planning report PDU/2786/01 5 September 2011 Former Cat Hill Campus, Cockfosters

in the London Borough of Enfield planning application no. TP/11/0904

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

The proposal Full planning permission for redevelopment of site, comprising demolition of college campus buildings and construction of a residential scheme containing 272 units in a range of houses and flats, with associated access roads, parking, amenity space and landscaping.

The applicant The applicant is London and Quadrant and the architect is Formation Architects.

Strategic issues The principle of a residential development on this site is acceptable, subject to confirmation from Enfield Council that there is no ongoing or future demand for the education use. Further clarification is required in relation to the affordable housing offer, and confirmation that the housing mix, and tenure meet local housing needs.

There are a number of other planning issues that will also need to be resolved before this application can be considered to fully comply with London Plan policy, including design, children’s play space, climate change and transport.

Recommendation

That Enfield Council be advised that the application does not comply with the London Plan, for the reasons set out in paragraph 88 of this report; but that the possible remedies set out in paragraph 90 of this report could address these deficiencies.

Context

1 On 1 August 2011 the Mayor of London received documents from Enfield 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 11 September 2011 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 Category 1A of the Schedule to the Order 2008:

“Development which comprises or includes the provision of more than 150 houses, flats, or houses and flats.”

3 Once Enfield 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 former Cat Hill Campus comprises accommodation for University, located at the junction of Cat Hill and , in the borough of Enfield. The site is 4.9 hectares in area and contains an approximate 17,000 sq.m. of educational buildings dating back to 1969, and including the Museum of Domestic Architecture. The university has vacated the site this summer and has relocated to new purpose built facilities on the university’s Campus and the museum is relocating to Beaufort Park.

6 The site contains a significant number of mature trees, and two landscaped ponds. The site slopes down from the roads to the south-west corner of the site. The site is bounded by a school to the south, playing fields to the east on the opposite side of Chase Side, and semi- detached and detached residential properties to the west and north.

7 The site is equidistant between Oakwood and Cockfosters stations, on the . Buses to Southgate and Barnet stations also pass the site. The PTAL (public transport accessibility level) of the site ranges across the site from 1b, 2 and 3 (where 1 is low and 6 is high). This equates to a poor to moderate level of access to public transport.

Fig 1 and 2: Site location plan and aerial photo (source: submitted D&A statement)

Details of the proposal

8 A detailed planning application is being submitted for redevelopment of the site to contain 272 residential units.

page 2 9 The scheme includes a mix of flats and houses, in a series of terraced houses and blocks of flats, ranging in height from two to six storeys in height.

10 A network of estate roads are proposed, including adopted, private and home zones. A total of 308 parking spaces are proposed, to be located at surface level or in basements below the 6-storey crescent blocks.

Fig 3: Layout and tenure (source: submitted D&A statement) Case history

11 A pre-application meeting was held with GLA officers in May 2011 where it was advised that the principle of introducing a residential development to this area was acceptable in strategic terms, subject to consideration being given demand for school land in the area and local employment policies. Issues were raised in relation to the housing provision, the protection of trees, the treatment of the flatted blocks, parking layout and landscape design and where revisions were requested in order to comply with the London Plan. Strategic planning issues and relevant policies and guidance

12 The relevant issues and corresponding policies are as follows:

 Principle of development London Plan; PPS1  Housing/affordable housing London Plan; PPS3; Housing SPG; Housing Strategy; interim Housing SPG; Housing SPG EiP draft  Density London Plan; PPS3; Housing SPG; interim Housing SPG  Urban design London Plan; PPS1  Child play space London Plan; Providing for Children and Young People’s Play and Informal Recreation SPG  Access and inclusive design London Plan; PPS1; Accessible London: achieving an inclusive environment SPG; Planning and Access for Disabled People: a good practice guide (ODPM)  Sustainable development London Plan; PPS1, PPS1 supplement; PPS3; PPG13; PPS22; draft PPS Planning for a Low Carbon Future in a Changing Climate; the Mayor’s Energy Strategy; Mayor’s draft Climate

page 3 Change Mitigation and Adaptation Strategies; Mayor’s draft Water Strategy; Sustainable Design and Construction SPG  Biodiversity London Plan; the Mayor’s Biodiversity Strategy; PPS9; draft PPS Planning for a Natural and Healthy Environment  Transport London Plan; the Mayor’s Transport Strategy; PPG13

13 The development plan in force for the area is the 2010 Enfield Core Strategy and saved UDP policies, and the London Plan (2011). Principle of development

14 The site presently comprises education and community uses that were until recently used by for an arts and design faculty, which has recently relocated to Hendon. The Museum for Domestic Architecture was also previously located here until it closed recently to relocate to Beaufort Park, in October 2011. Policy 3.18 of the London Plan seeks to resist the net loss of, and increase the provision of, social infrastructure and community facilities such as schools to meet future demand and existing deficiencies unless it can be demonstrated that there is no ongoing or future demand.

