Woolwich & Thamesmead Area Planning Committee Agenda

Home , Plumstead, Politics of Greenwich, Thamesmead, Woolwich, Woolwich Town Hall

Place The Town Hall, 35 Wellington Street, Woolwich SE18 6PW

Date Tuesday, 22 June 2021

Time 6:30 PM

This meeting is open to the press and public and they are entitled to take photographs, film or record the proceedings.

Councillors Stephen Brain (Chair) Labour Dominic Mbang (Vice Chair) Labour Sandra Bauer Labour Gary Dillon Labour John Fahy Labour Averil Lekau Labour Clive Mardner Labour John Hills Conservative

Members are reminded that officer contacts are shown at the end of each report and they are welcome to raise questions in advance with the appropriate officer. This does not prevent further questioning at the meeting.

If you require further information about this meeting please contact the Corporate Governance Officer: Jean Riddler Telephone: 020 8921 4350 Email: [email protected]

Page 1 Agenda 1 Apologies for Absence To receive apologies from Members of the Committee.

2 Urgent business The Chair to announce any items of urgent business circulated separately from the main agenda.

3 Declarations of Interest Report Members to declare any personal and financial interests in items on the agenda. Attention is drawn to the Council’s Constitution; the Council’s Code of Conduct and associated advice.

4 8 Streamdale, Abbey Wood, London, SE2 0PD – Ref: 21/0701/F Ward – Plumstead The Area Planning Committee is requested to grant to grant full planning permission for the part-retrospective application for the construction of two (2) single storey rear extensions and other associated external alterations to allow the conversion of the house into two (2) self-contained C3 houses. (Resubmission).

5 340 Wickham Lane, Plumstead, London, SE2 0NZ – Ref: 21/0173/F Ward – Plumstead The Area Planning Committee is requested to grant full planning permission for the proposed change of use from dwelling into HMO (6 people) with associated internal alterations.

Page 2 6 38 Wellington Street, Woolwich, London. SE18 6PE – Ref: 20/1082/F Ward: Woolwich Riverside The Area Planning Committee is requested to grant Full Planning Permission for the change of use of the lower ground floor to include Class D1 (educational and medical/dentist use) to already consented A3/A4/D2/B1 uses with the installation of a partial mezzanine floor and associated external alterations to include the provision of 3 new entrances, introduction of bollards on Wellington Street and Polytechnic Street and removal of brick panels to provide additional windows, provision of cycle storage on lower ground level and other minor alterations.

Date of Issue Debbie Warren Friday, 11 June Chief Executive 2021

Filming and Recording Meetings

This meeting may be photographed (without the use of flash), filmed or audio recorded, except where the public is excluded because confidential or exempt items will be discussed. Any footage is likely to be publicly available.

By entering the room where the meeting is being held, you will be deemed to have consented to being photographed, filmed or audio recorded, and that will apply to any representation you make to the meeting. You will also be deemed to have consented to the possible public use of any images and sound recordings.

If you have any queries regarding the recording of meetings, please contact the Corporate Governance Manager on 020 8921 5134

Safety Fire and Emergency Procedures

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Users of the Committee Rooms and the Council Chamber are asked to note the following fire and emergency procedures:-

When you hear the continuous ringing of the fire alarm bells, please make your way out of the building in an orderly manner. The nearest exit from the Council Chamber and the Committee Rooms is through the main exit leading to Wellington Street (at the front of the building). Do not use the lift and do not stop to collect personal belongings. Once outside the Town Hall please make your way to the Assembly Point between Sainsbury’s and The Vista via Market Street or Polytechnic Street

Page 4 PUBLIC INFORMATION

SAFE USE OF COUNCIL MEETING ROOMS

The local authority is required to make all its public meeting spaces Covid-19 secure.

To comply with this the local authority - • will apply socially distanced seating arrangements in its public meeting rooms. • requires all attendees, unless medically exempt, to wear a face covering. Guidance on face covering can be found on the Government’s website. • requests all attendees to undertake a lateral flow test before attending meetings, and if positive you must not attend this meeting. These are free, and are available at certain sites or kits can be acquired for home testing. Please see the Council’s website for more details. • requests all attendees to wash their hands thoroughly or use sanitiser before entering the meeting rooms. • requires all attendees to scan the QR code via NHS COVID-19 App to check-in before being admitted entry to the meeting rooms.

Council Meetings are open to the press and public to attend, except where personal or confidential matters are being discussed.

As a result of Covid-19 secure measures, spaces for public viewing are extremely limited and will be allocated based on a first come, first served basis. Consideration and weighting will also be given to the role attendees will play at the meeting. Full Council and Planning Board/Area Committee meetings will be filmed, for live webcasting through the Council’s website. Other meetings will be recorded and added to the Council’s YouTube Channel shortly after the meeting has finished. The recording of this meeting will be available to view for one year after the meeting.

If you are attending a meeting you are requested to contact Committee Services by email at [email protected] or telephone on 020 8921 4350 at least two days before the meeting, stating the capacity in which you will be attending i.e. to observe the proceedings, speak on an item of business.

Page 5 For all meetings the general rule is that the Chair has discretion with regard to speakers and speaking times. Some committees have defined specific rules. The Chair will take into account the safe capacity of the room. This may mean that the Chair will only permit a certain number in at any one time.

On arrival at the Town Hall, please see the relevant Officer who will confirm you are on the list of attendees and who will either direct you to the meeting room, or to a waiting room depending on the circumstance.

______AREA PLANNING COMMITTEES PUBLIC INFORMATION

Area Planning Committees are meetings in public, not public meetings.

Please note that Committee Members will be using electronic devices to access the agenda, reports and documents published and submitted for the meeting. PLEASE TURN ALL MOBILE PHONES TO SILENT MODE

Terms of Reference The Area Planning Committees have delegated powers to take decisions on matters within their Terms of Reference as published in the Council’s Constitution.

Areas The three Area Planning Committees (APC) deal with matters relating to the following Wards:

Eltham & Kidbrooke APC covers: Coldharbour & New Eltham, Eltham North, Eltham South, Eltham West, Kidbrooke with Hornfair, Middle Park & Sutcliffe, and Shooters Hill.

Greenwich APC covers: Blackheath Westcombe, Greenwich West, and Peninsula.

Woolwich & Thamesmead APC covers: Abbey Wood, Charlton, Glyndon, Plumstead, Thamesmead Moorings, Woolwich Common and Woolwich Riverside. Determining planning applications

Page 6 When determining planning applications and related matters Officers and Councillors must adhere to important principles set out in legislation and Central Government Guidance.

Applications shall be determined in accordance with the Development Plan unless material considerations indicate otherwise. (Section 38A, Planning and Compulsory Purchase Act, 2004). The development plan comprises the Royal Greenwich Local Plan: Core Strategy with Detailed Policies 2014 and the Spatial Development Strategy for Greater London. The Key Principles of which are: • If there are other material considerations, the Core Strategy is the starting point and other considerations weighed up against it. • Where the Core Strategy is not relevant or there are policy conflicts, the application must be treated on its merits.

Material Planning Considerations include;

• Statutory provisions contained in Planning Acts and Statutory Regulations and Planning Case Law. • Central Government planning policy and advice as contained in Circulars, The National Planning Policy Framework (NPPF) and National Planning Policy Guidance (NPPG). • Planning Briefs and other Supplementary Planning Guidance, e.g. Home Extension Guidelines. • Site specific issues such as availability of infrastructure, density, car parking. • Environmental effects such as effect on light, noise, overlooking, effect on the street scene. • The need to preserve or enhance the Special Character or appearance of Conservation Areas and protect Listed Buildings. • Previous planning decisions, including appeals. • Desire to retain and promote certain uses.

Matters that must not be taken into account when determining planning applications include

Page 7 • Moral and religious issues. • Unfair competition. • Breach of private covenants or other property rights. • Devaluation of property. • Protection of a private view. • Identity of an applicant or occupier.

The Procedure for considering Applications

The conduct of the meeting is at the discretion of the Chair. According to the number of items to be considered, the Chair will strictly control the time for speakers wishing to address the Committee.

Any additional material (i.e. photographs, dioramas’ etc.) not previously submitted to Planning Officers that you wish to draw to the attention of the Board / Committee must be submitted no less than two working days before the meeting to the Corporate Governance Officer at [email protected]

Any documentation received after this deadline, including at the meeting, will not be accepted. This deadline is to allow sufficient time to scrutinise any additional information and for it to be presented to Members.

At the start of the meeting the Chair will summarise the procedure to be followed and announce that anyone wishing to address the Committee should give the Corporate Governance Officer their names, as if they are not included on the list they will not be permitted to speak.

1 Council Officers will introduce each item, outlining Officers’ recommendations on the matter, and answer any questions from the Committee. The Chair will then invite members of the public on the list to come to the table and address the Committee.

2. Both objectors to and supporters off an application, including amenity societies will be invited to address the Committee. The Chair has indicated that the following times will generally be allocated to speakers on any one application. The Chair may vary the time available, e.g.

Page 8 where there is a significant number of speakers or where there is a repetition or non-planning matters are being raised. • Individuals – up to two minutes each • Organised groups – up to four minutes each • Elected representatives (MPs and Councillors) – up to five minutes each • Applicant – up to 10 minutes

3. Comments should be confined to planning matters and the public will be advised to include everything they wish to say in one contribution, as normally no further opportunity will arise. It must be noted that only relevant planning considerations can be taken into account when considering planning applications (see ‘determining planning applications’ for details).

4. Members of the Committee may wish to ask questions. The speaker should return to the public seating area. There will be no further input or interruption from members of the public.

5. The Applicant and or their representatives will be invited to address the Committee, once all other parties have spoken, in order to respond to any points raised by previous speakers or Members.

6. The public will be able to listen to the Councillors’ discussing the item and coming to a decision. The Chair will then announce the decision.

LEAD OFFICERS Victoria Geoghegan Assistant Director (Planning and Building Control) Alex Smith Major Developments Manager - Major Projects Neil Willey Area Development Manager West Louise Macionis Area Development Manager East Eleanor Penn Legal Adviser – Planning Committee Clerk Corporate Governance Officer - as per the agenda

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Page 10 WOOLWICH & THAMEASMEAD AREA PLANNING ITEM NO COMMITTEE 3 TITLE WARD(S) Declarations of Interests All DECISION CLASSIFICATION FINAL DECISION Non-key To be made at this meeting on the recommendations in this report

1. Decisions Required

The Area Planning Committee is requested to:

1.1 Note the list of Councilor’s memberships (as Council appointed representatives) on outside bodies, joint committees, and school governing bodies.

1.2 Request that Members orally declare any personal or financial interests, including those detailed, in specific items listed on the agenda as they relate to matters under discussion.

2. Members’ Interests

2.1 Appended to this report is a list of the outside bodies, joint committees, and school governing bodies that each member has been appointed to by the Council or the Leader. The list does not include bodies with which a Member is involved in a personal or private capacity.

Personal interests 2.2 A Member has a personal interest where any business is likely to affect:

(a) them, or

(b) a relevant person or a relevant body (where the Member is aware that they have the interest);

more than a majority of those in the ward you represent.

ITEM NO: 3 Page 11 A relevant person is defined as the member’s spouse or civil partner, a person who they are living with as husband and wife or as civil partners, or a person with whom they have a close association.1

A relevant body is defined as (a) any organisation, school governing body or outside committee or trust which they have been appointed to by the Royal Borough or by the Leader, or (b) any other voluntary organisation, school governing body or commercial organisation where you are a management committee member, school governor, trustee or director.

2.3 Members must declare the existence and nature of any personal interest at the start of the meeting, or when the interest becomes apparent. Members must say which item their interest relates to.

2.4 A Member who has a personal interest may stay, speak, and vote, except where the business:

(a) affects the financial position of the Member or any person or body described in paragraph 2.2 above, or

(b) relates to an interest that would be affected financially or relates to the determining to any approval, consent, licence, permission or registration in relation to the Member or any person or body described in paragraph 2.2 above

Financial Interests 2.5 A Member has a financial interest where any business relates to or is likely to affect an interest set out in paragraph 18 of the Code of Conduct, and which is the Member’s interest, or the interest of a person described in paragraph 2.2(a) above.

2.6 Members must declare the existence and nature of any financial interest at the start of the meeting, or when the interest becomes apparent. Members must say which item their interest relates to.

2.7 A Member who has a financial interest must leave the meeting, but may attend to make representations, answer questions or give evidence relating to the business, provided that the public are also allowed to attend the meeting for the same purpose, and provided they leave the meeting immediately after doing so. The Member must not participate in the discussion nor the vote.

1 See the guidance in Annex 1of the Code of Conduct ITEM NO: 3 Page 12 General 2.8 The Code also requires Members to declare interests in relation to relevant bodies for six months after ceasing from being a member and take the appropriate action in relation to financial interests.

Background Papers

Agenda and Minutes of the Annual Meeting of the Council – 19 May 2021

Report Author: Jean Riddler - Committee Services Officer Tel: 020 8921 5857 Email: [email protected]

Reporting to: Anthony Soyinka – Committee Services Manager Tel: 020 8921 2230 Email: [email protected]

ITEM NO: 3 Page 13

Page 14 Councillor Organisation Role Governorship Bauer Greenwich Leisure Ltd Deputy Bauer Overview & Scrutiny Joint Health Committee Deputy Brain DG Cities Limited Member Brain Greenwich Millennium Village Management Ltd Deputy Brain Greenwich Service Solutions Member Dillon Greenwich Housing Rights Member Thorntree Primary School Dillon Greenwich Service Plus Member Dillon Greenwich Wildlife Advisory Group Member Fahy Greenwich Co-operative Development Agency Member Fahy Learning Disability Partnership Member Hills Overview & Scrutiny Joint Health Committee Deputy Greenacres Primary School Lekau Environmental Protection UK Member Mardner - Abbey Wood Nursery School Mardner - St Pauls Academy Mbang Greater London Forum for Older People Member Mbang New Charlton Community Centre Member Mbang Overview & Scrutiny Joint Health Committee Deputy Mbang Town Twinning Association Executive Committee Deputy Mbang Walpole Estate Management Board Member

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Page 16 WOOLWICH AND THAMESMEAD AREA Agenda Item: 4 PLANNING COMMITTEE Reference No: 22 June 2021 21/0701/F

Applicant: Danshe Ltd Agent: Mr Ottery - P E Ottery Dip TP MRTPI

Site Address: Ward: Plumstead 8 Streamdale, Abbey Wood, London, Application Type: Full Planning SE2 0PD Permission

1. Recommendation

1.1 The Committee is requested to grant full planning permission as outlined below:

• Part-retrospective application for the construction of two (2) single storey rear extensions and other associated external alterations to allow the conversion of the house into two (2) self-contained C3 houses. (Resubmission).

1.2 Subject to:

i. To resolve to grant conditional planning permission according to the conditions in appendix 2, to be detailed in the notice of determination; and ii. To Authorise the Assistant Director of Planning & Building Control to make any minor change to the detailed working of the recommended conditions, as set out in the report and its addendums, where the Assistant Director of Planning & Building Control considers it appropriate, before issuing the decision notice.

ITEM NO: 4 Page 17 2 Summary

2.1 Detailed below is a summary of the application:

The Site Site Area (m²) 596 Local Plan Allocation Area of Special Character Close to Metropolitan Open Land Close to Southeast London Greenchain Close to Site of Nature Conservation Importance Heritage Assets None Tree Preservation Order None Flood Risk Zone None

Existing Building (86 Streamdale) Building height (metres) 8.25 No. of storeys 2 (not including loft conversion) Gross Internal Area, across all storeys (m2) 138.12

Transportation Car Parking No. Proposed Car 1 Parking Spaces Cycle Parking No. Proposed Cycle No details provided Parking Public Transport PTAL Rating 1b (very low)

Public Consultation Neighbours in Support None Neighbours in objection 9

2.2 This application has been called into committee by Councillor Cornforth, has set out that the application was called in due to the high amount of local interest in the site.

2.3 Additionally, this application has received nine (9) representations in objection to the proposal, which surpasses the set threshold for applications to be determined under delegated powers.

2.4 The report details all relevant national, regional and local policy implications of the scheme, including supplementary planning guidance.

ITEM NO: 4 Page 18

2.5 The application is considered to be acceptable and is recommended for approval subject to that set out in section 1.1 above.

Site Plan

3 Site and Surroundings

3.1 The application site is 8 Streamdale, Abbey Wood, London, SE2 0PD.

3.2 The application site comprises a two-storey end of terrace dwelling and is located on the eastern side of Streamdale.

3.3 The surrounding area is residential in character, with the surrounding properties having a generally similar appearance to the host dwelling.

3.4 An existing front and rear dormer extension and two-storey side extension exist at the property. Both of these were granted planning consent 40 years ago (relevant permissions dated 1981 and 1980).

3.5 The property is not in a conservation area, is not a statutorily or locally listed building, is not subject to a relevant Article 4 Direction, and has not had its permitted development rights removed. 3.6 Whilst the site is reasonably close to Metropolitan open land, the south-east London Green Chain, and a site of Nature Conservation Importance, given

ITEM NO: 4 Page 19 the sites positioning and the proposals extremely minimal external alterations beyond that of the existing lawful situation, it is considered that the development would not tangibly impact these designated areas.

3.7 The application site has a Public Transport Accessibility Level (PTAL) rating of 1b, suggesting very poor connectivity to public transport links. The site is not within a Controlled Parking Zone (CPZ).

4. Relevant Planning History

20/2052/F Refusal: Appeal Ref: Refusal, 03/06/2020 App Decision APP/E5330/ Decision: Appeal Appeal Number: Date: W/20/3260 Dismissed Dismissed: 115 22/01/2021 Address: 8 Streamdale, Abbey Wood, London, SE2 0PD Construction of two (2) single storey rear extensions and other Description: associated external alterations to allow the conversion of the house into two (2) self-contained C3 units. (Resubmission) 1. The principle of the proposed residential conversion is not considered to be acceptable as the gross net floor area of the original dwelling does not meet the minimum requirements for conversions which would also detract from the character, safety and free flow of traffic in the area. As such, the proposal would have a detrimental impact on the local environment generally and is not in accordance with Policy H(b) of the Royal Greenwich Local Plan: Core Strategy with Detailed Policies (2014).

Officer Comment: The inspector concluded that the proposed development would not result in the unacceptable loss of a small or Reasons for medium sized dwelling, despite the conflict with Policy H(b) of the CS. This refusal: aspect of the proposal is further discussed in the “principle of development” section of the report below.

2. The proposed extensions, cumulatively, when taking into consideration the existing non-original additions at the property, would result in a jarring development that would also be excessive in size, scale and bulk and thereby would detract from the visual character, legibility and amenity of the host property and the surrounding area. As such, the proposal would not be in accordance with Policies 3.5, 7.4 and 7.6 of the London Plan (2016), Policies DH1, DH(a), H(b) and H5 of the Royal

ITEM NO: 4 Page 20 Greenwich Local Plan: Core Strategy with Detailed Policies (2014), and the Council's Residential Extensions, Basements and Conversions SPD (2018).

Officer Comment: The inspector concluded that the proposal would not have an adverse effect on the character and appearance of the area, and would comply with Policies 3.5, 7.4 and 7.6 of the London Plan (2016), Policies DH1, DH(a), H(b) and H5 of the CS in this respect.. This aspect of the proposal is further discussed in the “design” section of the report below.

3. The proposed development would provide a substandard quality of accommodation as it would not comply with the relevant space standards in affording poor and cramped living conditions for prospective occupiers of the new self-contained units. As such, the proposed development is considered to be contrary to Policy 3.5 of the London Plan (2016), Policies H5 and DH1 of the Royal Greenwich Local Plan: Core Strategy with Detailed Policies (2014), the Technical Housing Standards (2015) and the Mayor of London Housing SPG (2016).

Officer Comment: The inspector concluded that the proposed three bedroomed house would provide acceptable living conditions for future occupiers, and would comply with Policy 3.5 of the London Plan and Policies H5 and DH1 of the CS. Further discussion of this point is provided in the “Quality of Accommodation” section of the report below.

4. The proposed development would not provide sufficient space within the front forecourt to allow for the provision of both waste bins and the 2 off-street parking spaces to serve the proposed dwellings. Furthermore, in the absence of a parking stress survey to demonstrate the surrounding area has capacity to absorb any potential overspill parking, the proposed development is considered to be contrary to Policy 6.10 of the London Plan (2016) and Policies IM4, IM(a) and IM(c) of the Royal Greenwich Local Plan: Core Strategy with Detailed Policies (2014).

Officer Comment: This reason for refusal was upheld at appeal. To overcome this reason for refusal, this application provides a parking survey. Further discussion of these points is set out in the “Waste and Refuse” and “Transport/ Highways Impacts” section of the report below.

