planning report PDU/1476b/01 5 September 2011 Westfield House Depot, Knaresborough Drive, Southfields in the London Borough of planning application no. 2001/2769

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 is sought for the replacement of the existing depot storage buildings with a residential development of 195 units, 200 sq.m. ground floor cafe and underground parking for 152 vehicles and 195 cycle parking spaces. Additional work is proposed to upgrade part of King George’s Playing Fields. This is submitted as a renewal of planning permission 0689/2007 granted on 19 January 2009.

The applicant The applicant is Q Developments Limited, and the architect is Conran & Partners.

Strategic issues The application raises strategic matters regarding housing (quantum of affordable housing, tenure, mix and density), urban design, climate change and transport.

Recommendation

That Wandsworth Council be advised that the application does not comply with the London Plan, for the reasons set out in paragraph 74 of this report; but that the possible remedies set out in paragraph 76 of this report could address these deficiencies.

Context

1 On 1 August 2011, the Mayor of London received documents from Wandsworth 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.

2 The application is referable under Category 1A.1 and 1B1.c) of the Schedule to the Order 2008:

page 1 Category 1A

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

Category 1B

1. 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.

3 Once Wandsworth 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 site is located in the Southfields Ward of Wandsworth and is just under one hectare in area. It is bounded to the north and west by King George’s playing fields, designated as Metropolitan Open Land (MOL), and to the east by the River Wandle. South of the site comprises existing residential terrace dwellings of Riverdale Drive and Knaresborough Drive.

6 The site is currently occupied by Westfield House, a single storey depot building of approximately 7,000 sq.m. used by the Department of Trade and Industry as an archiving facility. It is currently enclosed by a 4-metre high palisade metal fence, prohibiting public access.

7 The nearest section of the Strategic Road Network is 500 metres away (Garratt Lane, A217). The site is 1.5 kilometres from the Transport for London Road Network in two directions (A3 Wandsworth High Street to the north and A214 Trinity Road to the east). The site is 500 metres from four bus routes (number 44, 77, 156 and 270) and two night bus routes (number N44 and N87). National Rail station (21-27 trains per hour (peak) served by South West Trains) is 500 metres away. The nearest station is Southfields (), 1.6 kilometres away. The public transport accessibility level (PTAL) of the site is 3 (on a scale of 1-6 where 6 is considered very high and 1 very low).

Details of the proposal

8 The submission is for the renewal of planning permission granted on 19 January 2009 (reference 2007/0689). It proposes residential led mixed use development comprising 191 apartments and four houses. Parking for 195 cycles and 152 vehicles is also proposed at below ground level. Also proposed is a 200 sq.m. ground floor cafe is proposed facing onto King George’s playing fields. In addition, part of the playing fields will be enhanced to include child play facilities and improved pedestrian access with newly laid footpaths.

9 In design terms the submission is unchanged from the approved application. The development will comprise three buildings. The first at the southern end of the site is for the erection of four dwellings, three storeys high, adjacent to the existing terraced houses on Riverdale Drive and Knaresborough Drive. The building then rises to four storeys to form the first block of apartment accommodation. The third, and main block, is sited to the north, rising from four to five storeys. Central court yard areas will provide communal space for the main northern block. This is

page 2 separated from the two southern blocks of accommodation by a pedestrianised access road that leads down to the underground parking and cycle storage area.

10 The residential component to the scheme is reported in the updated planning statement as 191 apartments (73 x one-bedroom, 87 x two-bedroom, 31 x three-bedroom) and 4 x three- bedroom houses. This is different to the mix previously reported to the former Mayor and different to that secured in the section 106 agreement of the original approval. The split in terms of bedroom size mix by tenure is not confirmed (see further comment in housing section). Case history

11 The original application was previously considered by the former Mayor on 17 October 2006 (report PDU/1476/01). The proposal was for similar development of 206 residential units and cafe and 25% affordable housing. The former Mayor raised strategic concern at the justification for the shortfall in the affordable offer put forward. The former Mayor also raised concerns relating to energy, access and transport.

12 Following on from further discussion with Wandsworth Council, the application was withdrawn pending further analysis on matters raised by the Mayor and other consultees. A new application was made having taken on board the views raised during the previous consultation stage on the original submission. The former Mayor considered the case on 9 May 2007 and was content to allow the proposals to proceed subject to any action from the Secretary of State. The Council formally issued planning permission on 19 January 2009 after negotiations on the section 106. The permission includes standard condition regarding commencement of development within three years which expires on 19 January 2012.

