St Helier Hospital, Carshalton London Borough of Sutton Planning Application No

Home , Carshalton, London Borough of Sutton

planning report 2571/02 19 March 2010 St Helier Hospital, Carshalton London Borough of Sutton Planning application no. C2009/62093/OUT

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

The proposal Outline application for demolition of Ferguson House & adjoining nursery building, to determine access, layout and scale, for the erection of a new building comprising 24,600 sq.m. gross floor space to provide replacement hospital wards, out-patient accommodation and a local care centre.

Erection of a separate multi-deck car park for 560 cars and an additional 267 surface car parking spaces (total 827 spaces), the formation of internal roads and pedestrian routes and associated landscaping.

The applicant The applicant is the Epson and St Helier University Hospitals NHS Trust and the architect is Pirie Russell Associates.

Strategic issues Issues raised previously relating to design, access and inclusion, transport and energy have been addressed through provision of further information and, where appropriate, the use of planning conditions and/or the section 106 agreement.

Recommendation That Sutton Council be advised that the Mayor is content for it to determine the case itself, subject to any action that the Secretary of State may take, and does not therefore wish to direct refusal or direct that he is to be the local planning authority.

Context

• “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”

page 1 • “Development which comprises or includes the erection of a building of one or more of the following descriptions— (c) the building is more than 30 metres high and is outside the City of London”.

• “Development for a use, other than residential use, which includes the provision of more than 200 car parking spaces in connection with that use”.

2 On 2 February the Mayor considered planning report PDU/257a1/01, and subsequently advised Sutton Council that the application did not fully comply with the London Plan, for the reasons set out in paragraph 58 of the above-mentioned report; but that the possible remedies set out in paragraph 59 of that report could address these deficiencies.

3 A copy of the above-mentioned report is attached. The essentials of the case with regard to the proposal, the site, case history, strategic planning issues and relevant policies and guidance are as set out therein, unless otherwise stated in this report. On 10 March 2010 Sutton Council decided that it was minded to grant planning permission for the application, and on 15 March 2010 it advised the Mayor of this decision. Under the provisions of Article 5 of the Town & Country Planning (Mayor of London) Order 2008 the Mayor may allow the draft decision to proceed unchanged, direct Sutton Council under Article 6 to refuse the application or issue a direction to Sutton Council under Article 7 that he is to act as the Local Planning Authority for the purposes of determining the application and any connected application. The Mayor has until 28 March 2010 to notify the Council of his decision and to issue any direction.

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

Update

5 At the consultation stage Sutton Council was advised that the application did not fully comply with the London Plan; but that the following possible remedies could address these deficiencies:

• Urban design: further information should be provided in relation to the proposed car park design, the siting of the proposals and the proposed ‘phase 2’ development. • Access and inclusion: further information should be provided on how the proposals will meet the highest standards of inclusion and the applicant should ensure ongoing use of a specialist access consultant for the detailed design stage. A planning condition should secure this. • Climate change mitigation and adaptation: further information is required in relation to the proposed energy centre, the use of biofuel CHP and an alternative energy strategy should also be developed. Further information is also required on the sustainability elements. The energy strategy will need to be secured through the section 106 agreement and/or appropriate planning conditions. • Transport: further information is required in relation to transport assessment, bus trip analysis, the highways modelling, the low level of cycle parking, servicing and construction management and the need to agree and appropriate level transport mitigation where deemed necessary. 6 Due to the outline nature of the proposals and the urgent timescales to secure NHS funding, the application has not been significantly revised since the consultation stage. However, further clarification has been provided and planning conditions have been applied where appropriate to address concerns. Paragraphs 7 to 18 below set out how the issues have been addressed.

page 2 Urban design

7 The applicant has confirmed that the siting of the multi-storey car park has been dictated by a number of physical constraints on the site, including power lines and the need to ensure adequate spacing between buildings. Further information has also been provided in relation to the proposed use of gabion blocks at the ground floor level of the multi-storey car park, which will be set back from the pedestrian pathway by a 5-10 metre strip of landscaping. The landscaping strategy and proposed use materials have been secured by planning condition. The applicant has also provided confirmation that there is no proposed future development on the site.

8 As such, the urban design issues have been suitably resolved.

Access and inclusion

9 The applicant has clarified the procedures it intends to use to ensure that the final development meets the highest levels of accessibility and inclusion, including the use of an Access, Equality and Diversity Committee, with representatives from LINks (Local Involvement Networks). In addition, a planning condition has been attached to the draft planning permission to ensure that access and inclusion issues are appropriately addressed as the detailed design of the proposal progresses:

“Prior to the commencement of development an Access Strategy, carried out by a suitably qualified access consultant, showing how the principles of inclusive design, including the specific needs of disabled people, have been integrated into the proposed development, and how inclusion will be maintained and managed shall be submitted to and approved by the Local Planning Authority

REASON: To ensure that the needs of disabled people are integrated into the development.”

