy contained within the NPPF. The NPPG brings together and updates the previous raft of PPG documents into one online resource.
4.4 The NPPF sets out a presumption in favour of sustainable development (Para 14). This means that development which is sustainable should be approved without delay (Para 15).
4.5 The NPPF considers that good design is a key objective of delivering sustainable development and includes a requirement for local planning authorities to ensure that proposals optimise the potential of sites to accommodate development (Para 58).
4.6 The NPPF (para 59) sets out the Government’s objective of significantly boosting the supply of homes, stating that it is important that a sufficient amount and variety of land can come forward
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where it is needed, that the needs of groups with specific housing requirements are addressed and that land with permission is developed without unnecessary delay.
4.7 The NPPF (para 124) considers that the creation of high quality buildings and places is fundamental to what the planning and development process should achieve and that good design is a key aspect of sustainable development, creates better places in which to live and work and helps make development acceptable to communities.
4.8 In addition, the NPPF (para 122) states that planning policies and decisions should support development that makes efficient use of land, taking into account;
a) the identified need for different types of housing and other forms of development, and the availability of land suitable for accommodating it; b) local market conditions and viability; c) the availability and capacity of infrastructure and services – both existing and proposed – as well as their potential for further improvement and the scope to promote sustainable travel modes that limit future car use; d) the desirability of maintaining an area’s prevailing character and setting (including residential gardens), or of promoting regeneration and change; and e) the importance of securing well-designed, attractive and healthy places.
Development Plan
4.9 The site is subject to the following designations/relevant policies on the Local Plan Proposals Map;
• Policy 13 Renewal Areas Site
• Policy 14 Development Affecting Renewal Areas
• Policy 16 Bromley Common Renewal Area Site
• Policy 79 Biodiversity and Access to Nature
• Policy 109 Airport Public Safety (Biggin Hill Airport)
4.10 Other key policies include Local Plan Policy 83 which relates to the change of use of non- designated Class B use sites to non-employment uses and Local Plan Policy 3 relates to Backland and Garden Land Development.
4.11 An assessment of the proposals against these and other relevant policies is set out within the next section.
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5. Planning Policy Assessment
5.0 This section assesses the proposals against the Development Plan and NPPF.
Residential Use/Loss of Employment
5.1 The site is located within a predominately residential area and as set out above, the existing employment use (Use Class B1/B8) has ended and the buildings are dilapidated and reached the end of their useful life. Given the site context, residential development is proposed.
5.2 A Building Condition Report by Capital and Provincial is submitted as part of the application this concludes that;
5.3 ‘The buildings found on this site have reached the end of their life expectancy and have little or no value due to both their condition and the asbestos containing materials in which they are built. We do not believe that there is any benefit in undertaking any repairs to the building structures and would therefore, recommend that the buildings be taken down and carted away.’
5.4 A full Marketing Report for the site has been produced by The Acorn Group and is provided as part of the application. This document confirmed that despite a substantial marketing exercise, no offers were received for the purchase of the property on the basis of commercial use. The document concludes that;
5.5 ‘…Continued commercial use of any nature, whether across the entire site, or as part of a mixed-use scheme would appear inappropriate when we consider the feedback from the marketing, with special attention being paid to the feedback regarding the inappropriate location of the site when considering the surrounding residential properties…’.
5.6 London Plan Policy E7 states that mixed-use or residential development proposals on Non- Designated Industrial Sites should only be supported where there is no reasonable prospect of the site being used for the industrial and related purposes or it has been allocated in an adopted local Development Plan Document for residential or mixed-use development, or industrial, storage or distribution floorspace is provided as part of mixed-use intensification.
5.7 The site is within the Bromley Common Renewal Area (not the Crystal Palace, Penge and Anerley Renewal Area).
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5.8 Local Plan Policy 13 relates to Renewal Areas and states that the Council will seek to maximise opportunities for enhancement and improvement within the Renewal Areas. Proposals should provide demonstrable economic, social and environmental benefits and address identified issues and opportunities. For example, proposals will be expected to (inter alia) maximise opportunities to deliver high quality environments which complement and enhance existing development and ’assets', including built heritage and other environmental assets and create inclusive communities.
