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planning report PDU/2659/01 25 August 2010 Norwood Hall,

in the Borough of planning application no.10/02230

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

The proposal Demolition of existing community hall and redevelopment of the site comprising the construction of a part 1, part 2 and part 4 storey building on existing open space to the northeast of the site to provide a Joint Service Centre incorporating 2,702 sq.m. of floorspace (Use Class D1) to provide a customer service centre, primary care health centre, community meeting rooms; and 2,702 sq.m. of floorspace (Class D2) to provide a leisure centre (including a swimming pool and a gym), a dance studio, and a cafe with outdoor seating area; landscaping of existing and new open space including levelling of parts of the site involving earthworks; creation of a new woodland nature area to the north of the site, re-modelling of the entrance road from Knight's Hill to include a turning point for coaches and an informal drop off point, and provision of associated parking for 18 cars (including 4 disabled spaces) and 74 cycle parking spaces. The applicant The applicant is Building Better Health LSL Ltd., and the architect is Allford Hall Monaghan Morris.

Strategic issues The proposal raises serious strategic policy concerns with regard to the loss of open land and playing fields. Further work and discussion is also required on design, access, sustainable development and transport before the application is referred back to the Mayor.

Recommendation

That Lambeth Council be advised that the application does not comply with the , for the reasons set out in paragraph 73 of this report; but that the possible remedies set out in paragraph 75 of this report could address these deficiencies. The application does not need to be referred back to the Mayor if Lambeth Council resolve to refuse permission, but it must be referred back if Lambeth Council resolve to grant permission.

Context

1 On 15 July 2010 the Mayor of London received documents from Lambeth Council notifying him of a planning application of potential strategic importance to develop the above site for the

page 1 above uses. Under the provisions of The Town & Country Planning (Mayor of London) Order 2008 the Mayor has until 25 August 2010 to provide the Council with a statement setting out whether he considers that the application complies with the London Plan, and his reasons for taking that view. The Mayor may also provide other comments. This report sets out information for the Mayor’s use in deciding what decision to make.

2 The application is referable under Category 3E of the Schedule to the Order 2008: ”Development which does not accord with one or more provisions of the development plan in force in the area in which the application site is situated; and comprises or includes the provision of more than 2,500 square metres of floorspace for uses falling within the following classes in the Use Classes Order – class D1 (non-residential institutions) and class D2 (assembly and leisure).”

3 Once Lambeth Council has resolved to determine the application, it is required to refer it back to the Mayor for his decision, as to whether to direct refusal; or allow the Council to determine it itself, unless otherwise advised. In this instance if Lambeth Council resolves to refuse permission it need not refer the application back to the Mayor.

4 The Mayor of London’s statement on this case will be made available on the GLA website www.london.gov.uk. Site description

5 The site is located in the Knight’s Hill ward of Lambeth, in West Norwood. It is bounded by the residential areas of Prioress Road to the west and Canterbury Grove to the north, Network Rail land to the east and Devane Way and London Quadrant offices to the south. The site includes the existing Norwood Hall (disused since 1997), and is largely characterised by steeply sloping open space which slopes down towards the railway. Lambeth Council’s adopted UDP designates much of the site as open space, while the adjoining railway corridor is designated as a Borough site of nature conservation. The site also lies within an area of local archaeological importance.

6 Primary access to the site is obtained via Devane Way off A215 Knight’s Hill which is located to the east of the site, and forms part of the Strategic Road Network (SRN). Approximately 100m east of the site is West Norwood train station, which is served by trains from Victoria and London Bridge to West . 10 bus routes serve the proposed development from the A215 Norwood Road, less than 200m from the site. This generates a Public Transport Accessibility Level (PTAL) of between 4 and 5, on a scale where 1 is low and 6 is high.

Details of the proposal

7 The proposal is for a new joint service centre to include leisure and healthcare facilities on the sloping open space adjacent to the existing vacant Norwood Hall building. The existing Norwood Hall would be demolished and the site cleared and landscaped to re-provide a significant proportion of the open space lost due to the development of the new building. The re-provided open space would be levelled using material excavated in order to accommodate the new joint service centre building, therefore rendering it more usable for informal recreation. The area adjacent to the cafe would be designed as a toddlers play area, allowing parents to overlook the area.