10 As such, the access and inclusion issues have been suitably addressed in line with London Plan policy 4B.5. Climate change mitigation and adaptation

11 The applicant has provided further information relating to the energy strategy. This confirms that the energy efficiency measures would reduce carbon dioxide by 12% compared with baseline emissions, with the proposed use of a Biodiesel Combined Cooling Heat and Power (CCHP) to reduce carbon dioxide emissions by a further 55%. The cooling would be delivered through chilled beams and supplied partly by a 200 kW absorption chiller heated by the CHP engine. The existing buildings heating and domestic hot water system is based upon a steam system and this system would be upgraded at a later date so that it can also be supplied by the new energy centre.

12 Should the biomass CCHP for any reason not become a viable solution, an alternative ‘back-up’ energy strategy has been proposed comprising natural gas fired CCHP instead of biodiesel, with 140 sq.m. of photovoltaic panels to contribute towards the renewable energy carbon dioxide reduction target. Given the outline nature of the proposals, the following condition has been applied to secure the detail of the energy strategy:

“A heat network supplying the heat loads in the development shall be installed and sized to the space heating and hot water requirements, and shall have the following characteristics:

• It shall be operational prior to the occupation of the development and shall thereafter serve all heat loads. • It should be supplied with heat from either:

page 3 o combined heat and power system sized to the average combined heating and hot water load supplemented by condensing gas top-up boilers OR o an external district heating network OR o a combination of the two options above.”

13 As such, the climate change mitigation and adaptation elements have been satisfactorily resolved in line with London Plan policies 4A.5, 4A.6 and 4A.7. Transport

14 Transport for London’s (TfL’s) initial comments in relation to this application were set out within the GLA Stage 1 Report dated 2nd February 2010. Supplementary information was received on 17 February 2010.

15 TfL welcomes the submission of a full supplementary transport assessment. Further analysis has now been undertaken in relation to the number of additional bus trips generated as a result of these proposals. This illustrates that the increase in bus trips is expected to be minimal, in addition there appears to be sufficient spare capacity on existing bus services, at this point to adequately absorb the forecast demand. However, the condition of the existing bus stops on Wrythe Lane requires improvement and the applicant has agreed to a £7,000 contribution to address this, this is welcomed.

16 Further to consultation stage the applicant has agreed to increase the number of cycle parking spaces on the site to a total of 250 by providing additional cycle parking stands within the ground floor of the multi-storey car park. While this falls short of the 501 spaces required by London Plan standards, this doubles the level of provision original offer and is welcome. The applicant has also agreed to monitor and regularly review demand for cycle parking using the travel plan and an appropriate planning condition has been applied to ensure an additional 200 cycle parking spaces are delivered (making a total on site of 250 spaces) prior to the occupation of the development, and to agree the details of the layout and type of stands/racks and security measures.

17 As stated at consultation stage it is TfL’s view that further work is required in relation to highways modelling and in particular signal timings. This has been further discussed with both the applicant and the council and it has been agreed that all these issues can be satisfactorily resolved and will be addressed post planning approval as part of the Section 278 agreement. The council has agreed to include an appropriate planning condition requiring prior to implementation a detailed design of the access and crossings to be submitted to and agreed by the Local Planning Authority in consultation with TfL. An additional condition has will also be secured not to open the car park prior to the signals having been implemented.

18 A construction and logistics plan and a delivery and servicing plan have also been secured by planning condition.

19 As such, the proposals are now acceptable in transport terms.

Response to consultation

20 The application was advertised by site and press notices and consultation letters, which were sent to 281 neighbouring properties. No objections have been received in response to this consultation. Other statutory consultees responded as follows:

• English Heritage: no objection subject to the use of conditions..

page 4 • Thames Water: no objection subject to the use of conditions.

