planning report GLA/4412/02 2 July 2018 Leisure Centre in the Borough of Havering planning application no. P2048.17

Strategic planning application stage II referral Town & Country Planning Act 1990 (as amended); Authority Acts 1999 and 2007; Town & Country Planning () Order 2008.

The proposal Erection of a new leisure centre with phased demolition of the existing leisure centre and construction of new permanent one and overspill car park on its footprint.

The applicant The applicant is Sport and Leisure Management Ltd and the architect is GT3 Architects.

Key dates Stage 1 considered: 5 March 2018 Havering Council Planning Committee: 15 April 2018 Strategic issues

Open space: The site lies in an area of locally designated open space. To justify development in the park, the applicant has evidenced that there are no alternative sites in the surrounding area for developing the new leisure centre. Whilst the proposed development would result in the loss of 4,921 sq.m of local open space, the proposals would provide 5,151 sq.m of local open space, through ‘returning’ green space to the park as well as improving the quality of existing space. An additional view from Hornchurch Road has been provided which indicates that north-south views through the park will be improved as a result of the proposals. All outstanding issues have therefore been addressed and it is considered that the proposals accord with Policy 7.18 and draft London Plan Policy G4.

All outstanding issues relating to design, energy and transport have been addressed.

The Council’s decision In this instance Havering Council has resolved to grant planning permission subject to conditions and the completion of a S106 agreement.

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.

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Context

1 On 29 January 2018, 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.

2 The application is referable under Category 3F of the Schedule to the Order 2008:

● Category 3F: Development for a use, other than residential use, which includes the provision of more than 200 parking spaces in connection with that use.

3 On 5 March 2018, the Mayor considered planning report GLA/4412/01, and subsequently advised Havering Council that the application did not comply with the London Plan, but that the possible remedies set out in paragraph 52 of that report could address these deficiencies.

4 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 are as set out therein, unless otherwise stated in this report. On 15 April 2018, Havering Council (hereafter, the Council) resolved to grant planning permission in accordance with the officer recommendation, and on 19 June 2018, 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 or, direct Havering Council to refuse planning permission under Article 6. The Mayor has until 3 July 2018 to notify the Council of his decision and to issue any direction.

5 The Mayor’s decision on this case, and the reasons, will be made available on the GLA’s website www.london.gov.uk. Consultation stage issues summary

6 At the consultation stage Havering Council was advised that, whilst the application was broadly supported in strategic planning terms, it did not comply with the London Plan or draft London Plan for the following reasons:

● Principle of development: The principle of quantitative improvements to the leisure centre are supported, subject to the applicant adequately demonstrating that open space is protected and that any harm is outweighed by community benefits.

● Open space: The site lies in an area of locally designated open space. In accordance with London Plan Policy 7.18 and draft London Plan Policy G4, the applicant must provide details of the site search to justify that no alternative sites exist without an open space designation. Further details are also required to understand the impact of the proposals on the park’s openness, particularly whether any views will be improved.

● Design: Further work is required on: the western elevation; impact of the development on the park’s openness; active frontages; the car park; and inclusive access.

● Energy: Further details are required on: ‘be lean’ energy efficiency savings; the communal heat network and Combined Heat and Power network; and the proposed PV panels.

● Transport: The number of car parking spaces has not yet been adequately justified; further information is required on trips to the car park by different users. In addition, staff numbers must be confirmed before cycle parking can be assessed.

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7 GLA officers have engaged in discussion with the applicant, the Council and TfL to address the issues raised at consultation stage. In addition, various planning conditions and legal obligations have been secured as part of Havering Council’s draft S106 agreement and draft decision notice. Having regards to this, an assessment against the outstanding strategic issues raised at the consultation stage is set out below.

Principle of development

8 At consultation stage, GLA officers advised that the applicant had not yet suitably justified developing in an area of designated open space. Whilst it was considered that the proposals would result in qualitative and quantitative improvements to the leisure centre facilities, the impact on open space or its openness had not been adequately addressed. Furthermore, the proposals would result in the loss of some open space that is presently used by Abbey Bowmen, an archery club, and Tigers FC, a children’s football club and, at consultation stage, the applicant had not confirmed the relocation plans for these clubs.