8 The facilities provided by the joint service centre are listed below:

 25m swimming pool  80-100 station gym  dance studio

page 2  wet and dry changing areas  customer service centre  cafe and outdoor seating area  meeting rooms/community venues  two GP suites  dentistry suite  sessional suite with two group rooms  clinical suite  open plan office accommodation for staff  shared staff facilities

9 Proposals also include a remodelling of Devane Way to include a turning point for coaches, 18 car parking spaces (including 4 disabled spaces), and 74 cycle parking spaces. Case history

10 There is no relevant strategic case history. Site visit

11 A site visit was carried out by the case officer on 9 August 2010. Strategic planning issues and relevant policies and guidance

12 The relevant issues and corresponding policies are as follows:

 Open land London Plan; PPG17; draft PPS Planning for a Natural and Healthy Environment  Playing fields London Plan; PPG17, draft PPS Planning for a Natural and Healthy Environment  Biodiversity London Plan; the Mayor’s Biodiversity Strategy; PPS9; draft PPS Planning for a Natural and Healthy Environment  Urban design London Plan; PPS1  Access London Plan; PPS1; Accessible London: achieving an inclusive environment SPG; Planning and Access for Disabled People: a good practice guide (ODPM)  Equal opportunities London Plan; Planning for Equality and Diversity in Meeting the spatial needs of London’s diverse communities SPG; Diversity and Equality in Planning: A good practice guide (ODPM)  Sustainable development London Plan; PPS1, PPS1 supplement; PPS3; PPG13; PPS22; draft PPS Planning for a Low Carbon Future in a Changing Climate; the Mayor’s Energy Strategy; Mayor’s draft Climate Change Mitigation and Adaptation Strategies; Mayor’s draft Water Strategy; Sustainable Design and Construction SPG  Transport and parking London Plan; the Mayor’s Transport Strategy; PPG13

13 For the purposes of Section 38(6) of the Planning and Compulsory Purchase Act 2004, the development plan in force for the area is the 2007 Lambeth Unitary Development Plan and the London Plan (Consolidated with Alterations since 2004).

page 3 14 The following are also relevant material considerations:  The draft replacement London Plan, published in October 2009 for consultation.  The Lambeth Core Strategy (Submission Stage, March 2010).  The Lambeth Site Allocations Development Plan Document (Issues and Options Stage, July 2009). Principle of development

15 The application site is located predominantly on land designated as open space in Lambeth Council’s adopted UDP, and identified as playing field on the Council’s UDP proposals map. The red line boundary also encompasses an area of ‘white land’ (excluded from the open space designation) at the south and southwest of the site, which accommodates the main site access and existing community hall building.

16 The site is identified in Lambeth’s Local Development Framework Submission Stage Core Strategy as suitable for a joint service centre, including leisure and community uses. This designation is reflected by the Council’s West Norwood Masterplan, and the emerging Site Allocations DPD which identifies a preferred use of a sports hall and health centre, while retaining and improving open space at the site.

17 Chapter 3 of the London Plan is concerned with, amongst other things, open space, and Policy 3D.8 states that “The Mayor will work with strategic partners to protect and promote London’s network of open spaces, to realise the current and potential value of open space to communities and to protect the many benefits of open space...”.

18 The proposals involve demolishing the existing Norwood Hall, building the joint service centre on land currently designated as open space and playing field, and re-providing an area of landscaped open space in the currently undesignated ‘white land’ area (opened up by the demolition of the existing hall).

19 The proposals involve a significant reconfiguration of open space at the site, and result in an increase in built footprint of approximately 1,644 sq.m, and an increase in hardstanding of 1,523 sq.m. to 3,098 sq.m. in total (in order to provide improved site access and formal car and cycle parking). In terms of designated open space, the proposal would result in the net loss of 2,159 sq.m., or approximately 24% of the existing total. However, the proposed re-provision in the location of the existing hall would reduce the net loss at the site to 436 sq.m or 6% of the existing total (excluding hardstanding).

20 The applicant accepts that the loss of open space at the site is significant, but argues that the current amenity grassland at the site is of ‘poor quality’ and has only limited recreational or sporting use due to the sloping nature of the land. The proposals involve a ‘cut and fill’ approach to accommodate the proposed built development while creating an almost level area to provide a play area, seating area and grass space for informal ball games. In this way the applicant seeks to mitigate the loss of open space by providing replacement space of a higher quality.