ITEM NO: 4 Page 21 App Decision 20/0945/F Decision: Refusal 03/06/2020 Number: Date: Address: 8 Streamdale, Abbey Wood, London, SE2 0PD Construction of a single storey rear infill extension, part-one, part- two storey side extension, rear dormer roof extension and Description: conversion of house into 2 residential dwellings. (Amended Description) 1. The proposed residential conversion is not considered to be suitable as the gross net floor area of the original dwelling does not meet the minimum requirements for conversions. As such, the proposal would have an impact on the Borough’s small and medium family-sized dwelling stock and the local environment generally, and is not in accordance with Policy H(b) of the Royal Greenwich Local Plan: Core Strategy with Detailed Policies (2014) and Policy 3.8 of the London Plan (2016).

2. The proposed extensions, as a whole, by reason of their design, positioning and excessive size, would constitute bulky and dominant additions to the host building that would not remain secondary in size or appearance and would result the significant loss of open space between properties and the creation of a “terracing effect”. As such the proposal would not be in accordance with Policies 3.5, 7.4 and 7.6 of The London Plan Reasons for (2016), Policies DH1, DH(a), H(b) and H5 of the Royal refusal: Greenwich Local Plan: Core Strategy with Detailed Policies (2014), and the Council's Residential Extensions, Basements and Conversions SPD (2018).

3. The proposed development would provide a substandard quality of accommodation and it would not comply with the relevant space standards in affording poor living conditions for prospective occupiers of the new self-contained units. As such, the proposed development is considered to be not be in accordance with Policy 3.5 of the London Plan (2016), Policies H5 and DH1 of the Royal Greenwich Local Plan: Core Strategy with Detailed Policies (2014), the Technical Housing Standards (2015) and the Mayor of London Housing SPG (2016).

4. The proposal fails to demonstrate how refuse bins can be adequately stored on the site and would therefore conflict with the aims and objectives of Policy H5 of the Royal Greenwich

ITEM NO: 4 Page 22 Local Plan: Core Strategy with Detailed Policies (2014) and Policy 5.16 of the London Plan (2016).

App Decision 20/1245/PN1 Decision: Refusal 09/06/2020 Number: Date: Address: 8 Streamdale, Abbey Wood, London, SE2 0PD Prior Approval for the construction of a single storey rear extension which will extend beyond the rear wall of the original dwelling by 3.7 Description: metres, for which the maximum height will be 3.5 metres and the height at the eaves will be 2.5 metres. 1. The proposal plans include works relating to the subdivision of a dwelling house which has not been granted planning permission. As such, the proposal does not comply with Schedule 2 of the Town and Country Planning (General Permitted Development) (England) Order 2015 (as amended).

2. The proposed rear extension would be joined to an existing non- original two storey side extension. The resultant total enlargement Reasons for would exceed 4 metres in height. The resultant total enlargement refusal: would have more than one storey and would extend beyond the rear wall of the original dwellinghouse by more than 3 metres. The proposed total enlargement would be within 2 metres of the boundary of the curtilage of the dwellinghouse and would have a height of the eaves exceeding 3m. As such, the proposal does not comply with Schedule 2, Part 1, Class A, criteria (ja) of the Town and Country Planning (General Permitted Development) (England) Order 2015 (as amended).

App Decision 20/0938/PN1 Decision: Refuse 29/04/2020 Number: Date: Address: 8 Streamdale, Abbey Wood, London, SE2 0PD Prior Approval for the construction of a single storey rear extension which will extend beyond the rear wall of the original dwelling by 3.7 Description: metres, for which the maximum height will be 3.5 metres and the height at the eaves will be 2.5 metres. The proposal plans include works relating to the subdivision of a dwelling house which has not been granted planning permission. As Reasons for such, the proposal does not comply with Schedule 2 of the Town and refusal: Country Planning (General Permitted Development) (England) Order 2015 (as amended). Prior approval is therefore refused in this instance.

ITEM NO: 4 Page 23

No breach (property Enforcement Decision E/20/0508 Findings: not in use 02/02/2021 reference: Date: as 2 dwellings) Address: 8 Streamdale, Abbey Wood, London, SE2 0PD Description: Conversion of the property into 2 self-contained units

App Decision 19/4368/F Decision: Withdrawn 25/02/2020 Number: Date: Address: 8 Streamdale, Abbey Wood, London, SE2 0PD Subdivision of existing house to provide 2 self contained units, incorporating the construction of rear infill and side extensions, Description: removal of front porch, creation of a 2nd front door, installation of window at front elevation, changes to windows at side elevation, together with other associated external works.

App Decision 97/0667/F Decision: Refused 12/06/1997 Number: Date: Address: 8 Streamdale, Abbey Wood, London, SE2 0PD Retrospective application for a conversion to form two separate self- Description: contained three bedroom maisonettes. 1. The proposed separation of the existing residential property would represent an unsatisfactory layout and relationship with the original dwelling not suitable for conversion and result in an over- intensification of use, to the detriment of the amenity of existing and future occupants of the property being contrary to policies H2, H3 and H19 of the Unitary Development Plan and the Councils Advice Note 3 on Planning Standards for Conversions 2. The proposed access arrangements to the rear of the existing Reasons for property via the side of the property would be a sole means of refusal: access to the proposed residential accommodation to the detrimental of the personal safety and security, amenities and living environment of the future occupiers of the residential accommodation and contrary to policies H14, H18 and D11 of the Unitary Development Plan. 3. The proposed development together with the existing property and its front garden, triangular shaped in nature, at the end of the cul-de-sac does not provide adequate accommodation for the parking or garaging of vehicles off the highway and is likely to lead ITEM NO: 4 Page 24 to car parking which would be inconvenient to other road users and be detrimental to the residential amenities contrary to parking standards policy M32 of the Unitary Development Plan

App Decision 81/0753 Decision: Approved 21/10/1981 Number: Date: Address: 8 Streamdale, Abbey Wood, London, SE2 0PD Conversion of roof space to provide additional bedroom Description: accommodation

App Decision 80/0219 Decision: Approved 05/08/1980 Number: Date: Address: 8 Streamdale, Abbey Wood, London, SE2 0PD

5. Proposals (in detail)

5.1 The current application seeks full planning permission for the following:

5.2 The southernmost proposed single storey rear extension would have a depth of 3.7m and a width of 5.4m, with a mono-pitched roof construction including two (2) roof lights. This element would have a maximum height of 3.45m and a height to the eaves of 2.61m.

5.3 The proposed north-easternmost single storey rear extension would exist as a subtle extension from the rear of the existing non-original single storey side element. This would continue this element by an additional 1.7m, maintaining the existing height and width.

5.4 The other subtle alterations to aid in the conversion of the property would include alterations to the existing porch structure and the installation of a new front access door at the northernmost point on the front elevation.

5.5 The proposed development would primarily make use of materials that would match those used in the existing dwelling, though the flat roof elements would utilise fibreglass, the new front doors would be timber and partially glazed, and the proposed rear doors and new windows would be made of aluminium.

ITEM NO: 4 Page 25 5.6 As part of the submissions, the applicants have provided pre-existing, as existing, and proposed drawings. As it stands, internal works to separate the building into two distinct properties have been undertaken, and it is understood that one of the properties is currently occupied. The garden has also been separated into two with the erection of a boundary fence in the rear back garden space. It is understood that the proposed extension works, new access door or porch alterations brought forward in this application have not been undertaken at the time of writing.

The resultant accommodation units are proposed as follows: Unit A: Ground floor: Hall, Living room, Dining Room with incorporated kitchen space, toilet, Two (2) Storage spaces. First floor: One (1) single bedroom, One (1) double bedroom, hall, bathroom Second floor: one (1) double bedroom, ensuite bathroom.

Unit B: Ground Floor: Hall, three (3) storage spaces, Incorporated Living/Dining/Kitchen Space. First Floor: Hall, Bathroom, one (1) single bedroom, one (1) double bedroom

5.7 The proposed development brings forward the retention of the existing one (1) off-street parking space on the front forecourt.

5.8 Officers would like to emphasise that this application is a near identical application to that which was refused as part of application 20/2052/F. The only differences between this application and application 20/2052/F is that the proposed number of parking spaces on the forecourt has been reduced from 2 to 1, a parking survey has been submitted and the submissions accurately represent the part-retrospective nature of the development. Officers note that the principle of conversion, design and quality of accommodation have all been considered to be acceptable by the planning inspectorate at appeal.

6. Consultation

6.1 The application since being submitted in February 2021 has been subject to public consultation comprising of a site notice and thirteen (13) neighbour notification letters sent to occupiers within the vicinity of the application site.

6.2 Following discussions with the planning agent, additional submissions were received representing the part-retrospective nature of the proposals. To ITEM NO: 4 Page 26 allow neighbours to consider and make representations on these drawings, re-consultation did take place with respect to these new submissions.

6.3 Nine (9) representations were received from neighbours, all in objection to the proposed development. A summary of the neighbour objections is provided below:

Summary of Comments Officers comments Concern that the conversion would This aspect of the proposal is upset the established pattern of addressed in the Principle of development of the cul-de-sac. Development and Design sections in the bulk of the report. Concern that the submitted parking The Local Authorities Transport and survey is inaccurate and does not paint Highways Department have assessed a representative picture of the area, and reviewed the submitted parking particularly given that such a survey survey and have considered the would have been undertaken during conclusions to be measured on COVID-19 balance. This aspect of the proposal is further discussed in the “Transport and Highways Impacts” section of the report below. Concern that the proposed extension This aspect of the proposal is works would be excessive given the size addressed in the Design section of of the original dwelling. the report.

Concern that the proposed This aspect of the proposal is development would result in a poor addressed in the “Quality of quality of accommodation to Accommodation” section of the prospective tenants report below. Concern that the two-storey side This aspect of the proposal is extension and rear dormer extension addressed in the Design section of are already existing. the report. Any aspects of the proposal which have been implemented without the benefit of formal planning consent would be subject to possible enforcement action. Concern that the property has already This is not a planning consideration. been purchased as two dwellings.

Concern that the proposal would This aspect of the proposal is induce unacceptable parking stress and addressed below in the Transport vehicular traffic on the area. section of the report. ITEM NO: 4 Page 27 Concern that the provision of only one This aspect of the proposal is off street parking space in a forecourt addressed below in the Transport covering two properties would cause section of the report. domestic disputes between . Concern that the proposal would result This aspect of the proposal is in the loss of a large family home. addressed in the Principle section of the report.

Concern that the proposal would result This is not a planning consideration. in unacceptable pressure on the sewage system Concern that the proposal would result This aspect of the proposal is in an unacceptable loss of privacy to the addressed in the Amenity section of nearby dwellings. the report.

Concern that the proposal would result This aspect of the proposal is in a significant loss of light to the nearby addressed in the Amenity section of properties. the report.

Concern that the proposal would This aspect of the proposal is damage the character and appearance of addressed in the Design section of the wider street. the report. Concern that there have been Each application is assessed on its numerous refused previous applications own merits. at the property. Concern that the additional dwelling This aspect of the proposal is would present noise related issues in addressed in the Amenity section of the street. the report. Concern that one of the proposed Not a planning consideration as this is internal staircases would not conform related to building control to building regulations regulations.

Concern that the applicants do not own Following discussions with the all the land and have submitted the planning agent, the planning agent incorrect ownership certificate. confirmed that the ownership certificate submitted for this application was correct at the time of reception. Concern that any construction works Construction hours are set by the would cause disruption to residents in councils Environmental Health the local area. Department. This is also further

ITEM NO: 4 Page 28 discussed in the amenity section of this report. Concern that the developer is not of This is not a planning consideration. good character. Concern that the current occupier of This is not a planning consideration. the application property would not agree for the works to be undertaken. Concern that the construction phase of The construction phase of any the proposal would result in traffic and development would be only amenity impacts. temporary and so this could not constitute a reasonable reason for refusal. A condition is sought to be attached to the decision notice requiring a construction management plan to be submitted and approved by the Local Planning Authority so as to ensure that the Transport and Amenity impacts from the construction phase are reasonably mitigated. Concern that the proposed This is not a planning consideration as development would set a precedent for all applications are assessed on their similar proposals in the future own merits and only with respect to policy. Concern that trees in adjacent sites may Examining digital imagery, it is clear be negatively affected should the that the proposed works would be proposed development go ahead. significantly far away from any trees within the site or otherwise. Development that might affect parts of land outside the application site is subject to a Party Wall Agreement and is not a consideration of a planning application.

6.4 Councillors As noted in section 2.2 of the report, this has been called before committee by Councillor Cornforth for members to decide. Councillor Cornforth did not provide any reason for calling the application into committee at the time of call in.

6.5 Responses from Council Departments A summary of the consultation responses received along with the officer comments are set out in table below: ITEM NO: 4 Page 29

Details of Summary of Comments Officers comments Representation and date received Initial Comments: The transport and Transport and highways impact of the Highways: “Given the parking availability proposal is assessed in identified by survey, on section 14 below. balance, no highway objection is raised.”

Following further discussion, and an additional review in of the parking survey and objections received specifically relating to the inaccuracies, the following additional comments were received:

“Local resident concern is acknowledged and was previously highlighted that parking could be an issue in previous applications and at appeal.

Since the dismissal of the appeal by the planning inspectorate it is accepted that there has been the introduction of the new London Plan.

Policy T1 of the new London Plan promotes a strategic approach to transport to support the Mayor’s strategic target of 80 per cent of all trips in London to be made by foot, cycle or public transport and create a shift from car ITEM NO: 4 Page 30 use to more space-efficient travel. Policy T2 Healthy Streets also recognises that Development proposals should deliver patterns of land use that facilitate residents making shorter, regular trips by walking or cycling.

Policy T6 of The London Plan highlight that although starting point for new developments in areas of good access to public transport and there are CPZ restrictions should be car free, it does acknowledge that where this is not the case some parking could be accepted. Table 10.6 of the London Plan indicates that in inner London sites with a poor PTAL such as this site, should have a maximum car park requirement of up to 0.75 space for each unit.

The proposed development at 8 Streamdale will result in the provision of 2 residential dwellings at the site, which would require a maximum of 1.5 spaces to be provided. As the site can accommodate one parked vehicle, this would be policy compliant although the proposal may result in overspill parking of additional vehicle on-street.

In support of the application, and given the previous concerns, a parking survey was ITEM NO: 4 Page 31 undertaken of the area to determine the level of on street parking. From the results, it appears that the roads have sufficient opportunity to accommodate additional parking although there could be few general parking spaces near the site.

The surveys were carried out overnight on 2 evenings at a time when most residents would be expected to be at home and therefore create the biggest resident demand. Given the Pandemic at the time where most people were advised to stay home, this is likely to be the maximum residential demand. The surveys were undertaken in accordance with recognised methodology within the accepted 2-minute walk distance.

The survey results were fairly consistent for both survey nights indicating parking stress levels of around 73 and 74%. This reflects that there is heavy demand for parking at the kerbside but also that there is limited opportunity for additional vehicles. The surveys indicate that while future occupants may not be able to park immediately outside the premises, there was still opportunity for 18 vehicles to park on unrestricted

ITEM NO: 4 Page 32 carriageway overnight in the study zone.

On balance, given the above, no highway objection is raised.” Waste “We are satisfied with the The waste related Services: proposal.” aspects of this proposal are discussed at section 16 below. Housing “We have previously been The compliance with Occupational advised by Planning that accessibility policies as Therapy: compliance with M4(2) cannot set out in the London be enforced when an extension Plan (2021) is not of a property occurs. required for house conversions. It is however recommended that the applicant considers These aspects of the amending the entrance level proposal are further toilets to comply with Diagram discussed within section 1.4 and the bathroom layouts 13 of the report below. to comply with Diagram 2.7 of the Approved Document M4 category 2: accessible and adaptable dwellings.” Environmental No response received. The noise and other Protection: neighbouring amenity related aspects of this proposal are assessed in section 12 below.

7. Planning Context

7.1 This application needs to be considered in the context of a range of national, regional and local planning policies and Supplementary Planning Guidance / Documents.

• National Planning Policy Framework (NPPF – 2012) • The London Plan (March 2021) • The Royal Greenwich Local Plan: Core Strategy with Detailed Policies (“Core Strategy” – 2014)

ITEM NO: 4 Page 33 • New Developments: Guidance Notes for the storage and collection of waste and recycling materials for the Royal Borough of Greenwich (May 2018) • Mayors Housing SPG (2016) • Greener Greenwich SPD (2014)

7.2 For full details relevant policies, SPDs and other documents, refer to Appendix 3.

8. Material Planning Considerations

• Principle of development; o Creation of a new residential unit o Conversion of the previously lawful single dwelling into two properties o Density • Design • Quality of living environment provided for future residents; o Unit Sizes o Bedroom Size o Bathroom Provision o Floor to Ceiling Heights o Outdoor Space provision o Other internal amenity Considerations • Impact on neighbouring amenity • Inclusive Design • Transport and Highways Impacts • Cycle Parking • Waste and Refuse Storage • Sustainability • Community Infrastructure Levy (CIL); • RBG CIL;

9. Principle of Development

9.1 The overriding objective of the Royal Greenwich policy framework is to deliver high quality development which improves the quality and distinctive identity of places and contributes to their success and the area’s popularity as somewhere to live, work and stay. ITEM NO: 4 Page 34

Creation of a new residential unit

9.2 Policy H1 of the London Plan (2021) clearly sets out the pressing need for more homes in London in order to promote opportunity and provide a real choice for all Londoners in ways that meet their needs at a price they can afford.

9.3 Policy H2 of the LP states that boroughs should pro-actively support well- designed new homes on small sites through both planning decisions and small sites.

9.4 Policy H2 of the Core Strategy 2014 (CS) promotes a mix of housing types and sizes, varying according to the location of the development and the character of the surrounding area. Other relevant considerations include; the level of accessibility to public transport, schemes for special needs groups, or where there is a poor external environment.

9.5 The addition of one residential unit, over and above the previously existing lawful situation on the site is considered acceptable in principle in meeting the housing targets of Royal Greenwich and London in general, subject to demonstrating design quality and addressing potential amenity impacts are to be met.

Conversion of previously existing single dwelling into two self-contained houses

9.6 Policy H(b) of the CS makes it clear that the conversion of small and medium sized dwellings into residential units is not supported if the original premises is less than 130sqm of net floor area (criteria i), if on-street parking would aggravate the safety and free flow of traffic (criteria ii), or if the character and appearance of the surrounding area and buildings is adversely affected (criteria iii).

9.7 The previous application at this site, 20/2052/F, refused a proposal for a development of the same layout as that which is brought forward in this proposal, as it was considered that the principle of the proposed residential conversion was not acceptable as the original building, prior to the extension works in the 1980’s, did not meet the 130sqm threshold.

9.8 With respect to the above point, the appeal inspector ultimately came to the below conclusion:

ITEM NO: 4 Page 35 “I can fully understand the Council framing Policy H(b) in terms of the original dwelling, to prevent the extension of a property taking it above the threshold before an application is submitted for a conversion. However, in this case, the house was extended to take it beyond the 130 square metre threshold as long ago as the 1980s. It has not been a small or medium sized dwelling for over 30 years.

The proposal is contrary to Policy H(b), because of the size of the original dwelling. However, because it became a substantial house many decades ago, the aim of this element of the policy, to maintain a stock of small and medium sized family dwellings, would not be infringed. In respect of this main issue, I consider this to be an occasion where material considerations indicate a decision otherwise than in accordance with the development plan. I conclude that the proposed development would not result in the unacceptable loss of a small or medium sized dwelling, despite the conflict with Policy H(b) of the CS.”

9.9 With respect to the above points, given that the proposed development would maintain the stock of small and medium sized family dwellings, and acknowledging the previously existing lawful situation of the application building existing as a significantly extended extremely large dwellinghouse for a number of decades, the proposed development is considered to be acceptable with respect to this requirement, despite the conflict with Policy H(b) of the CS.

9.10 As set out in the relevant sections of the report below, the proposed development is not considered to result in an unacceptable impact on the character of the wider surrounding area nor is it considered to result in any unacceptable highways impacts.

Density

9.11 Whilst the new LP has removed the density matrix, it still requires an assessment of the suitability of the density of residential schemes. The London Plan now states that comparing density between schemes using a single measure can be misleading as it is heavily dependent on the area included in the planning application site boundary as well as the size of residential units.

9.12 Policy D3 of the LP states that higher density developments should generally be promoted in locations that are well connected to jobs, services, infrastructure and amenities by public transport, walking and cycling. This policy also states that In other areas, incremental densification should be actively encouraged by Boroughs to achieve a change in densities in the most appropriate way.

ITEM NO: 4 Page 36 9.13 To further support the above points, Policy H2 of the LP states that Boroughs should pro-actively support well-designed new homes on small sites through both planning decisions and plan-making in order to significantly increase the contribution of small sites to meeting London’s housing needs.

9.14 The site has an area of 596m², and with the addition of the proposed new dwelling on site would have 7 habitable rooms (across both prospective dwellings). As such, the site would have a density of 285.6HRH. Given the scale of development with relation to large size of the plot and taking into account the relatively minor scope of the proposed extension works beyond the lawful situation at the property, it is considered that the density proposed for the development would be acceptable.

