planning report D&P/ 3003d/01 16 January 2017 Whitgift Centre and surrounding land, , CR01LP in the Borough of Croydon planning application no. 16/05418/OUT

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 Mixed use redevelopment of the Site through the demolition (within and outside the Conservation Area), alteration, refurbishment and retention of existing buildings/structures and erection of new buildings/structures to provide a range of town centre uses including retail and related uses (Use Class A1 - A 5); leisure (Use Class D2); residential (Use Class C3); student accommodation (sui generis) or hotel (Use Class C1); community facilities (Use Class D1); office (Use Class B1); residential amenity space and public realm; alteration of existing and creation of new basements, underground servicing and multi-storey car parking; alteration to existing and creation of new vehicular and pedestrian access into the site; utility and energy generation facilities; infrastructure and associated facilities, together with any required temporary works or structures required by the development.

The applicant The applicant is Croydon Limited Partnership, the architect is Leonard Design Architects, and the agent is Quod.

Strategic issues Land-use: The principle of the proposed development is supported, further details and discussion required in regards to affordable retail and student residential accommodation (paras 21-26). Transport: The development will generate approximately 30 million visitors a year requiring significant upgrades to transport services and public realm. Tram and bus capacity mitigation measures along with highway access and walking and cycling improvements on the surrounding network are required. Other issues relate to rail stations, car parking, cycle parking and blue badge parking (paras 27-62). Housing: Delivery of between 626-927 homes in the build to rent sector with on-site delivery of discount market rent units is supported. The applicants approach to viability information is unacceptable (paras 63 -75). Urban design: The approach to height, massing and design is supported subject to refinements to the design guidelines (paras 76 -85). Strategic views and heritage assets: Further views information required to assess the impact on the Grade I Whitgift Almshouses (paras 86-88).

page 1 Recommendation That Croydon Council be advised that while the scheme is broadly acceptable in strategic planning terms, the application does not fully comply with the London Plan, with the reasons and remedies set out in paragraph 105 of this report.

Context

1 On 28 October 2016 the Mayor of London received documents from Croydon 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 is required to provide the Council with a statement setting out whether he considers that the application complies with the London Plan, and his reasons for taking that view. The Mayor may also provide other comments. This report sets out information for the Mayor’s use in deciding what decision to make.

2 The application is referable under Category 1A, 1B, 1C and 3F of the Schedule to the Order 2008:

 1A: Development which comprises or includes the provision of more than 150 houses, flats, or houses and flat;  1B:Development (other than development which only comprises the provision of houses, flats, or houses and flats) which comprises or includes the erection of a building or buildings - outside Central London and with a total floorspace of more than 15,000 square metres.  1C: Development which comprises or includes the erection of a building in respect of which one or more of the following conditions is met: a) the building is more than 30 metres high and is outside the City of London.  3F: Development for a use, other than residential use, which includes the provision of more than 200 car parking spaces in connection with that use.

3 Once the 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) Regulations 2011 (as amended) 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 extends to approximately 8.99 hectares and is located within the Croydon Metropolitan Centre and Croydon Opportunity Area. The site is bound to the south by George Street and to the west by the pedestrianised North End. The A212 Wellesley Road forms the site's eastern boundary, with Poplar Walk to the north.

7 The majority of the site is lies within the Primary Shopping Area of Croydon Metropolitan Centre as identified by the Croydon Local Plan and in the Retail Core as identified by the Croydon Opportunity Area Planning Framework. The site is currently occupied by a variety of town centre uses, primarily consisting of the Whitgift Shopping Centre, the former department store, a number of largely vacant office buildings and associated car parking. A schedule of the existing floorspace is set out in table 1 below. The site boundary includes buildings which are to be retained

page 2 and unaltered as a result of the proposed development, but are included as works and construction activities will be undertaken to facilitate its construction and delivery. These properties are not included in table 1.

Existing use Sqm GEA

Whitgift Shopping Centre 81,112

Former Allders 46,956

Total retail 128,068

Centre Tower and Blocks A-C&E 37,929

Link House 2,250

London Road 1,706

Green Park House 8,791

Total office 50,676

Table 1: Existing floorspace on site

8 Beyond the south eastern boundary of the Site, adjacent to Dingwall Avenue, is the Grade II listed Electric Showrooms and offices. George Street, to the south of the Site, is defined by three storey buildings with retail and service uses at ground floor level, characterised by high street banks, betting shops, public houses and restaurants. Beyond the Site to the west is the Centrale Shopping Centre and other individual retail units on North End. The properties along the North End and George Street frontages are within the Central Croydon Conservation Area. In addition to the Grade II listed Electricity showrooms and offices, there are two Grade 1 Listed buildings in close proximity to the site; the Hospital of the Holy Trinity (Whitgift Hospital); and the Parish Church of St Michael and All Angels. There are also a number of locally listed buildings.

9 The application site has a public transport accessibility level of 6b, which is the highest accessibility rating. The site lies within 150m of , providing mainline rail and London Overground services. is approximately 400 metres to the east of the site, providing frequent mainline rail services to central London and regional stations such as Gatwick Airport and Brighton. Croydon stops are situated at Wellesley Road, George Street and West Croydon bus station; serving Wimbledon, , Beckenham Junction and Elmers End. The site is also served by a large number of bus routes, which can be accessed on Wellesley Road, and from East and West Croydon bus stations and from Poplar Walk.

10 The Whitgift Shopping Centre is served by the Wellesley Road multi-storey car park which provides 1,059 car parking spaces, accessed from Wellesley Road with egress onto Poplar Walk. The former Allders store is served by a dedicated car park providing 583 spaces with ingress and egress via Dingwall Avenue off Wellesley Road. Furthermore, 500 spaces are provided in the Bank car park. In total the Site accommodates 2,142 spaces.

