planning report GLA/4825/01 25 September 2018 Brampton Manor , Roman Road in the Borough of Newham planning application no.18/02203/LA3

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

The proposal Full planning application for construction of a new three-storey teaching facility with sports and community facilities; a two-storey extension to the existing sixth-form, extension to the existing staffroom and library facilities, and landscaping works. The proposal also includes relocation of the seasonal athletics and track provision, MUGA and artificial pitch with flood lights.

The applicant The applicant is Brampton Manor Academy, and the architect is Rivington Street Studio.

Strategic issues summary Principle of development: The proposal results in the loss of open space; however, this is justified on balance given that the educational need, community benefits, as well as the quantitative and qualitative improvements in sports provision, clearly outweigh the loss. The proposal accords with London Plan and draft London Plan policies related to education, sports provision and open space. (paragraphs 14 to 29). Urban and inclusive design: The Council must secure details of the landscaping and key materials, and approach to inclusive design by condition (paragraphs 30 to 34). Sustainable development: A revised energy statement that demonstrates carbon savings meet the target set out within Policy 5.2 of the London Plan and Policy SI2 of the draft London Plan must be submitted. A drainage strategy that accords with policies of the London Plan and draft London Plan must be secured by condition (paragraphs 35 to 39). Transport: The applicant must reduce car parking and increase cycle parking; review and agree off-site local highway improvements for pedestrians and cyclists, and agree construction access A13 onslip interface. The Council must secure a DSP, CMP and an updated travel plan via appropriate conditions/ obligations (paragraphs 40 to 45).

Recommendation That Newham Council be advised that whilst the principle of development is acceptable, the application does not fully comply with the London Plan and draft London Plan, for the reasons set out in paragraph 49 of this report; but that the possible remedies set out in the report could address these deficiencies. The application does not need to be referred back to the Mayor if the Council resolves to refuse permission, but it must be referred back if the Council resolves to grant permission.

page 1 Context

1 On 8 August 2018 the Mayor of London received documents from Newham 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 must provide the Council with a statement setting out whether he considers that the application complies with the London Plan and draft London Plan, and his reasons for taking that view. The Mayor may also provide other comments. This report sets out information for the Mayor’s use in deciding what decision to make.

2 The application is referable under the following Categories of the Schedule to the Order 2008:

• Category 3C:”Development which is likely to prejudice the use as a playing field of more than 2 hectares of land which, (a) is used as a playing field at the time the relevant application for planning permission is made; or (b) has at any time in the five years before the making of the application been used as a playing field.”

• Category 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 floor space for a use falling within any of the following classes in the Use Classes Order—(ix) class D1 (non- residential institutions).”

3 Once Newham 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 or allow the Council to determine it itself, unless otherwise advised. In this instance if the Council resolves to refuse permission it need not refer the application back to the Mayor.

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 application site has an area of 8.3 hectares and is a designated community open space in the Council’s Local Plan. The site is located at the end of Roman Road, bordered to the North by the Greenway, to the East, by Roman Road Primary School, to the South by the A13 and to the West, Newham hospital. To the North-east of the site, the area is largely residential, with generally low scale, two-storey terraced and semi-detached dwellings ranging from Edwardian in era to post-war flats and more contemporary 3-4 storey apartment blocks.

6 The existing building arrangement on site is largely clustered to the north east and subsequently has little impact on the site’s surroundings. The ‘Greenway’ is also significantly elevated above the site, and therefore acts as a visual and acoustic buffer between the main school building and the rear gardens of the dwellings on Lonsdale Avenue. The site has nominal level changes, which again reduces the potential impact of the existing and proposed development on its surroundings.

7 The site is currently occupied by the main school building which is split across 3 levels and divided into an East & West Wing. The Sports Hall is a later addition, built in the early 2000s. Whilst a stand-alone sixth-form facility provides classrooms, study space and recreational amenities, it is currently supported/supplemented by facilities within the main building. The site is screened on much of its perimeter by mature trees, and therefore views out beyond the site are restricted. The key view being that across the playing fields to Roman Road, or from Roman Road looking towards Newham Hospital.

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Aerial view of the existing application site in context: Source – applicant’s design and access statement.

