planning report GLA/4412/01 5 March 2018 Leisure Centre in the London Borough of Havering

planning application no. P2048.17

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

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

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

Strategic issues summary Principle of development: The principle of quantitative improvements to the leisure centre are supported, subject to the applicant adequately demonstrating that open space is protected and that any harm is outweighed by community benefits (paras 14 - 15).

Open space: The site lies in an area of locally designated open space. In accordance with London Plan Policy 7.18 and draft London Plan Policy G4, the applicant must provide details of the site search to justify that no alternative sites exist without an open space designation. Further details are also required to understand the impact of the proposals on the park’s openness, particularly whether any views will be improved (paras 16 – 29).

Design: Further work is required on: the western elevation; impact of the development on the park’s openness; active frontages; the car park; and inclusive access (paras 34 - 40).

Energy: Further details are required on: ‘be lean’ energy efficiency savings; the communal heat network and Combined Heat and Power network; and the proposed PV panels (paras 41 – 42).

Transport: The number of car parking spaces has not yet been adequately justified; further information is required on trips to the park by different users. In addition, staff numbers must be confirmed before cycle parking can be assessed (paras 43 – 48).

Recommendation That Havering Council be advised that the application does not comply with the London Plan and draft London Plan, for the reasons set out in paragraph 52. 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 29 January 2018 the Mayor of London received documents from Havering Council notifying him of a planning application of potential strategic importance to develop the above site for the above uses. 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 consideration in deciding what decision to make.

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

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

3 Once Havering 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; 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 lies at the north of Harrow Lodge Park and is bound to the north by Hornchurch Road, to the east by the River Ravensbourne and the west by two storey residential dwellings. Harrow Lodge Park extends south of the site and connects with Chase Nature Reserve at its very south.

6 The site is designated locally by Havering Council as ‘parks, open space, playfields and allotments’; the site is not within the Green Belt or Metropolitan Open Land. Harrow Lodge Park as an entirety has the same designation. The park connects to land which is designated as Metropolitan Open Land in its very south, forming part of a green link that runs through the borough. The site has no other local planning policy designations. The St Leonards Conservation Area covers the some of the residential dwellings to the west of the site.

7 The existing leisure centre was constructed in 1956 and was extended to include a sports hall in 1987. It has now reached the end of its usable life; the facilities are outdated and are either costly to repair or no longer serviceable. The existing car parking is located to the north west of the existing site, where there is space for 195 cars. The application redline includes the existing leisure centre and an area of land to the west, including the existing car park; the proposed building will be located on this latter area.

8 Within the park, a mix of land use surround the site: the Havering Indoor Bowls Club lies to the south west; the charity Mind occupies a building immediately to the west; there is an existing play area to the south and a Cricket Club to the north. All of these uses are accessed from Hornchurch Road, via an internal road within the park.

9 The closest part of the Strategic Road Network (SRN) is Rush Green Road, 1.5 kilometres west of the site, and the closest part of the Transport for London Road Network (TLRN) is the A12, approximately 4 kilometres north of the site. and Hornchurch Underground stations are both approximately 2 kilometres to the south and the closest National Rail station is , 1.3 kilometres north east of the site. The nearest bus stops are on Hornchurch Road, within 400 metres of the site, and are served by three bus services. The site records a public transport accessibility level (PTAL) of 2 on a scale of 1-6, where 6 is the highest.

page 2 Details of the proposal

10 It is proposed to construct a new leisure centre on the west of the application site, with the existing leisure centre remaining operational until the proposed centre opens. Once the new centre opens, the existing building will be levelled and a permanent and an overspill car park will be constructed on its footprint. During the construction period, a temporary car park is proposed to the rear of the existing leisure centre. The redline, therefore, covers both the location of the proposed leisure centre and the existing centre.

