planning report PDU/3097/01 27 February 2013 Site of the Ice Rink, Rom Valley Way in the London Borough of Havering planning application no.P/1468/12

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 A hybrid application comprising:  Detailed proposals for redevelopment of the ice rink site to provide a food store with associated new access arrangement, parking and servicing space; and a petrol-filling station with kiosk and carwash facility.  Outline proposals for a residential development of up to 71 dwellings to be situated directly north-west of the proposed supermarket and with all matters reserved except the means of access and quantum of development.

The applicant The applicant is Chase & Partners, acting on behalf of Optimisation Developments Ltd (a wholly-owned subsidiary of Morrisons Supermarkets Ltd) and the architects are Collado Collins.

Strategic issues The key strategic issues relate to the re-provision of leisure facilities, out of centre retail development, housing and affordable housing, urban design, access and transport.

Recommendation

That Havering Council be advised that while the application is generally acceptable in strategic planning terms, it does not fully comply with the London Plan, but that the potential remedies set out in paragraph 89 of this report could address those deficiencies.

Context

1 On 21 January 2013, the Mayor of London received documents from Havering Council notifying him of a planning application of potential strategic importance to develop the above site for the above uses. Under the provisions of The Town & Country Planning (Mayor of London) Order 2008 the Mayor has until 1 March 2013 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.

page 1 2 The application is referable under Categories 1B, 3E and 3F of the Schedule to the Order 2008:

1B-“ Development (other than development which only comprises the provision of houses, flats, or houses and flats) which comprises or includes the erection of a building or buildings— (c) outside Central London and with a total floorspace of more than 15,000 square metres.”

3E- “Development—(a) which does not accord with one or more provisions of the development plan in force in the area in which the application site is situated; and (b) comprises or includes the provision of more than 2,500 square metres of floorspace for a use falling within any of the following classes in the Use Classes Order—(i) class A1 (retail); 3F- “Development for a use, other than residential use, which includes the provision of more than 200 car parking spaces in connection with that use.” 3 Once Havering Council has resolved to determine the application, it is required to refer it back to the Mayor for his decision as to whether to direct refusal; take it over for his own determination; or allow the Council to determine it itself.

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

5 The roughly rectangular site is 2.9 hectares in size and situated along the A125 Rom Valley Way, on the south-western edge of Romford town centre. The site is bounded on the north by relatively recent blocks of residential accommodation that front onto Oldchurch Road; on the west and south by the grounds of Queen’s Hospital/Oldchurch Park; and on the east by Rom Valley Way.

6 The ice rink building is sited centrally within the application site, with tarmac access routes and car parking areas to its south; and a significant portion of vacant but grassed open space to its north. The latter is the subject of outline proposals for the residential element of this hybrid planning application.

7 The surrounding area is predominantly residential in character, with a mixture of retail and other town centre uses concentrated in an area centred on Romford railway station, northeast of the application site.

Details of the proposal

8 The application is submitted in hybrid form. The detailed application proposals comprise-

 A food superstore with gross internal area of 9,732 sq.m. and a net trading area of 3,760 sq.m. Parking would be provided for 398 vehicles, including a proportion for disabled customers (25), ‘mother & child’ users (12) and 10 dedicated electric-vehicle charging points.

 A six-pump petrol-filling station with an 81sq.m. kiosk and a 12 sq.m. carwash facility.

 New site access arrangements off Rom Valley for both customers and service delivery vehicles.

 Peripheral landscaping.

9 The outline proposals comprise-

page 2  A development of up to 71 residential units on 0.88-hectare of land on the northern portion of the application site.

 Indicative illustrations for 25 three and four-bedroom townhouses, a five-storey block of 36 one and two-bedroom apartments fronting Rom Valley, and a three-storey block of 10 one and two-bedroom apartments in the north-west corner of the site.

10 Altogether, the application proposes a total development of 16,674 sq.m. (gross internal area), including 6,849 sq.m. of residential accommodation. Case history

11 No applications of ‘potential strategic importance’ have been made in respect of this site; however, this retail-led mixed-use application is made in anticipation of the imminent termination or expiry of the current ice rink operator’s lease, and the culmination of land swap negotiations between representatives of Morrison’s Stores Ltd and Havering Council.

12 This application should therefore be considered in conjunction with a separate application by Havering Council for the construction of a new leisure centre on a 0.97-hectare site currently owned by Morrison’s and situated at the junction of Mercury Gardens and Western Road.

