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PLANNING COMMITTEE AGENDA 26th NOVEMBER 2015

PART 6: Development Presentations Item 6.2

1 APPLICATION DETAILS

Ref: 15/04702/PRE Location: 1-5 Lansdowne Road & Voyager House, Wellesley Road, , CR9 1LL Ward: Fairfield Description: Redevelopment of the existing site for a predominantly residential and office based scheme with two towers ranging from 11 to 65 storeys, with retail/restaurant use at ground floor level Drawing Nos: Pre application pack to include development proposals, accommodation schedule and preliminary paper on viability of affordable housing Applicant: Guildhouse Rosepride LLP Agent: GHL Hearn Case Officer: Laura Field . 2 BACKGROUND

2.1 This proposed development is being reported to enable members of the Planning Committee to view it before a planning application is submitted and to comment upon it. The development does not constitute an application for planning permission and any comments made upon it are provisional and subject to full consideration of any subsequent application and the comments received as a result of consultation, publicity and notification.

2.2 A scheme for a smaller site and different height was presented to Committee on 8th May 2014 (LBC Ref 14/00699/PRE). This is the first presentation to Planning Committee of this larger scaled development.

3 PROPOSAL AND LOCATION DETAILS

Site and Surroundings

3.1 This is a level site, 0.475 ha in site area, situated at the corner of Wellesley Road and Lansdowne Road. It is approximately 300m from East Croydon Rail Station, 370m from West Croydon Rail Station and 60m to the east of the edge of Croydon Central Shopping Area. The site is occupied by a hostel, a hotel, a fitness centre, café, bar, restaurant and offices. The existing buildings on the site vary in height from 4-11 storeys. The site now also includes Voyager House, which is a six storey building fronting onto Wellesley Road.

3.2 To the west of the site lies Wellesley Road, a dual carriageway road on a north/south alignment which is a major artery through Central Croydon for public transport (buses, trams) but also for private motor vehicles. On the opposite side of Wellesley Road is the shopping core of Croydon, focused around the Whitgift and Shopping Centres. The and associated office blocks have recently been granted planning permission for redevelopment for a new shopping centre with residential blocks above the centre along Wellesley Road. The Council has secured funding from GLA to improve the environment and provide a new at-grade crossing on Wellesley Road (at Poplar Walk/Bedford Park) which is coordinated with illustrative proposals from Croydon Partnership to further upgrade the quality of the road. There are also emerging proposals from TfL to implement a new tram loop on Dingwall Road/Lansdowne Road.

3.3 To the south of the site is the Jury’s Inn Hotel and beyond this are a number of office buildings of varying heights with retail uses fronting onto Wellesley Road at ground floor level. Beyond this is the main education focus within the town centre.

3.4 To the north are various office buildings including the Home Office at Apollo House, which is a 22 storey building and Canterbury House which is an 8 storey office building. To the north of these office blocks is the development site, which is a residential development. This development includes buildings of varying heights, including a 44 storey tower.

3.5 To the east of the site are various office and multi-storey car parking uses.

3.6 East Croydon Rail Station lies to the south east of the site and a pedestrian bridge across the station has recently been constructed, linking the station directly to Lansdowne Road. Adjacent to the station are a number of cleared sites and construction sites being brought forward by Menta/Redrow and Stanhope Schroeder for residential and office purposes. Further to the east the character of the area changes to low rise Victorian housing.

3.7 The site is within the area covered by the Croydon Opportunity Area Framework, is within an area of high density and is located in an area suitable for tall buildings.

Proposal

3.8 The development is notionally divided into two linked east and west elements. The eastern element comprises 53 storeys of residential on a near square plan to sit on a 12 storey rectangular podium of office accommodation above ground floor entrance foyers, retail/restaurant floorspace and servicing zone. The larger tower element would rise to 65 storeys (including ground floor).

3.9 The western element includes a shorter residential tower of 37 floors with a 14 storey podium element above the ground floor entrance foyer and retail/restaurant accommodation in a square plan. Between the two main parts is the service access to back of house areas and the basement car parks.

3.10 The proposal includes public ream works including a plaza at the rear and two pedestrian routes running north to south and east to west.

3.11 The schedule of accommodation, at this stage is proposed as follows:

• The total of 966 units is broken down as follows: 184 studios, 419 one beds, 334 two beds, 12 three beds units and 12 penthouses. • Commercial floor space of 14,307m2 • Retail/restaurant floorspace of 2,726m2

3.12 Design development of the scheme is currently subject to discussion and workshops but the applicant has indicated that their intention is that the architectural expression and detailed finish of the building would be similar to that on the approved 2012 scheme; with main body of the development formed by rectilinear blocks with protruding box-like elements with large areas of glazing and curved bronze feature elements flowing around the building.

Planning History

3.13 The following planning decisions on this site are relevant to the application:

11/02986/P: 1-5 Landsdowne Road; Demolition of existing buildings and erection of a part 12, part 16, part 55 storey building, comprising residential (Use Class C3), office (Use Class B1), café/restaurant (Use Class A3), leisure (Use Class D2) and hotel (Use Class C1), with associated parking, landscaping and access. Planning permission granted subject to a Section 106 Legal Agreement

14/00699/PRE: 1-5 Lansdowne Road: Demolition of existing buildings & erection of a part 12, part 35 and part 57 storey development in 2 blocks (Block A & Block B) over a shared 2 level basement. Block A will rise to a height 57 stories, with block B rising to 35 stories. The proposed development to be used primarily for residential purposes (accomodating 900 residential units in total with a mix of studios, 1, 2, 3 and 4 bed units) with commercial uses at ground floor.

This case was presented to the former Strategic Planning Committee on the 8th May 2014 – and the main issues raised at that stage are outlined below:

• Differences between the consented and new scheme; • Retail at street level - need to justify • Proportion of larger units within the scheme • Permeability through the site and entrances to the building; • Overall increase in the number of residential units • Contribution to the night-time economy • Artistic contribution – lighting of development and street level details • Reason for set-back of taller tower element • Deliverability of the courtyard in the event of no other development contributing – avoiding a “dead end” • Details of external elevations and curves • Amount and location of affordable housing • Lack of hotel which was in the previous scheme • Impact of high density – standards of residential privacy • Uses of ground floor non-residential units – need for services for residents • Potential for common shared space • Distribution of different sized units throughout the development • Access to communal space for all residents • Potential for a car club and on site car parking provision • Public consultation prior to submitting the planning application • Possibility of nursery provision within the development • Active frontages at ground floor level, particularly around public spaces • Timeframe for the delivery of the scheme .

