planning report 2453/01 10 June 2009 former Samas Roneo factory, Maiden Lane, in the Borough of Planning application no. 09/00334/OUTM

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

The proposal Detailed planning application for redevelopment to provide a new gymnasium (Class D2) with associated parking, landscaping and a new access and outline planning permission for up to 254 residential units (illustratively 86 x 1-bed, 74 x 2-bed, 23 x 2-bed, 41 x 3-bed, 30 x 4 bed including a mixture of flats and houses) and associated landscaping areas and green open space.

The applicant The applicants are Barratt Homes and Europa Gym Club, and the architect is Formation Architects.

Strategic issues This application raises significant strategic concerns regarding the loss of industrial land and its change of use to residential and leisure uses. If the site is released from industrial uses, the site has many constraints that require various and numerous mitigation measures and/or further information.

Recommendation

That Bexley Council be advised that the application does not comply with the London Plan, for the reasons set out in paragraph 161 of this report; but that the possible remedies set out in paragraph 163 of this report could address these deficiencies.

Context

1 On 6 May 2009 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 11 June 2009 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.

page 1 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 and 3E of the Schedule to the Order 2008. The categories are as follows:

• 1A ”Development which comprises or includes the provision of more than 150 houses, flats, or houses and flats”; and

• 3E “Development (a) which does not accord with one or more provisions of the development plan in force in the area in which the appliaction site is situated; and (b) comprises …the provision of more than 2,500 square metres of floorspace for a use falling within …(xii) class D2 (assembly and leisure)”.

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 environmental information for the purposes of the Town and Country Planning (Environmental Impact Assessment) (England and Wales) Regulations 1999 has been taken into account in the consideration of this case.

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

6 The site has an area of 6.3 hectares and is located within the Crayford Industrial Estate on the eastern edge of Crayford. The site is bounded to the north by the River Cray (identified as a Metropolitan Site of Importance for Nature Conservation (SINC) and to the east by Crayford Marshes which form part of the Green Belt. Part of the site is also subject to protection as an area of Metropolitan Importance for Nature Conservation. Beyond the River Cray to the north is the residential area of Road. The southern boundary is defined by the London- - railway line and further south by the low-density residential area of Gable Close. The land to the west of the site contains established industry within the Crayford Industrial Estate, known as the Acorn Industrial Park. Maiden Lane forms the eastern boundary, while land on the eastern side of Maiden Lane is the aforementioned Green Belt.

7 The site contains a range of industrial buildings which have been vacant since 2001 when the operator Samas Roneo (office supplies) vacated the site. There are associated areas of car parking and hard surfacing.

8 The principal access to the site is off Maiden Lane, this entrance runs east-west across the site to the Acorn Industrial Park and also within to the industrial buildings. A disused gated emergency access severs the access into the Acorn Industrial Park. Land has also been raised here for flood protection purposes.

9 The site is identified in the Bexley Adopted UDP as a Primary Employment Area and is part of a Strategic Industrial Location (Industrial Business Park) within the London Plan.

10 The site is also within the boundary of Bexley Council’s Crayford Strategy and Action Plan (2005), where the site is identified with an ongoing, non-retail employment function. The disused access between the Samas Roneo site and the adjoining Acorn Business Park is identified as a

page 2 priority for improved access. The Plan recognises there is potential for industrial release in the area, although an area of land directly adjacent to the town centre.

11 The emerging policy documents that form part of the Local Development Framework, identify the site still forms part of designated primary employment area.

12 Running west to east, within the northern part of the site are several large electricty pylons.

13 The vacant site is located at more than 1km away from Crayford railway station and 2.5 kilometres from Dartford mainline railway station. Despite being on the eastern edge of Crayford town centre, the site is also poorly accessible by bus as Maiden Lane is not served by any existing bus route. The nearest services located within an acceptable walking distance from the site are Routes 96 and 428 operating along Crayford Road and Route 492 serving Crayford Way. The nearest part of the Transport for London Road Network is the A2 East Rochester Way located approximately 2.5 kilometres to the south-west whilst the nearest section of Strategic Road Network is the A207 Roman Way, approximately 700 metres to the west. As a result of this location, the site currently records a very low public transport accessibility level of 1b, out of a range of 1 to 6 where 6 corresponds to a high accessibility site.

Details of the proposal

14 This planning application comprises two main land uses, a new gym (use class D2) and 254 residential dwellings. There are also associated access roads, car parking, landscaping and green spaces. It is proposed to demolish all the vacant industrial buildings. Considerable earthworks are also proposed, this includes ground remodelling to create a re-graded area within the southern part of the site and a naturalised floodplain within the northern part of the site. This re-grading is proposed for flood protection purposes and will raise the ground level to 4.5 metres above ordnance datum (AOD).

The Europa gym

15 The gym application has been made in detail, with no matters reserved.

16 The proposed gym has a floorspace of 3, 208 sq.m., and will re-provide an existing facility known the Europa gym which is currently located on Fraser Road in . The gym is to located on the western boundary of the site. The gym is elevated on stilts above car parking below. The elevated design is the buildings response to the flood risk. Eighty-two car parking spaces are proposed. Thirty-five bicycle spaces are proposed. The main entrance to the gym is via a ramp along the front of the western elevation. To the front of the proposed gym is an area of parkland.

17 It is necessary for the Europa gym to move from its current location in Erith, given substantial increases in rent that are due to take effect in August 2010. Additionally, as the current building is only available on a lease, the gym struggles to get funding from external organisations who cannot be convinced of the on-going operation of the facility.

18 The owners of this not-for-profit organisation established the gym in 1992 and it provides coaching for gymnastics, boxing, weight lifting and martial arts. The existing gym is an industrial estate and has various limitations that restrict its function. The applicant puts forward that the building is neither tall or wide enough for various gymnastic events, such as the vault; it also does not have sufficient space for accommodate spectators and the building has generally becoming unfit for purpose.

page 3 19 The new gym proposes, two main halls for gymnastic disciplines and training studios for boxing, martial arts, weight lifting, dancing and supervised play. Retractable seating is to be provided in the gymnastic halls which could accommodate up to 690 spectators.

20 The operators of the Europa gym hope that the gym will become a training facility for the 2012 Olympics.

21 The gym will be accessed from Maiden Lane via the existing vehicular access towards the north of the site.

The residential use

22 This application has been made in outline. The applicant puts forward that the proposed level of affordable housing is 35% (on a unit basis), in line with Bexley Council policies. This equates to 40% provision by habitable room and 42% on floorspace.

23 The following table illustrates the proposed housing mix:

Market Social rent Intermediate TOTAL

1-bed flat 71 0 15 86

2-bed flat 66 0 8 74

2-bed house 5 14 4 23

3-bed house 13 28 0 41

4-bed house 10 20 0 30

TOTAL 165 62 27 254

24 This represents a tenure split, within the affordable housing of 70 social: 30 intermediate.

25 The residential properties will be accessed from Maiden Lane via a new vehicular access in approximately the middle of the site. This vehicular access is lined by a row of car parking on each side. Accessed off this main road are a series of short through roads, also with parking on either side.

26 The residential buildings range in height from two storey houses in the south of the site up to four storey blocks of flats along Maiden Lane and the main vehicular access.