13 The details of the aforementioned land deal are elaborated in a subsequent section of this report. Strategic planning issues and relevant policies and guidance

14 The relevant issues and corresponding policies are as follows:

 Leisure London Plan; Good Practice Guide on Planning for Tourism (DCLG)  Health London Plan; Health Inequalities Strategy  Retail/town centre uses London Plan; draft Town Centres SPG  Regeneration/economic London Plan; the Mayor’s Economic Development Strategy development Employment Action Plan;  Employment London Plan; Land for Industry and Transport SPG  Housing London Plan; 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; Housing Strategy; draft Revised Housing Strategy  Density London Plan; Housing SPG  Mix of uses London Plan  Urban design London Plan;  Access London Plan; Accessible London: achieving an inclusive environment SPG; Planning and Access for Disabled People: a good practice guide (ODPM)  Transport/parking London Plan; the Mayor’s Transport Strategy;  London Plan; Mayoral Community Infrastructure Levy; Crossrail SPG  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

page 3

15 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 2008 Havering Core Strategy, Site Specific Allocations DPD, Romford Area Action Plan, Development Control Policies DPD and the 2011 London Plan.

16 The following are also relevant material considerations:  The National Planning Policy Framework and Technical Guide to the National Planning Policy Framework.  The Revised Early Minor Alteration to the London Plan.

Land use policy and the loss of land in sports/leisure use

17 From a strategic perspective, the London Plan (paragraph 3.110) recognises the importance of sport and recreation facilities as parts of the social infrastructure that provide a range of social and health benefits for communities and neighbourhoods. Accordingly, the plan reaffirms the aim of the Mayor’s Sport’s Legacy Plan1, which looks to increase participation in and tackle inequality of access to sport and physical activity in London, particularly amongst groups/areas with low levels of participation.

18 In line with those objectives, London Plan policy 3.16 directs that proposals which would 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. For sports facilities in particular, policy 3.19 makes clear that development proposals which increase or enhance the provision of sports and recreation facilities should be supported; whilst those that result in a net loss of such facilities, including playing fields, should be resisted.

19 At the local policy level, however, the adoption of Havering Council’s Site Specific Allocations DPD pre-dates the 2011 London Plan. It describes the Romford Ice Rink site, which is owned by the Council itself, as being ‘adjacent to Romford Town Centre’ and states, under site allocation policy SSA7, that only a mixed-use development comprising residential, leisure and retail facilities would be allowed. This allocation is supported by core policy CP8 of the borough’s Core Strategy DPD, which states that the Council will work in partnership with other bodies to ensure that a suitable range of community facilities are provided to meet existing and forecast demand by measures that include: ensuring major developments provide facilities to meet new demand, especially in London Riverside and Romford Town Centre, where significant growth in the number of residents is planned; retaining or re-providing community facilities where a need exists; and seeking developer contributions towards the provision of essential new community facilities.

20 The loss of the existing ice rink site that allocation SSA7, core policy CP8 and the current application proposals entail, should therefore be mitigated to secure compliance with both the local and London Plan planning policies.

21 To facilitate the provision of a replacement sports/leisure facility for local residents, Havering Council has proposed the idea of an enabling mixed-use redevelopment on its existing ice rink site to fund the delivery of a new leisure centre in Mercury Gardens. The latter is a significantly smaller site owned by Morrison’s Stores Ltd, and originally intended for a more modest foodstore representation within Romford town centre.

1 Mayor of London: A Sporting Future for London. GLA, April 2009

page 4 22 In essence, the subsequent land exchange agreement between Havering Council and Morrison’s Stores is designed to ensure that there is substantially enhanced provision of a sporting/leisure facility in central Romford. Whilst for its part, Morrison’s Stores would enjoy the benefits of a larger foodstore than originally envisaged at Mercury Gardens, an associated petrol- filling station and the proceeds from residential development.

Continuity of provision

23 The Mayor’s policy position remains robust regarding re-provision of leisure facilities in such situations as set out in policy 3.19 described earlier. Part B of the policy in particular notes that ‘Temporary facilities may provide the means of mitigating any loss as part of the proposals for permanent re-provision’.

24 It is understood that the application at Mercury Gardens is linked to the superstore proposals through the development agreement. The planning statement confirms that the land swap agreement with the Council is only activated if permission is granted for both schemes. Where either scheme is refused permission then the agreement is terminated.