3.14 The following planning decisions on nearby sites are relevant to the application:

Cherry Orchard Road adjacent to

11/00981/P: Demolition of existing buildings; redevelopment to provide a mixed use development of 4 new buildings comprising offices (Class B1a), hotel and serviced apartments (Class C1), 424 flats and 225 habitable rooms of residential accommodation (Class C3), retail (Classes A1-A4) and community facilities (Class D1); Provision of Network Rail service building, public realm, Highway works, formation of vehicular accesses and new car and cycle parking.

Planning permission granted subject to a Section 106 Legal Agreement on the ‘Menta’ site in Cherry Orchard Road, Croydon.

Whitgift Centre

12/02542/P: Mixed use development of the site through the demolition, alteration, refurbishment and retention of existing buildings/structures and erection of new buildings/structures to provide a range of town centre uses including retail and related uses (Use Class A1-A5), leisure (Use Class D2), residential (Use Class C3), community facilities (Use Class D1), office, (Use Class B1), open space and public realm; vehicular bridge links; alteration of existing and creation of new basements, underground servicing and multi storey car parking; alteration to existing and creation of new vehicular and pedestrian access into the site; utility and energy generation facilities; infrastructure and associated facilities together with any required temporary works or structures required by the development.

Planning permission granted subject to a Section 106 Legal Agreement.

Ruskin Square

11/00631/P: The erection of five buildings with a minimum floor area of 53,880 sq metres and maximum of 62,080 sq metres to provide a minimum of 550 and a maximum of 625 residential units; erection of 6 buildings for class B1 use for a minimum of 88,855 sq metres and a maximum of 151, 420 sq metres; provision of a minimum of 7285 sq metres and a maximum of 10,900 sq metres of retail (class A1-A5 floorspace); provision of a maximum of 400 sq metres of community use (class D1); provision of a replacement theatre of 200 seats; provision of energy centre and estate management facilities; formation of vehicular accesses and provision of pedestrian routes public open space and car parking not to exceed 256 parking spaces.

Planning permission granted subject to a Section 106 Legal Agreement. Reserved matters for several phases have been approved and the development has commenced in relation to the first residential and commercial phases.

4 MATERIAL PLANNING CONSIDERATIONS

4.1 The main planning issues raised by the development that the committee should be aware of are:

1. Land use policies 2. Townscape and visual impact 3. Local impact 4. Amenities of future occupiers 5. Transportation, access and parking 6. Environmental impact 7. Water resources and flood risk 8. Archaeology 9. Microclimate 10. Sustainability

Land Use Policies

Retail/Restaurant Uses

4.2 The ground floor of the proposed building is proposed to contain retail/restaurant uses. The site is not within any defined retail frontage.

4.3 Paragraph 24 of the NPPF states that local planning authorities should apply a sequential test to planning applications for main town centre uses such as retail that are not in an existing centre and are not in accordance with an up-to-date Local Plan. Therefore, a sequential test and an impact test will be required for the retail element of this proposal.

Offices

4.4 Plan Policy 2.13 (consolidated with alterations since 2011) identifies Croydon as an Opportunity Area. This is a locality that has an opportunity for accommodating large scale development to provide substantial amounts of new employment and housing (within the region of 10,000 new homes and an employment capacity of 7,500 jobs by 2031).

4.5 London Plan Policy 2.15 identifies Croydon as a Metropolitan Centre and Policy 2.16 identifies Strategic Outer London Development Centres and Croydon as a Strategic Office Location.

4.6 The Croydon Opportunity Area Planning Framework (OAPF), adopted January 2013 as Supplementary Planning Guidance to the London Plan and adopted April 2013 as a Supplementary Planning Document to the Croydon Local Plan: Strategic Policies, provides a framework for the delivery of this development. The OAPF promotes the growth of 95,000 sq metres of office space in the COA over the next 20 years. There is a need for modern office space that meets the needs of modern users. It states that providing high quality, well located, office space will be crucial in attracting new office occupiers.

4.7 Policy 4.1 of the London Plan states that boroughs should promote and enable the continued development of a strong and increasingly diverse economy across all parts of London, ensuring the availability of sufficient and suitable workspaces in terms of type, size and cost, supporting infrastructure and suitable environments for both larger employers and small and medium sized enterprises.

4.8 The proposed provision of 14,307 square metres of office floor space in this accessible location would be acceptable. The provision of office accommodation built to modern standards would aid in the regeneration of the town centre by making the office offer more attractive to potential employers’ thereby increasing employment opportunities.

4.9 The proposed office and restaurant/retail uses are in principle in accordance with the above policy objectives and are a suitable mix of uses for this site. However, its acceptability is subject to a sequential test being undertaken and satisfied (in the case of retail accommodation) the finer details of the development and compliance with other planning policy and townscape requirements as discussed below.

Housing

4.10 Chapter 6 of the NPPF relates to delivering a wide choice of high quality homes. It states that:

‘housing applications should be considered in the context of the presumption in favour of sustainable development’ and that it is the role of local planning authorities ‘to deliver a wide choice of high quality homes, widen opportunities for home ownership and create sustainable, inclusive and mixed communities’.

4.11 Chapter 6 of the NPPF, on delivering a wide choice of high quality homes, requires local planning authorities to set out their own approach to housing density to reflect local circumstances.

4.12 London Plan Policy 2.13 identifies Croydon as an Opportunity Area and states that the Mayor will encourage and support the preparation of area frameworks to realise the growth potential as outlined in the London Plan. London Plan Policy 2.15 defines Croydon as a Metropolitan Centre (and therefore performs a regional function) for the purposes of retail planning alongside the Croydon Opportunity Area (COA) designation. Croydon is recognised in the London Plan as the largest Metropolitan Centre in London.