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

21 Under Article 7 of the Order the Mayor could take over this application provided the policy tests set out in that Article are met. In this instance the Council has resolved to grant permission with conditions and a planning obligation which satisfactorily addresses that matters raised at stage I, therefore there is no sound planning reason for the Mayor to take over this application. Legal considerations

22 Under the arrangements set out in Article 5 of the Town and Country Planning (Mayor of London) Order 2008 the Mayor has the power under Article 6 to direct the local planning authority to refuse permission for a planning application referred to him under Article 4 of the Order. He also has the power to issue a direction under Article 7 that he is to act as the local planning authority for the purpose of determining the application and any connected application. The Mayor may also leave the decision to the local authority. In directing refusal the Mayor must have regard to the matters set out in Article 6(2) of the Order, including the principal purposes of the Greater London Authority, the effect on health and sustainable development, national policies and international obligations, regional planning guidance, and the use of the River Thames. The Mayor may direct refusal if he considers that to grant permission would be contrary to good strategic planning in Greater London. If he decides to direct refusal, the Mayor must set out his reasons, and the local planning authority must issue these with the refusal notice. If the Mayor decides to direct that he is to be the local planning authority, he must have regard to the matters set out in Article 7(3) and set out his reasons in the direction. The Mayor must also have regard to the guidance set out in GOL circular 1/2008 when deciding whether or not to issue a direction under Articles 6 or 7. Financial considerations

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

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

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

26 The issues raised at the consultation stage relating to urban design, access and inclusion, transport and energy matters have now been adequately addressed through the submission of further information and use of planning conditions and/or the section 106 agreement.

page 5

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] Shelley Gould, Case Officer 020 7983 4803 email [email protected]

page 6

planning report 2571/01 2 February 2010 St Helier Hospital, Carshalton London Borough of Sutton Planning application no. C2009/62093/OUT

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 applicant The applicant is the Epson and St Helier University Hospitals NHS Trust and the architect is Pirie Russell Associates.

Strategic issues The principle of the redevelopment of part of the hospital site for continued healthcare uses is acceptable, however, the outline nature of the application hinders determination with strategic planning policy.

The proposed design of the scheme is generally acceptable subject to further information. The inclusive access elements of the proposals require clarification. Further information is required in relation to the energy strategy, sustainability and transport matters. The use of planning conditions or section 106 agreement is also required.

Recommendation

That Sutton Council be advised that while the application is generally acceptable in strategic planning terms the application does not comply with the London Plan, for the reasons set out in paragraph 58 of this report; but that the possible remedies set out in paragraph 59 of this report could address these deficiencies.

page 7 Context

1 On 30 December 2009 the Mayor of London received documents from Sutton 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 9 February 2009 to provide the Council with a statement setting out whether he considers that the application complies with the London Plan, and his reasons for taking that view. The Mayor may also provide other comments. This report sets out information for the Mayor’s use in deciding what decision to make.

2 The application is referable under categories 1B, 1C and 3F of the Schedule to the Order 2008, as follows:

• “Development which comprises or includes the erection of a building of one or more of the following descriptions— (c) the building is more than 30 metres high and is outside the City of London”.

• “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 Sutton 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 St Helier Hospital occupies an area of 5.78 hectares at the heart of the wider St Helier Estate which was developed between 1928 and 1936 by the London County Council, with the hospital opening in 1938. The application site itself is 4.2 hectares, is irregular in shape and has a 390 metre frontage to the south west side of Wrythe Lane and a rear boundary adjacent to Greenshaw Wood open space. The north west boundary abuts a green link and footpath between Wrythe Lane and Greenshaw Wood while the south east boundary joins the rear gardens of houses in Westminster Road. Greenshaw Wood is a site of interest for nature conservation and the open spaces to the east and west are designed as metropolitan open land.

6 The St Helier Hospital is a general hospital with 521 beds which provides a comprehensive range of diagnostic facilities, a 24-hour Accident and Emergency department dealing with 80,000 attendances per year and a range of outpatient facilities. It is also the host site for Queen Mary’s Hospital for Children. The hospital is currently accommodated within eight separate hospital buildings ranging in size and height from two to six storeys with white rendered finish and flat roofs. These are linked together by narrow service roads and underground tunnels.

7 The accommodation at the St Helier Hospital has fallen behind modern standards with inadequate provision for disabled access, a lack of single rooms and a lack single sex accommodation. There is a backlog of maintenance due to a series of postponed or failed plans to replace the buildings and as such the facilities are inadequate and in need of modernisation.

page 8 8 The nearest part of the Transport for London Road Network (TLRN) is the junction of the A217 Reigate Avenue and the A297 Helier Avenue approximately 600 metres north west of the site. The site has a public transport accessibility level (PTAL) of 2, on a scale of 1 to 6 where 6 is most accessible. Four bus services serve the hospital directly 151, 157, S1, and S4. In addition the hospital operates a shuttle bus service between hospitals in St Helier, Sutton and Epsom

Figure 1: Ariel view of St Helier’s Hospital (source: Design and Access Statement)

Details of the proposal and scope of the application

9 The application is for the demolition of Ferguson House and the adjoining nursery building and outline planning permission is sought to determine access, layout and scale (appearance and landscaping are to be reserved matters) for the erection of a new building of 24,600 sq.m. gross floor space, built to a maximum height of 22.4 metres (with the combined heat and power flue rising to a maximum height of 37.4 metres) to provide:

• A new acute care facility (comprising 7 general medical wards, 4 general surgical wards, a stroke ward, a cardiology ward, out-patients, pharmacy and energy centre).

