planning report PDU/2699a/01 14 December 2011 , Lane

in the Borough of Enfield planning application no.TP/11/0830

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

The proposal Masterplan for development of the north east corner of the site to provide replacement and additional accommodation for horticulture, animal care and arboriculture centres (OUTLINE - access, layout and scale). The applicant The applicant is Capel Manor College, and the architect is DLA Town Planning Ltd.

Strategic issues Green Belt, education, urban design, access, sustainable development, and transport are the strategic issues relevant to this scheme.

Recommendation

That Enfield Council be advised that the application does not comply with the London Plan, for the reasons set out in paragraph 46 of this report; but that the possible remedies set out in paragraph 48 of this report could address these deficiencies. The application does not need to be referred back to the Mayor if Enfield Council resolve to refuse permission, but it must be referred back if Enfield Council resolve to grant permission.

Context

1 On 11 November 2011 the Mayor of London received documents from Enfield Council, notifying him of a planning application of potential strategic importance to develop the above site for the above uses. Under the provisions of The Town & Country Planning (Mayor of London) Order 2008 the Mayor has until 22 December 2011 to provide the Council with a statement setting out whether he considers that the application complies with the London Plan, and his reasons for taking that view. The Mayor may also provide other comments. This report sets out information for the Mayor’s use in deciding what decision to make.

2 The application is referable under Category 3D of the Schedule of the Order 2008: “Development – (a) on land allocated as Green Belt or Metropolitan Open Land in the development plan, in proposals for such a plan, or in proposals for the alteration or replacement of

page 1 such a plan; and (b) which would involve the construction of a building with a floor space of more than 1000 square metres or a material change in the use of such building.”

3 Once Enfield 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 Enfield 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 development site is located towards the north east corner of the college grounds and currently comprises mostly of single buildings (the Duchess of Devonshire Building being the exception at 2 storeys) and an informal open parking area.

The application site (showing Development sites “A”, “B” and “C”) - Source: Applicant’s document & Google map)

6 Immediately to the north, screened by some high trees, is the M25. Along the eastern boundary is the and beyond this are some commercial developments and the A10/ M25 junction (Junction 25).

7 The site falls within the grounds of a Grade II* listed building, Capel Manor. It is also within the Metropolitan Green Belt and the majority of the site falls within the Conservation Area.

8 The M25 Junction 25 is only two minutes from the college and the M25 runs close to the Estate’s northern boundary. The nearest main bus stop is located approximately 400m east of the College on Bullsmoor Lane (A1055). The bus stop is served by the 217 and 317 services. Further to the east, the 327 also runs along Bullsmoor lane. There are no London Underground or rail services within walking distance of the site. As a result, the public transport accessibility level of the site is 1 (where 1 is low and 6 is high). This equates to a very poor level of access to public transport.

Details of the proposal

9 Outline planning permission (access, layout and scale) is sought for a Masterplan in respect of the development of the north east corner of the site to provide replacement and additional accommodation for horticulture, animal care and arboriculture centres, and staff accommodation.

page 2 The master plan identifies three sites within the estate (Development Sites ‘A’, ‘B’ & ‘C’), which will be the focus of future development.

10 The proposal seeks to replace and provide additional accommodation to help maintain the exemplar status of the college, and to re-establish the integrity of the historical element of the estate by relocating some activities currently spread around the estate to the north east corner. The key elements of the development include:

 Animal Care Building (Development Site ‘A’) - This will contain animal care facilities, additional toilets, a veterinary facility, science study area, classrooms and staff room and will have an area of approx 1,163 sq.m. over 2 ½ stories. This building will update, expand and replace existing facilities in substandard buildings on the site Stockyard Building (Development Site ‘A’).

 The stockyard (Development Site ‘A’) – This is a replacement facility for the existing animal housings and its design will reflect that of the Animal Welfare Building. It is also intended to refocus all the animal enclosures currently spread across the site to create a small animal zoo housing exotic and semi exotic animals but with the larger animals being relocated to Farm.

 Staff Cottage (Development Site ‘A’) - This element will be a 2-storey building that will be located immediately to the east of the stockyard building to provide supervisory accommodation for the animals housed within the stockyard and animal care buildings.

 Duchess of Devonshire Building (Development Site ‘B’) - The proposed 2-storey extension will be located to the south of the existing building. The design will reflect the existing building with the existing southern stair tower being used to link the extension to the existing building.