Table 1: Comparison of existing and proposed leisure centres

Existing Proposed

Gross internal area (sq.m) 6,500 6,150

Internal facilities - 30 x 12 metre swimming pool, - 25 x 17 metre swimming pool, with with diving boards at 1 metre, 3 diving boards at 1 metre, 3 metres metres and 5 metres and 5 metres - 11 x 6 metre learning pool - 20 x 10 metre learning pool - 200 x spectator seats for main - 250 x spectator seats for main pool pool - 60 x spectator seats in tiers for - 8 x sports courts diving boards - 2 squash courts - 4 x sports courts - 100-unit gymnasium - 150-unit gymnasium - 1 x fitness studio for classes - 3 x fitness studios for classes - Dry and wet changing - Creche - Café - Dry and wet changing

Car parking spaces 195 240 spaces (plus 60 within overspill car park).

Case history

11 GLA officers provided initial pre-application advice on a proposal for the redevelopment of the site on 19 October 2017 (GLA reference: D&P/4412). The written pre-application response, which was issued on 9 November 2017, confirmed that the creation of a new leisure centre, with improved facilities, was supported in principle, subject to impact on open space being fully justified and that it must be offset by the community benefits of the scheme. 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 Havering Council’s Core Strategy and Development Control Policies 2008, Site Specific Allocations 2008 and Core Strategy Proposals Map 2008 and the London Plan 2016 (Consolidated with Alterations since 2011). The following are relevant material considerations:

• The National Planning Policy Framework;

page 3 • National Planning Practice Guidance; and • Draft London Plan (consultation draft, December 2017).

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

• Sport facilities London Plan. • Open space London Plan. • Urban design London Plan; Draft London Plan (2017); Shaping Neighbourhoods: Character and Context SPG; Housing SPG; Shaping Neighbourhoods: Play and Informal Recreation SPG. • Inclusive design London Plan; Draft London Plan (2017); Accessible London: achieving an inclusive environment SPG. • Sustainable development London Plan; Draft London Plan (2017); Sustainable Design and Construction SPG; Mayor’s Climate Change Adaptation Strategy; Mayor’s Climate Change Mitigation and Energy Strategy; Mayor’s Water Strategy. • Transport London Plan; Draft London Plan (2017); the Mayor’s Transport Strategy; Land for Industry and Transport SPG.

Principle of development

14 It is recognised that locally designated open space is not afforded the same level of protection as the Green Belt or Metropolitan Open Land; however, it remains crucial to protect and retain the designated open space within the park, in accordance with London Plan 7.18 and draft London Plan G4. Whilst the applicant has carefully considered the proposed location of the new leisure centre within the park, the applicant has not yet suitably demonstrated that there are no alternative sites beyond the park and without the open space designation; this information must be provided.

15 In addition to justifying the location of the proposed leisure centre within Harrow Lodge Park, further details are required to understand the qualitative and quantitative improvements to the open space as well as the impact on the park’s openness, particularly whether any views will be improved. It is considered that the proposed development will provide qualitative improvements to the sports facilities for the local community; however, at present, due to the outstanding information set out above, the harm to the open space is not yet outweighed by these benefits. Open space designation

16 London Plan Policy 7.18 and draft London Plan Policy G4 seek to protect open space, and state that losses will only be acceptable where equivalent or better open spaces are created within the local area. More specifically, London Plan Policy 3.19 and draft London Plan Policy S5 state that, where sports facilities are proposed on existing open space, careful consideration of the impact on the green space and the borough’s need for facilities is required. The site is designated locally as an area of open space. Therefore, whilst the site is not afforded the same level of protection as the Green Belt or Metropolitan Open Land, the impact on the the green space remains a central material consideration.

17 In accordance with London Plan Policy 7.18, draft London Plan Policy G4 and Havering Council’s Core Strategy Policy DC18 and to justify the proposals, the applicant has presented the following case: the need for a new leisure centre; loss of open space; and impact on openness. These are addressed in turn below.

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Need for a new centre

18 The leisure centre would be developed as a separate and front-loaded construction, distinct from the existing centre, to avoid leaving residents without sports facilities for the duration of the build out. It is therefore not possible to construct the new leisure centre exactly on the footprint of the existing leisure centre. Further, the applicant has confirmed that redeveloping the existing building is not viable: it does not meet current standards, as much of the centre is not wheelchair accessible; retrofitting the building to meet current standards would be excessively costly; and some of the facilities, such as the pool, are beyond their serviceable life.