11 Wellesley Road forms part of the Strategic Road Network (SRN) and the nearest section of the Road Network (TLRN) is the A232 (Park Lane gyratory), approximately 300 metres to the south. Importantly the A23 Purley Way, part of the TLRN, is the main town centre distributer road and is approximately 1km from the site.

page 3 Details of the proposal

12 Outline planning permission is sought for the demolition, alteration, refurbishment and retention of existing buildings/structures and erection of new buildings/structures to create a retail-led mixed use development including a new shopping centre, leisure facilities, restaurants and cafes, and residential units of mixed tenure (indicatively between 626-967 units), together with the potential for student residential accommodation or hotel use in lieu of some residential use.

13 The planning application is submitted in outline with matters of appearance, landscaping, layout, scale and access (save for details of vehicular external access to/from the site) reserved within the parameters set out in the Parameter Plans, the Development Specification and Framework and the Design Guidelines.

Use Existing Proposed floorspace (sq.m) - GEA floorspace (sq.m) Retained Demolished New Total Net additional Retail and 128,068 254 127,814 173,430 173,684* 45,616 leisure use (A1-A5 and D2) Retail and 128,068 254 127,814 166,062 166,316 38,248 related uses (A1-A5) Leisure use 0 0 0 16,842 16,842 16,842 (D2) Residential 0 0 0 93,570- 93,570- 93,570- use (C3) 139,465 139,465** 139,465 Student 0 0 0 20,684 20,684*** 20,684 residential (sui generis) / hotel (C1) Community 0 0 0 1,053 1,053 1,053 use (D1) Office (B1) 50,676 0 50,676 3,895 3,895 -46,781 Car parking 50,265 0 50,265 100,000 100,000 49,735**** Malls 15,966 0 15,966 36,842 36,842 20,876 Back of 6,979 0 6,979 52,632 52,632 45,653 house facilities (all uses) * Total combined retail and related uses and leisure use shall not exceed 173,684 sq.m GEA; ** Permission is sought for between 93,570 sq.m GEA – 139,465 sq.m GEA of residential floorspace (indicatively between 626 and 967 residential units); ***Any student accommodation or hotel will be delivered from the maximum residential floorspace figure; **** The existing site contains 2,142 car parking spaces which are all to be demolished. The proposed development will be supported by a total of up to 3,140 commercial spaces.

page 4 Case history

14 On 5th February 2014 Croydon Council granted outline planning permission (LPA ref: 12/02542/P) (GLA ref: 3003b) and conservation area consent (ref: 12/02543/CA) to Croydon Limited Partnership (CLP) for the comprehensive redevelopment of the Whitgift Shopping Centre and land bounded by Poplar Walk, Wellesley Road, George Street and North End. The development included the demolition, alteration, refurbishment and retention of existing buildings/structures and erection of new buildings/structures to provide a range of town centre uses including retail and related uses, leisure, residential, community facilities, office, open space and public realm, as well as associated transport and parking improvements. These permissions have not been implemented by the applicant.

15 Subsequently in December 2014 planning permission was granted to improve an existing entrance off North End into the approved outline scheme by demolishing 96/98 North End and the existing Chapel Walk entrance to the Whitgift Centre to create an enhanced entrance and mall environment (Ref No: 14/02824/P). The permission has not been implemented by the applicant.

16 Further to these permissions at the Whitgift Centre site the Council made the CPO in April 2014 to acquire all land necessary to bring forward the comprehensive redevelopment of the site. An inquiry was held during February and March 2015 and the Secretary of State later confirmed the Order in September 2015. The CPO powers will need to be exercised to enable delivery of the proposed development.

17 GLA officers hosted a pre-application meeting with the applicant in July 2016. The principle of the development was supported although at that stage the proposals did not include student accommodation and hotel uses. The approach to height, scale and massing was broadly supported. Significant issues related to transport mitigation were raised. The applicant’s position on affordable housing was not clarified at the pre-application stage. Strategic planning issues and relevant policies and guidance

18 The relevant issues and corresponding policies are as follows:

 Principle of development London Plan;  Transport London Plan; the Mayor’s Transport Strategy; Mayoral Community Infrastructure Levy; Crossrail SPG;  Housing London Plan; Housing SPG; Housing SPG, draft Affordable Housing and Viability SPG; Neighbourhoods: Play and Informal Recreation SPG; Shaping Neighbourhoods: Character and Context SPG;  Urban design London Plan; Shaping Neighbourhoods: Character and Context, SPG; Housing SPG; London Housing Design Guide; Shaping Neighbourhoods: Play and Informal Recreation SPG;  Strategic views and heritage assets London Plan; London View Management Framework SPG;  Inclusive design London Plan; Shaping Neighbourhoods: Accessible London: Achieving an Inclusive Environment SPG  Air quality London Plan; The control of dust and emissions during construction and demolition SPG;

page 5  Climate change mitigation London Plan; Sustainable Design and Construction SPG; Mayor’s Climate Change Adaptation Strategy; Mayor’s Climate Change Mitigation and Energy Strategy; Mayor’s Water Strategy.

19 For the purposes of Section 38(6) of the Planning and Compulsory Purchase Act 2004, the development plans in force for the area are the Croydon local plan: strategic policies (2013); the saved policies from Croydon’s unitary development plan (UDP) of 2006; the South London waste plan; and the London Plan 2016 (The Spatial Development Strategy for London Consolidated with Alterations since 2011).

20 The following are also relevant material considerations:

 National Planning Policy Framework, Technical Guide to the National Planning Policy Framework and National Planning Practice Guidance;  Croydon Opportunity Area Planning Framework (2013);  Croydon’s conservation area general guidance SPD (2013);  Croydon’s local list of buildings of architectural or historic significance SPD (2006).

Principle of development

21 As outlined above the current proposals are an evolution of an earlier scheme granted outline planning permission in 2014. The extant planning permission established the principles of redevelopment for town centre uses with residential accommodation and the loss of office accommodation. The current scheme proposals incorporate additional land (including Green Park House) to deliver a comprehensive scheme across a wider area. The land-use principles of the scheme masterplan remain broadly the same with the key changes summarised as follows:

 A larger site than the extant consent;

 An additional 37,133sq.m GEA of retail and leisure floorspace;

 An additional 32,512sq.m to 48,924 sq.m GEA of residential floorspace; and,

 Potential for an element of student accommodation and / or a hotel use to replace part of the residential accommodation.