15 The site has become vacant due to the relocation by Middlesex University, which sold the site to the applicant. The applicant has provided a commentary that confirms that it is highly unlikely that another similar education operator would be able to purchase the site in the short or medium term given the potential funding issues facing education institutions at present. The site has a low accessibility level, which it is acknowledged could also limit interest from educational institutions.

16 In order to address the Council’s previous comments about the loss of employment use on the site, the applicant has submitted an appraisal from the property agent that marketed the site on behalf of the University and also carried out its own research. The reports confirm the lack of an office market in the area, and that the size of the site would be unlikely to attract a leisure facility, food store operator, or care home, for instance. Any proposed user would be expected to share the site with a complementary user, and only the house building sector submitted offers for the site. Given that the site is not protected for employment or educational uses, and subject to confirmation from Enfield Council that the site is not required to meet any educational need, on balance, the use of the site for housing is acceptable in principle.

Housing

17 The scheme proposes 272 residential units, made up of the following mix:

Unit Private Affordable Shared Rent to buy Total Type rent ownership

1-bed 29 (15% 3 (13% 6 (20%) 6 (20% 44 16% ) ) )

2-bed 66 (35% 6 (25% 2 (7%) 14 (47% 88 32% ) ) )

3-bed 48 (26% 6 (25% 22 (73%) 10 (33% 86 32% ) ) )

4-bed 45 (24% 9 (38% 0 0% 0 0% 54 20% ) )

page 4 Total 188 69% 24 9% 30 11% 30 11% 272 100%

18 London Plan policy 3.3 seeks provision of at least an annual average of 33,400 additional homes across London up to 2015/16. Table 3.1 sets annual average housing provision monitoring targets for London boroughs, of which Enfield’s is 560 units additional homes per year between 2011 and 2021. The proposed development represents 48% of Enfield’s annual housing target, and is welcomed in principle.

Affordable housing

19 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 current and future requirements for affordable housing at local and regional levels, its own overall target for affordable housing provision, and the need to encourage rather than restrain residential development. Policy 3.11 states that borough targets should take account of matters including current and future housing requirements, the strategic targets and priority accorded to affordable family housing, the need to promote mixed and balance communities, and the viability of future development, and that within those targets 60% of affordable housing should be for social rent, and 40% for intermediate rent or sale.

20 Policy 3.12 is supported by paragraph 3.71, which requires borough councils to take account of economic viability and the most effective use of private and public investment, including the use of developer contributions. Evaluations should draw on the GLA development control toolkit and other independent assessments to demonstrate that each scheme maximises affordable housing output. The results of a toolkit appraisal might need to be independently verified.

21 The scheme proposes 84 affordable units, of which 24 would be affordable rent and 60 would be intermediate (30 shared ownership and 30 rent to buy). The overall affordable housing provision amounts to 31% of units and habitable rooms, with a split of 29% affordable rented units and 71% intermediate accommodation.

22 Enfield Council’s Core Policy sets a borough-wide target of 40% affordable housing units in new developments, and states that in agreeing an appropriate level of affordable housing, factors such as viability assessments, market conditions, grant availability and land values will be taken into consideration. In order to accord with the Council’s policy and London Plan requirements that it be demonstrated that the maximum reasonable amount of affordable housing is being delivered, the applicant has submitted a Three Dragons viability assessment to support its assertions that an appropriate affordable housing offer is being made. At the time of writing, the Council had not confirmed its intentions in terms of independent appraisal, and in the absence of this assessment, it is not possible at this stage to confirm whether the applicant is providing the maximum reasonable amount of affordable housing in accordance with London Plan policy 3.12.

23 It is noted that the applicant has provided some details of discussions that have been held with Enfield Council about the affordable rent rates for the larger three and four bed units, with these being set at approximately 46% rather than 80% so as to ensure that the rent levels of the family units are more affordable. Rent discounts at less than 50% would be affordable to a greater proportion of those on the Council’s housing waiting list, and in this regard, would be

page 5 comparable to traditional social rented units. This is welcomed and should be secured by way of the section 106 legal agreement.

24 Notwithstanding the comments above, in order to be satisfied that the overall scheme meets London Plan affordable housing policies, GLA officers would expect to be involved in discussions relating to the toolkit appraisal. This is particularly in light of the fact that the applicant has used the acquisition cost rather than existing use value as a benchmark, and given that it is a registered social landlord, responsible for delivering social housing as a priority. Furthermore, it is noted that no information has been provided about the rent levels for the smaller affordable units. This information should be forthcoming as part of further discussions, in order to be clear that these units would be affordable and meet Enfield’s needs. If the applicant’s assumptions about rent levels, values and build costs, for example do require review, this may impact upon the viability of the scheme and as such these details will need to be confirmed before the section 106 agreement is drafted. Further discussion in relation to the points above and section 106 definitions would be expected before the application is reported back at Stage 2, so as to be clear that the scheme reflects London Plan policy and the Housing SPG, and that a transparent programme of affordable housing delivery is secured.