5.9 Local Plan Policy 16 relates specifically to the Bromley Common Renewal Area and states that the Council will maximise opportunities to create a successful transition zone from Bromley Town Centre to the suburban and semi-rural urban fringe and produce a positive gateway to Bromley Town Centre along the Hayes Lane / Homesdale Road / A21(Bromley Common) junction, supported by appropriate green infrastructure. Supporting paragraph 2.3.24 advises that the policy seeks to ensure that change is appropriately managed to ensure the opportunities for the area provide a successful transition to the town centre and a high quality residential environment whilst protecting and enhancing valued environments and ensuring that recreational opportunities are maximised to cater for the growing population within the Renewal Area.
5.10 The proposals must be assessed against the criteria set out in Local Plan Policy 83 as follows:
• Criteria A Demand for Existing Use- Marketing of the site was undertaken as part of the sale process and a report summarising this process and the demand for this type of use within the area is submitted as part of the application.
• Criteria B Opportunities for Re-Use/Development for Employment Use- the existing buildings are dilapidated and would need a very significant amount of investment to enable their re-use and as such this is not viable. Information to demonstrate this is included within the Marketing Report, Building Condition Report and DAS. In addition, given the scale of the site and the existing access the redevelopment of the site for employment purposes is not considered appropriate.
• Criteria C Mixed Use Scheme – given the scale of the site and limited access this is not considered feasible.
5.11 Overall therefore, given the relatively small size and constrained nature of the site, its location within a residential area and the poor condition of the existing buildings and lack of demand from commercial users, it is considered that the retention of the site for employment uses is not feasible or desirable.
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5.12 In contrast, the delivery of new homes is considered a priority within London and LB Bromley and as such the principle of residential use on this site is therefore considered acceptable by virtue of London Plan policies GG2 (Making the best use of land) and GG4 (Delivering the homes Londoners need) and Local Plan Policy 83.
5.13 As set out above, the loss of the existing employment use on the site and provision of residential use has already been accepted in principle by officers as part of the pre application advice provided in relation to the site.
Bulk and Massing
5.14 Achieving high quality design is an overarching planning policy objective of the NPPF and Development Plan and as demonstrated by the DAS, the proposals have been carefully designed with this in mind.
5.15 The NPPF (Para 124) states that the creation of high quality buildings and places is fundamental to what the planning and development process should achieve. Good design is a key aspect of sustainable development, creates better places in which to live and work and helps make development acceptable to communities.
5.16 London Plan Policy GG2 (Making the best use of land) states that to make the best use of land, those involved in planning and development must (inter alia) enable the development of brownfield land, utilising small sites including to ‘…proactively explore the potential to intensify the use of land to support additional homes and workspaces, promoting higher density development, particularly in locations that are well-connected to jobs, services, infrastructure and amenities by public transport, walking and cycling……applying a design–led approach to determine the optimum development capacity of sites…’.
5.17 London Plan Policy D3 states (inter alia) that;
5.18 ‘A All development must make the best use of land by following a design led approach that optimises the capacity of sites, including site allocations. Optimising site capacity means ensuring that development is of the most appropriate form and land use for the site. The design- led approach requires consideration of design options to determine the most appropriate form of development that responds to a site’s context and capacity for growth, and existing and planned supporting infrastructure capacity (as set out in Policy D2 Infrastructure requirements for sustainable densities), and that best delivers the requirements set out in Part D.’
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5.19 In other [not high density] areas, Policy D3 states that ‘…incremental densification should be actively encouraged by Boroughs to achieve a change in densities in the most appropriate way. This should be interpreted in the context of Policy H2.’