19 In order to justify developing the new leisure centre within the park, the applicant must demonstrate that there are no viable alternative sites that are not within an area of designated open space. The applicant states that it is not viable to acquire land elsewhere and then develop the replacement leisure centre; this has driven the need to build the new centre on Council-owned land. The applicant must provide details of the site search to demonstrate that all alternative Council-owned sites in the vicinity, without an open space designation, have been investigated; and this must be provided before the location within the park can be accepted.

20 It is accepted that the existing facility must be replaced to ensure the community has access to high quality sports facilities, in accordance with paragraph 73 of the NPPF, London Plan Policy 3.19 and draft London Plan Policy S5; however, the applicant has not yet adequately justified developing the new centre within Harrow Lodge Park.

Loss of open space

21 The proposed location of the new centre was selected by the applicant due to its proximity to other buildings and the topography of the site; it will be located primarily on the existing leisure centre’s car park, west of the internal road and between Harrow Lodge and the park depot buildings to the north. In addition, the applicant argues that the proposed location will retain the leisure centre in its historic location.

22 The re-positioning of the leisure centre will result in the loss of 4,921 sq.m existing green open space, which lies to the west of the existing car park and is presently used by a children’s football club and a children’s archery club. The applicant argues that the loss of this area of green space should be considered in the context of the state-of-the-art sports facility that will be provided, which offer a qualitative improvement on the existing facilities offered by this space. Whilst the open space to be lost is not demarcated for any official pitches, it is used by children’s sports clubs. The applicant states that it is liaising with the archery club and the football club to find alternative training sites; details of the final relocation strategy must be provided ensure that the loss of open space does not also have a consequential impact on sports facilities and clubs.

23 Once the existing centre has been demolished and levelled, it will be converted to a car park. As this is on the footprint of the existing building, it does not result in the loss of additional open space. At the pre-application stage, GLA and TfL officers recommended that the applicant create an overspill car park on reinforced grass to both reduce the number of permanent car parking spaces and to mitigate against the overall loss of open space. The applicant has now split the car parking into two areas: 240 spaces are located within the main car park, which will be located on hardstanding with some planting; and 60 spaces will be located within an overspill car park, located on reinforced grass. The introduction of an overspill car park is supported as it ‘returns’ 3,498 sqm of green space to the park, albeit on reinforced grass, which results in quantitative improvements to open space.

page 5 24 In addition, it is proposed to create an area of public realm in front of the new leisure centre, on land that is currently the existing car park. As such, the proposals are considered to improve 1,653 sqm of open space.

25 Table 2 illustrates the quantum of open space lost, created and bettered. Whilst the proposals result in the loss of open space, it is considered that this loss is offset by the qualitative and quantitative improvements to the open space; however, in accordance with London Plan Policy 7.18 and draft London Plan Policy G4, the applicant must demonstrate that no alternative sites exist beyond the park.

Table 2: Open space change

Open space change Quantum (sq.m)

Loss of open space 4,921

Open space created or improved 5,151

Existing building/carpark ‘returned’ to green open space 3,498

Existing carpark improved through creation of public realm 1,653

Impact on openness

26 Whilst the site is not designated Green Belt or Metropolitan Open Land, an assessment of openness should be undertaken to fully understand the impact of the proposals on the locally designated open space.

27 The proposed orientation aligns the leisure centre with the other buildings in this area of the park; at present, the leisure centre projects out into the park on the opposite side of the internal road. The applicant states that once the existing centre has been levelled and turned into car parking, north- to-south views through the park will be opened up, due to the removal of the centre which obstructs the view at present. However, this has not been illustrated in the Accurate Visual Representation (AVR) document, which focuses on the impact of the new centre in views. Whilst it is expected that the AVR will focus on the impacts of the proposed centre, it does not include any views that will be improved as a result of the proposal. An additional view from Hornchurch Road should be developed, looking due south, to illustrate how views will be improved north-to-south through removing the existing leisure centre. Further information on the scheme’s impact on openness must be provided to GLA Officers in advance of the Stage II referral.