8 The site is accessed from Boundary Road, which is adjacent to Newham University Hospital and Gateway Surgical Centre. Barking Road and Prince Regent Lane form part of the Strategic Road Network (SRN), which is 2 kilometres from the site and connected to the A13 (Newham Road), which forms part of the Transport for London Road Network (TLRN). There are three bus routes and stops within walking distance of the site. The nearest London Underground station is Upton Park, approximately 1.5 kilometres to the north of the site, and the closest Docklands Light Railway (DLR) station is Custom House station, approximately 1.8 kilometres south of the site. The site records a public transport accessibility level (PTAL) of 2 on a scale of 1-6, where 6 is the highest.

Details of the proposal

9 The proposed development comprises a total floorspace of 6,352 sq.m. (GIA) for:

• Construction of a new three-storey stand-alone teaching facility with adjoining new sports hall, to accommodate 420no Year 7 pupils (which equate to an additional 4- forms of entry) and additional associated staff (5,339 sq.m. (GIA)). • A two-storey extension to the existing sixth-form provision to accommodate an additional 150 sixth-form pupils (871 sq.m. (GIA)). • Extension to the existing staffroom and library facilities within the existing courtyard of the existing main school building (142 sq.m. (GIA)). • Other works including an entrance pavilion and improvements to the Boundary Lane entrance and service road, sixth-form garden, Year 7 playground, external pupil and staff dining facilities, relocation of the seasonal athletics and track provision, MUGA and artificial pitch with flood lights, and landscaping. Case history

10 The school was constructed between 1957 and 1962. It originally operated as Brampton Girls School and had relocated from a site in East Ham. The main school building underwent a series of expansions, refurbishment and retrofit in 2010, and in 2011 the school became an Academy. The , which is of modular construction was opened in 2012. The original sports hall was later converted into the music and media suite and a new sports hall was constructed in the early 2000s.

page 3 None of the proposals were referred to the Mayor as they were below threshold in terms of areas of proposed floor space of development related to playing fields, and departure from the local plan. Strategic planning issues and relevant policies and guidance

11 For the purposes of Section 38(6) of the Planning and Compulsory Purchase Act 2004, the development plan in force for the area is the 2012 Newham Core Strategy and its 2012 UDP (saved policies), and the 2016 London Plan (consolidated with Alterations since 2011).

12 The following are relevant material considerations:

• The Revised National Planning Policy Framework (July 2018), and National Planning Practice Guidance. • Draft London Plan (consultation draft December 2017), which should be taken into account on the basis explained in the NPPF, including minor amendments published in August 2018. • The Newham Strategic Leisure Facilities Needs Assessment (2017). • The Newham Playing Pitch Strategy (2017).

13 The relevant issues and corresponding policies are as follows:

• Education London Plan; Social Infrastructure SPG; • Open space London Plan; • Playing fields London Plan; • Community use London Plan; • Urban design London Plan; • Access London Plan; Accessible London: achieving an inclusive environment; • Sustainable development London Plan; Sustainable Design and Construction SPG; London Environment Strategy; • Transport London Plan; the Mayor’s Transport Strategy; Principle of development – education and open space

14 Brampton Manor Academy is a ten-form entry (FE) and sixth form. The proposal is to increase the pupil intake by four forms of entry to 14FE to mitigate the forecasted demand on secondary school places in the .

15 Paragraph 94 of the revised National Planning Policy Framework and Government Policy Statement on Planning for Schools Development (2011) emphasise that great importance should be attached to the delivery of a sufficient choice of school places to meet the needs of existing and new communities. London Plan Policy 3.18 and draft London Plan Policy S3 confirm that the Mayor strongly supports the provision of new schools in response to identified local need. These policies also encourage the shared use of services between schools, colleges, universities, sports providers, and community facilities.

Partial loss of open space/ playing fields

16 Policy 7.18 of the London Plan and Policy G4 of the draft London Plan stress that the loss of protected open spaces must be resisted in areas of deficiency, unless equivalent or better-quality provision is made within the local catchment area. Replacement of one type of open space with another is unacceptable unless an up to date needs assessment shows that this would be appropriate.

page 4 17 Policy 3.19 of the London Plan sets out that those proposals that increase or enhance the provision of sports and recreation facilities will be supported; whereas those that result in a net loss of sports and recreation facilities, including playing fields should be resisted. Policy S5 of the draft London Plan goes on to state that where sports facilities are proposed on existing open space, boroughs should consider these in light of policies on protecting open space and the borough’s own assessment of needs and opportunities for sports facilities, and the potential impact that the development will have.