22 As per the previous scheme the proposed mixed use redevelopment of the site for town centre uses with residential above is supported and will facilitate the regeneration of the Croydon Town Centre and the delivery of the Croydon Opportunity Area Planning Framework (OAPF). The additional retail and leisure floorspace will support the vitality and viability of the town centre in accordance with London Plan Policy 4.7 and 4.8. GLA officers will work with the applicant to secure provision of affordable units for independent retailers and service outlets in accordance with London Plan Policy 4.9.

23 Additional residential accommodation will help meet the pressing need for more homes in London and is supported in accordance with London Plan Policy 3.3. The proposals seek to introduce an element of flexibility in the residential floorspace to allow a proportion of it to be provided as a hotel use or student accommodation. It is understood that this would allow for up to 250 hotel rooms. The provision of new visitor accommodation in a town centre and opportunity area locations is supported in accordance with London Plan Policy 4.5 and the Croydon OAPF.

page 6 24 The Croydon OAPF supports the provision of new student accommodation and London Plan Policy 3.8 states that strategic and local requirements for student housing meeting a demonstrable need are to be addressed by working closely with stakeholders in higher and further education and without compromising capacity for conventional homes. In principle, the provision of student accommodation in a highly accessible location is supported in strategic planning terms. It is understood that the applicant does not have an agreement with a specific educational institution to take up proposed student accommodation. As such, in accordance with paragraph 3.53B of the London Plan, the applicant should, subject to viability, deliver an element of affordable student accommodation.

25 London Plan Policy 2.16 identifies Croydon as a strategic office location. The Croydon OAPF expands on this policy and promotes the consolidation of office development in the New Town and East Croydon character areas and the removal of redundant office space from other locations. The proposals will result in the loss of redundant office floorspace outside the New Town and East Croydon areas with the demolition of Green Park House, which is supported in accordance with the Croydon OAPF.

26 Overall, the principle of the proposed development is supported in accordance with the London Plan and the Croydon OAPF, subject to the above comments being addressed regarding affordable retail and student accommodation. Transport for London

27 The Croydon OAPF was supported by a transport study which identified a number of specific and cumulative highway and public transport capacity issues on the network. In 2014 the council, GLA and TfL adopted a Development Infrastructure Funding Study (DIFS), which identifies key infrastructure and funding required to support development within the Opportunity Area. A Growth Zone, tax increment finance model has also been set up to help fund infrastructure. Development in the OA is set to intensify significantly in the next few years and it is critical that all projects and developments are fully co-ordinated. Construction impact and management of construction activity will need to be carefully co-ordinated.

Trip generation

28 The proposed retail and leisure elements of the development are forecast to generate an additional 8.5 million trips per year to the town centre by all modes, over and above the existing trip generation. However the nature of the trips will change due to the substantially improved retail offer. Whilst the overall methodology has been agreed some further work is required in respect of the modal split and parking demand.

Highway impact and mitigation

29 The development will generate over 3 million new car journeys per annum, causing a significant impact on highway and bus operations. Journey times along Wellesley Road are predicted to significantly increase in the PM peak hour and weekends due to the additional traffic generation and new access proposals. This increase in journey times is particularly significant on bus operations. The modelling indicates delays of up to 90 seconds to bus services on the network. At present any delay over 30 seconds is considered unacceptable and these impacts will therefore need to be reduced through the mitigation strategy.

page 7 30 The delays to bus journeys equate to a £6 million cost to TfL and this figure will be sought to provide additional bus services. However, the strong preference is to reduce the bus journey delays through a series of highway improvements and design measures, which should be agreed with TfL and the Council and funded by the applicant. These improvements and measures should not be limited by the area covered by the submitted highways plans and should include local and strategic roads. TfL officers will review the bus journey delays once these measures have been agreed and a proportionate contribution for additional services will be sought for any delay over 30 seconds.

31 A number of changes are proposed to the existing highway layout to facilitate the development, including a major scheme of works to the Park Lane gyratory. The proposed access arrangements have been improved from the consented scheme, which is welcomed. A plan detailing the management and operation of access arrangements should be secured by condition. The applicant will be required to enter into highway agreements with the Council and TfL to carry out these changes. The proposed changes to the highway layout and access arrangements are supported and the detailed design will be refined in the highway agreements with the Council and TfL. Given the scale of the proposed works funding is sought for future TfL officer time to work on and monitor detailed design of the application.

32 Under the previous application, £2.5m was secured towards highway network improvements in the town centre, to be developed by the Council in consultation with the applicant and TfL. In addition up to £4,000,000 was secured towards public realm works towards various improvements including but not restricted to North End Park Lane The Council should confirm the amount sought and provide further details to assist in reviewing the effects on bus journey times.

Bus network impact and mitigation

33 In addition to the impacts on bus journey times discussed above, the effect on the bus network capacity is significant and equates to over 3 million extra bus journeys per annum. TfL currently estimates that two routes will require frequency increases (routes 60 and 250) and one route (109) will require an extra journey in order to accommodate the additional demand. An increase of three buses each on the 60 and 250 route is required, and this would require 6 additional buses at a cost of £250,000 per bus per year, plus £95,000 for an extra journey. This equates to £1,595,000 per year or £7,975,000 over five years. Further bus standing space will also be required to manage increases to bus services, and further discussions are sought with the council and applicant as to where this will be provided and how it will be funded.

34 All bus stops that will serve the development should be upgraded to ensure that they meet current standards. The stops adjacent to the site on Wellesley Road will be upgraded as part of the section 278 works. Other key stops that are not included in these areas will need to be identified and contributions secured towards improvements. The average cost of upgrading a bus stop is approximately £10,000 and the total contribution will be confirmed once the stops have been identified.

Tram network impact and mitigation

35 The effect on the tram network is significant, and equates to approximately over 2 million extra tram journeys per annum. It is not physically possible to add more trams into an already optimised timetable without providing wider network enhancements including tram operation, stabling and depot facilities, which would not be feasible or cost effective to require from this development alone.

page 8 36 A new tram loop via Lansdowne Road and Dingwall Road, referred to hereafter as the Dingwall Loop, is the only feasible mitigation option to address the increase in demand on the tram network generated by the development. TfL has undertaken public consultation on the Dingwall Loop, and received overwhelming support for the proposal. The delivery of the Dingwall Loop would provide enhanced resilience to the network and provide the capacity required to mitigate the impact of the development.

