planning report PDU/2841/01 13 March 2012 Bexleyheath Civic Offices in the Borough of planning application no. 11/01998/FULM

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

The proposal Demolition of all existing buildings including the car park area. Re-development of site to provide a mixed-use development comprising a large retail store (Use Class A1), three retail/restaurant/café units (Use Classes A1 and/or A3), a community use unit (Use Class D1) together with car and cycle parking, landscaping, public realm and highway works served by amended vehicular access off Albion Road and new vehicular access off Broadway.

The applicant The applicant is Tesco Stores Ltd and the architect is Collado Collins Architect.

Strategic issues The principle of retail-led mixed use development on this edge of town centre site is acceptable.

There are some matters relating to access and urban design which require further detailed consideration. There are also matters relating to the energy strategy which require resolution and a number of transport matters which need to be addressed.

Recommendation

That Bexley Council be advised that the application does not comply with the , for the reasons set out in paragraph 64 of this report; but that the possible remedies set out in paragraph 65 of this report could address these deficiencies.

Context

1 On 3 February 2012 the Mayor of London received documents from Bexley Council notifying him of a planning application of potential strategic importance to develop the above site for the above uses. Under the provisions of The Town & Country Planning (Mayor of London) Order 2008 the Mayor has until 15 March 2012 to provide the Council with a statement setting out whether he considers that the application complies with the London Plan, and his reasons for taking that view. The Mayor may also provide other comments. This report sets out information for the Mayor’s use in deciding what decision to make.

page 1 2 The application is referable under Categories 1B and 3F of the Schedule to the Order 2008:

 1B: Development (other than development which only comprises the provision of houses, flats, or houses and flats) which comprises or includes the erection of a building or buildings— (c) outside and with a total floorspace of more than 15,000 square metres.

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

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

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

5 The application site is located on the eastern edge of Bexleyheath town centre. It is 1.5 hectares and is at the western end of an island site which is bound by Broadway to the north, Gravel Hill to the east, Albion Road to the south and Highland Road to the west. The site is currently occupied by Bexley Council’s Civic Offices which comprise pre-fabricated buildings, constructed in the 1970’s. Bexley Council notes that these buildings have exceeded their life expectancy and are increasingly expensive to maintain. Behind the Council offices and on the frontage to Albion Road is a multi-storey car park accessed from Albion Road. This building is also of utilitarian appearance, although due to its height is not prominent within the immediate local environment.

6 The site slopes down from north to south. There is a drop of approximately two metres between Broadway on the northern boundary of the site and Albion Road on the southern boundary of the site.

7 The local development context is one of mixed character, with commercial buildings towards the town centre and residential development in the surrounding area to the north west and south of the sites. 16 bus routes operate within 400 metres of the site, with many terminating at Bexleyheath town centre. rail station is located some 1.2 kilometres to the northeast, although the site can also be accessed from Bexleyheath and Bexley stations by bus. The closest section of the Road Network (TLRN) is the A2 which is 1 kilometre to the south and accessed via the Black Prince junction. The A223 Bourne Road forms part of the London Strategic Road Network (SRN). The site has a high public transport accessibility level (PTAL) of 5 (in a range of 1 to 6 where 6 is excellent).

Details of the proposal

8 The proposal is for a mixed-use development comprising the following elements:

 A Tesco store: gross internal area of 10,000 sq.m. excluding atrium and a net internal retail sales area of 7,200sq.m (3,700 sq.m. of convenience floorspace and 3,500 sq.m of comparison floorspace). Within the store, a cafe is also proposed. This will be located on the corner of Highlands Road and Broadway, within the atrium feature on this corner of the site. Part of the store will be located at mezzanine level, again accessed via lifts and a travellator located within the store itself.

page 2  Three retail/restaurant/cafe units (Use Classes A1 or A3): these three units will have a gross internal area of 36 sq.m., 291 sq.m. and 181 sq.m. respectively.

 A community use (Use Class D1): the community use will be provided on the Broadway frontage of the site with a floor area of 371 sq.m. Potential occupiers include the Citizens Advice Bureau and Bexley Voluntary Services.

 Ancillary facilities and uses: 494 car parking spaces will be provided, along with 84 cycle parking spaces. Further cycle spaces will be provided outside the store, primarily for customers and town centre visitors more generally.