9.15 With reference to the above points, it is considered that the proposed development is acceptable in principle and would be in accordance with Policies D3, H1 and H2 of the London Plan (2021) and Policies H2 and H(b) of the Royal Greenwich Local Plan: Cores Strategy with Detailed Policies (2014).

10. Design

10.1 Policy D3 of the LP states that development proposals should be of high quality, enhancing local context by delivering buildings and spaces that positively respond to local distinctiveness through their layout, orientation, scale, appearance and shape, with due regard to existing and emerging street hierarchy, building types, forms and proportions.

10.2 Policy DH1 of the CS requires all developments to be of a high quality of design and demonstrate that they positively contribute to the improvement of both the built and natural environments.

10.3 Officers acknowledge that previous application 20/2052/F presented a scheme with exactly the same proposed built form as that which is brought forward in this proposal. Application 20/2052/F was refused on the basis that the cumulative impact of the proposed extension works, when taking into account the existing non-original extensions at the property, was considered to have resulted in a jarring development that would have been excessive in size, scale and bulk and would have detracted from the visual character, legibility and amenity of the host property and surrounding area.

10.4 In the appeal decision of application 20/2052/F, the Inspector did not agree with the Council’s conclusions and instead made the following comments in relation to the suitability of the design of the proposal: ITEM NO: 4 Page 37

“The Council argues that the two single storey rear extensions are unacceptable, because they “would mean that the application building as it originally existed would be completely dominated by non-original elements”. However, it is quite clear that the property is already dominated by non-original elements, and has been for over 30 years. This proposal must be determined on its own merits. The only impact from the building works proposed on the elevations of the property seen from the road is the removal of the front porch. The two single storey extensions proposed as part of this proposal are only visible from within the site and do not in themselves cause any harm to the character or appearance of the dwelling or the wider area.”

“I therefore conclude that the proposed development would not have an adverse effect on the character and appearance of the area, and would comply with Policies 3.5, 7.4 and 7.6 of the London Plan (2016), Policies DH1, DH(a), H(b) and H5 of the CS in this respect. These policies seek, amongst other things, development that provides a positive relationship between the proposed and existing urban context, and extensions of a scale and design appropriate to the building and locality.”

10.5 Whilst officers do acknowledge that there has been an extremely subtle design policy change in the adoption of the new 2021 London Plan, ultimately those relevant design policies as set out above are considered to be similar in their aims and scope. As such, the inspectors assessment of the previously identical proposal submitted as part of application 20/2052/F holds significant weight in the planning balance in this instance.

10.6 Indeed, and with reference to the above justification, officers do agree that the proposed development, would not result in a significantly detrimental impact on the character of the application site or wider surrounding area beyond the lawful situation. This is particularly relevant given how the proposed new extension works would be positioned to the rear and would not be visible from the public realm.

10.7 Whilst the development would result in the alteration of some elements of the front elevation of the dwellinghouse, including the removal of the front porch element and the addition of a front door to serve the new dwellinghouse, it is considered that these aspects would not result in an unacceptable design impact on the character of the application building or wider surrounding area.

10.8 The proposed development is therefore considered to be generally in accordance with Policy D3 of the London Plan (2021) as well as Policy DH1 and H5 of the Royal Greenwich Local Plan: Core Strategy with Detailed Policies (2014). ITEM NO: 4 Page 38

11. Quality of Living Environment provided for future residents

11.1 Policy D6 of the LP and Policies H5 and DH1 of the CS require that all new housing developments achieve a high quality of design. These policies also refer to the Technical Housing Standards – Nationally Described Space Standard (Technical Housing Standards) and are supported by the Mayor of London Housing SPG (Mayor’s Housing SPG).

Unit Size

11.2 The following sets out the relevant ‘Minimum Space Standards for New Dwellings as per the Technical Housing Standards and Table 3.1 of the London Plan. Category/ Proposed Proposed Requireme Unit A Unit A nt Complies? Number of Bedrooms 3 5 N/A Number of Bed Spaces 3 5 N/A Minimum GIA (3 99sqm 96.5sqm No Storey Dwelling) Built-in storage 2.5sqm 2.6sqm Yes

Category/ Proposed Proposed Requireme Unit A Unit A nt Complies? Number of Bedrooms 2 3 N/A Number of Bed Spaces 2 3 N/A Minimum GIA (2 70sqm 72.88sqm Yes Storey Dwelling) Built-in storage 2.0sqm 2.34sqm Yes

11.3 Whilst Unit B meets the required Minimum Gross Internal Area, Unit A does not meet the relevant Gross internal area requirement and also would not comply with the internal space storage requirement for a 3-bedroom five person dwelling.

11.4 However, it is acknowledged that this layout is identical to that which was brought forward in application 20/2052/F, for which the appeal inspector commented the below in their decision.

“The Council states that the original 8 Streamdale, before it was extended, had a net floor area of just over 77 square metres. From the evidence before me, it

ITEM NO: 4 Page 39 appears that the original house was a three bedroom (two double bedrooms and a single bedroom) five person dwelling, no doubt typical of many in the area.

The proposed three bedroom house is essentially the original house, with a staircase replacing one bedroom on the first floor, leading to a second floor bedroom that would now be part of this house. The number of bedrooms and likely occupiers would thus be the same as in the original dwelling, whilst the accommodation would be significantly larger, including as it would an extended kitchen/dining room on the ground floor. The proposal would therefore result in a house very close in GIA, by the Council’s calculations, to the minimum required by […] the London Plan, and of significantly greater GIA than the original house, which would have been intended for the same number of occupiers. In the circumstances, I consider that the GIA proposed would be acceptable.”

11.5 As such, and with reference to the above assessment and the closeness in size of the resultant proposed dwellings to the required minimum standard, it is considered that the proposed Gross Internal Floor Area of the prospective dwellings would be acceptable in this instance.

Bedroom Sizes

11.6 Pursuant to the Technical Housing Standards, a dwelling with two (2) or more bedspaces must have at least one (1) double (or twin) bedroom. A double or twin bedroom with two (2) bed spaces is required to have a minimum floor area of at least 11.5m² and a width of 2.75m. A single bedroom with one (1) bed space is required to have a minimum floor area of 7.5m² and be at least 2.15m wide.

11.7 Examining the proposed bedspaces shown on the drawings, Unit A is therefore shown to be a three bedroom, five person unit (3b5p). Unit B is shown to be a two bedroom, three person unit (2b3p).

11.8 In Unit A, bedroom A1 would have a floor area of 11.3sqm, which does not comply with the relevant floorspace requirements for double bedrooms as set out in the Nationally Described Space Standards. In Unit B, bedroom B1 would have a floor area of 10.67sqm which would not comply with the relevant floorspace requirements for double bedrooms as set out in the Nationally Described Space Standards.

11.9 Whilst the above is acknowledged, officers must reiterate that the previous in the previous appeal at this site, which examined an identical floor layout to

ITEM NO: 4 Page 40 that which is presented in this application, the appeal inspector raised no objection to the sizes of the prospective bedrooms.

11.10 Given the closeness of the proposed bedrooms to their relevant required standard, and taking into account how the provision of units this size would result in the retention of a family unit at the site whilst providing an uplift of housing in the borough in accordance with Policy H1 of the LP, it is considered that the proposed bedroom sizes brought forward in this proposal is considered to be acceptable in this instance. Bathroom Provision

11.11 The Technical Housing Standards require two and three storey dwellings to account for one (1) bathroom and one (1) additional WC/shower room.

11.12 The proposed development is compliant with the above requirement.

Floor to ceiling heights

11.13 It is noted that the Technical Housing Standards states that the minimum floor-to-ceiling height is 2.3m for at least 75% of the GIA. Standard 31 of the Mayor’s Housing SPG however ‘strongly encourages’ a minimum ceiling height of 2.5m for at least 75% of the GIA. However, the recently adopted London Plan (2021) sets out in Policy D6 that new dwellings should ensure that units have a minimum floor to ceiling height of 2.5m across 75% of the GIA.

11.14 As a conversion of an existing building, rather than a new build development, it is onerous to require the proposed development to comply with this standard.

11.15 In any case, the proposed development exhibits a Floor to Ceiling height of approximately 2.4m on average, which is considered to be a generous provision.

Outdoor Amenity Space

11.16 The Mayor’s Housing SPG also prescribes standards for outdoor space as follows: − Standard 26 – Minimum 5m² private outdoor space for 1-2 person dwellings and 1m² additional outdoor space per additional occupant. − Standard 27 – Minimum 1.5m width and depth for all private outdoor spaces.

ITEM NO: 4 Page 41 11.17 Examining the submitted proposed block plans, it is clear that both of the proposed resultant dwellings are in accordance with this requirement.

Outlook, privacy, access to daylight/sunlight and other considerations

11.18 Both of the proposed dwellings would be dual aspect. The dining and living spaces for both units, given the number of windows, their size, and their orientation would receive direct sunlight for part of the day. It is considered that both of the proposed dwellings would receive an adequate level of level of daylight, sunlight, natural ventilation and outlook.

Conclusion:

11.19 Overall, it is considered that the proposal would provide an acceptable quality of accommodation for prospective residents and would therefore be in accordance with D6 of the London Plan (2021), the Technical Housing Standards – Nationally Described Space Standard (2015), the London Housing SPG (2016) and Policies H5 and DH1 of the Royal Greenwich Local Plan: Core Strategy with Detailed Policies (2014)

12 Impact on neighbouring amenity

12.1 Policy D14 of the LP sets out that development proposals should seek to proactively manage noise impacts in a variety of ways where possible. Proposals should use good design to mitigate and minimise existing and potential nuisances generated by uses and activities located in the area.

12.2 Policy DH(b) of the CS requires new development to demonstrate that there would be no significant loss of amenity to adjacent or nearby properties, by reducing the amount of daylight, sunlight, privacy or outlook they enjoy, by creating an unneighbourly sense of enclosure, or by unacceptably impacting the wind environment or microclimate.

12.3 Policy E(a) states that planning permission will not normally be granted where a proposed development or change of use would generally have a significant adverse effect on the amenities of adjacent occupiers or uses, and especially where proposals would be likely to result in the unacceptable emission of noise, light, vibrations, odours, fumes, dust, water and Soil pollutants or grit.

12.4 On the southernmost boundary, the proposed development would consist only of a single storey rear infill extension with a mono-pitched roof. This single storey rear extension would have a depth of 3.7m and a width of 5.4m, with a mono-pitched roof construction including two (2) roof lights. This ITEM NO: 4 Page 42 element would have a maximum height of 3.45m and a height to the eaves of 2.61m.

12.5 Given the single storey rear extensions relatively restricted dimensions, and also recognising the existing rear conservatory at No. 9 Streamdale, it is considered that the proposed development would not result in any significantly detrimental loss of daylight/ sunlight or increased sense of enclosure impacts to No. 9. As this extension would be single storey, and this element and the proposed new roof dormer element would not feature any new windows on a side elevation, it is considered that the proposed development would not result in any significant loss of privacy or increased sense of overlooking related impacts to No. 9.

12.6 Examining how the proposed development would only extend the northernmost single storey side element by 1.7m further to the rear, it is considered that this aspect of the proposed development would not bring forward any significantly detrimental amenity impacts to No. 7 Streamdale beyond the current lawful situation.

12.7 Taking into account the proposals nature, positioning, and significant distance away from the other nearby dwellings, it is considered that the proposed development would not result in any significant amenity impacts to these properties.

12.8 It is considered that splitting the current large single-family home into two dwellings would not, in this instance, create any significant noise increase to any nearby properties that would warrant a refusal in this case.

12.9 Objections have been received on noise disturbance during construction works. Given the temporary nature of these works, it is not considered reasonable to refuse the application on these grounds. Given the scale of external works proposed it is not considered necessary that a Construction Management Plan be secured through condition. Other matters relating to disturbance during construction and hours of works are controlled through Environmental Health legislation.

12.10 It is considered that the proposed development is therefore in accordance with Policy D14 of the adopted London Plan (2021) and Policies DH(b) and E(a) of the Royal Greenwich Local Plan: Core Strategy with Detailed Policies (2014).

13 Inclusive Design

ITEM NO: 4 Page 43 13.1 Policy D5 of the LP requires developments to achieve the highest standards of accessible and inclusive design.

13.2 Policy D7 of the LP also sets out that all new dwellings should meet Building Regulation requirement M4(2) ‘accessible and adaptable dwellings’.

13.3 CS Policy H5 supports the principles of inclusive living environment and Policy DH1 also states that all new developments should achieve accessible and inclusive environments. The proposed new dwellings at the application site are therefore expected to comply with Part M4(2) of the approved Building Regulations.

13.4 Standard 11 of the Mayors Housing SPG (2016) further states that:

13.5 “90 per cent of new build housing should meet Building Regulation requirement M4(2) ‘accessible and adaptable dwellings’ with the remaining 10 per cent meeting Building Regulation requirement M4(3) ‘wheelchair user dwellings’.”

13.6 As a house conversion and not a new build development, the proposed development is not required to be compliant with the above accessibility standards.

14 Transport and Highways Impacts

14.1 Policy T2 of the LP states that development proposals should deliver patterns of land use that facilitate residents making shorter, regular trips by walking or cycling. Policy T2 also states that development proposals should reduce the dominance of vehicles on London’s streets whether stationary or moving.

14.2 Policy T6 of the LP states that car-free development should be the starting point for all development proposals in places that are (or are planned to be) well-connected by public transport, with developments elsewhere designed to provide the minimum necessary parking.

14.3 Policy T6.1 further sets out that maximum parking provision for residential development should be in accordance with Table 10.3. The site has an access level (PTAL) of 1b, which indicates a relatively poor level of public transport accessibility. For a residential development of this size and location, the London Plan (2021) sets out that a maximum of 0.75 car spaces should be provided.

14.4 The site is not located within a Controlled Parking Zone (CPZ). ITEM NO: 4 Page 44

14.5 Officers acknowledge that the previous application at this site (20/2052/F) refused the application on the below reason:

“The proposed development would not provide sufficient space within the front forecourt to allow for the provision of both waste bins and the 2 off-street parking spaces to serve the proposed dwellings. Furthermore, in the absence of a parking stress survey to demonstrate the surrounding area has capacity to absorb any potential overspill parking, the proposed development is considered to be contrary to Policy 6.10 of the London Plan (2016) and Policies IM4, IM(a) and IM(c) of the Royal Greenwich Local Plan: Core Strategy with Detailed Policies (2014).”

14.6 It was cited in the delegated report of application 20/2052/F that the previous proposed provision of two (2) spaces on the front forecourt was not sufficiently justified as the provision of this many spaces on the small forecourt would conflict with the proposed location of the bin provision on the front forecourt.

14.7 Officers were also previously concerned that such a provision would result in overspill parking on the street, and with the absence of any parking survey to justify the potential uplift in street parking, this could result in unacceptable parking impacts.

14.8 The appeal inspector for the previous application ultimately upheld this reason for refusal, citing the below:

“The Council also refused the application on the grounds that there is insufficient space on the front forecourt to accommodate two off-street parking spaces and the necessary waste bins, and that no survey has been undertaken to demonstrate whether the area has the proposal to absorb any overspill parking.

The appellant’s statement of case does not deal with parking in any detail, stating only that the forecourt area would provide shared access and parking. From my site visit, it appeared that, once the porch has been demolished, and part of the front fence removed, it would probably be possible to park two cars on the forecourt, and to leave just enough space for the storage of refuse bins. However, whether it would be possible to independently access the two parking spaces was much less clear, as was whether accessing these spaces would be possible without encroaching on the drive of the adjoining house at No 7.

The proposed plans do not show how two parking spaces would be laid out on site. They do however show a proposed location for wheelie bins. It was apparent from my site visit and from the submitted plans that, if the refuse bins are indeed located ITEM NO: 4 Page 45 where they are shown on Drawing 120-D-76A, there would not be space for two parking spaces on site. I have considered whether imposing a condition requiring a plan to be submitted, showing two parking spaces and a space for refuse bins on site, could resolve the issue. However, as I cannot be certain that this could in fact be achieved, this would not be an appropriate way forward.

As a consequence of this lack of information with regard to parking, I cannot be certain that the proposed development would not give rise to difficult manoeuvres at the end of Streamdale, which would have the potential to harm highway safety.

In relation to the availability of on-street parking, I noted on my site visit that the first part of Streamdale, where it adjoins the return frontages of houses fronting Woodbrook Road, appeared to provide ample opportunity for parking on one side of the road. However, I cannot rely on my impressions from one visit alone and do not have before any other evidence as to whether a potential shortage of off-street parking would cause parking stress in the local area.

I therefore conclude that, in the absence of any evidence to show otherwise, the proposed development could have an adverse effect on highway safety, and is contrary to Policy IM(c) of the CS, which deals with parking standards.”

14.9 In an effort to overcome previous reasons for refusal, the proposed development does not bring forward any additional parking spaces beyond that which is already present on the forecourt. The proposal brings forward the retention of one (1) off street parking space as is the existing situation.

14.10 This is an acceptable parking provision when taking into account the existing lawful situation, the requirements of the London Plan (2021) and the extremely poor level of public transport accessibility at the site.

14.11 With reference to the low level of public transport accessibility in the area, it is anticipated that the surrounding area is one of heavy private car use. In an effort to justify how the uplift of one (1) residential unit would not result in unacceptable on street parking stress or unacceptable transport/ highways impacts on the area, the submissions for this application also bring forward a parking survey to assess the level of parking stress in the area.

14.12 A Parking Beat Survey was undertaken on Tuesday the 16th of February 2021 and Wednesday the 17th of February 2021 at 3am on both days, recording base levels of residential parking within a 200m radius of the application site.

ITEM NO: 4 Page 46 14.13 The survey submits that as the site can accommodate one parked vehicle off street, with an additional vehicle that might serve one of the two dwellings may have to be accommodated on street.

14.14 The parking survey utilised the Lambeth Methodology for parking beat surveys covering potential parking locations including dropped kerbs, unrestricted areas and yellow lines.

14.15 The parking survey sets out that a minimum of 18 parking spaces were available within a 200m walking distance of the site during both overnight survey periods. Therefore, with the addition of one additional vehicle from the proposed development, a total of 17 parking spaces would remain in the vicinity of the site, which if used would equate to a maximum parking stress of 76% during the busiest overnight period.

14.16 Given the above findings it is considered that the submissions demonstrate that the proposal would not result in any significantly detrimental parking or Transport and Highways impacts on the application site or surrounding locality. The acceptability of the proposed development in terms of parking and transport and highways impacts is supported by the Local Authorities Transport and Highways Officer, who has raised no objection to the proposed development.

14.17 On balance, officers are satisfied that the proposal would be in accordance with Policies T2, T6 and T6.1 of the London Plan (2021) and Policies IM4, IM(a), IM(b) and IM(c) of the Royal Greenwich Local Plan: Core Strategy with Detailed Policies (2014).

15 Cycle Parking

15.1 Policy T5 of the LP states that development proposals should help remove barriers to cycling and create a healthy environment in which people choose to cycle. The policy is clear that proposals should do this by meeting providing cycle parking at least in accordance with the minimum standards set out in Table 10.2 and Figure 10.3. The cycle parking should be fit for purpose, secure and well-located.

15.2 Within Policy T5, Table 10.2 in the LP sets out that each dwelling brought forward as part of an application such as this should provide two (2) secure cycle parking spaces.

15.3 This is supported by Policy IM(b) and IM(c) of the Core Strategy.

ITEM NO: 4 Page 47 15.4 The submissions do not bring forward any plans to install any cycle parking associated with the proposed development. It is however anticipated that cycle parking could be provided in either the front forecourt area or in the rear gardens of the proposed dwellings.

15.5 Details of the proposed cycle parking provision for the development are sought via a condition attached to the decision notice.

15.6 The proposed development is therefore considered to be in accordance with Policy T5 of the London Plan (2021) and Policies IM(b) and IM(c) of the Royal Greenwich Local Plan: Core Strategy with Detailed Policies (2014).

16 Waste and refuse storage

16.1 Policy H5 of the CS identifies that development needs to minimise the production of waste, to promote the reuse and recycling of waste materials and to ensure that waste disposal is environmentally responsible. As such residential schemes should incorporate measures for community recycling that minimises waste disposal and should provide refuse bins and recycling boxes. This is supported by LP Policy SI7 and SI8.

16.2 In accordance with the “New Developments: Guidance Notes for the Storage and Collection of Waste and Recycling Materials for the Royal Borough of Greenwich (May 2018)” recommendations and correspondence with the Local Authority’s Waste and Refuse Department, the proposal makes clear that space at the front of the properties would be set out for the provision of 1x240L general waste bin, 1x240L mixed dry recycling bin, and 1x240L food waste bin per residential unit.

16.3 The proposed bin provision being located within the front forecourt is considered to be an acceptable location which would allow for easy waste deposits and a reasonable distance to allow for bin collection.

16.4 Officers note that the local authority’s internal waste department consultee has set out that they are satisfied with the proposed development in this regard. 16.5 Further details as to the design of the proposed waste bin storage units are sought to be provided via a condition attached to the decision notice.

