planning report PDU/2896a/02 13 February 2013 The Howbury Centre, Slade Green

in the London Borough of Bexley planning application no. 12/01219/OUTM

Strategic planning application stage II 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 Erection of mixed use development with both outline and full elements comprising outline details for demolition of existing buildings and provision of up to 94 residential dwellings and retail up to 300 sq.m. floorspace (A1) with all matters reserved. Full details for 278 residential dwellings including vehicular access, landscaping, open space and other ancillary works The applicant The applicant is Redrow Homes, and the agent is Tetlow King Ltd.

Strategic issues At the consultation stage further information was requested to justify the loss of a former school site, community facilities and playing fields.

The applicant was further requested to provide further information and changes to: housing mix and affordable housing provision, planning obligations, urban design and housing quality, inclusive access, sustainable energy and transport.

The Council’s decision

In this instance Bexley Council has resolved to grant permission/ agree a dual recommendation resolving to grant permission but giving delegated authority for officers to refuse permission if the Section 106 agreement is not signed within a specified date. Recommendation That Bexley Council be advised that the Mayor is content for it to determine the case itself, subject to any action that the Secretary of State may take, and does not therefore wish to direct refusal or direct that he is to be the local planning authority.

Context

1 On 24 August 2012 the Mayor of London received documents from Bexley Council notifying him of a planning application of potential strategic importance to develop the above site

S:\Planning Decisions\Cases\2896a\Stage 1 Report page 1 for the above uses. This was referred to the Mayor under Category 1A and 3c of the Schedule to the Order 2008:

 1A: provision of more than 150 residential units.

 3c: development which is likely to prejudice the use as a playing field of more than 2ha.

2 On 2 October 2012 the Mayor considered planning report PDU/2896/01, and subsequently advised Bexley Council that the application did not comply with the London Plan, for the reasons set out in paragraph 107 of the above-mentioned report; but that the possible remedies set out in paragraph 109 of that report could address these deficiencies.

3 A copy of the above-mentioned report is attached. The essentials of the case with regard to the proposal, the site, case history, strategic planning issues and relevant policies and guidance are as set out therein, unless otherwise stated in this report. Since then, the application has been revised in response to the Mayor’s concerns (see below). On 31 January 2013 Bexley Council decided that it was minded to grant planning permission and on 1 February 2013 it advised the Mayor of this decision. Under the provisions of Article 5 of the Town & Country Planning (Mayor of London) Order 2008 the Mayor may allow the draft decision to proceed unchanged, direct Bexley Council under Article 6 to refuse the application or issue a direction to Bexley Council under Article 7 that he is to act as the Local Planning Authority for the purposes of determining the application and any connected application. The Mayor has until 14 February 2013 to notify the Council of his decision and to issue any direction.

4 The environmental information for the purposes of the Town and Country Planning (Environmental Impact Assessment) Regulations 2011 has been taken into account in the consideration of this case.

5 The decision on this case, and the reasons will be made available on the GLA’s website www.london.gov.uk.

Update

6 At the consultation stage Bexley Council was advised that the application did not comply with the London Plan, for the reasons set out in paragraph 107 of the above-mentioned report; but that the possible remedies set out in paragraph 109 of that report could address these deficiencies:

 Principle of development: The applicant in conjunction with Bexley Council are requested to provide further information in relation to the loss of community facilities and playfields in response to London Plan polices 3.16, 3.18 and 3.19 for the principle of development to be compliant with The London Plan; details on where the library, pupil referral unit and other community uses are to be located elsewhere in the borough.

 Housing mix: the applicant should agree to fix the agreed housing mix for phase 3 within the s106 agreement.

 Affordable housing and planning obligations: Further justification is required from both the borough and applicant over the low level of affordable housing is required on a windfall greenfield site, especially if s106 contributions are to be prioritised for other objectives. Furthermore, details should be provided on how the capital receipts are to be utilised and the mechanism that will be adopted to meet the requirements of policy 8.2 of

S:\Planning Decisions\Cases\2896a\Stage 1 Report page 2 the London Plan – the applicant should agree to engage with GLA offices for further advice on resolving this matter.

 Affordable housing: A minimum level of affordable housing to be located in the outline application for phase 3 should be agreed and this should be secured and referenced in the s106 agreement condition.

 Urban Design: The applicant should consider modification of the development layout; provide further detail on the outline phase 3 in the form of parameter plans, design code and indicative layouts; all phase 1 and 2 residential units should meet London Plan minimum space standards; and confirmation provided that the phase 3 indicative layouts can meet the design guide and space standards and reference is made to the GLA design guide through condition in the s106.

 Children’s playspace: the applicant should provide a calculation of child yield and relate this to planned plays areas contained in the masterplan.

 Access & inclusive design: A need for a more comprehensively presented inclusive design strategy which responds to the issues raised relating to site layout, housing unit design, parking and inclusive public realm design. The applicant should include of 10% wheelchair accessible units across all tenures and this should be secured by condition in s106 agreement for the outline proposals for phase 3.

 Sustainable energy: Further revisions and information is required before the proposals can be considered acceptable and the carbon dioxide savings verified.

 Transport: further information and clarification is required before the proposals can be considered to fully accord with London Plan policy in terms of highway impact, public transport, walking and cycling, car parking, construction and provision of a travel plan. The applicant should agree to discussions on the outlined conditions proposed for the s106 agreement.

Principle of development: 7 At the consultation stage the applicant in conjunction with Bexley Council were requested to provide further information in relation to the loss of school site, community facilities and playfields for the principle of development to be compliant. Furthermore, details on where the library, pupil referral unit and other community uses are to be located elsewhere in the borough were requested.

8 The applicant, with support from Bexley Council, has provided an overview of the background to the school site and playing redevelopment. It is noted that Bexley Council is reinvesting £8.5 million into the community facilities and schools expansion programme in Slade Green as part of a wider regeneration programme.

Loss of a potential school site

9 Howbury secondary school closed in August 1992 due to decrease in demand for secondary school places and has since been used for range of community functions. The applicant, supported by Bexley Council, take the position that the use of the application site for educational purposes has ceased and planning permission would be required to revert back and the site development does not result in the loss of existing secondary educational facility.

S:\Planning Decisions\Cases\2896a\Stage 1 Report page 3 10 Bexley Council are in the process of producing a “commissioning plan for education” – to identify and have a shared view on current and future demand for school places. The demographic work undertaken with commissioning plan shows a shortage of reception places in the borough but not secondary school places. Data shows that 273 of the 3,454 year 7 places were available in September 2012. Bexley Council believes that there is sufficient provision until around 2019 (six years). Furthermore, pupils who live in the local area of the application site currently have access to the new Crayford Academy (opened 2011) located 2 miles away.

11 The applicant states that changing policy and the impact of free schools and other government initiatives may mean the extra demand will be met elsewhere. Potential capacity (surplus provision) has been identified by the applicant at the new Greenwich Free School (100 places); Greenwich Technical College opening in 2013 (300 places) for students aged 14 -16 in Greenwich, Bexley and Lewisham.

12 The applicant further states that even if there was demand, the cost of converting/ redeveloping the Howbury site is cost prohibitive due to the age of building and it not being fit for modern educational requirements. In addition the site contamination would need to be factored into redevelopment. Redrow have set aside £2.57 million for remedial works to deal with this issue, this is supported by a geo-environment investigation report.

13 The development agreement (paragraphs 58 -61) include within the terms that in purchasing the site from Bexley Council, Redrow are contractually obliged to contribute towards enhanced educational facilities – which will be used to help up-grade the adjacent Slade Green Schools from a three Forms of Entry Infants School and a Three Forms of Entry Junior School to two Forms of Entry Primary schools both for children aged 4 – 11. The existing junior school is to be run by the Haberdashers’ Aske's, Federation with all pupils going to the school being offered automatic entry to the new Crayford Academy.

14 An application for a single storey extension to Slade Green Infant School was submitted on 25th Oct 2012 (12/01640/FUL refers), and that an application for a single storey extension to Slade Green Junior School was submitted on 18th Oct 2012 (12/01641/FUL refers), and that both applications encompass changes to the site boundaries to facilitate changes to the current playing field provision.

15 Overall the applicant has provided a reasonable explanation for the development of the school site for non educational purposes.

Playing fields

16 The playing fields that exist on the site were affiliated with the former school and are stated as being not publically available and have not been used since the school closed in 1992. This is because the former playing fields were classed as surplus to educational requirements in April 1996 by Bexley Council’ s Land and Property Advisory Panel.