5.20 Part D of Policy D3 sets out detailed guidance for developments that they should;
‘1) enhance local context by delivering buildings and spaces that positively respond to local distinctiveness through their layout, orientation, scale, appearance and shape, with due regard to existing and emerging street hierarchy, building types, forms and proportions 2) encourage and facilitate active travel with convenient and inclusive pedestrian and cycling routes, crossing points, cycle parking, and legible entrances to buildings, that are aligned with peoples’ movement patterns and desire lines in the area 3) be street-based with clearly defined public and private environments 4) facilitate efficient servicing and maintenance of buildings and the public realm, as well as deliveries, that minimise negative impacts on the environment, public realm and vulnerable road users 5) achieve safe, secure and inclusive environments 6) provide active frontages and positive reciprocal relationships between what happens inside the buildings and outside in the public realm to generate liveliness and interest 7) deliver appropriate outlook, privacy and amenity 8) provide conveniently located green and open spaces for social interaction, play, relaxation and physical activity 9) help prevent or mitigate the impacts of noise and poor air quality 10) achieve indoor and outdoor environments that are comfortable and inviting for people to use 11) respond to the existing character of a place by identifying the special and valued features and characteristics that are unique, to the locality and respect, enhance and utilise the heritage assets and architectural features that contribute towards the local character 12) be of high quality, with architecture that pays attention to detail, and gives thorough consideration to the practicality of use, flexibility, safety and building lifespan through appropriate construction methods and the use of attractive, robust materials which weather and mature well 13) aim for high sustainability standards (with reference to the policies within London Plan Chapters 8 and 9) and take into account the principles of the circular economy 14) provide spaces and buildings that maximise opportunities for urban greening to create attractive resilient places that can also help the management of surface water.
5.21 Bromley Local Plan Policy 3 (Backland and Garden Land Development) is as follows;
5.22 ‘New residential development will only be considered acceptable on backland or garden land if all of the following criteria are met:
a - There is no unacceptable impact upon the character, appearance and context of an area in relation to the scale, design and density of the proposed development;
b - There is no unacceptable loss of landscaping, natural habitats, or play space or amenity space;
c - There is no unacceptable impact on the residential amenity of future or existing occupiers through loss of privacy, sunlight, daylight and disturbance from additional traffic;
d - A high standard of separation and landscaping is provided.’
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5.23 London Plan Policy H1 (Increasing housing supply) states that boroughs must prepare delivery focused Development Plans which amongst other things, encourage development on windfall sites and optimise the potential for housing delivery on all suitable and available brownfield sites, including small sites and housing intensification on other appropriate low-density sites in commercial, leisure and infrastructure uses.
5.24 London Plan Policy H2 states that;
…A Boroughs should pro-actively support well-designed new homes on small sites (below 0.25 hectares in size) through both planning decisions and plan-making in order to: 1) significantly increase the contribution of small sites to meeting London’s housing needs 2) diversify the sources, locations, type and mix of housing supply 3) support small and medium-sized housebuilders 4) support those wishing to bring forward custom, self-build and community-led housing 5) achieve the minimum targets for small sites set out in Table 4.2 as a component of the overall housing targets set out in Table 4.1….
5.25 In addition, Local Plan Policy 4 (Housing Design) requires that all new housing developments will need to achieve a high standard of design and layout whilst enhancing the quality of local places. Housing schemes will also need to respect local character, spatial standards, physical context and density. The policy also sets out a number of detailed requirements including that the site layout, buildings and space around buildings are designed to a high quality, recognising as well as complimenting the qualities of the surrounding areas. In addition, density must have regard to the London Plan density matrix whilst respecting local character.
5.26 Local Plan Policy 37 states that all development proposals will be expected to be of a high standard of design and layout, including in summary that they are imaginative and attractive to look at, of a good architectural quality and should complement the scale, proportion, form, layout and materials of adjacent buildings and areas, positively contribute to the existing street scene and/or landscape and respect important views, heritage assets, skylines, landmarks or landscape features and create attractive setting.
5.27 The massing of the proposals is the result of a design led process and has been specifically designed with these policies in mind. As such, the development reflects the general building height of the area and is located within the acceptable sunlight and daylight envelope for the site. As such, the massing of the proposals is a direct response to the immediate context and is entirely appropriate in this location.
5.28 The applicant is committed to producing a high quality residential development, in terms of the standard of architecture/appearance, space standards and materials. Timber framed windows are proposed which reflects the use of traditional timber sash windows of the adjacent terraces. Zinc will be used on the pitched roof element, this materiality picks up on the use of slate roofs and dormer windows in the local area.
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5.29 As such, the proposals have been developed through a rigorous design process with reference to other precedents within the borough and also best practice from other areas of London. In addition, the proposals would meet the London Plan Space Standards, as required by Local Plan Policy 4.
5.30 As set out within the DAS, a shared surface is proposed which will benefit from planting and new healthy trees to enhance the landscape and ecology of the site. Planting will also be used along the boundaries to provide screening as part of the landscape proposals. The proposed landscaping will therefore includes lawns, wild grasses, climbing plants and a semi-extensive biodiverse green roof system.