4.13 London Plan Policy 3.3 relates to increasing housing supply and states that the Mayor recognises 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. London Plan Policy 3.4 seeks to optimise housing potential, taking into account local context and character, the design principles and public transport capacity. Development should optimise housing output for different types of location within the relevant density range. Policy 3.8 of the London Plan requires new developments offer a range of housing choices, in terms of the mix of housing sizes and types. 4.14 The Croydon Local Plan: Strategic Policies SP2.1 applies a presumption in favour of development of new homes, subject to policy requirements. In order to provide a choice of housing for people in Croydon through SP2.2, the Council will seek to deliver a minimum of 13,300 homes between 2011 and 2021 in line with London Plan target for new homes, achieved by a) concentrating development in the places with the most capacity to accommodate new homes whilst respecting the local distinctiveness of the Places of Croydon and protecting the borough’s physical, natural and historic environment; and b) within the Croydon Opportunity Area, the Croydon Local Plan: Detailed Policies and Proposals DPD will be informed by an Opportunity Area Planning Framework and will allocate sites for at least 7,300 net additional homes. It should be acknowledged that since the adoption of the Croydon Local Plan: Strategic Policies (2013) the adopted Further Alterations to the London Plan (2015) have increased the borough’s annual housing target to 1,435 per annum. The proposal would provide much needed housing in the COA which is fully endorsed by the above policies. The Croydon Local Plan: Strategic Policies SP2.5 seeks to ensure that a choice of homes is available in the borough that will address the borough’s need for homes of different sizes.

4.15 An objective of the OAPF is to support the delivery of at least 7,300 new homes within the COA over the next 20 years (2011 – 2031) and supplement the evidence demonstrating the deliverability of 7,300 new homes within the COA as outlined in the Croydon Local Plan: Strategic Policies. This equates to 17,000 new residents in addition to the 8,000 already living there (paragraph 4.40). Across the COA, 20% of new homes need to provide 3 bedrooms. It is accepted that not all schemes will be able to deliver 20% 3 bed homes and therefore, the percentage required varies across the COA. Within the area of the COA within which this site is located, 10% of units will need to have 3 or more bedrooms.

4.16 UDP Saved Policy 2013 H2 states that the Council will permit housing development within the existing built-up area provided this does not conflict with its aim of respecting the character of residential areas and there is no loss of other protected uses.

4.17 The principle of residential use on this site is fully supported by policy at the national, regional and local level and is in accordance with the objectives of the London Plan, Croydon Local Plan: Strategic Policies, Croydon OAPF and UDP.

4.18 The scheme proposes 966 residential units on a site of 0.475 hectares. This results in a density of 2,034 dwellings per hectare. This is in excess of the densities listed in the London Plan. It is not unusual for high rise schemes in London to exceed density standards. However, these have to be determined with regard to all relevant considerations, particularly those relating to urban design, residential amenity, environmental conditions and the impact on transport.

4.19 Out of the 966 residential units proposed, there would be 184 studios, 419 one bed flats, 334 two bed flats, 12 three bed flats and 12 penthouses. In terms of the relevant percentages, 19% of the units would be studio’s, 43% would be one bed flats, 35% would be two bed flats, 1.2% would be three bed flats and 1.2% would be penthouses. The percentage of units that are proposed as 3 bed and above would be well below the 10% OAPF requirement. This issue was raised by Members when the previous iteration of the development was presented to the former Strategic Planning Committee. Affordable Housing

4.20 Paragraph 50 of the NPPF requires local authorities to deliver a wide choice of high quality homes, widen opportunities for home ownership and create sustainable, inclusive and mixed communities

4.21 London Plan Policies (consolidated with alterations since 2011) 3.8 to 3.13 relate to affordable housing. Policy 3.11 of the Further Alterations to the London Plan states that the Mayor will and boroughs and other relevant agencies and partners should, seek to maximise affordable housing provision and ensure an average of at least 17,000 more affordable homes per year in London over the term of this Plan. In order to give impetus to a strong and diverse intermediate housing sector, 60% of the affordable housing provision should be for social and affordable rent and 40% for intermediate rent or sale. Priority should be accorded to provision of affordable family housing. London Plan Policy 3.12 states ‘The maximum reasonable amount of affordable housing should be sought when negotiating on individual private residential and mixed use schemes (having regard to current and future affordable housing requirements, affordable housing targets, the need to encourage rather than restrain, the need to promote mixed and balanced communities, the size and type of affordable housing needed and the specific circumstances of individual sites).

4.22 London Plan policies 3.12 and 3.13 indicate that the maximum reasonable amount of affordable housing should be sought on schemes, taking into account viability and other issues.

4.23 The Croydon Local Plan: Strategic Policies seeks up to 50% affordable housing provision on sites such as this (SP2.4). Table 4.1 provides flexibility within the COA, requiring a minimum level of affordable housing on all sites, currently set at 15% (this minimum requirement will be reviewed in April 2016 and applied to applications determined after this April 2016 review). In the COA, a minimum of 10% affordable housing will need to be provided on-site with the remainder being provided (in order of preference) on-site, off-site, via a commuted sum and/or through a review mechanism.

4.24 Paragraph 4.42 of the OAPF seeks to secure as a minimum 15% affordable housing. It requires applicants to have a combined engagement with Registered Providers and local planning authorities, to demonstrate that off-site donor sites will contribute to a mixed and balanced community as well as delivering their own affordable housing requirements, to ensure that affordability is adequately considered where sub-market rental schemes are proposed and to demonstrate that rental levels are not out of reach for prospective tenants in the area. Whilst this may be sustainable for smaller homes, rents on larger homes will need to be carefully assessed because of benefit caps.

4.25 The applicants have proposed 15% affordable housing. This breaks down to 5% shared ownership on site and 10% off-site (5% shared ownership and 5% rented accommodation). It is stated that if it is the Council’s preference or if insufficient donor land can be identified and comes forward; a commuted sum will be paid.

4.26 The above offer is not compliant with adopted policy; at least 10% affordable should be on site and split 60:40 respectively between affordable rent and intermediate although a further 5% may be provided off site or in the form of a commuted sum depending upon circumstances. The applicant has advised that even with this non- complaint affordable housing offer, the scheme would not be viable. In any case, the policy is to seek to maximise affordable housing delivery (up to 50%) and irrespective of the 15% minimum, there might well be a scenario whereby affordable housing proportions could well exceed the 15% minimum – with an eventual scheme possibly being more viable and deliverable.

4.27 The affordable offer adopts a similar approach to that adopted by the 2012 planning permission (11/02986/P) and the attached S.106 legal agreement. It is important to note that the previous planning application was determined in different circumstances compared to today, particularly the complexion of the development plan. At the time of previous determination, the Croydon Local Plan was at pre submission stage whereas now, the Strategic Policies are formally adopted, following on from formal examination. When considered by the former Strategic Planning Committee, the minimum requirement for affordable housing within the emerging policy (rather than the current adopted Croydon Local Plan: Strategic Policies) was 20%. This was reduced to 15% prior to submission to the Secretary of State prior to formal examination. Furthermore, the economic situation at the time meant that developers were finding it difficult to provide affordable accommodation. This was all noted in the report to the former Strategic Planning Committee back in 2012.