9 The applicant has entered into a development agreement with Bexley Council to purchase and redevelop the application site, while the Council will purchase an adjacent site in the town centre from the applicant (the former Building Society Headquarters) which will be refurbished to allow the relocation of the Council offices. The applicant will develop residential accommodation to the rear of the refurbished council offices. It is envisaged that three separate planning applications will be submitted in total. This report provides comment on the planning application for the redeveloped Bexley Civic Offices site only. However, it is anticipated that the subsequent planning applications would be referable to the Mayor of London Order under the provisions of paragraph 2 of the Schedule to the Mayor of London Order. Case history

10 A planning application for a large retail store with residential located above on the site of the former Woolwich offices, was submitted by the applicant in 2008 (PDU reference 2178). This application did not progress to committee due to concerns over the scale and mass of the proposed development and the loss of an architecturally significant local building and was withdrawn in 2011.

11 A pre-application meeting was held on the wider proposals (including the refurbishment of the former Woolwich Building Society Headquarters and residential to the rear) on the 13 September 2011 and this concluded that the designation of the application site in the Bexley Civic Offices SPD (2007) establishes the acceptability of the proposed commercial and community uses on the civic offices site and provide an adequate impact assessment is carried out and mitigation measures put in place, there are no strategic planning concerns in relation to the principle of development. It was noted though that the lack of a true mixed-use, town centre proposal, including a residential element was disappointing.

12 It was also noted that the proposed civic and residential uses on the former Woolwich offices site are acceptable, provided a clear explanation of the planning advantages of the proposed arrangement is provided with any submitted planning application ands subject to the conclusion of viability discussions. Strategic planning issues and relevant policies and guidance

13 The relevant issues and corresponding policies are as follows:

 Economic development London Plan; the Mayor’s Economic Development Strategy; Employment Action Plan  Mix of uses London Plan  Retail/town centre uses London Plan; PPG13, PPS4  Employment London Plan; PPS4; Industrial Capacity SPG  Housing London Plan; draft Housing SPG

page 3  Urban design London Plan; PPS1  Access London Plan; PPS1; Accessible London: achieving an inclusive environment SPG; Planning and Access for Disabled People: a good practice guide (ODPM)  Transport London Plan; the Mayor’s Transport Strategy; PPG13;  Parking London Plan; draft Early Minor Alteration to the London Plan; the Mayor’s Transport Strategy; PPG13  Sustainable development London Plan; PPS1, PPS1 supplement; PPS3; PPG13; PPS22; draft PPS Planning for a Low Carbon Future in a Changing Climate; Mayor’s Climate Change Mitigation Strategy; Mayor’s Climate Change Mitigation and Energy Strategy; Mayor’s Water Strategy; Sustainable Design and Construction SPG

14 For the purposes of Section 38(6) of the Planning and Compulsory Purchase Act 2004, the development plan in force for the area is the 2012 Bexley Core Strategy and the 2011 London Plan.

15 The following are also relevant material considerations:

 The Early Minor Alteration to the London Plan  Bexleyheath Civic Offices Planning Brief Supplementary Planning Document (SPD) (July 2007).

Principle of development

16 The proposal for the development of the site is guided by the principles set out in the Bexleyheath Civic Offices Planning Brief Supplementary Planning Document (SPD) (July 2007). This sets out that the Civic Offices buildings require replacement as they have exceeded their life expectancy, are expensive to maintain and are unsuited to the needs of modern local government services. The brief sets out the new civic space requirements as follows: 16,500 sq.m. net useable area of which at least 25% should be provided flexibly.

17 The SPD notes that the proposed redevelopment of the site provides an exceptional opportunity to combine the replacement of civic accommodation with other uses that will enhance the vitality and viability of the town centre as a whole. The brief sets out that while the main focus of the redevelopment is to maintain the civic and community heart of Bexleyheath, that as the strategic centre of the borough, a wide range of other uses may be suitable on the site as part of a mixed-use redevelopment, including:

 Shops (A1);  Financial and professional services (A2);  Restaurants (A3);  Hot food take-aways (A5);  Assembly and leisure (D2);  Business (B1);  Housing (C3); and  Non residential institutions, including education and health use (D1).