• Local care centre (comprising GP surgery, out-patient facilities, X-ray, ultrasound and ECG, audiology, mental health facilities, occupational therapy and coffee shop).

10 A separate 6-storey multi-deck car park for 560 cars (built to a maximum height of 22.3 metres) together with 267 surface car parking spaces (total car parking provision 827 spaces) is also proposed, along with the formation of internal roads and pedestrian routes and associated landscaping. Major refurbishment works are also planned within the main hospital building but aside from some alterations to access arrangements, these works fall outside the scope of the current application.

page 9 Figure 2: The proposed redevelopment (source: Design and Access Statement)

11 The proposals for improved acute care facilities and the provision of a local care centre at the St Helier Hospital are a response to the NHS ‘Better Healthcare Closer to Home’ (BHCH) programme, which aims to provide modern, integrated and better quality healthcare services to allow patients to be treated closer to where they live. This requires the provision of new accommodation that is fit for the delivery of modern healthcare and a new model of care based on a network of local and intermediate care services. It is intended that the proposals will be funded through a scheme called ‘public dividend capital’ which is funding allocated by central Government. The NHS London approved an outline business case for the proposed redevelopment in June 2009, but the Department of Health requires outline planning permission before it will allow a full business case to be progressed for the proposed works. The applicant has noted that the outline nature of the application is necessary to allow for a bidding process at the detailed design stage, should funding be approved.

12 However, given the strategic importance of the proposals, the sensitive location of the site and the lengthy timescales within which this project has been conceived (initial discussions began in 2006) the outline scope of the application is disappointing. The lack of information on the current application and in relation to future proposed ‘Phase 2’ of the redevelopment hinders determination against strategic planning policy. The Mayor is not a statutory consultee on reserved matters applications and as such, this report raises the full range of issues that would usually be included within a stage 1 report. Case history

13 Limited informal discussions for the redevelopment of the St Helier Hospital site were originally held in 2006, although no application was lodged as a result of these discussions. No further pre- application discussions have taken place between the applicant and GLA officers and the current proposals vary substantially from those originally discussed.

page 10 Strategic planning issues and relevant policies and guidance

• Health & community facilities London Plan • Urban design London Plan; PPS1 • 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) • Climate change London Plan; PPS1, PPS3; PPG13; PPS22; the Mayor’s Energy Strategy; Sustainable Design and Construction SPG • Transport London Plan; the Mayor’s Transport Strategy; PPG1

14 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 Sutton Core Planning Strategy (2009), the Sutton UDP and the London Plan (Consolidated with Alterations since 2004). The draft replacement London Plan (2009) and the Sutton Site Development Policies Document (Preferred Options 2009) is also a material planning consideration in the determination of planning applications. Healthcare, community facility and the principle of the development

15 Sutton Council’s adopted Core Policy BP5 ‘Improving Health and Well Being’ sets out that the Council will support the development of a Local Acute Hospital at the St Helier Hospital site. The Sutton Council Site Development Policies Document (Preferred Options 2009) also identifies the St Helier Hospital site for ongoing healthcare uses and sets out that the board of the Epsom and St Helier University Hospitals NHS Trust is planning a major redevelopment and refurbishment of St Helier Hospital site to provide more bed spaces, more acute beds and a local care centre.

16 London Plan policies 3A.20 ‘Health objectives’, 3A.21 ‘Locations for health care’ and 3A.22 ‘Medical excellence’, support the provision of healthcare facilities across London as identified by the Strategic Health Authority and primary care trusts. Policy 3A.18 ‘Protection and enhancement of social infrastructure and community facilities’ and 3A.20 ‘Health Objectives’ of the London Plan seek to identify and address the needs of London’s diverse population, providing social infrastructure and community facilities wherever possible and encouraging the improvement of health of the local population and the reduction of health inequalities.

17 The draft replacement London Plan (October 2009) also includes policies to support the provision of high quality healthcare facilities in areas of identified need, particularly in places with accessibility by public transport, cycling and walking (Policy 3.18 Healthcare facilities).