17 When assessing the sites future use, it became apparent to LB Bexley that the playing fields were contaminated and that the costs of addressing this issue would be considerable, thus making it unfeasible to remediate them and set them aside as public playing fields/to use them in association with the adjacent junior and infant’s schools.

18 The playing fields did not form part of the playing fields assessment in Bexley Council’s Open Space Strategy 2008, and that whilst the Open Space Strategy Technical Paper 9 acknowledges at Para 104 that there are insufficient outdoor sports facilities in Erith in quantitative terms. But accessibility standards shows there is a good distribution of facilities within Erith, meaning the majority of residents are able to access either a grass pitch [or] tennis court within the

S:\Planning Decisions\Cases\2896a\Stage 1 Report page 4 recommended distance threshold. Furthermore, where the Howbury regeneration site sits, there are four local parks providing more than 15 hectares of public open space. Bexley Council’s Open Space Strategy Technical Paper 9 – states the Howbury site is not identified as forming part of any strategy to enhance access to outdoor sports facilities in the area.

19 The applicant takes the view that the application site is not within an area of play space deficiency, but it has never actively formed part of the existing publically accessible facilities, and is not identified as a site needed in the longer term to address any identified need. Its loss would not therefore conflict with the aims and objectives of policies 3.16 and 3.19 of the London Plan.

20 The expansion of Slade Green Infant School (12/01640/FUL) and Slade Green Junior School (12/01641/FUL) both provide for boundary changes. Which in effect part of the land currently occupied by the Howbury Centre will be subsumed into the adjacent schools, with the land affiliated with Slade Green Junior School slightly reduced to create parity in the level of sporting and play space provision between both schools. It is understood this arrangement received Secretary of State consent.

21 Overall the applicant has provided a reasonable explanation for the development of the playing fields.

Community facilities

22 As part of the development agreement Redrow are contractually obliged to contribute towards new community facilities. This contribution is to be used by Bexley Council to help fund a new community facility to be built upon the adjacent site owned by the Council, and for which a planning application is due shortly.

23 As the new community centre it will be located upon the current playing field of Slade Green Junior School and offers a high spec all-weather and floodlit sports multi use games area with two halls for flexible use. This new community facility will also incorporate an improved local library with IT access that is lacking in the existing facilities. The new school facilities, new Multi Use Games Area and the new flexible community provision proposed in the new community halls will be DDA compliant and the activities which they can host will meet the needs of disabled users.

24 The new school play facilities may, through agreements between the community centre management company and the schools management team, be accessible by the community and this is welcome.

25 It is understood that the Pupil Referral Unit moved out of the Howbury Centre in 2011 to relocate to Abbey Wood.

26 Redrow are contractually obliged under the terms of the Development Agreement to contribute towards other community facilities. This will form part of the funding package for the proposed community facilities. The Howbury Centre site development is supported by Bexley Council as both a major source of the funding and the catalyst to the regeneration program and whilst existing facilities will be lost, new improved facilities will be introduced that will compensate for the existing facilities.

27 Overall the case presented for new replacement community facilities is supported in strategic planning terms.

S:\Planning Decisions\Cases\2896a\Stage 1 Report page 5 Housing mix 28 At the consultation stage the applicant was requested to agree to fix the housing mix for phase 3 within the s106 agreement. The applicant has agreed to a condition that sets a range of house types within phase 3 in a provided schedule of the proposed accommodation and this is acceptable. Affordable housing and planning obligations 29 At the consultation stage the applicant was requested to provide further justification over the low level of affordable housing on this windfall greenfield site, especially if s106 contributions are to be prioritised for other objectives. Furthermore, details were requested on how the capital receipts are to be utilised and the mechanism that will be adopted to meet the requirements of policy 8.2 of the London Plan.

30 Furthermore, the applicant was requested to agree to a minimum level of affordable housing within the outline application for phase 3 and that this should be secured and referenced in the s106 agreement condition.

31 The applicant has set out the case for the affordable requirement to be for a minimum of 35% and the level of affordable housing proposed within this scheme (20.16%) is supported by a financial viability appraisal that has been verified by Bexley Council. The reason for the lower level of affordable housing provision is the associated with the scheme providing the partial funding necessary to relocate the existing community facilities.

32 The reason for a lower level of affordable housing has been justified on the basis that the North End Ward (where the site is located) has higher concentrations of social housing than any other ward in Bexley. In 2001 North End Ward comprised 67% private housing and 33% social. Taking into account completions information the tenure split is now 67% private and 34% (note error) social compared with an estimated 14% for the borough as a whole.

33 The Development Agreement (refer to paragraph 57-61) between the applicant and Bexley Council provides for a financial review mechanism at the completion of 75% of each phase, and indicates that if it becomes clear that that phase could viably accommodate additional affordable units, the said units will be provided on site in the next phase, and if this occurs in phase 3 an overage payment will be paid to the council so as to enable the provision of affordable units elsewhere in the area/ borough. This mechanism is considered an acceptable one, in this instance.

34 The applicant is in negotiation with Orbit South Housing Association within the proportion of affordable housing for affordable rent and shared ownership on a 70:30 affordable rent to shared ownership/intermediate split. Orbit South Housing Association has furthermore been in contact with GLA officers in relation to the development and this approach is acceptable.

35 The information set out by the applicant provides sufficient assurance of the affordable housing delivery. Urban Design

36 At the consultation stage the applicant was encouraged to consider modification of the development layout; provide further detail on the outline phase 3 in the form of parameter plans, design code and indicative layouts; all phase 1 and 2 residential units to meet London Plan minimum space standards; and confirmation provided that the phase 3 indicative layouts can meet the design guide and space standards and reference is made to the GLA design guide through condition in the s106.

S:\Planning Decisions\Cases\2896a\Stage 1 Report page 6 Layout

37 The design has been substantially revised since pre-application stage and further revised pre – stage.2. Additional drawings demonstrating the quality of design and public spaces has been provided which give assurance on the overall design rationale and the appearance of public spaces. The issue of the definition of development edges and the potential linkage to adjoining potential site developments has been further explained and it is accepted that potential linkage can be achieved. The increased landscape strip treatment to the industrial are to the north provide an adequate solution to the site development edge.

38 It is welcome that the modified layout drawings demonstrate how the new development relates to the up-graded schools, community centre and related facilities. This helps to demonstrate and clarify strategic thinking behind the development form and the nature of proposed linkages within the masterplan.

Residential quality

39 At the pre-application stage only 25% were compliant and at stage 1 a number of properties were identified as not meeting London Plan space standards all of these were identified as affordable housing units. Following negotiation between GLA officers and the applicant, together with advice from HCA officers and Orbit Housing Association. It was agreed the affordable non-compliant 3B5P units being changed to 3B4P units which would make all units compliant. This is supported by a full schedule which demonstrates 100% space standards and is welcome.

Parameter plans for outline stage

40 At stage 1 the applicant was requested that assurance was required in relation to the indicative layout provide for the outline proposals for phase 3. In response to this issue the applicant has provided parameter plans for the outline phase of development as requested at the consultation phase. These plans provide assurance of the design quality for phase 3 in terms of linkages, disposition of buildings and sufficient space to accommodate GLA space standard compliant units. Children’s playspace 41 At the consultation stage the applicant the applicant was requested to provide a calculation of child yield and relate this to planned plays areas contained in the masterplan.

42 A copy of the calculation undertaken in accordance with the GLA’s play space SPG has been completed. This indicates a need to provide for 2719 sqm of play space (0.27ha). As the application provides for 3,250 sqm (0.32ha) it exceeds the requirements of the London Plan.

Access & inclusive design: 43 At the consultation stage the applicant was requested to provide a more comprehensively presented inclusive design strategy which responds to the issues raised relating to site layout, housing unit design, parking and inclusive public realm design. The applicant was further instructed to include of 10% wheelchair accessible units across all tenures and this should be secured by condition in s106 agreement for the outline proposals for phase 3.

44 At stage 1 the submitted the scheme encompassed 57% Lifetime Homes. With the changes bought about to meet the wheelchair accessibility requirements/ the London Plan space

S:\Planning Decisions\Cases\2896a\Stage 1 Report page 7 standards, the scheme is now at 100 % Lifetime Homes, and 1:50 house type floor plans have been produced, with detail notes, to explain how the scheme meets Lifetime Homes requirements.

45 The applicant has stated that GLA was correct in its criticisms of the level of wheelchair provision. Rather than 10% of the total number of units, the scheme only provided for 10% of the affordable units to be wheelchair accessible. This was a mistake and has been rectified in the revised planning application with a total of 37 wheelchair accessible units are now proposed across a variety of tenures and house types, and the development does therefore accord with policy 3.8 of the London Plan.

