14 December 2020

London Borough of Bromley Planning Department Civic Centre Stockwell Close Oliver Wheeler Bromley BR1 3UH 33 Margaret Street W1G 0JD T savills.com

Dear Sir or Madam,

149 Anerley Road, Anerley, London SE20 8EF Full Planning Application Planning Portal Reference: PP-09328338

On behalf of our client, BMR Compass Ltd (“the Applicant”), I write to submit, online via the Planning Portal (reference: PP-09328338) details pursuant to the ‘prior approval’ of the conversion of the basement and ground floor of 149 Anerley Road into residential accommodation. The proposals comprise three new studio units under Class M of the Town and Country Planning (General Permitted Development Order) 2015 (as amended).

The application comprises the documents set out below:

 Application Form;  CIL Additional Questions Form  Existing Basement and GF Plans – drawing no. 20.1226/028;  Existing Side Elevation – drawing no. 20.1226/024;  Existing Rear Elevation – drawing no. 20.1226/026;  Proposed Basement and GF Plans – drawing no. 20.1226 /020;  Proposed Front Elevation – drawing no. 20.1226 /022  Internal Daylight Assessment, prepared by T16 Design.

The planning application fee of £206.00 has been paid through the Council’s website.

THE SITE

The application site comprises a three storey (plus basement) mixed-use building, comprising a retail unit (Use Class E) on the ground floor with residential (Use Class C3) above. The retail unit on the ground floor is occupied as a Dry Cleaners (Use Class E). The building is located along a terrace of mixed use buildings.

According to LBB’s Policies Map, the site is situated within the ‘Crystal Palace, Penge and Anerley Renewal Area’, a ‘Skyline’ designation and an ‘Airport Public Safety’ designation.

The site is not located within a Conservation Area. There are no locally or statutory listed buildings on site or within the vicinity of the site.

According to the Environmental Agency’s Flooding Map, the site is situated within Flood Zone 1, where there is a minimal risk of flooding.

The site is in close proximity to a range of public transport infrastructure and has a Public Transport Accessibility Level rating (PTAL) of 4. Anerley Station is located 0.1miles / two minute walk from the site, and provides both

Offices and associates throughout the Americas, Europe, Asia Pacific, Africa and the Middle East. Savills (UK) Limited. Chartered Surveyors. Regulated by RICS. A subsidiary of Savills plc. Registered in England No. 2605138. Registered office: 33 Margaret Street, London, W1G 0JD the Overground Service into and around London and Southern Railway. In addition to this, there are a number of bus stops located along Anerley Road, including Stop D (where buses 157, 354, 358 and N3 operate) which is located 32m / 1 minute walk from the site.

There are a number of local amenities nearby including Betts Park which is located 160m / 1 minute walk from the site and provides a large amount of open green space for locals to enjoy. Supermarkets including ALDI are located within less than 500m / 7 minute walk from the site, along with many other local independent shops and cafes along Anerley Road.

Planning History

A desk-top search of London Borough of Bromley’s public access has identified that identified a number of planning applications relevant to the site, the details of which are below.

Decision / LPA Reference Description of Development Date Part 2/3 storey rear extensions (including enlargement of 20/04042/FULL1 basement) to provide enlarged first floor flats and retail/storage space at ground and basement floors, formation of terraces above Awaiting 149-151 Anerley ground and first floor extensions and construction of side and rear decision Road dormers with front rooflights to form additional 2 bedroom flat within the extended roofspace. Provision of integral refuse store at side. 13/03529/FULL1 Single storey rear extension and construction of basement. Approved 11th December 143 Anerley Road 2013 01/00560/FULL1 Part one/part two storey rear extension incorporating basement Approved and flat roof patio garden. 7th January 147 Anerley Road 2001

THE PROPOSAL

The proposal comprises the change of use of the basement and ground floor of 149 Anerley Road into residential accommodation, providing three new studio units and replacing an existing retail unit (Use Class E).

A large studio flat is located within the basement of the site to the rear, with additional storage space to the front of the basement. At ground floor, there are two one-bedroom studio flats proposed which are evenly sized and each include lounge/dining/bedroom and bathroom facilities.

All work is proposed under permitted development rights.

The proposed accommodation schedule is as follows:  1 x 2 bedroom dwelling – 69.7sqm;  1 x 1 bedroom dwelling – 33.5sqm;  1 x 1 bedroom dwelling – 34.5sqm;

The refuse storage provided in a secure store will be:

 2 x 1100L bins.