5.31 The scheme has been designed by TDO, a Southwark based practice with considerable experience of residential schemes at all scales. The appearance of the proposed development has been carefully designed to reflect the local context however also provide a contemporary development that is of high quality. As set out in the DAS, the development will incorporate a good quality palette of materials is proposed to reflect and complement the character of the area, including red brick, timber framed windows and Zinc.
5.32 In terms of density, Policy D3 in the London Plan states that all development must make the best use of land by following a design led approach that optimises the capacity of sites. Optimising site capacity means ensuring that development is of the most appropriate form and land use for the site. The design-led approach requires consideration of design options to determine the most appropriate form of development that responds to a site’s context and capacity for growth, and existing and planned supporting infrastructure capacity.
5.33 The site has a PTAL rating of 2 (poor) and is within a suburban setting. As set out in detail within the DAS, the proposed development has been design led in accordance with Policy D3 and this has resulted in a density of 44 dwellings per hectare. This is therefore considered to be an appropriate level of development that optimises the development potential of the site.
5.34 Overall therefore, the it is considered that the proposals are well designed and of a high quality design that is of an appropriate density and will result in an attractive development which carefully responds to and complements the local context, in accordance with the NPPF, London Plan Policy D3, Local Plan Policies 3 and 4 and other key planning policies.
Residential Amenity
5.35 Planning policies at all levels seek to ensure that proposed development does not have an unacceptable impact on residential amenity.
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5.36 Local Plan Policy 3 requires that there is no unacceptable impact on the residential amenity of future or existing occupiers through loss of privacy, sunlight, daylight and disturbance from additional traffic and also that a high standard of separation and landscaping is provided.
5.37 Local Plan Policy 37 states that (inter alia) that all development should allow for adequate daylight and sunlight to penetrate in and between buildings, respecting the amenity of occupiers of neighbouring buildings and those of future occupants.
5.38 As demonstrated within the enclosed information, the layout and massing of the proposals has been carefully developed to minimise impacts on the amenity of the surrounding residential properties and to be in line with the criteria set out in Local Plan Policy 3.
5.39 As set out in the DAS, the proposals have been oriented and designed to maximise distances to existing residential windows and also avoid direct overlooking. As part of the pre application process the amount of glazing within the southern elevation was reduced in order to minimise overlooking. In addition, obscure glazing is also proposed within first floor windows within the northern elevation of the development.
5.40 A full daylight, sunlight and overshadowing assessment of the proposals has been undertaken by the Chancery Group which includes an assessment of the impacts on surrounding residential properties. This document concludes that;
‘The results of our daylight and sunlight assessment for the surrounding residential properties demonstrate full compliance with the BRE Guidelines.
Regarding sunlight, all surrounding residential properties demonstrate full compliance with the BRE Guidelines.
The results of the overshadowing assessment demonstrate full compliance with the BRE Guidelines.
The results of the daylight quality within the proposed development demonstrate an excellent level of compliance with the BRE Guidelines (100% for the ADF and 100% for the NSL).
In terms of sunlight, all main living kitchen diners relevant for assessment will demonstrate full compliance with the BRE Guidelines.
Overall, it is considered that the proposed development meets the BRE Guidelines and is acceptable in daylight, sunlight and overshadowing terms.’
5.41 In accordance with relevant planning policy at all levels, the proposed development has therefore been carefully designed to take into account the context of the site and the potential impacts of the proposals on surrounding residential and other users.
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Affordable Housing
5.42 Bromley Local Plan Policy 2 seeks affordable housing on all housing developments capable of providing 11 residential units or more or where the residential floorspace is more than 1,000sqm.
5.43 The proposals would not meet these thresholds, therefore there is no affordable requirement in this case.
Housing Quality and Amenity
5.44 London Plan Policy D6 states that housing development should (inter alia) be of high quality of design, provide adequately-sized rooms, avoid single aspects dwellings and provide sufficient daylight and sunlight to surrounding dwellings. Detailed qualitative and quantitative standards are provided within accompanying tables including minimum housing sizes etc.