21 The London Plan seeks to realise the full potential of open spaces that are currently undervalued, but makes clear that poor quality is not reason in itself to justify the loss of open space. In this particular case Lambeth Council have expressed the desire for community intensification of the Norwood Hall site through their emerging LDF, identifying the need for better leisure facilities in the Norwood area, and exploring the potential for a primary health care resource at this site with NHS Lambeth. A detailed site assessment was carried out by the Council and NHS Lambeth between 2005 and 2007 which identified the Norwood Hall site as suitable to

page 4 accommodate a joint service centre. The applicant cites this as justification for the proposed development at the site, coupled with the proposed improvements to the remaining areas of open space.

22 While the principle of a joint service centre in this location accords with the findings of the site selection process, and the aspirations of the Council’s emerging LDF, concern is raised with regard to the proposed approach to developing the site.

23 While it is accepted that the proposals enhance public access and look to provide a levelled and landscaped area of improved open space, the current configuration of development would appear to maximise the area of designated open space that would be lost by the proposals.

24 The submitted design and access statement suggests a number of development configurations have been considered at the site, including ‘Option 1A’, an approach to build over the footprint of the existing Norwood Hall (largely outside of the area designated as open space). Very limited information has been provided on the feasibility of this option, and the applicant is asked to give further justification as to why this approach cannot be pursued in order to retain the maximum amount of useable open space at the site.

25 Policy 3D.8 in the London Plan also seeks to protect the benefits of open space associated with health, sport and recreation. Emerging policy in the draft replacement London Plan reinforces this principle, and policy 3.20 seeks to support proposals that increase or enhance the provision of sports and recreation facilities while resisting any net loss of such facilities or playing fields.

26 The applicant’s claim that the sloping nature of the site severely limits the potential of the open space to be used for sport is accepted on the basis that there is a 6m change in elevation from west to east across the area designated as playing field.

27 The built element of the proposed development would provide facilities for a range of leisure and sporting activities, greatly enhancing the site’s potential for sport and recreation. This is expected to increase participation in such activities in an area where there is currently a lack of provision, and could also encourage greater use of the associated open space at the site.

28 Lambeth Council consulted Sport on the application who provided a response on 18 August 2010. The response states that Sport England does not object in principle to the application as it “clearly presents a substantial opportunity to create indoor sports facilities on a playing field of poor quality.”

29 Notwithstanding this, it is considered that these benefits could still be achieved while retaining much of the existing area of playing field and open space if a more sympathetic approach to developing the site were to be adopted (similar to that outlined in Option 1A). The applicant must provide greater justification for the configuration, as proposed, before the loss of the playing field could be acceptable.

30 The need for a health centre and sporting facilities in the area has been identified by Lambeth Council as part of their LDF process, with the decision to locate a joint service centre at Norwood Hall made following a detailed site selection process. It is accepted that part of the loss of open space arising from the built development would be offset by the demolition of the existing Norwood Hall, and that the joint service centre will greatly enhance the provision of sporting and care facilities in the Norwood area. However, there are concerns with regard to the configuration of the development and associated access and hard standing which will result in a significant reduction in open space at the site. Further information should be provided on the feasibility of building in the location of the existing hall, in order to determine whether the proposed approach, and associated loss of open space and playing field can be justified.

page 5 Biodiversity

31 The application site is not situated within any designated nature conservation sites, however, there are a number of sites of local importance nearby, including Railsides which adjoins the east of the site. The majority of the application site itself is of a low value for biodiversity, consisting largely of mown amenity grassland. However, a portion of land running along the north and east of the site offers a belt of woodland, tall herbs and rough grassland which provides greater biodiversity value.

32 Proposals to retain the wooded area and improve it through careful management and planting are supported in line with Policy 3D.14 which expects new development to seek opportunities to achieve positive gains for biodiversity conservation. Policy 3D.14 and 4A.11 would also support proposals to include a total of 950 sq.m. of green and brown roofs on top of the joint service centre. This would offer the potential for additional biodiversity gains at the site and should be secured by planning condition. Urban design

33 Good design is central to all objectives of the London Plan and is specifically promoted by the policies contained in chapter 4B. London Plan policy 4B.1 sets out a series of overarching design principles for development in London. Other polices in chapter 4B and elsewhere in the London Plan set out design requirements relating to specific issues. Chapter 7 of the draft replacement London Plan sets out design related policies.

34 The concerns identified in the ‘Principle of development’ section in this report regarding the site configuration apply equally to the consideration of the design and the proposed layout, and have not been demonstrated as consistent with the requirements of London Plan policy 4B.1.