18 Paragraph 97 of the revised NPPF states ‘Existing open space, sports and recreational buildings and land, including playing fields, should not be built on unless:

a) an assessment has been undertaken which has clearly shown the open space, buildings or land to be surplus to requirements; or

b) the loss resulting from the proposed development would be replaced by equivalent or better provision in terms of quantity and quality in a suitable location; or

c) the development is for alternative sports and recreational provision, the benefits of which clearly outweigh the loss of the current or former use.’

19 The proposed development would result in the loss of approximately 0.7 hectares of the existing playing fields, which would be reduced from 5.3 hectares to 4.6 hectares (i.e. a 13% reduction). As set out above, national and London Plan policies seek to resist the loss of open space and playing fields. There are a number of factors which could justify the loss, however, which are set out below.

Educational need

20 London Plan Policy 3.16 and draft London Plan Policy S1 identify that additional and enhanced social infrastructure provision, including schools, is required to meet the needs of London’s growing and diverse population. London Plan Policy 3.18 and draft London Plan Policy S3 both seek to ensure a sufficient supply of good quality educational choice to meet the demands of a growing population and enable local communities.

21 The proposed development will result in the expansion of the school from 10FE to 14FE for years 7 to 11 with an increase in capacity from 1,500 students to 2,100, providing all necessary spaces and functions for the curriculum. It also results in consolidation of accommodation for years 12 and 13 (6th Form), and will provide high quality class rooms, enlarged library and staff rooms, and variety of formal/informal external student spaces.

22 In its application documents, the applicant has set out that the current design has come about through detailed feasibility analysis which considered refurbishment of the main school but found that the new build option for the Year 7 facility was the only feasible option to provide the required facilities and ease pressure on the existing school. The proposal sets out that a separate Year 7 building would mitigate the overcrowding of the main building, whilst easing pupils’ transition from smaller primary settings to a larger secondary school. The increased pupil intake requires additional sports, assembly and examination space, which are arranged on site to provide access to the whole school as well as being accessible by the community for out-of-hours use. The sixth form extension would consolidate the sixth form provision, again alleviating pressure on pupil numbers in the main school building.

23 Having regard to the applicant’s assessment, it is acknowledged that the proposed development is required to address the shortage in school places in East London. Therefore, the proposal is supported in terms of educational need.

page 5 Lack of alternative options/sites

24 The applicant has considered seven alternative site arrangement options within the Academy, which were thoroughly assessed against their size, suitability for the school’s educational needs and operational requirements, deliverability, affordability and planning constraints. The assessment demonstrated that the other six options were discounted for operational and feasibility reasons, and the current site arrangement represented the best option in terms of scale, the operation of the school and the opportunity for community benefits.

Enhancement of sports provision and community use

25 Whilst the proposals would lead to the loss of playing fields in terms of area, the proposals seek to enhance the quality and diversity of sports provision at the school. A table of comparison of the gains or losses of existing and proposed sports and playing fields provisions is set below:

26 As set out above, the proposals would result in the gain of a sports hall, gym and fitness studio and either no change or a gain in outdoor sports provision, with the exception of the existing non-regulation grass athletics track which would be replaced by a 100-metre grass sprint straight. Additionally, there would be qualitative improvements to existing sports provision from the relocation and resurfacing of pitches and courts.

27 Given the expansion and enhancement of sporting provision, it is considered that the proposals could meet Sport England’s Exceptions Test 5 for the loss of playing fields, namely that ‘the proposed development is for an indoor or outdoor facility for sport, the provision of which would be of sufficient benefit to the development of sport as to outweigh the detriment caused by the loss, or prejudice to the use, of the area of playing field’. Sport England would need to confirm this position. However, from GLA officers’ perspective, the significant enhancement of sports provision on the site outweighs the harm from the loss of 0.7 hectares of playing field.

page 6 28 In addition, the proposals have been designed to allow enhanced community use and access to the ground floor elements of the existing and proposed school development, in particular the new sports hall and the playing fields. There will be an increase of 17 hours per week availability in term time and 29 hours per week in the school holidays and weekends, for the new sports hall, the fitness facility, the dance/fitness studio, the two MUGAs and the athletics field event facilities. Whilst the enhanced community use and access to existing and newly provided sports facilities, and the proposed draft community use agreement are welcomed, further active engagement with Sport England and local sports communities is recommended to ensure that the community use agreement meets expected demands. Details of the community use arrangements would be expected to come forward prior to approval and secured by s106 planning agreement. This must include arrangements for affordable and accessible usage of the sports facilities in consultation with Sport England.

