planning report GLA/4405/01 13 August 2018 164 – 196 Trundley’s Road and 1 – 4 Sanford Street, in the London Borough of Lewisham planning application no. DC/18/106941

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

The proposal Demolition of existing buildings and construction of two building from 6 to 15 storeys to provide 2,200 sq.m. of flexible commercial space and 189 residential units.

The applicant The applicant is Trundley’s Road Limited (Aitch Group) and the architect is Formation Architects.

Strategic issues summary Principle of development: The inclusion of residential units on this protected industrial site is not currently compliant with London Plan Policies 2.17 and 4.4 and draft London Plan Policy E6 and Lewisham Council should provide evidence of a plan led approach to SIL consolidation before any residential use can be supported. Notwithstanding this, the inclusion of industrial uses is supported, but the applicant must demonstrate that the industrial floorspace meets market requirements for the proposed land use and the B1c, B2, and B8 use should be secured in perpetuity (Para’s 15-29) Affordable housing: 35% by habitable room with a 63:37 split in favour of affordable rent. This does not meet the 50% threshold for industrial land under the Fast Track Route set out in the draft London Plan Policy H6. GLA officers have robustly interrogated the applicant’s submitted viability and have provided comments which must be addressed before stage 2. (Para’s 28-35).

Design: Further discussion is required on aspects of residential quality and viability of the industrial floorspace design to meet proposed industrial user requirements and the design of the cycle parking access (Para’s 38-47) Further information on Energy, Flood Risk and Transport required.

Recommendation That Lewisham Council be advised the application does not comply with the London Plan and draft London Plan, for the reasons set out in paragraph 62 of this report. However, the resolution of those issues could lead to the application becoming compliant with the London Plan and draft London Plan.

page 1 Context

1 On 14 July 2018, the Mayor of London received documents from Lewisham 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 must provide the Council with a statement setting out whether he considers that the application complies with the London Plan and draft 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.

2 The application is referable under Categories 1A, 1B, 1C and 3E of the Schedule to the 2008 Order: • 1(A) ‘Development which comprises or includes provision of more than 150 houses, flats or houses and flats’

• 1B(c) ‘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 outside Central London and with a total floorspace of 15,000 square metres’

• 1C(c) ‘Development which comprises or includes the erection of a building of more than 30 metres high and is outside of the City of London’

• 3E ‘Development which does not accord with one or more provisions of the development plan in force in the area in which the application site is situated; comprising more than 2,500 square metres of floorspace for a specific Use Class.

3 Once Lewisham 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 site is located in Deptford, to the west of Trundley’s Road, and Folkestone Gardens. The application site measures approximately 0.9 hectares and is bounded to the north by a metal scrap yard, to the east by Trundley’s Road, to the south by the overground railway track and a rail substation to the west. The applicants have also developed a wider masterplan involving the redevelopment of two separate sites to the north of the application site.

6 The site currently accommodates a variety of uses including a street care business (Class B8), workshops, a vehicle repair business (Class B2), and a row of five, two storey terrace properties with retail/ restaurant uses at ground floor (currently vacant) with residential above to the southern end of the site.

7 The wider conceptual masterplan site which is not part of the application comprises a scrap metal yard, between the application site and Surrey Canal Road, accessed via Juno Way, which is owned by Lewisham Council. The second site, owned by Network Rail, is just beyond the scrap metal yard Apollo Business Centre to the north of Surrey Canal Road and comprises a number of stand-alone, industrial/ light industrial sheds and goods yard with further industrial uses under the railway arches to the north.

page 2 8 The whole masterplan site, including the rail substation to the rear of the application site, is within the Surrey Canal Strategic Industrial Location (SIL). The remaining Surrey Canal SIL designation lies to the north and west of the site. The site is also located within the Lewisham, Catford and Opportunity Area as well as being identified as an Area for Regeneration in the London Plan. The site is not within a Conservation Area and there are no listed buildings on or in the vicinity of the site.