25 The proposed new leisure centre remains a priority for the Council since the closure of the Dolphin Centre in mid 1990’s. It is however important that continuity of provision is fully investigated in the context of policy 3.19. At present it is understood that the current ice rink will close in April 2013 to allow the operators to vacate the building in May 2013 for redevelopment. This would be before the new replacement facilities and leisure centre at Mercury Gardens is constructed and opened to the public.

26 In terms of temporary provision the Council has investigated the opportunity to deliver a temporary facility and has advised that this is not financially viable in the current climate of budget cuts and priority of protection for essential Council services. The Council has however expressed a desire to find a temporary solution and has invited users and skating clubs to develop a business plan. The terms put forward at present by the Council would be to provide a site and building on a rent free basis which would need to be managed by the skating clubs or others.

27 The long term benefits for Havering and Romford Town Centre in particular are clearly evident in this case and the temporary loss of ice skating provision is outweighed by the substantial improvements not just to skating facilities but to leisure facilities in general with the introduction of a new competition pool and fitness centre almost 20 years since the closure of the previous centre. In policy terms therefore there will be no net loss overall in sporting/leisure facilities once the replacement leisure facilities are constructed, rather there will be a net gain of substantially improved facilities in a more central location.

28 In terms of temporary facilities that may provide the means to mitigate short term loss, the Council has suggested an approach which requires input from the local community and users of the current ice rink. This is a reasonable approach in a difficult economic climate and is therefore generally supported.

29 In terms of the applicant’s (Morrisons Stores Ltd) viability and opportunity for further subsidy of temporary provision, a technical appraisal submission has been made to the Council, which the GLA is currently in the process of scrutinising. The Council as planning authority has also commissioned an independent review of this submission, which has recently been undertaken and is also being reviewed by the GLA.

30 This process was principally commissioned to review the viability of providing affordable housing in the residential component of the scheme, but it is also helpful in interpreting the wider section 106 obligations that could arise from this development. At present therefore the GLA is

page 5 still reviewing the applicant’s viability position and will report these findings to the Mayor and the Council prior to final determination. Retail development and the sequential test of location

31 In strategic terms, Romford is designated as a metropolitan centre in the London Plan town centre hierarchy. An application for retail and town centre development stands to be considered against the principles set out in London Plan policy 4.7, most notably that retail, commercial, culture and leisure uses should be focused on sites within town centres, or if no in-centre sites are available, on sites on the edges of centres that are, or can be, well integrated with the existing centre and public transport.

32 The Romford Ice Rink site is located south-west of the designated town centre boundary, approximately 750 metres from Romford Station, which lies close to but clearly outside the southern end of the core retail area of that centre. For such sites, paragraph 23 of the National Planning Policy Framework (NPPF) provides, amongst other things, that in drawing up local plans, local planning authorities should set policies for the consideration of proposals for main town centre uses which cannot be accommodated in or adjacent to town centres.

33 Paragraph 24 adds that local planning authorities should apply a sequential test to planning applications for main town centre uses that are not in an existing centre and are not in accordance with an up-to-date Local Plan. They should require applications for main town centre uses to be located in town centres, then in edge of centre locations and only if suitable sites are not available should out-of-centre sites be considered.

34 In this instance, however, the proposal for a major foodstore in an out-of-centre location accords with an up-to-date borough plan, by virtue of a site-specific allocation and Core Strategy policy. A sequential location test is, therefore, not strictly required. The applicant has, nonetheless, considered the suitability, feasibility and availability of sequentially preferable alternatives in or on the edge of Romford town centre, to allow a more robust assessment of the proposal.

35 The sequentially preferable sites considered by the applicant are:

Site Suitability Feasibility Availability Mercury Yes. On the fringe of the Yes. For comparably-sized Yes. Already owned by Gardens core shopping area. retail store only. applicant for a foodstore development. Angel Way Yes. Within the town No. Not large enough for a stand No. Privately owned. Extant centre’s Ring Road alone store comparable to that permission and other boundary. proposed. No scope for enabling development under residential development. consideration. Como Street Yes- Outside Ring Road No. Not large enough for Yes. Council owned but Car Park but closer to town centre proposed development and previously marketed without than Ice Rink site. constrained by surrounding uses. success.