18 It is noted that this site is the last remaining town centre development site (although there is the possibility that sites along The Broadway may come forward in the future) and that it will be vital to ensure that when redeveloped, the civic offices site is well integrated along the Highland Road frontage to ensure that it complements the existing town centre uses. This site designation

page 4 establishes the acceptability of the proposed commercial and community uses on the civic offices site and raises no strategic planning concerns in relation to the principle of development.

Housing

19 However, it is disappointing that a mixed use proposal has not been possible on this site, as supported by the development brief. While the proposal to develop the former Woolwich Building Society Headquarters site for residential (also included in the SHLAA as potentially suitable like to come forward for residential development) to some extent compensates for this, Bexley Council will need to ensure that it has sufficient capacity to deliver its annual target of 335 new homes taking into account the loss of the application site for residential uses.

20 As the applications for the two development sites are not planned to be linked in any way, it is suggested that the council seek a contribution towards affordable housing, in line with the section 106 requirements as set out in chapter 5 of the Bexley Civic Offices SPD and London Plan policy 8.2 ‘Planning obligations’. This will ensure that the maximum public benefit has been gained from the sale of this strategic site. At the pre-application stage, it was commented that there were some viability issues relating to the civic offices site and no further information has been provided on this matter. This should be addressed before the application is referred back to the Mayor.

Economic development/retail

21 Bexleyheath is located in Outer London, as identified in the London Plan. London Plan Policy 2.7 ‘Outer London: economy’ states that boroughs should be “f) identifying and bringing capacity in and around town centres with good public transport accessibility to accommodate leisure, retail and civic needs and higher density housing”. Bexleyheath is also designated as a Major Centre in the London Plan and the application site is located adjacent to the non-core retail frontage. London Plan policy 2.15 ‘town centres’ sets out a range of objectives that development proposals in town centres should seek to achieve. These include: sustain and enhance the vitality and viability of the centre, accommodate economic and/or housing growth, support and enhance competitiveness, quality and diversity of town centre retail, leisure, arts and cultural, other consumer services and public services; be in scale with the centre, promote access by public transport, walking and cycling.

22 The proposed commercial uses on the site comply with London Plan policy 4.7 ‘Retail and town centre development’ which sets out that retail, commercial, culture and leisure development should be focused on sites within town centres and that where no such sites are available, sites on the edges of town centres that can be well integrated with the existing centre. In addition, the Bexley Core Strategy (2012) identifies the need for further retail provision in Bexleyheath Town Centre. In line with PPS4, critical to the acceptability of new retail provision in this location will be its impact on the vitality and viability of nearby town centres.

23 The applicant has submitted a Town Centre and Retail Statement to support the proposal. This statement demonstrates that there is identified need for additional retail floorspace in the town centre and that the site meets the requirements of the impact test set out in Planning Policy Statement 4: Planning for Sustainable Economic Growth. Eight sites within the town centre have been considered, and of these, the civic offices site is identified as the most preferable. In terms of the impact of the proposed Tesco store on Bexleyheath town centre, the town centre and retail impact assessment for the proposal is based on the site being an ‘edge of town’ location and sets out that:

 the proposed development will have a strong positive effect on Bexleyheath centre, which will have lost trade to improved convenience provision in and in recent years, whilst the level of provision and choice available in the strategic centre has declined.

page 5 The development will improve the centre’s share of convenience trade from 59% in the PCA to 62% and to 33% from 31% within the catchment area as a whole, following recent declines to an estimated 46% in the PCA and 26% overall in recent years.

 the direct impact on existing in-centre trade will be felt mainly by the and Sainsbury’s stores, but the future trading of the stores would not be affected.

 the main comparison trade draw will also be from the larger foodstores in the area, with trade from other Bexleyheath town centre stores likely to come from the national multiples in the eastern end of the town. There would be little effect on the western end of Bexleyheath town centre, nor would there be any measureable effect on the smaller neighbourhood centres in the area.

 some in-centre trade will be diverted from the nearby centres of Crayford and Welling, the majority clawing back convenience trade recently lost to the new foodstore developments in these centres. However, both centres will remain vital and viable, and stronger than in 2008.

 the trade diversion from would also not be expected to affect the long term trading future of the anchor Morrisons store and thus the vitality and viability of Erith centre will not be harmed.