4.28 Whilst the financial assessment of the 2012 proposals indicated that the development (at the time of determination) was not viable, the applicants still offered 15% affordable with 5% Intermediate on site and 5% Affordable Rent and 5% Shared Ownership off site. This was not policy compliant; hence the use of a review mechanism. It was also noted that viability would have to improve significantly before the scheme could realise sufficient value to facilitate delivery.

4.29 When a previous iteration of the current proposal for 900 units on a smaller site excluding the Voyager House land was presented to the Strategic Planning Committee in May 2014, the amount and location of the affordable housing was identified as an issue .

4.30 The non-compliant nature of the development has been raised with the applicants. Officers have requested that alternative configurations of development be tested to determine whether there are alternative development scenarios that could facilitate a viable proposal whilst at the same time a policy complaint affordable housing offer. A preliminary outline analysis (that has not been independently assessed) has been carried out whereby the height of development is restricted to 20 storeys, thereby reducing the costs of construction, thereby enhancing the cost/end value ratio. The applicant has argued that this alternative would allow for a 23% affordable provision (with a 60:40 split) – although with a lower (equivalent number of affordable housing being delivered overall) compared to their current proposals. The applicant also places some caution over this alternative approach as they believe that this high level analysis will prove to be optimistic when a detailed design and analysis is further explored. Notwithstanding this, the crucial issue for officers is that delivery of affordable housing (irrespective of the number proposed) need to be policy complaint (in terms of the mix between affordable rent and shared ownership and current policy requirement for a minimum 10% on site delivery of affordable housing). Furthermore, there may well be other potential development scenarios to be explored which might be able to maximise absolute housing numbers whilst at the same time increase the affordable housing percentage beyond the stated minimum policy requirement. Whatever the situation, the eventual viability assessment will need to be submitted and independently appraised to ensure that a proposal is properly embracing the Council’s adopted affordable housing policy.

4.31 A development of nearly 1,000 units would be a notable contribution to the delivery of new housing in the COA. However, such a large scheme needs to be tested against current planning policies and material considerations. It is worth noting for example that financial contributions towards local infrastructure (public realm, education, health, transport) were secured under the 2012 planning permission – linked to the associated S.106 Agreement. These infrastructure requirements are now secured separately under the CIL Regulations and Members will be aware that the current Croydon CIL charging schedule does not cover residential floorspace within the Croydon Opportunity Area (although the whole scheme would be liable for London Mayoral CIL).

4.32 To summarise, whilst the previous planning permission represents a material consideration when dealing with the planning merits of the current pre application proposal, it does not alone justify a substantially different proposed redevelopment of this important site in the Croydon Opportunity Area, especially in view of the degree of policy non-compliance around affordable housing delivery. Each planning permission application has to be determined on its own merits.

Townscape and Visual Impact

4.33 Through the NPPF, significant importance is attached to the design of the built environment. Paragraph 61 highlights the importance of the visual appearance and the architecture of individual buildings, but also addresses the importance of connections between people and places and the integration of new development into the natural, built and historic environment. Paragraph 63 places significant weight on outstanding or innovative designs which help raise the standard of design more generally in the area.

4.34 London Plan Policies 7.1 to 7.7 set out a series of design principles for development in London. These seek to maximise the potential of sites and improve the quality of development. London Plan Policy 7.2 requires all new development in London to achieve the highest standards of accessible and inclusive design. London Plan Policy 7.3 seeks to create safe, secure and appropriately accessible environments that reduce the opportunities for criminal behaviour and contribute to a sense of security without being overbearing or intimidating. London Plan Policy 7.4 requires buildings, streets and open spaces to provide a high quality design response that: a) has regard to the pattern and grain of the existing spaces and streets in orientation, scale, proportion and mass; b) contributes to a positive relationship between the urban structure and natural landscape features, including the underlying landform and topography of an area; c) is human in scale, ensuring buildings create a positive relationship with street level activity and people feel comfortable with their surroundings; d) allows existing buildings and structures that make a positive contribution to the character of a place to influence the future character of the area; and e) is informed by the surrounding historic environment. London Plan Policy 7.6 demands the highest architectural quality, to enhance the public realm, use appropriate materials, not harm surrounding amenity, provide high quality indoor and outdoor spaces, be adaptable, inclusive and optimise potential. London Plan Policy 7.7 states that tall and large buildings should: a) be located in town centres that have good access to public transport; b) only be considered in areas whose character would not be affected adversely by the scale, mass or bulk of a tall or large building; c) relate well to the form, proportion, composition, scale and character of surrounding buildings, urban grain and public realm; d) improve the legibility of an area; e) incorporate the highest standards of architecture and materials, including sustainable design and construction practices; f) have ground floor activities that provide a positive relationship to the surrounding streets; g) contribute to improving permeability; h) incorporate publicly accessible areas on the upper floors where appropriate; and i) make a significant contribution to local regeneration.

4.35 Croydon Local Plan: Strategic Policies require development of high quality, which respects and enhances Croydon’s varied local character and contributes positively to public realm, landscape and townscape to create sustainable communities (SP4.1). SP4.2 requires development to be informed by the distinctive qualities, identity, topography, protect Local Designated Views, the setting of Landmarks, other important vistas and skylines and enhance social cohesion and well-being. SP4.4 and SP4.5 relate to the Croydon Opportunity Area, supporting high quality, high density developments that are tailored to and help to protect or establish local identity (SP4.4) and encouraging proposals for tall buildings only in the Croydon Opportunity Area (SP4.5). SP4.6 requires tall buildings to respect and enhance local character and heritage assets, minimise the environmental impacts and respond sensitively to topography, make a positive contribution to the skyline and image of Croydon and include high quality public realm. SP4.12 requires development to respect heritage assets.

4.36 The OAPF identifies three building height areas. This site is located in the Central Area, which is considered the most appropriate location for future tall buildings. It identifies this area as housing the largest number of existing tall and large buildings and the least amount of sensitive heritage assets, amenity spaces and there is very little residential in or near the area. It also has the best access to public transport and the most capacity to accommodate future development.