5.45 Policy 4 of the Bromley Local Plan states that all new housing developments will need to achieve a high standard of design and layout whilst enhancing the quality of local places. Housing schemes will also need to respect local character, spatial standards, physical context and density. As such, the Council expects the following to be demonstrated;
a - The site layout, buildings and space around buildings are designed to a high quality, recognising as well as complimenting the qualities of the surrounding areas; b - Minimum space standards for dwellings as set out in Policy 3.5 and Table 3.3 of the London Plan and the London Plan Housing Supplementary Planning Guidance (as updated); c - The provision of sufficient external, private amenity space that is accessible and practical; d - The provision of appropriate play space in accordance with the Mayor’s Play and Informal Recreation SPG; e - Off-street parking that is well integrated within the overall design of the development; f - Density that has regard to the London Plan density matrix whilst respecting local character, including heritage; g - Layout that is designed to give priority to pedestrians and cyclists over the movement and parking of vehicles; h - Safety and security measures are included in the design and layout of buildings and public areas; i - Ninety percent of new housing meets Building Regulation requirement M4 (2) ‘accessible and adaptable dwellings; and j - Ten percent of new housing meets Building Regulation requirement M4 (3) ‘wheelchair user dwellings’ i.e. is designed to be wheelchair accessible, or easily adaptable for residents who are wheelchair users.
5.46 As demonstrated by the DAS, the proposals have been designed in accordance with the above policies. The proposed development is of a high quality of design and has been developed in accordance with the minimum gross internal floorspace (GIA) requirements outlined in the
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London Plan. In addition, the proposed units all benefit from private amenity space in the form of a garden at least 10sq.m. in accordance with the London Plan Housing SPG.
5.47 In terms of accessibility, Local Plan Policy 4 requires that ninety percent of new housing meets Building Regulation requirement M4 (2) ‘accessible and adaptable dwellings and ten percent of new housing meets Building Regulation requirement M4 (3) ‘wheelchair user dwellings’ i.e. is designed to be wheelchair accessible, or easily adaptable for residents who are wheelchair users.
5.48 Each proposed dwelling will be compliant with the requirements of Building Control Approved Document M.4(2) to achieve an inclusive built environment that enables users to maximise their individual abilities and enjoy a safe and independent participation in accordance with Policies 26 and 33 of the Bromley Local Plan. Where feasible, the dwellings will demonstrate compliance to Part M4(3): Wheelchair user dwellings, and Part M4(2): Accessible and adaptable dwellings. Level access is provided between Albert Road and the entrance of each home.
Transport and Refuse
5.49 The Transport Statement describes how the site has a PTAL of 4 which is ‘poor’. There are 6 bus routes which are reasonably accessible and provide links to Orpington, Crystal Palace, Chislehurst, Lewisham, Farnborough, Biggin Hill and Catford. In addition, Bickley railway station lies approximately 1.5km away to the northeast.
5.50 Planning policies at all levels seek to reduce the use of cars and the proposals provide a satisfactory level of car and bicycle parking that accords with London Plan and Local Plan standards.
5.51 The Transport Statement advises that cars can satisfactorily access and egress the proposed car parking areas and that the traffic generated by the proposals will not intensify the use of the existing site access, which has been subject of a Road Safety Audit where no highway safety concerns were raised.
5.52 The document concludes that pedestrian access to the site is acceptable using the existing shared route into the site from Albert Road because of the low frequency of vehicular traffic and available width to accommodate both modes of transport.
5.53 A Refuse and Recycling Management Strategy will be negotiated and agreed with the Council’s Cleansing Department. As part of this, future residents will be made aware of the requirements of the Council’s refuse collection service and it is anticipated that these would be
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moved to a suitable collection point within 20m of the highway collection point at collection times.
5.54 It is therefore concluded that the proposed residential development is acceptable on highway and transportation grounds.
Ecology
5.55 The proposals have been designed to seek to protect and enhance biodiversity on site in line with policies 70, 78 and 79 of the Bromley Local Plan.
5.56 A Preliminary Ecological Appraisal (PEA) including a preliminary bat roost inspection and tree inspection has been undertaken by Watermans and submitted as part of the application.
5.57 This concludes that ecological features including designated sites, on-Site habitats, badgers, bats (foraging and commuting) birds, hedgehogs and reptiles have been scoped out of the assessment due to insufficient biodiversity conservation value or a lack of an identified pathway for potential effects to occur.