Tenure split

25 London Plan policy 3.12 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 Council, in its Core Strategy, also establishes a broad tenure split for the affordable housing to be delivered over the plan period, seeking 70% of the total housing within the borough to be social rented housing, with 30% as intermediate provision. The application provides 29% affordable rent and 71% intermediate provision, when measured by habitable room. The proposed mix does not therefore accord with strategic policy 3.12 or Enfield Council’s own policies.

26 As noted in paragraph 3.63 of the London Plan, PP3 (Housing) introduces affordable rent as a new social housing product. Affordable rent, although not operated under the same agreements as social rented housing, is considered an affordable housing product, and is intended to be available to those eligible for social rented housing. It is also solely a rented product, as opposed to intermediate housing, which typically involves an element of sale to the occupier. In the recent funding programme issued by the Homes and Communities Agency for the period 2011 to 2015, it has been made clear that funding for social rented products will only be supported in limited circumstances.

27 This move in national housing policy is not reflected in the 2011 London Plan, but as an interim measure the Mayor intends to provide guidance in the Housing SPG on how this new product can be used to implement the policies for the London Plan. An early alteration to the Plan’s policies on affordable housing is also proposed, to factor in the new product and address the implications of the new policy direction given its introduction after the strategic planning policies for London. In the meantime, it is acknowledged that the introduction of a new affordable housing product, together with the lack of government funding for social rented housing, will impact on the ability of developments to meet the tenure mix set out in policy 3.12.

28 The rent-to-buy units are based on a new model called ‘UpToYou’, which was introduced by the applicant, L&Q in 2009. This is a flexible rent to purchase product that is backed by the Mayor’s First Steps low-cost homes initiative, a funding programme that provides assistance in helping first time buyers to get onto the property ladder. The ‘UpToYou’ programme allows customers who fall below certain income levels to choose whether they rent

page 6 or buy the home, either outright after six months of renting, or through shared ownership. If customers are unable to buy now they can rent at submarket levels for as long as they choose. Their tenancy has a purchase option which they can call on when they are able to buy and their intermediate rent means they are able to save up for a deposit if they wish. Together with the shared ownership units, the scheme ensures that a range of intermediate housing types is provided - allowing greater flexibility for movement between tenures, and the implementation of one of the Mayor’s low-cost housing initiatives. This is welcomed and in accordance with policy 3.8 of the London Plan.

29 It is acknowledged that the 60:40 target within London Plan policy 3.12 is not a site specific target, and that the recent shifts in government policy are not currently reflected in strategic policy. The introduction of a new affordable housing product, together with the lack of government funding for social rented housing, will impact on the ability of developments to meet the strategic target within policy 3.12. Furthermore, as discussed in paragraph 23 above, it is likely that the larger affordable rent units that are targeted at less than 50% market rent, will in fact be affordable to those tenants who would have previously been allocated social rented housing. As such, and subject to confirmation from the Council that the proposed tenure split meets its local housing needs, the tenure split as proposed is acceptable in principle.

Mix of units

30 London Plan policy 3.11 accords priority to family housing within affordable housing provision. In addition, policy 3.8 requires developments to provide a range of housing sizes and types. This is supported by the London Plan Housing Supplementary Planning Guidance, 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. It sets out the following housing mix in line with strategic need: 32% 1-bed units, 38% 2 and 3-bed units, and 30% 4-bed plus units. Also relevant is Policy 1.1C of the London Housing Strategy, which sets a strategic target for 42% of social rented homes to have three or more bedrooms.

31 The scheme proposes: 16% one-bed units, 64% two and three-bed units and 20% four- bed plus units. Whilst this mix does not therefore accurately reflect the London-wide need identified in the SPG, in accordance with strategic priorities, family accommodation has been prioritised within the affordable element, with 78% of the affordable rent units being proposed for families, and all of these units being houses with gardens.

32 As discussed above, strategic policy does not currently reflect the recent shifts in affordable housing, particularly the amendments to the definitions of affordable housing to include affordable rent products, and changes to funding priorities. However, it is acknowledged that affordable rent is to be targeted at those eligible for social rented housing, and that it is an affordable housing product markedly different in funding and operation to intermediate housing. In this context, the prioritisation of family accommodation within the affordable rent element does recognise strategic objectives, and is therefore supported.