18 The applicant has provided information setting out the need for the proposed redevelopment in the context of the wider changes to healthcare provision by the Sutton and Merton PCT. As the proposed local care centre will be part of an improved provision to serve the catchments of both Sutton and Merton, this location is suitable in terms of public transport access and service need. As such, the principle of re-providing and enhancing the healthcare facilities on a site that is already in healthcare use is compliant with both existing and emerging strategic planning policy. Urban design

19 Good design is central to all objectives of the London Plan and is specifically promoted by the policies contained within Chapter 4B which address both general design principles and specific design issues. London Plan Policy 4B.1 sets out a series of overarching design principles for development in London. Other design polices in this chapter and elsewhere in the London Plan include specific design requirements relating to maximising the potential of sites, the quality of new housing provision, tall and large-scale buildings, built heritage, views, and the Blue Ribbon

page 11 Network. The draft replacement London Plan reinforces these principles, with new development required to have regard to its context, and reinforce or enhance the character, legibility and permeability of the neighbourhood (policy 7.1).

20 The original buildings within the existing hospital complex share a common design theme, coming together to represent a form that is recognisably institutional. It is also an imposing and visible landmark. While this may be attractive from an architectural perspective, it does not tend to accord with the architectural aspirations of modern NHS trusts. The aim for the new build is therefore to create accessible and flexible buildings that assist in the functional requirements of the hospital.

21 The site is constrained by the presence of two areas of metropolitan open land (MOL) to the east and the west of the site. The area of the site where the new buildings are proposed is the narrowest area of the hospital site, where the two MOL areas are closest together; the existing open car park enables visual and ecological links between these two Green Chain areas. The new plan allows for east-west permeability through the site and this is welcomed, as it will enable physical and visual links between the two areas of MOL to be retained, however restricted. To assist biodiversity, the landscaping plan should aim to make these corridors as attractive as possible. Further detail should also be provided on the proposed Phase 2 development, which looks to infill the area of space currently proposed between the two new built elements.

22 The present buildings have a strong impact on views from the MOL, being relatively isolated from surrounding development, and of significant scale. The new buildings will continue this theme and will extend the built form of the hospital closer to the residential area to the north. Although the aforementioned permeability corridors within the site will assist in linking the two areas of MOL, the only retained unobstructed corridor will be the reservation under the high- tension power lines to the north of the site. The preferred approach would have been to consolidate the envelope of the existing buildings rather than expanding across the site, however, it is accepted that this is not operationally possible.

23 The location and proposed treatment of the multi-storey car park, which will be removed from the cluster of existing and new hospital buildings (although it will be linked by the future building in phase 2). Although the elevational treatment proposals within this scheme are only indicative (as appearance is a reserved matter of this outline application), multi-storey car parks are generally unattractive and unsympathetic to their surroundings in the majority of cases. It is accepted that the multi-storey car park is necessary to maintain parking provision and free up existing parking areas for the redevelopment. However, officers have reservations regarding the current design case for the car park, and the proposed appearance of this and the other new building, based on the limited material submitted to date.

24 Although the existing Ferguson House contributes little to the immediate surroundings, it has a useful role in aiding the setting of the hospital as a whole. The case made for the demolition is limited, and appears to be based on functional rather than design reasons. There would be no objection to its demolition, provided a replacement building of similar of higher quality and contribution would be built. The images provided within the design and access statement indicate an interesting design approach that would set the building apart from the other buildings on the site, but again without detailed information on the appearance of the building it is difficult to determine whether this is the correct response. However, the intention to make the building subordinate to the existing buildings, in terms of height and massing, is supported.

25 The ultimate appearance of the building should incorporate features to demonstrate to visitors its importance as the main entrance to the hospital, making it an obvious destination from the

page 12 street and car park. Elevational treatment around the plant room at ground floor level should seek to interact with its surroundings and avoid problems associated with inactive frontages.

26 Officers support the design aspirations for the new building’s internal area, which seek to make the building welcoming and flexible but the applicant is recommended to consult the findings of CABE’s report relating to the design of primary healthcare buildings (http://www.cabe.org.uk/publications/assessing-design-quality-in-lift). Access and inclusion

27 London Plan policy 4B.5 ‘Creating an inclusive environment’ sets out that development should meet the highest standards of accessibility and inclusion (not just the minimum). The draft replacement London Plan policy 7.2 ‘An inclusive environment’ also requires the highest standards of accessible and inclusive design in all new development. This together with the Mayor’s Supplementary Planning Guidance ‘Accessible London: achieving an inclusive environment,’ underpins the principles of inclusive design and the aim to achieve an accessible and inclusive environment consistently across London.