 Arboriculture Building (Development Site ‘C’) - This will remain at its existing location near to the historical heart of the site and will replace existing timber workshops. The building will contain an all weather tree climbing facilities workshop and classroom facilities. The architecture will be designed to complement the nearby Frank Parkinson building.

 Hessayon Refurbishment - This building is to be re-planned to provide an improved flow of students and visitors to the flower court and main campus buildings, providing two classrooms and shops. A small section to the rear of the building will be demolished to provide a wider entrance to the garden part of the site. Case history

11 A revised scheme for the erection of detached building to provide staff office and IT suite with associated facilities together with extension link between existing floristry block (ref:TP/07/0113) was granted on 27/02/2007.

12 Planning permission (ref: TP/06/1247) was granted in October 2006 for the extension of the existing building involving a single storey infill extension between the two existing buildings, and the erection of a third linked building to provide a new IT suite. Strategic planning issues and relevant policies and guidance

13 The relevant issues and corresponding policies are as follows:

page 3  Green Belt London Plan; PPG2  Education London Plan  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)  Sustainable development London Plan; PPS1, PPS1 supplement; PPS3; PPG13; PPS22; draft PPS Planning for a Low Carbon Future in a Changing Climate; Mayor’s Climate Change Mitigation Strategy; Mayor’s Climate Change Mitigation and Energy Strategy; Mayor’s Water Strategy; Sustainable Design and Construction SPG  Transport London Plan; the Mayor’s Transport Strategy; PPG13; Land for Transport Functions SPG

14 For the purposes of Section 38(6) of the Planning and Compulsory Purchase Act 2004, the development plans in force for the area are the 2010 Enfield Council Core Strategy, saved policies of the 1994 Enfield UDP and the 2011 London Plan.

Principle of use/ educational accommodation

15 In relation to the provision of educational facilities, policy 3.18 'Education facilities' of the London Plan states that “Development proposals which enhance education and skills provision will be supported, including new build, expansion of existing facilities or change of use to educational purposes”.

16 Capel Manor College is a specialist land-based further education college, having its main site at Bullsmoor Lane, a farm at forty Hall and ancillary sites at Regent’s Park, , Crystal Palace Park and Castle Green in Dagenham. The educational vision of the College is to create a network of centres across London to provide all Londoners with access to world class learning opportunities relating to land-based green skills in the education sector.

17 It is acknowledged that there is a need for additional accommodation for horticulture, animal care and arboriculture centres at the Capel Manor College. Therefore, the extension of the College for education purpose is supported. Green Belt

18 The application site is designated as Green Belt. Policy 7.16 of the London Plan clearly indicates that Green Belt is to be protected from inappropriate development, and such inappropriate development should not be approved except in very special circumstances. The London Plan also makes clear that London’s growth should be sustainable and not encroach on

page 4 London’s own precious green spaces (paragraph xi). The reference to “inappropriate development” flows directly from PPG2, which sets out the Government’s policy towards Green Belt.

19 PPG2 identifies the purposes of Green Belt, which are: to check the unrestricted sprawl of large built up areas; to prevent neighbouring towns from merging; to assist in safeguarding the countryside from encroachment; and to assist in urban regeneration by encouraging the recycling of derelict land. Government guidance states that development is inappropriate unless it is for the following purposes:

 Agriculture and forestry

 Essential facilities for outdoor sport and recreation; for cemeteries; and for other uses of land, which preserve the openness of the Green Belt

 Limited extension, alteration or replacement of existing dwellings

 Limited infilling or redevelopment of major existing developed sites identified in adopted development plans, which meet the criteria in Annex C of PPG2

20 The proposed development is inappropriate as defined by PPG2, the London Plan and Enfield UDP policies. That said, the only possible justification for allowing this proposal would be if very special circumstances could be demonstrated i.e. sufficient to outweigh the harm that would be caused to the Green Belt by the inappropriate development. There is no precise definition of ‘very special circumstances’ and each planning application has to be judged on its own merits.

21 In July 2011 the Government published a ‘draft National Planning Policy Framework’ (dNPPF) for public consultation, which is intended to replace all existing national planning policy (PPGs and PPSs). The dNPPF maintains that inappropriate development should only be permitted where ‘very special circumstances’ exist. Paragraph 144 sets out that 'A local planning authority should regard the construction of new buildings as inappropriate in Green Belt. Exceptions to this include the replacement of a building provided the new building is not materially larger than the one it replaces.'