28 Further, through locating the leisure centre on the west side of the internal service road, the built form is brought closer to the residential properties on Wallis Close and Bridgefields Close. There is an impact on openness from these surrounding residential streets; however, through adopting a neutral palette on the building’s facade and incorporating planting around the building, it is considered that this is minor in nature. The impact on these views could be reduced by breaking up the western elevation’s massing.

29 GLA officers consider that the views across the park from Abbs Cross Lane, on the eastern side of the park, are improved as a result of the proposals; however, as these properties are located a greater distance away from any substantial structures within the park, the improvements to openness from this view do not outweigh the impact on Wallis Close and Bridgefields Close. As such, at present, the applicant has not demonstrated how the scheme limits impact upon openness, or how the scheme may improve openness.

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Open space designation conclusion

30 It is considered that the proposals will provide a qualitative improvement to local sports facilities and a quantitative and qualitative improvement in green space; however, before the proposals can be considered acceptable in the context of the open space designation and in accordance with the London Plan and draft London Plan, the applicant must demonstrate that no viable alternative sites exist and provide further justification on the proposals’ impact on openness. Leisure centre use

31 Both the London Plan and draft London Plan recognise the importance of social and recreation facilities in community wellbeing. Specifically, London Plan Policy 3.19 and draft London Plan Policy S5 seek to enhance sports and recreation facilities, where multiple uses of the facilities have been secured, and will resist the loss of any existing facilities unless it can be demonstrated that there is no ongoing or future demand. As noted above, London Plan Policy 3.19 and draft London Plan Policy S5 state that applications for sports facilities on existing open space must be considered carefully in light of protecting open space.

32 The proposed leisure centre is approximately 350 sq.m. smaller than the existing centre; this is due to internal rationalisation and the loss of some existing facilities. The existing facility comprises 8 sports courts and 2 squash courts, whilst the new facility contains 4 sports courts. The applicant states that the facilities within the proposed leisure centre have been selected based on a study of the existing centre’s usage over the last 5 years; the study showed that squash courts have seen a decline of over 1000 visits over the last 3 years, whilst visitors to the sports hall were down by 4000 visits over the same period. In addition, the 8 sports courts do not comply with current Sport England Guidance. The proposed facilities would therefore respond to current demand as well as offering qualitative improvements to the retained sports facilities. However, in addition to the internal floorspace, as noted above, the proposals result in the loss of some external green space, which is currently used by children’s archery and children’s football clubs; the applicant must evidence that these clubs have been re-located to an area of similar quality open space, to justify the external loss of sports facilities.

Table 3: Comparison between key facilities in the existing and proposed leisure centres.

Existing Proposed

Swimming pool Non-standard 33 metre length and is Standard 25 metre length pool, with approaching end of serviceable life seating enabling it to be used for competitions.

Diving boards The existing 5 metre diving board is All three diving boards will be unstable and as such it cannot be used. accessible, with seating enabling them to be used for competition.

Sports hall Existing sports courts do not comply New sports courts will be compliant with Sport England Guidance. with Sport England Guidance.

Fitness suite 100-unit gym is over capacity. 150-unit gym.

33 The proposed leisure centre will significantly improve the facilities within the leisure centre, as summarised in table 3. In addition, the proposed facility would be fully wheelchair accessible and

page 7 is designed to enable wheelchair sports; this is strongly supported as it provides opportunities for participation all members of a community, in accordance with the NPPF, London Plan Policy 3.1 and draft London Plan Policy GG1.

34 Given the inefficient existing building and the qualitative improvements, and subject to the confirmation of the relocation of the children’s archery and football clubs, it is considered that the loss of 350 sq.m of internal floorspace, is adequately justified, in accordance with London Plan Policy 3.19 and draft London Plan Policy S5. However, as the scheme lies within an area of open space, the proposals must be considered in the context of protecting the open space, also in accordance with London Plan Policy 3.19 and draft London Plan Policy S5. As outlined in paragraphs 26-29, further information on the impact on openness is required before it can be demonstrated that the community benefits of the scheme outweigh any harm to the open space. Urban design

35 Good design is central to all objectives of the London Plan and draft London Plan. In addition to ensuring that the design limits the proposed development’s impact on open space, there are also outstanding concerns relating to the following: the western elevation; active frontages; car park design; and inclusive access.