28 A detailed access statement has not been submitted with the planning application to explain the design rationale behind the application and to demonstrate how the principles of inclusive design, including the specific needs of disabled people have been integrated into the proposed development and how inclusion will be maintained and managed. Although the submitted design and access statement makes some reference to the Disability Discrimination Act, this is civil legislation and does not demonstrate that the building will be designed to meet or exceed Part M of the Building Regulations. It is extremely disappointing that such a fundamental consideration in the design of the hospital has not been afforded greater importance, as it is essential to imbed principles of inclusivity from the outset of the design process. Given the outline nature of the application, further consideration should be given to how this will be addressed as the design process continues.

29 In particular, the detailed design of the car park and the pedestrian routes through the car park should ensure legible and safe pedestrian routes clear of vehicular movements with direct accessible routes to the main entrances. The needs of users of the proposed mental health facility and any older or disabled people with cognitive impairments is particularly important given the nature of the uses on the site. The taxi drop off area will need to be designed to ensure safe and easy deployment of ramps for wheelchair users (i.e located beside a raised kerb). An access audit of the surrounding streets showing existing and proposed pedestrian links and step free routes to and within the site should also be undertaken to demonstrate that any barriers to disabled people have been removed.

30 Reference is made to a proposed access audit in the supporting literature, and this should be secured through a planning condition. A consultative access forum should also be established to ensure that local access needs and the expertise of disabled users are incorporated into the design process as this progresses. The number and location of blue badge bays needs to be carefully considered given the likely high use of the building by disabled and older people.

31 There are several matters that require further consideration to ensure full compliance with London Plan policy 4B.5 relating to creating inclusive environments. Climate change

32 The London Plan promotes five principles in policy 4A.9 to promote and support the most effective adaptation to climate change. These are to minimise overheating and contribute to heat

page 13 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. The London Plan Consultation Draft Replacement Plan also includes policies to ensure the development makes the fullest contribution to London’s adaptation to climate change.

33 The applicant has broadly followed the energy hierarchy in Policy 4A.1 although further information is required before the proposals can be considered acceptable.

BE LEAN

Baseline carbon dioxide emissions (policy 4A.4 of London Plan)

34 The baseline emissions have been estimated using benchmarks that are representative of a building regulations 2006 compliant development. The baseline emissions have been estimated to 2,417 tonnes of carbon dioxide per annum, however, the applicant needs to confirm whether the emissions due to non-regulated energy use, have been accounted for.

Energy efficiency standards (Policy 4A.3 of the London Plan).

35 A qualitative description of energy efficiency measures that could be adopted in the design of the proposed building/s has been included in the energy statement. Measures proposed include passive design measures such as improved insulation values and air tightness, access to daylight and reduction of solar gains in the summer season.

36 Although the energy statement has stated that the proposed measures would reduce carbon emission beyond building regulation 2006 minimum requirements, the reduction is not quantified and no modelling has been submitted that supports this statement.

37 It is understood that this is an outline application and that not much information is known about the building details. However, the applicant should use building regulations modelling for a similar building in order to calculate the baseline emissions and to demonstrate/quantify the carbon savings that could be achieved as a result of adopting the proposed demand reduction and energy efficient design measures. The applicant should commit to a quantified carbon reduction target.

BE CLEAN

District heating (policies 4A.5 and 4A.6 of the London Plan)

38 A new energy centre at ground floor level is being proposed to meet the demands of the proposed extension. Currently, other buildings at the site are supplied with heat using plant installed in an existing energy centre, which is proposed to be demolished as part of the redevelopment. The energy statement states that the proposed new energy centre will be large enough to supply both the existing and new buildings on the site. This approach is welcomed and the construction of an energy centre of a sufficient size to accommodate these requirements should be secured by condition. The applicant should also provide the following further information:

• Estimate of the space requirements for an energy centre to supply the whole hospital buildings (new and existing).

page 14 • Submission of a schematic that includes the existing buildings (and its floor areas) on-site and existing energy centre as well as planned buildings and location of the proposed new energy centre.

• Submission of drawings to indicate how a heat network (according to the phasing provided in the energy statement) could potentially supply all the hospital buildings with heat.

• Description of the existing heat network and building heating systems including operational temperature, hot water/steam, etc. This is necessary to investigate how compatible the plans for the new energy centre/heat network are with the intention of also supplying heat to the existing buildings in the short or medium term.

Combined Heat and Power (Policy 4A.6) and renewable (policy 4A.7)

39 The applicant has proposed the installation of bio fuel-fired combined heat and power (CHP) in the form of three separate 360 kWe units, which would not operate at the same time.