Strategic planning issues and relevant policies and guidance

13 The relevant issues and corresponding policies are as follows:

 Housing London Plan; PPS3; Housing SPG; Providing for Children and Young People’s Play and Informal Recreation SPG, Housing Strategy; Interim Housing SPG; Housing SPG EiP draft  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; Housing SPG EiP draft  Urban design London Plan; PPS1  Mix of uses London Plan  Regeneration London Plan; the Mayor’s Economic Development Strategy  Transport London Plan; the Mayor’s Transport Strategy; PPG13  Parking London Plan; the Mayor’s Transport Strategy; PPG13  Retail/town centre uses London Plan; PPG13, PPS4  Biodiversity London Plan; the Mayor’s Biodiversity Strategy; PPS9; draft PPS Planning for a Natural and Healthy Environment  Access London Plan; PPS1; Accessible London: achieving an inclusive environment SPG; Planning and Access for Disabled People: a good practice guide (ODPM)  Equal opportunities London Plan; Planning for Equality and Diversity in Meeting the spatial needs of London’s diverse communities SPG; Diversity and Equality in Planning: A good practice guide (ODPM)  Tall buildings/views London Plan; RPG3A, Revised View Management Framework SPG

page 3  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 Change Mitigation and Adaptation Strategies; Mayor’s draft Water Strategy; Sustainable Design and Construction SPG  River Thames/flooding London Plan; Mayor’s draft Water Strategy; PPS25, RPG3B

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 2010 Wandsworth Core Strategy, 2003 Wandsworth UDP (as saved) and the 2011 London Plan. The Council has also published the submission version of the Site Specific Allocations Development Plan Document and Development Management Development Plan Document. These two documents are due to go through public examination in September 2011. The Mayor’s updated opinion on general conformity of these documents with the previous London Plan (London Plan consolidated since 2004) was issued on 22 June 2011. The Mayor is due to issue a further update to the Inspector prior to the start of the examination in public regarding the implications for the two documents following publication of the London Plan 2011. Principle of development

15 As previously reported, the site is currently an archiving depot for the Department of Trade and Industry, employing approximately twelve persons. It has no restrictive local or strategic policy constraints to steer any specific re-development or land use. Under the 2003 UDP such a loss of employment would normally be resisted, however, following application to the Secretary of State for a saving request (September 2007), a number of policies expired, including those protecting smaller sites outside designated employment areas (BIN2 and BIN5) as referenced in the previous report PDU/1476/01.

16 In considering the case in 2007, however, Wandsworth Council, reported “There is no policy objection to the loss of the employment use on this site, as it is not located on a main road, in an industrial employment area or in a town centre. The use of the site for residential purposes is in accordance with policy”. This view underpinned the Council’s resolution to grant planning permission for the current consent.

17 In strategic planning terms, the use does not conflict with any strategic site identification within the London Plan. Given the reasonable transport links, waterside location and proximity to King George’s Park (protected open space, MOL); a residential led scheme is, in principle, an acceptable use subject to other policies within the Plan which are considered below. Housing

Affordable housing

18 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. Negotiations on sites should take account of their individual circumstances including development viability, the availability of public subsidy, implications of phasing and other scheme requirements. 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 family housing, the need to promote

page 4 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.

19 The Council’s adopted Core Strategy, policy IS5, sets a borough wide target of 3,725 affordable homes up to 2016/17 and that on individual sites the maximum reasonable amount of affordable housing will be sough with a minimum target of 33%. The policy also requires that a viability appraisal should be submitted where less than 50% affordable housing is proposed.

20 The overall quantum of affordable housing secured in previous section 106 agreement is for 35 social rented units and 17 intermediate units. The remaining 143 were agreed as private market accommodation. The bedroom size mix by tenure was not reported by the Council in 2007 nor is it clear in the section 106 what the approved bedroom size mix was intended to be. It remains unclear in the current submission how the provision will be split across unit sizes by tenure, and therefore the applicant should confirm the exact approach.

21 The mix reported to the former Mayor at the consultation stage of the previous application is set out below.

Table 1 previous bedroom size mix

1-bed 2-bed 3-bed 4-bed total

social rent 8 12 11 4 35 (18%)

intermediate rent 6 11 0 0 17 (9%)

Market 67 56 20 0 143 (73%)

Total 81 (42%) 79 (40%) 31 (16%) 4 (2%) 195 (100%)

22 The resubmission does not include an updated three dragons model or supporting documentation and cost plans. These formed a crucial part of the consideration of the previous case. Viability may have become more constrained in the current climate; however this material is required and should be submitted for independent scrutiny to ensure the policy position regarding the maximum reasonable amount remains justified.