9 The closest rail stations to the site are New Cross and New Cross Gate, which are approximately 1.2 kilometres south the site. These provide access to London Overground and National Rail services. Deptford and South stations are also located approximately 1.5 kilometres of the site (east and west respectively) providing further access to National Rail services. The nearest bus stops which provide access to Route 225 are located adjacent to the site on Trundley’s Road. Overall, the site has a poor Public Transport Accessibility Level (PTAL) of between 1b and 2 (on a scale of 1-6 where 6 is most accessible). Details of the proposal

10 The application proposes the demolition of existing buildings and the construction of a double height commercial plinth at ground floor and two building of one part 6 and 9 storeys and one of part 11 and 15 storeys to provide 2,200 sq.m. of flexible commercial space at ground and mezzanine floors, 189 residential units above, with associated access and highway works, amenity areas, cycle, disabled and commercial parking (within basement) and refuse/ recycling stores. Case history

11 On 1 December 2017 and 18 May 2018, pre-application meetings were held with GLA officers regarding the above proposal (D&P/4407). The applicant was advised that the principle of the redevelopment of the site for a mixed-use scheme containing residential uses in the strategic industrial location was not supported by the London Plan and draft London Plan policy in the absence of an evidenced plan-led process of SIL consolidation. Further advice was provided in this report with respect to affordable housing and that any redevelopment should re-provide industrial floorspace. Revisions to the design were also required. Strategic planning issues and relevant policies and guidance

12 For the purposes of Section 38(6) of the Planning and Compulsory Purchase Act 2004, the development plan in force for the area comprises Lewisham’s Core Strategy (2011), Site Allocations Local Plan (2013), Development Management Local Plan (2014) and the London Plan 2016 (Consolidated with Alterations since 2011).

13 The following are also relevant material considerations: • National Planning Policy Framework and National Planning Practice Guidance; • The draft London Plan (Consultation draft December 2017, which should be taken into account on the basis described in the NPPF); and • The Mayor’s Affordable Housing and Viability SPG.

14 The relevant strategic issues and corresponding policies are as follows:

• Principle of development London Plan; Land for Industry and Transport SPG; • Housing/ affordable housing London Plan; Housing SPG; Affordable Housing and Viability SPG; Housing Strategy; Shaping Neighbourhoods: Play and Informal Recreation SPG; Shaping Neighbourhoods: Character and Context SPG;

page 3 • Urban design London Plan; Shaping Neighbourhoods: Character and Context SPG; Housing SPG; Shaping Neighbourhoods: Play and Informal Recreation SPG; • Inclusive access London Plan; Accessible London: achieving an inclusive environment SPG; • Sustainable development London Plan; Sustainable Design and Construction SPG; Mayor’s Climate Change Adaptation Strategy; Mayor’s Climate Change Mitigation and Energy Strategy; Mayor’s Water Strategy; Mayor’s Ambient Noise Strategy; • Transport and parking London Plan; the Mayor’s draft Transport Strategy;

Principle of development

Mixed use redevelopment in SIL

15 London Plan Policy 2.17 states that strategic industrial locations should be promoted, managed and protected as London’s main reservoir of industrial and related capacity. Furthermore, proposals in SILs should be refused unless: they fall within the broad industrial type activities appropriate to the function of the particular SIL in question (in this regard the Surrey Canal SIL is identified as a Preferred Industrial Location (PIL), therefore suitable uses would comprise general industrial, light industrial, storage and distribution, waste management, recycling, some transport related functions, utilities, wholesale markets and other industrial related activities); or they are part of a strategically co-ordinated process of SIL consolidation through an opportunity area planning framework, or borough development plan document; or the proposal is for employment workspace to meet identified needs for small and medium sized enterprises or new emerging industrial sectors; or the proposal is for small scale ‘walk to’ services for industrial occupiers such as workplace creches or cafes. Development proposals within or adjacent to SILs should not compromise the integrity or effectiveness of these locations in accommodating industrial type activities.