Other elements of the scheme

27 The site will also have significant areas of open space and landscaping. The north of the site, along the banks of the River Cray and the River Wansunt, is designated as a Site of Metropolitan Importance for Nature Conservation. It is proposed that this area will be cleared of the invasive species and a new timber boardwalk will be erected to the south of the River Wansunt from Maiden into the site. In the future there is potential that this boardwalk could link into the Cray Riverside Walk and the London Outer Orbital Path 1.

28 A park will be provided which is approximately in the centre of the site. This will include defined and undefined areas of children’s playspace, and a wetland area and swales. The wetland

page 4 and swales will incorporate sustainable urban drainage systems and a vegetative buffer to the residential development. It is mentioned that there is enough space to provide a 5-aside football pitch, but it is unclear is this is to be provided. Case history

29 The site was previously used for manufacturing and employed approximately 250 – 260 people. The site has been vacant since June 2001.

30 In September 2004, the former Mayor considered (PDU/0985/01) a mixed-use development comprising industrial units and office space and 350 residential units. At that time, significant concerns were raised about the proposals, in particular the fact the mix of uses was not in accordance with planning policy which sought to retain employment uses on the site. This application was withdrawn before a decision was made.

31 In November 2005, the former Mayor considered (PDU/0985a/01) another application. This application proposed a residential development with 442 dwellings. This application was also considered contrary to the London Plan, particularly in relation to employment policies that did not support the loss of employment uses from the site. This application was also withdrawn before a decision was made. Strategic planning issues and relevant policies and guidance

32 The relevant issues and corresponding policies are as follows:

• Mix of uses London Plan • Employment London Plan; PPG4; draft PPS4; Industrial Capacity SPG • Retail/Leisure London Plan; PPS6; PPG13 • Housing London Plan; PPS3; Housing SPG; Providing for Children and Young People’s Play and Informal Recreation SPG • Affordable housing London Plan; PPS3; Housing SPG • Density London Plan; PPS3; Housing SPG • Urban design London Plan; PPS1 • Access London Plan; PPS1; Accessible London: achieving an inclusive environment SPG; Wheelchair Accessible Housing BPG; Planning and Access for Disabled People: a good practice guide (ODPM) • Transport London Plan; the Mayor’s Transport Strategy • Parking London Plan; the Mayor’s Transport Strategy; PPG13 • Green Belt/MOL London Plan; PPG2 • Biodiversity London Plan; the Mayor’s Biodiversity Strategy; Improving Londoner’s Access to Nature: Implementation Report; PPS9 • Ambient noise London Plan; the Mayor’s Ambient Noise Strategy; PPG24 • Sustainable development London Plan; PPS1, PPS Planning and Climate Change Supplement to PPS1; PPS3; PPG13; PPS22; the Mayor’s Energy Strategy; Sustainable Design and Construction SPG • River Thames/flooding London Plan; Mayor’s draft Water Strategy; PPS25, RPG3B

33 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 2004 Bexley Unitary Development Plan and the London Plan (Consolidated with Alterations since 2004).

page 5 34 The Crayford Strategy and Action Plan adopted by Bexley Council as Supplementary Planning Guidance in July 2005 is also a relevant material consideration for this application.

Mix of uses Loss of employment use

Quantity

35 The London Plan identifies ‘strategic industrial locations’ as a means of promoting and managing industrial and storage/distribution uses. The London Plan and the associated Industrial Land SPG aims to reconcile demand and supply and to take account of industry’s needs in terms of clustering, capacity, environment, accessibility and cost requirements. The application site falls within a strategic industrial location, of the ‘industrial business park’ category. Industrial business parks are areas where companies need a relatively good environment to operate. This site is within one of only five industrial business parks in East London.

36 Policy 3B.4 of the London Plan states that the Mayor will “promote and manage and where necessary protect the varied industrial offer of the SILs…as London’s strategic reservoir of industrial capacity”. The London Plan, together with the supporting supplementary planning guidance, reaffirms the policy approach to sustaining the strategic reservoir of industrial supply. In accordance with the overall approach to ‘planning, monitoring and managing’ development, changes to the strategic industrial location framework should therefore only be undertaken in light of strategic and local reviews of industrial capacity and supply. Any departure from this approach, could send a confused message to developers and can increase the ‘hope value’ of the employment land, making it uncompetitive for industry or could even lead to it being kept vacant and out of productive use, in the hope that it will be released for other purposes over time.

37 Accordingly, the general policy stance is to protect SIL for employment purposes. The Industrial Capacity SPG does however, make reference to the fact that within the North East and South East of London there is ‘scope for strategically coordinated further release from some SILs’. The same SPG also identifies that within Bexley, an approach of ‘managed transfer of industrial sites’ can be applied. The submission of this planning application, is not however, a basis for a strategically coordinated release programme.

38 Bexley Council has assessed possibility of releasing industrial land in the Crayford area, within the Crayford Strategy and Action Plan and within emerging local development framework. Accordingly, there is land that has been earmarked for release further to the west of this Maiden Lane site. This has been identified for retail/leisure/employment uses. The Samas Roneo site on Maiden Lane is not part of the land currently planned for release.

39 Within this context, the planning application has been supported by a report entitled ‘Employment Land Supply and Demand in Bexley’. This report provides a strategic overview of employment land in the area, namely drawing upon the GLA commissioned study entitled ‘London Industrial Land Release Benchmarks’ and the GLA’s Industrial Capacity SPG. The evidence put forward, identifies that within the South East sub region, Bexley has the largest stock of built on land, the largest amount of vacant land and the largest proportion designated as SIL. These statements are not opposed.

40 The study then analyses the local employment land supply and demand. This looks at both Bexley and Dartford borough (which is nearby to the subject site). The report concludes that over the next 10 –15 years, the overall requirement for manufacturing floorspace and employment land

page 6 in Bexley and Dartford is expected to decline given the changing nature of employment and land requirements. For example, there are changing work practices and revised employment densities for manufacturing.

41 The GLA’s ‘Industrial Capacity’ report indicates that within Bexley the demand for industrial land is to decrease by 45 hectares up to 2026. Although, these figures do not specifically identify how much of this land should be SIL, there general assumption is that some of this industrial land release will be SIL.

42 Within the applicant’s study, it is interesting to note that the supply of industrial space is growing as new space is constructed or in the planning pipeline, which would appear to give some indication of demand for new facilities. This aside, it is the conclusion of the applicant is that there is enough employment land to meet supply in quantitative terms.

43 It is unclear whether the submitted information takes into account the large ‘windfall’ industrial site within Bexley, namely the 64-hectare Prologis or Howbury Park Strategic Rail Freight Interchange, which has granted planning permission on appeal several years ago. This site was designated as Metropolitan Open Land but gained planning permission for industrial uses, for amongst other reasons, the strategic need for rail freight interchange facilities in London. The provision of this facility introduces even more industrial land into the area. This matter should be clarified.

Quality

44 A qualitative assessment of the supply of land has also been undertaken. This has been used as a way of ascertaining the relative attractiveness and suitability of land for employment uses. The key feature of this site which appear to let the site down in terms of attractiveness when compared to other sites, is the poor accessibility. The poor accessibility is related to the presence of a single-lane tunnel under the railway lines to the south of the site on Maiden Lane and the presence of narrow residential streets to the north. It is also noted that in relation to other sites, it is the environmental quality of the site which also performs badly. It would appear that environmental quality of the site is based on a combination of factors including the age and quality of the buildings; noise and other pollutants; state of external areas and parking and internal circulation.