24 The conclusions of this impact assessment are accepted. The proposed community use is supported in line with London Plan policy 3.16 ‘Protection and enhancement of social infrastructure’ and it suggested that the terms of use for this are secured as part of the developer agreement or section 106 agreement. Urban design

25 Good design is central to all objectives of the London Plan, in particular the objective to create a city of diverse, strong, secure and accessible neighbourhoods to which Londoners feel attached whatever their origin, background, age or status. Policies contained within chapter seven specifically looks to promote development that reinforces or enhances the character, legibility, permeability and accessibility of neighbourhoods by setting out a series of overarching principles and specific design policies related to site layout, scale, height and massing, internal layout and visual impact.

26 The design of the proposed development has been previously commented on at pre- application stage and comments were provided to the applicant. This set out that that the design of the proposal had a number of good elements, but that there was significant concern with regard to the missed opportunity to try and improve the quality of Albion Road. Whilst a number of other improvements have been made to the development since the pre-application meeting, there is still significant concern with regards to this issue.

27 London Plan Policy 7.4B sets out the requirement for buildings to provide a contemporary architectural response to a site whilst having regard to the pattern and grain of development in the wider area. London Plan Policy 7.6B sets out the requirement for development to be of a proportion, composition, scale and orientation that enhances, activates and appropriately encloses the public realm. As outlined in the pre-application note, the height and massing of the proposal presents no strategic concern as it is in keeping with the surrounding area and provides a good level of enclosure to surrounding streets and spaces.

page 6 28 The changes to the layout of the ground floor of the building facing Broadway is also strongly supported, as it successfully creates as it successfully minimises the amount of frontage taken up by inactive uses on the street ensuring it will be a lively, safe and attractive street.

29 It is disappointing that a similar approach was not taken along Albion Road. Albion Road is currently a vehicular dominated street that creates significant severance between the residential areas to the south and the town centre. This negative impact is particularly exacerbated by the poor relationship between buildings along its northern edge and the street. The site plays a strategic role in influencing the way this street is used and its character, and the proposed development has the opportunity to start to rebalance its role by bringing some pedestrian activity to it. In response to this the applicant has rightly attempted to locate the community centre along this edge, but has claimed that due to the level difference between the street and the site this is not possible. Officers are not convinced that this constraint is enough to preclude this to happen and further consideration is recommended.

30 Of particular relevance to this proposal are London Plan Policy 7.1, that sets out the requirement for developments to reinforce or enhance the permeability and legibility of neighbourhoods, so that communities can easily access community infrastructure, commercial services and public transport; and London Plan Policy 7.3 that sets out a series of overarching principals to ensure that the design of a development should look to reduce the opportunities for criminal behaviour by maximising activity throughout the day and night, clearly articulating public and private spaces, enabling passive surveillance over public spaces and promoting a sense of ownership and respect. For reasons outlined above, the current proposal does not comply with these policies.

31 There area several areas which require further consideration before the proposal can be accepted in design terms.

Access and inclusion

32 London Plan policy 7.2 ‘An inclusive environment’ seeks to ensure that proposals achieve the highest standards of accessibility and inclusion (not just the minimum). This and all developments should seek to exceed minimum access requirements in all elements of the proposal, but particularly relating to the residential component and the public realm. Design and access statements should explain the design thinking behind the application and demonstrate how the principles of inclusive design, including the specific access needs of disabled and older people, have been integrated into the proposed development and how inclusion will be maintained and managed. The development should aim to meet the highest standards of accessibility and inclusion.

Commercial development

33 The Tesco store has been designed to be fully inclusive in terms of the access it provides. The main pedestrian entrance to the proposed supermarket would be via a travellator from the Highland Road frontage and lift access will also be provided to the upper floors where the supermarket is located. However, there is concern relating to how customers will access the supermarket and other retail units along the Broadway from the town centre, particularly given the barriers and the change of level between The Mall and the proposed development site. A ramped access is already provided to address this level change and the applicant should confirm that there is no opportunity to improve this access solution to ensure that it integrates well with the surrounding public realm.

page 7 34 Adequate blue badge parking has been provided although the applicant has not confirmed whether town centre parking blue badge facilities will be provided as part of the proposal or whether the shop mobility scheme has been included.

