planning report PDU/2126/01 8 February 2011 Excalibur Estate, Catford in the London Borough of Lewisham planning application no. DC/10/75973

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

The proposal Hybrid application for the demolition of the existing buildings and provision of 371 residential units in buildings ranging from 1 to 3-storeys in height with associated car and cycle parking, highway infrastructure, landscaping and open space.

The applicant The applicant is London and Quadrant Housing Group, and the architect is Hunter and Partners.

Strategic issues The principle of renewing this estate is strongly supported and in the interest of good strategic planning in London. The proposal is broadly consistent with London Plan policies; however, the proposal would benefit from some design alterations. Further information and discussion is also required on access, child play space, energy and transport.

Recommendation That Lewisham Council be advised that while the application is generally acceptable in strategic planning terms the application does not comply with the London Plan, for the reasons set out in paragraph 66 of this report; but that the possible remedies set out in paragraph 68 of this report could address these deficiencies.

Context

1 On 13 January 2010 the Mayor of London received documents from Council notifying him of a planning application of potential strategic importance to develop the above site for the above uses. Under the provisions of The Town & Country Planning (Mayor of London) Order 2008 the Mayor has until 23 February 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 of the Schedule to the Order 2008:”Development which comprises or includes the provision of more than 150 houses, flats or houses and flats”.

page 1 3 Once Lewisham Council has resolved to determine the application, it is required to refer it back to the Mayor for his decision as to whether to direct refusal; take it over for his own determination; or allow the Council to determine it itself.

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

5 The 6.7 hectare site is located to the east of Forester Memorial Park and to the south of Catford town centre. The site comprises 178 post war pre fabricated homes, which were erected in 1946 and intended to have a 10 year life span. The site is an infill site and with the exception of the access roads and the children’s nursery, is entirely bounded by rear garden fences. The site is not located in a Conservation Area.

6 The site is located on borough roads approximately 1kilometre from the A21 Bromley Road and the A205 South Circular Road, both of which form part of the Transport for London road network. The nearest railway stations are Grove Park and Bellingham, although as these are both located over a kilometre away, they are not considered to be within an acceptable walking distance of the site. The site is directly served by one bus route, with bus stops located throughout the estate. As such, it has been demonstrated that the site records a very poor public transport accessibility level of 1, on a scale of 1-6, where 6 is the highest.

Details of the proposal

7 Permission is sought to redevelop the existing pre-fab estate to provide a new residential development comprising a mixture of flats and houses ranging from 1 to 3-storeys in height.

8 The site has been split into two phases. The first phase is a detailed planning application for 152 residential units and the second phases is an outline application fixing the siting, access, scale and massing of the proposal for 219 units.

9 A breakdown of the units is shown below.

Social Intermediate Market Total rent 1bed - 11 29 40 11% 2 bed 118 61 104 283 76% 3 bed 33 - - 33 9% 4 bed 15 - - 15 4% Total 166 72 133 371 45% 19% 36%

Case history

10 On 13 March 2008 a pre-application meeting was held between the applicant and GLA officers to discuss the redevelopment of the estate. After which advice note PDU/2121 was issued. The advice note concluded that the proposal was broadly consistent with London Plan policy; however, further information and discussion was required on housing, playspace, design

page 2 and energy. The need for a follow up pre-application meeting was also expressed by both the applicant and GLA officers, although one never took place. Strategic planning issues and relevant policies and guidance

11 The relevant issues and corresponding policies are as follows:

 Estate renewal and London Plan; PPS1;PPS3; Housing SPG; Housing Strategy; affordable housing interim Housing SPG; Housing SPG EiP  Density London Plan; PPS3; Housing SPG; Interim Housing SPG; Housing SPG EiP draft  Urban design London Plan; PPS1  Access London Plan; PPS1; Accessible London: achieving an inclusive environment SPG; Planning and Access for Disabled People: a good practice guide (ODPM)  Child play space London Plan; Providing for Children and Young People’s Play and Informal Recreation SPG,  Climate change London Plan; PPS1, PPS1 supplement; PPS3; PPG13; PPS22; draft PPS Planning for a Low Carbon Future in a Changing Climate; the Mayor’s Energy Strategy; Mayor’s draft Climate Change Mitigation and Adaptation Strategies; Mayor’s draft Water Strategy; Sustainable Design and Construction SPG  Transport London Plan; the Mayor’s Transport Strategy; PPG13