(Site allocations: Angel Way ROMSSA1 and Como Street ROMSSA3)

36 It is also pertinent to state that the subject application site is already occupied by an established town centre (i.e. leisure) use; the replacement in a more central location of which is inextricably linked to the proposed retail store. It is accepted in this instance that the other sites identified are not suitable and that none are capable of delivering the combined benefits arising

page 6 from the proposals at this site and those currently being considered at Mercury Gardens linked to this scheme. Potential retail impact assessment

37 Paragraph 26 of the NPPF also advises that when assessing applications for retail, leisure and office development outside of town centres, which are not in accordance with an up-to-date Local Plan, local planning authorities should require an impact assessment if the development is over a proportionate, locally set floorspace threshold (if there is no locally set threshold, the default threshold is 2,500 sq.m.).

38 The latter should include an assessment of:

 The impact of the proposal on existing, committed and planned public and private investment in a centre or centres in the catchment area of the proposal;

 The impact of the proposal on town centre vitality and viability, including local consumer choice and trade in the town centre and wider area, up to five years from the time the application is made. For major schemes where the full impact will not be realised in five years, the impact should also be assessed up to ten years from the time the application is made.

39 Where an application fails to satisfy the sequential test or is likely to have significant adverse impact on one or more of the above factors, it should be refused. (Paragraph 27).

40 Having regard to the applicant’s submissions at appendix 5-8 of the retail analysis, officers are satisfied that the proposal would not threaten existing investment nor would it lead to significant adverse effect on either Romford or other nearby centres sufficient to justify refusal under paragraphs 26-27 of the NPPF or policy 4.7 of the London Plan.

Affordable housing

41 London Plan Policy 3.12 requires borough councils to seek the maximum reasonable amount of affordable housing when negotiating on individual private residential and mixed-use schemes. In doing so each council should have regard to it’s own overall target for the amount of affordable housing provision. This target should take account of the requirements of London Plan Policy 3.11, which include the strategic target that 60% of new affordable housing should be for social rent and 40% for intermediate rent or sale. The Mayor has published an early minor alteration to the London Plan to address the introduction of affordable rent, with further guidance set out in a draft Affordable Rent SPG. With regard to tenure split the Mayor’s position is that both social rent and affordable rent should be included within the 60%.

42 While the Mayor has set a strategic investment benchmark that across the affordable rent programme as a whole rents should average 65% of market rents, this is an average investment output benchmark for this spending round and not a planning policy target to be applied to negotiations on individual schemes.

43 Policy 3.12 is supported by paragraph 3.71, which urges borough councils to take account of economic viability when estimating the appropriate amount of affordable provision. The ‘Three Dragons’ development control toolkit or other recognised appraisal methodology is recommended for this purpose. The results of a toolkit appraisal might need to be independently verified. Paragraph 3.75 highlights the potential need for re-appraising the viability of schemes prior to implementation.

page 7 44 The Council’s 2008 Core Strategy and Development Control DPD sets out a 50% target for affordable housing (policy DC6) amongst other detailed policies regarding housing mix and design.

45 The housing offer is based on an outline mix which includes 25 - 3 & 4 bedroom town houses, a five storey block of flats containing 36 - 1 & 2 bedroom flats and a three storey block of flats containing 10 – 1 & 2 bedroom flats. The overall indicative mix is set out below:

1-bed 2-bed 3-bed 4-bed Total

Market 15 31 10 15 71

46 These are currently proposed as private accommodation only. The affordable housing offer is therefore zero. This is based on the applicant’s land swap arrangement and is supported by viability appraisal submitted by the applicant. As set out earlier in this report the GLA is in the process of reviewing this submission in the context of the applicant’s ability to offer continuity of ice skating provision and in terms of the affordable housing offer and other section 106 requirements. Density

47 The residential site area is 0.88 hectares. Based on the indicative scheme the proposals would provide 238 habitable rooms generating a density of 270 habitable rooms per hectare. The site is in an accessible location (public transport accessibility level 5a) falling within the density range of 200-700 habitable rooms per hectare as set out in the London Plan. The proposals are therefore at the lower end of the range in the London Plan. This is largely due to the approach to the indicative town house style provision of family housing with private gardens.

48 Whilst the proposal is not inconsistent with the guidance in the plan there is clearly scope to increase density on this site, which may allow for provision of affordable housing and other section 106 benefits, subject to viability. Increase in density would however result in a very different design approach and therefore the applicant should confirm what density options have been considered to establish if the current offer represents the optimum approach in terms of both design and density arrangements.