Architecture and massing

36 The architecture of the proposal is broadly supported; the massing of the building is broken up using glazing, timber and masonry, albeit it to a lesser degree on the western elevation; the applicant should consider breaking this elevation up, as discussed below. The height is similar to the existing building and varies according to what activity that section contains; for example, the roof above the diving boards is proposed to be higher than the surrounding swimming pool. These variations enable adequate floor to ceiling heights for the activities proposed, without unnecessarily increasing the building’s bulk overall. To ensure that the development represents the quality envisaged, full details of materials must be reserved by condition, including how the applicant intends to mitigate against undesirable weather of the timber cladding.

37 Whilst the architecture is broadly supported, the applicant should provide the additional view requested in paragraph 26 and also render all of the views of the leisure centre within the AVR document to better understand the impact of the proposals. Further, of particular importance is view 4 from Wallis Close, where the rear of the proposed leisure centre entirely obscures views into the park. The applicant should seek to lessen this impact through breaking up the massing on this western elevation. In addition, breaking up this elevation using addition glazing or openings would provide surveillance out onto the interstitial space between the rear of the proposed leisure centre and Wallis Close. The applicant must consider opportunities to activate this space, including exploring opportunities for outdoor gym uses.

Active frontages

38 Plant and storage rooms are currently proposed on the north east of the ground floor; this results in an inactive frontage on an element of the building’s front elevation as well as on the northern elevation, which is visible to pedestrians arriving at the site from the internal service road. As requested at pre-application stage, the applicant should consider the internal organisation to provide some activity along this elevation, with particular importance on providing natural surveillance onto the internal road. The front of the building features a double height glazed wall, from the entrance up the fitness suite; this provides natural surveillance onto the park and the proposed car parking from the entrance lobby and from the first-floor gym, which is welcomed.

page 8 Car park

39 Since pre-application stage, the applicant has sought to minimise the impact of the car park through landscaping and reducing the number of permeant car parking spaces from 300 to 240, with a 60-sapce overspill car park. The overspill car park will be located on an area of reinforced grass on the eastern side of the car park, which aids in minimising the impact of parking on the open space as well as reducing the perception of car parking in this area. Rendered views of the proposed car park should be provided to illustrate the impact on the open space and whether the proposed relocation of the leisure centre improves north-south views, as discussed in paragraph 27. The perception of openness and the size of the car park is central to the success of the design; the applicant has sought to reduce the size of the permeant car park but further evidence is required to understand its impact.

40 The car park is located obliquely from the proposed building and is connected by one access point in the northwest of the car park. There is a need to balance the requirement for visual and physical links between the car park and the building with the need to screen the car park to minimise its impact on the open space. The applicant has added significant soft landscaping since pre- application stage as well as introduced an overspill car park, which is welcomed in terms of screening the car park; however, the applicant should demonstrate that this space will be suitably illuminated at night to ensure safety and legibility. All planting and lighting must be secured by condition.

Inclusive access

41 London Plan Policy 7.2 and draft London Policy D3 require that all new development is accessible and inclusive for all. The applicant has confirmed that the internal facilities will be fully accessible and have been designed to accommodate wheelchair sports. The applicant must confirm that the ‘relatively flat’ exterior landscaped area is an acceptable gradient to be accessible for wheelchair users, in accordance with London Plan Policy 7.2, draft London Plan Policy D3 and the Mayor’s Accessible London SPG.

Energy

42 The applicant has broadly followed the energy hierarchy; however, further information is required before the proposals can be considered compliant with London Plan Policy 5.9 and draft London Plan Policy S12. In terms of ‘be lean’, the proposed development does not appear to achieve any carbon savings from energy efficiency alone; the applicant should investigate and model additional energy efficiency measures. With regard to ‘be clean’, it is proposed to install a communal heat network and a Combined Heat and Power Network; further information is required on the plant efficiencies and on the CHP contribution. For the ‘be green’ element, the applicant must evidence that PV panels have been maximised.