46 GLA requested for plans that identify the parking bays allocated for the wheelchair units, LTH parking bays and the location of EV charging points. The revised application layout plan information addresses this requirement and a condition is imposed on the consent to ensure that these are provided. Sustainable energy 47 At the consultation stage the applicant was requested to provide further revisions and information before the proposals can be considered acceptable and the carbon dioxide savings verified.

48 GLA officers have carefully considered the location of the proposed site and the opportunity to connect it to any wider district heating network developed in future in the Slade Green area. The railway line and major road to the west of the site present a major barrier to connecting to the higher density residential areas in the area. Other areas to the east and south are low density residential. Therefore, there is no requirement to install a communal heating system for the development.

49 The applicant has provided a breakdown of the savings in regulated carbon dioxide emissions at each level of the energy hierarchy as requested which demonstrates that the development achieves the 25% savings set out in Policy 5.2 of the London Plan. The energy strategy is now compliant with the London Plan. Transport 50 At Stage 1, TfL raised a number of issues but considered the application to be broadly in accordance with the London Plan in terms of strategic transport. The response to each of these issues, extracted from the Committee Report, is given below:

Highway Impact

51 The primary concern was the impact of the development traffic on the A206 Northend Road / Bridge Road junction. The A206 is part of the Strategic Road Network (SRN) and both local bus routes 89 and 99 could be affected by additional congestion at this junction. However it was accepted that there is limited scope to improve this junction without impacting unacceptably on traffic flow on the SRN. The Council have indicated that a sum of £340,000 has been secured in the legal agreement for transport, part of which could fund improvements at this junction.

Public transport, walking and cycling

52 The Council have indicated that the agreed £340,000 for transport will be used to fund new and improved bus stops, improvements at Slade Green station and improvements to the local walking and cycling network. These are welcomed as they will encourage use of public transport and walking and cycling

S:\Planning Decisions\Cases\2896a\Stage 1 Report page 8 53 The Council considers that delivery of the ‘green link’ along the eastern edge of the site at the early stages of the development should be ruled out due to concerns over crime and safety until the last phase is complete. Whilst this delays improved connections for residents this reasoning is understood and accepted.

54 The Council has confirmed that the site layout will not preclude permeability to the northwest should adjacent sites be redeveloped, and this is welcomed.

Car Parking

55 The overall level of parking is within London Plan standards. The number of disabled parking spaces has been increased to 32 (from 8). Also it has been confirmed that EV charging points will be provided to London Plan standards, which is a condition of planning approval. The Council have confirmed that they are satisfied that the street design will control on-street parking through ‘self regulation’.

Construction management plan and travel plan

56 The Council has confirmed that construction should accord with the Construction Environmental Management Plan and that a Travel Plan should be submitted for approval prior to commencement. These are conditions of planning approval. Other comments Development Agreement

57 As the site is currently owned by the Council, it is not possible to enter into a s106 agreement as a S106 agreement binds land owners and in this case, the Council are the land owner.

58 Bexley Council have entered into a Development Agreement with the applicant which in such cases is normal practice. This sets out a number of contractual issues associated with the sale of the site and transfer of the land ownership but also details with the issues normally incorporated within a s106 agreement and other contributions required as part of the purchase of the site. The agreement secures contributions towards:

 Education facilities - £1,032,269

 Community facilities - £171,585

 Sports and leisure - £19,655

 Transport - £341,890

59 Contributions are to be used in vicinity of the site to mitigate the impacts of development and to provide new/improved facilities for future residents. The education contribution is assist the funding of extensions to adjoining Infants and Junior schools. The community facilities and sports and leisure contribution is to be used towards the funding of the new facility.

60 The applicant has provided a copy of an overview of the Development Agreement on a private and confidential basis. .

S:\Planning Decisions\Cases\2896a\Stage 1 Report page 9

Response to consultation

61 Bexley Council consulted the occupants of 219 neighbouring properties as well as statutory and non-statutory organisations. A total of 4 letters of objection were received as a result of the wider consultation process. Concerns raised were in relation to the following:

 If there is a need for a retail store within the scheme.

 Disruption and noise during construction including safety of children at adjacent schools.

 Concern over the proposed road layout.

 Local ecological impacts.

62 These issues are of a local nature and have been addressed in the Council’s committee report.

63 Representations were also received from the following statutory organisations and bodies:

 Metropolitan Police: require a secured by design condition that the applicant should achieve certification and not just accreditation to attached in the permission. This has been responded to through an addendum to the Committee report which includes a condition in relation to issue raised.

 Environment agency: No objection to the proposals, but are required to included proposed conditions relating to surface water drainage, landscape implementation, land contamination and remediation, undertaking of piling and foundations, groundwater and contaminated land. All have been included within the permission conditions.

 Sports England: object to the proposal and loss of the sports fields and take the view exceptional circumstances criteria have not been met. This is in line with the organisations policy to ensure that there is no further reduction in the supply of conveniently located, quality playing fields for sport to satisfy current and likely future demand. It is noted that Sports England is a non statutory consultee to this application on the basis the site has not been used as playing fields in the last five years. The applicant has also provided an explanation for the development of the sports fields which supported by Bexley Council.

 Thames Water: due to being unable to determine the waste water infrastructure needs of the application, Thames Water require the application of Grampian conditions to waste water infrastructure with development not commencing until an agreed drainage strategy has been submitted. This condition has been included in the permission.

 London Wildlife Trust: no response

 Fields in Trust: no response.

Article 7: Direction that the Mayor is to be the local planning authority

64 Under Article 7 of the Order the Mayor could take over this application provided the policy tests set out in that Article are met. In this instance the Council has resolved to grant permission

S:\Planning Decisions\Cases\2896a\Stage 1 Report page 10 with conditions and a planning obligation, which satisfactorily addresses the matters raised at stage I, therefore there is no sound planning reason for the Mayor to take over this application. Legal considerations

65 Under the arrangements set out in Article 5 of the Town and Country Planning (Mayor of London) Order 2008 the Mayor has the power under Article 6 to direct the local planning authority to refuse permission for a planning application referred to him under Article 4 of the Order. He also has the power to issue a direction under Article 7 that he is to act as the local planning authority for the purpose of determining the application and any connected application. The Mayor may also leave the decision to the local authority. In directing refusal the Mayor must have regard to the matters set out in Article 6(2) of the Order, including the principal purposes of the Greater London Authority, the effect on health and sustainable development, national policies and international obligations, regional planning guidance, and the use of the River Thames. The Mayor may direct refusal if he considers that to grant permission would be contrary to good strategic planning in Greater London. If he decides to direct refusal, the Mayor must set out his reasons, and the local planning authority must issue these with the refusal notice. If the Mayor decides to direct that he is to be the local planning authority, he must have regard to the matters set out in Article 7(3) and set out his reasons in the direction. Financial considerations

66 Should the Mayor direct refusal, he would be the principal party at any subsequent appeal hearing or public inquiry. Government guidance in Circular 03/2009 (‘Costs Awards in Appeals and Other Planning Proceedings’) emphasises that parties usually pay their own expenses arising from an appeal.

67 Following an inquiry caused by a direction to refuse, costs may be awarded against the Mayor if he has either directed refusal unreasonably; handled a referral from a planning authority unreasonably; or behaved unreasonably during the appeal. A major factor in deciding whether the Mayor has acted unreasonably will be the extent to which he has taken account of established planning policy.

68 Should the Mayor take over the application he would be responsible for holding a representation hearing and negotiating any planning obligation. He would also be responsible for determining any reserved matters applications (unless he directs the council to do so) and determining any approval of details (unless the council agrees to do so). Conclusion

69 Having regard to the details of the application, the newly submitted information regarding loss of a former school site, playing fields and community facilities, housing quality, inclusive access, sustainable energy and transport and the matters set out in the Council’s committee report and representations received, the application is considered acceptable in strategic planning terms and does not warrant a Mayoral direction to refuse planning permission.

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]

S:\Planning Decisions\Cases\2896a\Stage 1 Report page 11 Jonathan Aubrey, Case Officer 020 7983 4310 email jonathan.aubrey @london.gov.uk

S:\Planning Decisions\Cases\2896a\Stage 1 Report page 12

planning report PDU/2896a/01 2 October 2012 The Howbury Centre, Slade Green in the London Borough of Bexley planning application no.12/01219/OUTM

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

The proposal Erection of mixed use development with both outline and full elements comprising outline details for demolition of existing buildings and provision of up to 94 residential dwellings and retail up to 300 sq.m. floorspace (A1) with all matters reserved. Full details for 278 residential dwellings including vehicular access, landscaping, open space and other ancillary works.