16 London Plan Policy 4.4 deals specifically with the management of industrial land and states that the Mayor and Local Authorities will need to take a rigorous approach to ensure a sufficient stock of land and premises to meet the future needs of different types of industrial and related uses including good quality and affordable space; and plan, monitor and manage release of surplus industrial land where is it compatible with the above and where it would contribute to strategic and local planning objectives, especially to provide more housing or social infrastructure.

17 Lewisham Council commissioned an Employment Land Study (2015) to inform the Local Plan review. The study identifies the masterplan site as one of two SIL sites that could be suitable for release from SIL for mixed uses. The reasons cited for release of the masterplan site from SIL are that: the cluster contains residential and retail uses along Trundley’s Road and is situated opposite parkland and some mid-density housing; parking is inadequate with evidence of congestion caused by businesses within the cluster; and the poor quality of the existing industrial buildings on site. However, it is important to note that a large proportion of the application and wider masterplan sites are currently in active use.

18 In terms of the current status of the local plan review, Lewisham Council consulted on the main issues Local Plan in October 2015. The potential release of this site did not form part of that consultation. Consultation on the preferred options Local Plan is due to take place in October 2018 with adoption currently anticipated in 2020. The review will be informed by an updated Employment Land Study which will provide a more up-to-date review of industrial land demand and supply across the Borough. Therefore, the recommendations with respect to SIL release may be subject to change in the intervening period.

page 4 19 The Mayor is acutely aware that London’s reservoir of industrial land has drastically diminished in recent years. Industrial land has and is continuing to be lost to higher value uses such as residential at a significant rate, well outstripping benchmark London Plan figures and often on an ad hoc basis rather than a plan led one, as required by the London Plan. This has resulted in more competition for sites, increasing industrial rents, which is in turn forcing industrial businesses to look to locate in less sustainable locations in the outskirts of London and beyond. This trend is highlighted in the London Industrial Land Demand report (June 2017). The report therefore suggests that most London boroughs should seek to ‘retain’ existing industrial land (including Lewisham) going forwards rather than allowing release in certain circumstances as it is now.

20 The findings of this report have been reflected in the draft London Plan Policy E4 which seeks to ensure a sufficient supply of land and premises in different parts of London to meet current and future demands for industrial and related functions be maintained. In line with the Demand Report, Lewisham has been re-categorised to ‘retain’ its existing industrial capacity (Table 6.2). More specifically, Policy E5 of the draft Plan details the types of uses appropriate to SILs and development proposals for uses in SILs other than those deemed appropriate, should be refused except in areas released through a strategically co-ordinated process of SIL consolidation. This release must be carried out through a planning framework or Development Plan document review process and adopted as policy in a Development Plan or as part of a co-ordinated master-planning process in collaboration with the GLA and relevant borough.

21 In recognition of the need to intensify industrial capacity within London, Policy E7 of the draft London Plan actively encourages development proposals to intensify industrial use of selected sites, and where this is possible, and delivers increases in capacity, it may be possible through a plan-led or masterplan-led approach to deliver residential or other uses. Such co- location must be sensitivity designed, and be developed in close collaboration with both the GLA and Council, as well as existing operators, and must meet the criteria set out in Policy E7. Furthermore, any development proposals should not compromise the integrity or effectiveness of these locations in accommodating industrial-type activities and their ability to operate on a 24- hour basis. In line with Agent of Change principles (Policy D12 of the draft Plan) residential development must be designed to ensure that the industrial activities are not compromised or curtailed. Particular attention should be given to layouts, access, orientation, servicing, public realm, air quality, soundproofing and other design mitigation in the residential development.