40 This option has been estimated to reduce carbon emissions by a further 98%. There is a reasonable heating demand for this development and the decision to install CHP supplying heat to the proposed new extension an potentially to the all the hospital buildings is welcomed. However, the decision to opt for a bio fuel CHP system for the proposed development, giving claimed carbon savings of 98% over the baseline is less robust - as the GLAS are not aware of any similar installation that has operated in the UK in the long term. Therefore, the applicant should address the following uncertainties regarding the proposed bio diesel CHP installation:

• Provide more detail regarding the calculation of the carbon savings.

• The CHP manufacturer’s warranty for the use of the proposed liquid bio fuel in the CHP engine chosen needs to be provided, as well as details of the CHP engine to be used i.e. manufacturer, etc.

• Evidence should be provided that the choice of fuel will not compromise the ongoing operation and maintenance cover for the engine.

• Whist the calculations undertaken by the applicant in relation to the carbon emission factor actor of bio fuel are welcomed, the applicant should provide the carbon intensity of the actual bio fuel that will be used and to identify suitable bio fuel suppliers able to provide the amount of bio fuel the development would need.

41 Due to the uncertainties associated with the bio fuel installation, the applicant should also develop a back-up strategy based on gas fired CHP and the use of photovoltaic (PV) panels. For this purpose the applicant should provide drawings showing the amount of roof space that could be used for the installation of PV with a suitable orientation and free of shading as well as calculating the carbon savings this option could realise.

Cooling (Policies 4A.6 of the London Plan)/Renewable energy technologies (policy 4A.7)

42 The summary of the energy statement indicates that the proposed combined heat and power plant would also provide heat to run heat-fired chillers contributing to the cooling requirements of the site. However, this option has not been detailed within the main body of the energy statement and this should have been the case, e.g. size of heat fired chillers proposed, etc.

page 15 Sustainable design and construction (policy 4A.9)

43 The London Plan promotes five principles in policy 4A.9 to promote and support the most effective adaptation to climate change. These are to minimise overheating and 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. The draft replacement London Plan also includes policies to ensure the development makes the fullest contribution to London’s adaptation to climate change.

44 The applicant has not assessed the proposal against London Plan policy or the sustainability assessment checklist from the Mayor’s Essential and Preferred Standards in the Sustainable Design and Construction SPG and this should be addressed as part of the revised energy strategy. Transport

45 London Plan (2008) policy 3C.1 Integrating transport and development and 3C.2 Matching development to transport capacity, and draft replacement London Plan policies 6.1 Strategic approach and 6.3 Assessing transport capacity seek to integrate transport and development and ensure that there is sufficient transport capacity to allow for travel generated by new development. In addition these policies state that developments with significant transport impacts should include a transport assessment in line with TfL’s Transport assessment best practice guidance (May 2006). A preliminary transport statement has been submitted as part of this proposal and this should be progressed into a full transport assessment so that the impacts of this development on the surrounding public transport and highway networks can be fully understood and mitigated.

46 No analysis has been undertaken in relation to the number of additional bus trips generated by the proposal. Given that the hospital staff and visitors are heavily reliant on existing bus services, further trip generation analysis required so that the impacts on local bus services can be assessed. Depending on the outcome of this analysis TfL may request contributions towards improving capacity/frequency of any affected services as well as contributions towards improving the accessibility and conditions of existing bus stops within the vicinity of the site. This will be necessary in order for the proposals to comply with London Plan policy 3C.20 Improving conditions for buses and draft replacement London Plan policy 6.7 Buses, bus transits, trams.

47 As part of the redevelopment a new, rationalised access to the hospital site is proposed. On initial review TfL agrees, in principle, with the proposed layout of this junction, however this is subject to further detailed discussions. A TRANSYT model has been prepared and it is requested that the full set of inputs and outputs of the modelling are provided so that the model can be audited. In addition base modelling (using PICADY) should be provided. This is required to ensure all highways proposals fully comply with London Plan policy 3C.16 Road Scheme Proposals and replacement London Plan Policies 6.11 Smoothing traffic flow and tackling congestion and 6.12 Road network capacity which focus on smoothing the flow of traffic, congestion and road network capacity.

48 Should this application be granted planning permission, the developer and their representatives are reminded that this does not discharge the requirements under the Traffic Management Act 2004. Formal notifications and approval may be needed for both the permanent highway scheme and any temporary highway works required during the construction phase of the development.