37 The Dingwall Loop (including the Wellesley Road tram stop) will cost £34.5m and cannot progress without funding from this development. The Mayor has agreed to contribute £5m to the cost of the project leaving £29.5m, which should be secured from the development via the section 106 legal agreement. A Transport and Works Act Order application will be submitted in 2017 with construction expected to be complete in 2021, subject to a funding agreement being reached with the applicant. Because of the specific nature of the impact from this development, delivery of the Dingwall Loop should be secured through the section 106 legal agreement prior to opening of the new shopping centre, with TfL having approval through the s106 agreement.

38 Further tram improvements to the George Street tram stop are also necessitated by the development itself. The full cost for these works must be funded by the applicant, and are estimated to cost £1m. Again delivery of the works to the tram stop should be secured through the section 106 legal agreement prior to opening of the new shopping centre, with TfL having approval through the s106 agreement. A Tram Asset Protection agreement will be required in order to ensure safe management of the tram network and facilities during construction and future operation.

Rail network impact and mitigation

39 The effect on the rail network is significant and equates to 1 million extra rail journeys per annum. However, it should be noted that much of the information in the transport assessment is incorrect and this may underestimate the impact on West Croydon station. This is particularly important given that the revised proposals for Poplar Walk offer a greatly improved connection to the station. TfL has long term aspirations to redevelop West Croydon station to ensure it is better integrated with the town centre redevelopment. Therefore, it is important that service frequencies are checked and the overall impact analysis updated to reflect this. TfL have been developing options to upgrade the station with indicative costs including a £1.5m basic step free access scheme and a more radical platform step free access scheme and overbridge which is £10m.

40 Since the previous application a second entrance, at West Croydon station has been provided to relieve congestion during peak periods. At the pre-application stage TfL recommended that the feasibility of opening this second entrance for longer was investigated. TfL still recommend that this is investigated and that the costs associated with this are secured through the section 106 agreement. Further discussions regarding mitigation works and costs will be required following submission of revised and additional information outlined above.

41 It is considered that there is sufficient capacity to accommodate the additional demand at East Croydon station, subject to any comments from Network Rail.

Pedestrian network impact and mitigation

42 The main pedestrian entrance to the development is from Wellesley Road opposite Lansdowne Road where a new signalised pedestrian crossing facility is proposed. The TA still states that this will be delivered by other parties. Given that this is the main pedestrian desire line and access to the development for people arriving from East Croydon station, this should be funded by the applicant.

page 9 43 A more qualitative / diagrammatic analysis of pedestrian movements throughout the area should be provided for comment to better understand the development impacts and inform the detailed design of public realm improvements.

44 Where the pedestrian assessment has identified areas requiring improvements (George Street crossing over Wellesley Road and North End crossing Station Road), mitigation will need to be identified. A number of other junctions have been identified as requiring improvements, which should be detailed and secured by the Council.

Cycle network impact and mitigation

45 In general the cycling strategy and provision for cycling is inadequate and does not reflect the Mayor’s objectives for cycling. The total peak hour cycle trip generation predicted in the TA is considered to be too low for a development of this size and requires further discussion. A draft cycle strategy should be provided prior to determination to inform measures designed to encourage cycling including further consideration of a potential cycle hub. Following submission of a draft cycle strategy further discussions are required to agree measures necessary to implement the cycle strategy.

46 The applicant should commit to providing long stay cycle parking in accordance with the London Plan minimum standards for both residential and commercial uses and the detailed design and location should be secured by condition. The applicant has committed to providing 300 short- stay cycle spaces within the public realm. Further information on the possible breakdown of retail and leisure uses is required to ensure that adequate provision will be delivered.

47 The proposed public realm improvements and new access to Poplar Walk are broadly supported. However further information is required to demonstrate how any conflicts between bus and cycle routes on Poplar Walk will be designed and managed given the high pedestrian movements. The pedestrian and cycle entrance to residential Tower 1 would be taken directly off Wellesley Road except for Tower 1 and further information is required to understand how this may impact on pedestrian movements.

Car parking

48 The consented scheme provided a total of 3500 car parking spaces, although it was agreed that the full amount would only be available for 20 days with parking restricted to 3140 spaces at all other times. The current proposals include the provision of 3,140 retail / leisure car parking spaces, equivalent to the restricted scenario in the consented scheme and a reduction overall and relative to retail floorspace, which is welcomed. Whilst this is in excess of the London Plan standards for retail use, the proposed level is in broad conformity with Parking Scenario 2 of the Croydon OAPF. The applicant and Council should provide further detail on the strategy for consolidation of parking in the retail core to ensure compliance with the Croydon OAPF.

49 157 of the 3,140 retail car parking spaces will include EVCPs. This equates to a total of 5% of the overall provision. A further 15% will include passive provision. Whilst the active provision doesn’t meet London Plan standards, the combined active and passive provision would, which is supported.

50 126 disabled car parking spaces are proposed for the retail/leisure element of the development which equates to 4% of the total provision. A further 2% will be available for either disabled users or those with children. This approach is supported. The London Plan requires a further 4% future provision (enlarged spaces) to be identified, which could be used as parent and child spaces unless disabled demand arises.

page 10 51 The residential element of the development will be car free with the exception of disabled car parking. 10% of the proposed residential units will be accessible units and each accessible unit will have access to 1 disabled car parking space which is in accordance with London Plan standards.

52 A coach drop-off and pick-up facility is proposed on the northern kerb of Poplar Walk, which is supported in principle. Further discussion with TfL and operators will be required in respect of the design and operation of the facility, which should be secured by planning condition.

53 No site related car club provision has been identified. Two car club bays were agreed as part of the consented scheme. Given the uplift in residential units, it is recommended the car club provision is also uplifted. It is recommended that 20 car club spaces are provided. The applicant should also offer free car club membership to residents to be secured in the s106 agreement. It is estimated that a payment of £180,000 would be required to pay for membership.