35 On the basis of the material so far presented the design rationale for the positioning of the new building is not accepted as sound given the policy bearing on the site, the site context and the nature of the open space. Furthermore it is not clear that the applicant has given sufficient consideration to alternative layouts that could offer a more policy compliant solution, specifically locating the new building at the western end of the site, on the current site of Norwood Hall, abutting Prioress Road, in a manner similar to that considered under ‘Option 1A’ of the West Norwood Masterplan.

36 A design solution of this nature would appear to offer a better fit with national, strategic and local planning policy, the site context and the nature of the open space. In design terms such a solution would minimise or negate the need for any loss of playing fields, regularise the boundary of the open space and provide surplus soil to facilitate the re-profiling of the open space to the north to enhance its function. The northern and eastern edge could continue to be landscaped and managed for biodiversity with the new building and associated disturbance being as distant as possible. It would also have the distinct advantage over the current proposal of making the building readily visible from the main access from Knight’s Hill and provide a more legible and secure approach to the building. In short there is much to commend an alternative design approach and little presented that would appear to rule this out or support the proposal in its current configuration.

37 Notwithstanding the above comments the architecture of the building itself is well resolved and would readily accommodate the various functions contained within while exploiting the change in levels on the site. A similar architectural approach should be applied to developing a proposal for the alternative configuration proposed above.

page 6 Accessibility

38 Inclusive design principles if embedded into the development and design process from the outset help to ensure that all of us, including older people, disabled and deaf people, children and young people, can use the places and spaces proposed comfortably, safely and with dignity. The aim of London Plan policy 4B.5 is to ensure that proposals achieve the highest standards of accessibility and inclusion (not just the minimum). The design and access statement should therefore explain the design thinking behind the application and demonstrate how the principles of inclusive design, including the specific access needs of disabled people, have been integrated into the proposed development and how inclusion will be maintained and managed.

39 The submitted design and access statement addresses issues of inclusive access, and the expressed aspiration to exceed the statutory requirements of the Building Regulations (Part M) is supported.

40 As expressed in the ‘Urban design’ section of this report the built element of the scheme appears to be well resolved, and it is clear that the principles of inclusive design have been considered throughout the design process. The provision of lifts at each of the stairwells in the building ensures that all areas of the building have level access for both visitors and staff and is supported. The proposed allocation of accessible WCs, showers and changing rooms is acceptable, and the provision of a poolside platform lift, hoist, and wheelchair storage facilities to encourage inclusive use of all the leisure facilities is supported.

41 However, the substantial level changes across this area of the site present significant challenges for inclusive access in the surrounding public realm. Concern is raised with regard to the new access route at the north of the site off Canterbury Grove. While the intention to provide access from this location is supported, it is not apparent from the material submitted how a wheelchair user would gain inclusive access to the main entrance and external cafe seating area when arriving to the site from Canterbury Grove. The plans propose three sets of landscaped steps and raised planting to deal with the level change from west to east towards the main entrance. This means a wheelchair user must continue down the path to the coach turning point at Devane Way before turning back towards the main entrance. This represents a very significant detour and is not in accordance with the principles of London Plan policy 4B.5.

42 The applicant should address this concern by providing a means of inclusive access from the Canterbury Grove footpath down to the main entrance area.

43 It should be noted that the most severe level changes are likely to be avoided if the built element of the scheme were to be located on the site of the existing Norwood Hall building as discussed in the ‘Urban design’ section of this report. Sustainable development and climate change

44 The London Plan climate change policies as set out in chapter 4A collectively require developments to make the fullest contribution to tackling climate change by minimising carbon dioxide emissions, adopting sustainable design and construction measures, prioritising decentralised energy supply, and incorporating renewable energy technologies with a target of 20% carbon reductions from on-site renewable energy. The policy sets out ways in which developers must address mitigation of and adaptation to the effects of climate change. Chapter 5 of the draft replacement London Plan considers climate change.

45 The applicant has broadly followed the energy hierarchy in Policy 4A.1 and sufficient information has been provided to understand the proposals as a whole. The regulated carbon

page 7 dioxide emissions of the proposed development, based on a 2006 Building Regulations compliant development, have been estimated to be 335 tonnes of CO2 per annum. The applicant should, however, also provide an estimate of unregulated emissions and a breakdown of the tonnes of carbon dioxide emissions from regulated and unregulated energy at each tier of the energy hierarchy.