16.6 The proposed development is therefore considered to be in accordance with Policies SI7 and S18 of the London Plan (2021) and Policy H5 of the Royal Greenwich Local Plan: Core Strategy with Detailed Policies (2014).

ITEM NO: 4 Page 48 17 Sustainability

17.1 Policy DH1 sets out Council’s expectations for all development to maximise energy conservation and minimise future carbon dioxide emissions and mitigate climate change, and to comply with London Plan Policy S12 and Policy E1 (Carbon Emissions) of the Royal Greenwich Core Strategy and Detailed Policies 2014.

17.2 Carbon emissions are to be reduced in accordance with the Mayor’s energy hierarchy; 1. Be lean: use less energy 2. Be clean: supply energy efficiently; and 3. Be green: use renewable energy

17.3 The Greener Greenwich Supplementary Planning Document provides guidance on how new development in the borough should be designed and built so that it has a positive impact on the environment and achieves the highest standards of sustainable design and construction.

17.4 The above is not a requirement for a development of this scale, however the development as a whole should strive to meet these standards and applicants are encouraged to submit a report that addresses the requirements set by the Greener Greenwich Supplementary Planning Document (SPD).

17.5 London Plan Policy SI5 requires development to minimise the use of mains water by incorporating water saving measures and equipment and designing residential development so that mains water consumption would meet a target of 105 litres or less per head per day. This is captured under the Greener Greenwich Supplementary Planning Document (SPD).

17.6 A condition is attached to the decision notice to ensure that the above polices and recommendations are adhered to. The proposed development is therefore considered to be in accordance with Policies S12 and S15 of the London Plan (2021) and Policies DH1 and E2 of the Royal Greenwich Local Plan: Core Strategy with Detailed Policies (2014). 18 Community Infrastructure Levy (CIL)

18.1 The Mayor has introduced a London-wide Community Infrastructure Levy (CIL) to help implement the London Plan (2021), particularly Policy T9. The Mayoral CIL formally came into effect on 1st April 2012, and it will be paid on commencement of most new development in Greater London that was granted planning permission on or after that date. The Mayor's CIL will contribute towards the funding of Crossrail. The Mayor has arranged ITEM NO: 4 Page 49 boroughs into three charging bands. The rate for Greenwich is £35 per square metre.

18.2 The current application is liable to this requirement.

19 RBG CIL

19.1 The Royal Borough adopted its Local Community Infrastructure Levy (CIL) charging schedule, infrastructure (Regulation 123) list, instalments policy and exceptional circumstances relief policy on the 25th March 2015 and came into effect in Royal Greenwich on the 6th April 2015.

19.2 The current application is liable to this requirement.

20 Implications for disadvantaged groups

20.1 Beyond those aspects brought forward in the inclusive design section of this report at section 13 of the committee report, there are no implications for disadvantaged groups. A proposal of this size is not required by the London Plan (2021) to provide any dwellings which are in accordance with Building Regulation Requirement M4(3) ‘wheelchair user dwellings.’

21 Conclusion

21.1 The proposed development is acceptable in principle and would contribute to the achievement of the boroughs housing provision aims.

21.2 The proposed development would not result in a significantly detrimental effect on the character and appearance of the application building or the wider public realm.

21.3 The proposed development would provide an acceptable quality of accommodation for residents.

21.4 The proposed development would not result in any unacceptable impacts to the amenity enjoyed by neighbouring occupiers.

21.5 Accordingly, it is recommended that permission be granted for application reference 21/0701/F, in line with Section 1.1 of this report.

Report Author: Luke Sapiano (Planning Officer) Email.: [email protected] ITEM NO: 4 Page 50

Reporting to: Victoria Geoghegan, Assistant Director, Planning & Building Control Email.: [email protected]

ITEM NO: 4 Page 51

Page 52 APPENDICES Appendix 1 – Drawing Numbers

The below lists all of the drawings taken into consideration in this assessment:

120-D-70B, 120-D-71B, 120-D-72B, 120-D-73B, 120-D-74B, 120-D-75B, 120-D- 76A, 120-D-77C`, 120-D-78C, 120-D-79A, 120-D-80B, 120-D-81A, 120-D-82A, 120-D-83A, 120-D-84A, 120-D-85A, Design and Access Statement (Issue 3), Parking Survey (dated 19/02/2021).

ITEM NO: 4 (Appendices) Page 53 APPENDICES Appendix 2 – Conditions and Informatives

1. Conditions and Reasons for Application Reference 21/0701/F:

01. The development to which this permission relates must be begun not later than the expiration of three (3) years beginning with the date on which the permission is granted.

Reason: As required by Section 91 of the Town and Country Planning Act 1990.

02. The development hereby permitted shall be carried out in accordance with the following approved plans:

120-D-70B, 120-D-71B, 120-D-72B, 120-D-73B, 120-D-74B, 120-D-75B, 120-D-76A, 120-D-77C`, 120-D-78C, 120-D-79A, 120-D-80B, 120-D-81A, 120-D-82A, 120-D-83A, 120-D-84A, 120-D-85A, Design and Access Statement (Issue 3), Parking Survey (dated 19/02/2021).

Reason: For the avoidance of doubt and in the interests of proper planning.

03. Unless otherwise stated on the documents hereby approved, the materials to be used for the external surfaces of the development hereby permitted shall match those of the existing building. All new works and works of making good to the retained fabric shall be finished to match the adjacent work unless otherwise stated on the approved drawings and retained for the lifetime of the development.

Reason: To ensure that the high design quality demonstrated in the plans and submission is delivered so that local planning authority may be satisfied as to the external appearance of the building(s) and to comply with Policy D3 of the London Plan (2021) and Policies H5 and DH1 of the Royal Greenwich Local Plan: Core Strategy with Detailed Policies (July 2014).

04. a) Within 6 months of the date of this decision notice, the layout and details of the refuse storage units, recycling facilities and refuse collection storage, including plan, elevation and materiality details, associated with the use hereby approved development shall be submitted to, and approved in writing by, the local planning authority.

ITEM NO: 4 (Appendices) Page 54 APPENDICES b) The storage and recycling facilities shall in all respects be constructed in accordance with the approved details prior to the occupation of the development and maintained for the lifetime of the development.

Reason: To ensure that adequate refuse/recycling facilities are proposed and to ensure that the appearance of any storage facilities would be acceptable in design and heritage terms. This is to ensure compliance with Policies SI7 and SI8 of the London Plan (2021) and Policies H5, DH1 and DH(a) of the Royal Greenwich Local Plan: Core Strategy with Detailed Policies (July 2014).

05. a) Within 6 months of the date of this decision, details of the cycle parking associated with the use hereby permitted shall be submitted to, and approved in writing by, the local planning authority. Two (2) secure and dry cycle parking spaces for each proposed dwelling should be provided at the application site. Details shall include the following: - Detailed drawings (elevations and plans at a suitable scale) to show the appearance, siting and design of the covered and secure cycle storage facilities. - Type of Cycle Parking Mechanism Proposed - Details of the proposed materiality of the cycle parking units.

(b)Prior to the occupation of the development the cycle parking facilities as outlined in the drawings hereby approved shall be fully constructed and made available. The cycle parking facilities shall be maintained thereafter and kept available for use for the lifetime of the proposed development.

Reason: To promote sustainable travel and to ensure that the appearance of any storage facilities would be acceptable in design and heritage terms. To ensure compliance with Policy T5 of the London Plan (2021) and DH1, DH(a), IM4, IM(b) and IM(c) of the Royal Greenwich Local Plan: Core Strategy with Detailed Policies (July 2014).

06. Notwithstanding the Town and Country Planning (General Permitted Development) Order 2015 (or any Order revoking, re-enacting or modifying that Order), no extensions or alterations to the building(s) hereby approved shall be carried out without the prior written permission of the local planning authority.

Reason: In order that, in view of the nature of the development hereby permitted, the local planning authority may have the opportunity of assessing the impact of any further development and to comply with Policies D3 and D4 of the London

ITEM NO: 4 (Appendices) Page 55 APPENDICES Plan (2021) and Policies DH1 and Policies DH(b) of the Royal Greenwich Local Plan: Core Strategy with Detailed Policies (2014)

07. All dwellings hereby approved shall be constructed in order to achieve a reduction in potable water demand to a maximum of 105 litres per person per day based on the Government’s national calculation method for water efficiency for the purpose of the Building Regulations.

Reason: To conserve water for the future occupiers and to comply with Policy SI5 of the London Plan (2021) and Policy DH1 of the Royal Greenwich Local Plan: Core Strategy with Detailed Policies (2014).

2. Informative(s) for Application Reference 21/0701/F:

01. Positive and Proactive Statement: The Council engages with all applicants in a positive and proactive way through specific pre-application enquiries and the detailed advice available on the Council’s website. On this particular application, positive discussions took place which resulted in further information being submitted.

02. Works of demolition and construction shall be carried out during normal working hours, i.e. 08:00 to 18:00 hours Monday to Friday, and 08:00 to 13:00 hours on Saturdays, with no noisy working audible at the site boundary being permitted on Sundays or Bank Holidays. Reference shall be made to: The Councils’ Construction Site Noise Code of Practice http://www.royalgreenwich.gov.uk/downloads/file/469/noise_from_smallscale_ building_works_leaflet

03. The applicant be advised that the implementation of the proposal will require approval by the Council of a Street naming & Numbering application. Details of how to do this and application forms are available on the Council's website

ITEM NO: 4 (Appendices) Page 56 APPENDICES Appendix 3 – National, regional and local planning policies and Supplementary Planning Guidance / Documents.

1. National Planning Policy Framework (NPPF – 2012) Chapter 5 – Delivering a Sufficient Supply of Homes Chapter 9 – Promoting Sustainable Transport Chapter 11 – Making the best use of land Chapter 12 – Achieving Well-Designed Places

2. The London Plan (March 2021) – The following policies are of consideration:

Good Growth Policies Policy GG2 – Making the best use of land Policy GG4 – Delivering the Homes Londoners Need

Design Policies Policy D3 – Optimising site capacity through the design led approach Policy D4 – Delivering Good Design Policy D5 – Inclusive Design Policy D6 – Housing Quality and Standards Policy D7 – Inclusive Design Policy D14 – Noise

Housing Policies Policy H1 – Increasing Housing Supply Policy H2 – Small Sites Policy H10 – Housing Size Mix

Sustainable Infrastructure Policies Policy S12 – Minimising greenhouse gas emissions Policy S15 - Water Infrastructure Policy SI7 - Reducing waste and supporting the circular economy Policy SI8 – Waste Capacity and Net Waste Self Sufficiency

Transport Policies Policy T2 – Healthy Streets Policy T4 – Accessing and Mitigating Transport Impacts Policy T5 - Cycling Policy T6 - Car Parking Policy T6.1 – Residential Parking

ITEM NO: 4 (Appendices) Page 57 APPENDICES 3. The Royal Greenwich Local Plan: Core Strategy with Detailed Policies (“Core Strategy” – 2014) – The main Core Strategy policies relevant to this application are:

Housing Policies H1 New Housing H2 Housing Mix H5 Housing Design H(b) Conversions

Design and Heritage Policies DH1 Design DH(b) Protection of Amenity for Adjacent Occupiers

Environment and Climate Change Policies E1 Carbon Emissions E(a) Pollution OS(f) Ecological Factors

Infrastructure and Movement Policies IM4 Sustainable Travel IM(a) Impact on the Road Network IM(b) Walking and Cycling IM(c) Parking Standards

4. Supplementary Planning Guidance / Documents – the following planning guidance / documents are considered relevant:

• New Developments: Guidance Notes for the Storage and Collection of Waste and Recycling Materials for the Royal Borough of Greenwich (May 2018) • Mayors Housing SPG (2016) • Greener Greenwich SPD (2014)

ITEM NO: 4 (Appendices) Page 58 WOOLWICH AND THAMESMEAD AREA Agenda Item: 5 PLANNING COMMITTEE Reference No: 22 June 2021 21/0173/F

Applicant: Mr Nelson Ahonsi Agent: Mr Hitesh Sodvadiya – Ideal Design LTD

Site Address: Ward: Plumstead 340 Wickham Lane, Plumstead, London, Application Type: Full Planning SE2 0NZ Permission

1. Recommendation

1.1 The Committee is requested to grant full planning permission as outlined below:

• “Proposed change of use from dwelling into HMO (6 people) with associated internal alterations.”

Subject to:

2 Summary

2.1 Detailed below is a summary of the application:

The Site Site Area (m²) 165 Local Plan Allocation No allocations. Heritage Assets None Tree Preservation Order None Flood Risk Zone No

ITEM NO: 5 Page 59 Transportation Car Parking No. existing car 1 parking spaces No. Proposed Car 1 Parking Spaces Public Transport PTAL Rating 2 (low)

Public Consultation Number in Support 0 Number of objections 2 Main issues raised • Impact on parking; • Residential area is not suitable for high occupancy dwellings. • HMO would be over-occupied; • HMO could harm the amenity of neighbouring residents. • Impact on amenity from the rear dormer and ground floor extension.

2.2 Whilst this application has received only one objection from members of the public, it has been called before committee by Councillor Angela Cornforth for members to decide in the event officers recommend approval. No specific areas of concerns were raised within the call-in request.

2.3 The report details all relevant national, regional and local policy implications of the scheme, including supplementary planning guidance.

2.4 The application is considered to be acceptable and is recommended for approval subject to that set out in section 1.1 above.

ITEM NO: 5 Page 60 Site Plan

3 Site and Surroundings

3.1 The application site is a 2-storey mid-terrace single family dwellinghouse (Class C3) located on the south western side of Wickham Lane. The surrounding area is residential in character consisting of similarly styled 2- storey terraced and semi-detached houses.

3.2 The application building benefits from prior approval under application reference 19/3408/PN1 for a single storey rear extension as well as a Lawful Development Certificate (proposed) under reference 20/0333/CP for a rear dormer roof extension. Photographic evidence has been obtained from the applicant which demonstrates that at the time of writing, these elements have been substantially completed.

3.3 The property is not a statutory listed or locally listed building. The property does not fall within a Conservation Area. ITEM NO: 5 Page 61

3.4 The property benefits from 1 on-site car parking space at the front of the site. The application site has a Public Transport Accessibility Level (PTAL) of 2 (on a scale of 1-6, where 6 is highest), indicating a low connectivity to public transport links.

4. Relevant Planning History

App Decision 19/3408/PN1 Decision: Granted 11/11/2019 Number: Date: Address: 340 WICKHAM LANE, PLUMSTEAD, LONDON, SE2 0NZ Prior notification for the construction of a single storey rear extension which would measure 6.0 metres beyond the rear Description: wall of the property, with a maximum height of 3.2 metres and an eaves height of 3.0 metres.

Officer It is noted that works to implement this consent have been Comment: substantially completed.

App Decision 20/0333/CP Decision: Granted 10/03/2020 Number: Date: Address: 340 WICKHAM LANE, PLUMSTEAD, LONDON, SE2 0NZ Lawful Development Certificate (proposed) is sought for construction of a rear dormer roof extension and insertion Description: of 2 rooflights in the front rooflsope.

Officer It is noted that works to implement this consent have been Comment: substantially completed.

5. Proposals (in detail)

5.1 The current application seeks full planning permission for the following:

‘Proposed change of use from dwelling into HMO (6 people) with associated internal alterations.’

5.2 The proposed new HMO would have five (5) bedrooms, and the requested description of development sets out that the maximum capacity of the HMO would be six (6) persons. The layout of the proposed HMO is described below:

ITEM NO: 5 Page 62

Ground Floor: - Communal Hallway; - Room 1 (single occupancy), 10.5sqm; - Room 2 (single occupancy), 10.5sqm; - Communal kitchen/living/dining room, 31.7sqm.

First Floor: - Communal Landing; - Room 3 (double occupancy), 17.2sqm; - Room 4 (single occupancy), 10.8sqm; - Communal bathroom.

Converted loftspace: - Room 5 (single occupancy), 11sqm; - Landlord’s storage in loftspace.

5.3 The submissions do not bring forward any plans to make any external alterations to the application building that are not already consented and substantially completed.

5.4 Revisions have been made during the assessment process to amend the internal layout at 1st floor level to provide a larger bedroom rather than 2 smaller single occupancy rooms. Given the nature of these revisions, no re- consultation was considered to be necessary.

6. Consultation

6.1 The application since being submitted in January 2021 has been subject to public consultation comprising of: • Ward Councillors were notified on 21st January 2021; • 6 neighbouring properties were notified on 21st January 2021; • A site notice was displayed on site on 23rd January 2021.

6.2 A summary of the consultation responses follows below:

Members of the public 6.3 Two comments raising objections were received from local residents, these comments are summarised in the table below:

Comment Officer Response ITEM NO: 5 Page 63 • Impact on parking; An assessment of the proposal in relation to highways and transport follows in Section 13 of this report. • Residential area is not suitable An assessment of the proposal in for high occupancy dwellings. relation to the quality of HMO • HMO would be over- accommodation and neighbour amenity occupied. follows in Sections 11 and 12 of this • HMO could lead to anti-social report respectively. behaviour. • HMO could harm the amenity of neighbouring residents. • The dormer roof extension The application building benefits from under construction at the site prior approval under application overlooks neighbouring reference 19/3408/PN1 for a single properties; storey rear extension as well as a • The single storey rear Lawful Development Certificate extension under construction (proposed) under reference at the site is excessive in scale. 20/0333/CP for a rear dormer roof extension, these developments are currently under construction. As these works have been substantially completed, they are not relevant planning considerations for the current application.

Councillors 6.4 Councillor Angle Cornforth commented calling the application into the Woolwich & Thamesmead Area Planning Committee in the event officers recommend the application for approval. No specific concerns were raised.

6.5 No other responses from councillors were received.

Responses from Council Departments 6.6 A summary of the consultation responses received along with the officer comments are set out in table below:

Details of Summary of Officers comments Representation Comments and date received

ITEM NO: 5 Page 64 No objection in principle. An assessment of the Transport and It is recommended that proposal in relation to Highways: adequate cycle provision highways and transport is made in line with the follows in Section 13 of proposed London Plan this report. standard. A condition relating to cycle parking has been recommended in Appendix 2. Waste Services: No response received. Although no comments from Waste Services have been received, the applicant has not provided any details of waste storage, however there would be adequate space at the front of the site for bin storage which would be similar to the adjacent properties. Further details of the exact waste storage facilities have been secured by condition.

The waste related aspects of this proposal are discussed at section 15 below. Further details are proposed to be provided via a condition (refer to appendix 2). Environmental No response received. Noise and other Protection: neighbouring amenity related aspects of this proposal are assessed in section 12 below. HMO Licensing: No response received. The proposed development is compliant with the limitations set out in the RBG HMO

ITEM NO: 5 Page 65 Standards as set out in section 11 of this report.

7. Planning Context

7.1 This application needs to be considered in the context of a range of national, regional and local planning policies and Supplementary Planning Guidance / Documents. • National Planning Policy Framework (NPPF – 2012) • The London Plan (March 2021) • The Royal Greenwich Local Plan: Core Strategy with Detailed Policies (“Core Strategy” – 2014) • Residential Extensions, Basements and Conversions Guidance SPD (Dec 2018) (SPD) • Royal Borough of Greenwich Standards for Houses in Multiple Occupation (Standards for HMOs) (2017) • New Developments: Guidance Notes for the storage and collection of waste and recycling materials for the Royal Borough of Greenwich (May 2018)

7.2 For full details relevant policies, SPDs and other documents, refer to Appendix 3.

8. Material Planning Considerations

8.1 This section of the report provides an analysis of the specific aspects of the proposed development and the principal issues that need to be considered in the determination of the planning application (Ref: 21/0173/F): Principle of development; • Design • Quality of living environment provided for future residents; • Impact on neighbouring amenity • Transport and Access • Cycle Parking • Waste and Refuse Storage • Community Infrastructure Levy (CIL); • RBG CIL; 9. Principle of Development

9.1 The overriding objective of the Royal Greenwich policy framework is to deliver high quality development which improves the quality and distinctive

ITEM NO: 5 Page 66 identity of places and contributes to their success and the area’s popularity as somewhere to live, work and stay.

9.2 Policy H9 of the London Plan (2021) (LP) sets out that boroughs should take account of the role of houses in multiple occupation (HMOs) in meeting local and strategic housing needs. Policy H9 clearly states that where HMO’s are of a reasonable standard they should generally be protected.

9.3 Policy H2 of the Core Strategy (2014) (CS) promotes a mix of housing types and sizes, varying according to the location of the development and the character of the surrounding area. Other relevant considerations include; the level of accessibility to public transport, schemes for special needs groups, or where there is a poor external environment.

9.4 It is important to note that the Council’s CS does not include any policies which protect the loss of family sized accommodation in relation to the conversion of single family dwellinghouses into HMO accommodation. Further, the minor internal works related to the change of use would not prevent the residential accommodation being converted back into a single C3 dwelling in the future if desired. As such, the loss of the existing accommodation in order to convert the property is considered acceptable.