12 For the purposes of Section 38(6) of the Planning and Compulsory Purchase Act 2004, the development plan in force for the area is the Lewisham Unitary Development Plan 2004 and the London Plan (Consolidated with Alterations since 2004).

13 The following are also relevant material considerations:  The draft replacement London Plan, published in October 2009 for consultation.  The Core Strategy Development Plan submission draft (2010).

Estate renewal and affordable housing

14 The provision of residential accommodation on this site is supported by policy 3A.1, which seeks to increase London’s supply of housing. Policy 3A.3 seeks to ensure that development proposals achieve the maximum intensity of use compatible with the local context, the design principles in policy 4B.5 of the London Plan and with public transport.

15 Policy 3A.15 of the London Plan resists the loss of housing, including affordable housing, without its planned replacement at existing or higher density. Paragraph 3.75 of the London Plan gives further advice on the Mayor’s approach to estate renewal. This approach is carried through to the draft replacement plan in policy 3.13 (B) and paragraph 3.75. More detailed guidance is set out in Section 20 of the Housing SPG. This clarifies that there should be no net loss of affordable housing, which can be calculated on a habitable room basis and should exclude right to buy properties. Replacement affordable housing can be of a different tenure mix where this achieves a better mix of provision.

page 3 16 Private housing that forms part of estate renewal schemes need not provide the normal level of additional affordable provision, where this is necessary to cross subsidise redevelopment. This would need to be justified through a financial appraisal.

17 The site contains 178 existing residential units, of which 152 are social rented and 27 having been purchased from the local authority are now freeholder properties. The proposal will provide 238 affordable units. As such there will be a net gain of 83 affordable units, this is broken down into a net gain of 11 social rented units and 72 intermediate units. Overall the proposal will provide 67% affordable housing by habitable rooms.

18 The applicant has produced an economic viability assessment to demonstrate that the proposal includes the maximum reasonable amount of affordable housing. This is based on the L&Q Housing Group receiving grant funding for the proposal. GLA officers understand (on advice from the applicant) that providing planning permission is granted before the end of the financial year grant funding by the Homes and Communities Agency will be approved. However, if grant funding is not available the applicant requests the right to sell the intermediate units at market value to make up the short fall. Whilst this may be necessary to make the project viable, the S106 agreement should be carefully worded to ensure that there is no reduction of the 166 social rented units.

19 All of the existing pre-fab units are two bedroom units and the majority of the new proposal will also be two bedroom units, however, the applicant has also provided three and four bedroom social rented units and some 1-bedroom intermediate and private units. As such the proposed mix fits broadly within the Mayor’s London wide preferred housing mix. It also takes account of the needs of the existing residents to be re-housed and is the product of extensive consultation with local residents and Lewisham Council.

20 There is some opposition to the proposal from local residents especially those who have lived in the units since their erection in 1946; who wish to see the pre-fab estate retained as a piece of living history from the second world war. However, Lewisham Council’s justification for renewal is supported. Density

21 London Plan policies 4B.1 and 3A.3 outline the need for development proposals to achieve the highest possible intensity of use compatible with local context, the design principles of the compact city, and public transport accessibility. Table 3A.2 of the London Plan provides guidelines on density in support of policies 4B.1 and 3A.3.

22 The proposed residential density of the site is 184 habitable rooms per hectare. This is within the guidance contained within table 3A.2, which provides a guidance range of 150 - 200 habitable rooms per hectares for suburban sites with a public transport accessibility level of one.