35 As such, there are a couple of matters which require further clarification to ensure that the proposal complies with London Plan policy 7.2. Climate change

36 The London Plan climate change policies set out in Chapter 5 collectively require developments to make the fullest contribution to the mitigation of, and adaptation to, climate change, and to minimise carbon dioxide emissions. London Plan Policy 5.2 ‘minimising carbon dioxide emissions’ sets out an energy hierarchy for assessing applications, London Plan Policy 5.3 ‘Sustainable design and construction’ ensures future developments meet the highest standards of sustainable design and construction, and London Plan Policies 5.9-5.15 promote and support effective adaptation to climate change. Further detailed policies on climate change mitigation and adaptation are found throughout Chapter 5 and supplementary guidance is also given in the London Plan sustainable design and construction SPG.

Climate change adaptation

37 A detailed energy strategy has not been provided to support the proposal, as discussions have been ongoing. Instead, the applicant has submitted an environmental sustainability statement and an addendum. These documents have been reviewed and officers have concluded:

 The applicant has demonstrated that the potential for connecting other loads (cinema, Marriott hotel and Bexley Council offices) has been explored and two of these are not feasible due to planned replacement of CHP (hotel) and phasing (Bexley Council offices).

 The applicant has confirmed that a heat network will allow local connection to the energy centre for the community use unit and the retail unit.

 The applicant has reviewed the option of seeking to place solar thermal or photovoltaic (PV) installations on the adjacent Bexley Council building during refurbishment but this is not attractive to Bexley Council.

 The applicant has reviewed the potential for using biomass as a fuel option to reduce regulated carbon dioxide emissions but this has been discounted due to space limitations and corresponding fuel storage requirements on the site.

 The applicant has investigated the use of solar PV on the roof of the development. Although there is a 'crowded' roof area there does appear to be potential to install 784 sq m (scaled down to 80% to allow for access) which would yield a potential saving in regulated carbon dioxide emissions from the 'Be Green' element of the Energy Hierarchy of 34 tonnes per year. The commitment to this to maximise savings should be confirmed.

38 This would suggest that solar PV will result in an increase in savings from 11% to 17%. However, this is still short of the target in the London Plan and Policy 5.2 of the London Plan clearly sets out that any shortfalls will be subject to cash-in-lieu payments towards to the local authority's offsite carbon reduction projects. Further guidance on how this will be quantified will be set out in a replacement Sustainable Design and Construction SPG. However, as an interim position, the Department for Communities and Local Government has issued a working assumption

page 8 that would cap the price of CO2 at £46/tCO2 PA over 30 years (46 x 30 = £1,380/tCO2). This figure would be applied to the development's shortfall of 447 tonnes.

39 The applicant proposes instead to use a planning condition to allow a revised energy strategy to be submitted prior to implementation of the proposal, on the basis that it anticipates that by that time it will be able to meet the 25% requirement. However, given the complexity of securing a condition/106 clause which allows for an either/or situation in which the shortfall cash in lieu payment is secured if the proposal does not meet policy requirements, the applicant should first set out a strategy for maximising onsite carbon reductions prior to the planning application being determined. Details of carbon emission and savings in line with Tables 1 & 2 of the GLA's energy assessment guidance should be submitted to the GLA for review.

Climate change mitigation

40 The submitted environmental sustainability statement sets out that the intention is for the proposed Tesco store to be an Eco-Store and that this will feature the use of rainwater harvesting, maximum passive design features in terms of lighting and ventilation and the inclusion of combined heat and power plant.

41 The proposals do not comply with London Plan policies 5.2 or 5.3 although they do broadly comply with policies 5.9-5.15 of the London Plan and supplementary guidance is also given in the London Plan sustainable design and construction SPG.

Transport

Parking

42 The development will result in the loss of the existing 160 spaces public car park that has charges but no maximum length of stay. 494 customer parking spaces are proposed, allowing a maximum of three hour stay. This equates to 21 spaces per sq.m. of retail floorspace. This is above the standards set out in London Plan policy 6.13 ‘Parking’, which allows a maximum range of 263 to 400 spaces for large retail developments in areas of high PTAL. This policy only allows a more flexible approach to car parking where it would serve wider town centre where there are identified issues of vitality and viability.