33 Within the private accommodation, 50% of the units are larger family units. The Mayor’s Housing SPG (2005) does not establish a specific target for private family accommodation, but acknowledges that access to housing within the private sector is in relation to ability to pay, rather than housing requirements. The Mayor’s Housing Strategy (2010) provides updated guidance on this issue, and states that “While there is obviously a significant demand for family- sized market homes in the capital, the Strategic Housing Market Assessment found little net requirement for this type of housing across London, although there are bound to be local variations”.

page 7 34 The Mayor’s Housing Strategy does provide some updated guidance with regard to intermediate provision and sets a target of 16% of homes within this tenure to be family sized. The application includes 32 three-bed intermediate properties, which represents 53% of intermediate provision. This significantly exceeds the Housing Strategy and is strongly supported.

35 Given that over half of the units overall are family units and the proposal gives priority to family social housing above other tenures, together with the nature of the affordable rent product and the limitations to the delivery of traditional social rent, the proposed mix is broadly in accordance with the strategic objectives established in London Plan policy 3.11. In order to be satisfied that the scheme meets local needs, further details of how the mix was arrived at and details of discussions that have been held with Enfield Council’s housing department should be provided before the application is reported back at Stage 2.

Density

36 London Plan policy 3.4 requires development to optimise housing output for different locations taking into account local context and character, the design principles in Chapter 7 and public transport capacity. Table 3.2 provides density guidelines in support of this. The site has a public transport accessibility level (PTAL) of between 1b and 3, on a scale of 1-6, where 6 is most accessible. The site lies in a suburban setting, as defined by the London Plan and a density range of 150 – 250 habitable rooms per hectare or up to 95 units per hectare is indicated in Table 3.2.

37 With a site area of 4.8 hectares sq.m., the density of the scheme is approximately 230 habitable rooms per hectare, or 57 units per hectare, which is within the density range set out in the London Plan. Subject to the scheme delivering a high quality living environment (including adequate provision of amenity space, an appropriate level of affordable housing, a good mix of unit sizes, high quality design and resolution of all transport and climate change issues), the density of the scheme is appropriate in this instance,.

Residential quality

38 London Plan policy 3.5 promotes quality in new housing provision and sets out minimum space standards at Table 3.3, requiring units to have adequately sized rooms and convenient and efficient room layouts. The London Housing Design Guide (LHDG) sets out a number of aspirations that would ensure the design and layout of residential developments will be of the highest quality both in their internal design and the impact they will have on the surrounding area. the Mayor will produce a new Housing SPG, building on a draft Housing SPG that was produced for the London Plan examination in public, and will look to provide guidance and demonstration of best practice in residential design quality, to apply to all housing tenures (not just affordable).

39 The scheme proposes a range of houses and flat sizes and the applicant has provided an assessment of the scheme against the LHDG. All units would meet relevant minimum space standards, and all dwellings would be provided with private outdoor space, either as a garden or balcony. The majority of the LHDG guidelines are incorporated, including maximisation of dual aspect units, storage space, and no solely north facing units. Subject to the commitments set out by the applicant being secured by the Council through conditions, the scheme is in accordance with London Plan policy 3.5.

Urban design

page 8 40 Good design is central to all objectives of the London Plan (2011) and is specifically promoted by the policies contained within chapter seven which address both general design principles and specific design issues. London Plan Policy 7.1 sets out a series of overarching design principles for development in London. Other design polices in this chapter and elsewhere in the London Plan include specific design requirements relating to maximising the potential of sites, the quality of new housing provision, views, the public realm and the natural environment. New development is also required to have regard to its context, and make a positive contribution to local character within its neighbourhood (policy 7.4).

Context and layout

41 The justification for the loss of the existing buildings is accepted. The existing buildings on the site clearly have a specific form and function that would not be suited to residential development.

42 The landscape (particularly the existing trees) is the most significant character-defining element of the site, and retention of as many trees as possible must be a priority, in accordance with London Plan policy. Biodiversity and incorporation of features to enhance the existing site ecology is also necessary. In this case, the development acknowledges both aspects of the site’s character reasonably well, with the attractively verdant perimeter zones being retained within the design. It is, however disappointing that this organic, landscaped character has not been applied more widely on the residential streets. Although the crescent form of these streets contributes to their character, the limited space available in each house’s front garden means that there are no opportunities for tree planting. The landscape character should be extended through the site, and the landscape plan should demonstrate this commitment through the addition of street trees and, if possible, a further reduction in the level of on-street parking.

43 The site location and limited opportunities for permeability through to existing, adjoining residential development presents constraints in terms of neighbourhood integration. The separation of the new community from its surroundings would be visual as well as physical, as a result of the vegetated site perimeter. The proposal would entail the removal of some trees, but this would be for the overall benefit of the new community. Additional tree planting is proposed throughout the site and together with the new buildings, would assist in integrating the community with the existing neighbourhood (rather than creating a spatially separated community completely hidden within edge vegetation). Furthermore, the applicant has designed the northern entrance to the development to include blocks that would create a built chain between the site and existing development.