45 The access issue has over the past few years been consistently referred to as the main problem facing the re-use of the site for industrial purposes. Within the Crayford Strategy and Action Plan, and through involvement by the London Development Agency, it has been a strategic priority to improve access through the facilitation of opening up the access on the western side of the site. Unfortunately, the planning application does not appear to make reference to attempts to explore improving the access of the site, which could improve the attractiveness of the site for industrial purposes. Further information should be provided as to what attempts have been made to try and overcome this access problem.

46 As recently as November 2008 the ‘Bexley Employment Land Study’ states that the access issues that effect the former Samas Roneo site would be best addressed through opening up the access into the Acorn Estate.

47 There are obvious issues with opening up the access to the site, namely the co-operation of the adjoining owner of the adjacent Acorn Industrial Estate (Schroders). Opening the access through to the former Samas Roneo site, is presumably only attractive to the Acorn Estate if it is planning on extending itself into the currently vacant site. If it were not planning on extending, the re-use of the Samas Roneo site might prove to be competition to their own operation, with all the inconvenience that increased traffic movements through the Acorn Estate would bring. There

page 7 are presumably also private property issues as the owners of the respective sites would need tonegotiate on an appropriate sales price or lease agreement.

48 Similarly, there is also a disincentive for the owners of the Samas Roneo owners to open up this access, as by doing so, the access problems would be lessened and the argument for the site to be released from employment use would be weak. This relates to the ‘hope value’ referred to in the Mayor’s Industrial Capacity SPG. There is no indication from Bexley Council that it has any intention to adopt the access roads of the Acorn Industrial estate.

49 While all these issues are appreciated, the application submission should include a full analysis and commentary of efforts made to over the access limitations over the years. This should include details of previous meetings/discussions/written correspondence between the landowners as they attempted to open access into the Acorn Industrial Estate. It is not acceptable in strategic planning terms, to set this issue aside without thorough justification as improving this access is identified as a strategic priority within the Crayford Area and Strategy Plan and the industrial land use is offered a high level of protection in local, regional and national planning policy. Comments from Bexley Council would also be useful in this respect.

50 To qualify the difficulties in re-using the site for industrial uses, the applicant has provided information on the marketing of the site. This includes details of when advertisements where placed in relevant journals, marketing boards and preparation of marketing brochures. No evidence of these were actually supplied, but the activity is recent up until June 2008. There appears to have been reasonable levels of interest in the site but these efforts have not yet proved successful. The feedback from those viewing the site or the site’s marketing information, is that the site suffers from poor access and the existing buildings are in a poor condition. In November 2007, an offer was made but at an unrealistically low level.

51 While the information on the efforts to market the site for industrial purposes are useful, further information is required to confirm the appropriateness of the approach. Such information should include copies of any of the adverts placed in the Estates Gazette (and similar), but more importantly details of the sale or lease price the site has been marketed at. The price should reflect realistic prices for an industrial site and not be inflated in light the hope value attached to the change of use.

52 This further marketing information and that on the potential site access will help justify the loss of the employment site, although in relation to strategic planning policies for the area, the loss of the employment use from the site would impact on the integrity of this patch of SIL. The apparently successful Acorn Industrial Estate and the adjoining Crayford Industrial Estate, would become a more isolated pocket of SIL, particularly in light in the development plan lead release of SIL further the west.

53 In summary, the loss of the site from SIL does appear contrary to London Plan policy 3B.4. The loss of the Samas Roneo site from SIL needs to be further explored in light of access to the adjoining Acorn Estate and, if this cannot be progressed, the evidence relating to the marketing of the site needs to be more robust. Having said this, the applicant has provided compelling evidence that the site is not suitable for on-going employment use as a result as the restricted site access and there is potential for loss of SIL in Bexley given the amount of space available on sites which are of a higher quality.

54 The loss of the SIL use should not be considered in isolation of the replacement uses that are proposed, in this instance, it is the Europa (leisure use) and residential accommodation. These uses will be considered now in turn, however, it is important to note that the issue with restricted site access that impacts on the industrial use is also relevant to these other uses, which although

page 8 will not be served by heavy goods vehicles, will still have the potential to generate significant vehicular trips.

55 There are also site constraints which are less significant to the industrial use but have more of an impact on non-industrial uses, namely the flood risk, presence of the power pylons, neighbouring industrial uses, distance from the town centre and low public transport accessibility. Provision of leisure use

Need

56 The proposed Europa gym is currently located in the industrial area of Fraser Road in Erith. The gym was founded in 1992 and is described within the supporting information as “a not-for profit organisation…which provides extensive community-based leisure and sports facilities for local youths and adults”. One of the key sports offered is gymnastics with the services of top coaches Len and Yvonne Arnold, who are currently training youngsters with potential for Olympic selection in 2012. Letters of support for the club and the new facility have been included within the application submission, these are from English Gymnastics, London Gymnastics Federation and British Gymnastics.

57 As well the gymnastic coaching, there is high level coaching in boxing, judo, weight lifting and karate. There are also community sport/leisure classes and coaching including recreational gymnastics from pre-schoolers to adults, the only permanent special needs gymnastics facility in London, disco and street dancing and yoga. The existing gym has 1,400 members, of which 95% are under the age of 18 years old.

58 The on-going operation and range of these type of facilities provided by the club are strongly supported by London Plan policies 3D.6 ‘The Olympic and Paralympic Games and sports facilities’. However, the same policy and PPS6, require leisure applications to be supported with a by a leisure assessment. PPS6 considers leisure facilities as a town centre use, and if such proposals are not within town centre it is necessary to assess the need for the development, to assesses the appropriate scale of development, apply a sequential approach to site selection, assess impact and to ensure the location of such facilities is accessible. The requirements of policy 3D.6 are along similar lines.

59 The applicant contends that as it is a replacement facility then the establishment of need is in many ways not required. The existing facility has numerous members and long waiting lists and provides relatively specialist services. These factors are very persuasive in respect of need. This aside, a needs assessment has been undertaken, which provides details of the catchment area of the existing members that extend from Erith, Crayford and and Dartford. Some members who are training for British/Olympic teams do travel from further a field in the United Kingdom.

60 The assessment lists other gyms and specialist clubs in the area, some of which offer similar services but none of which offer the same range of services. This relates to the gymnastic, boxing and weight training activities. The applicant also highlights the level of teaching as a unique element of the club.

61 The great work of the club and its importance to both athletes and the general public, particularly young persons, is highly supported and the need to get and retain the participation of young people in sport and leisure activities is highlighted as a Mayoral priority within the Mayor’s recent document ‘A sporting future for London – April 2009’.

page 9 62 There seems no question that the facility is needed and the deficiencies of the existing building both financially and practically is accepted as evidence that it needs to move from its existing location within Erith. However, from a planning policy perspective it is important to consider whether the replacement facility needs to be located on SIL.