22 The proposal seeks planning permission for the preparation of a Masterplan for development of the north east corner of the site to provide replacement and additional accommodation for horticulture, animal care and arboriculture centres (OUTLINE - access, layout and scale). It is noted that there is a net increase of 893 sq.m. in footprint, though the overall footprint of the proposed scheme is 1,203 sq.m. There will also be an overall height increase of approximately 3m in the current application than the existing buildings. That said, the proposed development is contained within the area of the existing built environment. It is also considered that the buildings are a size necessary to meet the College’s teaching needs.

23 However, the increase in floorspace, height and scale of development has the potential to impact on the openness of the Green Belt. Consequently, the applicant must demonstrate how the harm to the openness is outweighed by other considerations so as to amount to the very special circumstances necessary to justify the development.

24 To this end, the applicant has put forward four special circumstances (the appropriateness of agricultural-oriented college in the Green Belt, the enhancement of a nationally significant education establishment, the improvement to community learning facilities and the rationalisation of existing development confining development to the north east corner of the site).

page 5 25 The very special circumstances forwarded by the applicant with the exception of the first would not be acceptable on their own as special circumstances. It is understood that the college provides courses related to horticulture, garden design, animal care, arboriculture, countryside management and the environment, each of which offers considerable practical teaching in agriculture and forestry. These courses are suited to the semi rural location of Capel Manor. Although the primary use of the site is education, its main purpose is for horticultural, animal care and arboricultural studies. This type of education is directly related to the purpose of agriculture and forestry which is an appropriate use in the Green Belt. Therefore, this is considered as a very special circumstance in its own right.

26 The rationalisation of existing structures and their siting further away from the historic core of the estate is welcomed but is not in itself a very special circumstance. This is because whilst the proposal would largely be centred away from the historic core, the development is still inappropriate in Green Belt terms. However, the building will be sited upon an existing area of hard standing and will not be seen in views from the north (M25) due to the tree screen or views from the wider site to the south due to the presence of other buildings and vegetation within the estate. In this regard, the rationalisation of existing development confining development to the north east corner of the site is considered to have positive contributions in minimising the impact on the openness of the Green Belt.

27 Annex C of PPG2 provides guidance on Higher and Further Education (HFE) sites within the Green Belt. The Annex brought such institutions under the same Green Belt controls as other developments whereas previously they were excluded, resulting in development on a scale that was considered inappropriate for the Green Belt.

28 The proposed development would not meet the tests contained in Annex C3 (Infilling) or C4 (Redevelopment). This is because the development cannot be considered to be infilling or redevelopment due to the proposal having impact on the purposes of including land in the Green Belt. In particular, the Animal Care Building will exceed the height of the existing buildings (by approximately 3m), and the development would occupy a larger area of the site than existing buildings.

29 That said, on balance, it is considered that in this instance, the proposed development will not detrimentally harm the open character of the Green Belt as the proposal will result in development being confined to one part of the estate, and will improve the central part of the estate through the removal of some existing structures. Most importantly, as the college provides courses related to agriculture and forestry (which is an appropriate use in Green Belt), this by itself constitutes a very special circumstance and it is acceptable.

Urban design

30 Good design is central to all objectives of the London Plan (2011) and is specifically promoted by the policies contained within chapter seven which address both general design principles and specific design issues. London Plan Policy 7.1 sets out a series of overarching design principles for development in London.

31 Other design polices in this chapter and elsewhere in the London Plan include specific design requirements relating to maximising the potential of sites, the quality of new housing provision, tall and large-scale buildings, built heritage and World Heritage Sites, views, the public realm and the Blue Ribbon Network. New development is also required to have regard to its context, and make a positive contribution to local character within its neighbourhood (policy 7.4).

page 6

East and south elevations of the Duchess of Devonshire Building, respectively (Source: applicant’s document, drawing No. 4)

32 Whilst applications in conservation areas should generally be detailed applications it is accepted that in this case Enfield Council are supportive of a masterplan approach for this site.

33 There is no concern regarding the height and massing of the illustrative proposals, however there is concern regarding the illustrative elevation design. Whilst it is acknowledged that the intention is to provide a series of agricultural/barn style buildings the illustrations provided are not convincing and do not reflect the historical context or character of the conservation area.