Evaluation and conclusion

22 London Plan and draft London Plan policy both establish that the release of SIL land must be undertaken through the strategic plan making process that will release land for alternative use. At the same time the draft London Plan has increased protection of Lewisham SIL through re- categorisation to ‘retain’ existing industrial capacity and also promotes co-location on released sites.

23 In this instance the proposed site has been identified by a Lewisham Council industrial land review for release for mixed use development, however the local plan process will not be concluded until 2020 and it will be supported by an updated industrial land review. Lewisham Council officers are supportive of the principle of a mixed-use development of the site on the basis of the previous recommendation of its employment land review and indicated that the current on-going employment land review will designate new areas of SIL with specific reference to future designation of land to the north of the site in the area of the Bermondsey dive under.

24 Notwithstanding the current SIL designation, it is acknowledged that the site is potentially a suitable location for a mixed-use employment and residential development as it would contribute to the consolidating the urban form in this part of Lewisham. This is because it is separated from the larger designated SIL area to the north and west and has residential neighbourhoods adjacent

page 5 to the south, west and east with a large park area Folkstone Gardens opposite that will provides an existing amenity space. It is not a SIL site that is wholly industrial in nature having both retail and residential use forming 43% of the site use and can be released in isolation without compromising the integrity of the larger area of SIL to the north or result in a residential development surrounded by industrial use.

25 For these reasons, there may be evidence for Lewisham Council to release this site as part of a plan-and led approach to SIL consolidation intensification. However, draft London Plan Policy E7 is clear that the release of SIL must only take place as a part of a development plan or masterplan –led process, and not through ad-hoc planning applications. Noting the timescales for Lewisham Council’s consultation on its new local plan, the application is premature. Lewisham Council should provide evidence on its plan-led approach to SIL consolidation before any residential use can be supported.

26 Notwithstanding this, if the introduction of residential uses is acceptable, it would be a requirement to re-provide industrial uses on the site. As a result of pre-application discussion, the proposal has been designed to co-locate at ground floor B1c, B2, and B8 business floorspace with residential above, the proposed employment uses comply with industrial uses on SIL as set out in London Plan and draft London Plan policies. A total of 2,200 sq.m. of internal floorspace is proposed compared to the existing 1,320 sq.m., this results in a 168% uplift of commercial floorspace, resulting in an increase in industrial capacity in line with draft London Plan Policy E7. As set out in the design section there are concerns that that the proposed space would not function effectively to accommodate the proposed use and further discussion is required on the viability of floorspace proposed before this can be supported.

27 Should the employment floorspace be found to be suitable and the change on land use accepted, the applicant must agree to a condition that the B1c, B2, and B8 use is secured in perpetuity; that a proportion of affordable workspace floorspace is provided; and that given the protection of industrial land uses by London Plan and draft London Plan policy existing business occupiers, should be given support with relocation and given the option to occupy the proposed units. Housing

Affordable housing

28 London Plan Policies 3.11 and 3.12 and draft London Plan Policies H5 and H6 seek to maximise the delivery of affordable housing, with the Mayor setting a clear strategic target of 50%.

29 Policy H6 of the draft London Plan and the Mayor’s Affordable Housing and Viability SPG set out a ‘threshold approach’ whereby schemes meeting or exceeding a specific threshold of affordable housing (in this case 50% on SIL land) by habitable room without public subsidy and which meets other criteria are not required to submit viability information to the GLA, nor would the application be subject to a late stage review mechanism. Draft London Plan Policy H7 and the Mayor’s SPG sets out a preferred tenure split of at least 30% low cost rent (social or affordable rent, significantly less than 80% of market rent), at least 30% intermediate (with London Living Rent and shared ownership being the default tenures), and the remaining 40% to be determined by the local planning authority.