Site selection

63 PPS6 prioritises the provision of leisure facilities within a town centre. It outlines that a sequential site assessment process should be undertaken which town centre locations are sequentially preferable. This application is supported with a sequential test, based on sites within Erith and Crayford, where the main bulk of the members are from. All sites were considered that were within the Major District Centre and those that are within a 300 metre walking distance of the Major District Centre boundary. The existing Fraser Road site for the gym is out-of-centre and also SIL.

64 Given the uniqueness of the facility in terms of training facilities, the applicant has discounted the prospect of diseggregation of uses, i.e. dividing the gymnastic use off from the other training facilities. This is approach is reasonable, particularly in light of the effectiveness of the training facility.

65 The sequential test submitted is not robust. Many sites are discounted on the basis of size of the site or the dimensions of the existing industrial buildings. However, it is not apparent anywhere within the document what the size requirements of the gym would be, either in square metres or building height/width etc. Another is discounted on low accessibility, although no comparison to the very low accessibility of the Samas Roneo site is provided. Other sites have planning permission for other uses and are therefore not available and are accordingly discounted. Others are discounted as they are only available on a lease-hold basis, and would suffer the same funding issues as the current site.

66 However, the most important reason for discounting a site is referred to within the assessment of the site called the Tanner Works Site. The submitted report states “Whilst the site could accommodate the proposed gym building, the site is not viable for the proposed development as a whole. The provision of the gym building to Europa Gym Club is based on the provision of a significant residential element. If this significant housing element cannot be provided, the gym building cannot be financed”. Essentially, the site selection process does not relate to just the gym, but to the residential accommodation. In this way, the process is somewhat unrealistic given the interlinked nature of the Barratt’s housing development to the provision of the gym. The applicants have not assessed whether the gym could be provided within a sequentially preferential town centre site, with the ‘enabling housing’ being elsewhere (including Samas Roneo).

67 This approach undermines the viability of the sequential test. Although, it does highlight the practical issues relating to the provision the gym. The Europa Gym requires a new site, which Barratt Homes is prepared to offer. Barratt Homes will offer a further £1.5 million of funding. Obviously, such an offer is incredibly attractive to Europa Gym. The planning system should not operate completely independently of these commercial/practical realities and the offer by Barratt’s and the benefits for the Europa Gym of relocating to this site are noted.

68 The fact the gym is not a commercial enterprise and is unlikely to be able to afford a town centre site, where it would have to compete against commercial leisure uses and other appropriate town centre uses (including residential) is a material consideration. Further certainty on delivery is essential if the presence of the sym is a factor in deciding if the loss of industrial land is acceptable.

page 10 Gym funding

69 As part of this development the gym site will be given freehold to the Europa Gym. Barratt Homes have valued this site at £800,000. The provision of the site, will obviously very much help the gym and is a substantial saving to having to acquire itself. As above, the gym will also receive a further £1.5 million from Barratt’s and it is stated that a further £500,000 will be provided by British Gymnastics. This raises the issue as to where the other £4 million required to get the new gym up and running, will come from. Further information should be provided on what other sources of funding are available for the gym, including confirmation of the money from British Gymnastics. Given such a large shortfall in funding, until this information is supplied, there is no certainty that the gym can be delivered.

70 Additionally, as well as establishing the gym, the long-term operation of the gym is also questioned. It is clear that the existing gym has struggled financially, which maybe entirely the result of the current lease arrangement. However, to ensure the long-term viability of the gym for the Olympics and beyond, the applicants should submit a business plan that outlines how revenue will be generated into the future including public funding and membership income etc.

Suitability of the site for leisure use

71 Setting aside the issue of the fact this leisure is not within a sequentially preferential town centre site, there are questions raised over the suitability of the site for the gym use. Although the gym will benefit from generous grounds and use of the park, the site is remote from public transport and has the potential to suffer from flooding. The flood risk issue has been dealt with the provision of a building elevated on stilts, this is discussed within the flood risk section of this report.

72 As mentioned, policy 3D.4 of the London Plan seeks leisure uses to be preferably located in town centres, have good access by public transport, cycling and walking and be accessible to all sections of the community. While the premise of the Europa Gym is supported in line with policy 3D.4, the suitability of the location for such a facility is questioned. As outlined in full within the transport section of this report, the proposed gym will have a very low public transport accessibility level and is a difficult and long walk from the town centre. This seems far from ideal, particularly for a facility that is predominately used by children. The location of this gym would appear to almost guarantee that all children are dropped off at the site by car, which is contrary to policy 3C.2 ‘Matching development transport capacity’. Although the further information requested in the transport section below, may help better justify the proposal, it seems this facility which could have a membership of up to 3000 members, would almost always rely on car journeys to get members to and from the site. Housing

Suitability of the site for residential uses

73 Besides the policy designation as an SIL, as outlined within the site description, there are also several physical characteristics of this site that limit the attractiveness of the site for residential uses. These factors are as follows:

• The high flood risk (see paragraphs 138 - 143 of this report); • The public transport accessibility is low, which is compounded by the poor access on Maiden Lane through a single lane road under the railway lines;

page 11 • The site is adjacent to a industrial business park (see paragraphs 131 – 137 of this report relating to noise); • The air quality is low (see paragraphs 153 - 156 of this report); • In the north of the site is a series of large power pylons.

74 In relation to flooding, transport, noise and air quality as is outlined later in this report, there are potential measures that may mitigate the risks and problems outlined. Although, in many respects when so many matters require condition and mitigation, and detailed information on the proposed residential design is limited (given the outline nature of the residential scheme), there is no certainty that all such issues can be adequately addressed by the design. This is especially true of the noise and air quality issues.

75 The presence of the adjoining industrial estate is problematic on the grounds that any residential use on the former Samas Roneo site may compromise the ability of the industrial site to operate without disturbance to the residents. Additionally, if the owners of that industrial estate were to consider bringing a planning application site forward for residential uses on its site (on the basis that a better return might be on offer), the arguments to resist this would be significantly weakened and effectively the SIL in this location could disappear entirely.

76 The poor access, although limiting the ability of heavy goods vehicles to access the site from the south and north if the site were to stay as an industrial use, also affects residential access to south for the residential use.

77 Besides the impact on the SIL, the use of the site for residential properties does not appear to comply with policy 3A.7 ‘Large residential developments’ which seeks to promote large residential developments in areas of high public transport accessibility and where borough councils have prepared an appropriate planning framework.

78 The power pylons are at the northern end of the site, so at least the residential properties will be built as far as possible away from them. This distance should be confirmed. However, the pylons are unsightly and can emit the buzzing noise which many people find irritating. Although there are much reported ‘health risks’ of living close to pylons, there is no national planning guidance against the provision of residential properties near pylons.

Quantity and type of housing

79 The proposal will provide up to 254 dwellings. These are welcomed in terms of increasing London’s supply of housing, London Plan policy 3A.1.