Conclusion on principle of development

29 The provision of educational facilities on a site already in education use is supported in principle. Having considered the quantitative loss of open space resulting from the development, the justification in terms of educational need, the quantitative and qualitative improvements in sports provision, and community benefits clearly outweighs the loss. As such, the proposal is supported in principle and is in accordance with London Plan and draft London Plan policies related to open space, sports facilities and education use.

Urban design

30 Good design is central to all objectives of the London Plan and draft London Plan and is specifically promoted by the policies contained within Chapter 7 of the London Plan, which address both general design principles and specific design issues.

31 Layout and massing: The broad layout principle of containing the majority of development towards the western boundary of the site (reducing its visual impact on openness and neighbouring residents, and where flooding is at a lower risk), is supported. The scale and massing of the year 7 and sports building responds to the arrangement of the site falling away to the North and South- east to reduce the visual impact of the new development. The three-storey height is also broadly consistent with the surrounding character of the site and is therefore supported. The simple plan form of the school is welcomed and is designed to meet Building Bulletin design guidance. The intention to cluster classrooms, recreation and teaching spaces around the courtyard ‘hub’ is strongly supported and will help to foster a sense of community as well as passive surveillance.

32 Architecture and use of materials: The simple architectural approach is welcomed, and the Council is encouraged to secure key details of window reveals, parapets and facing materials to ensure the highest possible build quality is delivered. The use of render should be minimised as far as feasible and its colour/tone and quality carefully considered to avoid staining and weathering over time and ensure ease of maintenance. This must be secured by a condition relating to submission of materials and architectural details.

33 Fire safety: In accordance with Policy D11 of the draft London Plan, the Council and the applicant have agreed to secure an Informative requiring the submission of a fire statement, produced by a third party suitable qualified assessor. Inclusive design

34 Policy D3 ‘Inclusive design’ of the draft London Plan and Policy 7.2 of the London Plan seek to ensure that proposals achieve the highest standards of accessible and inclusive design (not just the minimum). The proposed new teaching facilities, sports hall and extensions will offer a fully inclusive access to all users. However, the Council must ensure and secure the provision of Blue-

page 7 badge parking on the existing car park in line with the London Plan and draft London Plan; 5% of parking spaces should be designated and suitable for use by disabled people with a further 5% provided as enlarged spaces. Sustainable development

Energy

35 The applicant has submitted energy and sustainability statement. However, they have not provided the carbon emissions for each stage of the energy hierarchy and the BRUKL files. Further information on the PV, overheating and the cooling demand is required. The applicant must submit a revised energy statement and the carbon dioxide savings must meet the target set out within Policy 5.2 of the London Plan and Policy SI2 of the draft London Plan. As it stands, the application does not comply with these energy policies of the London Plan and draft London Plan. Full details of the comments have been provided directly to the applicant and Council.

Flood risk, sustainable drainage and water efficiency

36 The flood risk assessment demonstrates that the proposed teaching facilities and extensions lie in the western part of the site within Flood Zone 1, which is at low risk of flooding, though it is noted that the south-east corner of the school site is located within Flood Zones 2 and 3, where no built development is proposed, though it is an area benefiting from River Thames tidal defences.

37 Flood risk: The approach to flood risk management for the proposed development complies with London Plan Policy 5.12 (and draft London Plan Policy SI.12). The flood risk assessment provides a Sequential Test and Exception Test for the development, as required by the NPPF. The Sequential Test notes that the use of the proposed buildings is suitable in Flood Zone 1.

38 Sustainable drainage: The surface water drainage strategy addresses the drainage hierarchy, however, it does not comply with London Plan Policy 5.13 (and draft London Plan Policy SI.13), as the option to discharge to sewer if infiltration is not feasible does not adequately consider greenfield runoff rate. Further details on how greenfield runoff rate will be achieved should be provided. Additional attenuation storage discharge and volume calculations, and attenuation tank dimensions should also be provided.

39 Water efficiency: A BREEAM pre-assessment has been provided for the proposed development. This shows an intent to reduce water consumption by 25%. Additional effort should be made, including considering water reuse in conjunction with the sustainable drainage strategy, to better this reduction to 40% and better meet the intent of draft London Plan Policy SI.5. Transport

40 It is considered that this proposal will have an impact on the bus network, however given the range of routes within an acceptable walking distance of the school, in this instance no contributions will be sought. The application material does not provide details on the existing quality of walking routes to and from the school, where the catchment area may include sites to the south of the A13 as well as to the north of the ‘Greenway’ where improvements are proposed. There is likely to be a significant increase and pedestrian and cycling trips on the local highway network where any amendments identified should be secured through an appropriate legal mechanism.