34 Given that the application is in a conservation area and is nearby listed buildings the Council should ensure that the design is appropriate and of sufficient quality for its historic setting. Access

35 London Plan policy 7.2 'An Inclusive Environment' seeks the highest standards of accessibility and inclusion in new developments. London Plan policy 7.1 also stresses the importance of extending these inclusive design principles to the neighbourhood level by meeting Lifetime Neighbourhoods criteria. This can help to ensure that the public realm, parking areas, routes to the site and links to adjacent public transport and local services and facilities are accessible, safe and convenient for everyone, particularly disabled and older people

36 The design and access statement falls short of incorporating inclusive design. It is essential that the design of the College is fully accessible in order to ensure that disabled people and those with special educational needs can fully participate in College activities. The design and access statement should address the specific access requirements associated with the College. A set of inclusive design principles specific to the detailed design of the College should be proposed and secured as part of the outline permission.

37 Detailed drawings and layouts should be submitted that demonstrate the incorporation of inclusive design. These requirements should be met before the application can be considered compliant with London Plan policies 7.1 and 7.2. Sustainable development

38 London Plan policies 5.2, 5.6 and 5.7 focus on mitigation of climate change and require a reduction in a development’s carbon dioxide emissions through the use of passive design, energy efficiency and renewable energy measures. The London Plan requires developments to make the fullest contribution to tackling climate change by minimising carbon dioxide emissions, adopting sustainable design and construction measures and prioritising decentralised energy, including renewables.

Climate change mitigation

39 The College has been exploring the use of a biomass boiler CHP system and an energy strategy feasibility report accompanies this application. The College is committed to reducing its

page 7 energy consumption by up to 20%. All new buildings would be insulated to levels above the standard Building Regulations guidelines. As much natural lighting and ventilation would be provided as possible, with large glazed opening provided where appropriate. The proposals would incorporate the use of recyclable, natural materials wherever possible, with a preference towards timber and brick. The College is also currently preparing a Green Travel Plan, and this will be submitted to the Council shortly.

40 That said, a full energy strategy should be submitted in line with the GLA energy guidance at the later stage (detailed application) of the proposed development addressing all elements of the London Plan energy hierarchy using benchmark data.

Climate change adaptation

41 London Plan policy 5.3 Sustainable Design and Construction seeks to ensure future developments meet the highest standards of sustainable design and construction. Specific policies relate to overheating (5.9), green roofs (5.11), urban greening (5.10), flood risk (5.12) and sustainable drainage (5.13), water (5.14 and 5.15) and waste (5.17). Further guidance is provided in the London Plan Sustainable Design and Construction SPG. Transport for London’s comments

42 The application raises no strategic transport concerns. Local planning authority’s position

43 Enfield Council officers have yet to confirm their position. Legal considerations

44 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. Financial considerations

45 There are no financial considerations at this stage. Conclusion

46 London Plan policies on educational use, Green Belt, urban design, access, climate change mitigation and adaptation, transport and parking are relevant to this application. The application complies with some of these policies but not with others, for the following reasons:  Green Belt: The proposed scheme for the college that provides courses related to the purpose of agriculture and forestry, which is an appropriate use in the Green Belt, justifies the development in Green Belt. The scheme complies with policy 7.16 of the London Plan.

page 8  Urban design: There is no major concern on the proposed layout but any approval should be subject to the securing of appropriate details of the final design and materials for each of the buildings at a later stage and compliance with design policies of the London Plan. Given that the application is in a conservation area and is nearby listed buildings the Council should ensure that the design is appropriate and of sufficient quality for its historic setting.

 Access: The applicant is required to incorporate inclusive design. This is a major concern that must be addressed.  Climate change mitigation and adaptation: A full energy strategy should be submitted in line with the GLA energy guidance at the later stage (detailed application) of the proposed development addressing all elements of the London Plan energy hierarchy using benchmark data. Green roofs and rainwater harvesting, and the discharge of surface water using SuDS should be considered.  Transport: The application raises no strategic transport concerns.

47 On balance, the application does not comply with the London Plan. 48 The following changes might, however, remedy the above-mentioned deficiencies, and could possibly lead to the application becoming compliant with the London Plan:  Urban design: Secure appropriate details of the final design and materials for each of the buildings at a later stage that the design is appropriate and of sufficient quality for its historic setting and compliance with the design policies of the London Plan.  Access: Incorporate inclusive design.  Climate change mitigation and adaptation: Provide an energy strategy at a later stage, incorporate green roofs, rainwater harvesting and the use of SuDS.

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] Tefera Tibebe, Case Officer 020 7983 4312 email [email protected]

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