80 Table 3A.2 of the London Plan outlines a density matrix for residential developments in light of factors such as the public transport accessibility level and location. This scheme has a density of 260 habitable rooms per hectare or 80 units per hectare. This density is slightly higher than the guidelines, which seek 150 – 200 hr/ha, although given that much of the site is not developable given the flood risk, the future residents will enjoy access to generous open space, many will have private gardens, and generous and diverse play space. Accordingly, the density is appropriate in this instance.

page 12 81 The Housing SPG has a preferred housing mix. The table below is a comparison as to how the proposal compares to the preferred mix:

Social housing preferred mix (SPG) Proposed housing mix

1-bed 19% 0%

2/3 bed 39% 67%

4-bed 42% 32%

82 The application does not specifically accord with this guidance, however, in this instance is it is acceptable. This is because the scheme provides a significant proportion of 3/4 bed units and many of the units are houses, as opposed to flats, and will benefit from private gardens. Accordingly, the scheme adequately complies with policy 3A.5 ‘Housing choice’.

83 The application would be strengthened by a commitment to decent unit and room sizes which should be supplied at this outline stage.

Affordable housing

84 London Plan Policy 3A.10 ‘Negotiating affordable housing in individual private residential and mixed-use schemes’ requires borough councils to seek the maximum reasonable amount of affordable housing when negotiating on individual private residential and mix-use schemes. In doing so, each council should have regard to its own overall target for the amount of affordable housing provision. Policy 3A.9 ‘Affordable housing targets’ states that such targets should be based on an assessment of regional and local housing need and a realistic assessment of supply, and should take account of the London Plan strategic target that 35% of housing should be social and 15% intermediate provision, and of the promotion of mixed and balanced communities. In addition, Policy 3A.10 encourages councils to have regard to the need to encourage rather than restrain residential development, and to the individual circumstances of the site. Targets should be applied flexibly, taking account of individual site costs, the availability of public subsidy and other scheme requirements.

85 Policy 3A.10 is supported by paragraph 3.52, which urges borough councils to take account of economic viability when estimating the appropriate amount of affordable provision. The ‘Three Dragons’ development control toolkit is recommended for this purpose. The results of a toolkit appraisal might need to be independently verified. As the application falls short of the 50% borough side target as required by the London Plan, the application is supported by a toolkit appraisal. This appraisal appears to outline an acceptable methodology for determining the appropriate level of affordable housing. Although, it is noted that the scheme appears to be specifically designed to accord with the 35% (on unit basis) requirement of Bexley Council. The tenure split of the affordable housing, does comply with the London Plan.

86 Barratt Homes have put forward that Gallions Housing Association will be the registered social landlord involved in the provision of the affordable homes. However, within the appraisal, it is mentioned that Barratt/Gallions were entering into discussion with the Homes and Communities Agency (HCA) as to the level of grant subsidy that will available. Further information is requested as to how these discussions progressed and whether there is any further update on the level of affordable housing. As it stands, it is not clear how the levels of grant offered impact on the toolkit appraisal.

page 13 87 Overall the 40% level of affordable housing (habitable room basis), the tenure split of that affordable housing and the associated toolkit appraisal appear to provide a reasonable approach to compliance with London Plan policies 3A.9 and 3A.10. However, before full support can be offered, further information regarding the level of grant funding and the latest discussions with the HCA and Bexley Council is required.

Children’s play space

88 Policy 3D .13 of the London Plan sets out that “the Mayor will and the boroughs should ensure developments that include housing make provision for play and informal recreation, based on the expected child population generated by the scheme and an assessment of future needs.” Using the methodology within the Mayor’s supplementary planning guidance ‘Providing for Children and Young People’s Play and Informal Recreation’ it is anticipated that there will be approximately 168 children within the development. The guidance sets a benchmark of 10 sq.m. of useable child playspace to be provided per child, with under-5 child playspace provided on-site. As such the development should make provision for 1680 sq.m. of playspace.

89 This development does provide significant open space in the form of the park and three separate areas of under 5 children’s play (880 sq.m.). There is also space demarcated as local play space for children aged 0-11 years old and youth space for age 12+. In total, the amount of playspace, excluding the park, is 3440 sq.m. with another 5,950 sq.m. if the park and woodland walkway are included. This generous provision is welcomed and is a pleasing aspect of the scheme. These areas should be secured by condition on any planning permission.

90 As the details provided on the layout and management of the spaces are only in writing at this stage, a future condition should also seek more specific plans on these issues. Summary on land use issues

91 As outlined above, the site is within protected strategic industrial land and normally should only be removed from such a designation during a plan led process. While there is a general acceptance that there is scope within Bexley Council to lose some of the SIL land, at present there is no indication within any adopted or emerging planning policies that this particular site, should be one of those sites lost. The loss of this site from SIL may impact on the viability of this entire pocket of SIL including the Acorn Industrial Estate.

92 However, the applicants have highlighted various problems with the re-use of this site for industrial purposes namely the poor access and the availability of other more desirable industrial land. Additionally, by granting planning permission for the Howbury Park Rail Freight Interchange, an additional 64-hectares of industrial land, which was previously not designated as industrial land, is also available to the area.

93 Further commentary on efforts made to progress the improved access to the site from the adjoining industrial estate is required from both the applicant and the Council, given that the Crayford Area and Strategy Plan identifies this access as a strategic priority. While it is appreciated that the site been vacant since 2001, further information on the marketing of the site is requested to ensure that all reasonable endeavours have been made to keep the site in industrial use.

94 Assuming that this information can be satisfactorily addressed and it becomes clear that improved access to the site is not possible, despite strong policy reservations, it seems pragmatic to consider an alternative use on the site.

95 The re-provision of the Europa Gym within Bexley is strongly supported, given the important role this facility offers to athletes and the community alike. The work of the gym owners

page 14 is strongly applauded. While the selection of this site in planning terms has not been made on a robust basis, there are clear and practical advantages of the gym being located on this site, these advantages are primarily financial, as the site will be given to the gym by Barratt Homes. However, there are concerns raised on the low accessibility of the site that are further outlined in the transport section of this report and there is general assumption that most parents will drop their children at the gym by car. The gym travel plan may help mitigate this issue, but the site is remote and difficult to get to, especially from the south.

96 To provide further comfort that the gym will be delivered and its operation on-going, further detail on options on how the £4 million funding shortfall will be met and the business plan for the gym are requested. The application states that the gym will only be provided if planning permission for the residential accommodation is also granted.

97 Besides planning policy conflicts, there are many site constraints that limit the attractiveness of this site for residential uses. These constraints are mostly environmental or access related (again, this will be addressed elsewhere in this report), although the access problems are less pronounced as those associated with industrial uses. Mitigation measures are proposed to create a more suitable setting for residential accommodation including a design which responds to the flood risk, noise, flood protection work, the proposal offers generous open space and relatively low density housing.

98 Subject to the information requests and the other issues raised in this report, there would appear to be an opportunity for a pragmatic strategic decision. This decision would require weighing up the options as to whether the re-provision of the gym with all the benefits it provides to young people and its role leading up to the 2012 Olympics, outweighs the loss of the industrial site and relatively limited attractiveness of the site for residential uses. The long-term vacant nature of the site and the limited industrial access are major considerations in making this decision. At this stage, insufficient information has been provided to allow this decision to be made and in line with London Plan policies, the industrial land designation should remain. Urban design

99 Good design is central to all objectives of the London Plan and is specifically promoted by the policies contained within Chapter 4B which address both general design principles and specific design issues. London Plan Policy 4B.1 sets out a series of overarching design principles for development in London. In addition to Chapter 4B, London Plan policies relating to density (3A.3) and sustainable design and construction (4A.3) are also relevant.