Tenure split

23 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 application does not provide any affordable rent units under the new definition as discussed further below.

24 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.

25 Planning Policy Guidance 3: Housing formally introduces affordable rent as a new affordable housing product. This shift in national housing policy is not currently reflected in strategic planning policies for London.

page 5 26 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 It is acknowledged that the 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.

28 The applicant needs to confirm the bedroom size mix by tenure, but under the previous approved scheme the proposals provide 22% social rent and 8% intermediate provision, when measured by habitable room. The application previously assumed grant funding and therefore given the changes to the funding regime, further consideration is required to establish the deliverability of affordable housing products without external funding and whether social rented accommodation in the previous format is viable or whether other affordable rent products need to be considered as part of the scheme.

Mix of units

29 London Plan Policy 3.11 accords priority to family housing within affordable housing provision. In addition, London Plan 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. 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

30 The applicant needs to confirm the proposed bedroom size mix by tenure. 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 element still needs to be recognised to meet strategic objectives.

31 The Mayor’s Housing SPG (2005) does not establish a specific target for private and intermediate 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 capitol, the Strategic Housing Market Assessment found little net requirement for this type of housing across London, although there are bound to be local variations”.

32 The Mayor’s Housing Strategy provides further updated guidance with regard to intermediate provision and sets a target of 16% of homes within this tenure to be family sized. Further discussion is therefore required regarding housing mix once the bedroom size mix by tenure has been established.

page 6 Density

33 London Plan Policy 3.4 seeks to optimise the potential of sites, having regard to local context, design principles and public transport accessibility. The site has a public transport accessibility level of three and its immediate setting is urban in character. The London Plan density matrix therefore suggests a residential density of between 200 and 450 habitable rooms per hectare.

34 The density proposed is also undefined in the re-submission. Broadly the calculation can be applied regarding previous material. The site has an area of 0.965 hectares and approximately 555 habitable rooms. This provides an approximate density of 575 habitable rooms per hectare which falls above the guidance within the London Plan.

35 The new plan moves away from maximising the potential of development sites to optimising their potential having particular regard to local and site context. In considering the density of a proposal, a wide range of factors are relevant, as detailed in the Mayor’s draft Housing SPG (EiP version). These include, the need to provide good quality accommodation that is well designed and delivers an appropriate mix of units, sufficient play amenity space in line with London Plan requirements, and be well designed and in context with its surroundings and public transport accessibility. In this context, the applicant should note comments below regarding housing quality. This issue is particularly important given paragraph 1.3.2 of the SPG, which stresses in formulating density policy the quality of housing output should not to be compromised by the need to make efficient use of land, and highlights the importance of the need to secure residential quality. The applicant should confirm the density which requires consideration in the context of the design comments on residential quality set out below. Urban design

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

37 The revised submission does not include a copy of the design and access statement or images of the proposed development. This material should be provided. The layout plans are currently available on the Council’s website and have been used to consider the design matters set out below.

Layouts and residential quality

38 Since the former Mayor’s consideration of the original application, strategic policy has sought to address the issue of housing quality. Policy 3.5 of the London Plan introduces a new policy on the quality and design of housing developments. Part A of the policy states that housing developments should be of the highest quality internally, externally and in relation to the wider environment. Part C of the policy states that new dwellings should generally conform with the dwelling space standards set out in Table 3.3, have adequately sized rooms and convenient and efficient room layouts. Part E of the policy states that the Mayor will provide guidance on implementation of this policy including on housing design for all tenures. The reasoned justification provides further guidance and explanation. In particular, paragraph 3.32 makes clear that “Securing new housing of the highest quality and protecting and enhancing residential neighbourhoods are key Mayoral priorities”.

39 To address these, the Mayor has produced a new draft Housing SPG (EiP version) on the implementation of Policy 3.5 for all housing tenures, drawing on his interim Housing Design Guide.

page 7 Paragraph 3.38 highlights what the proposed SPG would cover, in terms of requirements for individual dwellings. This draft was produced for the London Plan examination in public.