54 A car park management strategy for both the retail/leisure and residential uses will be required and should be secured by the Council. This will need to feed into a wider strategy for the town centre, which given the scale of change in parking demand generated by this development, should also be secured by the Council. The strategy should include a comprehensive town centre Variable Message Signage (VMS) system to manage parking. A contribution of £300,000 is sought to deliver a suitable VMS system.

Taxi and private hire vehicles

55 The development will generate significant demand for taxi trips and there is a need for a large taxi rank, there may also be a need for more than one taxi rank to serve the site. A taxi rank is proposed on Dingwall Avenue, accessed via Wellesley Road. The applicant should provide further details on the capacity and operation of the taxi rank and whether this is the only taxi rank proposed for the site. An area for set down / pick up for private hire vehicles should also be provided.

Travel plan

56 The provision of a framework travel plan which details the overarching structure and guidance and is intended to be developed into land-use specific Travel Plans prior to occupation, is welcomed. An ATTrBuTe assessment will need to be undertaken of the travel Plan and the results provided to TfL. In order to ensure that the application complies with London Plan policy 6.1 Strategic approach and 6.3 Assessing effects of development on transport capacity, TfL expects the final travel plan(s) to be secured through the section 106 agreement. Specific measures such as car club membership and cycle vouchers should also be secured through the section 106 agreement, as well as other measures which are befitting a 21st Century regionally significant shopping centre, based on the applicant experiences at other shopping centres.

57 Given the level of car parking proposed along with heavy delays to bus services it will be important that the overarching transport strategy is correct. A sustainable transport fund of £1,625,000 was secured under the extant permission which sought to implement measures in the travel plan and cycle strategy. As a minimum this should be maintained with indexation. Additional funds might be required to implement the cycle strategy. The developer will be required to rigorously monitor travel data and to propose both ‘hard’ and ‘soft’ measures to ensure that the mode share targets are achieved and exceeded.

page 11

Construction management

58 A section detailing forecast construction traffic generated during construction of the proposed development and the construction programme is included within the TA. Due to the scale of development activity projected in Croydon town centre over the next 5 years and the complex nature of the build and the potential impacts on pedestrians, trams, buses and traffic, detailed discussions on construction arrangements should be undertaken as early as possible, and the potential issues clearly documented prior to determination. If granted permission, it is predicted that the construction timelines of a number of sites in the vicinity of this development along with the Dingwall Loop may overlap, so the interface will need to be carefully managed so that all schemes can be successfully facilitated. As much information as possible will be required from an early stage in order to facilitate co-ordination of this work.

Delivery and servicing

59 All servicing for the retail and commercial uses will take place within a dedicated basement service yard accessed via Wellesley Road. Servicing of the residential uses will be split between the main retail basement for refuse collection and vehicles over 3.5m in height, and a dedicated residential basement accessed via Poplar Walk. A draft Delivery and Servicing Plan (DSP) should be submitted prior to determination, detailing a commitment to reduce peak hour servicing, delivery booking systems and a responsible procurement process. In order to ensure compliance with London Plan Policy 6.14 Freight, both the servicing and construction management plans must be secured by appropriate planning conditions or through the section 106 agreement. Both should be submitted to TfL and the Council for approval.

Community Infrastructure Levy

60 In accordance with London Plan policy 8.3, Community Infrastructure Levy, the Mayor commenced CIL charging for developments on 1st April 2012. This application is liable to pay a CIL charge, the cost of which in Croydon is £20 per square metre.

Summary

61 The proposals do not currently comply with transport policies in the London Plan. Significant further work is required in respect of transport and access. The additional details, revisions and mitigation measures required to ensure compliance with the London Plan can be summarised as follows:

 Bus journey time delays s106 payments (£6m or equivalent journey time saving through works);  Section 278 agreements with TfL and the Council for highway works including works Park Lane gyratory and TLRN;  Local highway improvements s106 payment (provisional £2.5m to be confirmed by Council);  Public realm improvements s106 payment (provisional £4m to be confirmed by Council);  Additional bus service s106 payment (£7,975,000);  Bus stop audit and upgrades to local bus stops through s106 payments (£10k per stop);  Payment of s106 contributions and associated controls in order to deliver the Dingwall Loop prior to occupation (£29.5m);  George Street tram stop improvement s106 payment (£1m);

page 12  Check service frequencies, update impact analysis and discuss required mitigation for West Croydon Station;  Feasibility study into second entrance at West Croydon Station with s106 payment to secure delivery if feasible (amount to be confirmed);  Delivery of Lansdowne Road/ Wellesley Road crossing;  Further analysis of pedestrian movement;  Submission of a draft Cycling Strategy and commitment to providing cycle parking to London Plan standards;  Further analysis of potential pedestrian and cyclist conflict on Poplar Walk and Wellesley road;  Further detail on the strategy for consolidation of car parking in the retail core;  Detailed design and management of coach drop-off and pick up to be secured;  Car club provision;  Car park management strategies for both the development and the wider town centre to be secured;  Delivery of a Variable message signage system (£300,000)  Further details on taxi and private hire vehicle provision;  Travel plan and payment of a s106 travel plan fund (£1.5m)  Further information on construction impacts and programming  Construction management and logistics plans to be secured;  Delivery and servicing plans to be secured  TfL to be a s106 party including payment of legal fees  Funding for future TfL officer time to work on and monitor detailed design of the application (£20k per annum for five years) 62 Overall the s106 payments identified above come to a total of £46,630,000, which does not include the payments to be confirmed by the Council or payments to be confirmed through the bus stop audit or identified through further information on West Croydon Station and the draft cycle strategy. The following table sets these payments out alongside the payments secured under the extant consent.