The applicant The applicant is Redrow Homes, and the agent is Tetlow King Ltd.

Strategic issues The application raises a number of strategic matters including the housing mix and affordable housing provision, planning obligations, urban design and housing quality, inclusive access, sustainable energy and transport.

Recommendation

That Bexley 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 107 of this report; but that the possible remedies set out in paragraph 109 of this report could address these deficiencies.

Context

70 On 24 August 2012 the Mayor of London received documents from Bexley Council notifying him of a planning application of potential strategic importance to develop the above site for the above uses. Under the provisions of The Town & Country Planning (Mayor of London) Order 2008 the Mayor has until 3 October 2012 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.

71 The application is referable under Category 1A and 3c of the Schedule to the Order 2008:

S:\Planning Decisions\Cases\2896a\Stage 1 Report page 13  1A provision of more than 150 residential units  3c development whichis likely to prejudice the use as a playing field of more than 2 ha.

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

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

74 The Howbury Centre site is located in the Borough of Bexley and covers an area of 8 hectares in the form of an L-shaped site with a frontage to Slade Green Road on both its southern and eastern edges. The southern part of the site is the location of the former buildings of a secondary school that is currently occupied by the Council as offices and a training centre. Other parts of this group of buildings are occupied by a local library, pupil referral unit and community uses. To the rear of these buildings is an ancillary car parking area. Most of the Bexley Council services are to relocate within a new development on the site of the Civic Offices in Bexleyheath.

75 The northern part of the site, including the area extending east to Slade Green Road, is currently former school playing fields, which are according to the Howbury Regenration Brief underused. The site is generally level, with some parts lying slightly lower than adjoining land, in an area once occupied by brick pits. Consequently Slade Green Road is built up on a higher level. The site is currently fenced and enclosed, and does not provide any through route.

76 The site has a dual context with industrial use to the north (Anchor Bay Industrial Estate) and west (Church Trading Estate) and Slade green Infant and Juniors School and residential neighbourhoods to the south and east. It has vehicular access routes from Slade Green Road currently providing access to the Howbury Centre. There is no access to the north or west. Consequently, access to Erith town centre is poor and only currently possible via Manor Road or footpaths alongside the railway to Queens Road.

77 The roads adjacent to the site are part of the borough network. The closest part of the Strategic Road Network (SRN), for which TfL and the borough have a statutory duty to ensure expeditious movement of traffic, is the A206 Northend Road, which is just under a kilometre from the site. The nearest part of the Transport for London Road Network (TLRN), the A2 Rochester Way is some five kilometres away.

78 The Thames Cycle Route (National Cycle Network route 1), Thames Path National Trail and London Loop (both strategic walking routes in the London Plan) run along Manor Road, 300m to the north of the proposed eastern site entrance.

79 Bus routes 89 and 99 pass along Slade Green Road and Slade Green National Rail station is 450m from the southern site entrance. Slade Green station is only three stops (around 8 minutes) from Abbey Wood station, which will be an interchange with Crossrail from 2018/19. Therefore there will be much faster and more frequent links to Docklands, the City and West End which could encourage much greater rail use from the development.

80 The site records a public transport accessibility level (PTAL) of 1b to 2, on a scale of 1 to 6, where 6 is the highest. The lowest PTAL is recorded in the north-west corner of the site, which would be part of phase 2.

PDU1217LO02 – Stage I report page 14 Details of the proposal

81 The planning application is for the development of land at the Howbury Centre, Slade Green consisting of the construction of 360 dwellings with public amenity space and a 356 sq.m. retail unit with residential use on the upper floors. The development proposals (figure 1) consist of the following elements:

 A residential layout based on an irregular development block pattern with a main spine road and secondary access routes leading off. Full application phase 1 and 2 are rendered part of the plan).  Two site access points leading from the site onto Slade Green Road to the south and east.  Two areas of open space in the south at the Slade Green entrance (with multi-use games court and informal kick about area) and centrally in the north of the site (with a LEAP and informal kick about areas). A further three small pocket green spaces are located along the spine road.  A potential shared pedestrian/cycle link between the two open spaces is located along the western boundary with the school site.

Figure 1: Application Masterplan covering full and outline phases

 Phase 3 is the outline part of the application (non –rendered part of the drawing) could include a potential location of a replacement community centre in the south of the site together with a neighbourhood store of approximately 300 sq.m. with residential use over fronting the southern green space and entrance.  The potential for future linkages to the west have been incorporated into the proposed layout.

PDU1217LO02 – Stage I report page 15  Sports and youth facilities are provided on land reserved towards the south west boundary.  Proposed architectural character is to be defined by predominantly terraced houses, town houses and low rise apartment blocks.  Parking for dwellings are set out in courtyards and parking courts for flats. Visitor spaces are provided on street and around open spaces.

Case history

82 The application was subject to the GLA pre-application meeting process and a pre- application advice report was issued on the 27 January 2012 (PDU 2896). Strategic planning issues and relevant policies and guidance

83 The relevant issues and corresponding policies are as follows:

 Housing London Plan; Housing SPG; Interim Housing SPG; draft Housing SPG; Housing Strategy; draft Revised Housing Strategy; Providing for Children and Young People’s Play and Informal Recreation SPG;  Affordable housing London Plan; Housing SPG; Interim Housing SPG; draft Housing SPG; draft Affordable Housing SPG; Housing Strategy; draft Revised Housing Strategy;  Planning Obligations London Plan  Density London Plan; Housing SPG; Interim Housing SPG; draft Housing SPG  Urban design London Plan;  Mix of uses London Plan  Regeneration London Plan; the Mayor’s Economic Development Strategy  Transport London Plan; the Mayor’s Transport Strategy;  Crossrail London Plan; Mayoral Community Infrastructure Levy; Crossrail SPG  Parking London Plan; the Mayor’s Transport Strategy  Retail/town centre uses London Plan  Playing fields London Plan  Access London Plan; Accessible London: achieving an inclusive environment SPG; Planning and Access for Disabled People: a good practice guide (ODPM)  Ambient noise London Plan; the Mayor’s Ambient Noise Strategy;  Air quality London Plan; the Mayor’s Air Quality Strategy;  Education London Plan  Sustainable development 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

84 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 2012 Bexley Core Strategy, the 2004 Bexley Unitary Development Plan saved policies and the 2011 London Plan.

85 The following are also relevant material considerations:  Howbury Regeneration Brief SPD

PDU1217LO02 – Stage I report page 16

 The draft Revised Early Minor Alteration to the London Plan (2012)

Principle of development

86 The site has been identified as a strategic site in the emerging Core Strategy and has a regeneration brief SPD aimed at facilitating its development for a mixed use residential led scheme, this approach is potentially supported by London Plan policy 2.14 Areas for regeneration. Bexley Council is the development partner with Redrow Homes and linked to the development is an agreement that a contribution will be made to fund new community facilities in the Borough. Although the strategic development principle for the site being developed for a residential led development with local retail and community facilities is in keeping with the London Plan policy 3.3 increasing housing supply and policy 3.7 large residential developments. The applicant and Bexley Council will need to provide further supporting evidence in relation to why the site is unsuitable for future potential school use (in context of a lack sites for “Free Schools”) and why the former playing fields cannot be retained for recreational use.

87 The southern part of the site is occupied by former secondary school buildings, which are currently used as Council offices and training centre. A part of this group of buildings is used as a library, pupil referral units and other community uses. In context of the identified London wide shortage of places and shortage of sites for free schools the GLA require further details on why the site is surplus to education need and where provision has been made to compensate for the loss of this site. Furthermore, the applicant needs to outline where the library, pupil referral unit and other community uses are to be located elsewhere in the borough to be compliant with London Plan policy 3.16 protection and enhancement of social infrastructure.

88 The northern part of the site extending across to Slade Green Road is identified in the applicant’s planning statement as an “underused area of former school playing fields”. As requested at the pre-application stage the GLA require the applicant to provide confirmation that the former school playing fields are no longer required as a borough facility together with evidence of consultation with Fields in Trust (formerly National Playing Fields Association) and Sport England on their development.