40 Whilst the applicant has acknowledged the strategic policy requirements with regard to housing quality, and the Mayor’s Housing Design Guide, it has not provided sufficient information to allow for an assessment of the residential units. Analysis of the floor plans is however difficult without scale drawings. It is however evident that the proposals include a number of single aspect units and that there are examples where the number of units accessed of a single core is above the maximum guidance of eight. The applicant must revisit the quality and space being created and provide commentary on all aspects of the Mayor’s Housing Design Guide, including the number of units accessed of a single core, floor to ceiling height parameters, north facing units, single aspect units and balcony sizes amongst other matters. Further information is therefore required regarding housing quality to ensure compliance with Policy 3.5 of the London Plan.

Architecture

41 London Plan policy 7.6 underpins the Mayor’s aspiration to create buildings of the highest architectural quality. The proposal retains the form of the original approved perimeter blocks. Whilst the building is broadly similar there are very limited rendered images provided in the updated submission. The design team should provide some further details, showing the appearance of the elevation and street views of all elevations.

Inclusive access

42 London Plan Policy 7.2 requires all future development to meet the highest standards of accessibility and inclusion, and requires design and access statements submitted with planning applications to explain 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 managed and maintained. London Plan Policy 3.8 expects 10% of all new housing to be wheelchair accessible or easily adaptable for wheelchair users. Further guidance to this policy is provided in the Mayor’s Supplementary Planning Guidance ‘Accessible London: achieving an inclusive environment.’

43 The drawings need to be provided for scrutiny and the applicant needs to provide commitment to 10% wheelchair accessible homes and 100% Lifetime Homes Standard. Basement plan is also required to consider the location of parking and access cores in relation to disabled parking provision.

Children’s play space

44 Policy 3D .13 of the London Plan sets out that “the Mayor will and the boroughs should ensure 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’ and based on the bedroom size mix set out in table 1, it is anticipated that there will be approximately 79 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 790 sq.m. of playspace.

45 As previously reported the development is located in excellent proximity to open space with significant options for play and recreation activities. The location is suited to family living and the Council previously secured significant improvements to the current park as part of the approved application. Previously this was to be delivered through a financial contribution of £150,000 to

page 8 fund the upgrade and improvement of the park, including its access, and £50,000 to fund its future management. At the consultation stage the Mayor requested some on-site provision for under 5 age group. The applicant previously agreed to provide on-site play within the courtyard. The size and type of equipment was to be agreed with Wandsworth Council. The applicant should confirm these matters remain as previously agreed or provide further details regarding any updated approach. Climate change mitigation

46 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 technologies on-site. The policies set out ways in which developers must address mitigation of, and adaptation to, the effects of climate change.

47 The applicant has broadly followed the energy hierarchy. Sufficient information has been provided to understand the proposals as a whole. The proposals are broadly acceptable; however, further information is required before the carbon savings can be verified.

Energy efficiency standards

48 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 values required by building regulations. Other features include energy efficient lighting and low energy ventilation systems.

49 The development is estimated to achieve 2010 Building Regulations compliance through energy efficiency measures alone.

District heating

50 No information has been provided on the potential to connect to district heating networks. The applicant should investigate the potential to connect to existing or planned heat networks in the vicinity of the development. The applicant should also confirm that provision will be made within the development to allow connection to a district heating network. A site heat network is proposed to supply all residential units and commercial spaces within the development. The heat network will be supplied from a single energy centre on the basement level.

Combined heat and power

51 The applicant is proposing to install gas fired combined heat and power as the lead heat source for the heat network. A reduction in carbon dioxide emissions of 52 tonnes per annum is envisaged through this second part of the energy hierarchy. The applicant should confirm the electricity capacity of the plant proposed. Also, given the relatively small scale of this residential led development and the complexities involved in selling electricity generated by combined heat and power at this scale, the applicant should provide details of the electricity sales strategy.

Cooling

52 Passive design measures will be adopted to avoid the need for active cooling in the residential units. The commercial space will be actively cooled.

page 9 Renewable energy technologies

53 The applicant has considered the feasibility of different renewable technologies and concluded that roof mounted photovoltaic panels is feasible. However, no renewable energy technologies are currently proposed.

Summary

54 The applicant should provide the estimated regulated carbon emissions of the development in tonnes of carbon dioxide per year after the cumulative effect of energy efficiency measures, combined heat and power and renewable energy has been taken into account.

55 The applicant should provide the overall reduction in regulated carbon dioxide emissions, expressed in tonnes per year and percentages, compared to a 2010 Building Regulations compliant development.