2 Class M Permitted Development Rights

The Government introduced the new permitted development right in 2013. It has been subsequently amended and the relevant legislation is now the Town and Country Planning Act (General Permitted Development) (Amendment) (England) Order 2015. The development proposal comprises ‘Class M(b)’ which is ‘development development referred to in paragraph (a) together with building operations reasonably necessary to convert the building … to a use falling within Class C3 (dwellinghouses) of that Schedule’ where conversion is proposed from an existing use to Class C3 residential dwellings.

Class M of Schedule 2, Part 2 states:

‘Where the development proposed is development under Class M(a) together with development under Class M(b), development is permitted subject to the condition that before beginning the development, the developer must apply to the local planning authority for a determination as to whether the prior approval of the authority will be required as to—

a) transport and highways impacts of the development, b) contamination risks in relation to the building, c) flooding risks in relation to the building, d) whether it is undesirable for the building to change to a use falling within Class C3 (dwellinghouses) of the Schedule to the Use Classes Order because of the impact of the change of use i. on adequate provision of services of the sort that may be provided by a building falling within Class A1 (shops), Class A2 (financial and professional services) or Class A5 (hot food takeaways) of that Schedule or, as the case may be, a building used as a launderette, but only where there is a reasonable prospect of the building being used to provide such services, or ii. where the building is located in a key shopping area, on the sustainability of that shopping area, and e) the design or external appearance of the building, and the provisions of paragraph W (prior approval) of this Part apply in relation to that application.’

Assessment

Transport and Highways Impact

Due to the site’s high PTAL rating and close proximity to many public transport options, the development is proposed to be car-free.

By promoting a car free development, the scheme is promoting alternative forms of transport and supporting the promotion of sustainable transport modes, something which is encouraged by both the London Plan and NPPF. This is considered the most appropriate approach to the site given its close proximity to Anerley Station and many bus stops. This demonstrates how the site is located in a sustainable location as it is accessible by a range of public transport infrastructure.

Based on this good level of transport infrastructure, the development proposals are therefore considered to be wholly acceptable in transportation planning terms and will meet the transport and highways requirements for “Prior Approval” as defined within the General Permitted Development Order.

Contamination Risks

The current retail and residential based use of the site does not pose a risk to contaminating the site. As the surrounding uses are also retail along with residential in character it is not considered that any adjacent land uses would create contamination risks on the site.

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On this basis there is not considered to be any contamination risks for the proposed future residential land use.

Flood Risk

The site is set within flood zone 1, as such, the proposed development has a low risk of flooding from external sources.

As a permitted development proposal, this development only alters the internal use and the elevations to the existing building. The impermeable footprint of the site or external ground levels remain unaltered. As a result, there would be no alteration to the existing surface water drainage network, and no impact as a result of the proposals. Therefore the development should be granted prior approval in respect of flood risk.

Undesirable for the building to change to a use falling within Class C3

The surrounding area is predominantly residential, with a number of buildings along Anerley Road already existing with retail uses on the ground floor and residential above. The properties immediately adjacent to the site are no.151, which is made up of a vacant butchers at ground floor and residential accommodation above and no. 147 which is consists of restaurant at ground floor and accommodation at the upper floors. There have been some developments along Anerley Road which has converted or built extensions to the rear of the property to provide additional residential dwellings, including the development at 143 and 147 Anerley Road.

A local availability search of commercial units has been carried out using EGPropertyLink, and Zoopla, focusing on a 1 mile radius around the site. The commercial units identified within the local availability search are summarised in Table 1. This local availability search demonstrates that there is over 1500 sq m of available Class E floorspace within 1 mile of the site, with many of these sites also of a high quality fit out to modern standards unlike 149 Anerley Road. In addition, as highlighted in Table 2, there are already a high number of laundrette and dry cleaning services operating within the local area. It is important to note that a large number of the retail units have been marketed for substantial period of time, many for over 9 months. In addition, as highlighted in Table 2, there are already a high number of dry cleaners and laundrettes already operating within the local area.