43 The proposed level of parking has not been justified, as requested by TfL at pre-application stage. Specifically, information on the utilisation of the exiting car parks in the town centre is still outstanding. The rationale behind restricting the length of stay to three hours has not been made clear and does not reflect restrictions at other town centre car parks. Three hours is not considered long enough to allow a reasonable trip to the town centre, as offered by the existing 160 car park. A short stay restriction is also likely to increase vehicle trip generation as it encourages a higher turn over, which would serve to disadvantage traffic movement in the town centre. TfL expects the car park to be made available for all users of the town centre in line with the current charging regime of the current public car park.

44 The applicant has committed to providing blue-badge holder parking space and electric vehicle (EV) charging points in line with London Plan standards, which is supported.

45 The level and location of cycle parking is in line with London Plan policy 6.9 ‘Cycling’, and TfL expects appropriate showering and changing facilities to be provided from the outset.

Road network and bus service impacts

page 9 46 The application proposes the closure of the northern end of Highland Road, which is currently used by bus services 269 and B13 (southbound only). These services will experience longer journey times as a result of this alteration, having to divert around the site via Gravel Hill. This will increase bus operating costs and disadvantage bus passengers. Whilst these concerns were raised by TfL at pre-application stage, the applicant has failed to provide a robust assessment of the impact on bus services of this closure. Any delay to bus services is considered contrary to London Plan policy 6.7 and should be fully justified.

47 TfL considers that the cumulative impact of traffic from this development and the related scheme at site (which is subject to separate planning applications) would add significant additional traffic congestion at key junctions in the vicinity of the site, which currently operate at or close to capacity. Whilst signals at these junctions could be optimised to improve traffic flow, this would ultimately result in unacceptable delays to pedestrian, which is inconsistent with London Plan policy 6.10. The proposals for signal optimisation should be revised to ensure at least the minimum standards for pedestrian phases at all junctions which will enable TfL to assess whether the traffic impact of the development is acceptable.

48 TfL welcomes the Council’s aspirations to improve the pedestrian environment of the /Erith Road junction and considers pedestrian improvements at this junction necessary to provide appropriate access to the proposed new Civic offices. The performance of this junction with proposed improved pedestrian crossing facilities should be modelled before TfL can provide a conclusion on the acceptability of traffic impact.

49 At pre-application stage, TfL raised a number of other concerns in relation to traffic modelling which have not been addressed by the applicant. Given the level of congestion experienced on the surrounding road network, it is essential that the existing highway assumptions as assumed in the applicant’s transport assessment are robust. As part of this, TfL would support the development of a microsimulation model.

Relocation of Eastbound Bus Stop and bus layover

50 The junction realignment will necessitate the relocation of the eastbound bus stop on The Broadway. TfL is concerned by the proposed layout and location of the bus stop as there is a risk that passengers wishing to board at this location will be required to wait in the private forecourt of the adjacent cinema as the public footway could be too narrow. As requested at pre-application stage, full details (including dimensions) of the proposed bus stop, footway widths and kerb heights are required, along with a tracked vehicle swept path analysis.

51 The provision of additional bus layover space is welcomed although more detail of how this area will function, given that smaller retail units proposed along the Broadway will be serviced from the same location. It may also be appropriate for additional bus driver convenience facilities to be provided close to this layover space in line with London Plan policy 6.7, and TfL welcomes further discussion in this respect.

Travel planning

52 A framework travel plan is provided, which contains targets for future mode share and measures to meet these targets, which is welcomed. It would be expected that adoption of the travel plan is a condition of planning permission and measures outlined are delivered either through the planning permission itself or through the s106 agreement.

53 A Construction Logistics Plan should be secured by condition on any permission and should identify efficiency and sustainability measures to be undertaken while the development is being built including booking systems, consolidated or re-timed trips, secure, off-street loading and

page 10 drop-off facilities, details of traffic management and using operators committed to best practice, demonstrated by membership of TfL’s Freight Operator Recognition Scheme or similar.

54 A Delivery and Servicing Plan (DSP) should also be secured by condition on the development and should aim to minimise peak time deliveries. It should address the issue of managing the small retail unit servicing from the bus lay-over/stop, as highlighted above. Any proposals to operate a Tesco.com van fleet from the store should also be outlined.

Planning obligations and Community Infrastructure Levy

55 Should the above points be addressed, it may be appropriate for TfL to request a number of planning obligations to be secured through any planning permission. These could relate to bus infrastructure and operating costs, travel planning, and pedestrian improvements along Broadway, at the Watling Street/Erith Road junction and across Albion Road. The scope of these measures will be influenced by the further modelling and assessment work required.