5.58 Low potential for roosting bats has been identified within two existing buildings on the site and as such it is recommended that further bat surveys are undertake during May-September.
5.59 A detailed landscaping strategy has been developed for the site in order to enhance green planting within the site to promote ecological diversity. The proposed development will promote the protection of all the existing trees from damage in line with Policy 73 of Bromley’s Local Plan during site demolition and the completion of the construction works.
5.60 In addition, other green design features have been incorporated into the proposals including grascrete parking areas, lawn areas, planting over bin stores and climbing plants.
5.61 An extensive green / living roof (94 m2 in total) will be incorporated on the flat portion of the roof of each home. This will provide the following ecological and sustainable benefits:
• Provision of habitat to promote species diversity;
• Reduction in urban heat island effect;
• Improvement in air quality;
• Minimisation of heat loss during winter months;
• Protection from solar gain during summer months; and
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• Provision of a sustainable urban drainage technique.
5.62 Proposed garden areas will be landscaped, with areas of planting and new trees provided. In addition, the design team is considering bird and bat boxes to provide nesting opportunities in this nest-limited urban environment. The shared surface space will also benefit from planting and new healthy trees to enhance the landscape and ecology of the site.
5.63 As such it is concluded that taking into account the mitigation measures set out above, the proposals will have an acceptable ecological impact when assessed against relevant Development Plan policies.
Sustainability and Energy
5.64 The proposals have been specifically designed to take a holistic approach to sustainable design and construction, in line with the need for sustainable development as set out in the Adopted and Publication London Plan, Sustainable, Design and Construction SPG, NPPF and Local Plan policies. These include Local plan Policy 37 which states that all developments should (inter alia) be of a sustainable design and construction; accessible to all, secure; include; suitable waste and refuse facilities.
5.65 London Plan Policy G5 states that major development proposals should contribute to the greening of London by including urban greening as a fundamental element of site and building design, and by incorporating measures such as high-quality landscaping (including trees), green roofs, green walls and nature-based sustainable drainage. As such, Boroughs should develop an Urban Greening Factor (UGF) to identify the appropriate amount of urban greening required in new developments. In the interim, the Mayor recommends a target score of 0.4 for developments that are predominately residential.
5.66 Full details of the sustainable credentials of the scheme, including key features intrinsic to achieving low carbon developments, are set out in the Sustainability Statement and Energy Statement prepared by Eight Associates as part of the application submission. This document states that in summary the scheme will adopt the following sustainable features:
• The whole development will reduce total carbon emissions by 67.0% and 83.8% over Building Regulations using SAP 2012 and draft SAP 10.0 carbon dioxide emission factors, respectively.
• Reduce energy consumption by targeting improved U-values and airtightness. Low energy lighting will be specified.
• Implement a site waste management plan and stringent resource efficiency benchmarks.
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• Follow best practice policies in terms of air, water and ground pollution and appoint a contractor who will register for the Considerate Constructors Scheme.
• Achieve a water consumption target of 105 litres/person/day through the implementation of low water-consuming fittings.
• Utilise sustainable transport, including the provision of six electric vehicle charging points, access to public transport and inclusion of cycle storage facilities.
• Minimise embodied carbon through efficient design, procurement of materials from a local source, or with a high-recycled content.
• Be of high build quality, surpassing the minimum Building Regulations.
Ensure all materials are responsibly sourced and of low environmental impact where feasible.
• Consider health and wellbeing through design and operational procedures, including daylight, optimum indoor air quality and thermal comfort.
• Protect and enhance the ecological value of the site by introducing native planting, 94m2 of green roof and potentially bird and bat boxes.
5.67 The Energy Statement describes how all dwellings have been modelled for the purposes of the energy assessment. High energy efficiency performance building services have been used for these units in order to achieve the required carbon emission targets.