Urban design

23 Good design is central to all objectives of the London Plan and is specifically promoted by the policies contained within Chapter 4B which address both general design principles and specific design issues. London Plan Policy 4B.1 sets out a series of overarching design principles for development in London. Other design polices in this chapter and elsewhere in the London Plan include specific design requirements relating to maximising the potential of sites, design quality, inclusive design and safety. The draft replacement plan includes further detailed design policy in Chapter 7

page 4 Layouts: masterplan

24 The existing layout of the estate is largely disconnected from the wider surrounding environment, almost hidden from view with a limited relationship to the existing scale, grain or character having almost landed on site in response to the World War II housing crisis as temporary accommodation which has remained ever since. It does however have its own character for that very reason.

Existing layout (Source: design and access statement)

25 The new masterplan layout has been through extensive consultation with various stakeholders, including the Council, GLA and existing residents.

Spine road within the master plan (Source: design and access statement)

26 The introduction of the central spine route that runs east to west across the northern part of the site will provide an important and well-defined route, that will help to distinguish the main road from the other home zone parts of the site. At pre-application GLA officers were keen to ensure the legibility of the layout was clear for residents and visitors. It would appear that the spine road is now an uninterrupted route, having previously been sectioned off at three points. The presence of the linear park that runs parallel could, however, be stronger. At present it is less of a park and more a landscape buffer to the spine road, which is also suggested in the

page 5 visualisations in the design and access statement. The design team should consider the function of this space and whether parts of it could be increased in size.

27 The design team has amended the layouts to remove rear-parking courtyards. Parking is all on street, which will help to limit antisocial behaviour often associated with poorly surveyed dead end spaces.

28 Some of the materplan layout needs further localised analysis in particular regarding boundary relationships; specifically in the north-west corner, and where existing buildings puncture the masterplan to the west, south and southeast corner. At present it is not clear how these existing buildings will be integrated into the masterplan layout. Whilst to the south of the spine road the application is in outline, the detail needs to be set out in the form of design coding to establish key design principles, in particular showing sections and precedent images regarding how this will be considered at reserved matters stage. (see comments below regarding the outline scheme).

29 Notwithstanding the above, the overall approach remains similar to that seen at pre- application with a clear focus on blocks that face public routes, having a clear and direct relationship to those routes by introducing active uses throughout the site. Key to the success of the layout is underpinned by the use of perimeter blocks, orientated in a north – south alignment that will provide good access to natural light for most units.

Layouts: units

30 The design and access statement and plans confirm that dwellings will meet the minimum space standards set out in the Mayor’s Housing Design Guide and the Mayor’s emerging draft replacement plan. Some basic amendments to the internal configuration to some of the units could, however, provide much-improved layout and a more flexible living space. For example, in the terraced and town house accommodation, the location of the WC on the ground floor between the kitchen and living room could be relocated to provide flexibility for a single kitchen-dining- living room space, creating light from front and back and options for open plan living that can be sub-divided with folding doors or similar. The design team should explore this approach.

31 Balcony space is provided for all flats above ground floor. Communal space, however, for these units and those on the ground floor is unclear. There is no detailed plan showing the ground floor arrangements for each character area, other than the internal layouts and the masterplan shown on page 4 of the design and access statement. These should be provided and communal space identified as part of the overall ground floor arrangements.

Form/architectural appearance

32 London Plan policy 4B.1 and 4B.2 underpin the Mayor’s aspiration to create world class architecture that inspires, excites and delights.

33 The proposals are submitted as a hybrid part detail (phase 1), part outline (phase 2) basis. Phase one comprises the north of the site and is submitted in detail. Here the architects have identified five character areas. Whilst the approach to character areas is not uncommon in masterplanning, the character of the architecture should be based on urban design analysis and design rationale with the intended end users as consideration in the round.

34 Character area five needs further consideration regarding the broad approach. This area relates to the provision of over-55 accommodation. The merits of keeping these units in close proximity or in clusters is supported, however they are unnecessarily distinguishable from the rest of the masterplan, not for specific architectural or urban design reasons but on functionality for the

page 6 intended occupiers. This can, however, be improved in terms of the need for blue badge parking bays across the whole street frontage. If these are allocated to individual units then the need for signage should be reconsidered. The London Plan seeks that affordable housing is tenure blind. Whilst character areas are supported, the current approach seems to distinguish this character area on end user only rather than on the basis of any informed urban design analysis or design rationale. This matter requires further consideration by the design team.