Site layout

100 Subject to comments from Transport for London, regarding the additional entrance on to Maiden Lane, the general principles of the site layout are supported. The provision of the large riparian buffer area, the reasonable size of the open space and the provision of the housing as far away as possible from the river, are all supported.

101 Unfortunately, there is a lack of clarity about the function of the main access road. At present, it appears to function largely as a car park and is somewhat disappointing as the main spine through the site. Other options for providing the car parking should be explored. The relationship that these parking spaces will have the adjoining residential flats should be provided. The level difference here should help, but sketch images would confirm how this relationship would work

102 In general, the road and areas of hard surfacing, particularly through the provision of the 90-degree parking, appear overly wide. This hardsurfacing should be minimised, this is particularly

page 15 prevalent in front of the flats on the far east of the site, where there appear to be two directly adjacent road/homezones separated by carparking spaces and prominent bin stores in the centre of the streets. This arrangement should be amended.

103 In the south of the site, houses back on to private gardens, which in turn back onto the vegetated strip towards the railway tracks. It should be made clear how this space been the gardens and the railway is to be treated. For security and ecological reasons, it is suggested that the space vegetated strip not be accessible to the public, although it is also recommended that larger gardens might be possible to better utilise the space, without compromising the ecological value of the vegetated strip. Provision of this information is required to ensure compliance with policy 4B.6 ‘Safety, security and fire prevention and protection’.

104 The provision of the river walkway and the park are welcomed. However, the paths through the site, particularly across the park, should be reconsidered to better provide for pedestrian desire lines.

The proposed gym

105 This part of the application has been made in detail, accordingly detailed floorplans and elevation drawings have been provided. The building has a simple box design, and is positioned on stilts to address the flooding issue. The use of the stilts in this location is acceptable, however there are several issues that this raises.

106 Firstly, it is unclear how the building will relate to the adjoining street to the south of gym. The south elevation shows that the car parking area under the building is open to the street. This could create a relatively awkward relationship between the parking area and street, particularly at night when the gym is closed. The approach does not adequately take into account secure by design issues. Details should be provided on the how the undercroft car park will be screened and secured should be provided.

107 Following on from this, the position of the lift access into the building is queried. At present, the lift is only accessible from the undercroft parking area. The lift will accordingly suffer from a lack of visibility for visitors and for those persons being dropped off in the drop off area, they will have navigate through the undercroft parking to get to the lift. This is unacceptable and does not accord with London Plan policy 4B.1 ‘Design principles for a compact city’ and 4B.5 ‘Creating an inclusive environment’. Various design solutions should be explored to overcome this problem, with potentially the lift being provided on the front or southern elevation where it would be more visible. Alternatively, the entrance could be moved to the northern end of the site with stair and lift/core being provided in the same location.

108 The ramp is also quite long and potentially relatively steep, and although rest points are shown on the layout plan these are not easily discernable in the elevation diagram. The gradient of the ramp should be provided and alternatives should be explored as the ramp. Further access issues are identified later in this report.

109 The simple elevations seem appropriate for this land use, although details of the proposed glazing system should be provided.

110 The gym does not appear to have any disabled parking spaces nor is it obvious where the disabled toilet, change and shower facilities are provided. These should be clearly annotated on the plans in accordance with policy 4B.5.

Residential design

page 16 111 As the application is made in outline only, little information has been provide on the elevations and general design quality. Although based on the design and access statement, which was submitted in support of the application, it is somewhat unfortunate that the overall design is not especially distinctive or original, with all of the buildings resembling many other recent residential developments around London and the UK. Future reserved matters applications should be made and assessed with this in made and improvements should be made. To help promote this application, the applicants may wish to commit to a design code.

112 The proposed buildings are of an appropriate scale and height within this setting. The provision of the 4-storey (tallest) elements of the proposal along Maiden Land and the main access road is supported.

113 Details of how the blocks of the flats relate to the ground and a commitment to private balconies/terraces should be provided. It is mentioned that low brick walls will help screen the ground floor flats, which is not ideal. Front gardens could help buffer flats from passers-by.

114 It is mentioned that all flats will be built to lifetime home standard and that 10% will be wheelchair accessible. This provision is welcomed in line with policy 3A.5 ‘Housing choice’ and should be secured as a condition on any the future reserved matters application.

115 Overall, the proposal does not comply with the design policies of the London Plan, particularly 4B.1 ‘Design principles for a compact city’, 4B.3 ‘Enhancing the quality of the public realm’, 4B.5 ‘Creating an inclusive environment’ and 4B.6 ‘Safety, security and fire prevention and protection’. The use of a condition will ensure compliance with policy 3A.5 ‘Housing choice’. Transport

116 In total, 257 car parking spaces are proposed for the residential element of the site and 82 spaces for the gym use. Whilst those standards would appear reasonable, the applicant is encouraged to consider reducing those levels further, particularly in light of the comments made earlier in this report on the design of the roads and car parking spaces.

117 A car parking management plan be secured by condition. Also the applicant should designate at least 10% of the total parking provision suggested for both uses, for blue badge holders, which should be designed in accordance with DDA standards. The applicant should also provide charging points for electric vehicles in line with the Mayor's essential standard set out in the Sustainable Design and Construction SPG.

118 No mention of cycle parking has been made in the transport assessment report and as such, all facilities be provided in line with Transport for London standards, to comply with London Plan policy 3C.22 ‘Improving conditions for cycling’. Within the planning application, it is noted that 35 spaces are proposed for the gym, however, further details are required on the exact location and proposed quantum, which is currently too low. Whilst the level of provision for the gym use should take into account and reflect the expected doubling of members over the next five years, all facilities, to be accommodated on site, should be secure, covered and easily accessible. The provision of CCTV coverage as an additional security measure should also be considered. The bicycle parking for the flats, including the number and the design of the shelters should be provided.

119 Given that the site has been vacant for almost eight years, the methodology presented in the Transport Assessment report in relation to trip generation and modal share is not appropriate and should be revised as further detailed in Transport for London’s initial comments on the application. It is proposed to mitigate the impact of the development on the highway network by improving the Maiden Lane/Crayford Way junction, which is supported. However, concerns remain

page 17 that the other two junctions will still operate over capacity and more importantly, no impact assessment of nearby strategic road network roads (Crayford Way junctions with Thames Road and Crayford High Street/Roman Way) has been carried out. It is particularly disappointing to see that this concern has already been raised by Transport for London in relation to previous applications for the site, and this has still not been addressed.

120 There is also a concern that if the development has any significant adverse impact on the highway network, there may also be an impact upon bus services in the area. The applicants are encouraged to address the above concerns and if congestion in the area is identified as having a detrimental effect on bus services, there is the expectation that some form of bus priority measures be provided by the applicants’ in the area in line with London Plan policies 3C.14 ‘Enhanced bus priority, tram and bus transit schemes’ and 3C.20 ‘Improving conditions for buses’.

121 Although a decrease in freight movements caused by the change of land use is expected for the site, no consideration has been given to how the site will be serviced. As further detailed in initial comments and to comply with the London Plan policy 3C.25 ‘Freight Strategy’, a Construction Logistics Plan and a Delivery and Servicing Plan, are requested to and secured by planning condition.