89 The development proposal involves the loss of existing social infrastructure (a former school building containing existing community uses) and sports facilities (playing fields). London Plan policy 3.16 protection and enhancement of social infrastructure states under planning decisions “Proposals which result in a loss of social infrastructure in areas of defined need for that type of social infrastructure without realistic proposals for re-provision should be resisted”- this supports policy 3.18 education facilities. London plan policy 3.19 sports facilities states “proposals that result in a net loss of sports and recreational facilities, including playing fields should be resisted”. In response to London Plan policy further justification and supporting evidence is required over the loss of a potential school site and the related school playing fields.

90 As stated the GLA welcome the potential provision of new housing within Bexley and the provision of funding for a new community centre (off site) as part of the agreement between Bexley Council and Redrow Homes. These elements could be supported by London Plan policy 3.16 protection and enhancement of social infrastructure. The inclusion of this local facility and retail floorspace are further supported by policy 3.17 because the aim is to develop the site through a plan led process which could coordinate provision of social, environmental and other infrastructure. The site is in addition located outside of the Strategic Industrial Location (SIL) identified in the London Plan (policy 2.17) covering the Belvedere Industrial Area and Thames Road (including Crayford Industrial Area, which removes a potential constraint development . The

PDU1217LO02 – Stage I report page 17 applicant in conjunction with Bexley Council is requested to provide further justification and information in relation to the loss of community facilities and playing fields in response to London Plan polices 3.16, 3.18 and 3.19 for the principle of development to be compliant with the London Plan.

91 The following text provides guidance on the submitted application and provides guidance on the conformity of the proposals with the London Plan. Should the issues raised in relation to the principle of development are resolved in full.

Housing mix & quality

92 London Plan Policy 3.8 encourages a full range of housing choice. This is supported by the London Plan Housing SPG, which seeks to secure family accommodation within residential schemes, particularly within the social rented sector, and sets strategic guidance for councils in assessing their local needs. Policy 3.11 of the London Plan states that within affordable housing provision, priority should be accorded to family housing. Recent guidance is also set out in the London Plan Interim Housing SPG (April 2010). Also relevant is Policy 1.1, part C, of the London Housing Strategy, which sets a target for 42% of social rented homes to have three or more bedrooms.

93 The applicant information sets out a schedule for the housing and breaks down the housing mix by type and size of unit over the two full consent phases and for the outline application (figure 1).

Figure 1: Full and outline phases of housing delivery

Phase 1 and 2 1 bed flat 2 bed flat 3 bed 4 bed con 2 bed Total Private 0 101 5 131 237 1B 2P Flat 2B 4P Flat 3B 5P 3B 5P WH 4B 6P Total Affordable 5 13 23 0 0 41 Total 5 114 28 131 0 278 % 2 41 10 47 0 100 % Private 85 Affordabl e 15

94 The full consent for stages 1 and 2 will deliver a total of 278 residential units with an emphasis on larger family units.

Phase 3 1 bed flat 2 bed flat 3 bed 4 bed con 2 bed Total Private 0 18 2 51 71 1B 2P Flat 2B 4P Flat 3B 5P 3B 5P WH 4B 6P Total Affordable 2 7 4 10 23 Total 2 18 6 51 10 94 % 2 19 6 54 11 93 Private 76 Affordabl e 24

PDU1217LO02 – Stage I report page 18 95 The outline application set out under phase 3 delivers the majority of affordable units and once again the emphasis is on larger units and this is welcome. Looking at the overall development mix (figure 2) to be delivered there is a strong emphasis on family housing (58% 3-4 bed units) and 2 bed residential units (37%).

Figure 2: Overall housing mix

1 bed flat 2 bed flat 3 bed 4 bed con 2 bed Total Private 0 119 7 182 0 308 1B 2P Flat 2B 4P Flat 3B 5P 3B 5P WH 4B 6P Total Affordable 7 20 27 0 10 64 Total 7 139 34 182 10 372 % 2 37 9 49 3 100 % Private 83 Affordabl e 17

96 The overall mix of both market and affordable housing unit type is welcome and compliant with London plan policy 3.10 and 3.11. There is however a requirement that the outline application phase 3 housing mix is secured in the s106 agreement (and the provision of additional information requested in paragraph 46), this is because The Mayor will not have the opportunity to comment on the proposed reserved matters application for this phase.

Affordable housing

97 London Plan Policy 3.11 requires borough councils to seek the maximum amount of affordable housing when negotiating individual private residential and mix use schemes. Furthermore it seeks to ensure that 60% of the affordable housing delivered throughout the Plan period is social rented housing, and that 40% is intermediate provision. The proposed Early Minor Alteration to the London Plan clarifies that affordable rented provision should be included within the 60% component of this split.

98 The Bexley local requirement in the emerging Core Strategy is for 50% of any future housing development to be affordable housing, whilst it is also acknowledged the Howbury Regeneration Brief SPD has set a lower target of 35% of units being affordable to meet with local circumstances where there is already a predominance of rented housing.

99 The applicant has submitted a housing schedule that sets out the level of affordable housing at 20% for the overall development. The schedule sets out the different phases of development and split between the full and outline application – it is noted the majority of the affordable housing will come forward under the outline consent in the last phase. There is however some confusion over this figure of 20% affordable housing provision across the whole development as GLA estimate the level will be lower at 17% affordable units. The applicant should confirm that 20% is the minimum level of provision and demonstrate this in the housing schedule.

100 Whilst it is understandable that the full application phases 1 and 2 will be predominantly market housing as this will generate income for later phases of development and fund the commitment of funding a new community centre, assurance is required over the delivery of the minimum level of affordable housing in the later phase. For this reason an agreed minimum level of affordable housing and unit type and size should be agreed in advance of and secured through

PDU1217LO02 – Stage I report page 19 the s106 agreement. This is because as with the housing mix (paragraph 26) The Mayor will not provide response to the later reserved matters stage of this application.

101 The applicant planning statement proposes a minimum of 20% affordable housing will be provided across the site and a viability assessment has been submitted as part of the planning application that justifies this level of affordable housing and mix of unit type and size and this is welcome. Bexley Council should have the viability assessment independently reviewed to verify its findings.

102 Notwithstanding the 35% affordable housing target in the Howbury regeneration SPD, the provision of 20% is low for a windfall greenfield site. Policy 8.2 of the London Plan gives the highest importance to affordable housing, supporting the funding of Crossrail and other public transport when negotiating section 106 agreements. The Council and the applicant will need to provide further justification if the section 106 contributions are to be prioritised for other objectives. If the Council intends to use the capital receipt for the delivery of social infrastructure (in lieu of a higher affordable housing provision and therefore lower capital receipt), this not only needs to be justified, but there needs to be a mechanism to ensure that these facilities are delivered or that additional affordable housing is delivered if there are none provided. GLA officers can provide further advice on this matter.

Affordable rent model

103 At the pre-application stage the applicant indicated a preference for adopting the new affordable rent model. The GLA was supportive (London Plan policy 3.10 and 3.11) of the use of this new tenure model as it adds further diversification to tenure mix in areas such as Slade Green – where there is a predominance of social rented accommodation at present.

104 The planning statement includes no information regarding what approach will be adopted in providing affordable housing for rent. It is requested the applicant provide this information and adopt the affordable rent model. Furthermore the applicant should provide information and confirmation of registered landlord involvement in the delivery of the affordable housing and whether grant funding has been sought.

Housing density

105 The London Plan policy optimising housing potential (also refer to table 3.2) sets out specific policy in relation to density levels across the city. The applicant should provide a calculation of site density set out showing the habitable rooms per hectare. Play space provision

106 Children and young people need free, inclusive and accessible spaces offering high-quality play and informal recreation opportunities in child-friendly neighbourhood environments. Policy 3.6 of the London Plan seeks to ensure that all children and young people have access to such provision. The challenge facing boroughs and their partners in play provision will be to find opportunities to retain and increase the provision of play and informal recreation, particularly in housing developments.

107 The draft Supplementary planning guidance Providing for children and young people’ s play and informal recreation (January 2012) relates to the implementation of London Plan Policy 3.6 and provides detailed guidance. It sets out benchmark standards that were developed for the Mayor’s SPG on Providing for Children and Young People’s Play and Informal Recreation in 2008.

PDU1217LO02 – Stage I report page 20 108 The applicant has included within the masterplan layout for phases 1 and 2 a central Green in the north of the site. This will incorporate an activity zone of 500 sq.m. with surrounding informal lawns and 3,250 sq.m. playspace – it is planned that the playspace will be one-third for pre-school children and two-thirds for children age 5-14 years. A number of small green spaces are also included in key squares which provide additional local doorstep play for infants. In addition to the on site play provision there are linked off-site proposals to develop a new community centre on land adjoining the site. The proposals include a multi-use games area (MUGA) providing a focus for older children and teenagers.