Urban design

49 Good design is central to all objectives of the London Plan and is specifically promoted by the policies contained within chapter seven which address both general design principles and specific design issues.

50 The GLA raised a number of layout issues at pre-application. In particular regarding the superstore service yard arrangement backing onto the new residential plots and the wider connections of the residential layout. The design team has explored options to improve the arrangements but the layout remains generally the same as originally presented to the GLA. Some additional mitigation is proposed to screen and enclose the service yard from the proposed residential units, which is supported. The main issue however relates to pedestrian movement around the site and this needs to be resolved, in particular regarding the relationship to the bus stops and the routes for pedestrians into the site (see TfL comments).

51 The architecture of the store is generally supported. It proposes a flowing roof form which uses natural lighting. The materials palette includes a mix of insulated interlocking panels (grey

page 8 and yellow), glazing, timber and render. The car park deck is also supported to maximise the efficiency of the site.

52 In terms of housing quality London Plan Policy 3.5 promotes quality in new housing provision and sets out minimum space standards at Table 3.3. The Mayor has produced a housing SPG on the implementation of Policy 3.5 for all housing tenures, drawing on his London Housing Design Guide, which sets quality and design standards for new housing.

53 This proposal recognises much of the principles enshrined in the SPG. Indicative layout is provided and is broadly supported. There is however no clear playspace strategy for the site. Whilst it is recognised that most of the units would benefit from private gardens, not all benefit from such access and therefore some communal space needs to be considered. Policy 3.6 of the London Plan sets out that “development proposals that include housing should make provision for play and informal recreation, based on the expected child population generated by the scheme and an assessment of future needs.” The applicant should use the methodology within the Mayor’s supplementary planning guidance to calculate the approximate child occupancy levels. The guidance in the SPG sets a benchmark of 10 sq.m. of useable child playspace to be provided per child, with under-5 child playspace provided on-site. Further work is therefore required to secure a suitable strategy.

Access

54 Inclusive design principles, if embedded into the development and design process from the outset, help to ensure that all of us, including older people, disabled and deaf people, children and young people, can use the places and spaces proposed comfortably, safely and with dignity.

55 Lifetime homes and wheelchair accessible homes should be conditioned by the Council in relation to the residential component of the scheme. The superstore proposals provide a generally accessible layout in terms of egress around and within the building. Parking arrangements for disabled users is generally well located.

Climate change mitigation

56 For the superstore the proposals provide an approach which utilises the high refrigeration demands and recovers heat for domestic hot water and space heating. This is supplemented by the efficient design of the building and residential units which will include photovoltaic panels to provide electricity generation. Overall the proposals will provide in excess of 25% carbon reduction beyond building regulations 2010. The GLA Energy Team is however still in the process of reviewing the overall strategy. In particular it is disappointing that the applicant has not been able to establish suitable connection to Queen’s Hospital district heating network. Further comments will therefore be provided. Climate change adaptation

57 The London Plan promotes key adaptation principles in Chapter 5 that promote and support the most effective adaptation to climate change. These are to minimise overheating and contribution to heat island effects; minimise solar gain in summer; contribute to flood risk reductions, including apply sustainable drainage principles; minimise water used; and protect and enhance green infrastructure and urban greening. Specific policies cover overheating, urban greening, living roofs and walls and water.

page 9 Overheating (Policy 5.9)

58 The passive measures are shown within the design and access statement in terms of the layouts proposed, including the use of double and multi aspect houses and apartments in the residential component of the scheme. The store has generally been designed to avoid the need to actively cool, which is also supported. Some smaller areas will require an element of cooling.

Living roofs and walls (Policy 5.11)

59 Green and brown roofs are not compatible with the design of the store roof in this instance. There may however be scope for provision as part of the residential component of the scheme, which should be secured by condition by the Council, consistent with London Plan policy 5.11.

Flooding (5.12), sustainable drainage (5.13) water use (5.15)

60 This site is within the Environment Agency’s Flood Zone 1 with a low probability of river flooding in any given year. Both residential and retail developments are therefore generally acceptable in these conditions. The flood risk assessment notes that surface water runoff will be improved to near greenfield rates. The store includes rainwater harvesting system. The overall approach to this site is and is consistent with London Plan Policy 5.13.