9.5 In respect of the suitability of the proposed HMO, the Council’s Residential Extensions, Basements and Conversions Guidance SPD (2018) states:

“It is important that the Royal Borough supports a range of homes in terms of size and tenure in order to meet a variety of housing need. HMOs that are of a good standard form an important part of the provision of lower cost housing. However, the unmanaged conversion of family housing stock to HMOs can undermine the Royal Borough’s objective to meet these varying needs and make it difficult to achieve mixed and balanced communities as set out in the Core Strategy.”

9.6 It is therefore evident that HMOs have been identified as providing suitable residential accommodation, which will be supported by the Council subject to other material considerations including the quality of the internal living environment.

9.7 In relation to over concentration of HMO’s, no applicable planning policy restricts the amount of HMO’s within a specific area.

9.8 On the basis of the above, the proposal is considered acceptable in principle, subject to the provision of an acceptable quality of accommodation for its occupants. This is discussed elsewhere within this report. ITEM NO: 5 Page 67

10. Design

10.2 Policy DH1 of the CS requires all developments to be of a high quality of design and demonstrate that they positively contribute to the improvement of both the built and natural environments.

10.3 No external changes are proposed to be implemented to application building, and so the impact of the development on the character and appearance of the application building and wider surrounding area is considered to be acceptable in this instance.

10.4 The application building benefits from prior approval under application reference 19/3408/PN1 for a single storey rear extension as well as a Lawful Development Certificate (proposed) under reference 20/0333/CP for a rear dormer roof extension, these developments are currently under construction. As these works have been substantially completed, they are not relevant planning considerations for the current application.

10.5 The proposed development is therefore considered to be generally in accordance with Policy D3 of the London Plan (2021) as well as Policy DH1 and H5 of the Royal Greenwich Local Plan: Core Strategy with Detailed Policies (2014).

11. Quality of Living Environment provided for future residents

11.1 The Royal Borough of Greenwich Residential Extensions, Basements, and Conversions Guidance SPD (2017) includes new guidance for Houses in Multiple Occupation (HMOs). The SPD seeks to secure a quality internal living environment for new HMOs. It states: “The quality of accommodation provided by HMOs can be poor and can give rise to concern. To be considered good quality, proposals for the conversion to an HMO will need to: - provide sufficient internal space - provide occupants with a reasonable standard of amenity - not give rise to significant adverse amenity impacts to the surrounding properties/residential neighbourhood” ITEM NO: 5 Page 68

11.2 Policy H5 of the CS seeks that new residential development, redevelopment, refurbishment or conversions will be expected to achieve a high quality of housing design and an integrated environment.

11.3 This is supported by LP Policy D6 which states that housing developments should be of high-quality design and provide adequately-sized rooms with comfortable and functional layouts which are fit for purpose and meet the needs of Londoners without differentiating between tenures. The policy goes on to state that the design of development should maximise the provision of dual aspect dwellings and provide sufficient daylight and sunlight to new and surrounding housing that is appropriate for its context.

11.4 The above Policies and Guidance are also further clarified in the Royal Borough of Greenwich HMO Standards, which sets out the standards for prospective HMO’s.

11.5 The proposed new HMO would have 5 bedrooms, seeking a maximum capacity of six persons. The layout of the proposed HMO is described below:

Ground Floor: - Communal Hallway; - Room 1 (single occupancy), 10.5sqm; - Room 2 (single occupancy), 10.5sqm; - Communal kitchen/living/dining room, 31.7sqm.

First Floor: - Communal Landing; - Room 3 (double occupancy), 17.2sqm; - Room 4 (single occupancy), 10.8sqm; - Communal bathroom.

Converted loftspace: - Room 5 (single occupancy), 11sqm; - Landlord’s storage in roofspace. Bedroom Sizes

11.6 Bedroom sizes are assessed against Table 1 of the Royal Greenwich HMO Standards – “Minimum where kitchen facilities are within a separate room” within the Royal Borough of Greenwich Standards for HMOs.

Bedrooms

ITEM NO: 5 Page 69 Bedroom Proposed Occupancy Size (sqm) Standard Complies? (sqm) 1 1 10.5 9 Yes 2 1 10.5 9 Yes 3 2 17.2 12 Yes 4 1 10.5 9 Yes 5 1 10.5 9 Yes

11.7 All of the proposed bedrooms brought forward comply with the relevant floor space requirements. This aspect of the proposal is therefore considered to be acceptable. If the applicant was seeking to use the HMO for more than 6 persons, a further planning application would have to be submitted and considered by the Council, as any more than 6 occupants would constitute a Sui Generis Use Class and not a C4 Use Class as set out in the description of development.

Kitchen Provision

11.8 The Royal Borough of Greenwich Standards for HMOs also gives recommendations on the size of provided kitchen facilities:

“Where exclusive kitchen facilities cannot be provided, one set of kitchen facilities shall be provided for every 5 occupants. […] The kitchen size and layout must enable the practical, safe & hygienic use of the kitchen for storage, preparation and cooking of food.”

11.9 As a proposed six (6) person HMO, two (2) sets of kitchen facilities are required to be provided.

11.10 With a size of 13.5sqm, the kitchen would comfortably meet the required minimum kitchen requirement for six persons of 10.5sqm as set out in Table 5 of the Royal Borough of Greenwich Standards for HMO’s. It is considered that two sets of kitchen facilities could easily be provided within this space.

11.11 With reference to the above, it is considered that the proposal would be acceptable in relation to the relevant kitchen provision.

Indoor Amenity Space

11.12 The RBG Standard for Houses in Multiple Occupation provide guidance as to the required living room provision for HMO’s and Table 3 confirms that a living room provided within a 6 person HMO should be 11sqm in area.

ITEM NO: 5 Page 70 11.13 The proposed HMO would provide an 18sqm communal living room at ground floor level which would be well in excess of the requirements of HMO standards.

Bathroom Provision

11.14 The RBG Standard for Houses in Multiple Occupation provides guidance as to the required bathroom provision for HMO’s:

“Where exclusive bathroom/shower room and toilet facilities cannot be provided, […] for every 5 persons, one bathroom or shower room, and one toilet with a wash hand basin shall be provided.”

11.15 All of the proposed bedrooms would have access to their own ensuite bathroom provision. This provision is considered to be in accordance with the above requirement.

11.16 This aspect of the proposal is therefore considered to be acceptable.

Outdoor Amenity Space

11.17 The proposed HMO would reuse the existing garden space to provide a total of 84sqm of external amenity space in the rear garden.

11.18 This is considered to be a generous provision for a 6 person HMO. This aspect is therefore considered to be acceptable.

Other Internal Amenity Factors

11.19 The RBG HMO Standards state that it is expected that all rooms will have a minimum ceiling height of 2.1m over at least half the floor area.

11.20 The submitted section drawings confirm that 2.8m of floor to ceiling height would be provided at ground floor, 2.5m at first floor and 2.1m in the converted loftspace which would be in accordance with the RBG HMO Standards.

11.21 The proposed HMO as a whole would be dual aspect. Habitable windows would serve every bedroom and living space, with all of these spaces having a reasonable outlook and receiving adequate daylight and sunlight throughout the day.

ITEM NO: 5 Page 71 11.22 Given the positioning of neighbouring habitable opening and amenity spaces, none of the proposed bedrooms brought forward in this application would be subject to any significant privacy or overlooking related impacts from neighbouring properties. These aspects of the proposal are therefore considered to be acceptable.

Conclusion

11.23 The proposed development would provide an acceptable level of internal amenity and would therefore provide an adequate quality of accommodation for future residents.

11.24 As such, these aspects of the proposal are considered to be compliant with Policy D6 of The London Plan (2021), Policy H5 of the Royal Greenwich Local Plan (2014), the Residential Extensions, Basements and Conversions SPD (December 2018), and the Royal Borough of Greenwich Standards for Houses in Multiple Occupation (April 2017).

12 Impact on neighbouring amenity

12.1 Policy DH(b) of the CS require new development to demonstrate that there would be no significant loss of amenity to adjacent or nearby properties, by reducing the amount of daylight, sunlight, privacy or outlook they enjoy, by creating an unneighbourly sense of enclosure, or by unacceptably impacting the wind environment or microclimate.

12.2 Policy D14 of the London Plan states that development proposals should avoid significant adverse noise impacts on health and quality of life.

12.3 Policy E(a) of the CS states that planning permission will not normally be granted where a proposed development or change of use would generally have a significant adverse effect on the amenities of adjacent occupiers or uses, and especially where proposals would be likely to result in the unacceptable emission of noise, light, vibrations, odours, fumes, dust, water and Soil pollutants or grit.

12.4 The application building benefits from prior approval under application reference 19/3408/PN1 for a single storey rear extension as well as a Lawful Development Certificate (proposed) under reference 20/0333/CP for a rear dormer roof extension, these developments are currently under construction.

ITEM NO: 5 Page 72 As these works have already been approved and substantially completed, they are not relevant planning considerations for the current application.

12.5 Examining how the proposal does not bring forward any external alterations to the application building, it is considered that the development would not bring any significantly detrimental amenity impacts to any of the nearby properties with regard to loss of daylight/ sunlight, creation of an unneighbourly sense of enclosure, loss of outlook or loss of privacy beyond the existing lawful situation.

12.6 It is acknowledged that the submissions do bring forward an increase in the proposed number of occupants at the application property. With reference to this, an increase to the number of persons residing in the dwelling to a maximum of six (6) is not considered to present a significantly detrimental impact on the amenity enjoyed by the nearby neighbouring properties beyond the existing lawful use of the building as a large C3 family unit.

12.7 It is considered that the proposed development is therefore in accordance with Policy D14 of the London Plan (2021), Policies DH(b) and E(a) of the Royal Greenwich Local Plan: Core Strategy with Detailed Policies (2014) and Council’s Residential Extensions, Basements and Conversions Guidance SPD (December 2018).

13 Transport and Highways Impacts

Car Parking

13.1 Policy T2 of the LP states that development proposals should deliver patterns of land use that facilitate residents making shorter, regular trips by walking or cycling. Policy T2 also states that development proposals should reduce the dominance of vehicles on London’s streets whether stationary or moving. 13.2 Policy T6 of the LP states that car-free development should be the starting point for all development proposals in places that are (or are planned to be) well-connected by public transport, with developments elsewhere designed to provide the minimum necessary parking.

13.3 Policy T6.1 further sets out that maximum parking provision for residential development should be in accordance with Table 10.3. For a residential development of this size, the London Plan sets out that a maximum of 0.5 spaces should be provided.

ITEM NO: 5 Page 73 13.4 The requirements of these London Plan policies are supported by Policy IM(c) of the Royal Greenwich Local Plan: Core Strategy with Detailed Policies (2014).

13.5 The site has a Public Transport Accessibility Level (PTAL) of 2, which indicates a low level of public transport accessibility.

13.6 The site is not located within a Controlled Parking Zone (CPZ) which indicates that the surrounding roads are not subject to severe parking stress.

13.7 The proposed development would benefit from access to 1 car parking space located at the front of the site. This is considered to be acceptable provision and in accordance with the provisions of the LP given that it replicates the existing situation at the host property.

13.8 The increase in the occupancy of the building from a C3 family unit to a HMO of an absolute maximum of six persons is not considered to result in significantly detrimental parking issues or traffic impacts.

13.9 The acceptability of the proposed development in terms of parking and transport and highways impacts is supported by the Local Authorities Transport and Highways Officer, who has raised no objection to the proposed development.

13.10 Given the above, officers are satisfied that the proposal would be in accordance with Policies T2, T6 and T6.1 of the London Plan (2021) and Policy IM(c) of the Royal Greenwich Local Plan: Core Strategy with Detailed Policies (2014).

Cycle Parking

13.11 Policy T5 of the LP states that development proposals should help remove barriers to cycling and create a healthy environment in which people choose to cycle. The policy is clear that proposals should do this by meeting providing cycle parking at least in accordance with the minimum standards set out in Table 10.2 and Figure 10.3. The cycle parking should be fit for purpose, secure and well-located.

ITEM NO: 5 Page 74 13.12 Within Policy T5, Table 10.2 in the London Plan (2021) sets out that a proposal of the type brought forward in this application should provide two (2) cycle parking spaces.

13.13 This is supported by Policy IM(b) and IM(c) of the Core Strategy.

13.14 The submissions do not provide details of any cycle parking provision. A condition is recommended to be attached to any decision notice, in order to secure further details in relation to the proposed cycle parking provision (see Appendix 2).

13.15 Given the above, the proposed development is considered to be in accordance with Policy T5 of the London Plan (2021) and Policies IM(b) and IM(c) of the Core Strategy (2014).

14 Waste and refuse storage

14.1 Policy H5 of the CS identifies that development needs to minimise the production of waste, to promote the reuse and recycling of waste materials and to ensure that waste disposal is environmentally responsible. As such residential schemes should incorporate measures for community recycling that minimises waste disposal and should provide refuse bins and recycling boxes. This is supported by LP Policies SI7 and SI8.

14.2 In accordance with the “New Developments: Guidance Notes for the Storage and Collection of Waste and Recycling Materials for the Royal Borough of Greenwich (May 2018)” recommendations and correspondence with the Local Authority’s Waste and Refuse Department, the proposal would be required to provide for the provision of 2x240L general waste bins, 2x240L mixed dry recycling bins, and 1x240L food waste bin.

14.3 It is apparent that there would be space for the provision described above within the front of the site and details of the final waste arrangements are secured by condition in Appendix 2.

15 Community Infrastructure Levy (CIL)

15.1 The Mayor has introduced a London-wide Community Infrastructure Levy (CIL) to help implement the London Plan (2021), particularly Policy T9. The Mayoral CIL formally came into effect on 1st April 2012, and it will be paid on commencement of most new development in Greater London that was granted planning permission on or after that date. The Mayor's CIL will contribute towards the funding of Crossrail. The Mayor has arranged ITEM NO: 5 Page 75 boroughs into three charging bands. The rate for Greenwich is £35 per square metre.

15.2 The current application is not liable to this requirement.

16 RBG CIL

16.1 The Royal Borough adopted its Local Community Infrastructure Levy (CIL) charging schedule, infrastructure (Regulation 123) list, instalments policy and exceptional circumstances relief policy on the 25th March 2015 and came into effect in Royal Greenwich on the 6th April 2015.

16.2 The current application is not liable to this requirement.

17 Implications for disadvantaged groups

17.1 There are no specific implications identified.

18 Conclusion

18.1 The proposed development would not result in a significantly detrimental effect on the character and appearance of the application building or the wider public realm.

18.2 The proposed development would provide an acceptable quality of accommodation for residents.

18.3 The proposed development would not result in any unacceptable impacts to the amenity enjoyed by neighbouring occupiers.

18.4 Accordingly, it is recommended that permission be granted for application reference 21/0173/F, in line with Section 1.1 of this report.

Background Papers: National Planning Policy Framework (2019) The London Plan (2021) Royal Greenwich Local Plan: Core Strategy with Detailed Policies (2014) Residential Extensions, Basements and Conversions Guidance SPD (Dec 2018) (SPD) Royal Borough of Greenwich Standards for Houses in Multiple Occupation (Standards for HMOs) (2017)

ITEM NO: 5 Page 76 New Developments: Guidance Notes for the storage and collection of waste and recycling materials for the Royal Borough of Greenwich (May 2018) Responses from consultations

Report Author: Joe Higgins (Planning Officer) Email.: [email protected]

Reporting to: Victoria Geoghegan, Assistant Director, Planning & Building Control Email.: [email protected]

ITEM NO: 5 Page 77

Page 78 APPENDICES Appendix 1 – Drawing Numbers

The below lists all of the drawings taken into consideration in this assessment:

340WL(21) rev A; 340WL(32) rev B; 340WL(33) rev A; Title Plan; Design & Access Statement dated November 2020 (ref 340WL/HS).

ITEM NO: 5 (Appendices) Page 79 APPENDICES Appendix 2 – Conditions and Informatives

1. Conditions and Reasons for Application Reference 21/0173/F:

01. The development hereby permitted shall be carried out in accordance with the following approved plans:

340WL(21) rev A; 340WL(32) rev B; 340WL(33) rev A; Title Plan; Design & Access Statement dated November 2020 (ref 340WL/HS).

Reason: For the avoidance of doubt and in the interests of proper planning.

02. a) Prior to the first occupation of the development hereby approved, full details of the refuse and recycling facilities for the development shall be submitted to and approved in writing by the local planning authority.

b) The storage and recycling facilities shall in all respects be constructed in accordance with the approved details prior to the occupation of the development and maintained for the lifetime of the development.

Reason: To ensure that adequate refuse/recycling facilities are proposed and to ensure that the appearance of any storage facilities would be acceptable in design terms. This is to ensure compliance with Policies D3, SI7 and SI8 of the London Plan (2021), Policies H5, DH1 and DH(a) of the Royal Greenwich Local Plan: Core Strategy with Detailed Policies (July 2014) and the New Developments: Guidance Notes for the storage and collection of waste and recycling materials for the Royal Borough of Greenwich (May 2018).

03. a) Prior to the first occupation of the development hereby approved, full details of the cycle parking facilities for the development shall be submitted to and approved in writing by the local planning authority.

b) The cycle parking facilities shall in all respects be constructed in accordance with the approved details prior to the occupation of the development and maintained for the lifetime of the development.

Reason: To promote sustainable travel and to ensure that the appearance of any storage facilities would be acceptable in design terms. To ensure compliance with Policies, D3 and T5 of the London Plan (2021) and DH1, DH(a), IM4, IM(b) and IM(c) of the Royal Greenwich Local Plan: Core Strategy with Detailed Policies (July 2014). ITEM NO: 5 (Appendices) Page 80 APPENDICES

2. Informative(s) for Application Reference 21/0173/F:

02. The premises should be registered with Royal Borough of Greenwich Council as a House in Multiple Occupation (HMO).

Appendix 3 – National, regional and local planning policies and Supplementary Planning Guidance / Documents.

1. National Planning Policy Framework (NPPF – 2012) o Chapter 5 – Delivering a Sufficient Supply of Homes

ITEM NO: 5 (Appendices) Page 81 APPENDICES o Chapter 9 – Promoting Sustainable Transport o Chapter 12 – Achieving Well-Designed Places

2. The London Plan (March 2021) – The following policies are of consideration:

Good Growth Policies G4 – Delivering the homes Londoner’s need

Design Policies Policy D3 – Optimising site capacity through the design led approach Policy D6 – Housing Quality and Standards Policy D14 – Noise

Housing Policies Policy H9 - Ensuring the best use of stock

Sustainable Infrastructure Policies Policy SI7 - Reducing waste and supporting the circular economy Policy SI8 – Waste Capacity and Net Waste Self Sufficiency

Transport Policies Policy T2 – Healthy Streets Policy T4 – Assessing and Mitigating Transport Impacts Policy T5 - Cycling Policy T6 - Car Parking Policy T6.1 – Residential Parking

3. The Royal Greenwich Local Plan: Core Strategy with Detailed Policies (“Core Strategy” – 2014) – The main Core Strategy policies relevant to this application are:

Housing Policies H1 New Housing H2 Housing Mix H5 Housing Design H(a) Protection of Existing Housing

Design and Heritage Policies DH1 Design DH(b) Protection of Amenity for Adjacent Occupiers

ITEM NO: 5 (Appendices) Page 82 APPENDICES Environment and Climate Change Policies E(a) Pollution

Infrastructure and Movement Policies IM4 Sustainable Travel IM(a) Impact on the Road Network IM(b) Walking and Cycling IM(c) Parking Standards

4. Supplementary Planning Guidance / Documents – the following planning guidance / documents are considered relevant:

• Royal Borough of Greenwich Standards for Houses in Multiple Occupation (April 2017) • New Developments: Guidance Notes for the Storage and Collection of Waste and Recycling Materials for the Royal Borough of Greenwich (May 2018) • Residential Extensions, Basements and Conversions Guidance SPD (Dec 2018)

ITEM NO: 5 (Appendices) Page 83

Page 84 WOOLWICH AND THAMESMEAD AREA Agenda Item: 6 PLANNING COMMITTEE

22 June 2021 Reference No: 20/1082/F

Applicant: Paradigm Wellington Ltd Agent: Paige Linley (Leith Planning Ltd)

Site Address: Ward: Woolwich Riverside 38 Wellington Street, Woolwich, London. Application Type: Full Planning SE18 6PE Permission

1. Recommendation

1.1 The Committee is requested to grant Full Planning Permission as outlined below:

• Change of use of the lower ground floor to include Class D1 (educational and medical/dentist use) to already consented A3/A4/D2/B1 uses with the installation of a partial mezzanine floor and associated external alterations to include the provision of 3 new entrances, introduction of bollards on Wellington Street and Polytechnic Street and removal of brick panels to provide additional windows, provision of cycle storage on lower ground level and other minor alterations.