109 Whilst the range of playspace appears to be adequate the applicant should, as requested at the pre-application respond to London Plan policy 3.6 and provide an estimate of the child population of both the private market and affordable housing and how the design provides for the required integral children’s play space. This should be completed using London Plan policy and 2012 SPG as a guide to demonstrate the level of provision and how this relates to the estimate of the child population.

Urban design

110 The proposed development has been commented on at pre-application stage, where it was set out that its design needed further work to comply with design related policies in the London Plan. Issues relating to the layout of buildings on the site and the quality of the spaces they create were highlighted as a particular issue and it is disappointing this has not been appropriately addressed. The following comments refer to both the positive and negative aspects of the proposal and where appropriate provide suggested amendments.

Layout

111 The overall layout of the proposal is arranged around a central street running along the middle of the site with a number of different open spaces hanging from it. Secondary streets are arranged perpendicular creating short cul-de-sacs which accommodate parking courts.

112 Whilst this overall strategy is supported as it has the potential to create a legible and efficient use of the site, with high quality open spaces and residential development, there are a number of aspects that need further consideration. Detail of the massing and layout should be secured as part of the outline planning application for phase 3 through parameter plans and design coding.

113 As set out previously, the attempt to break up the linearity of the main street by dog- legging its alignment at the eastern entrance of the site makes the area less legible and indirect which is a concern. Consideration should be given to straightening this street allowing a clear line of site into the area from existing streets. Traffic calming can be designed by deflections solely on the carriageways rather than through the whole street.

114 The proposed development edges to the industrial areas, the retained school buildings and residential area require attention. At the pre-application stage the designers were advised that the development needs to respond appropriately each of these edges. Officers are not convinced that terminating streets with the rear of the adjacent industrial areas is an appropriate approach unless it is envisaged that this are will be developed in the near future. Consideration should be given to an alternative layout where residential buildings back on to this edge. The proposed 3 metre buffer edge along the northern boundary presents more of a concern over security than mitigation of the impact of noise from the industrial units.

Residential quality

PDU1217LO02 – Stage I report page 21 115 At the pre-application stage the applicant was informed that a large percentage of the proposed units did not meet the London Plan (Table 3.3) minimum dwelling space standards. The applicant in phases 1 and 2 has continued to provide undersized units and the applicant’s planning statement states that all one bed apartments and three bedroom two storey houses accounting for 12% of development do not meet London Plan (table 3.3) standards. In addition to this no commitment is made or sufficient information is provided on the minimum dwelling space standards for the outline phase 3. The applicant has supplied an itinerary of units through phases 1 and 2 in square feet and this should be revised setting out units in square metres unit size by phase and comparison to London Plan standards. The delivery of undersized units is a significant concern and the applicant should ensure all units are complaint with London Plan space standards and furthermore additional information should be provided on the outline phase 3 -this should set out parameter plans, design code and indicative layouts that allows for future development in this phase to meet London Plan dwelling space standards which should also be referenced to the London Housing Design Guide through condition in the s106 agreement.

116 Also of relevance to this proposal is the need to increase the levels of animation on the public realm and provide as many residents with their own identifiable front entrances. This can be achieved by ensuring that circulation core for apartment buildings have access directly from the public realm and all ground floor units are accessed directly from the street. This expected in all new buildings and officers will require a ground floor plan layout of the whole scheme illustrating this.

Scale, height and massing

117 London Plan Policy 7.4B sets out the requirement for buildings to provide a contemporary architectural response to a site whilst having regard to the pattern and grain of development in the wider area. London Plan Policy 7.6B sets out the requirement for development to be of a proportion, composition, scale and orientation that enhances activates and appropriately encloses the public realm.

118 The material provided illustrates building heights for half of the scheme. Whilst this does not present any significant concern, a plan illustrating building heights for the whole of the site is required so that officers can asses the overall building heights strategy. The outline application for phase 3 can be illustrative, but parameter plans of maximum heights will be required. Inclusive design and access

119 At the pre-application stage the following issues were highlighted in relation to access and inclusive design:

 The housing design should meet London Plan requirements for Lifetime Homes or robustly justify where there are areas of non-compliance.

 The layout must incorporate blue badge disabled parking spaces.

 The inclusive access strategy needs to explain floor and site levels

 Shared surface areas need to be carefully detailed to consider the disabilities of potential users.

120 It was expected that the applicant has addressed all of these points in the current application.

PDU1217LO02 – Stage I report page 22

Phases 1 and 2 (full application)

121 The applicant does not appear to have explained in the inclusive access strategy how the floor and site levels will work, and what gradients are proposed to external routes.

122 In terms of Policy 3.8 Housing Choice, page 38 of the submitted Design and Access statement explains that: “The GLA housing design guide has inserted the lifetime homes criteria into the body of the standards. The standards have been applied throughout the design of the houses and flats.” This statement is supported, however typical floor plans illustrating how the lifetime homes criteria has been adopted in the various housing types is requested to illustrate how this will be delivered.

123 The applicant also states in the Design and Access Statement: “There is a policy requirement to provide 10% of the affordable dwellings as wheelchair accessible units. These have been provided in the ground floor of some of the flat blocks and three of the affordable 3 bedroom houses.” This statement is not correct as it limits the 10% wheelchair accessible housing requirement to just affordable dwellings, whereas the London Plan policy applies to all new housing (as highlighted below).

Housing Choice

124 London Plan Policy 3.8 Housing Choice states: “B. (d.) ten per cent of new housing is designed to be wheelchair accessible or easily adaptable for residents who are wheelchair users.” Therefore 10% of all of the proposed dwellings, not just the affordable homes should therefore be designed as wheelchair accessible, or easily adaptable.

125 The location of the wheelchair accessible units is also a concern, as it is stated (above) that they have all been provided on the ground floor. Some wheelchair users will prefer ground floor units, as they will not have to negotiate a lift (which could break down), however it would be wrong to assume that this is there preference for all wheelchair users. It is also desirable that two lifts are provided in some of the cores to ensure that level access is maintained should one of the lifts be out of service.

126 Locating all of the wheelchair accessible units (or easily adaptable units) on the ground floor does not provide equality of choice for potential residents, does not represent integration of the wheelchair accessible units and the potential residents and ‘corrals’ wheelchair users or disabled people together – this is an approach which does not satisfy London Plan Policy 3.8 Housing Choice which states: “Londoners should have a genuine choice of homes that they can afford and which meet their requirements for different sizes and types of dwellings in the highest quality environments.” The wheelchair accessible, or easily adaptable units should be distributed across tenure types and flat sizes to give disabled and older people similar choices to non disabled people (unless the Council through its Accessible Housing Register work can advise on the need in this part of the borough for a particular size of wheelchair accessible unit).

127 As the number of wheelchair accessible units will need to be increased (to form 10% of total housing provision, not just affordable housing), this is an ideal opportunity to re-think the approach to wheelchair accessible housing provision, clarify the above points, providing units throughout all of the different housing sizes and types proposed, and therefore providing greater choice for disabled people.

Parking provision

PDU1217LO02 – Stage I report page 23 128 The number of and design of disabled persons parking bays is a concern. None appear to be illustrated on the proposed plans. One designated disabled persons parking bay should be provided per wheelchair accessible unit, and these should be located as close as possible to the properties they are provided for. If the wheelchair accessible units are to be ‘easily adaptable’ (again, clarification on this is required) it may be acceptable to have some of the parking bays associated with these flats large enough to be used as or marked up as disabled persons parking bays if required at a later date, and the management of these bays (to ensure that they are available at a later date) should be highlighted in the parking management plan.

129 The applicant should also show how the lifetime homes criteria in terms of parking have been satisfied. The potential widening of any bays in accordance with lifetime homes criteria should not have an impact on the general pedestrian circulation route/ paths around this site. Blue badge parking for visitors to the site should also be considered when re-planning the car parking plans.

Public realm

130 There are still concerns regarding the use of and extent of shared surface arrangements around this site. It is not clear from the plans provided what level of segregation is proposed to the road and footpath network throughout this site, wording such as ‘subtle delineation’ is used and as no further information than this is provided, this is a concern.

131 Areas are proposed with a two metre wide footways which is welcome, although the further information should be provided on how this will be segregated from the road surface e.g. by a kerb etc. and as a range of surfaces are proposed the applicant should provide information as to how someone would know when they are leaving a ‘safe’ segregated pavement, and travelling onto a ‘feature/ tumbled block paving’ area which would appear to form the ‘3 smaller landscaped shared surface squares’ which are referred to in the design and access statement.