44 The use of focal neighbourhood points within the development layout, such as the pond areas, is supported. Visual connections from the houses through the development are also welcomed. The layout of the flatted blocks in a regular geometric pattern is reminiscent of mid- late twentieth century development and although this has benefits in the context of the development, there were concerns at the pre-application stage that these would be at odds with the landscape character of the wider development. However, the landscape proposals have been developed as part of the submission and would provide effective communal spaces for residents.

45 There is evidently a trade-off between the level of on-street parking that is required for this number of units and the overall character of the site, and it appears that the former would dominate to the detriment of the latter. As noted earlier in this section, there are opportunities which exist for street landscaping and tree planting, which could assist in reinforcing the green character of the site and help to soften the harder aspects of the street environment. Officers would welcome further discussion and commitment from the applicant on this point.

page 9 46 In terms of internal site permeability, the design approach that has been taken is generally welcomed. The transverse pathways between the crescent streets are positive, but as advised at pre-application stage, the houses adjoining these routes should provide passive surveillance through the inclusion of flank windows – offset from each other if possible, to avoid privacy issues.

47 The ‘trim trail’ along the western boundary is a welcomed feature of the scheme, but as was also advised at pre-application stage, there are a number of secure by design and biodiversity issues regarding lighting and night-time use that require will require addressing in order for this to be a successful space. Additionally, although the landscape strategy notes the potential for individual management of the boundaries between this public space and adjoining private gardens, the Council will need to ensure that appropriate boundary materials and a management strategy are secured in order to ensure that there is effective surveillance and the space is appropriately managed. There is a particular concern about the isolated and restricted area of public space in the south western corner of the site, behind the private garden boundaries, which has the potential to be neglected and could create issues of anti-social behaviour, for instance. Consideration should be given to extending the private gardens to the site boundary in this area, or some other means of managing this area to ensure there is surveillance and effective management of this space. Further discussion on this aspect would be welcomed before the scheme is reported back at Stage 1 and appropriately worded conditions will need to be secured.

Scale and massing, amount and appearance

48 The proposed scale of development is appropriate to its context. Building heights appear appropriate and would work well, in conjunction with the site’s contours. The massing of buildings is functional and appropriate in this case, although perhaps more organic forms would have better suited the landscape character.

49 Houses would be similar in appearance but would have similar proportions to traditional residential terraces, and the curved streets would further assist in creating more visual interest. The appearance of the flatted blocks is generally positive, although the five main blocks would appear similar, which could lead to issues with legibility. There is a further concern that proposed A and C blocks at the main site entrance appear bland and have areas of inactive frontage; this impression is perhaps intensified by the fact that in this location, these buildings should offer the impression of a gateway, which is a role that they do not successfully perform at present. Further discussion and refinement of this element of the scheme would be welcomed. Children’s play space

50 London Plan policy 3.6 requires developments that include housing make provision for play and informal recreation, based on the expected child population generated by the scheme and an assessment of future needs. Using the methodology within the Mayor’s supplementary planning guidance ‘Providing for Children and Young People’s Play and Informal Recreation’ it is anticipated that there will be approximately 120 children within the development. The guidance sets a benchmark of 10 sq.m. of useable child playspace to be provided per child, with under-5 child playspace provided on-site. As such the development should make provision for approximately 46 children under the age of five and provide 460 sq.m. of playspace on-site to cater for them.

51 The applicant has submitted a comprehensive landscape statement that sets out the public realm, play and recreation provision for the site. Generous communal, semi-private and

page 10 private gardens are proposed and particular attention is paid to ensuring the biodiversity and landscape qualities of the existing site are retained, with the ponds being enhanced and provided with viewing platforms. Two large local areas for play (LAP) for under-5 year olds are proposed, totalling 550 sq.m. together with a equipped space totalling 400 sq.m. for older children, which ensure compliance with the Mayor’s SPG. As noted above, a trim trail is proposed around the perimeter of the site, to cater for 12 + year olds, which is welcomed. As noted previously, it will be necessary to ensure that there is an appropriate management and maintenance regime for the public realm, and further discussion would be welcomed about the extent of the trim trail, particularly in the far south western corner.

52 The applicant’s commitments to providing a high quality residential environment is welcomed, subject to further clarification about the landscaping noted above and in paragraph 45 and 46 and the detailed design and management regime for the public realm being secured by the Council by way of condition. Access and inclusive design

53 London Plan policy 7.2 seeks to ensure that proposals achieve the highest standards of accessibility and inclusion (not just the minimum), and this and all developments should seek to better minimum access requirements. Policy 3.8 requires that all new housing is built to Lifetime Homes standards and that 10% of new housing is designed to be wheelchair accessible, or easily adaptable for residents who are wheelchair users. Design and access statements should explain the design thinking behind the application and demonstrate how the principles of inclusive design, including the specific access needs of people with disabilities, have been integrated into the proposed development and how inclusion will be maintained and managed.