1.2 Subject to:

(i) To resolve to grant conditional planning permission according to the conditions in appendix 2, to be detailed in the notice of determination; and

(ii) To Authorise the Assistant Director of Planning & Building Control to: a. make any minor changes to the detailed wording of the recommended conditions as set out in this report and its addendums, where the Assistant Director of Planning & Building Control considers it appropriate, before issuing the decision notice.

ITEM NO: 6 Page 85 2. Summary

2.1 Detailed below is a summary of the application:

The Site - Site Area (m²) 311m² Heritage Assets Setting of a Grade II* listed building (Woolwich Town Hall) Woolwich Conservation Area Tree Preservation Order No Flood Risk Zone Flood Zone 1

Non-Residential Uses Existing Use(s) Existing use (Classes) / A3, A4, D2 and B1 Operator m² 455m² Proposed Use(s) Proposed uses (Classes) / D1 (Education) Operator D1(Medical/Dentist) m² 737m² (Education) 98m² (Medical/Dentist) Employment Existing Number of Jobs 0 jobs existing on-site as no businesses have occupied the space since it was constructed. Proposed number of jobs D1 (education) Fifteen (15) full time staff

D1 (medical/dentist) Sixteen (16) full time Staff

Transportation Car Parking No. Existing Off-Street Four (4) residential spaces Car Parking Spaces and no non-residential spaces No. Proposed Off-Street Four (4) residential spaces Car Parking Spaces and no non-residential spaces Cycle Parking Total No. Existing Cycle No non-residential spaces Parking No. Proposed Cycle Sixteen (16) non- Parking residential (unknown if short term or long term)

ITEM NO: 6 Page 86 Total uplift in No. Cycle Sixteen (16) non- Spaces residential Complies with policy Yes Public Transport PTAL Rating 6b

Public Consultation Number in Support 0 Number of objections (addressed 2 objections have been received from in section 6.5 of this report) residents.

2.2 Whilst the application has only received two objections, Councillor Fahy has also called in the application to be determined by Members at Committee.

2.3 The report details all relevant national, regional and local policy implications of the scheme, including supplementary planning guidance.

2.4 The application is considered acceptable and is recommended for approval, subject to that set out in section 1.1 of this report.

Site Plan

ITEM NO: 6 Page 87 3. Site and Surroundings (in detail)

3.1 The site is situated on the northern side of Wellington Street on the junction with Polytechnic Street and measures approximately 1,218 square metres (m²) in size. This building which comprises 455m² of A3/A4/D2 space on the ground floor and 34 residential units was approved in 2015. The specific application site comprises the ground floor commercial space within the building. The site is adjacent to the Grade II* listed Woolwich Town Hall which wraps around the site to the west and north.

3.2 The site is also located within the Woolwich Conservation Area, which was designated on the 14th May 2019.

3.3 The site is located in Woolwich Town Centre, which is a designated as a Major Centre that has excellent access to public transport and a wide range of essential services.

3.4 This application specifically relates to the use of the lower and upper ground floor for an educational use and medical/dental use.

4. Relevant Planning History

4.1 20/1164/F Planning Permission was refused on the 28 July 2020 for the change of use of the lower ground floor to include Class D1 to already consented A3/A4/D2/B1 uses, with the installation of a partial mezzanine floor and associated external alterations to include the provision of 2 new entrances, introduction of bollards/ramps on Wellington Street and Polytechnic Street and removal of brick panels to provide additional windows. The reasons for refusal were:

1. In the absence of a secure boundary around the perimeter of the site, such as a fence or wall, there would be insufficient defensible space between the property boundary and the entrances to the proposed education facility. Given the nature of this specific education facility and guided by the comments made by the Metropolitan Police, this proposal would therefore result in a development which does not provide a secure site and cannot ensure the safety of the pupils entering and exiting the building and protection from intruders. As such, the proposal would be contrary to Section 8 and 12 of the National Planning Policy Framework (2019), Policy 7.3 of the London Plan, and Policies DH1 and CH1 of the Royal Borough of Greenwich Core Strategy (2014).

ITEM NO: 6 Page 88 An appeal against the Council’s refusal with an associated Costs Application was submitted by the applicant (appeal ref: APP/E5330/W/20/3257735). The appealed was allowed subject to conditions on 23rd March 2021. No costs were awarded to either party. Details of the appeal and costs decision are included below within section 4.4 and 4.5 respectively.

4.2 19/4390/F – Planning permission was refused on the 16th April 2020 for the change of use of the ground floor level from A3/A4/D2/B1 to A3/A4/D1/D2/B1 (inclusion of D1 Educational Facility), with the installation of a partial mezzanine floor and associated external alterations to include the provision of 2 new entrances, introduction of bollards/ramps on Wellington Street and Polytechnic Street and removal of brick panels to provide additional windows and provision of cycle storage on ground level. The reasons for refusal were:

1. In the absence of any D1 details relating to pupil numbers and outdoor space the proposal fails to demonstrate that it does not negatively impacts the adjoining highways in terms of pickups and drop offs and how the quality of education provision would be acceptable and compliant to the Education guidance and standards. As such, the proposal is considered contrary to policies 3.1, 3.18 and 4.10 of the London Plan (2016) and policies CH, EA(c) and IM(a) of the Royal Greenwich Local Plan (2014).

2. In the absence of the plant and air conditioning equipment details the proposal by reason of its siting and close proximity creates unacceptable levels of pollution and vibration impacts upon adjacent residential units in the same development. As such, the proposal is considered contrary to policy 7.15 of the London Plan (2016) and policies CH1 and E(a) of the Royal Greenwich Local Plan (2014).

3. The location of the cycle parking provision provides a conflict between the new (non-residential) and existing (residential) uses leading to unacceptable safety and security concerns to existing occupiers of the residential units in the same development. As such, the proposal is considered to be contrary to policy 6.9 of the London Plan (2016) and policies CH1, IM4, IM(b) and IM(c) of the Royal Greenwich Local Plan (2014).

An appeal against the Council’s refusal with an associated Costs Application was submitted by the applicant (appeal ref: APP/E5330/W/20/3251833). As part of the appeal the Planning Inspector accepted additional information submitted by the applicant to overcome the reasons for refusal. Consequently, the Council confirmed to the Planning Inspector that only reason for refusal 2 remained relevant.

ITEM NO: 6 Page 89 The appealed was allowed subject to conditions on 23rd March 2021. No costs were awarded to either party. Details of the appeal and costs decision are included below within section 4.4 and 4.5 respectively.

4.3 19/3612/F – An appeal for non-determination (appeal ref: APP/E5330/W/20/3245415) was lodged for this application which sought planning permission for the change of use of the ground floor level from A3/A4/D2/B1 to D1 (Educational facility), with the installation of a partial mezzanine floor and associated external alterations to include the provision of 2 new entrances, introduction of bollards/ramps on Wellington Street and Polytechnic Street and removal of brick panels to provide additional windows and provision of cycle storage on ground level.

The Council submitted a SoC to the Planning Inspectorate on 18 May 2020. As part of the appeal the Planning Inspector accepted additional information submitted by the applicant to overcome the reasons for refusal. Consequently, only reason 2 from application 19/4390/F remained relevant to be included as a recommendation for refusal in the SoC.

The appeal was allowed subject to conditions on 23rd March 2021. Details of the appeal are included within section 4.4 of the report below.

4.4 Appeal Decisions 19/3612/F, 19/4390/F & 20/1164/F

Applications 19/3612/F, 19/4390/F & 20/1164/F were joined by the inspector owing to their similarity to each other.

In respect to application no. 20/1164/F (appeal ref: APP/E5330/W/20/3257735), the inspector assessed the effect of the proposals on the personal safety of pupils at the education facility. The inspector’s comments are as follows:

The main issue between the parties is the lack of defensible space which could be afforded by a boundary wall or some other structure to assist in protecting pupils. The Council’s reason for refusal reflects concerns over pupil safety in response to comments received from the Metropolitan Police. The Police do not make an objection in principle to the proposed use and suggest a planning condition designed to address its concerns.

The scheme includes an airlock entrance which allows all access to be controlled into the teaching areas by ‘fobs’ enabling access by staff only. The airlock entrance would prevent tailgating and pupils leaving without ITEM NO: 6 Page 90 permission. This lobby negates the need for a wall or some form of boundary treatment suggested by both the Police and interested parties. All primary and secondary entrance doors would be controlled via CCTV.

The proposed use has been confirmed as being suitable by both the Council’s Education Department, the DFE6 and Ofsted. Whilst I acknowledge the Council’s comments that the planning system seeks a broader view of proposals, the agreement of these bodies would be critical to the operational management of the proposed school.

Requirements to design out crime are a common thread through both the London Plan 2021 at Policy D11 and the Royal Borough of Greenwich Local Plan 2014 at Policy DH1. Policy CH1 of the Local Plan includes a requirement that development supports the creation of safe and secure environments. 41.

The inclusion of a planning condition, requiring further details of the security measures designed to address the concerns of the Metropolitan Police would address the Council’s objections to the proposed scheme. For these reasons, and subject to the suggested condition, I conclude that the proposed use would not conflict with Policy D11 of the London Plan (2021) and Policies DH1 and CH1 of the Royal Borough of Greenwich Core Strategy 2014.

In respect to application no.’s19/3612/F & 19/4390/F (appeal ref: APP/E5330/W/20/3245415 & 3251833), the Planning Inspector assessed the outstanding concerns regarding the effects of extraction and air conditioning plant on the living conditions of the occupiers of the flats in the upper floors. The inspector’s comments are as follows:

Underpinning this main issue is that the absence of detail and inconsistencies in what has been submitted for the air conditioning and extraction plant, prevents a full assessment of its impacts, on the living conditions of the occupiers of flats in the upper floors.

The Council’s objection to the scheme relates to the variation in the plans for the plant compared to its actual roof location together with a need for details of extraction method and the need for a ventilation and extraction strategy.

Policy D14 of the London Plan 2021 and Policy E(a) of the Greenwich Local Plan 2014 seek to protect the living conditions of existing occupiers from environmental disturbance to improve health and quality of life. ITEM NO: 6 Page 91

I am satisfied that the details submitted with the appeals of the proposed odour control methods are acceptable and would not adversely impact on the occupiers of the flats.

In their statement, the appellant has substantiated why roof top plant was located in a different position from that indicated on the submitted plans. However, there still remains a requirement to confirm the exact location of the roof top plant and other equipment. For this reason, I have included a condition in this letter required to address this matter.

I conclude on this main issue, and subject to the imposition of a condition, as described above, the appeal scheme would not conflict with Policy D14 of the London Plan (2021) which seeks to reduce and manage the effects of noise on residents and Policy E(a) of the Royal Greenwich Local Plan (2014) which seeks to protect the amenities of residents from effects of noise, vibration, emissions and fumes.

4.5 Costs Decision 19/4390/F & 20/1164/F (appeal ref: APP/E5330/W/20/3251833 & 3257735) – to summarise, the Planning Inspector found that whilst the appellant, in their desire to secure a planning permission could have addressed all matters referred to in the pre application advice from the outset, this situation was compounded by the Council in not accepting the additional information supplied. It was considered that both parties acted unreasonably and therefore no costs were awarded.

4.6 19/0659/F – Planning permission was approved on the 28th February 2020, for the construction of a lower ground floor extension for the relocation of cycle storage and conversion of plant area at upper ground floor to provide 262 sqm of A3, A4, B1 or D2 floorspace with the installation of windows on North and East elevations.

4.7 19/0656/F – Planning permission was approved on the 28th February 2020 for the construction of a lower ground floor extension for the relocation of cycle storage and creation of 2 x studio and 2 x 2-bed self-contained flats at upper ground floor level with the installation of windows on North and East elevations.

4.8 19/0658/F – Planning permission was approved on the 28th February 2020 for the construction of a lower ground floor extension for the relocation of cycle storage and creation of 3 residential units (1 x 1-bed and 2 x 2-bed) at upper ground floor level with the installation of windows on North and East elevations.

ITEM NO: 6 Page 92

4.9 18/0879/F – Planning permission was approved on the 30th October 2018 for the change of use of the lower ground floor to include Class B1 to already consented A3/A4/D2 uses.

4.10 18/0314/F – Planning permission was refused for the relocation of cycle storage to lower ground floor and conversion of plant room at upper ground floor to create five residential units (1 x 1-bed and 4 x bedsits).

This application was appealed and was subsequently dismissed on 4 January 2019. Appeal Ref. APP/E5330/W/18/3202424.

4.11 18/1583/F – Planning permission was refused on the 5th July 2018 for the relocation of cycle storage to lower ground floor and conversion of plant room at upper ground floor to create five residential units (5 x 1-bed).

This application was appealed and was subsequently dismissed on 4 January 2019. Appeal Ref. APP/E5330/W/18/3207817.

4.12 16/4052/F – Planning permission was refused on the 30th May 2017 Construction of an additional storey on top of previously approved five storey block to create four self-contained flats (1 x 1-bed, 2 x 2-bed and 1 x 3-bed).

This application was appealed and was subsequently dismissed on 10 July 2018. Appeal Ref. APP/E5330/W/17/3189667.

4.13 16/1499/V - Variation of conditions 41 (Brown Roof Details) & 42 (Brown Roof Insulation) of planning permission dated 19/03/15 (Ref: 13/2798/F) to replace Brown Roof with Wildflower Blanket Roof was approved on the 29th July 2016.

4.14 16/0086/V - Submission for a Deed of Variation to the Section 106 agreement dated 19th March 2015 (Ref: 13/2798/F) to remove part 1 (Affordable Housing) was not determined.

The non-determination of this application was appealed and was subsequently allowed on 16 April 2016. Appeal Ref. APP/E5330/W/17/3189667.

4.15 13/2798/F – Planning permission was approved on the 19th May 2015, for the demolition of existing buildings and the construction of a building comprising a lower ground level with five storeys providing 455sqm of A3/A4/D2 space on the ground floor and 34 residential units comprising 13 x 1 bed flats and 21 x

ITEM NO: 6 Page 93 2 bed flats with associated disabled car parking, cycle parking and refuse storage.

5. Proposals (in detail)

5.1 The current application seeks full planning permission for the following:

Change of use of the lower ground floor to include Class D1 (educational and medical/dentist use) to already consented A3/A4/D2/B1 uses with the installation of a partial mezzanine floor and associated external alterations to include the provision of 2 new entrances, introduction of bollards on Wellington Street and Polytechnic Street and removal of brick panels to provide additional windows, inclusion of rooftop plant, provision of cycle storage on lower ground level and other minor alterations..

5.2 This proposal relates to the creation of two separate units on the ground floor. A dentist would create a 98m² sized unit on the ground floor and an education use would create a 737m² sized unit on the ground floor and within a proposed the mezzanine floor, which would increase the existing floor space by 337m².

5.3 The proposal for an education facility and medical (dentist) (Use Class D1) to operate on the lower and upper ground floors of this building would fall outside of the approved use classes (Class A3, A4 and D2 – restricted by Condition 46 attached to the Permission) and Class B1 under Ref: 18/0879/F granted separately in 2018, and therefore requires planning permission to introduce an additional use on the site.

5.4 Notwithstanding point 5.3 above, since the application has been submitted, a single unit on the lower ground floor with a mezzanine has been approved for D1 use (education facility) (see applications 19/3612/F, 19/4390/F & 20/1164/F).

5.5 The proposed operating hours of the education facility would be 6:45am to 8pm Monday to Friday and 8am to 12pm on Saturdays. The dental practice is proposed to operate between 8am to 6pm Monday to Friday and 8am to 12pm on the Saturdays.

5.6 The Planning Statement states that the D1 education facility (Sumus Education and Tuition) would provide a varied educational offer including before/after school care, tuition and an alternative provision.

ITEM NO: 6 Page 94 5.7 A breakfast cub is proposed to operate between 7am to 9am Monday to Friday and would provide children with breakfast and learning. A private tuition service is also proposed after school on weekdays and on Saturday mornings.

5.8 The proposed daytime education facility would be an alternative provision to mainstream education offer for children 7 to 18 years of age who may need support.

5.9 A maximum capacity of 60 students have been proposed to be on-site at any one time.

5.10 It is also noted that the operation of the college requires the on-site preparation of hot food which requires plant associated with the discharge of pollution to be installed.

5.11 The proposed changes to the existing building as shown on the submitted plans are as follows: • Removal of 1 window facing Wellington Street and 2 facing Polytechnic Street to be replaced with doors to provide new formal entrance to the lower ground floor separate from the residential entrances. • Step free access into the building. • Internal layout changes. • Fresh air supply ventilation window included on ground floor Wellington Street facing elevation above existing residential entrance. • Installation of new curtain wall on ground floor windows along Wellington Street and Polytechnic Street. • Ventilation/Extraction system at roof level. 5.12 It is noted that the majority of these works were completed prior to gaining planning approval but have now been granted via applications 19/3612/F, 19/4390/F & 20/1164/F.

5.13 The application initially applied for an unfettered D1 use. Officers raised concerns that owing to the broad nature of the D1 use class, it would not be appropriate to grant approval for this use without details of the proposed operations of specifics sub uses. To overcome officers’ concerns, the applicant submitted amended plans and operational details for the site to be used as part education facility and part medical (dentist). The development description was also updated to reflect the proposed specific uses and the required consultation undertaken again.

5.14 Officers note that the most recently advertised development description states 2 new entrances were proposed however owing to the changes to the ITEM NO: 6 Page 95 application 3 proposed new entrances are now proposed. The development description has been updated to reflect 3 new entrances however it was not considered necessary to re-consult the application on this point. The development description does state ‘and other minor alterations’ and the advertised plans indicate the location of this new entrance.

5.15 A roof plan and some plant specification details were also provided after the consultation had expired. Given that these details could have been secured as part of a pre-commencement condition and that the plant was included within the development description and indicated throughout other application material, it was considered acceptable that this information was provided without the need to re-consult.

5.16 As set out within Section 4 of this report (Relevant Site History) and discussed throughout the report, there have been 3 recent appeal decisions on the site allowing a D1 (education facility). The current application proposes a similar scheme with the main difference being there would be a reduction (98m2) in overall floor space of the education unit at lower ground floor to allow for the inclusion of an independent medical / dentist unit. Consequently, an additional entrance along Polytechnic Street is also proposed. Therefore, officers note that principle of a D1 education facility use on-site has therefore been considered acceptable within these recent appeal decisions.

5.17 Apart from a reduction in floor space to the education facility and the inclusion on a new entrance off Polytechnic Street, there have not been material changes in circumstances, including policy, since the recent appeals were allowed to warrant a departure from consistency in decision making and accordingly Members are advised that the recent appeal decisions should be afforded significant weight.

5.18 Lastly, officers note that the Town and Country Planning (Uses Classes) Order 1987 (as amended) has been amended since the submission of this application and consequently the D1 Use Class has been split out and replaced by the new Use Classes E(e-f) and F1. As the application was submitted prior to these changes coming into effect, the using the old Use Classes is considered acceptable in this context.

ITEM NO: 6 Page 96 6. Consultation

6.1 The application since being submitted in April 2020 and has been subject of public consultation, comprising of a press notice, 2 x site notices and 53 individual letters, sent to individual occupiers in the vicinity of the application site. Re-notification of the application was also undertaken in October 2020 on the receipt of amended plans and changes to the development description.

6.2 Statutory Consultees A summary of the consultation responses received along with the officer comments are set out in table below:

Details of Summary of Comments Officers Representation comments and date received London Fire An undertaking should be given These Brigade that, access for fire appliances as requirements are required by Part B5 of the current required under Building Regulations Approved the building Document and adequate water regulations. supplies for firefighting purposes, will be provided.

This is without prejudice to any requirements or recommendations that may be made by the Authority under the Regulatory Reform (Fire Safety) Order 2005/Petroleum (Consolidation) Act 1928, the local authority or the Health and Safety Executive. Historic We do not wish to offer No comment England comments. GLASS It is not necessary for GLAAS to No comment comment. Metropolitan This proposal is a very similar to a These comments Police previous proposal for an are addressed in Educational facility on the site, to Section 16 of this which the Metropolitan Police report. objected. The concerns for this site as an Educational facility have not changed and the Metropolitan ITEM NO: 6 Page 97 Police still object to the site being used for this Educational facility.

Concerns relate to: - Building environs - Site location - Existing youth violence within area - Staffed route from public transport only proposed part of the day - Ofsted report does not consider location of school and how pupils would be protected outside the site, particularly after hours

The amended proposal for a dental practice does give some additional vulnerability to the rear shared entrance via the bin stores.

In terms of the development achieving ‘Secured by Design’ standards should the development still be approved. 2 suggested conditions were included relating to secure by design.

Detailed comments and 2 suggested conditions, relating to how secure by design could be achieved were also provided.

Following the appeal decisions for applications 19/3612/F, 19/4390/F & 20/1164/F the Metropolitan Police were re-consulted and provided the following comments:

I have had a meeting with the design team [the applicant’s] since

ITEM NO: 6 Page 98 the decision, where we agreed the physical security features required to achieve Secured by Design criteria. These are in line with the comments made in my previous formal reply so I am happy for those comments to remain.