5.68 The scheme complies with the 2013 Building Regulations Part L and the minimum energy efficiency targets in the following documents have been followed:
o New build (Part L2A) – The actual building CO2 emissions rate (BER) is no greater than the notional building CO2 target emissions rate.
o In addition, the CO2 emissions of the scheme have been calculated using the SAP 10.0 carbon emission factors, and the scheme can achieve:
o An on-site CO2 reduction of 83.8% beyond Building Regulations through energy efficiency measures and maximised of renewable technologies (Air Source Heat Pumps and PV panels)
o The development achieves 12.6% CO2 improvement through energy efficiency measures, ‘Be Lean’stage
o A further improvement of 71.2% CO2 has been achieved through renewable technologies ‘Be Green’ stage (Air Source Heat Pumps and PV panels)
o Overall, the scheme achieves an improvement of 83.8% through measures on-site
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5.69 The scheme therefore meets and exceeds the planning policy carbon reduction target and complies with London Plan Policy 5.2 and Publication London Plan 2019 Policy SI2 and the principles of Local plan Policy 37.
5.70 London Plan Policy G5 seeks a target Urban Greening Factor of 0.4 as part of major developments. Although the proposals are only a minor application, the design of the proposals has been specifically designed to meet this target. As such, the proposals have an UGF of 0.42 which has been achieved through landscaping and a number of design features including the inclusion of trees, the use of extensive green roof areas to homes and also bin stores and the provision of planting including the provision of climbing plants.
5.71 As such, the scheme accords with the key planning policies relating to energy use as set out within both the existing and emerging Development Plan.
Air Quality
5.72 The Publication Draft London Plan includes Policy SI1 ‘Improving air quality’ provides detailed policy in relation to air quality and developments including that development proposals should (inter alia) not:
a) lead to further deterioration of existing poor air quality
b) create any new areas that exceed air quality limits, or delay the date at which compliance will be achieved in areas that are currently in exceedance of legal limits
c) create unacceptable risk of high levels of exposure to poor air quality.
2. In order to meet the requirements in Part 1, as a minimum:
a) Development proposals must be at least air quality neutral
b) Development proposals should use design solutions to prevent or minimise increased exposure to existing air pollution and make provision to address local problems of air quality in preference to post-design or retro-fitted mitigation measures….’
5.73 Policy 120 of the Bromley Local Plan, 2019 refers to the impact of developments on the local air quality. It states that:
5.74 ‘…Developments which are likely to have an impact on air quality or which are locate in an area which will expose future occupiers to pollutant concentrations above air quality objective levels will be required to submit an Air Quality Assessment. Developments should aim to meet “air quality neutral” benchmarks in the GLA’s Air Quality Neutral report.
5.75 In the designated Air Quality Management Area:
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• Developments should incorporate Ultra Low NOx boilers
• Biomass boilers should be avoided unless emission standards can be met…’
5.76 An Air Quality Assessment of the development has been prepared by Watermans and submitted as part of the application.
5.77 In summary, this states that the main likely effects on local air quality during construction relate to the generation of dust and particulates. A range of measures to minimise or prevent dust and particulates would be implemented throughout the construction works, therefore, it is considered that residual effects would be not significant.
5.78 It is also anticipated that after management measures have been implemented, the effect of construction vehicles on air quality would be not significant in the context of existing local road traffic emissions.
5.79 It has been estimated that the Development would generate 38 vehicle trips daily and would therefore be below the Environmental Protection UK and Institute of Air Quality Management (EPUK/IAQM) guidance criteria. In addition, the residential units would be served by individual domestic boilers. The boilers would have a combined NOx emission rate less of than 5 mg/s and would be below the EPUK/IAQM guidance criteria.
5.80 Based on the low trip generation and proposed combustion plant, according to the EPUK/ IAQM guidance, the Development is not expected to give rise to air quality impacts. As such the likely effect of the operational Development on local air quality would be not significant and would be in accordance with relevant Development Plan policies.
Drainage Strategy
5.81 The NPPF states that developments should incorporate Sustainable Urban Drainage Systems (SuDS) unless there is clear evidence that this would be inappropriate. The systems used should:
• Take account of advice from the lead local flood authority;
• Have appropriate proposed minimum operational standards;
• Have maintenance arrangements in place to ensure an acceptable standard of operation for the lifetime of the development; and
• Where possible, provide multifunctional benefits.
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5.82 London Plan Policy 5.13 sets out the following drainage hierarchy;
• store rainwater for later use;
• use infiltration techniques, such as porous surfaces in non-clay areas;
• reduce the force of rainwater in ponds or open water features for gradual release;
• reduce the force of rainwater by storing in tanks or sealed water features for gradual release;
• discharge rainwater direct to a watercourse;
• discharge rainwater to a surface water sewer/drain; and
• discharge rainwater to the combined sewer
5.83 In addition, Bromley Local Plan Policy 116 indicates that all developments should seek to incorporate SuDS or demonstrate alternative sustainable approaches to the management of surface water as far as possible.