30 The housing unit mix proposed is as follows:

page 6

Shared Total Total Unit mix Affordable Rent Market Ownership units (HR) % Units HR Units HR Units HR Studio 0 0 0 0 1 1 1 1 0.5 1 Bed 12 24 16 32 60 120 88 176 46.6 2 Bed 13 39 7 21 53 159 73 219 38.6 3 Bed 15 60 0 0 12 48 27 108 14.3 Total 40 123 23 53 126 328 189 504 100 Total HR 176 328 % HR 35 65 Affordable Total Units 63 126 % Units 33 67 Affordable

31 The applicant proposes 63 affordable units which equates to 35% by habitable room (33% by unit) with a 63:37 split in favour of affordable rented tenure. This does not meet with the 50% threshold for the Fast Track Route for applications on industrial land. The application has therefore been considered under the viability tested route.

32 GLA officers have robustly interrogated the applicant’s submitted viability assessment and have identified points of disagreement. It is not agreed that the scheme produces a negative RLV with 35% affordable housing. The applicant is required to include ground rents in the GDV and profit on the private residential element should be reduced to 17.5% to appropriately reflect risk on the current scheme which is not unduly complex. A revised FVA, taking into account these points, must be submitted to the GLA before stage 2 referral. Lewisham Council should ensure that the correct figures from their appraisals and also the points included above are used in the formulae for the review mechanisms.

33 Early implementation and late stage review mechanisms will be secured as appropriate in accordance with Policy H6 of the draft London Plan and the Mayor’s SPG; as the application does not deliver 50% affordable housing in accordance with draft London Plan. The affordability of the units must accord with the requirements of Policy H7 of the draft London Plan, the Mayor’s Affordable Housing and Viability SPG, and the London Plan Annual Monitoring Report. GLA officers will work with the Council to agree affordability levels of all affordable tenures as part of the review of viability.

34 A draft of the s106 agreement must be provided to the GLA for review as soon as one is made available to ensure that the review mechanisms have been applied as required by Policy H6 and the Mayor’s SPG.

35 Lewisham Council has published the financial viability assessment on its website and this is welcome, the independent review should also be published, in accordance with Policy H6 of the draft London Plan and the Mayor’s SPG and to ensure transparency of information.

page 7 Housing mix

36 London Plan Policy 3.8 and draft London Plan Policy H12 encourage a full range of housing choice. Draft London Plan Policy H12 recognises that central or urban sites may be most appropriate for schemes with a significant number of one and two beds, as well as recognising that the number of family sized affordable homes provided should be driven by local and strategic need and that some families live in units smaller than three bedrooms. The application includes 86% of the units as two or less beds, with 14% as three bed units. The proposed mix responds positively to the requirements of draft London Plan H12 by providing a range of unit types appropriate to this location. The mix is considered to be appropriate to the characteristics of this scheme, which includes a mix of land uses that constrain the provision of a large proportion of family housing. Overall, the mix would optimise housing potential on the site.

Children’s play space

37 London Plan Policy 3.6 and draft London Plan Policy S4 seeks to ensure that development proposals include suitable play provision for all ages, of at least 10 sq.m. per child. Further detail is provided in the Mayor’s Shaping Neighbourhoods: Play and Informal Recreation SPG. The development makes provision for doorstep play for under 5 age groups on-site, with play space provided at podium level. The play space would be easily accessible and safe to use and it would also incorporate green planting and the proposed play space provision is acceptable. Play provision for all other age groups will be accommodated off-site with the adjacent park and Lewisham Council should consider a secured financial contribution towards improvement to existing play facilities. Design

38 The design principles in chapter seven of the London Plan and chapter 3 of the draft London Plan place expectations on all developments to achieve a high standard of design which responds to local character, enhances the public realm and includes architecture of the highest quality that defines the area and makes a positive contribution to the streetscape and cityscape.

Layout

39 The scheme occupies a linear site with primary frontage onto Folkstone Gardens and a clearly defined and secure back-of house and yard space zone along its western edge. The site is a significant distance away from South Bermondsey and Deptford Stations and so it is important that the application clearly sets out how the scheme’s layout and public realm strategy is designed to respond and connect with the wider network of public realm, including key pedestrian desire lines.