61 Policy 5.15 sets a maximum water use target of 105 litres per person per day for residential dwellings. The applicant should make a clear commitment to meeting this policy requirement, which should be secured by condition by the Council. ’s comments

Accessibility of the Site

62 The development proposes a number of segregated pedestrian links and these are in principle, welcomed. TfL considers that the most significant of these is the one between the adjoining Queens Hospital and the site, especially since most of the bus routes which would serve the store stop at the bus facility on hospital land between the site and the hospital.

63 Currently the main users of buses at the facility are associated with the hospital itself. TfL consider the foodstore will create a more balanced distribution. TfL are concerned that pedestrians will seek the most direct route to the store, creating potential conflicts with buses egressing the Queens Hospital site and vehicles travelling along the access road. The foodstore will attract a number of vulnerable user groups, and the Road Safety Audit should consider the interaction of pedestrian desire lines and vehicular traffic. TfL request the scope of the Road Safety Audit is revised to consider these pedestrian movements.

64 These safety issues would be reduced significantly with the implementation of a pedestrian link between the store and the bus facility. However, whilst the applicant has agreed to construct that part which is within its site, it has stated it would not be willing to be bound to ensure the remainder (outside of its ownership) is completed. This is not unreasonable as it could create a ‘ransom’ situation. However, TfL is concerned that the incentive for the applicant to resolve this issue will diminish if permission is granted and as the development is implemented. TfL therefore seek clarification from the applicant as to how they intend to continue to seek a resolution and from the Council on means of securing these continued efforts. Without the completion of the link, TfL consider that pedestrians will seek the most direct route to the site which may promote the creation and use of informal routes, which are not as safe and secure as the aspired link.

Highway Impact of the Scheme

page 10 65 TfL have reviewed the modelling supplied within the TA to test whether it provides enough supporting evidence for TfL to provide in principle support and whether this would be a sufficient basis to gain relevant approvals from TfL as strategic traffic authority. TfL consider the principal of the revised junction layout on Rom Valley Way acceptable. However, the TA currently does not provide a strong enough evidence base to support its implementation.

66 In respect of modelling for individual junctions, TfL are concerned by the impact of the development upon the performance of the A125/A126 junction, and encourage the applicant to explore ways to reduce the impact of the development upon the local road network.

Vehicular Access Arrangements

67 TfL consider the provision of an egress onto Rom Valley Way solely for petrol tankers unnecessary and could impact upon the safety of the SRN. TfL therefore request that the applicant submits a design that ensures petrol tankers can use instead the primary vehicle egress.

68 TfL note the route to the proposed store pick up and drop off facility is indirect and will encourage use of Rom Valley Way instead. TfL request that the applicant looks again at vehicular routes to the facility and consider whether these can be made more to direct, to increase the desirability of use by drivers.

Car Parking

69 For the foodstore, 400 car parking spaces are proposed, equating to a parking ratio of 1 space per 20sqm of floorspace. This is in excess of the maximum standards for parking for foodstores in areas with a PTAL of 5 and 6 set out in the London Plan. It is acknowledged that the applicant has taken note of TfL’s pre-application comments and reduced parking levels from the initial proposal. However, it is requested that the number of spaces is reduced further to both lessen the impact of the development upon the local road network and ensure the proposal accords with Policy 6.13 of the London Plan. TfL consider the provision of 314 spaces the acceptable maximum.

70 The proposal includes the provision of 25 spaces for Blue Badge users, this ratio accords with London Plan standards for foodstore customers. However, there is also a requirement to provide for disabled employees who are motorists and TfL request clarification as to how the applicant will ensure their needs are met.

71 The TA outlines that 10 parking spaces will be equipped with Electric Vehicle Charging Points (EVCPs), with passive provision for an additional 30 parking spaces. As this does not accord with London Plan standards TfL request the shortfall is addressed.

72 With regards to the residential element of the site, TfL consider the proposed ratio of 0.8 car parking spaces per unit acceptable. However Blue Badge parking and EVCPs should be provided in line with the standards set out in the London Plan.

Bus Services and Infrastructure

73 The commitment to promote access to the site by public transport is cited as one of the objectives of the Travel Plan for the site, and is welcomed.