Table 1

Unit Address Size of Unit

44 Westow Street, London, SE19 3RY 121 sq m 18 Westow Street, SE19 124 sq m 23 Westow Street, London, SE19 3RY 147 sq m Westow Hill, London, SE19 1TQ 91 sq m 2 Church Road, London, Greater London, SE19 267 sq m 2ET 124 Oakfield Road, London, SE20 8RQ 302 sq m 46-48 Westow Street, Crystal Palace, SE19 3AF 236 sq m 105-107 Elmers End Road 162 sq m 73 High Street, South Norwood, London SE25 6EB 50 sq m

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Table 2

Laundrette Address Distance from 149 Anerley Road (km) Golden Arrow Dry Cleaners 80 Anerley Rd, London SE19 2AH 0.80 Browns Ironing Parlour 61 High St, London SE20 7HW 0.86 Aquar Dry Cleaners 29 High St, London SE20 7HJ 0.84 Penge Express Dry Cleaning 86 High St, London SE20 7HB 0.91 SE20 Dry Cleaners 6 Central Parade, High Street, 0.98 London SE20 7TN Regency Launderette 203 High St, London SE20 7PF 1.01 Southern Launderette 261 S Norwood Hill, London SE25 1.50 6DP Palace Cleaners 101 Church Rd, Upper Norwood, 1.26 London SE19 2PR Top Quality Dry Cleaners 9 Westow Hill, Upper Norwood, 1.53 London SE19 1TQ Kensington Dry Cleaners - Gipsy 81 Gipsy Hill, Norwood, London 1.92 Hill SE19 1QL

The following tables demonstrate that there is already a significant provision of surplus Class E floorspace in the immediate local area. In addition, there are numerous laundrette/dry cleaning services operating in the local area, highlighting that the change of use of the site into Class C3 (dwellinghouses) would not have an undesirable impact on the provision of such services in the area.

As identified on the Council’s Policies Map the site is situated within the ‘Crystal Palace, Penge and Anerley Renewal Area’, which is identified as a targeted area of regeneration. The Council’s Local Plan Policy 15 states that proposals under this designation will be expected to “to support renewal in Penge Town Centre”. The sites position along Anerley Road means that the change of use will not directly impact on the existing retail frontage. The unit is underutilised at present and therefore the development will maximise the potential of the unit. It is worth noting that the retail occupier is in support of these proposals.

Given that the site already houses residential accommodation on the site, it is considered that the introduction of 3 new dwellings to enable better quality residential accommodation is acceptable. The loss of the floorspace is not considered to adversely impact on the provision of services within the locality as detailed within Condition D of Class M.

The Design or external appearance of the building

In regards to design, the GDPO allows consideration of design or external appearance of the building, where building operations are necessary to convert the building to residential. In this case, the proposed changes broadly reflect the Council’s design guidelines.

The proposed front elevations have been carefully designed to ensure that all of the existing shopfront features have been retained in line with the character of the retail shopfronts along the terrace. The proposed window style and detailing will match that of the existing building and is considered necessary in order to allow for the conversion of the unit to residential. Whilst the original window shape has been retained for appearance, an etched film is proposed over the windows to ensure sufficient privacy for future occupiers. In addition, the signage and render across the front elevation will be painted white. Solid timber infil panels are also proposed for the front door entrance.

5 Due to the combination of measures proposed to protect the appearance of the retail frontage along Anerley Road, it is considered that the proposed external alterations would maintain the character of the area and be acceptable in terms of design.

Standard of Accommodation and Internal Space

A daylight/sunlight assessment has been carried out by T16 in support of this application. The report assesses the proposals in respect of daylight matters within habitable rooms in the proposed dwellings at basement and ground floor levels, having regard to industry standard guidance. The report concludes that the proposal is acceptable and in accordance with planning policy requirements in relation to daylight for those rooms assessed.

The proposed dwellings across the basement and ground floor therefore demonstrate the provision of adequate natural light into all habitable rooms and therefore can be considered acceptable in terms of design.

Conclusion

 It is proposed to convert the basement and ground floor (Class E) into residential accommodation, providing three new studio flats.

 There are no highways, flooding, contamination, undesirable issues for the change of use or design reasons why the development should not proceed.

 The loss of the retail floorspace is not considered significant with regards to the impact on the services for the area.

For the reasons listed above, it is considered that sufficient information has now been submitted to enable your Council to confirm that development may now proceed.

The conversion of the unit will make a much needed contribution to housing supply in Bromley. Please do not hesitate to contact should you require any further information.

Yours Faithfully,

Ollie Wheeler Savills

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