122 Given the above position on the trip generation exercise, it cannot be confirmed at this stage what the likely impact of the site on the public transport network, and particularly buses, will be. Given the location, the nature and scale of the proposals, it is anticipated that the development is unlikely to have a significant impact on rail services. If bus fleet or frequency alterations are required as a direct result of the proposal, the applicant should contribute towards bus capacity enhancement for the area in accordance with the London Plan policy 3C.2 ‘Matching development to transport capacity’.

123 Additionally, given that the development proposals is likely to generate additional bus trips, all existing bus stops located within a 400 metre radius of the site should be compliant with Transport for London’s accessibility standards. In the absence of any audit, a contribution of £30,000 per pair of stops is required, as commonly requested from new developments. This should be secured through the S.106.

124 Whilst the proposed financial contribution of £227,330 towards ‘Transport, access and public realm’ is noted, further discussions with Bexley and the applicants on the S.106 are sought. On receipt of the additional information requested, further comment can be provided on the acceptability of this sum and the subsequent level of S.106 monies, conditions and mitigation measures required can be provided.

125 Given the expected increase in pedestrian trips towards the south of the site along Maiden Lane, Transport for London raise serious concerns about the lack of safety of the proposed highway layout at the railway bridge, in accordance with the London Plan policy 3C.21 ‘Improving conditions for walking’. Whilst a minimum of 2-metre width footway is required, clarification on the pedestrian improvements planned at this particular location should be provided. As requested as part of the previous applications, information on the condition of surrounding pedestrian and cycle environment, particularly to key transport nodes such as the station and bus stops, should be submitted. Footways are also expected along the access road serving the gym and should be compliant with current accessibility standards, as are all nearby crossing points, with dropped kerbs and tactile paving. The ‘homezone’ type approach, the suggested pedestrian and cycle link from the site to Maiden Lane, is welcomed. Confirmation that this route will be at least 3 metres wide and appropriately segregated to minimise conflict between pedestrians and cyclists, should be provided.

page 18 126 Although the travel plans submitted as part of this application are both acceptable in their current form, the documents would benefit from a few minor improvements as further detailed in the previous comments on the application and to comply with policy 3C.2.

Biodiversity

127 The application site includes land within a Site of Importance for Nature Conservation (SINC) as identified through the adopted procedures for London. This is part of the River Cray Metropolitan SINC, in the north of the application site and beyond the proposed development area.

128 London Plan policy 3D.14 ‘Biodiversity and nature conservation’ is clear on the expectation of boroughs to strongly protect SINCs and populations of important species from negative impacts of new developments. The policy also expects new developments to seek opportunities to achieve positive gains for biodiversity conservation through the creation, enhancement and management of wildlife habitat and improving access to nature.

129 The applicant has submitted a detailed and extensive Ecological Impact Assessment (EIA) in support of the application. This assesses the risk of impacts on the Metropolitan SINC and includes surveys for the presence of legally protected species in the proposed development area.

130 The EIA finds there will be no significant impacts on the biodiversity value of the Metropolitan SINC. Protected species within the development area include reptiles (for which the site appears locally significant) and bats. The EIA presents various solutions to mitigate against the likely impacts on these species, and for the enhancement of the biodiversity value of the Metropolitan SINC. The proposed mitigation measures, as recommended in the EIA are in general compliance with 3D.14 and should be secured by condition. Ambient noise

131 London Plan policy 4A.20 ‘Reducing noise and enhancing soundscapes’ is concerned, amongst other things, with minimizing the existing and potential adverse impacts of noise on development proposals and seeks to separate new noise sensitive development away from major noise sources where practicable.

132 This submitted noise report provides information on noise levels by looking at three main sources in the area namely the road traffic, the railway, the adjoining industrial land use and noise from the proposed gymnasium.

133 The report concludes that noise from both the railway and road would require either limited degree or extensive mitigation to ensure that the indoor and external noise limits advised within the appropriate British Standard are met. This appears to include design features such as glazing but also garden walls are also recommended.

134 While the gym itself has not been found to be noisy, the report recommends that a maximum rating level of 42dB at the nearest affected property/dwelling is used a target whith the plant is selected.

135 In respect of the industrial estate, the assessment concludes that noise complaints from future residential occupiers are likely. Given there are no restrictions on operation of the industrial estate where activity could take place 24-hours a day, 7-days a week. The background noise levels on the boundary adjacent to the estate, were 5 decibels greater than the La90 background levels. One of the suggested mitigation measures was a 2 metre high barrier along the western boundary, although this was unlikely to be successful in reducing noise levels significantly. Instead, it was

page 19 suggested that a specialist glazing be provide, with alternative ventilation to enable windows to be kept closed at night.

136 The mitigation measures appear reasonable, although it cannot be ignored that the residents will from time to time suffer from noise disturbance. While not ideal, in the busy urban environment of London, this is perhaps not so unusual. However, the noise problems are of more of a concern if complaints lead to the situation where the operation of the industrial estate is prejudiced. The estate is within one of the borough’s protected industrial areas and is long established, the new residents to the area should be made aware of the existing unrestricted operation of estate by the use of informatives on any planning permission and Bexley Council should consider a condition that removes the right of complaint regarding noise.

137 The conditions should also include the recommended mitigation measures as summarized on page 15 of the noise assessment report prepared by Peter Brett Associates. Flood Risk

138 The site falls partly within Flood Zone 3a ‘high probability’. This is particularly important given the proximity of rivers that are known to have flooded and reports of previous surface water flooding at the site.

139 The main concern with the flood risk assessment is that it does not quantify tidal flood risk for this particular site. There is a risk of flooding in excess of 1-metre depth if the tidal flood defences were breached or overtopped. Unless the applicants demonstrate that the site can be safely developed, this could be a reason to refuse planning permission. At present the application does not demonstrate compliance with London Plan policies 4A.12 ‘Flooding’ and 4A.13 ‘Flood risk management’.

140 The flood risk assessment addresses fluvial flood risk in a number of ways. The gym application is in detail and will involve building on stilts to overcome the flood risk. This is acceptable. The housing element is in outline but appears to involve building on a raised platform to a height of 4.40m above ordnance datum. This is 370mm above the modeled 1 in 100 year + climate change fluvial flood plain and is acceptable in principle, subject to the resolution of the tidal flood risk issues.

141 The development now includes a safe access in the south east of the site, which is outside of the flood zone. A floodplain storage area is proposed in the north of the site. Additionally some enhancements to the northern part of the site, including ecological enhancement works and new accessible green spaces are welcomed.

142 A permeable block paving system, a green roof over the gymnasium and brown roofs over the majority of the roof space of the residential element is proposed. This is acceptable in accordance with London Plan policy 4A.14 ‘Sustainable drainage’.

143 The measures outlined above such as the access, the ecological enhancements and green spaces, floodplain storage, permeable paving, brown and green roofs should all be secured using a series of planning conditions.

Energy

Be lean

page 20 144 The baseline emissions for the development have been estimated to be 597 tonnes of carbon dioxide per annum. The baseline emissions for the development have been adequately calculated using building regulations approved modelling. The appropriate carbon emissions from non-regulated energy usages have been taken into account, i.e. appliances and equipment, in line with the requirements of the London Plan policy 4A.4.