35 There are examples of successful home zones. In this particular case the home zone is illustrated as a very hard environment, presumably on the basis that it is low maintenance rather than for creating high quality environments. Areas of play and public open space are not clearly defined other than to the east in character area five.

36 The success of this scheme will be dependent, therefore, on the quality of the materials. Some of the porch detail appears overbearing or hard additions to the street where the environment is already dominated by brick block and paving. The Council should ensure that adequate conditions are imposed that require a high quality material finish to all aspects of the development, and ensure that in particular the quality of finish to the public realm, foot paths and parking bays is not neglected. Further work is required to improve the broad approach. Whilst the architecture is generally acceptable, it does not necessarily inspire, excite or delight, but is rather more functional, understated and designed to standard.

Outline scheme

37 In order for the Mayor to be satisfied that the outline element of the proposals will meet the aspirations of the London Plan, the design and access statement should include an addendum that draws key aspects of the detailed scheme that will be carried through to phase 2 details. This should be set out in the form of a design code that should be part of the approved documentation that will inform the subsequent detail of reserved matters for phase 2. Access

38 The aim of policy 4B.5 is that proposals aim for the highest standard of accessibility and inclusion and that the design process has from the outset considered how everyone, including disabled and deaf people, older people, children and young people, will be able to use the places and spaces that are proposed. London Plan policy 3A.5 requires that 10% of all new homes be wheelchair accessible or easily adaptable for occupation by a wheelchair user.

39 Policy 3.8 in the draft replacement London Plan (Paragraph 3.42) references the Habinteg Housing Association Wheelchair Housing Design Guide, which requires one parking bay for every wheelchair user home (10% of the total number of residential units). The revised Lifetime Home standards (published June 2010 see www.lifetimehomes.org.uk) recommends that in addition to those bays needed for residents of the wheelchair user homes, at least one designated Blue Badge bay should be provided beside each lift core/block entrance.

40 Currently, the applicant provides limited detail regarding parking provision for blue badge users and the Lifetime Homes standards. It is not clear exactly what percentage of parking will be blue badge. Regarding the Lifetime Homes standards it is not clear if this has been assessed against the revised June 2010 guidance referred to above. Page 49 of the design and access statement states that “a small number of the criteria shall not be met”. The applicant should be clear what these are and provide details to justify the approach. The reference to blue badge parking adjacent to lift cores does not apply to phase 1 given there is no lift access identified in the flatted blocks or anywhere in this phase. Should lift access be identified for phase 2, this approach would apply. This matter should be dealt with as part of the design coding for phase 2.

page 7 Child play space

41 Policy 3D .13 of the London Plan sets out that “the Mayor will and the boroughs should ensure developments that include housing make provision for play and informal recreation, based on the expected child population generated by the scheme and an assessment of future needs.” Using the methodology within the Mayor’s supplementary planning guidance ‘Providing for Children and Young People’s Play and Informal Recreation’ it is anticipated that there will be approximately 158 children within the development. The guidance sets a benchmark of 10 sq.m. of useable child playspace to be provided per child, with under-5 child playspace provided on-site. As such the development should make provision for 1,580 sq.m. of playspace.

42 The design and access statement states 1,479 sq.m. of child play space will be incorporated into the open space master plan, however, it would appear that the applicant has double counted general open space as designated child play space. The applicant has been asked to provide plans detailing the exact location of the play space, along with the details of the type of play equipment to be provided. The applicant has also been asked to provide details of existing surrounding play facilities that residents of the site could use to supplement the onsite offer. This information should be submitted before the application is referred back to the Mayor. Climate change mitigation

43 The London Plan climate change policies as set out in chapter 4A collectively require developments to make the fullest contribution to the mitigation of adaptation to climate change and to minimise carbon dioxide emissions (policy 4A.1).