54 The applicant has committed to ensuring that all of the housing is designed to exceed Lifetime Homes and detailed plans have been provided for a range of flat and house types to show how the 16 standards would be met, which is welcomed. The applicant is proposing that 29 units are allocated as wheelchair accessible, which is acceptable, however the accommodation schedule and/or plans fail to indicate these units or how they would be distributed throughout the development. As requested at pre-application stage, a proportionate amount of wheelchair accommodation should provided across the range of unit sizes and tenure types in order to ensure genuine housing choice in accordance with London Plan policies. The commensurate amount of blue badge parking, appropriately located, should also be provided, as detailed in paragraph 72 below. The accommodation schedule and typical floor plans for the wheelchair accessible units should be provided before the application is reported back at Stage 2. These details should be secured by way of condition, so as to ensure compliance with London Plan policies 3.8 and 7.2.

55 In terms of the external environment, the applicant has committed to ensuring the public realm and landscaped spaces would be accessible, and care will be required at detailed design stage to ensure these areas are step-free and easily accessible, and that resting places are provided, particularly given the slope of the site. Sustainable development

56 The London Plan climate change policies as set out in chapter 5 collectively require developments to make the fullest contribution to tackling climate change by minimising carbon dioxide emissions, adopting sustainable design and construction measures, prioritising decentralised energy supply, and incorporating renewable energy. The policies set out ways in which developers must address mitigation of, and adaptation to, the effects of climate change.

page 11 Energy – climate change mitigation

57 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.

Energy efficiency standards

58 A range of passive design features and demand reduction measures are proposed to reduce the carbon emissions of the proposed development. Both air permeability and heat loss parameters will be improved beyond the minimum backstop values required by building regulations. Another measure that is proposed is energy efficiency lighting.

59 The development is estimated to achieve a reduction of 74 tonnes per annum in regulated carbon dioxide emissions compared to a 2010 Building Regulations compliant scheme.

District heating

60 The applicant has investigated whether there are any heat networks in the vicinity of the development however, none have been identified. Nevertheless, the development will be future proofed to allow future connection of the flats.

61 A site heat network will supply the blocks of flats from a central energy centre. A drawing has been provided showing the layout of the energy centre. Given the higher heat distribution losses arising from serving individual houses, it is accepted that the houses will not be connected to the heat network.

Combined Heat and Power

62 The applicant is proposing to install gas fired CHP as the lead heat source for the heat network. A reduction in regulated carbon dioxide emissions of 47 tonnes per annum (13%) is envisaged through this second part of the energy hierarchy.

63 The applicant should confirm the electricity capacity of the plant proposed. Given the relatively small scale of this residential led development and the complexities involved in selling CHP electricity, the applicant should provide details of CHP electricity sales strategy.

Cooling

64 The applicant should provide further information on the passive measures that will be used to avoid the need for active cooling in the dwellings.

Renewable energy technologies

65 The applicant is proposing to install photovoltaic panels (PV) for the roof tops of the flats and some of the houses. The applicant should confirm the total PV panel area proposed and illustrate with drawings where the PV will be located. A total of 33 houses will use ground source heat pumps.

66 A reduction in regulated carbon dioxide emissions of 62 tonnes per annum is envisaged through this third element of the energy hierarchy.

page 12 67 In summary, the estimated regulated carbon emissions of the development are 259 tonnes of carbon dioxide per year after the cumulative effect of energy efficiency measures, CHP and renewable energy has been taken into account. This equates to a reduction of 182 tonnes per year in regulated emissions compared to a 2010 Building Regulations compliant development, equivalent to an overall saving of 41%.

Climate change adaptation

68 Policies 5.10 to 5.15 of the London Plan set out policies that seek to minimise overheating and contribute to heat island effects; minimise solar gain in summer; contribute to flood risk reduction, including applying sustainable drainage; minimising water use; and protect and enhance green infrastructure. Specific policies cover overheating, living roofs and walls and water and require the inclusion of sustainability measures within developments. Further guidance on this policy is given in the London Plan Sustainable Design and Construction SPG.

69 The applicant has submitted a sustainability statement, which includes an assessment against the Mayor’s essential standards and includes a Code for Sustainable Homes pre- assessment. The applicant states that it is intended that all homes be designed to meet Code for Sustainable Homes Level 4. The applicant’s statement sets out a number of techniques proposed to reduce energy consumption and cut carbon emission, using low energy lighting, energy efficient appliances, metering, high levels of insulation, and by maximising solar gain. Rainwater butts, together with low water use sanitary-ware and fittings will be specified in order to meet target water consumption levels. These commitments are welcomed, and should be secured by the Council as part of any planning permission that is granted. Biodiversity and trees

70 Policy 7.19 of the London Plan seeks to ensure that proposals make a positive contribution to the protection, enhancement, creation and management of biodiversity. Policy 7.21 seeks to retain existing trees of value and that any loss is appropriately replaced. The site is subject to a tree preservation order (TPO), and the applicant acknowledges that the trees, woods and ponds are a major contributor to the character of the site.