Conclusion

56 TfL has significant concerns that the traffic generation associated with the retail development, coupled with the proposal to close Highland Road, will have an unacceptable impact on the surrounding road network and thus impact bus services and/or existing pedestrian access. Further work is required on this. TfL is also concerned that this traffic impact will reduce the scope to provide much needed and already identified improvements to the pedestrian access which will become more important with the relocation of the Civic offices. The number and management/charging of parking still remains to be justified. Further information is also sought on the details for relocation of westbound bus stop and management of servicing for the small retail units. Community Infrastructure Levy

57 In accordance with London Plan policy 8.3, the Mayor of London proposes to introduce a London-wide Community Infrastructure Levy (CIL) that will be paid by most new development in Greater London. Following consultation on both a Preliminary Draft, and then a Draft Charging Schedule, the Mayor has formally submitted the charging schedule and supporting evidence to the examiner in advance of an examination in public. Subject to the legal process, the Mayor intends to start charging on 1 April 2012. Any development that receives planning permission after that date will have to pay, including:

 Cases where a planning application was submitted before 1 April 2012, but not approved by then.  Cases where a borough makes a resolution to grant planning permission before 1 April 2012 but does not formally issue the decision notice until after that date (to allow a section 106 agreement to be signed or referral to the Secretary of State or the Mayor, for example),.

58 The Mayor is proposing to arrange boroughs into three charging bands with rates of £50 / £35 / £20 per square metre of net increase in floor space respectively (see table, below). The proposed development is within the where the proposed Mayoral charge is £20 per square metre. More details are available via the GLA website http://london.gov.uk/ .

59 Within London both the Mayor and boroughs are able to introduce CIL charges and therefore two distinct CIL charges may be applied to development in future. At the present time,

page 11 borough CIL charges for Redbridge and are the most advanced. The Mayor’s CIL will contribute towards the funding of Crossrail.

Mayoral CIL London boroughs Rates charging zones (£/sq. m.) Zone 1 Camden, City of London, City of , £50 and , , Kensington and Chelsea, Richmond- upon-Thames, Wandsworth

2 Barnet, Brent, , , , Hackney, £35 Haringey, Harrow, , , , , , , Redbridge, , Tower Hamlets

3 Barking and , Bexley, , Enfield, Havering, £20 Newham, Sutton, Waltham Forest

Local planning authority’s position

60 Bexley Council is understood to support the proposals. Legal considerations

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

62 There are no financial considerations at this stage. Conclusion

64 London Plan policies on economic development, outer London, town centres, retail, social infrastructure, urban design, access and inclusion, climate change and transport are relevant to this application. The application complies with some of these policies but not with others, for the following reasons:

 Principle of development: the proposal for a retail-led mixed use scheme in this edge of town centre location complies with London Plan policies 2.5 and 2.7. The provision of community facilities complies with London Plan policy 3.16.

page 12  Economic/retail: the proposal complies with London Plan policy 4.7 and the sequential test as required by PPS4 has been satisfactorily carried out.

 Urban design: the proposal does not comply with London Plan policy 7.4 or 7.6.

 Access and inclusion: the proposal does not fully comply with London Plan policy 7.2.

 Climate change: the proposal does not comply with London Plan policy 5.2.

 Transport: the proposal does not comply with London Plan policies 6.13, 6.10 and 6.7.

65 On balance, the application does not comply with the London Plan. The following changes might, however, remedy the above-mentioned deficiencies, and could possibly lead to the application becoming compliant with the London Plan:

 Urban design: further consideration should be given to the treatment of the corner of Albion Road and Highland Road.

 Access and inclusion: further information should be provided on the blue badge parking arrangements for town centre shopping and the shop mobility scheme.

 Climate change: a detailed energy strategy should be submitted and further discussion is recommended.

 Transport: the parking, pedestrian and bus impacts described in the report must be addressed.

for further information, contact Planning Decisions Unit: Colin Wilson, Senior Manager - Planning Decisions 020 7983 4783 email [email protected] Justin Carr, Strategic Planning Manager (Development Decisions) 020 7983 4895 email [email protected] Shelley Gould, Case Officer 020 7983 4803 email [email protected]

page 13