49 There are currently 827 car parking spaces provided on site. It is proposed that the number of car parking spaces is maintained at this level. The majority of these spaces (64%) are allocated for staff use and are controlled through a permit system, with staff charged for a permit. 187 are for

page 16 general visitor use 60 are for disabled/blue badge parking and the remainder for operational purposes. The approach to car parking is compliant with policy 3C.23 Parking Strategy and Annex 4 of the London Plan (2008), as well as Table 6.1 of the draft replacement London Plan.

50 Further details are required in relation to the proposed number of cycle parking spaces and how this relates to London Plan standards for hospitals. Initial investigation highlights that the proposed 100 spaces fall far short of what will be expected. In addition, further consideration should be given to how the hospital site can be linked to the surrounding cycle network, for example linking the hospital to the existing cycle track facilities alongside Robersbridge Road. Therefore further information is required to ensure that the provision of cycle spaces and infrastructure is in line with London Plan policy 3C.22 Improving conditions for cyclists and draft replacement London Plan policy 6.9 Cycling.

51 The preliminary transport statement fails to make any reference to servicing or construction management/impacts. The preparation of a delivery and servicing plan and a construction management plan will need to be secured by planning condition or s106 obligation. All construction access routes and access details also need to be approved by the relevant highway authority prior to the commencement of any works. This will help to ensure compliance with London Plan (2008) policies 3C.17 Tackling congestion and reducing traffic and 3C.25 Freight strategy.

52 A full travel plan has been recently prepared for St Helier Hospital as part of TfL’s corporate scheme. The travel plan has been successfully implemented and is commonly referred to as best practice. This travel plan must be referred to in terms of the development proposals, alongside details of how the new facilities will tie into this travel plan, alongside specific objectives, targets and measures. In order to ensure compliance with London Plan policy 3C.3 Sustainable transport in London and draft replacement London Plan policy 6.1 Strategic approach the travel plan should be iTRACE and TRAVL compliant and secured, enforced, monitored, funded and reviewed as part of the Section 106 agreement.

53 Until further analysis is carried out particularly in relation to trip generation and impacts TfL reserves its position in relation to the level of transport mitigation required. At this stage the following items, although not exhaustive, are some areas towards which appropriate transport mitigation may be sought: improvements to bus service capacity/frequency; measures to improve the accessibility and condition of existing bus stops; and improved connections to from the site to the local cycle network

54 Whist supportive of the nature and scale of the proposed development, there are several matters which require further clarification/resolution before the proposals can be determined for compliance with the relevant policies set out within the London Plan. Local planning authority’s position

55 Sutton Council generally supports the proposals for the redevelopment of the site. Legal considerations

56 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

page 17 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

57 There are no financial considerations at this stage.

Conclusion

58 London Plan policies relating to health and community facilities, urban design, access and inclusion, climate change mitigation and adaptation and transport are relevant to this application. Whilst the application is broadly acceptable in strategic planning terms, there are some areas where the application does not yet fully comply with the London Plan:

59 Health and community facilities: the proposal complies with London Plan policies 3A.18 (and draft replacement London Plan policy 3.18) relating to the provision of health facilities.

60 Urban design: the proposal broadly complies with London Plan policy 4B.1 relating to design (draft replacement London Plan policy 7.1) although some further information is required in relation to the proposed ‘phase 2’ development and the proposed car park design.

61 Access and inclusion: there are some outstanding issues which require resolution to ensure compliance with London Plan policy 4B.5 (and draft replacement London Plan policy 7.2 relating to inclusive design).

62 Climate change mitigation and adaptation: the general approach to the energy strategy is acceptable, but further information is required should be further developed to ensure compliance with London Plan policies 4A.5, 4A.6 and 4A.7 relating to climate change mitigation (and draft replacement London Plan policies 5.6 and 5.7). The application should also demonstrate how it meets the essential and preferred standards at required by the ‘Sustainable design and construction’ SPG to ensure compliance with London Plan policy 4A.3 (and draft replacement London Plan policy 5.3).

63 Transport: The approach to car parking is compliant with policy 3C.23 Parking Strategy. Other matters require clarification/resolution to ensure compliance with London Plan policies 3C.1, 3C.2, 3C.3, 3C.16, 3C.20, 3C.21, 3C.22 and 3C.25.

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

page 18 elements. The energy strategy will need to be secured through the section 106 agreement and/or appropriate planning conditions. • Transport: further information is required in relation to transport assessment, bus trip analysis, the highways modelling, the low level of cycle parking, servicing and construction management and the need to agree and appropriate level transport mitigation where deemed necessary.

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] Shelley Gould, Case Officer 020 7983 4803 email [email protected]

page 19