Be lean

44 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. Other features include mechanical ventilation with heat recovery.

45 Based on the information provided, the proposed development does not appear to achieve any carbon savings from energy efficiency alone compared to a 2010 Building Regulations compliant development.

46 Using 2010 Building Regulations compliance software, the applicant should model, and commit to, additional measures that can be adopted to enable the development to exceed 2010 Building Regulations compliance through energy efficiency alone.

Be clean

47 No reference is made to existing or planning district heating networks within the vicinity of the development. Further information is required in this regard.

48 The applicant claims that the blocks of flats are too spread out across the development to implement a community heating system, as this would result in high distribution losses reducing the potential savings. Instead individual condensing gas fired boilers are proposed to provide heating and domestic hot water to the flats, as well as the houses. The ‘over ‘55s’ block will implement a centralised system with a gas fired boiler.

49 It is acknowledged that a site wide heat network will not be applicable in this case. However, the applicant should further investigate the potential for communal heating in the blocks of flats along the development’s central spine road.

page 8 50 The applicant has discounted the use of CHP. Given the type and scale of the development this is accepted in this instance.

51 The applicant should confirm the proposed cooling strategy for the proposed development particularly the passive measures to be adopted.

Be green

52 113 sq.m. of solar thermal is proposed for the ‘over 55’s block’. Additionally, a total of 1,246 sq.m. of photovoltaic panels is proposed across the development. A reduction in carbon dioxide emissions of 102 tonnes per annum 10.86% will be achieved through this third element of the energy hierarchy. The applicant should provide roof drawings showing the roof area currently allocated to solar technologies.

53 The applicant should consider the potential for solar thermal technologies to supply part of the heat requirements of communal heating serving the blocks of flats. The applicant’s attention is drawn to the recently completed Greenwatt Way development, which adopts such an approach in conjunction with a very low temperature heat network. Climate change adaptation

54 The London Plan promotes five principles in policy 4A.9 to promote and support the most effective adaptation to climate change. These are to minimise overheating and contribution to heat island effects, minimise solar gain in summer; contribute to flood risk reduction, including applying sustainable drainage; minimise water use; and protect and enhance green infrastructure. Specific policies cover heating, living roofs and walls and water.

55 In line with policy 4A.10 of the London Plan particular attention should be paid to the use of passive design and natural ventilation. The east/west orientation of the buildings and solar spaces to the south of the houses is welcomed.

56 Policy 4A.14 seeks to ensure that surface water run-off is managed as close to its source as possible, and sets out a hierarchy of preferred measures to achieve this. Policy 4A.11 seeks major developments to incorporate living roofs and walls where feasible and seeks boroughs to encourage the use of living roofs in smaller developments where the opportunity arises. Policy 4A.16 of the London Plan seeks to ensure that new development has proper regard to the impact of those proposals on water demand and existing capacity by minimising the use of treated water and maximising rainwater harvesting opportunities.

57 The sustainability statement states that rainwater harvesting system will be provided for landscaping purposes, this will include communal rainwater tanks for private gardens and individual water butts, The provision of these and the proposed living roof are strongly supported and should be secured by condition.

Transport

58 Car parking is being proposed at a ratio of 0.8 spaces per unit. This level of provision is in accordance with London Plan standards, and given the site’s inaccessible location, is therefore considered to be acceptable. In line with policy 6.13 of the draft replacement London Plan however, TfL requests that 20% of all parking spaces are fitted with electric vehicle charging points, with an additional 20% of spaces having passive provision, so that they can be easily converted in the future if needed. The uptake of the these points should be monitored through the travel plan, so that additional spaces can be activated as required.

page 9 59 Given the scale and distance of the proposals from the TfL road network, TfL is satisfied that the development is unlikely to negatively impact on the operation of the network. Similarly, it is considered unlikely that the development would have a negative impact on the capacity of the local bus network, given that it is an estate renewal and that the number of new trips being generated will be limited. However, a number of bus stops on the estate do not currently meet current accessibility standards, and following discussions with the applicant, a sum of £20,000 has been identified towards implementing the necessary improvements. This should be secured through the s106 agreement.