Be lean

46 A range of passive design features and demand reduction measures are proposed to reduce the carbon emissions of the proposed development. Both air permeability and heat loss parameters will be improved beyond the minimum requirements set by building regulations. Other features include energy efficient lighting, ‘a’ rated boilers and high efficient heat recovery air handling plant.

47 The applicant has included a combined heat and power (CHP) plant in its estimate of savings from energy efficiency. CHP falls under the ‘Be clean’ tier of the energy hierarchy. The applicant should, therefore, re-calculate the savings from energy efficiency separately.

48 Best practice suggests that up to 25% carbon dioxide savings (compared to 2006 Building Regulations) can be achieved through energy efficiency measures alone in similar developments. The applicant should aim to achieve or exceed this.

49 The applicant should also provide a table of the proposed building parameters e.g. air permeability, U-values, etc., against the values used for the 2010 Building Regulations Notional Building.

Be clean

50 No information has been provided on existing or potential district heating schemes in the area. The applicant should investigate district heating schemes within the vicinity of the proposed development. If there are no existing networks the applicant should commit to ensuring the development is equipped with the provision for future connection to a district heating scheme, should one be installed locally.

51 A 140kWe CHP unit is proposed as the lead heat source to supply domestic hot water, space heating and heating the swimming pool. The electricity produced by the CHP onsite will be used to power the electrical equipment for the pool with an option to be used for the essential NHS Lambeth equipment and the rest exported to the grid.

52 The development is estimated to emit 287 Tonnes of regulated carbon dioxide emissions per annum after the application of CHP (and passive design, energy efficiency). A cumulative reduction in carbon dioxide emissions of 14% compared to the Target Emissions Rate of a 2006 Building Regulations compliant development will be achieved after the second element of the energy hierarchy.

53 Percentage carbon dioxide reductions in regulated emissions from CHP alone, over and above those due to energy efficient design, should also be provided separately along with the load profiles to support the sizing of the CHP. Prior to the consideration of renewables, the size of the CHP should be optimised.

54 High levels of insulation, solar shading, thermal mass, and window configurations to admit good levels of daylight without excessive solar gain are proposed as part of the cooling strategy. Mechanical ventilation is also proposed to provide ventilation and cooling. The applicant states,

page 8 however, that the principle at Norwood Hall is not to rely on air conditioning to keep the building cool.

55 Air source heat pumps will also be used to provide cooling in the server rooms, IT rooms and rooms with high internal gains that cannot be controlled through passive measures.

Be green

56 The applicant proposes the use of 45kW air source heat pumps to provide under-floor heating in the scheme. This is primarily in the changing rooms. The system proposed is a stand alone distribution network which provides this heating requirement. The applicant should commit to connecting the space heating for the changing rooms to the site heat network supplied by the CHP or provide robust reasoning why the changing room’s space heating cannot be connected to the network.

57 80 sq.m. (9.7kW) of photovoltaic array is proposed. A roof drawing showing the amount of roof area available to install photovoltaic modules has also been provided.

58 The development is estimated to emit 219 tonnes of regulated carbon dioxide emissions per annum after the application of renewable energy. A reduction in carbon dioxide emissions of 24%, compared to the emissions after energy efficiency and CHP, will be achieved through this third element of the energy hierarchy.

59 In summary, the estimated regulated carbon emissions of the development are 219 tonnes of carbon dioxide per year after the cumulative effect of energy efficiency measures, CHP and renewable energy has been taken into account. This equates to an overall reduction of 34% compared to a 2006 Building Regulations compliant building. However, further information is required, in respect to the points made above, before the carbon savings can be verified and the scheme justified as acceptable in line with the London Plan. Transport

60 On site car parking is to be restricted to 14 spaces for essential NHS users and 4 disabled parking bays. This is supported by TfL and is in accordance with the London Plan policy 3C.1 and 3C.23, and emerging policy 6.13 in the draft revised London Plan. TfL also welcomes the proposed car park management strategy which should be secured by planning condition.

61 No on-site parking is provided for the leisure centre and the site is not within a Controlled Parking Zone (CPZ). Whilst it is recognised that this is an issue for the Council to determine, TfL would advise that consideration be given to the implementation of parking controls on the A215 Knight’s Hill, an SRN road, in order to minimise the impact of overspill parking on bus services.