40 The proposed layout creates a consistent frontage along Trundley’s Road, with the building set back to create a generous zone of public realm facing the park. Vehicular servicing and access to the industrial yard space is contained at the southern end of the site to allow the potential for consistent active frontage across the remainder of the Trundley’s Road frontage. As discussed, the ability to maximise the extent of active frontages will depend on the nature of the end users and in turn, the ability to provide public facing entrances along the Trundley’s Road frontage. Indicative internal layouts of the commercial units should be provided to demonstrate how this can be achieved.

page 8 Functionality of re-provided industrial floorspace

41 The re-provision of the industrial space raises some concern in regards to its functionality. Research suggests that a minimum floor to ceiling height of 4.2 metres for most B1c/B2/B8 uses which is not provided in the proposed development. The yard space is also tight allowing for access only for a 7.5 metres van and the space may therefore not be attractive to potential occupiers, restricting its flexibility to a range of industrial type occupiers. It is questionable whether the mezzanine as designed would functionally contribute to the re- provision of industrial space. One option would be to increase the volume of the industrial space and height.

Residential quality

42 The provision of yard space to the rear of the block is welcomed in terms of supporting the function of light industrial spaces but the horizontal form of co-location and proximity of residential units overlooking the yard space raises concern in terms of the resulting impact on residential amenity. It is noted that winter gardens are provided to help mitigate noise and air quality which is supported. There are however a number of single aspect units with direct outlook onto the yard. The applicant should confirm the width of the protruding section to these units and ensure it provides genuine east facing aspect and cross ventilation.

43 The positioning of cores creates efficient residential floorplans and a reasonable proportion of dual aspect units overall. The applicant should explore means of screening the amenity deck from the industrial yard to ensure this space is usable and comfortable for residents. All cores are naturally lit and ventilated which is welcomed.

44 In accordance with Policy D11 of the draft London Plan, the Council should secure an Informative requiring the submission of a fire statement, produced by a third party suitable qualified assessor.

Height, massing and scale

45 The applicant has demonstrated how the scheme would relate to a wider masterplan area which includes the neighbouring Juno site and Apollo site’s A and B further to the north. This approach is welcomed and indicates how this cluster of sites can come forward to collectively enhance the quality of public realm and street frontage along Trundley’s Road/Surrey Canal Road and the park edge.

46 The applicant has also tested a variety of massing and heights options in conjunction with the neighbouring sites, ensuring that the proposed scale and form of blocks responds positively to the character of future townscape in long and short-range views. The submitted verified views suggest that while the scheme will represent an uplift in scale in relation to the surrounding townscape, its massing and heights configuration responds successfully to the park edge and is consistent with the scale and proportions of emerging development in the wider area, including Neptune Wharf.

Appearance

47 The simple approach to the architecture and use of high quality brickwork, with varying tones to denote each massing element is welcomed. Details of all facing materials, balconies, window reveals, ground frontages and rooflines should be secured in the application to ensure exemplary build quality is delivered.

page 9

Inclusive design

48 London Plan Policy 3.8 ‘Housing Choice’ and Policy D5 of the draft London Plan requires that 90% of new housing meets Building Regulation requirement M4(2) ‘accessible and adaptable dwellings’ and 10% meets Building Regulation requirement M4(3) ‘wheelchair user dwellings’, that is, designed to be wheelchair accessible or easily adaptable for residents who are wheelchair users. The application has demonstrated that these requirements will be met and the plans identify the location of the wheelchair accessible homes. The Council should secure M4(2) and M4(3) requirements by condition. Climate change