56 If the percentage savings in regulated emissions do not meet the target in Policy 5.2 of the London Plan, the applicant should propose renewable energy technologies, e.g. photovoltaic panels or other measures aimed at achieving the percentage reduction target set out in the London Plan. Climate change adaptation

57 The applicant submitted a sustainability strategy as part of the previous application. Measures proposed include maximising rainwater harvesting opportunities, grey water recycling systems, green and sedum roofs, tree planting and waste management measures. The package of measures remains consistent with London Plan requirements regarding climate change adaptation, however the issue of flooding needs to be considered in further detail and is subject to the advice from the Environment Agency and Wandsworth Council. Transport for London’s comments

58 The existing western entrance from Knaresborough Drive will be maintained and a new access road through site constructed to link into Riverdale Drive. Members of the public will be able to access the site through King George’s Park via the new pedestrian and cycle links and the riverside walkway will open up access to wider Earlsfield via the pedestrian bridge across the River Wandle. This is supported as it is in line with London Plan Policy 6.10, Walking, opening up new links.

Highway network

59 Based on the expected number of car trips generated, TfL considers that the proposed development is unlikely to constrain capacity on the strategic highway network. The development is broadly consistent with London Plan policy 6.12 Road network capacity.

Parking

60 A total of 145 car parking spaces have been proposed within the basement area, this includes 14 disabled parking bays and equates to a parking ratio of 0.74 spaces per residential unit. TfL previously accepted 152 spaces on the site as part of the current permission. Whilst this level of car parking may be compliant with the Parking Standards detailed in London Plan Policy 6.13 Parking; TfL would welcome further reductions where possible.

page 10 61 Notwithstanding the above, TfL seeks clarification of the proposed use of the 7 additional surface spaces as highlighted in section 1.6 (page 6) of the planning statement as this reference does not appear within the Transport Assessment. Confirmation that the commercial unit will not have any car parking provision is sought.

62 Electric vehicle charging points must be provided in line with London Plan policy 6.13, ‘Parking’, which states that 20% of all spaces should have an electric charging point installed, with a further 20% having passive provision so that additional spaces or points can be provided at the time of implementation or at some point in the future. Based on current parking levels this would equate to 29 electric charging points being provided initially, with a further 29, able to be provided at some point in the future. This level of parking should be secured by way of the section 106 agreement.

63 TfL welcomes the applicant’s commitment to produce a car parking management plan for the whole site. This plan should be conditioned as part of any planning permission. The proposal to host an on-site car club through the provision of three car parking spaces (included within the total of 145) is welcomed by TfL. These spaces should be in accessible locations, able to be used by residents at the development and those in the neighbouring area whilst being promoted through the on-site travel plan. As agreed with the previous application occupants rights to park within the surrounding Controlled Parking Zone should be removed. This should be secured by condition.

Pedestrian environment

64 In order to ensure consistency with London Plan Policy 6.10 Walking a robust assessment of pedestrian levels of service around the site should be conducted by the applicant pre- determination. This audit will identify existing barriers and issues to walking that can be remedied through the section 106 agreement and promote walking from the site. Such mitigation measures may include the legible London wayfinding strategy. In order for the targets of the travel plan as identified below to be met, pedestrian conditions must be such that they encourage walking.

Cycling

65 A total of 195 cycle spaces are proposed for all land uses. TfL notes that this does not accord with London Plan Policy 6.13 Parking as the larger 3 bed units should have 2 spaces per unit. Therefore an increase to a minimum of 230 cycle parking spaces is required.

66 TfL expects all spaces are provided in accessible but safe locations with shelters located around the basement. Further detail is required.

Public transport

67 Given the size of the scheme and the nature of TfL operated services, TfL considers that the demand from the development can be accommodated onto the existing network and that no contribution towards strategic public transport services is required. This is however subject to any comments or requirements the council may identify.

Travel plan, servicing and delivery

68 In order to ensure consistency with London Plan Policy 6.3 assessing transport capacity TfL expects the full travel to be prepared and submitted in line with TfL’s guidance. This travel plan should be tested using the ATTrBuTE tool, further guidance is available upon request. This travel plan should be secured, enforced, monitored and reviewed as part of any section 106 agreement.

page 11 69 In line with TfL’s ‘A new way to plan’ travel planning guidance, the delivery and servicing plan must be included within the overall travel plan. This must consider elements including minimising disruption to the local road network. In order to mitigate any adverse impacts of construction traffic a construction logistics plan should be secured by condition. This will ensure consistency with London Plan Policy 6.14 Freight.