4.37 The OAPF also identifies that tall buildings must achieve the highest quality design and architecture. The lower levels of such buildings should relate well to their surroundings and should provide better definition of the public realm. Tall buildings should be defined as slender and elegant towers with a slenderness ratio of 1:3.

4.38 UDP Saved Policies 2013 UD1-15 relate to urban design, requiring a high standard of design for all development and require it to respect the existing development pattern. Policy UD1 requires development to be high quality, inclusive and sustainable in design, Policy UD2 requires development to respect the existing development pattern and address street frontages. Policy UD3 refers to the scale and design of new buildings, in relation to height and proportions, character, density, architectural features and the use of materials. Policy UD6 demands issues of safety and security to be an intrinsic consideration, Policy UD7 expects proposals to be designed with ease of access for all users as a prime consideration and Policy UD8 seeks to protect residential amenity. Policy UD11 relates to views and landmarks, particularly for high buildings. Policies UD12 and 13 demand that new street and parking must not be allowed to dominate or determine urban form. The Council will have regard to (i) creating a new, appropriate and desirable landmark feature amongst views in the town centre; and (ii) adversely impacting upon, for instance by obscuring or detracting from, designated panoramas, local views and landmarks.

4.39 Guidance on Tall Buildings 2007 an advice document produced jointly by CABE and English Heritage identifies criteria required for evaluating tall building proposals. 4.40 The development proposes two buildings on the site (that would be linked by architectural features). These buildings would cover the majority of the site area with the exception of a new public square.

4.41 The tallest part of the development would be 65 storeys with the lower tower being 37 storeys. The extant permission is for a 55 storey building on a smaller site. This site now includes Voyager House. This is positive and provides a more developable plot which should facilitate a better ground floor and better form of development. Whilst the public square and routes are supported in principle, further work is required, including further testing and detail to ensure that the proposed routes and spaces are active, safe and in the optimal position in term of the wider public realm network.

4.42 Whilst the applicant has provided preliminary work on views and impact, there are fundamental items of the design process that need to be undertaken before officers can provide a full assessment and commentary. As outlined above, officers have asked the applicant to present a design process demonstrating how different design options have been tested in response to policy and contextual requirements and how the current proposals have evolved. There should a baseline assessment of local context and character including a baseline heritage assessment. There is concern that limited work has been undertaken to test alternative forms of development for the site, including forms that would be potentially capable of achieving a higher proportions of affordable housing in line with current policy. Further work is required to explore how the scheme might further co-ordinate with the adjacent sites.

4.43 A full assessment of the visual impact of the proposal will be required as part of any future planning application. This is essential to make sure that the visual impact of the proposed development is analysed from various locations to make sure that it would be acceptable. It will need to be demonstrated that there are no prominent locations where the east and west towers can be viewed where they blend together and create the impression of a ‘slab block’. It will also need to be demonstrated that the higher west tower, in combination with the taller east tower, does not have a detrimental impact on short range views within the Metropolitan Centre, particularly in relation to heritage assets such at St Michael and All Angels Church and the Alms Houses, both of which are Grade I listed. The applicant will need to further work with officers to identify the potential impact of the proposed development on the setting of heritage assets, with reference to the baseline heritage assessment which needs to be undertaken. The evolving design will need to be tested using 3D computer models and views and a series of verified views will be required to be submitted with any future planning application. The resultant design will need to result in a building of exceptional quality. Early indications based on the material provided thus far are that the scheme as proposed would have a more marked impact on views from the north- west and south west, where the two towers would be more likely to visibly coalesce in views. These views are also those that would potentially impact on the setting of St Michael and All Angels and the Alms Houses. Given the scale of the scheme, it is recommended that the scheme should be part of an independent design review.

Local Impact

4.44 One of the core planning principles (paragraph 17) in the NPPF is that decisions should ‘always seek to secure high quality design and a good standard of amenity for all existing and future occupants of land and buildings’. 4.45 London Plan Policy 7.1 states that in their neighbourhoods, people should have a good quality environment. London Plan policy 7.7 requires tall buildings not to adversely affect their surroundings and attention should be paid to the effects on overlooking and privacy. Attention should also be paid to the effects of overshadowing.

4.46 Croydon Local Plan: Strategic Policies SP4.1 and SP4.2 seeks to respect and enhance character to create sustainable communities and enhance social cohesion and well-being.

4.47 Croydon Plan 2006 (Saved Policies 2013) UD8 states that regard should be had to protecting residential amenities. Policies UD2 and UD8 require adequate sunlight and daylight to penetrate into and between buildings.

4.48 All adjacent buildings to the site are of a commercial nature although Canterbury House (located towards the rear of the site) is currently being converted from offices to residential – pursuant to a previous prior approval which will need to be considered as part of the emerging proposals. Notwithstanding this particular conversion scheme, the nearest residential properties are approximately 200 metres away which is a significant distance. There are no planning policies to protect the privacy of users of commercial buildings.

4.49 Given the height of the proposed buildings, it would be visible from nearby properties and from further away. However, given that the nearest properties to the site are commercial in nature and residential properties are further away, it is unlikely that harm will result from visual intrusion.

4.50 Any future planning application will require a daylight and sunlight assessment to demonstrate if there are any impacts in relation to available light to buildings in the locality. There will also need to be extensive environmental testing (especially an assessment of existing and proposed wind conditions – including the interplay between the two proposed towers and the overall increases in height). The impact of passing shadows across a wider area from the building will also need to be considered.

Amenities of Future Occupiers

4.51 Policy 3.5 of the London Plan states that housing developments should be of the highest quality internally, externally and in relation to their context and to the wider environment, taking account of strategic policies in the Plan to protect and enhance London’s residential environment and attractiveness as a place to live. Homes should meet dwelling space standards and be conceived and developed through an effective design process. Development proposals which compromise the delivery of elements of this policy should be resisted unless they are otherwise of exemplary design and make significant contributions towards achievement of other objectives of this Plan. Policy 3.6 requires that children and young people have safe access to good quality, well-designed, secure and stimulating play and informal recreation provision, incorporating trees and greenery wherever possible. Policy 3.8 states Londoners should have a genuine choice of homes that they can afford and which meet their requirements for different sizes and types of dwellings in the highest quality environments. All new housing should be built to ‘Lifetime Homes’ standards and 10% of new housing should be wheelchair accessible, or easily adaptable for residents who are wheelchair users 4.52 Policy 7.2 states that the Mayor will require all new development in London to achieve the highest standards of accessible and inclusive design. Policy 7.15 set outs the Mayor’s expectations with regard to reducing noise and enhancing soundscapes.