41 There is an existing car park with 110 vehicle parking spaces, and while this provision is not proposed to be increased the parking ratio would nonetheless be almost 1 space for every two staff. Whilst the London Plan and draft London Plan do not have standards for educational car parking, the applicant should set out how car parking can be reduced, alongside an increase in cycle parking.

page 8 To comply with London Plan and draft London Plan standards on Blue-badge parking, 5% of parking spaces should be designated and suitable for use by disabled people with a further 5% provided as enlarged spaces. A proportion of parking spaces should be equipped with active electric vehicle charging points and passive provision. Both these must be secured by condition. A delivery and servicing plan (DSP) must also be secured by condition.

42 There are 120 cycle parking spaces on site currently and 40 more covered spaces are proposed, however, to meet draft London Plan standards 387 student spaces and 31 staff spaces should be provided. The travel plan shows that the school already has a high cycling mode share, a reflection of the nature and location of the school including its proximity to local cycling infrastructure such as ‘The Greenway’. The location of additional cycle parking spaces should be confirmed at this stage, such as in place of car parking, and the details must be secured by condition.

43 A construction management plan (CMP) has been produced. The CMP sets out that an agreement has been reached with Newham Council to allow access for construction purposes only via a haul route last used for the adjacent hospital development, accessed from eastbound onslip to the A13, which forms part of the TLRN. This access would reduce impact on the local highway network in the vicinity of the school, however further discussion is needed with TfL before the acceptability of this proposal can be confirmed, given the existing A13 network conditions and to ensure safety and capacity measures are addressed.

44 There is an existing school travel plan and updates to this plan should be secured, managed, monitored and enforced through the S106 agreement and encourage further growth in the number of pupils and staff walking or cycling to school, and to minimise impact on bus network. To back up the travel plan, to manage potential conflicts arising from a large number of people travelling to and from the site and to spread the demand to travel across a longer period a school management plan must also be secured by condition.

Summary

45 In summary, the applicant must address the following issues to ensure compliance with the transport policies of the London Plan and draft London Plan:

• Reduce car parking; • Increase cycle parking in accordance with draft London Plan and the MTS; • Review and agree off-site local highway improvements for pedestrians and cyclists; • Agree construction access A13 onslip interface, and • Secure a DSP, CMP and an amended travel plan via appropriate conditions/ obligations. Local planning authority’s position

46 The Council’s planning officers have confirmed that they are recommending approval at the Council’s planning committee meeting of 9 October 2018. Legal considerations

47 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 draft 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

page 9 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. 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

48 There are no financial considerations at this stage. Conclusion

49 London Plan and draft London Plan policies on education, open space, sports facilities and community use, urban and inclusive design, sustainable development and transport are the key strategic issues relevant to this planning application. Whilst acceptable in principle, the application does not comply with the London Plan and draft London Plan; the following changes could lead to the application becoming compliant:

• Principle of development: The proposal results in the loss of open space; however, this is justified on balance given that the educational need, community benefits, as well as the quantitative and qualitative improvements in sports provision, clearly outweigh the loss. The proposal accords with London Plan and draft London Plan policies related to education, sports provision and open space.

• Sports facilities and community use: A detailed community use agreement for affordable and accessible usage of the sports and school facilities must be secured by way of s106 planning agreement.

• Urban and inclusive design: The Council must secure details of the landscaping and key materials, and approach to inclusive design by condition.

• Sustainable development: A revised energy statement that demonstrates carbon savings meet the target set out within Policy 5.2 of the London Plan and Policy SI2 of the draft London Plan must be submitted. A drainage strategy that accords with policies of the London Plan and draft London Plan must be secured by condition.

• Transport: The applicant must reduce car parking and increase cycle parking; review and agree off-site local highway improvements for pedestrians and cyclists, and agree construction access A13 onslip interface. The Council must secure a DSP, CMP and an updated travel plan via appropriate conditions/ obligations.

For further information contact the GLA Planning Team: Juliemma McLoughlin, Chief Planner 020 7983 4271 email: [email protected] John Finlayson, Head of Development Management 020 7084 2632 email: [email protected] Katherine Wood, Team Leader – Development Management 020 7983 5743 email: [email protected] Tefera Tibebe, Strategic Planner, Case Officer 020 7983 4312 email: [email protected]

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