70 In summary a number of issues need to be resolved before the application can be considered to be in line with the transport policies set out within the London Plan. This includes the need to clarify and where possible reduce residential car parking levels, a commitment to providing electric vehicle charging points in line with the relevant standards, assessing the quality of pedestrian environment and improving this where necessary. In addition cycle parking numbers should be increased and a travel plan and combined construction logistics plan should both be secured by condition and section 106. Local planning authority’s position

71 The officer recommendation is unknown. Legal considerations

72 Under the arrangements set out in Article 4 of the Town and Country Planning (Mayor of London) Order 2008 the Mayor is required to provide the local planning authority with a statement setting out whether he considers that the application complies with the London Plan, and his reasons for taking that view. Unless notified otherwise by the Mayor, the Council must consult the Mayor again under Article 5 of the Order if it subsequently resolves to make a draft decision on the application, in order that the Mayor may decide whether to allow the draft decision to proceed unchanged, or direct the Council under Article 6 of the Order to refuse the application, or issue a direction under Article 7 of the Order that he is to act as the local planning authority for the purpose of determining the application and any connected application. There is no obligation at this present stage for the Mayor to indicate his intentions regarding a possible direction, and no such decision should be inferred from the Mayor’s statement and comments. Financial considerations

73 There are no financial considerations at this stage. Conclusion

74 London Plan policies on employment, urban design, access, climate change and transport are relevant to this application. The application complies with some of these policies but not with others, for the following reasons:  Principle of development: (compliant) The loss of employment is broadly accepted in strategic terms and having regard to the Council’s recently adopted core strategy and proposals map.  Affordable housing, tenure split, bedroom size mix and density (non-compliant): The housing offer needs clarification in terms of the bedroom size mix by tenure. The quantum may require independent review. The approach to deliverability of social rented affordable housing without grant funding may also need reconsideration along with the mix of family units. The density exceeds the guidance within the London Plan.  Urban design and access (non-compliant): The report identifies some detailed design matters that require further consideration, including further work on residential quality and

page 12 further assessment regarding the quality of design (appearance) and level of accessibility. The playspace strategy should also be confirmed.  Climate change mitigation (non-compliant): Consideration of existing heat networks should be provided. The overall carbon dioxide savings need to be provided which will inform the requirement for further saving contributions in the form of renewable energy technologies.  Climate change adaptation (non-compliant): Further consideration is required regarding flooding.  Transport (non-compliant): A number of issues need to be resolved including the need to clarify and where possible reduce residential car parking levels, a commitment to providing electric vehicle charging points in line with the relevant standards, assessing the quality of pedestrian environment and improving this where necessary. In addition cycle parking numbers should be increased and a travel plan and combined construction logistics plan should both be secured by condition and section 106. 75 On balance, the application does not comply with the London Plan. 76 The following changes might, however, remedy the above-mentioned deficiencies, and could possibly lead to the application becoming compliant with the London Plan:  Affordable housing, tenure split, bedroom size mix and density (non-compliant): The housing offer needs clarification in terms of the bedroom size mix by tenure. The quantum may require independent review. The approach to deliverability of social rented affordable housing without grant funding may also need reconsideration along with the mix of family units. The density exceeds the guidance within the London Plan and needs to be justified.  Urban design and access (non-compliant): The applicant should consider the matters identified in this report including further analysis on residential quality having regard to the Mayor’s space standards set out in the London Plan and the guidance within the Mayor’s draft Housing Design Guide. Further material should also be provided regarding the appearance of the proposals and a set of floor plans should also be provided to allow further scrutiny in particular regarding accessibility. The playspace strategy should also be confirmed.  Climate change mitigation (non-compliant): The applicant should consider the matters identified in this report in particular other existing heat networks. The applicant should also verify the overall carbon dioxide savings to inform the requirement for further saving contributions in the form of renewable energy technologies.  Climate change adaptation (non-compliant): The advice from the Environment Agency and Wandsworth Council is required in order to allow further consideration regarding flooding.  Transport (non-compliant): A number of issues need to be resolved including the need to clarify and where possible reduce residential car parking levels, a commitment to providing electric vehicle charging points in line with the relevant standards, assessing the quality of pedestrian environment and improving this where necessary. In addition cycle parking numbers should be increased and a travel plan and combined construction logistics plan should both be secured by condition and section 106.

page 13 for further information, contact Planning Decisions Unit: Colin Wilson, Senior Manager - Planning Decisions 020 7983 4783 email [email protected] Justin Carr, Strategic Planning Manager (Development Decisions) 020 7983 4895 email [email protected] Matthew Carpen, Case Officer 020 7983 4272 email [email protected]

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