5.84 A Drainage Strategy for the proposed development has been prepared by Watermans to take into account the relevant policy and guidance and submitted as part of the application.
5.85 In summary, it is proposed that surface water runoff from the Site would be restricted to the 1 in 100 year greenfield rate of 1.0 l/s for all events up to and including the 1 in 100 year plus 40% climate change scenario. This restricted rate provides a betterment of 89% when compared to the existing runoff rate of 9.9 l/s.
5.86 It is proposed that an attenuation storage volume of 66.5m3 would be provided by a geocellular storage tank to restrict surface water runoff before discharging to the surrounding Thames Water surface water sewers. The modelling of the attenuation has been undertaken using the MicroDrainage Source Control Module for the 1 in 100 year event plus an allowance of 40% for climate change.
5.87 Appropriate treatment would be incorporated into the drainage system to ensure that the quality of water discharged is acceptable. This would be achieved through the incorporation of green roofs, and permeable surfaces in the form of grasscrete. If required, a biomat filtration system, downstream defender or other hard engineered solution could also be incorporated to ensure discharge is appropriately treated. The final strategy will be confirmed at the detailed design stage.
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5.88 The on-site drainage network and SuDS would be privately managed and maintained for the lifetime of the development, ensuring that they remain fit for purpose and function appropriately. The management company/operator would be appointed post-planning.
5.89 The existing and proposed foul flows from the Site have been calculated to be 0.03 l/s and 0.05 l/s respectively. A Pre-Planning Enquiry has been submitted to Thames Water to confirm that the existing public sewer network has the capacity to accommodate both the proposed foul and surface water flows, a response is currently awaited.
5.90 The report confirms that surface water runoff from the site will be appropriately managed through the use of Sustainable Drainage Systems thereby ensuring that flood risk is not increased elsewhere. It is considered that the proposals will satisfy the requirements of the National Planning Policy Framework and the Development Plan.
Noise
5.91 An Acoustic Assessment has been undertaken by Watermans and submitted as part of the planning application.
5.92 The document advises that the development would not generate significant levels of operational noise given the absence of any fixed mechanical plant and the small number of vehicle trips (38 daily trips). As such, operational noise impacts associated with the development are not considered.
5.93 Due to Covid-19 restrictions it is likely that any noise surveys completed over the current period would not be representative of the future with Development acoustic environment of the area. In light of this baseline noise surveys have not been completed at this time but rather the baseline has been set with reference to Watermans experience of sites similar to the proposed and publicly available noise modelling information.
5.94 Given that the development is screened on all sides by existing sensitive receptors, it is expected that noise levels across the site would fall below 50dB LAeq,16 hour during the daytime and 40dB LAeq,8 hour during the night-time. Such noise levels equate to a negligible risk and it is considered that on noise grounds the site is suitable for the proposed residential use.
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6. Planning Obligations
6.0 In respect of the negotiation of planning obligations associated with development, Regulation 122 (2) of the Community Infrastructure Levy Regulations states that: ‘A planning obligation may only constitute a reason for granting planning permission for the development if the obligation is –
a) Necessary to make the development acceptable in planning terms;
b) Directly related to the development; and
c) Fairly and reasonably related in scale and kind to the development’.
6.1 Paragraph 204 of the NPPF states that planning obligations should only be sought where they meet all of the tests outlined in Regulation 122 of the Community Infrastructure Regulations, as set out above.
6.2 In this case the scheme will be CIL liable, however no other planning obligations are anticipated that would require a s106 agreement.
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7. Conclusions
7.0 This Statement has demonstrated that the proposed development complies with the objectives of national and local policy guidance, and in so doing, delivers a high quality, sustainable and attractive residential development that will provide much needed housing that is appropriate to the context of the site, in accordance with planning policies at all levels.
7.1 It is therefore considered that the overall planning merits of the proposal as set out in this Statement demonstrate that the Council should approve the planning application as submitted.
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APPENDIX 1
CONSULTATION LEAFLET
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APPENDIX 2
DIAGRAMS RESPONDING TO CONSULTATION PROCESS