132 London Plan policy 6.10 paragraph 6.37 places emphasises on the importance of providing “safe and attractive routes that are easy to navigate”, and paragraph 6.38 explains that “Walking issues should be addressed in development proposals, to ensure that walking is promoted and that street conditions, especially safety, security and accessibility for disabled people, are enhanced.” If shared surfaces are proposed, the applicants should illustrate what design features and details will be incorporated to ensure that the areas are safe and usable for disabled people. Further information is therefore required on this element of the proposals to accurately assess the proposals and the impact they will have in terms of access for disabled people.

133 Play equipment is proposed, and the applicant should show what elements of this will be accessible for disabled children, and how the play area has been designed to take into account the needs of disabled children.

134 Outline information should also be provide on inclusive design for phase 3 including for the housing, retail units, and disabled persons parking. As presently there is no indication of the quality of design response to access and inclusive design issues.

135 Both the vehicle access points for phase 1 and 3 into and out of the site should incorporate dropped kerbs which are designed in accordance with the DfTs ‘ Guidance on the use of tactile paving surfaces’. Again, confirmation of this should be provided.

Further action and information required

136 The above points should be resolved, further information on a number of issues is required to accurately assess the proposals in terms of access for disabled people. Particular attention

PDU1217LO02 – Stage I report page 24 should be given to a level of wheelchair user housing (or easily adaptable) for all units that is compliant with The London Plan and typical floor plan layouts for the various house types should illustrate how criteria has been achieved. A plan illustrating the revised location for these units should also be provided.

137 Furthermore, the car parking layout should incorporate the correct levels of disabled persons parking and should also satisfy lifetime homes criteria in terms of parking. Sustainable energy

138 Policy 5.1 and 5.2 of the London Plan seek to achieve an overall reduction in London’s carbon dioxide emissions through a range of measures including using less energy, supplying energy efficiently and using renewable energy, improving on Building Regulations targets by 25% in the period 2010-2013.

Overview of proposals

139 The applicant has not followed the energy hierarchy and sufficient information has not been provided to understand the proposals as a whole. Further revisions and information is required before the proposals can be considered acceptable and the carbon dioxide savings verified.

Be lean: energy efficiency standards

140 The applicant should detail the passive design features and demand reduction measures proposed to reduce the carbon emissions of the proposed development. The applicant should also detail how the demand for cooling will be minimised.

141 The applicant should provide more detail on energy efficiency measures and commit to the development exceeding 2010 Building Regulations compliance through energy efficiency alone.

142 The applicant should calculate and state the reduction in regulated carbon dioxide (CO2) emissions in tonnes per annum that will be achieved through this first part of the energy hierarchy.

Be clean: district heating

143 The applicant should carry out an investigation to determine if there are any existing or planned district heating networks within the vicinity of the proposed development. The applicant should however, provide a commitment to ensuring that the development is designed to allow future connection to a district heating network should one become available.

144 The applicant should investigate installing a site heat network to serve the apartments. A drawing showing the route of the heat network linking all the apartments on the site should be provided. A site heat network should be supplied from a single energy centre and information on the floor area and location of the energy centre should be provided.

Combined Heat and Power (CHP)

145 The applicant has not investigated the feasibility of CHP. However, due to the nature and size of the heat load, CHP is not proposed. This is accepted in this instance.

PDU1217LO02 – Stage I report page 25 146 The applicant should calculate and state the reduction in regulated CO2 emissions in tonnes per annum that will be achieved through this second part of the energy hierarchy.

Be green: renewable energy technologies

147 The applicant has investigated the feasibility of a range of renewable energy technologies and is proposing to install air source heat pumps (ASHP) in all dwellings.

148 The applicant should calculate and state the reduction in regulated CO2 emissions in tonnes per annum that will be achieved through this third part of the energy hierarchy.

Overall carbon savings

149 The estimated regulated carbon emissions of the development are 401 tonnes of CO2 per year after the cumulative effect of energy efficiency measures and renewable energy has been taken into account. This equates to a reduction of 102 tonnes of CO2 per year in regulated emissions compared to a 2010 Building Regulations compliant development, equivalent to an overall saving of 20%.

150 The carbon dioxide savings fall short of the targets within Policy 5.2 of the London Plan. The applicant should consider the scope for additional measures aimed at achieving further carbon reductions.

151 The applicant should state the estimated regulated carbon emissions of the development in tonnes of CO2 per annum before (baseline) and after the cumulative effect of energy efficiency measures, district heating and renewable energy has been taken into account and at each interim stage of the energy hierarchy. The applicant should present the information required in the format set out in Tables 1 & 2 of the document ‘Energy Planning - GLA Guidance on preparing energy assessments – September 2011’ which is available on the GLA website. Transport

Highway Impact

152 TfL is primarily concerned with the impact of the development traffic on the A206 Northend Road / Bridge Road junction. The A206 is part of the strategic road network (SRN) and both bus routes 89 and 99 could be affected by additional congestion at this junction.

153 The transport assessment (TA) shows that in future years, queue lengths could increase on the Bridge Road arm at peak times as the junction approaches capacity, which could in turn impact on bus services. It is accepted that the degree of impact on the junction will be dependent on background traffic growth, which is hard to predict accurately and outside of the control of the applicant. Any mitigation is likely to be difficult as this junction is ‘left in left out’, favouring traffic flow on the A206 and signalisation is unlikely to be an option due to impacts on the SRN. Therefore, in the context of this planning application, the appropriate solution may be to use the travel plan to reduce peak hour car trips as much as possible and to provide a mitigation package that encourages greater use of public transport, walking and cycling. However, Bexley council highways should consider if the junction can be improved in any way, in consultation with TfL Traffic Directorate. Any improvements should be funded by the applicant.

Public transport

154 No data was included in TA on impacts on bus or rail service capacity. As only 145 daily trips by public transport are predicted, there is unlikely to be an unacceptable impact on either.

PDU1217LO02 – Stage I report page 26 New and improved bus stops serving the site to encourage bus use and improvements at Slade Green station to encourage rail use could reduce pressure at the Northend Road/Bridge Road junction.

Walking and Cycling

155 It is unfortunate but understandable that the later Phase 3 development occupies the southern section of the site, where the Howbury Centre is located at present. Prior to Phase 3, access for residents of Phases 1 and 2 will only be via Slade Green Road (east), with only one bus route (99) nearby but stops beyond 400m walk distance for some residents in the northwest corner, and no station or local services within reasonable walking distance (the nearest being 1.4km away). The consequent risk is that the first two phases of the development, particularly Phase 2 are primarily car based.

156 It is therefore requested that the applicant work with Bexley Council to assess the feasibility of a pedestrian and cycle route from phase 1 of the development (and subsequently phase 2) through or around the phase 3 site. This would provide permeability towards the additional public transport services and local facilities to the south from the outset. This could be achieved through delivering the ‘green link’ along the eastern edge of the site at the early stages of the development.

157 As set out below, further off-site pedestrian and cycle improvements should be considered and secured through the section 106 to encourage use of sustainable transport and reduce pressure on the Northend Road/Bridge Road junction.

158 The site context does not lend itself to permeability to the northwest, however the proposed layout does not appear to preclude a pedestrian/cycle link in this direction in the future should the adjoining sites come forward for redevelopment. This would greatly benefit the residents of the development, particularly in the northwest corner of the site, as it would considerably reduce the walk distance to Erith town centre. This route could therefore be safeguarded by condition.

159 Cycle parking is to be provided in line with London Plan standards and this is supported.

Car Parking

160 The development comprises of up to 372 units, with significant proportion of three and four bedroom houses. Therefore the proposal to provide 419 resident car parking spaces is within London Plan parking standards. Although the provision of 56 visitor spaces seems excessive, the overall level of parking is still within London Plan standards. However, there is also no information on how ‘on street’ parking will be controlled and the level of disabled parking provision is low, at only 8 spaces.

161 No information is given on the provision of electric vehicle (EV) charging points. In order to conform with London Plan standards, it would be expected that each of the larger residential units with allocated/curtilage parking/garages would have reasonable provision for EV charging, for example an appropriately placed plug point or passive provision. The communal parking should have 20 per cent of spaces with active provision and 20 per cent passive provision, distributed so that each ‘courtyard’ has this provision.