Open space designation

9 The applicant has adequately addressed points raised at consultation stage regarding alternative sites, the loss of open space and the impact on openness, as discussed below and in accordance with paragraph 73 of the NPPF, London Plan Policy 7.18 and draft London Plan Policy G4.

Alternative sites

10 The applicant confirmed that the scheme is only viable if the Council uses land within its ownership and, therefore, does not need to purchase land. A site search was conducted, which was limited to considering Council-owned sites within a 1-kilometre radius of the existing site. The search identified that many existing Council-owned site were already in active usage, such as for schools, housing, allotments, libraries or theatres. Several Council-owned car parks were identified as being appropriately located, but were subsequently rejected due to size. The 1-kilometre search radius was selected due to the proximity of an existing leisure centre in , approximately 3-kilometres to the west, and to ensure that the new facility would remain accessible for nearby residents. The search concluded that there are no alternative, council-owned sites in a reasonable vicinity and, therefore, the applicant has adequately justified developing within .

Loss of open space

11 As raised in the consultation response, whilst the applicant has demonstrated that the 4,921 sq.m of open space that is to be lost will be offset by the provision of 5,151 sq.m of ‘bettered’ open space, in accordance with London Plan Policy 7.18 and draft London Plan Policy G4, the applicant must adequately re-locate the clubs that use the land which would be lost. Neither of these clubs use officially demarcated pitches, rather they use informal areas of grass. Since consultation stage, the applicant has confirmed that discussions are underway for the archery club propose to relocate to Noak Hills Sports Complex in the north of the borough. The children’s football club will revert to their own facilities at Bretons Farm. These relocation measures will be secured within the S106.

Impact on openness

12 Since consultation stage, the applicant has produced additional views to show that the proposals would improve north-to-south views through the Harrow Lodge Park. The proposed orientation of the leisure centre will line the new facility up with the existing structures in the park, and will simultaneously open-up views north-south through the park, which are currently blocked by the positioning of the existing leisure centre. In addition, a condition has been secured that requires the submission of a

page 3 landscaping scheme as well as the details of the surfacing materials; these ensure that the proposed car park will be suitably screened and that the submitted views are an accurate representation of the future situation.

13 As discussed at consultation stage, the proposals will significantly affect the openness of the park when viewed from Wallis Close, on the west of the park, due to the western elevation of the leisure centre blocking views through to the park. In recognition of this, the applicant has introduced recessed elements into the timber cladding which breaks the long elevation into three distinct elements and windows, from the site offices, have been introduced to provide some surveillance onto the land to the rear of the proposed centre. On balance, given the amendments made, the qualitative and quantitative improvements proposed to the leisure centre and the improvements to the view from Hornchurch Road, it is considered that the benefits of the proposals outweigh the impact on openness on this view.

Urban design

14 In accordance with comments raised at consultation stage, conditions have been secured, which require the applicant to submit details of all proposed surfacing materials, the boundary treatment as well as all materials to be used in the external construction, including the maintenance of the timber cladding.

15 At consultation stage, concern was raised with the western elevation of the proposed leisure centre as it was entirely inactive, which would result in no passive surveillance onto the strip of grass between the proposed centre and the houses on Wallis Close, where the building entirely obscured views into the park. In addition to no activation, the facade featured limited architectural articulation, resulting in limited visual interest from Wallis Close. As discussed above, the applicant has subsequently added windows into the ground floor office area, which look out onto the grass behind the centre, providing passive surveillance, and sought to add greater articulation along the western elevation.

16 GLA officers raised concern regarding the inactive frontage on the north east of the proposed building, caused by the positioning of the plant room, as this would limit surveillance onto the pedestrian access route into the site from Hornchurch Road. It was subsequently confirmed that, due to the size of the required plant, it is not possible to entirely internalise the plant room and that its relocation to the rear of the site would further reduce surveillance into the area to the rear of the proposed centre. On balance, therefore, it is considered acceptable.

17 All outstanding issues relating to the openness, size, planting and illumination of the car park have been addressed or adequately secured through condition. In addition, the applicant has confirmed that both the proposed facilities and all exterior public realm will be accessible for people in wheelchairs.