4.53 Policy SP2.6 of the CLPSP seeks to ensure that new homes in Croydon meet the needs of residents over a lifetime and contribute to sustainable communities with the borough.

4.54 Policy 3.5 of the London Plan is supported by the Mayor’s Housing Supplementary Planning Guidance (adopted November 2012) together with the National Housing Standards. These provide more detailed guidance regarding the quality required from new residential development.

4.55 The scheme as currently proposed would provide 966 flats of varying sizes, all of which would be in compliance with the floorspace requirements of the Housing SPG.

4.56 The applicant has stated that nearly all of the units would have their private internal or external amenity spaces; in the form of balconies or winter gardens. Where the pattern of the elevations does not provide a balcony or winter garden then these flats would be oversized to include this amenity area within the flats themselves. In addition the proposal includes a public square. The amount of private amenity space proposed appears to be in line with the requirements set out in the Housing SPG, but the applicant will need to demonstrate this in relation to the occupancy levels that are capable of being achieved on site in any future planning application. Any future planning application will also need to include child yield calculations to ensure that an appropriate level of play space is provided. The communal amenity spaces are proposed as a combination of internal and external space. These areas will need to be appropriately fitted out and landscaped to ensure that they are suitable usable spaces.

Transportation, Access and Parking

4.57 Chapter 4 of the NPPF seeks to promote sustainable transport. London Plan Policy 6.1 covers the strategic approach to transport across London, encouraging patterns and nodes of development that reduce the need to travel, especially by car, seeking to improve the capacity and accessibility of public transport, walking and cycling, supporting development that generates high levels of trips at locations with high public transport accessibility, improving interchange between different forms of transport, facilitating the efficient distribution of freight, supporting measures that encourage shifts to more sustainable modes, promoting greater use of low carbon technology, promoting walking and seeking to ensure that all parts of the public transport network can be used safely, easily and with dignity by all Londoners. Policy 6.2 requires adequate provision and safeguarding of land with transport functions such as bus and rail infrastructure and coach parking should also be protected.

4.58 London Plan Policy 6.3 requires development proposals to fully assess their impacts on transport capacity and the transport network, at both a corridor and local level and requires that they should not adversely affect safety on the transport network. The cumulative impacts of development on transport requirements must be taken into account. Where existing transport capacity is insufficient to allow for the travel generated by the proposed developments and no firm plans exist for an increase in capacity, local planning authorities should ensure that development proposals are phased until it is known these requirements can be met. Policy 6.9 demands secure, integrated and accessible cycle parking facilities in line with the minimum standards and Policy 6.10 seeks high quality pedestrian environments. Policy 6.11 requires DPDs and Local Implementation Plans to take a co-ordinated approach to smoothing traffic flow and tackling congestion and DPDs to develop an integrated package of land use and transport measures to foster the use of the more sustainable transport modes. When assessing proposals for increasing road capacity, Policy 6.12 supports the need for limited improvements to London’s road network to address clearly identified significant strategic or local needs. When considering such improvements it also requires consideration of the contribution to London’s sustainable development and regeneration including improved connectivity, the extent of any additional traffic and any effects it may have on the locality, and the extent to which congestion is reduced, how London’s environment can benefit, how conditions for pedestrians, cyclists, public transport users, freight and local residents can be improved and how safety for all is improved. London Plan Policy 6.13 states that the Mayor wishes to see an appropriate balance being struck between promoting new development and preventing excessive car parking provision that can undermine cycling, walking and public transport use. Maximum parking standards should be applied to planning applications. Policy 6.14 requires development proposals that generate high numbers of freight movements to be located close to major transport routes.

4.59 Policy SP8.4 of The Croydon Local Plan: Strategic Policies requires major development proposals to be supported by transport assessments, travel plans, construction logistics plans and delivery/servicing plans. SP8.6 focuses on improving conditions for walking and enhancing the pedestrian experience, SP8.7 seeks to provide new and improved cycle infrastructure, SP8.8 prioritises tram infrastructure provision and network improvements, SP8.9 encourages rail infrastructure provision and network improvements and SP8.10 encourages bus infrastructure provision and network improvements. SP8.12 requires the delivery of electric vehicle charging infrastructure throughout the borough, as well as car clubs and car sharing schemes (SP8.13). SP8.14 seeks to ensure enough space is provided in the Croydon Opportunity Area for taxi ranks/waiting and coach parking. In terms of car parking, SP8.15 encourages car free development in the CMC, SP8.16 seeks to limit parking spaces in the borough and aims to reduce the overall amount of surplus car parking spaces in the Croydon Opportunity Area, SP8.18 seeks to improve the efficiency with which people and goods are moved and SP8.19 promotes efficient and sustainable arrangements for the transportation and delivery of freight.

4.60 Chapter 7 of the OAPF states that efforts need to be made to mitigate the impact of growth on the transport network. This includes reducing the need to travel by co- locating homes and jobs, improving the walking and cycling environment, and improving access to, and the capacity of, public transport. This will be achieved through a mixture of hard infrastructure improvements, sustainable transport measures and softer behavioural initiatives. In planning for Croydon’s predicted level of growth, the Council's and the Mayor's planning policies have focused a large proportion of the borough’s housing and economic growth within the COA. The principle of consolidating growth within the COA should help reduce the need to travel and the length of journeys. By placing homes side-by-side with new and existing workplaces, shops and other services, the OAPF aims to create a walk-able and cycle-able town centre. This report sets out further detail of the OAPF under each of the transport sub-headings below. 4.61 UDP Saved Policy 2013 UD12 demands the safety of all users to be maintained and the layout to be based on a series of spaces, rather than a network of roads and UD13 requires car and cycle parking to be designed as an integral part of the scheme and to minimise their visual impact. Policy T2 states planning permission will only be granted where the traffic generated can be satisfactorily accommodated on nearby roads. Policy T4 seeks the provision of cycling and cycle parking facilities. Policy T8 states that development will not be permitted unless it provides car parking in accordance with the adopted standards. These are maximum car parking standards and provision lower than the maximum will be encouraged in areas of good public transport accessibility.

4.62 The site is located in an area with a PTAL of 6b on scale from 1a to 6b where 6b is the most accessible to public transport. The site is located in the centre of the Metropolitan Centre between the northern entrance to East Croydon Station and the retail core.