162 Given the outstanding issues raised above, it is suggested that a condition of planning permission is that a parking management plan is submitted to the local planning authority for approval, in consultation with TfL. The draft parking management plan or scoping note addressing

PDU1217LO02 – Stage I report page 27 the above points should be submitted to the Council for consideration and consultation with TfL prior to the determination of the application.

Construction

163 Given the scale and phased nature of the development, the Construction Management Plan (CMP) should be secured as a condition of planning permission.

Travel Plan

164 The travel plan and travel plan coordinator should be secured as a condition of planning permission. As highlighted above, due to the critical nature of the Northend Road/Bridge Road junction in the future, it is essential that the travel plan should have robust mode shift targets, in addition to the ‘single occupancy car journeys to work’ target that is highlighted in the Planning Statement. The travel plan should be backed up by parking management and on and off site measures such as public transport and cycling information provision to homebuyers and improvements listed below, to ensure these targets can realistically be met.

Mitigation

165 No indication of the likely contributions towards transport improvements in the s106 agreement is given. Given the criticality of the Northend Road/Bridge Road junction and the consequent need to reduce development traffic, the following conditions would be expected to be considered by the Council for inclusion in the s106:

 improved pedestrian environment at the junction of Slade Green Road and Bridge Road;  improvements to the station environment at Slade Green station such as improving the platform shelters which are currently inadequate and providing more customer information screens;  improvements to the footpath to Erith town centre alongside the railway with possible widening to enable cyclists to use;  new bus stops on Slade Green Road, near to the eastern site entrance to provide stops within 400m of all residents;  improvements to bus stops on serving the site, for example new shelters and Countdown signs, upgrading to meet TfL Accessible bus stop design guidelines.

166 The Head of Terms of the s106 agreement should be provided prior to the council determining the application so as to enable consideration at stage 2.

Conclusion

167 TfL have no objection to the proposals in principle, but there are concerns about the future operation of the Northend Road/Bridge Road junction, with subsequent impact on bus services, and the parking management, particularly in relation to EV infrastructure provision. Therefore further information and clarification is required before the proposals can be considered to fully accord with London Plan policy in terms of transport. Community Infrastructure Levy

168 The Mayor has introduced a London-wide Community Infrastructure Levy (CIL) to help implement the London Plan, particularly policies 6.5 and 8.3. The Mayoral CIL formally came into effect on 1 April 2012, and it will be paid on commencement of most new development in Greater

PDU1217LO02 – Stage I report page 28 London that was granted planning permission on or after that date. The Mayor's CIL will contribute towards the funding of Crossrail

169 The Mayor has arranged boroughs into three charging bands. The rate for is Bexley is £20/sq.m. The required CIL should be confirmed by the applicant and council once the components of the development or phase thereof have themselves been finalised. See the 2010 regulations: http://www.legislation.gov.uk/ukdsi/2010/9780111492390/contents as amended by the 2011 regulations: http://www.legislation.gov.uk/uksi/2011/987/made

170 London borough councils are also able to introduce CIL charges which are payable in addition to the Mayor’s CIL. Bexley Council has yet to adopt a scheme. See the council’s website for more details.

171 The site is within the area where section 106 contributions for Crossrail will be sought in accordance with London Plan policy 6.5 and the associated Supplementary Planning Guidance (SPG) ‘Use of planning obligations in the funding of Crossrail’ (July 2010 ).

172 In these situations, the Mayor’s CIL charge (but not the borough’s) will be treated as a credit towards the S106 liability. The practical effect of this will be that only the larger of the two amounts will normally be sought. As the CIL charge will not be confirmed until development is about to commence, the s106 agreement will need to be worded so that if the s106 contribution based on the assumed CIL proves incorrect the contribution is adjusted accordingly (assuming it is still more than the CIL). Other contributions towards the mitigation of transport impacts may also be sought in accordance with London Plan policy and with relevant legislation. Local planning authority’s position

173 The Bexley Council attended the pre-application meeting and are supportive of the scheme as they take the position that the development will enable the re-provision of new community youth and sports facilities on the adjacent school land. Legal considerations

174 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

175 The application is linked to an agreement between the developer and Bexley Council to provide support funding for new community facilities in the borough. Conclusion

PDU1217LO02 – Stage I report page 29 176 London Plan policies on housing, affordable housing, planning obligations, urban design, children’s playspace, access, climate change mitigation and transport are relevant to this application. The application complies with some of these policies but not with others, for the following reasons:

 Principle of development: the loss of potential school site and playing fields (London Plan polices 3.16, 3.18 and 3.19; loss of social infrastructure currently occupying The Howbury Centre (London Plan policy 3.16).  Housing mix: confirmation of the housing mix in the outline application phase 3 and assurance on the delivery of that mix (London Plan Policy 3.8).  Affordable housing & planning obligations: the application in its current form is not compliant with London Plan policy as it does not secure the maximum number of units and the approach to planning obligations and lack of mechanism for delivery of benefits requires discussion (London Plan Policies 3.10, 3.11, 8.2).

 Affordable housing: confirmation of the level of affordable housing and mix for phase 3 and assurance of the delivery of minimum level; the viability assessment has not been independently assessed; approach to affordable housing to rent (London Plan Policies 3.10, 3.11, 8.2).

 Urban Design: concerns relating to aspects of the design layout and approach to defining the public realm; a lack of clarity over design approach and quality in phase 3; a failure to comply with London Plan (Table 3.3) minimum dwelling space standards in phase 1 and 2 and lack of assurance over outline phase 3 ((London Plan policies 3.5, 7.1, 7.3, 7.4).  Children’s playspace: a need for justification for the level of playspace provision across all age groups (London Plan policy 3.6).  Access: concerns relating to residential layouts, housing design, parking provision and creating an inclusive public realm (London Plan policies 3.8, 6.7, 6.10, 6.13, 7.1, 7.2 and 7.6).  Climate change mitigation/ sustainable energy: The applicant has not followed the energy hierarchy. Sufficient information has not been provided to understand the proposals as a whole (London Plan policy 5.1 and 5.2).

 Transport: concerns about the future operation of the Northend Road/Bridge Road junction, with subsequent impact on bus services, and the parking management, particularly in relation to EV infrastructure provision. 177 Whilst the application is broadly acceptable in strategic planning terms. On balance, the application does not comply with the London Plan.

178 The following changes might, however, remedy the above-mentioned deficiencies, and could possibly lead to the application becoming compliant with the London Plan:

 Principle of development: The applicant in conjunction with Bexley Council are requested to provide further information in relation to the loss of community facilities and playfields in response to London Plan polices 3.16, 3.18 and 3.19 for the principle of development to be compliant with The London Plan; details on where the library, pupil referral unit and other community uses are to be located elsewhere in the borough.

PDU1217LO02 – Stage I report page 30  Housing mix: the applicant should agree to fix the agreed housing mix for phase 3 within the s106 agreement.  Affordable housing and planning obligations: Further justification is required from both the borough and applicant over the low level of affordable housing is required on a windfall greenfield site, especially if s106 contributions are to be prioritised for other objectives. Furthermore, details should be provided on how the capital receipts are to be utilised and the mechanism that will be adopted to meet the requirements of policy 8.2 of the London Plan – the applicant should agree to engage with GLA offices for further advice on resolving this matter.  Affordable housing: A minimum level of affordable housing to be located in the outline application for phase 3 should be agreed and this should be secured and referenced in the s106 agreement condition.  Urban Design: The applicant should consider modification of the development layout; provide further detail on the outline phase 3 in the form of parameter plans, design code and indicative layouts; all phase 1 and 2 residential units should meet London Plan minimum space standards; and confirmation provided that the phase 3 indicative layouts can meet the design guide and space standards and reference is made to the GLA design guide through condition in the s106.

 Children’s playspace: the applicant should provide a calculation of child yield and relate this to planned plays areas contained in the masterplan.  Access & inclusive design: A need for a more comprehensively presented inclusive design strategy which responds to the issues raised relating to site layout, housing unit design, parking and inclusive public realm design. The applicant should include of 10% wheelchair accessible units across all tenures and this should be secured by condition in s106 agreement for the outline proposals for phase 3.  Sustainable energy: Further revisions and information is required before the proposals can be considered acceptable and the carbon dioxide savings verified.  Transport: further information and clarification is required before the proposals can be considered to fully accord with London Plan policy in terms of highway impact, public transport, walking and cycling, car parking, construction and provision of a travel plan. The applicant should agree to discussions on the outlined conditions proposed for the s106 agreement.

PDU1217LO02 – Stage I report page 31 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] Jonathan Aubrey, Case Officer 020 7983 5823 email [email protected]

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