71 The Council has been involved in discussions with the applicant at pre-application stage about ensuring that the proposal does not impact significantly on the existing tree screens and individual specimens and imposed a blanket TPO across the site in order to ensure that the groups of trees and individual specimens most worthy of protection are retained in any future development. The scheme retains the woodland blocks and veteran trees as part of the proposals, and proposes improvements to the existing ponds, to increase attractiveness to wildlife.

72 Key to retaining the character of the site is retention of the ponds, major woodland areas around the perimeter and key individual species, with generous landscaping throughout the site, which will also assist in maintaining and enhancing the biodiversity values of the site. A detailed habitat survey has been carried out which reveals that whilst there is evidence of bats around the wooded areas, there do not appear to be any roosts on the site. A Great Crested Newt survey has also been carried out, which did not detect the presence of newts, but that the ponds and woodland could provide a suitable habitat. The ecological study recommends that further survey work would be appropriate, noting that they have been known to be present in the vicinity. Detailed survey work and management of these habitats will be necessary, in

page 13 consultation with Natural , in order to ensure that appropriate mitigation measures are assured during and after construction, should newts be present.

73 Concerns have previously been raised about tree canopies having the potential to impact upon gardens and light to properties and therefore being at threat in the future, and as such, careful consideration needs to be given to the management and ‘ownership’ of these areas. This of particular note along the western boundary in the area of the ‘trim trail’ and south-west corner which closely abut the private gardens. Further discussion about this aspect, particularly the management regime of the trees and these spaces is requested, and appropriately worded conditions and/or section 106 obligations would be expected in this respect.

Transport

74 The site is not within the vicinity of any Transport for London Road Networks and has a poor to moderate level of access to public transport.

Car Parking

75 A total of 272 residential parking spaces are proposed, providing a residential parking ratio of 1.13 spaces per unit. In addition, 36 visitor parking spaces are proposed. Given the number of family units proposed on this site and the relatively low PTAL, this ratio is deemed to be in accordance within London Plan parking standards. However, noting concerns about parking stress in the area, it may also be appropriate to supplement the parking levels with a car club and further discussion on such provision would be welcomed. Comments raised earlier in the design section regarding the amount of hard surfacing caused by the car parking and the provision of street trees also needs to be considered.

76 In terms of blue badge parking, the design and access statement states that 5% of the total parking provision will be allocated to disabled drivers. However, as noted at pre- application stage, policy 6.13 of the London Plan requires that that blue badge parking is provided for disabled people in line with the Lifetime Homes standards and the Mayor’s Wheelchair Accessible Housing Best Practice Guidance. As such, one bay should be provided for each wheelchair accessible flat or house (i.e 29 or 10% of the total number of residential units). These spaces should be located adjacent to the entrances where the wheelchair accessible homes are located, and should be indicated on plan.

77 Provision should also be made for electric vehicle charging points (EVCP’s) at a ratio of 20% active and 20% passive provision, as set out in the London Plan. The allocation of EVCPs must be agreed by planning condition.

78 London Plan policy 6.13 seeks to ensure that an appropriate balance is struck between promoting new development and preventing excessive car parking provision that can undermine cycling, walking and public transport use. Conformation of the above will ensure conformity with the London Plan (2011) policy 6.13.

Cycling

79 A total of 302 cycle parking spaces have been proposed however, in order to comply with standards set out in London Plan policy 6.9, a minimum of 412 spaces are required. Additional cycle parking should also be provided for public use within the public realm. Furthermore, in order to help link the site to Cockfosters and Oakwood Underground stations, a commitment to upgrading the local cycle network and crossings over the A110/A111 roundabout would be expected and should be secured through the section 106 agreement.

page 14 Walking

80 Due to concerns about the quality of the streetscape in the surrounding area, it is expected that contributions be secured through the section 106 agreement to make improvements to the paths surrounding the site in order to simplify the streetscape, de-clutter and ensure access for all. This will ensure conformity with London Plan (2011) policy 6.10.

Public transport

81 To ensure conformity with London Plan (2011) policy 6.7, a contribution of £40,000 is necessary to upgrade the four bus stops located around the site’s periphery in line with TfL’s Accessible Bus Stop Design Guidance. The applicant has been informed of the specific works that are required, and these works should be secured in the section 106 legal agreement.

82 Further discussion regarding the modelling of the Cat Hill/Chase Side junction is also required in order to identify new travel patterns arising as a result of the changing nature of vehicular trip generation from the proposed development. This may give rise to some changes to the junction layout or signal timings being necessary, and to ensure conformity with London Plan policy 6.3.