4.63 The site is located within a Controlled Parking Zone. As an additional measure, to prevent unreasonable demand for residents parking permits a clause will be required within a Section 106 Legal Agreement (as part of any future planning application) to advise future residents that they will be ineligible to apply for residents parking permits.

4.64 Any future planning application will need to be accompanied by a Transport Assessment to fully assess the impact of the development on traffic flows in the vicinity of the site, parking and public transport. The full scope of the Transport Assessment should be agreed with the local planning authority prior to the submission of a planning application. A Travel Plan, Construction Logistics Plan and Delivery Servicing Plan will also need to be submitted.

4.65 Annex 2 of the Housing SPG sets out Best Practice Guidance for Wheelchair Accessible Housing and states that “The WHDG recommends that one parking bay is provided for every designated wheelchair accessible home. Policy 3.8 of the London Plan (as amended by the Revised Early Alterations to the London Plan October 2013) requires 10% of new housing be designed to be wheelchair accessible or easily adaptable for residents who are wheelchair users. As the site has a PTAL rating of 6b and is in a highly accessible location in the Metropolitan Centre, a zero level of general parking would be acceptable, subject to an appropriate level of disabled parking being provided.

4.66 A provision of 1025 secure and covered cycle spaces has been made on site within the basement. The applicant has stated that a limited number of parking bays will be provided on site which 40% will be accessible bays. If any bays are designated for use by the officers at least 10% will be designated accessible bays. Further detail will need to be submitted by the applicant on car parking layout and this should include Electric Vehicle Charging Points in accordance with London Plan Policy 6.13. As the site has a PTAL rating of 6b and is in a highly accessible location in the Metropolitan Centre, a zero level of general parking would be acceptable, subject to an appropriate level of disabled parking being provided.

4.67 It should be note TfL are in the process of assessing amendments to the tram route so that it will pass along Lansdowne Road and Dingwall Road.

Environmental Impact Contamination

4.68 Chapter 13 of the NPPF relates to facilitating the sustainable use of minerals and seeks to (in part) ensure that permitted operations do not have unacceptable adverse impact on migration of contamination from the site.

4.69 London Plan Policy 5.21 supports the remediation of contaminated sites and that the development of brownfield sites does not result in significant harm to human health or the environment and to bring contaminated land to beneficial use.

4.70 Croydon Local Plan: Strategic Policies 6.3 requires development to positively contribute to improving air, land, noise and water quality by minimising pollution.

4.71 UDP Saved Policies 2013 EP2 and EP3 seek to ensure that the land is suitable for the proposed use and require that an investigation into the extent of any possible contamination with any remedial measures is provided before any application can be determined. Policy EP3 allows for remediation to be secured via an appropriate planning condition or planning obligation if appropriate.

4.72 The Local Planning Authority will need to be satisfied that there is no contamination on the land that would have an adverse impact on future residents or if contamination exists, that it is appropriately remediated. The site has been used for residential, hostel, hotel and office uses. There are potential sources of contamination connected with existing uses on site such as those associated with heating systems and the swimming pool.

4.73 Any future planning application will need to demonstrate that a future residential use of the land is appropriate in terms of land contamination, through an appropriate ground condition survey.

Air Pollution, Noise and Vibration

4.74 Chapter 11 of the NPPF requires planning policies and decisions to: avoid noise from giving rise to significant adverse impacts on health and quality of life as a result of new development; mitigate and reduce to a minimum other adverse impacts on health and quality of life arising from noise from new development; and to recognise that development will often create some noise. Chapter 13 states that when determining planning applications, local planning authorities should ensure that any unavoidable noise, dust and particle emissions and any blasting vibrations are controlled, mitigated or removed at source.

4.75 Policy 7.14 of the London Plan states that the Mayor will work with strategic partners to ensure that the spatial, climate change, transport and design policies of his plan support the implementation of his Air Quality Strategy to achieve reductions in pollutant emissions and public exposure to pollution. It also states that development should be ‘air quality neutral’ and not lead to further deterioration of existing poor air quality (such as areas designated as Air Quality Management Areas). The whole of Croydon Borough has been designated as an Air Quality Management Area – AQMA

4.76 London Plan Policy 7.15 seeks to minimise the existing and potential adverse impacts of noise on, from, within, or in the vicinity of, development proposals, separate new noise sensitive development from major noise sources and promote new technologies and improved practices to reduce noise at source. 4.77 Croydon Local Plan: Strategic Policies 6.3 requires development to positively contribute to improving air, land, noise and water quality by minimising pollution.

4.78 EP1 of the UDP Saved Policies 2013 refers to the pollution of water, air or soil or pollution through noise, dust, vibration, light heat or radiation.

4.80 The proposed development will need to ensure that it does not cause adverse impacts in terms of air pollution noise and vibration. During demolition and construction, the main effects on air quality would be from construction traffic, emissions from construction equipment and dust. During construction, these effects would be temporary. However, the effects can be dealt with by the imposition of conditions for a Construction Management Plan, Construction Logistics Plan, ensuring there is no burning on site and recommending that the developer observes the Council’s Code of Practice ‘Control of Pollution and Noise from Demolition and Construction Sites’ as well as the Mayor of London’s Best Practice Guidance ‘The control of dust and emissions from construction and demolition’

4.81 The effects on air quality associated with the completed development would result from traffic changes associated with the development, proposed car parks and mechanical plant (associated with cooling, heating and hot water).

4.82 Road traffic noise along Wellesley Road is likely to be the dominant source of noise at the site. Therefore, suitable sound insulation should be provided to ensure adequate protection from noise and this could be secured via a planning condition attached to any future planning application. Windows should also be fitted with mechanical ventilation and this can also be secured via condition at application stage.

Water resources and flood risk

4.83 London Plan policy 5.12 states that the Mayor will work with all relevant agencies including the Environment Agency to address current and future flood issues and minimise risks in a sustainable and cost effective way. London Plan Policy 5.13 states that developments should use Sustainable Urban Drainage Systems unless there are practical reasons for not doing so.

4.84 The application site is in Flood Zone 1 which means that there is a low risk of flooding (once in 1000 years or less). There is no history of past flood events. It is not anticipated that climate change will produce any significant increase in risk. The existing site is almost completely covered by impermeable surfaces (buildings and tarmac surfacing).