43 As presently proposed, the scheme will achieve an overall saving of 26%; this does not meet the target set out in London Plan Policy 5.2 and draft London Plan Policy SI2. The applicant must consider scope for further measures to reduce carbon emissions. Following the resolution of the outstanding energy issues, any shortfall in carbon savings should be offset through financial contributions to the Council’s carbon offset funds. The detailed technical comments have been sent to the applicant and the Council. Transport

44 The trip generation information shows that the site will operate above its theoretical capacity; therefore, impact on the local highway network must be discussed with Havering Council and mitigation measures, in accordance with London Plan Policy 6.3 and draft London Plan Policy T4.

page 9 45 A total of 240 car parking spaces are proposed within the permanent car park, with an additional 60 within the overspill car park. Neither table 6.2 associated with London Plan Policy 6.13 nor table 10.5 associated with draft London Plan Policy T6 set prescriptive car parking standards for sports facilities, rather an appropriate quantum of spaces is determined on a site-by-site basis taking into account Policy 6.13 and draft Policy T6, PTAL rating and future pedestrian and cycle connectively. As it is not proposed to restrict the car park to users of the leisure centre, it is not considered that the number of spaces in the proposed car park has been adequately justified. The applicant must provide an assessment of the split between the different users of the park, the length of stay and turnover of vehicles in their Transport Assessment; TfL will then review this data to agree the acceptable number of car parking spaces. A Car Park Design and Management Plan must then be secured by condition.

46 The proposal includes a temporary car park with 97 spaces, which will be used during the construction of the new leisure centre on the existing car park. As the leisure centre will remain operational during construction, the creation of temporary car parking is reasonable; however, this must be subject to a condition requiring it to revert to open space post-construction.

47 To enable an assessment of the total number of cycle parking spaces, against London Plan Policy 6.9 and draft London Plan Policy T5, the applicant must confirm the likely number of employees working within the building and the gross external size of the proposed centre. In accordance with London Cycle Design Standards, 5% of all spaces should be suitable for non-standards bikes such as cargo bikes, accessible bikes and trikes.

48 The provision of a detailed construction logistics plan and a delivery and servicing plan must also be secured by condition, in accordance with London Plan policies 6.11 and 6.14 as well as draft London Plan T4 and T7. The submitted travel plan, and all agreed measures therein, should be secured, enforced, monitored and reviewed as part of the S106 agreement.

49 In accordance with London Plan Policy 8.3 and draft London Plan Policy T4, a contribution to Mayoral CIL must be secured; the level required should be confirmed by the applicant and Council once the components of the development have been finalised. The full transport comments have been sent to the applicant and the Council. Local planning authority’s position

50 Havering Council Planning Officers are reviewing the scheme and intend to take it to committee in April 2018. Legal considerations

51 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. 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.

page 10 Conclusion

52 London Plan and draft London Plan policies on open space, sports and recreation facilities, urban design, car parking, other types of transport and energy are relevant to this application. The proposals do not comply with the London Plan and draft London Plan. The following changes, however, might lead to the application becoming compliant:

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

• Open space: The applicant must provide details of the site search to justify developing the proposed leisure centre within any area of open space. Further details are also required to understand the impact on the park’s openness, particularly whether any views will be improved; the applicant should provide an additional view from Hornchurch Road, looking due south.

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

• Energy: Further information is required on: ‘be lean’ energy efficiency savings; the communal heat network and Combined Heat and Power network; and evidence that renewables have been maximised. The scheme does not yet comply with London Plan Policy 5.9 and draft London Plan Policy SI2; therefore, further measures must be included to reduce carbon emissions.

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

for further information, contact GLA Planning Unit: Juliemma McLoughlin, Chief Planner 020 7983 4271 email [email protected] Sarah Considine, Head of Development Management (acting) 020 7983 5751 email [email protected] Vanessa Harrison, Senior Strategic Planner (Case Officer) 020 7983 4467 email [email protected]

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