60 One cycle parking space per unit is being proposed, which is supported. However, in accordance with TfL’s cycle parking standards, it is recommended that a minimum of 2 spaces are provided for each 3+ bedroom unit. It should also be ensured that all spaces are in a secure, convenient and covered location.

61 The submitted travel plan is considered to be of a very high standard, and it is therefore recommended that it is secured, managed, monitored and enforced through the s106 agreement.

62 In accordance with London Plan policy 3C.25 ‘Freight’, and draft replacement London Plan policy 6.14 ‘Freight’, TfL recommends that a construction logistics plan should be secured for the site by condition. Local planning authority’s position

63 The application will be reviewed by Lewisham Council’s planning committee on 17 March 2010. Legal considerations

64 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

65 There are no financial considerations at this stage. Conclusion

66 London Plan policies on estate renewal, affordable housing, density, urban design, access, child play space, climate change and transport are relevant to this application. In general, the application complies with these policies, for the following reasons:  Estate renewal and affordable housing: The proposal will provide a net gain of 83 affordable units and 67% affordable housing by habitable room overall. The applicant has demonstrated that the proposal provides the maximum reasonable amount of affordable housing. As such the proposal complies with policy 3A.15 of the London Plan.

page 10  Density: The proposal is well within the density range guide of the London Plan. As such the proposal complies with policies 4B.1 and 3A.3 of the London Plan.  Urban design: The design is broadly consistent with London Plan policy however; there are several elements of the proposal which should be improved. A design code for the outline element of the planning application is also needed.

 Access: It is not clear exactly what percentage of parking will be blue badge. It is not clear if the proposal has been assessed against the revised June 2010 guidance for Lifetime Homes. Page 49 of the design and access statement states “a small number of the criteria shall not be met”. As such the proposal does not comply with policies 4B.5 and 3A.5 of the London Plan.  Child play space: Insufficient information regarding the quantum and quality of child play space has been submitted, As such it is not possible to ascertain whether the proposal complies with policy 3D.13 of the London Plan.  Climate change mitigation: In sufficient information regarding energy efficiency and district heating networks has been provided. As such it is not possible to ascertain whether the proposal complies with the London Plan energy policies.  Climate change adaptation: The provision of the rainwater harvesting system and living roofs should be secured by condition.  Transport: TfL is satisfied that this development is unlikely to have a negative impact on the strategic highway or public transport network, and subject to the above matters being satisfactorily addressed, it is considered that the development could be in general conformity with the transport polices of the London Plan. 67 Whilst the application is broadly acceptable in strategic planning terms. On balance, the application does not comply with the London Plan. 68 The following changes might, however, remedy the above-mentioned deficiencies, and could possibly lead to the application becoming compliant with the London Plan:

 Urban Design: Further discussion on the design of the proposal is needed. Te design code for the outline element of the application should be submitted before the application is referred back to the Mayor.  Access: The percentage blue badge parking should be submitted. Further information on the assessment of the proposal against the Lifetime Homes standards is required.  Child play space: Details of the location, size and nature of the designated play spaces should be submitted. Details of existing surround play spaces should also be submitted.  Climate change mitigation: The applicant should provide an estimate of the carbon savings, expressed in tonnes of carbon dioxide per annum and percentages, relative to a 2010 Building Regulations compliant development. Further information on district heat networks should be provided.

 Transport: Electric car charging points and a contribution of £20,000 to upgrade the existing bus stop should be secured. Cycle parking provision should be increased. The travel plans should be secured and monitored in the S106 agreement. A construction logistic plan should be secured by condition.

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for further information, contact Planning Decisions Unit: Colin Wilson, Senior Manager - Planning Decisions 020 7983 4783 email [email protected] Justin Carr, Strategic Planning Manager (Development Decisions) 020 7983 4895 email [email protected] Kim Hoffman, Case Officer 020 7983 6589 email [email protected]

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