6.3 Council Departments A summary of the consultation responses received along with the officer comments are set out in table below:

Details of Summary of Officers comments Representation Comments and date received Waste Services We are satisfied with the Issues relating to refuse bin area and the bins and recycling are assessed proposed, providing a in section 15 of this clinical waste bin is report. provided. Highways No highway objection is Issues relating to raised. highways are assessed in section 14 of this report. Environmental Regarding the above Issues relating to Pollution application, the proposed pollution are assessed in operational hours are section 12 of this report. generally similar timings to traditional business hours. So the likelihood of noise disturbance is reduced.

There is mention of rooftop plant in the description above, however no details have been provided. So subject to this being conditioned (Noise from fixed plant & equipment Condition), there is no objection

ITEM NO: 6 Page 99 Education Children’s Services has Issues relating to recently provided Education are assessed in comments in support of section 10 of this report another application relating to this property It is noted that application (Planning Inspectorate ref. no. 19/3612/F has been 3245415 – 38 Wellington recently approved by the St, Woolwich (LPA ref. planning Inspector. 19/3612/F).

If the proposals within application 20/1082/F enables 19/3612/F to progress, then Children’s Services supports this application. If this is not the case, Children’s Services has no comment.

Community No defensible spaces These comments are Safety Team between the pavement addressed in Section 16 and the front door to of this report. prevent the front door being infiltrated. No secure drop off point

There is not a clear unobstructed view to the front of the building from the reception.

There is also no escape route for the reception staff to leave safely if someone was to forcibly breach the front door.

The Premises is in Woolwich Town we would recommend that it be connected to the Town Centre Radio Scheme which would

ITEM NO: 6 Page 100 connect the school to Royal Greenwich CCTV Service in the event of an incident.

Placing an additional education provision within the town centre could potentially increase existing frictions between local schools and alternative provisions in the area.

The planning application makes no reference to the impact of child exploitation and youth related violence in Woolwich Town Centre and how they plan to combat this.

The plan makes no reference to how Sumus plans to work with Royal Greenwich in identifying young people from different boroughs who pose a risk to themselves and others attending the school.

Being a small provision of up to 50 students with a wide age group of 7 – 17 year old with different support needs, concerns of exploitation from children within the school is a concern.

ITEM NO: 6 Page 101 Sumus makes no account of how they intend to manage this.

6.4 Amenity Groups No representations from local amenity groups were received.

6.5 Local Residents and Businesses 2 objections were received by members of the public and are set out in table below:

Summary of objections Officers comments received Details regarding parking The red line boundary for this application and cycle parking for does not include the residential parking and existing resident are cycling areas and therefore these areas are incorrect not being assessed and cannot be changed as part of this application. Insufficient cycle parking Cycle parking has been addressed in section 14 of this report. Proposal will increase Issues relating to highways are assessed in crime impacting the section 14 of this report. residents safety and cycle storage It is noted that the proposal would not change the existing approved layout for the residents carparking area, as the red line boundary does not encompass this area. Conflict of interest with As indicated in the planning inspectors appeal proposed marketing decision for application no.’s 19/3612/F, report 19/4390/F & 20/1164/F this is not a planning matter. Fire access panels for the This is an issue relating to the existing building resident flats are showing and would not fall within the scope of the faults in several zones and planning application. have not been addressed by the developer for several month Proposed opening hours Operating hours and nuisance are discussed will generate unacceptable within Section 12 of this report. noise levels for residents’ early hours and weekends

ITEM NO: 6 Page 102 Air conditioning has been The red line boundary for this application installed within residents does not include the residential areas and car parking spaces. plant is not in these areas as part of this application. This would seem to be an enforcement matter if the plant within the car parking area has not been removed. Existing highways Pedestrian safety is discussed in Section 14 of infrastructure doesn’t this report provide safe crossing points for students Noise, pollution and Issues relating to highways operations a are highway congestion as a assessed in section 14 of this report. result of deliveries to the site and student drop off Issues relating to noise and pollution are and pick up. discussed in Section 12 of this report. No details regarding how Concerns relating to refuse and recycling are medical waste will be addressed in Section 15 of this report. disposed safety Plans suggest sharing The proposed waste storage room is separate waste facilities with the from the existing residential waste facility. residential building.

6.6 Councillors Councillor Fahy has called this application in to be determined by Members. 7. Planning Context

7.1 This application needs to be considered in the context of a range of national, regional and local planning policies and Supplementary Planning Guidance / Documents.

• National Planning Policy Framework (NPPF – 2019) • The London Plan (2021) - Full details of relevant policies refer to appendix 3. • The Royal Greenwich Local Plan: Core Strategy with Detailed Policies (“Core Strategy” – 2014) - Full details of relevant policies refer to appendix 3. • Full details of relevant SPD / Documents refer to appendix 3.

8. Material Planning Considerations

• Principle of Development; • Quality of Education Offer; • Design and Heritage; • Residential Amenity; • Inclusive Design • Transport and Access; • Refuse and Recycling; • Secure by Design; • Community Infrastructure Levy (CIL); • RBG CIL; and • Implications for Disadvantaged Groups

9. Principle of Development

Provision of D1 Use

9.1 The original 2015 approval for the building approved A3, A4 or D2 uses for the ground floor. Although none of these uses had physically occupied the premises, the residential component (upper floors) of the planning permission had been implemented and commenced. As such, an assessment is required to consider the impact of the loss of these uses. 9.2 In relation to the additional B1 use, this was approved under a separate planning permission (18/0879/F) in 2018.

9.3 Application no.’s 19/3612/F, 19/4390/F & 20/1164/F, all of which proposed a D1 education facility on the ground floor, were recently approved by the planning inspector and therefore the principle of a D1 education facility on the site is considered acceptable against current policy below. Nevertheless, consideration of the acceptability of the principle of the education use has still been addressed below.

9.4 The previous applications did not consider a D1 medical / dental use and therefore the principle of this specific use is also considered below.

9.5 Policy S2 of the London Plan (2021) (LP) states that development proposals that support the provision of high-quality new and enhanced health and social care facilities to meet identified need and new models of care should be supported. It also notes that new facilities should be easily accessible by public transport, cycling and walking.

9.6 Policy S3 of the LP states that development proposal for education and

ITEM NO: 6 Page 104 childcare facilities should: 1) locate facilities in areas of identified need 2) locate facilities in accessible locations, with good public transport accessibility and access by walking and cycling 3) locate entrances and playgrounds away from busy roads, with traffic calming at entrances 4) link to existing footpath and cycle networks to create healthy routes to schools, and other education and childcare facilities, to enable all children to travel actively to school (walk, cycle or travel by public transport) 5) maximise the extended or multiple use of educational facilities for community or recreational use, through appropriate design measures 6) encourage the shared use of services between schools, colleges, universities, sports providers, and community facilities, and between early years and health and social care providers 7) ensure that new developments are accessible and inclusive for a range of users, including disabled people, by adopting an inclusive design approach 8) ensure that facilities incorporate suitable, accessible outdoor space 9) locate facilities next to parks or green spaces, where possible

9.7 Policy CH1 of the Councils Core Strategy (2014) (CS) supports the Policies S2 and S3 above which looks to ensure development must include measures that help to create and maintain cohesive communities that encourage diversity and reduce inequalities between areas.

9.8 Policy EA(a) seeks to maximise the contribution to employment from sites in existing or previous employment uses. The proposal for an education facility and medical / dental use on the site would retain the floor space as an employment site. However, the proposal is still required to demonstrate that the proposed D1 use maximises the employment opportunities as a result of this change.

9.9 Policy TC1 of the Local Plan states that town centres are the preferred location for major retail, leisure, cultural, office and other uses that attract and serve the public. Supporting text 4.3.2 and 4.3.4 of this policy also mentions that community facilities are an important service within town centres and that the improvement of our town centres will provide residents with greater opportunities to access community facilities amongst other uses. It should be highlighted that within the Local Plan an education facility and a health care facility such as a dentist is a defined community use.

ITEM NO: 6 Page 105 9.10 Furthermore, the Woolwich Town Centre Masterplan SPD identifies the that the area bound by Market Street, Calderwood Street, Thomas Street and Wellington Street is Woolwich’s Municipal education quarter as it has unified clusters of civic and education buildings which span the Victorian, Edwardian and inter-war periods.

9.11 The proposal to include community uses consisting of a new education facility and medical / dental practice on-site is considered to be supported by the above mentioned policies. The medical / dental practice would increase the health facilities within the town centre. The proposed education facility would provide education and be located within the traditional education quarter of Woolwich Town Centre. Both uses would provide employment for the Borough and are located in a highly accessibly and central environment.

9.12 Furthermore, it is noted that given the broad range of differing uses which could be implemented under the current approvals (A3, A4 and D2 and B1 uses), it is considered that this demonstrates that the site is adaptable to many uses.

9.13 As such, the introduction of a D1 education facility and a D1 medical / dentist use on the site is considered acceptable, subject to proposal meeting the other material planning considerations which are considered in the rest of this report.

Loss of existing A3/A4/D2/B1 9.14 It is noted that when the original consent was granted at Planning Board in 2014, this was subject to a s106 legal agreement. This s106 was signed and completed on the 19th March 2015, and section 9 of the agreement stipulated the following: “The Developer covenants with the Council that it shall submit to the Council for its prior approval the D2 marketing Plan at least 6 months before the estimated Practical Completion of the non-residential floorspace and that following approval of the D2 Marketing Plan it shall implement such forthwith.

The Developer may not use the non-residential floor space for the purposes of A3 or A4 use (of the Town and Country Planning Use Classes) Order 1987, as amended) until the expiry of 2 years from the date of the start of the D2 Marketing as approved by the Council.”

9.15 The requirement for marketing the ground floor space for a D2 use over a ITEM NO: 6 Page 106 period of two years was included in the s106 legal agreement in an attempt to retain a specific community use on the site on the basis that many historical uses on the site were community uses.

9.16 The marketing evidence submitted, although limited does provide evidence of marketing the site for a potential D2 operator over a 2-year period. It is important to note that this same marketing material was submitted and initially considered acceptable in the previous application Ref: 18/0879/F where consent was granted for the additional B1 use. Furthermore, the proposal would bring in appropriate D1 uses that would ensure the vitality of the town centre location of Woolwich Town Centre is promoted. This would therefore promote sustainable economic growth in line with requirements of the NPPF, London Plan and Core Strategy.

9.17 Therefore, the principle of the provision of a D1 education facility and medical/dental use within the existing ground floor commercial space is acceptable in principle in meeting the above town centre and employment policies, subject to the development being acceptable in relation to the other material planning considerations listed in section 8 of this report which are assessed later in the report. 10. Quality of Education offer

10.1 Policy S3 of the LP states that development proposals for education and childcare facilities, amongst other requirements, should ensure that facilities incorporate suitable, accessible outdoor spaces.

10.2 Policy CH1 of the CS states that all development must include measures that help to create and maintain cohesive communities, that encourage diversity and reduce inequalities between areas and that developments are expected to support the development of new and improved community facilities where there are identified local needs and where the development is in line with the Royal Borough's strategy for the provision of services.

10.3 The proposal states that the education facility would be an alternative provision facility. It is noted that requirements for Alternative Provision Education differs from Schools. The Alternative Provision Statutory guidance for local Authorities (January 2013) defines Alternative provision as,

‘education arranged by local authorities for pupils who, because of exclusion, illness or other reasons, would not otherwise receive suitable education; education arranged by schools for pupils on a fixed period exclusion; and pupils being directed by schools to off-site provision to improve their behaviour.’ ITEM NO: 6 Page 107

10.4 The current application (20/1082/F) includes a similar same education offer to which was recently approved by the Planning Inspector for application no.’s 19/3612/F, 19/4390/F & 20/1164/F and is therefore considered acceptable on this basis. Nevertheless, for clarity an assessment of the education offer follows.

10.5 In relation to Policy S3 of the LP and Area guidelines for SEND and alternative Provision, the proposal includes a multipurpose (dining/social) indoor space and the Ofsted report for the site details that local park and leisure centres will assist in incorporating physical education classes into timetables. It is noted that Area guidelines for SEND and alternative Provision states:

An alternative approach on a restricted site is to use sports spaces at a nearby school or community sports centre, as long as there is safe access and the travel time has a minimal effect on the rest of the curriculum.

10.6 In relation to pupil numbers, the application has advised a maximum of 60 pupils would be on-site at once. 10.7 The site is considered to be restricted as it is limited in size and location within an existing mixed-use residential development.

10.8 The proposed multi-purpose space on-site is considered too small to meet the guidance however when paired with access to outdoor space off-site and when considering the proposal is for an alternative provision education rather than a general school which has greater outdoor space requirements, the scheme is considered to meet the guidance for outdoor space on balance.

10.9 The Council’s Education Department have reviewed the application material and commented that the D1 education proposal is acceptable.

10.10 Officers note that this application has been assessed against guidance for an Alternate Provision education only and not the requirements that would apply for a school. For instance requirements within the School Premises (England) Regulations 2012 (SPRs) and Building Bulletin 103: Area Guidelines for Mainstream Schools (BB103) detail greater requirements for outdoor space for schools which have not been applied for this application.

10.11 In respect to application no.’s 19/3612/F, 19/4390/F & 20/1164/F, the Council had proposed a personal use condition to limit the use of the site to alternative provision education. This was proposed given the lack of outdoor space and the generally cramped nature of the site. The planning inspector

ITEM NO: 6 Page 108 however decided that limiting the D1 use to education only was suitable as and noted the following:

The other matters would be controlled through the registration of the premises with both the DFE and Ofsted. The inclusion of planning conditions would duplicate controls managed through other legislation. For this reason, I do not consider that they would fulfil the tests laid out in Guidance.

10.12 As a summary, guided by the recent planning inspector decisions on-site for a D1 education facility, the proposal demonstrates that it would provide a suitable community D1 facility and would be comply to policy S3 of the London Plan (2021), policies CH1 and EA(c) of the Royal Greenwich Core Strategy (2014) and the Area guidelines for SEND and alternative Provision.

ITEM NO: 6 Page 109 11. Design and Heritage

11.1 The NPPF states when considering the impact of a proposed development on the significance of a designated heritage asset, great weight should be given to the asset’s conservation. The more important the asset, the greater the weight should be. Significance can be harmed or lost through alteration or destruction of the heritage asset or development within its setting. As heritage assets are irreplaceable, any harm or loss should require clear and convincing justification.

11.2 Policy HC1 states that development proposals affecting heritage assets, and their settings, should conserve their significance, by being sympathetic to the assets’ significance and appreciation within their surroundings.

11.3 CS Policy DH (i) criteria iv) states proposals for development which would detract from the setting and proportions of a Listed Building or Group will be resisted.

11.4 Policy DH(h) of the CS states that planning that planning permission will only be granted for proposals which pay special attention to preserving or enhancing the character or appearance of the Conservation Area and that the local scale, the established pattern of development and landscape, building form and materials will all be taken into account.

11.5 Policy DH1 of the Local Plan requires proposals to have a high quality of design and to be limited to a scale and design appropriate to the building and locality. This should take account of the established layout and spatial character of an area and the architecture of surrounding buildings. This is supported by policy D3 of the London Plan.

11.6 The site adjoins a Grade II* listed building on the corner of Wellington Street and Market Street (Town Hall). Additionally, the site falls within the recently designated Woolwich Conservation Area. Therefore, strong consideration is required as to how the proposal would affect the setting of the Grade II* listed building and the conservation area in general.

11.7 External alterations proposed to the existing building consist of the creation of one entrance along Wellington Street and two entrances along Polytechnic Street. Bollards would be with the construction of bollards in front of the two education facility entrances which open outwards. A glass panel is to be replaced above the residential entrance on Wellington Street for an air intake vent associated with a proposed ventilation system. Additionally, it is proposed to cover the ground floor front windows with a curtain wall. ITEM NO: 6 Page 110

11.8 The proposed facing materials would match the appearance of the rest of the building.

11.9 Officers consider the external alterations proposed to the building to be minor as the design of the entrances, the air vent and curtain walls match the style of the existing building and are not considered to be visually harmful.

11.10 The submitted plans also propose plant at roof level. The plant would be located towards the centre of the roof and would not be readily visible from the street scene.

11.11 It is noted that the proposed external works, with the exception of the proposed entrance door to the medical / dental unit off Polytechnic Street, were recently approved at appeal by the planning inspector and have already been completed. However, as these elements were included in this application at the point of submission, they have been included within this report for completeness.

11.12 As such, the external alterations to the elevations are considered to not harm the visual appearance of the existing host building, nor the setting of the adjoining Grade II* listed Town Hall or the greater Woolwich Conservation Area and would continue to comply with policies regarding design and impact on the setting of the listed building as per the original design of the building.

12. Residential Amenity

Daylight/sunlight, outlook and privacy

12.1 Policy DH(b) of the CS states that extensions will only be permitted where it can be demonstrated that the proposal does not cause an unacceptable loss of amenity to adjacent occupiers by reducing the amount of daylight, sunlight or privacy they enjoy or result in an un-neighbourly sense of enclosure.

12.2 The alterations proposed to the elevations are not considered to impact on any adjoining occupier’s residential amenity in terms of overlooking and loss of privacy over and above any impact that was deemed from the consented upper floors residential units. As such, the alterations would comply with policy DH(b) of the CS.

Noise, Disturbance and Pollution

ITEM NO: 6 Page 111 12.3 Policy D14 of the LP sets out that development proposals should seek to proactively manage noise impacts in a variety of ways where possible. Proposals should use good design to mitigate and minimise existing and potential nuisances generated by uses and activities located in the area.

12.4 Policy E(a) of the CS states that planning permission will not normally be granted where a proposed development or change of use would generally have a significant adverse effect on the amenities of adjacent occupiers or uses, and especially where proposals would be likely to result in the unacceptable emission of noise, light, vibrations, odours, fumes, dust, water and soil pollutants or grit.

12.5 The site is within in a mixed-use building in a town centre location where these types of uses are encouraged. The application site is also located on a busy road with high levels of ambient noise owing to the number of vehicles including local buses that frequent Wellington Street.

12.6 The application proposes to be open 6:45am to 9pm Monday to Friday and 8am to 12pm on Saturdays. These opening hours are less than what is currently approved for the A3, A4, B1 and D2 uses, and are similar to the recently approved operating hours for a D1 education facility on-site.

12.7 Given that the site is located within a town centre and that the proposed operating hours are considered to be reasonable considering the location, the D1 uses are not expected to generate noise levels which would be out of character for the area, and are expected to be less than noise levels which would be expected from the existing approvals over the site. Therefore, on this basis, the anticipated noise pollution generated from the proposed D1 education facility and medical / dental use is considered acceptable.

12.8 Although the proposal is acceptable in terms of the location, given the mixed- use nature of the proposal, the proposal must not adversely affect the existing residential properties within the building. Given that the ground floor unit already exists, it is expected that existing levels of residential amenity would be retained.

12.9 The proposal also includes an extraction system to cater for the proposed kitchen associated with the education facility. The applicant has submitted a roof plan indicating the location of the extraction system on the roof and provided some detail relating to the specification of this plant however further details are required such as odour control and extraction system details within each unit. Therefore, further details are required and would be secured via condition. As such the proposal would comply with Policy D14 of the ITEM NO: 6 Page 112 London Plan (2021) and Policy E(a) of the Royal Greenwich Core Strategy (2014).

13. Inclusive design

13.1 Policies DHI and CH1 of the CS seek to secure developments that contribute to a safe environment to users and the public. Lifetime neighbourhoods are designed to be welcoming, accessible and inviting for everyone regardless of age, health and disability.

13.2 Policy IM(c) of the CS requires that Developments must provide the minimum level of car parking provision necessary, for people with disabilities, as set out in the London Plan.

13.3 Policy D5 of the LP states development proposal should achieve the highest standards of accessible and inclusive design.

13.4 Policy T6.5 of the LP states that disabled persons parking should be provided in accordance with the levels set out in Table 10.6, ensuring that all non- residential elements should provide access to at least one on or off-street disabled persons parking bay, and disabled persons parking bays should be located on firm and level ground, as close as possible to the building entrance or facility they are associated with. It is noted that the standard for non- residential disabled persons parking within table 10.6 are based on a percentage of the total number of parking bays proposed. As no parking is proposed, the standard therefore requires 1 disabled persons parking bay to be provided.

13.5 Step free access is proposed for the education unit along Wellington Street and a lift is proposed internal to move between the lower and upper ground floors. Step free access is proposed for the medical / dentist use off Polytechnic Street.

13.6 No on-site accessible parking bays are provided owing to site constraints. The applicant does identify that there are two accessible on-street car spaces within 30m of the site along Polytechnic Street and 2 spaces along Bathway. Officers however note that access to the lift for the education unit is along the Wellington Street entrance which is further away. Nevertheless, the proposal is located in a highly accessible location and given the site constraints, the proposal is acceptable in terms of providing a safe and accessible environment for people visiting the building.

ITEM NO: 6 Page 113 13.7 The proposal is therefore considered to comply with policy D3 of the London Plan (2021), and policies IM(c), DH1 and CH1 of the Royal Greenwich Core Strategy (2014).