Energy

49 The applicant has submitted an energy statement which sets out how the development proposes to reduce carbon dioxide emissions. The applicant should undertake revision of its overheating analysis and provide additional verification information. Connection to the proposed district heating network should be prioritised and it should be confirmed that all apartments and non-domestic building uses will be connected to the site heat network and further detail is required on the plant room. The applicant has included renewable technologies in the form of photovoltaic (PV) panels and air source heat pumps (ASHPs), verification information is required in relation to the PV. The non-domestic part of the building exceeds the 35% carbon target, but the domestic part of the building falls below the zero-carbon target set out in draft London Plan Policy SI3 (Energy infrastructure) and London Plan Policy 5.2 (Minimising carbon dioxide) by 140 tonnes. Once all measures to minimise on-site carbon savings have been exhausted an appropriate contribution to the borough’s carbon fund should be secured, in compliance with Policy 5.2 of the London Plan and Policy SI2 of the draft London Plan. The full energy strategy review has been sent to the applicant and Lewisham Council under separate cover.

Flood risk

50 The proposed development flood risk strategy complies with London Plan Policy 5.12 (and draft Policy SI.12), however more detail should be provided as to flood resilient design in the basement and ground floor. The proposed surface water management strategy does not comply with London Plan Policy 5.13 (and draft Policy SI.13). While the reduction in peak runoff rate is broadly compliant, the approach to managing surface water does not sufficiently comply with the drainage hierarchy. Incorporation of rainwater harvesting and nature-based SuDS options, as well as integration with the landscape strategy, should be provided. If these strategies are not possible, more a robust justification should be provided. The proposed water use strategy is compliant with London Plan Policy 5.15 (and draft Policy SI5), which should be maintained through detailed design. Full flood risk comments have been sent under a separate cover to the borough and applicant.

Transport

Trip generation

51 The TA does not provide an assessment of personal injury accident data and no observed baseline traffic survey data or assessment of the existing or future operational performance of surrounding junctions has been completed. Furthermore, in accordance with TA best practice guidance, a sensitivity test should be provided to gauge the impact of the development against

page 10 the measured number of trips that the existing site is generating at the time of the application. This should be provided before stage 2 though discussions with TfL.

52 Further discussion will be required on the impact of the development on the bus network based on finalised trip generation and the applicant should provide a s106 contribution of £90,000 to fund an additional journey for the 225 service. The relocation of the bus stop on Trundley’s Road could be supported subject to further discussions on finalising the precise location. A financial contribution of £8,000, should also be secured to install or fund Legible London wayfinding.

Pedestrian access and healthy streets

53 The applicant should complete a PERS audit and CLOS assessment of key routes and crossings between the site, transport nodes, cycling infrastructure, retail centres and other important destinations. Walking and cycling routes particularly to local transport hubs are optimised and further discussion is required in relation to the public realm design and balance of space given to all users of the site. The applicant should work with Lewisham Council to ensure that these improvements are secured through relevant S106 and/or S278 agreements.

Cycle parking

54 There are inconsistencies in the proposed level of cycle parking reported in the TA and DAS. The cycle parking total should be broken down by land use and the number of spaces provided cycle should be compliant with draft London Plan Policy T5. Further discussion is required in relation the design of the visitor cycle as there are issues due to its location with its accessibility, visibility and security. Its design neds to be reconsidered as the entrance door needs to be wider width; 5% of long-stay stand should accommodate larger cycles; two-tier cycle racks should be mechanically or pneumatically assisted system; and although showers for the employment use is welcomed, other supporting facilities such as lockers, changing rooms and maintenance facilities should be considered.