Contribution Amount secured in Amount sought for current previous consent application Public realm works £4,000,000 Tbc by Council Bus network enhancements £10,000,000 £7,975,000 plus up to £6,000,000 dependent on journey delays Bus stands £600,000 Tbc £10,000 per bus stand Car club membership - £180,000 Local highway improvements £2,500,000 Tbc by Council Variable message signage - £300,000 Sustainable transport fund £1,625,000 £1,625,000** Dingwall Loop £15,000,000 £29,500,000 West Croydon Station - Tbc George Street Tram Stop - £1,000,000 TfL monitoring officer £50,000 £50,000** Total £33,775,000 £46,630,000* * Total figure does not include payments to be confirmed by the Council or identified through the bus stop audit, further information on West Croydon Station and the cycle strategy. ** Subject to indexation from previous consent.

page 13 Housing

63 London Plan Policy 3.3 confirms the pressing need for more homes in order to promote opportunity and provide a real choice for all Londoners in ways that meet their needs at a price they can afford. London Plan Table 3.1 sets a target for Croydon Council to deliver a minimum of 1,435 new residential units a year until 2025. The Croydon OAPF seeks to secure approximately 1,100 new homes within the Retail Core in which the site is located.

64 The total amount of residential accommodation to be provided on the site is set out as a range between the minimum and maximum development parameters. The proposed development seeks between 93,570 sq.m and 139,465 sq.m GEA of residential floorspace, which could provide indicatively 626 to 967 residential homes with the precise number of homes to be defined at the reserved matter stage. The extant consent permits a range between 32,512 sq.m and 48,924 sq.m GEA of residential floorspace, which secures an indicative range of 400 to 600 residential homes. The current proposals therefore have the potential to make a greater contribution to the town centre's residential offer, which is strongly supported in accordance with London Plan Policy 3.3 and the Croydon OAPF.

65 The proposed development scheme provides the option to deliver an element of student housing (sui generis use) or hotel (Use Class C1) floorspace (but not both). Any student accommodation or hotel will be delivered from the maximum residential floorspace figure (139,465 sq.m GEA). The scheme allows for a maximum of 20,684 sq.m GEA of student accommodation or hotel which would provide up to 500 bed spaces. In such a scenario an indicative maximum figure of 825 residential units would be achievable.

Build to rent

66 The proposed residential accommodation would be delivered as build to rent, which is supported in accordance with London Plan Policy 3.8 and the draft Affordable Housing and Viability SPG. The draft SPG provides specific guidance on build to rent developments. The homes should be secured as build to rent as defined by the draft SPG, including a covenanted period of at least 15 years, which the applicant has confirmed. A clawback mechanism will be required in the event of units being sold out of the build to rent sector during the covenant. Regard should also be given to the five key management standards set out in the draft SPG, which should be embodied within the section 106 legal agreement. GLA officers will work with the applicant and Council to agree suitable obligations within the section 106 legal agreement.

Affordable housing

67 London Plan Policy 3.12 requires that the maximum reasonable amount of affordable housing is sought when negotiating on development proposals. The draft SPG provides specific guidance for affordable housing and viability that recognises the distinct economics of the build to rent sector. The application proposes that on-site affordable housing will be provided in the discounted market rent (DMR) tenure, the principle of which is supported in accordance with the draft SPG. The DMR units will be provided with a minimum 20% discount to open market rent, although further details and discussions are required to agree a level of discount that will meet local housing needs.

68 As set out in the draft SPG the DMR units should be owned and managed by the build to rent landlord. The applicant has confirmed that the DMR units will be pepper potted with the non- discounted rental units and secured in perpetuity via the section 106 legal agreement, which is supported in accordance with the draft SPG.

page 14 69 At present the applicant has not confirmed what proportion of the proposed build to rent units will be provided as DMR units. A full viability assessment has been made available to the Council and their independent viability consultants subject to a non-disclosure agreement. The applicant has offered to provide the GLA with a copy of the summary viability assessment on the basis that it enters into a non-disclosure agreement. The applicants approach to viability information is unacceptable, being inconsistent with the principles of openness and transparency required to foster a greater understanding of and trust in the planning system as promoted within the Mayors draft Affordable Housing and Viability SPG.

70 The applicant must set out the proportion of affordable housing proposed and allow this to be robustly interrogated in an open and transparent manner. If very exceptional circumstances provide legitimate reasons for keeping limited elements of viability information confidential, the applicant must clearly detail them to allow the Mayor to consider whether the public interest in maintaining the exception outweighs the public interest in disclosing the information.

Housing mix

71 London Plan Policy 3.8 requires new developments to offer a range of housing choices, in terms of sizes and types. London Plan Policy 3.11 accord a priority to family sized affordable housing. As the application is outline stage the final mix of unit sizes have not been confirmed. Given the sites town centre location and the build to rent tenure of the housing proposed, local policy requiring a range of unit sizes should be applied flexibly.

Children’s play space

72 Given that the application is in outline, the child yield and play space requirements in accordance with the Mayor’s Shaping Neighbourhoods: Children and Young People’s Play and Informal Recreation SPG, cannot be confirmed at this stage. However, the submitted landscape and public realm strategy includes a play and recreation strategy assumes a child yield range of 43- 66 children. Although the final unit size and tenure mix will have a big impact upon the final child yield figure, this indicative figure appears to be low and further discussion is required to ensure that the development is able to meet the play space requirement.

73 The majority of play space proposed in the development will be designed for 0-11 year olds. Dedicated play space will be provided at roof level and the Council should secure the delivery of suitably designed and located play space through appropriately worded conditions. Play and recreation opportunities for 12+ year olds have been identified within 800m of the site, including Park Hill Recreation Ground and Wandle Park, which is supported.