74 Whilst the development will result in additional use of bus services, TfL do not consider that capacity issues will arise. The site is also already well connected by bus to its potential catchment. However to maximise use of buses TfL consider it important that the above mentioned issues relating to the link between the store and the bus facility are resolved.

page 11 75 TfL request a contribution of £80,000, secured through a S 106 agreement, towards the upgrade and extension of bus shelters and for safety and public realm improvements at the bus facility. The latter improvements would support the improved pedestrian link between the store and the bus facility once the land issue referred to above is resolved. If agreement between the NHS Trust and the applicant is not possible this funding would help mitigate impacts arising from there being no resolution.

Cycling and Pedestrian Provision

76 In respect of cycle parking for the store, though it is acknowledged that in the application, the site is described as a “out of town centre location”, TfL request that the in centre cycle parking standard outlined in the London Plan is applied, given the proximity of the site to the town centre. TfL request that 63 cycle parking spaces are provided instead of the 22 currently proposed. For the residential element of the development, TfL are content that the level of cycle parking proposed accords with London Plan standards. All cycle parking should be secured by an appropriate planning condition.

77 TfL welcome the provision of showers and changing facilities within the store, and consider this will further increase the desirability of cycling amongst employees.

78 TfL seeks further details regarding the pedestrian routes proposed within the development including the width of footways and lighting along them. TfL request the applicant submits a number of “views” illustrating the visibility of the store from the proposed entrances to the site, and in particular from the adjoining bus facility and vice versa. These submissions should illustrate the legibility of routes from the perspective of the pedestrian, and illustrate that pedestrian destinations are well defined.

79 TfL note that LB Havering is seeking to enhance pedestrian links between the town centre and the site through the development of the Romford Town Centre Major Scheme which seeks to tackle local severance and improve pedestrian connectivity.

Travel Plan

80 TfL note the submission of a Travel Plan for the food store, however this has failed the ATTrBuTe assessment. TfL are able to provide a summary of the results upon request, in particular additional information regarding how the Travel Plan will be secured and funded should be provided as well as an assessment of the existing transport links to the site. In addition, TfL request that a Travel Plan for the residential element of the site is secured through a S 106 agreement.

Construction

81 TfL request that the submission of a Construction Logistics Plan (CLP) is secured via an appropriate planning condition/obligation. TfL request this CLP is submitted and approved before any works commence, including site clearance and preparation and enabling works.

Servicing

page 12 82 TfL welcome the commitment of the applicant to submit a Delivery and Servicing Plan (DSP). It is requested that a condition is imposed on any permission which requires this DSP to be submitted to and approved by LB Havering in conjunction with TfL prior to occupation Community Infrastructure Levy

83 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 London that was granted planning permission on or after that date. The Mayor's CIL will contribute towards the funding of Crossrail

84 The Mayor has arranged boroughs into three charging bands. The rate for Havering 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

85 London borough councils are also able to introduce CIL charges which are payable in addition to the Mayor’s CIL. Havering has yet to adopt a scheme. See the council’s website for more details. Local planning authority’s position

86 The officer recommendation is currently unknown. Legal considerations

87 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

88 There are no financial considerations at this stage. Conclusion

89 London Plan policies on leisure, retail, housing, design, energy and transport are relevant to this application. The application complies with some of these policies but not with others and on balance does not comply with the London Plan; the reasons and potential remedies to non compliance are set out below:

 Principle of development: (compliant). The long term benefits clearly outweigh the temporary loss of leisure (ice rink) provision in this instance. The Council has however

page 13 suggested a joint solution which would require direct support from the local community. GLA officers are reviewing the viability submission in regard to other wider continuity contributions possible from the applicant.  Affordable housing quantum, mix and density (non-compliant). GLA officers are reviewing the viability submission in the context of the zero quantum of affordable housing currently offered.  Play space (non compliant). A strategy should be set out to meet the needs of the emerging child population.  Urban design (non-compliant): The design of the store is generally supported. The flat layouts and approach to residential quality is also broadly supported. Further work is needed to ensure the pedestrian environment around the site will function efficiently in the context of the bus stand arrangements.  Access (compliant): The proposals are generally accessible. Suitable conditions for lifetime homes and wheelchair homes should be secured.  Climate change mitigation (non-compliant): the GLA’s technical officers are in the process of detailed review of the energy strategy. Further comment will be provided.  Climate change adaptation (compliant): Broadly acceptable subject to conditions set out in this report.  Transport (non-compliant): The report sets out a series of transport matters that require further work.

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] Matthew Carpen, Senior Strategic Planner (Case officer) 020 7983 4272 email [email protected]

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