Energy

18 At consultation stage, whilst the proposed climate change mitigation measures were broadly supported, to ensure compliance further information was required on the ‘be lean’ energy efficiency savings, the communal heat network, the Combined Heat and Power network and the proposed PV panel. 19 All additional information requested at consultation stage has been provided which shows that the. application therefore complies with London Plan Policies 5.2, 5.10, 5.12 and 5.13 and draft London Plan policies SI2, SI3 and SI13. Transport 20 The applicant has provided some further justification on existing levels of use of the existing car park (where there are no standards in the draft London Plan), which is used by both visitors to the Leisure Centre and visitors to the park as a whole, and it is agreed that the Car Park Management Plan, which is secured by condition, will include monitoring of use of the car park as well as access to the overflow area of 60 spaces. In addition, the Travel Plan will include measures to reduce car use and promote walking and cycling to the site.

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21 The cycle parking provision has been increased from 40 to a minimum of 68 spaces, in line with draft London Plan standards and this provision is secured by condition.

22 The S106 secures a Travel Plan and contribution to local highway and cycling improvements. The following are secured by condition: electric vehicle charging points; Construction Method and Construction Logistics Plan; and a Service and Delivery Plan.

23 In summary, TfL is satisfied that the application scheme generally accords with the transport policies of the London Plan.

Response to consultation

Response from neighbours

24 The Council advertised the application with a local press notice and through notices placed around the site. In addition, 84 properties were notified of the proposals. The Council received 19 letters of representation, including one letter from a local councillor. The main points of concern relate to: ● Impact on residential amenity, including noise and pollution, daylight and sunlight, visual impact and privacy, both during construction and once operational; ● Traffic, including traffic flows, road safety, car parking, both during construction and once operational; ● Impact on openness; ● Impact on the area’s character; ● New leisure centre is not necessary; ● Not an appropriate site for a new leisure centre; ● Proposed facilities within the new centre; ● Concerns about clubs that use the existing site; ● Concerns regarding anti-social behaviour; ● Flood risk impact; ● Insufficient public consultation; ● Discrepancy between local press reporting on the proposals and the planning process; and ● Determination of the application during Purdah. Response from statutory bodies and other organisations

25 The following external bodies were consulted on the proposals: ● Thames Water - no response received; ● and Suffolk Water – no objection; ● – no objection, subject to Secured by Design principles being applied. An appropriate condition has been applied to the draft decision notice. ● – no objection; ● Sport – issued a ‘holding objection’, due to the lack of justification for the loss of formal playing pitches on open space; however, Council officers subsequently confirmed that the playing pitches are informal and, as such, Sport England have acknowledged that their

page 5 objection becomes non-statutory; however, they stated that the relocation of Abbey Bowmen archery club should be secured in the S106; and ● Historic England – no objection, subject to a condition on archaeology. An appropriate condition has been added to the draft decision notice. 26 It is noted that, having considered the above consultation responses, Havering Council has provided specific responses within its Committee Report or within the draft S106. Having had regard to these, GLA officers are satisfied that the statutory and non-statutory responses to the Council’s consultation process do not raise any material planning issues of strategic importance that have not already been considered at consultation stage, and/or in this report. Section 106 heads of terms

27 The following Heads of Terms were set out within Havering Council’s committee report or agreed subsequently by GLA and Havering officers:

● Development phasing; ● Provision of alternative venues for existing sports clubs using the park, if this is not resolved by engrossing; ● Travel Plan; ● £12,000 towards road infrastructure improvements; and ● £15,000 towards local cycle improvements study and works.

Financial considerations 28 Should the Mayor direct refusal, he would be the principal party at any subsequent appeal hearing or public inquiry. Government Planning Practice Guidance emphasises that parties usually pay their own expenses arising from an appeal. 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. Conclusion

29 The strategic issues raised at consultation stage regarding principle of development, open space, design, energy and transport have been satisfactorily addressed, and appropriate planning conditions and obligations have been secured. As such the application complies with the London Plan and draft London Plan, and there are no sound reasons for the Mayor to intervene in this case.

for further information, contact GLA Planning Unit: Juliemma McLoughlin, Chief Planner 0207 983 4271 email [email protected] Lyndon Fothergill, Principal Strategic Planner 020 7983 4512 email [email protected] Vanessa Harrison, Senior Strategic Planner (case officer)

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