Archaeology

4.85 London Plan policy 7.8 and policy UC11 of the Croydon Plan seek to ensure that the archaeological heritage of the site is properly recorded and if they are found, archaeological remains are retained in situ, where possible. Development should also incorporate measures that identify, record, interpret, protect and where appropriate, present the site’s archaeology.

4.86 The site is not within an Archaeological Priority Zone (APZ). The nearest APZ is located 125 metres to the north east of the application site. Any future planning application should be accompanied by an archaeological assessment given that excavations for basements are proposed on the site. The archaeological assessment for the extant development on the site concluded that the site would have a low potential to contain remains dated to Prehistoric, Roman and early/late Medieval periods and that there would be moderate potential to contain remains dated to the Post-Medieval period in the form of the remnants of footings of four mid-19th Century villas. As the existing buildings on the site have basements, this would have truncated archaeological remains. However, the assessment is required to ensure that all matters are considered fully.

Microclimate

4.87 London Plan Policy 7.6 requires buildings not to cause unacceptable harm to the amenity of surrounding land and buildings, particularly residential buildings, in relation to privacy, overshadowing, wind and microclimate. This is particularly important for tall buildings - which is covered further on Policy 7.7. This states they should not affect their surroundings adversely in terms of microclimate, wind turbulence, overshadowing, noise, reflected glare, aviation, navigation and telecommunication interference.

4.88 The Croydon Local Plan: Strategic Policies SP4.6 requires applications for tall buildings will be required to, in part, minimise the environmental impacts and respond sensitively to topography.

4.89 Any future planning application will be required to submit with it a full technical wind microclimate report to include wind tunnel testing to assess the mean and gust wind conditions around the existing site and the proposed development in terms of pedestrian comfort. Particular attention should be paid to building entrances and amenity areas. If any area of concern is identified, appropriate mitigation should be introduced and tested to ensure compliance with requirements.

Sustainability

4.90 At the heart of the National Planning Policy Framework is a golden thread presumption in favour of sustainable development. It states: ‘Planning plays a key role in helping shape places to secure radical reductions in greenhouse gas emissions, minimising vulnerability and providing resilience to the impacts of climate change, and supporting the delivery of renewable and low carbon energy and associated infrastructure’.

4.91 Policies 5.1-5.15 of the London Plan relate to sustainability, seeking to achieve an overall reduction in London’s carbon dioxide emissions of 60 per cent (below 1990 levels) by 2025. Since 2013, Policy 5.2 of the London Plan has required residential buildings to minimise carbon dioxide (CO2) levels by 40%. By 2016, residential buildings should be zero carbon. Proposals should seek to reduce carbon dioxide emissions through the energy efficient design of the site, buildings and services. Energy assessments should reduce carbon dioxide emissions through the use of decentralised energy where feasible, such as district heating and cooling and combined heat and power. The highest standards of sustainable design and construction should be achieved in London to improve the environmental performance of new development. Policy 5.9 requires major development proposals to reduce potential overheating and reliance on air conditioning systems and to demonstrate how the design, materials, construction and operation of the development would minimise overheating and also meet its cooling needs. Policy 5.11 states that major development proposals should be designed to include roof, wall and site planting, especially green roofs and walls where feasible.

4.92 In sustainability and energy terms, the Croydon Local Plan: Strategic Policies applies a presumption in favour of development provided applications meet the requirements of Policy SP6 and other applicable policies of the development plan (SP6.1). SP6.2 seeks to ensure development makes the fullest contribution to minimising carbon dioxide emissions in accordance with the London Plan energy hierarchy, which includes promoting the development of district energy networks. SP6.3 seeks high standards of sustainable design and construction from new development.

4.93 The sustainability aspects of the development have not been discussed in detail. Policy requires reduction in carbon dioxide emission by at least 35% based on 2013 Building Regulations and also requires non-residential parts of a scheme to be constructed to BREEAM “Excellent” standards. A detailed energy strategy will be required to be submitted with any future planning application and then would be secured through conditions including mains water consumption.

4.94 To future proof the development provision would need to be made for connections and space within the buildings to allow connection to any future Croydon District Heating Network, should such a network come forward. This provision would be secured through an appropriate clause in the S.106 Agreement and by conditions to secure all relevant pipe work from the buildings to the edge of the site (to allow easy connection).

Other Planning Issues

Designing Out Crime

4.95 Paragraph 164 of the NPPF requires Local Planning Authorities to take into account the most up-to-date information about defence and security needs in their area and work with local advisors and others to ensure that they have and take into account the most up-to-date information.

4.96 Policy 7.3 of the London Plan states that boroughs and others should seek to create safe, secure and appropriately accessible environments where crime and disorder and fear of crime do not undermine quality of life or community cohesion. In particular they should reduce the opportunities for criminal behaviour and contribute to a sense of security without being overbearing or intimidating.

4.97 Policy 7.13 of the London Plan states that development proposals should contribute to the minimisation of potential physical risks. Development should include measures that, in proportion to the risk, deter terrorism, assist in the detection of terrorist activity and help defer its effects.

4.98 Croydon Plan policy UD6 state that the Council require that issues of safety and security are intrinsic considerations in the detailed design and layout of buildings and spaces around them, helping to deter crime and reduce the fear of crime

4.99 For a building of this nature, the main considerations would relate to counter terrorism, access to the building and the areas of public realm around the building. 4.100The developer is encouraged to consider Secured by Design principles and conditions requiring CCTV, delivery and servicing plan, public realm management plan and a car park management plan are likely to be imposed on any future planning application to ensure that the proposed development would provide a safe and secure environment.

Telecommunications

4.101The NPPF in paragraph 44 requires local planning authorities to ensure they have considered the possibility of the construction of new buildings interfering with broadcast and telecommunication interference.

4.102London Plan policy 7.7 in relation to tall buildings states that they should not adversely affect telecommunications. There are no policies in the Croydon Plan that refer to telecommunication interference from tall buildings.

4.103Tall buildings have the potential to affect the reception of TV and radio signals. Given the height of the building proposed, there is potential for existing TV and radio signals to be affected. Any future planning application will need to demonstrate that either there is no adverse impact or any effects are appropriately mitigated.

4.104Any future planning application will also require a S.106 Agreement that will require additional surveys and mitigation measures to be put in place if there is a detrimental impact on television reception. Potentially affected occupiers would need to be notified of the development’s commencement and advised of the means of seeking mitigation.