62 The application proposes that the existing vehicle access from A215 Knights Hill will be retained, with alterations to improve pedestrian and cyclist facilities, as well as to accommodate coaches. TfL is concerned about the proximity of this access to the existing zebra crossing which will result in vehicles waiting to turn right into the site blocking the crossing and requests further research regarding this impact.

63 The road access from A215 Knights Hill will be a shared surface. It is essential that the design and material used meet the needs of mobility or visually impaired users. In order to comply with the London Plan policy 3C.21 and the draft revised London Plan policy 6.10. To ensure the safety of all users TfL recommend that a segregated access is provided.

page 9 64 A secondary pedestrian access point is proposed from Canterbury Grove to the north of the site. The applicant carried out a pedestrian audit of the surrounding area and identified a number of deficiencies in the pedestrian environment along Canterbury Grove. The works required to address these deficiencies should be secured either through a planning condition or through the Section 106 agreement.

65 TfL has concerns in relation to coaches entering, turning and exiting the site via a shared surface. TfL requires further information as to how these manoeuvres would be facilitated in order to maintain safety of all users. In addition, TfL requests clarification on the location of parking spaces for coaches that are waiting for a visiting school party. The proposed coach management strategy is welcomed by TfL and should be secured by a planning condition in consultation with TfL.

66 A total of 29 cycle spaces are proposed for the staff in the joint service centre, with an additional 45 spaces for visitors. TfL welcomes this level of provision, which is considered to be an appropriate number and is consistent with the draft revised London Plan Table 6.2. In addition, the development includes the provision of sheltered storage, secure lockers and shower and changing facilities for staff, which conforms with the London Plan policy 3C.22 and draft revised London Plan policy 6.9.

67 TfL confirms that the development will not have a significant impact on bus service capacity. However, in order to improve the accessibility to the existing bus network, TfL requests a capped contribution of £20,000 to remove street clutter and to adjust kerb height. This will enhance accessibility to the bus network for users of this site.

68 A framework travel plan has been submitted as part of this application. However, the applicant must commit to provide a travel plan for each occupier on the site and determine how they will integrate into the site-wide travel plan. Further work is required before the plans can be considered to be in line with London Plan policy 3C.2 and draft revised London Plan policy 6.11. The travel plan should be secured, enforced, funded, monitored and reviewed as part of the Section 106 agreement.

69 In addition, a construction management plan and a delivery and servicing management plan should be conditioned, in line with London Plan policy 3C.25 and draft revised London Plan policy 6.14. Local planning authority’s position

70 The view of the local planning authority is not known at the time of writing this report. Legal considerations

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

page 10 Financial considerations

72 There are no financial considerations at this stage.

Conclusion

73 London Plan policies on open land, playing fields, biodiversity, urban design, access, sustainable development and transport are relevant to this application. The application complies with some of these policies but not with others, for the following reasons:

 Open land and playing fields: Insufficient evidence has been provided to justify the loss of open space and playing field at the site. The proposal does not comply with London Plan policy 3D.8.  Biodiversity: The retention and improvement of the wooded area and provision of green and brown roofs offer the potential for biodiversity gains at the site and are supported.

 Urban design: It has not been demonstrated that the proposal is consistent with the requirements of London Plan Policy 4B.1.

 Accessibility: Further work is required to ensure accordance with London Plan policy 4B.5.

 Sustainable development: Further information is required.

 Transport: Further information is required.

74 On balance, the application does not comply with the London Plan.

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

 Open land and playing fields: Further information should be provided on the feasibility of building in the location of the existing hall, in order to determine whether the proposed approach, and associated loss of open space and playing field can be justified in accordance with London Plan policy 3D.8.  Urban design: Further information should be provided on the feasibility of building in the location of the existing hall, in order to demonstrate that the design meets the requirements of London Plan policy 4B.1.

 Accessibility: The applicant should address the concerns raised in the ‘Access’ section of this report and provide a means of inclusive access from the Canterbury Grove footpath down to the main joint service centre entrance.

 Sustainable development: The applicant should address the points raised in the ‘Sustainable development and climate change’ section of this report.

 Transport: The applicant should address the points raised in the ‘Transport’ section of this report.

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for further information, contact Planning Decisions Unit: Colin Wilson, Senior Manager – Planning Decisions 020 7983 4783 email [email protected] Justin Carr, Strategic Planning Manager (Development Decisions) 020 7983 4895 email [email protected] Graham Clements, Case Officer 020 7983 4265 email [email protected]

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