Car parking

55 The provision of six commercial parking spaces exceeds both current and draft London Plan policy and should be reduced. In line with London Plan policy, the applicant should provide a blue badge compliant car parking space per accessible dwelling. For the proposed 189 residential dwellings this is 19 spaces and the draft London Plan requires 3% (6 spaces) of spaces to be provided from the outset with a further 7% (13 spaces) of spaces provided if there was sufficient demand. As the basement space is constrained, further discussion should be undertaken on this matter to ensure sufficient space is allocated to meet blue badge parking requirements

56 The car-free nature of the residential element of this scheme is supported, but there concerns that parking will overspill onto the surrounding local road network which is currently not part of a CPZ and has largely unrestricted on-street parking. Lewisham Council should therefore seek to extend this to cover a period of up to 5 years post occupation to allow for sufficient time to consult and implement a CPZ. The applicant car park management plan should secured by condition. It establishes that the parking spaces will be leased through a permit system rather than sold, as set out in draft London Plan Policy T6.1 and this this is welcome. The proposal however will need to provide both active and passive electric vehicle charging points for 20% of any parking spaces provided in line with draft London Plan policy.

page 11 London Overground and substation safeguarding

57 Prior to any demolition and construction, the applicant will need to gain London Overground (LO) written consent that the demolition and construction techniques used will not affect the safe and efficient operation of the railway. The applicant should conduct radio surveys before construction, followed by further surveys at interim stages (to be agreed) and after the construction to assess the level of impact the development has on radio signal. This has safety implications and a financial contribution from the developer towards any equipment upgrade could be required to mitigate identified adverse impact.

Travel, construction logistics and delivery service plans

58 The workplace travel plan and all agreed measures should be secured by condition in compliance with London Plan Policy 6.11 and draft London Plan policy T4 and the construction logistics plan and delivery and servicing should be secured by condition, in line with current London Plan polices 6.11 and 6.14 and draft London Plan polices T4 and T7. Local planning authority’s position

59 The applicant has undertaken pre-application discussions with Lewisham Council planning officers. It is understood that the Council planning officers are supportive of the scheme. There is no committee date set yet. Legal considerations

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

61 There are no financial considerations at this stage. Conclusion

62 London Plan and draft London Plan policies on industrial land; housing; affordable housing, playspace, urban design, access, climate change and transport; are relevant to this application. The application does not comply with the London Plan and draft London Plan. The following strategic issues must be addressed for the application to fully accord with the London Plan and draft London Plan: • Principle of development: The inclusion of residential units on this protected industrial site is not currently compliant with London Plan Policies 2.17 and 4.4 and draft London Plan Policy E6 and Lewisham Council should provide evidence of a plan led approach to SIL consolidation before any residential use can be supported. Notwithstanding this, the inclusion of industrial uses is supported, but the applicant must demonstrate that the

page 12 industrial floorspace meets market requirements for the proposed land use and the B1c, B2, and B8 use should be secured in perpetuity • Affordable housing: 35% by habitable room with a 63:37 split in favour of affordable rent. This does not meet the 50% threshold for industrial land under the Fast Track Route set out in the draft London Plan Policy H6. GLA officers have robustly interrogated the applicant’s submitted viability and have provided comments which must be addressed before stage 2. • Design: Further discussion is required on aspects of residential quality, viability of the industrial floorspace design to meet proposed industrial user requirements and the design of the cycle parking access. • Climate change: Once all measures to minimise on-site carbon savings have been exhausted an appropriate contribution to the borough’s carbon fund should be secured, in compliance with Policy 5.2 of the London Plan and Policy SI2 of the draft London Plan. The proposed surface water management strategy does not comply with London Plan Policy 5.13 (and draft Policy SI.13) and further revisions are required. • Transport: The applicant must address issues with respect to pedestrian access and public realm design; car and cycle parking; London Overground and substation safeguarding; trip generation, vehicle servicing and impact on buses; Travel Plan, construction logistics plan and Legible London signage should be secured.

for further information, contact GLA Planning Unit: Juliemma McLoughlin, Chief Planner 020 7983 4271 email: [email protected] John Finlayson, Head of Development Management 020 7084 2632 email: [email protected] Katherine Wood, Principal Strategic Planner 020 7983 5743 email: [email protected] Jonathan Aubrey, Case Officer 020 7983 5823 email: [email protected]

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