14. Transport and Access

14.1 The NPPF recognises that sustainable transport has an important role to play in facilitating sustainable development but also contributing to wider health objectives. In particular it offers encouragement to developments which support reductions in greenhouse gas emissions and those which reduce congestion. The NPPF also outlines that developments which generate significant vehicle movements should be located where the need to travel will be minimised and the use of sustainable transport options can be maximised. It is also expected that new development will not give rise to the creation conflicts between vehicular traffic and pedestrians.

Car parking

14.2 The application site has an excellent PTAL rating of 6b and falls within Woolwich Arsenal CPZ subject to on-street parking controls between Monday to Saturday 08:30 to 18:30.

14.3 In relation to the demand for car parking on the site for the proposed opening hours, the proposed D1 uses would be accessed from a variety of people at a variety of times during the day. In this instance, considering the excellent PTAL, being located within the Woolwich Town Centre which provide a range of services, and that lack of space on the site, there would be no requirements for car parking.

14.4 The education facility would cater for a maximum of 60 pupils and have 15 employees. The medical / dental facility would have up to 16 employees. Therefore, it is considered that the proposal would not result in significant parking pressures on the adjoining highways in terms of pickups and drop offs above previously approved uses on the site.

Cycle parking

14.5 LP Policy T5 states that developments should provide secure appropriate level of cycle parking which is fit for purpose, secure and well located and meet the ITEM NO: 6 Page 114 minimum standards set out in the table 10.2 and the guidance set out in the London Cycling Design Standards. Table 10.2 states that D1 uses such as Universities and Colleges should provide 1 space per 4 staff and 1 space per 20 FTE students for long stay visitors and 1 space per 7 FTE students for short stay visitors. In terms of D1 dentists, the table identifies 1 space should be provided per 5 FTE staff for employees and 1 space per 3 FTE staff for customers. Policy IM(c) of the CS states that developments must meet, as a minimum, the standards for cycle parking as set out in the LP.

14.6 The highways officer initially commented that the proposed cycle parking accessed through the bin was not ideal and would be likely to dissuade users. On re-consultation of the proposal the highways officer provide no objection.

14.7 The applicant has confirmed that 16 secure and sheltered cycle parking spaces (double stacked arrangement) would be located within the building. The cycle storage room would be accessed through the bin store which opens to Polytechnic Street and would have a separate direct internal access to the building. The submitted plans indicate the route to the cycle storage room would be level. Although concerns were initially raised by the highways officers regarding the proposed arrangement, officers considered it to be acceptable. The arrangement to access the cycle store through the bin store has been accepted with the recent appeals over the site and would not impact upon the use of the building for the existing residents.

14.8 While it is noted that no cycle provision was secured for the previous approvals relating to the A3, A4, D2 and B1 uses, the proposed educational use is considered to have a greater demand for cycle parking considering it would cater for students. A total of 15 staff are proposed and a maximum of 60 pupils. As such, the proposal would provide sufficient cycle parking in accordance with the LP requirements.

14.9 Further, it is noted that the submitted cycle storage solution requires a minimum height of 2.6m whereas, it is understood that the maximum clearance height at the location where the cycle storage is proposed has a maximum height of approximately 2.3m. It is considered that an alternative cycle storage solution would be able to fit in this location and therefore a condition is recommended on any approval to secure the design and provision of the amended cycle parking. 14.10 Notwithstanding the above, officers have sought clarification on whether these cycle spaces would be available for use by both the dentist and the education use. The proposed cycle parking is located in an area which provides access to the education facility and officers would seek separate

ITEM NO: 6 Page 115 cycle parking for each unit. Further, the submitted floor plans for the D1 education use does not show the cycle parking but the site plan does.

14.11 Given the above lack of clarity regarding the provision of cycle parking and discrepancies between plans, officers have recommended a condition requiring the submission of amended plans for each unit for the provision of suitable cycle parking. The condition requires that each unit be provided with cycle parking in accordance with the requirements of Policy T5 of the LP. The inclusion of this condition is a similar approach to the how the Planning Inspector required amended plans to be submitted for inconsistencies regarding the roof top plant as part of the recent appeals on the site, and therefore is considered suitable.

Pedestrian Environment

14.12 Policy IM(b) of the CS states that new developments should promote walking and cycling safety with well lit, signed and well-maintained routes and safe facilities for crossing roads and at transport interchanges.

14.13 The proposal includes doors which open out over a private forecourt and includes bollards to warn pedestrians of the door opening. This is required as there is no visual distinction between the private forecourt and the footpath. Within previous applications on the site, the highways officer has recommended visibility panels be includes within these doors to further identify to pedestrians when one of these doors are open. As such, the comply with the abovementioned policies a recommended condition of approval requires visibility panels to be included in these outward opening doors.

14.14 It has been raised that the site provides a poor pedestrian environment for students crossing the road. Officers note that Polytechnic Street is one way, is a single lane and has coloured pavement at the junction of Wellington Street indicating a formalised nut not controlled crossing point. Wellington Street has a formalised light crossing in close proximity to the site. As such, officers consider that the pedestrian environment is acceptable.

Conclusion

14.15 Officers consider that the development would provide a suitable quality and quantity of cycle parking and facilities, and an appropriate pedestrian environment to deliver a sustainable development and therefore would ITEM NO: 6 Page 116 comply with the policies regarding transport listed within this committee report.

15. Refuse and Recycling

15.1 Policy S1 8 of the LP states Development Plan should plan for identified waste needs.

15.2 Core Strategy Policy DH1 states that to achieve a high quality of design, all developments are expected to demonstrate on-site waste management including evidence of waste reduction, use of recycled materials and dedicated recyclable waste storage space.

15.3 The proposed refuse and recycling room would be shared between the education facility and the medical/ dental use. This room would be separate from the existing residential waste storage rooms and would be accessed from Polytechnic Street.

15.4 The Council’s Waste Team provided no objection to the proposal subject to medical waste bin being provided. Further details can be secured via a planning condition ensuring the appropriate bins and storage requirements are secured. As such, subject to a condition of approval, the proposal is considered to comply with the relevant waste and recycling policies.

16. Secured by Design

16.1 Policy D11 of the LP states development should include measures to design out crime that – in proportion to the risk – deter terrorism, assist in the detection of terrorist activity and help mitigate its effects.

16.2 Policy DH1 of the CS states that all developments are expected to demonstrate how they contribute to a safe and secure environment for users and the public. Policy CH1 goes to state that all developments must include measures that help to create and maintain cohesive communities.

16.3 The proposal has been assessed by the Metropolitan Police Designing Out Crime Officer. The Officer objected to the scheme on the basis that the proposal lacks sufficient details to demonstrate a safe and secure environment and the location, within the Woolwich city centre, is wrong for an education centre for children who have a higher degree of social, emotional and behavioural needs and who have been excluded from mainstream education

ITEM NO: 6 Page 117 as the building will become a focal point for recruiting new gang members and those wishing to expand a criminal network.

16.4 The Council’s Community Safety team also reviewed the proposal and had similar concerns to the Metropolitan Police.

16.5 Planning Officers note that the principle of development has already addressed the suitability of the building to be used as an education centre from a planning perspective. It would be up to future occupiers of the building to ensure the facility is operated in a manner which discourages and limits the behaviour mentioned earlier.

16.6 In relation to providing a safe and secure education facility, officers note that although the proposal cannot provide a secure site boundary owing to the site constraints, the application does have the ability to internally secure the site via various internal alterations.

16.7 The Metropolitan Police have noted that if this was to be recommended forward as an approval, then the following conditions are suggested:

• The development hereby permitted shall incorporate security measures to minimise the risk of crime and to meet the specific security needs of the development in accordance with the principles and objectives of Secured by Design. Details of these measures shall be submitted to and approved in writing by the local planning authority prior to commencement of the development and shall be implemented in accordance with the approved details prior to occupation. • Prior to occupation a satisfactory Secured by Design inspection must take place. The resulting Secured by Design certificate shall be submitted to and approved by the local planning authority.

16.8 Officers also note that the concerns raised by the Metropolitan Police and the Council’s Community Safety team were provided to the Planning Inspector in considering the previously appeals on the site for an D1 Education Facility. The Planning Inspector noted that subject to the imposition of conditions requiring the submission of security measures and compliance with secure by design standards, the Metropolitan Police and the Council’s concerns would be addressed. In coming to this conclusion, the Planning Inspector noted that the proposed use has been confirmed as being suitable by both the Council’s Education Department, the DFE6 and Ofsted and the agreement of these bodies would be critical to the operational management of the proposed school.

ITEM NO: 6 Page 118 16.9 Subject to conditions, it is considered that the proposed development would reduce opportunities for criminal behaviour and contribute to a sense of security generally, in accordance with Policy D11 of the London Plan (2021) and Policy DH1 and CH1of the Council’s Core Strategy (2014).

17. Community Infrastructure Levy (CIL)

17.1 The Mayor has introduced a London-wide Community Infrastructure Levy 2 (CIL 2) to help implement the London Plan, particularly policies 6.5 and 8.3. The Mayoral CIL2 formally came into effect on 1st April 2019, and it will be paid on commencement of most new development in Greater London that was granted planning permission on or after that date. The Mayor's CIL will contribute towards the funding of Crossrail. The Mayor has arranged boroughs into three charging bands. The rate for Greenwich is £25 per square metre.

17.2 It is noted that all new floorspace including the floor area created by the proposed mezzanine would be CIL liable (see High Court decision in R (Orbital Shopping Park Swindon Ltd) v Swindon Borough regarding the CIL impacts of the inclusion of mezzanine floor space within an application).

17.3 The current application is liable to this requirement

18. RBG CIL

18.1 The Royal Borough adopted its Local Community Infrastructure Levy (CIL) charging schedule, infrastructure (Regulation 123) list, instalments policy and exceptional circumstances relief policy on the 25th March 2015 and came into effect in Royal Greenwich on the 6th April 2015.

18.2 The current application is not liable to this requirement.

19. Implications for disadvantaged groups

19.1 The implications for disadvantaged groups identified below are an integral part of the consideration of the development and community benefits as set out in the report:

• There are no identified implications for disadvantaged groups.

ITEM NO: 6 Page 119 20. Conclusion

20.1 The proposal for a D1 use (educational facility and Medical / dentist use) occupying the lower and upper ground floors of the existing building and in an accessible town centre location is acceptable in principle in land use terms. Additionally, the proposal would provide a suitable quality of education offering and provide additional health care facilities for the borough. The scheme would also contribute to local employment.

20.2 The proposed external alterations to the building are considered to be in keeping with the style of the existing building and appropriate for the locality.

20.3 Subject to the imposition of conditions the proposal would provide acceptable waste storage and cycle parking, the proposal would not impact existing residents to an unacceptable level. The proposal would not lead to any significant parking pressures within the surrounding roads.

20.4 Subject to the imposition of the secure by design condition the proposal would provide a safe and secure facility given the site constraints.

20.5 Accordingly, it is recommended that permission be approved for application reference 20/1082/F, in line with Section 1 of this report.

Background Papers: National Planning Policy Framework (NPPF – 2019) The London Plan (2021) Royal Greenwich Local Plan: Core Strategy with Detailed Policies (2014) Council's Waste Guidance Notes May 2018

Report Author: Matthew Lund (Planning Officer) Tel No.: 020 8921 4398 Email.: [email protected]

Reporting to: Victoria Geoghegan, Assistant Director Planning & Building Control Tel No.: 020 8921 4296 Email.: [email protected]

ITEM NO: 6 Page 120 APPENDICES Appendix 1 - Drawing numbers

The following drawings and associated documentation have been submitted by the applicant in support of application reference 20/1082/F:

8502-01 Rev C, 8502-04, 8502-06 Rev E, 8502-17 Rev C, 8502-18 Rev D, 8502-20, 010, 011, 012, 001-375, Covering Letter dated 18 August 2020, Design and Access Statement dated April 2020, Planning Statement dated April 2020, Heritage Impact Assessment dated April 2020, Operational Statement, Ofsted School pre-registration inspection report dated 29-30 July 2020, Rebuttal Letter dated 9 November 2020, Lynx AC (Technical Data for Fan Model – SLC450-1EC (9.7 Speed)), External Products & Finishes, John D Wood Marketing Letter dated 25 October 2019 and Airclean Baffle Type Grease Filters specifications

ITEM NO: 6 (Appendices) Page 121 APPENDICES Appendix 2 – Conditions and Informatives

1. Conditions

Condition 1 (Time Limit) The development to which this permission relates must be begun not later than the expiration of three (3) years beginning with the date on which the permission is granted.

Reason: As required by Section 91 of the Town and Country Planning Act 1990.

Condition 2 (Approved Drawings) The development shall be carried out strictly in accordance with the application plans, drawings and documents hereby approved and as detailed below:

Reason: In the interests of good planning and to ensure that the development is carried out in accordance with the approved documents, plans and drawings submitted with the application and is acceptable to the local planning authority.

Condition 3 (Materials to Match Existing) The materials to be used for the external surfaces of the development hereby permitted shall match those of the existing building. All new works and works of making good to the retained fabric shall be finished to match the adjacent work unless otherwise stated on the approved drawings.

Reason: To ensure that the high design quality demonstrated in the plans and submission is delivered so that the local planning authority may be satisfied as to the external appearance of the building and to comply with Policies D3 and HC1 of the London Plan (2021), and Policies DH1 and DH3 of the Core Strategy (2014). ITEM NO: 6 (Appendices) Page 122 APPENDICES

Condition 4 (Restrict Use Class (D1) Notwithstanding the provisions of the Town and Country Planning (Use Classes) Order 1987 as amended, and the Town and Country Planning) General Permitted Development) (England) Order 2015 (or any Order revoking and re-enacting these Orders with or without modification), the D1 uses hereby approved shall be restricted to an Educational Facility and a Medical / Dental Use as identifies with the application material approved in Condition 2 and no other uses within the D1 Use Class, without the prior written approval from the Local Planning Authority.

Reason: In order to safeguard the amenities of neighbouring properties and the area generally and to ensure compliance with Policy D14 of the London Plan (2021) and Policy E(a) of the Core Strategy (2014).

Condition 5 (Cycle Parking Provision) a) Notwithstanding the drawings hereby approved, prior to occupation of the development, full details of the cycle parking facilities must be submitted to and approved in writing by the local planning authority, including details of the dimensions of the cycle storage room and of the double stacking bike system that fits within. The submission of these details will require amended layouts of each unit to that of the approved drawings in Condition 2 above. b) A minimum of 16 secure and dry cycle parking spaces shall be provided within the development for the education use only. c) A minimum of 10 secure and dry cycle parking spaces shall be provided within the development for the medical / dentist use only. d) All cycle parking spaces shall be provided in accordance with the approved details and made available for use prior to the first occupation of the development and maintained thereafter for the lifetime of the development.

Reason: To promote sustainable travel and to ensure compliance with Policy T5 of the London Plan (2021), and Policies IM4 and IM(b) of the Core Strategy (2014).

Condition 6 (Accessibility) a) Prior to the occupation of the development, drawings illustrating that the D1 use in the development hereby permitted comply with Building Regulations requirements M1, M2 and M3, have been submitted to and approved in writing by the Local Planning Authority in consultation with the Council's Housing Occupational Therapist.

ITEM NO: 6 (Appendices) Page 123 APPENDICES b) The development shall be carried out and retained for the lifetime of the development in accordance the approved details.

Reason: To accord with Policies S3 and D5 of the London Plan (2021) and Policy DH1 of the Core Strategy (2014).

Condition 7 (Hours of Operation) The D1 (educational facility) unit hereby permitted shall not operate outside of the following hours: • Monday to Friday - 6.45am to 8.00pm; and • Saturdays - 8.00am to 12.00pm

The D1 (medical / dentist use) unit hereby permitted shall not operate outside of the following hours: • Monday to Friday - 8am to 6.00pm; and • Saturdays - 8.00am to 12.00pm

Reason: In the interests of securing a good living environment for the prospective occupiers of the land and the adjoining properties and to ensure compliance with Policy D14 of the London Plan (2021) and Policies E(a) and DH(b) of the Core Strategy (2014).

Condition 8 (Secured by Design) a) No development shall commence on-site until details of security measures have been submitted and approved in writing by the Local Planning Authority which shall be in line with the standards set out by `Secured by Design'. The approved security measures must be implemented prior to the occupation of the development. b) Prior to the first occupation of the units hereby consented, confirmation that door and window products that meet the standard recommended by Secure by Design for that building has been achieved shall be submitted to and approved in writing by the Local Planning Authority.

Reason: To ensure that Secured by Design principles are implemented into the development in accordance with policies D11 of the London Plan (2021) and Policy DH1 of the Core Strategy (2014).

Condition 9 (Visibility Panels)

ITEM NO: 6 (Appendices) Page 124 APPENDICES Prior to the commencement of the use hereby approved, vision panels must be included within the outward opening doors over the private forecourts along Wellington Street and Polytechnic Street.

Reason: To ensure the safety of footpath users and to comply with Policy IM(b) of the Royal Borough of Greenwich Local Plan.

Condition 10 (Refuse and Recycling) Prior to the occupation of the development hereby approved, full details of the refuse storage, recycling facilities and refuse collection arrangements shall be submitted to, and approved in writing by, the Local Planning Authority. The refuse and recycling details should be in accordance with Council's Waste Guidance Notes May 2018 and include a medical waste bin for use by the Medical / Dentist use.

The storage and recycling facilities shall in all respects be constructed in accordance with the approved details, before the relevant part of the development is first occupied and maintained for the lifetime of the development.

Reason: In order that the Council may be satisfied with the details of the proposal and to ensure compliance with Policy S1 8 of the London Plan (2021) and Policies H5 and DH1 of the Core Strategy (2014).

Condition 11 (Plant details) Prior to the commencement of the relevant part of the development, an extraction method and a ventilation and extraction strategy must also be submitted to the Local Planning Authority for Approval. The scheme shall thereafter be implemented in complete accordance with the approved details.

Reason: To protect the living conditions of existing occupiers from environmental disturbances to improve health and quality of life and comply with Policy D14 of the London Plan (2021) and Policies DH(b) and E(a) of the Core Strategy (2014).

ITEM NO: 6 (Appendices) Page 125 APPENDICES

Appendix 3 – National, regional and local planning policies and Supplementary Planning Guidance / Documents.

1. National Planning Policy Framework (NPPF Feb 2019)

Chapter 6 Building a strong, competitive economy Chapter 7 Ensuring the vitality of town centres Chapter 8 Promoting Heathy and safe communities Chapter 9 Promoting sustainable transport Chapter 11 Making effective use of land Chapter 12 Achieving well-designed places Chapter 16 Conserving and Enhancing the Historic Environment

2. The London Plan (2021)

The London Plan policies relevant to this application are:

Chapter 1 – Planning London’s Future – Good Growth GG1 Building strong and inclusive communities GG5 Growing a good economy

Chapter 2 – Spatial Development Patterns SD6 Town centres and high streets SD7 Town centres: development principles and development plan documents

Chapter 3 - Design D1 London’s form, character and capacity for growth D3 Optimising site capacity through the design-led approach D5 Inclusive design D14 Noise

Chapter 5 – Social infrastructure S1 Developing Social Infrastructure S3 Education and childcare facilities

Chapter 7 – Heritage and Culture HC1 Heritage conservation and growth

Sustainable Infrastructure SI1 Improving air quality SI8 Waste capacity and net waste self-sufficiency

ITEM NO: 6 (Appendices) Page 126 APPENDICES Chapter 10 – Transport T1 Strategic approach to transport T2 Healthy Streets T4 Assessing and mitigating transport impacts T5 Cycling T6 Car parking

3. The Royal Greenwich Local Plan: Core Strategy with Detailed Policies (“Core Strategy” – 2014)

The main Core Strategy policies relevant to this application are:

Economic Activity and Employment EA(a) Local Employment Sites

Town Centres Policies TC1 Town Centres TC2 Woolwich Town Centre

Design and Heritage Policies DH1 Design DH3 Heritage Assets DH(b) Protection of Amenity for Adjacent Occupiers DH(h) Conservation Areas DH(i) Statutory Listed Buildings

Environment and Climate Change Policies E1 Carbon Emissions E(a) Pollution E(c) Air Pollution

Cohesive and Healthy Communities Policies CH1 Cohesive Communities CH2 Healthy Communities

Infrastructure and Movement Policies IM4 Sustainable Travel IM(b) Walking and Cycling IM(c) Parking Standards

ITEM NO: 6 (Appendices) Page 127 APPENDICES 4. Supplementary Planning Guidance / Documents

The following planning guidance / documents are considered relevant:

• Mayor’s Housing SPG (2016) • Woolwich Town Centre Masterplan SPD (2012) • Waste and Recycling for New Developments (Updated May 2017) • Waste Guidance Notes (May 2018) • Woolwich Conservation Area Designation Assessment • Building Bulletin 104 - Area guidelines for SEND and alternative provision (December 2015)

ITEM NO: 6 (Appendices) Page 128