Servicing, deliveries and construction

83 A delivery servicing plan and construction management plan have been submitted, and the details provided within the transport assessment are acceptable. It is requested that both plans are formalised through appropriate planning conditions, so as to ensure conformity with London Plan policy 6.14.

Travel Plan

84 The applicant has submitted a travel plan, however it has failed TfL’s ATTrBuTe test and it is recommended that the applicant provides evidence of how the travel plan will be secured and funded in order to rectify this. A revised travel plan will need to be secured, enforced, monitored and reviewed via the section 106 agreement. It is suggested that the applicant includes a range of travel planning measures including but not limited to subsidised Oyster cards, cycle vouchers, subsidised car club membership, marketing and promotional events. This should be discussed further between TfL, the Council and the applicant, and details secured through the section 106 agreement in order to ensure conformity with London Plan (2011) policy 6.3. Local planning authority’s position

85 Enfield Council has advised that it has received a number of objections and is still to form a view over the acceptability of the scheme, but is due to report it to its planning committee in September/October 2011. Legal considerations

86 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

page 15 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

87 There are no financial considerations at this stage. Conclusion

88 London Plan policies on the principle of development, housing, affordable housing density, urban design, access, child play space, climate change, biodiversity and transport are relevant to this application. The application complies with some of these policies but not with others, for the following reasons:

 Land use: Subject to confirmation from Enfield Council that the education use is surplus to requirements, the principle of this residential development is acceptable, and in accordance with London Plan policy 3.3 and 3.17.  Housing: In the absence of an appraisal of the applicant’s financial viability report, it is not possible to establish if the affordable housing is the ‘maximum reasonable amount’, in accordance with policy 3.12 of the London Plan. Whilst the range of housing and tenure split are inconsistent with strategic planning policies, subject to the scheme meeting Enfield Council’s housing needs, the mix is acceptable. The residential quality that is proposed is also in accordance with London Plan policy 3.5.  Density: The proposed residential density is in accordance with the guidance range set out in London Plan policy 3.4 and the surrounding context supports a scheme of this form.

 Urban design: The scale, height, massing and architecture is appropriate to its context, however further discussion and clarification in relation to landscaping and management, and detailed design of the flatted blocks in order ensure that the scheme is fully in accordance with the London Plan.  Child play space: The proposal provides dedicated on-site child play space for children as part of the comprehensive landscaping and public realm proposals, thereby complying with London Plan policy 3.6.  Inclusive design and access: The applicant has committed to meeting Lifetime Homes standards, together with the provision of 10% wheelchair accessible units however, further information is required in order to be satisfied that the scheme fully accords with London Plan policies 3.8 and 7.2.  Energy – climate change mitigation: The applicant has broadly followed the energy hierarchy. Sufficient information has been provided to understand the proposals as a whole and the proposals are broadly acceptable however, further information is required before the carbon savings can be verified.

page 16  Climate change adaptation: The applicant’s commitments to climate change adaptation are welcomed, and ensure that the proposal complies with the Mayor’s Sustainable Design and Construction SPG and London Plan climate change policies.

 Biodiversity: The scheme proposes retention of significant trees on the site and biodiversity enhancement measures through its landscaping strategy, in accordance with London Plan policies 7.19 and 7.21 however key to the success of these features will be appropriate management and ‘ownership’.

 Transport: The scheme is generally acceptable in transport terms, although further information and commitments are required from the applicant in order to fully comply with the London Plan.

89 Whilst the application is broadly acceptable in strategic planning terms, on balance, the application does not fully comply with the London Plan.

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

 Housing and affordable housing: Verification of the applicant’s financial appraisal to demonstrate that the affordable housing level is the maximum reasonable amount is required, and confirmation that the tenure and mix of units meets Enfield’s housing needs.  Urban design: Further discussion is required in relation to the landscaping strategy and detailed design aspects to address concerns about biodiversity and secure by design issues, the design of the flatted blocks and the dominance of parking.  Inclusive design and accessibility: Further information is required in relation to the allocation of wheelchair units and blue badge parking spaces across the development, with typical floor plans to show the how these units would meet the Mayor’s Best Practice Guidance.  Climate change mitigation: Further information in relation to the CHP electricity sales strategy, passive cooling measures and details of PV are required, details of which should be secured by way of condition.

 Biodiversity: Further discussion and appropriately worded conditions are required in relation to the management regime for the wooded areas and trees around the site.

 Transport: Further information and amendments are required in relation to the number of cycle parking spaces, contributions towards bus stops, cycle and walking routes, and investigations into the implementation of a car club. Appropriately worded conditions and planning obligations are also required in relation to deliveries and servicing, construction management and the travel plan.

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] Samantha Wells, Case Officer 020 7983 4266 email [email protected]

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