145 A series of demand reduction measures to reduce carbon emissions beyond the baseline emissions have been provide. These include low energy lighting and lighting controls, more stringent insulation and air tightness standards than those required by current building regulations and mechanical and heat recovery ventilation systems for the gym.

146 These measures have been suitably modelled and have been estimated to reduce carbon emission by 14.5% beyond the baseline emersions. However, there does appear to be scope to further reduce the demand of the proposed houses. These should be explored to ensure compliance with London Plan policy 4A.3 ‘Sustainable design and construction’.

Be clean

147 The proposed development is located within a low-density area that, in principle, is not suitable for the development of site wide district heating network. There does not appear to be any available heat network to which the proposed scheme could connect, although it should be confirmed if there are any such networks being progressed as part of the Bexley Council’s Crayford Area and Strategy Plan.

148 The proposal includes a centralised heat supply using heat-generating plant. It would seem that all heating plant would be installed in a single energy centre. This heat network will serve both the residential dwellings and non-domestic buildings. Such a measure would be welcomed, however, it is not clear the extent to which the heat network will supply all residential units and further clarification is needed to ensure compliance with policies 4A.5 ‘Provision of heating and cooling networks’ and 4A.6 ‘Decentralised energy: heating, cooling and power’.

149 The proposed heat network will be partially supplied with combined heat and power plant. The combined heat and power plant has a capacity of 70 kWe and would save carbon dioxide emissions by a further 18%.

150 The energy statement has not provided much information on the proposed cooling strategy. These should be described, including the design measures incorporated to reduce/minimise or avoid the need for active cooling provision. This applies to all elements of the scheme i.e. flats, houses and the gym.

Be green

151 In line with policy 4A.7, a review of the potential renewable energy technologies has been provided. The proposals include the provision of a circa 170 kWth biomass boiler that would be operating along with the combined heat and power plant. The biomass boiler has been estimated to save carbon emissions by a further 12%. However, biomass boilers and combined heat and power are both usually a base load technology and considered incompatible. Further explanation of how the use of these two technologies will be successfully in tandem should be provided.

152 The development offers opportunities for the installation of photovoltaic panels for both the houses and blocks of flats. However, the applicant has stated that there are shading issues and that the orientation of the roofs are not suitable for the installation of photovoltatics. These reasons are not accepted as a suitable layout of the buildings should take these matters into account in the design process. This statement needs to better addressed, as the generation of

page 21 electricity with photovoltaic panels is likely to offer a good opportunity to contribute further to the 20% renewable target. Air quality

153 An air quality assessment has been provided as part of the application. This assesses both traffic and the impacts of the operation of the energy centre. The approach taken is relatively robust in relation to both sources of potential air pollution. The report concludes that the baseline air quality of the site is already poor, as it is for much of Bexley. The poor air quality appears to be linked to the busy junctions near the site, although this is not entirely clear. This should be clarified, as if the low air quality is a result of the location adjacent to the Acorn Industrial Park, a different approach may be taken.

154 The report surmises that the air quality may improve as a result of the application and the move away from heavy goods vehicles associated with the industrial use of the site. This statement should be given little weight as there has not been an industrial use on the site for many years and therefore the impacts of heavy goods vehicles will have not be included within baseline assessment of air quality.

155 However, the assessment does conclude that there is ‘no constraints to residential development at the site with regard to air quality’. This statement is broadly accepted, despite the comments above.

156 Before the application can be considered fully compliant with policy 4A.19 ‘Improving air quality’ the position of the chimney stack (as broadly illustrated in figure 4 of the ‘Air Quality Assessment’) in relation to the height of the proposed building and residential windows should shown on plan. Also the requested information on the reasons for the existing low air quality should be provided. Local planning authority’s position

157 Not known at this stage.

158 A letter of support from the Leader of Bexley Council relating to funding and securing a new home for the Europa Gym was provided with the application. This letter was addressed to the Minister for the Olympics. It was non-specific to this particular planning application. Legal considerations

159 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

page 22 160 There are no financial considerations at this stage.

Conclusion

161 London Plan policies on are relevant to this application. The application complies with some of these policies but not with others, for the following reasons:

• Industrial Land: The proposal is contrary to the London Plan policy 3B.14 relating to the management of Strategic Industrial Locations. • Leisure: The re-provision of the Europa gym is strongly supported in line with policy 3D.6, however, as yet there are outstanding issues which question the deliverability of the gym. The site selection process submitted is not robust and instead the gym is intrinsically linked with the proposed residential accommodation. • Housing: The proposal is contrary to policy 3A.7 as it is currently unsuitable for housing, a result of the employment designation and environmental factors. Having said this, the housing proposed is of an appropriate scale, density and unit mix in compliance with policies 3A.1, 3A.5 and table 3A.2. • Affordable housing: Further information is requested on the approach to social housing grant but it would appear the proposal may be able to demonstrate compliance with policies 3A.9 and 3A.10. • Urban design: at present the application does not comply with policies 4B.1, 4B.3, 4.B.5, 4B.6 and 3A.5. • Transport: There is a lack on information on cycle parking contrary to policy 3C.22. The methodology of the transport assessment is flawed. The proposal has not demonstrated compliance with other transport policies outlined in paragraph 116 - 126 of this report. • Biodiversity: The proposal adequately complies with London Plan policy 3D.14. • Noise: Subject to various conditions relating to noise mitigation, the proposal should be able to comply with policy 4A.20. • Flood risk: The scheme does not comply with policies 4A.12 and 4A.13. The provision of sustainable urban drainage systems and brown and green roofs is complies with policy 4A.14. • Energy: The energy assessment adequately addressed policy 4A.4, however, the proposal has not yet demonstrated compliance with other policies in chapter 4A. • Air quality: At present, it is unclear if the proposal complies with policy 4A.19. 162 On balance, the application does not comply with the London Plan.

163 London Plan policies on are relevant to this application. The application complies with some of these policies but not with others, for the following reasons:

• Industrial Land: Further detail on the marketing and efforts to improve the access to the site are required. • Leisure: Further details of the funding strategy and long-term business plan of the gym are required. • Housing: Further commitment is required to unit sizes and balconies/private gardens.

page 23 • Affordable housing: Further information is requested on the approach to social housing grant. • Urban design: Further details on the elevations of the gym and secure by design issues are required. The residential road/parking layout is queried and further information on the ways in which level differences will work are required. • Transport: Further information is requested as outlined in paragraphs 116 - 126 of this report. • Biodiversity: Planning conditions to secure the proposed biodiversity mitigation measures. • Noise: Various conditions relating to noise mitigation should be secured. • Flood risk: Further detail on tidal flood risk is required. Conditions are required to secure sustainable drainage and flood mitigation measures. • Energy: Further information is required on the use of CHP, biomass, energy efficiency measures and the heat network. The design/position of the biomass stacks is also queried. • Air quality: Further information is required on why the existing site suffers from low air quality and details of the biomass stacks are required.

for further information, contact Planning Decisions Unit: Giles Dolphin, Head of Planning Decisions 020 7983 4271 email [email protected] Justin Carr, Strategic Planning Manager (Development Decisions) 020 7983 4895 email [email protected] Loren Brown, Case Officer 020 7983 4296 email [email protected]

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