Density

74 London Plan Policy 3.4 seeks to optimise housing output taking into account local context and character, the design principles in chapter 7 and public transport capacity. With an urban character context and excellent Public Transport Accessibility Level (PTAL) of 6b the site is at the upper range of the density matrix set out in Table 3.2. Moreover the London Plan and associated guidance within the Mayor’s Housing SPG, acknowledges the potential for large development sites in Opportunity Areas to define their own character. As such the principle of a high quality, high density development is supported in the interests of optimising development potential and increasing housing supply in accordance with London Plan policies 3.3 and 3.4. The applicant should confirm the net residential density of the proposed development in the maximum scenario.

page 15 Residential quality

75 London Plan Policy 3.5 promotes quality in new housing provision and sets out minimum space standards at Table 3.3. As of 1 October 2015 the Government’s technical housing standards came into effect, and these have been adopted through a minor alteration to the London Plan. The design guidelines confirm ensure that all residential accommodation will be designed in accordance with these standards. In addition the guidelines require the design of the residential towers to conform with requirements relating to shared amenity space and floor to ceiling heights. The Council should secure details of the design of residential accommodation to ensure compliance with London Plan Policy 3.5. Urban design

Layout

76 The general layout follows the broad principles laid down by the approved scheme, including the disposition of routes through the site. The proposed arrangement will deliver a significant improvement to the layout and permeability of the Croydon Town Centre. The provision of a new 24 hour accessible route, referred to as the Galleria, will improve connections from Lansdowne Road through the site to the old town centre. The revised proposals allow this route to be step free, which is welcomed. Whilst the principles set out in draft design guidelines generally support the creation of a high quality route, further detail should be provided in the guidelines to achieve the objective of a permeable route, including restrictions to avoid clutter such as retail kiosks.

77 The proposals include provision for the creation of threshold spaces at the entrance of public routes through the development, which is welcomed. The applicant is encouraged to further refine the guidelines with relation to specific threshold spaces to provide individual character that is more responsive to the character of the specific locations.

78 The environmental statement includes a wind microclimate study based on the results of a wind tunnel assessment in the minimum and maximum massing parameters. Most receptors at ground level have been assessed as having conditions suitable for their intended uses. However, the entrance location at Galleria East has been assessed as being one category windier than the desired condition in the windiest season. The design guidelines for this threshold space should be refined to secure the delivery of the mitigation measures recommended in the environmental statement.

79 One of the key differences to the approved scheme relate to the additional site areas now included in the proposals. The residential zone fronting Wellesley Road extends further north to incorporate the site of Green Park House, which is supported. The demolition of the Whitgift car park removes parking from the lower levels and the Marks and Spencer building is demolished and replaced. These changes provide an opportunity to create a significant new public open space on Poplar Walk, which is strongly supported.

Height and massing

80 An average background height profile exists in the region of 10 to 12 storeys, although individual buildings rise markedly above this, including Saffron Square, which rises to 150.9m. As established by the approved scheme the principle of developing tall building on this site, within an opportunity area and town centre with good access to public transport, is supported in accordance with London Plan Policy 7.7.

page 16 81 The approved scheme focused taller elements towards the Wellesley Road frontage stepping down in height towards the more sensitive areas of George Street, North End and Poplar Walk where heritage assets and the Conservation Area are located. The approved scheme would deliver four residential towers along Wellesley Road forming a legible group and marking key routes. The revised scheme follows this general approach, although there are areas where the height and massing has increased, including the addition of car parking to the upper levels. The additional height and massing related to car parking and retail elements enables significant improvements at street level and is supported.

82 The maximum height of the proposed residential towers has increased from 160m to 194.3m and the massing has increased from a maximum width of 26m to 38m. The increased site area also allows for the delivery of an additional residential tower in the maximum scenario. The principle of buildings within the proposed locations and height ranges is supported with regard being had to the visual impact of the proposals on the character of the area and heritage assets as discussed in the following section. The increased building width allowances are proposed to allow for greater articulation of the towers as shown in the illustrative scheme. The design guidelines should be further refined to ensure that the maximum width does not result in an overly bulky massing form.

83 The environmental statement includes a wind microclimate study based on the results of a wind tunnel assessment in the minimum and maximum massing parameters.

Architecture and materials

84 The application is to be submitted in outline and the detailed appearance and materials will be dealt with via reserved matters. The draft design guidelines set out principles to guide the appearance and materiality of the street frontages, which is welcomed.

Landscape and public realm

85 The proposed development will deliver extensive improvements to existing public realm and create new areas of public realm, which is strongly supported. Whilst detailed landscape design will be dealt with via reserved matters, the design guidelines provide extensive guidance for works both within and outside the red line application boundary, which is welcomed. New tree planting on Wellesley Road should be of a scale and maturity that responds to the scale of the development. Strategic views and heritage assets

86 The site is not over-sailed by any strategic viewing corridors and none of the views identified in the London View Management Framework are relevant to the proposed development of the site.

87 The impact of the proposed development upon nearby heritage assets has been assessed with reference to the applicants townscape and visual impact assessment. In making this assessment, regard has been had to the Planning (Listed Buildings and Conservation Areas) Act 1990, which sets out the tests for dealing with heritage assets in planning decisions. Regard has also been had to the extant consent as a material consideration. Generally the proposed development under both minimum and maximum massing scenarios, would represent a significant improvement on the existing buildings that would have a positive effect upon the character and setting of nearby heritage assets including the Grade I Listed Parish Church of St Michael and All Angels, the Grade II Listed Electric Showrooms and the Central Croydon Conservation Area.

88 In the maximum massing scenario the commercial element and one of the residential towers would be visible behind the Grade I Listed Hospital of the Holy Trinity and from within its enclosed

page 17 central courtyard. High quality design and materials will be required in the detailed design of the facades to minimise any impact. The design guidelines ensure that any nearby plant is located to ensure that harmful visual impacts are minimised, which is welcomed. In order to fully assess the impact of the development on this heritage asset, views 11 and 25 should be rendered with the illustrative scheme. Air quality

89 The whole of Croydon is an area where air quality does not meet national air quality standards. The environmental statement includes an assessment of traffic and plant emissions resulting from the proposed development. Whilst some receptors are likely to experience adverse effects, overall the development is not considered likely to cause a significant effect on local air quality. Inclusive design

90 London Plan Policy 7.2 seeks to ensure that new development achieves the highest standards of accessible and inclusive design. The proposed development has been designed in accordance with the principles of inclusive design and the needs of disabled and ambulant disabled occupants and visitors have been considered throughout the design process. The proposals have been presented to the GLA Strategic Access Panel at pre-application and application stage.

91 The proposed development creates two new, fully accessible routes that bisect the site north-south and east-west. A level change of 2-3 metres between the eastern part and western part of the latter route is addressed with a slope up from North End towards Wellesley Road. The design guidelines states that the maximum gradient for all routes will be 1:20 with every effort to be made to achieve more shallow gradients. The guidelines also require a level landing to be provided for every 500mm rise. As previously discussed the design guidelines for the Galleria route should ensure that the route is free of obstructions and clutter.

92 Central to many of the shopping mall areas are escalators. It is however not clear from the plans provided where the alternative means of vertical access will be located in relation to these. The design and access statements accept that escalators are not accessible for many people, it should therefore be ensured that alternative options i.e. lifts and stairs are within close proximity to present users with all the available options, minimising travelling distances between them.

93 The applicant is committed to working in conjunction with Tramlink to remodel the existing tram stop on George Street to provide a more legible, step-free arrival by tram and directly into the redeveloped Whitgift Centre, which is welcomed. A dedicated accessible setting-down parking bay, off Wellesley Road and close to an entrance to the shopping centre will be provided. The proposed levels of disabled persons parking for new shopping, recreation and leisure facilities are not in accordance with Table 6.2 of the London Plan. GLA officers would welcome further discussions with the applicant and TfL officers aimed at securing an acceptable amount of disabled persons parking. The provision of shopmobility is welcomed. However, the guidelines currently provide for shopmobility services within 50 metres of accessible car parking bays but do not contain provisions for people arriving by public transport. The applicant should consider opportunities to provide shopmobility services in locations accessible to the pedestrian accesses.

page 18 94 The illustrative view of ‘Poplar Walk towards Wellesley Road’ shows tapering steps with a ramp cutting through them from street level up to the pedestal level. This approach will be problematic for many people and does not achieve the ‘highest standards of accessible and inclusive design’ required by London Plan policy 7.2. The sloped area is described as an accessible ramp and as such should be designed in accordance with the latest guidance on ramps and incorporate the correct dimensions, level landings, gradients, edge upstands, handrails and handrail extensions.

95 The design and access statement confirms that 90% of the proposed residential units will be designed to M4(2) and 10% M4(3)- which is in accordance with current London Plan Policy. The applicant should address the above comments and the Council should secure the provision of wheelchair units and blue badge parking through condition or legal agreement to ensure compliance with London Plan Policy 7.2. Climate change mitigation

Energy strategy

96 A range of passive design features and demand reduction measures are proposed to reduce the carbon emissions of the proposed development. Both air permeability and heat loss parameters will be improved beyond the minimum backstop values required by building regulations. The applicant should outline the measures considered to avoid overheating and minimise cooling and provide further information on energy performance to ensure compliance with London Plan Policy 5.9.

97 It is understood that connection of the development with the planned Croydon Metropolitan Centre District Heating Network is not feasible due to timescales and the relatively low heating loads of the retail component. The applicant should provide further evidence to demonstrate this.

98 The applicant has provided a commitment to ensuring that the development is designed to allow future connection to a district heating network should one become available, which is welcomed. The applicant should confirm that a site wide heat network is proposed to which all uses, residential and commercial, will be connected and provide further information on the heat network and energy centre.

99 The applicant is proposing to install a 2.19 MWth gas fired CCHP unit as the lead heat source for the site network. Further information on the CCHP should be provided including the total anticipated space heating, space cooling and domestic hot water (DHW) demand of the development (MWh annually) as well as any implications associated with the phasing of the development.

100 The applicant has investigated the feasibility of a range of renewable energy technologies but is not proposing to install any renewable energy technology for the development. However, in light of the zero carbon target the applicant is strongly encouraged to maximise the on-site carbon savings through the inclusion of PV panels. A roof layout of the likely areas that could accommodate the PV should be provided.

101 An on-site reduction of 4,424 tonnes of CO2 per year in regulated emissions compared to a 2013 Building Regulations compliant development is expected for the domestic buildings, equivalent to an overall saving of 37%. However, the comments above should be addressed before compliance with London Plan energy policy can be verified.

page 19 Local planning authority’s position

102 The Council is currently assessing the application and a provisional committee date has not been set for the application to be presented to planning committee. Legal considerations

103 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

104 There are no financial considerations at this stage. Conclusion

105 London Plan policies on transport, housing, urban design, strategic veis and heritage assets, air quality, inclusive access and climate change are relevant to this application. The application broadly complies with the London Plan however, further information and/or confirmation, as detailed below is required to comply fully. Land-use: Further details and discussion required in regards to affordable retail and student residential accommodation. The applicant should provide an assessment of demand for student accommodation that includes analysis of the supply and demand for purpose built student accommodation in the South London sub-region. Affordable student accommodation should be secured. Transport: The development will generate approximately 30 million visitors a year requiring significant upgrades to transport services and public realm. Tram and bus capacity mitigation measures along with highway access and walking and cycling improvements on the surrounding network are required. Other issues relate to rail stations, car parking, cycle parking and blue badge parking. Housing: Delivery of between 626-927 homes in the build to rent sector with on-site delivery of discount market rent units is supported. The applicants approach to viability information is unacceptable. The proportion of affordable housing should be clarified along with the level of discount and the viability information should be rigorously interrogated in an open and transparent manner. Urban design: Various to refinements to the design guidelines required to secure matters related public routes and realm, wind mitigation and massing. Strategic views and heritage assets: The illustrative scheme should be rendered in views 11 and 25 to fully assess the impact on the Grade I Whitgift Almshouses.

page 20 Inclusive design: The Galleria route should be clutter-free and further information is required in relation to accessible lift access. Shop mobility should be provided for people arriving from public transport and pedestrian routes. The illustrative design of the tapering ramp at the Poplar Walk entrance is not acceptable and should be revised.

Climate change mitigation: The comments in the energy strategy section should be addressed to verify compliance with the London Plan.

for further information, contact GLA Planning Unit (Development & Projects Team): Colin Wilson, Senior Manager – Development & Projects 020 7983 4783 email [email protected] Sarah Considine, Strategic Planning Manager (Development Decisions) 020 7983 5751 email [email protected] Russell Smith, Case Officer 020 7983 4782 email [email protected]

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