16/06400/FUL Homefield House, 57 Homefield Road, Coulsdon, CR5 1ET

Site Location Plan PLANNING COMMITTEE AGENDA 11th May 2017

PART 7: Planning Applications for Decision Item 7.3

1 SUMMARY OF APPLICATION DETAILS

Ref: 16/06400/FUL (Link to associated documents on the Planning Register) Location: Homefield House, 57 Homefield Road, Coulsdon, CR5 1ET Ward: Coulsdon East Description: Demolition of former care home. Erection of 1x3 storey building comprising 5x1 bedroom and 5x2 bedroom flats. Erection of 6x2 bedroom and 8x3 bedroom houses. Formation of vehicular access and provision of associated car parking, landscaping and other associated works. Drawing Nos: 1602/38/PL007 B, 1602/38/PL009 C, 1602/38/PL010 A, 1602/38/PL013, 1602/38/PL014, 1602/38/PL001 C, 1602/38/PL002 H, 1602/38/PL003 E, 1602/38/PL004 E, 1602/38/PL005 C, 1602/38/PL006 C, 1602/38/PL008 C, 1602/38/PL011 B, 1602/38/PL012 A, 1602/38/PL015 A, 1602/38/PL016 E, 1602/38/PL017, 1602/38/SUR01 E Applicant: Brick by Brick (Croydon) Ltd Agent: Carter Jonas Ltd Case Officer: Samantha Dixon

1 bed 2 bed 3 bed Total Houses 6 8 Flats 5 5 Totals 5 11 8 24

Number of car parking spaces Number of cycle parking spaces 19 44

1.1 This application is being reported to Planning Committee because Councillor Bird made representations in accordance with the Committee Consideration Criteria and requested Planning Committee consideration and objections above the threshold in the Committee Consideration Criteria have been received

2 RECOMMENDATION

2.1 That the Planning Committee resolve to GRANT planning permission subject to:

A: Resolutions to grant planning permission by Planning Committee in respect of applications LBC Refs 16/06422/FUL (Tollgate A&B) 16/06337/FUL (Thornloe Gardens) 16/06374/FUL (Ravensdale A&B)

B: The grant of planning permission (to be determined under delegated powers) in respect of the following applications:

Application Number Site 16/06276/FUL Drovers Road 16/06366/FUL Academy Gardens 16/06273/FUL Coldharbour 16/06438/FUL Marston Way 16/06372/FUL Tollgate (C) 16/06343/FUL Cheriton House 16/06275/FUL Eagle Hill 16/06375/FUL Ravensdale (site C) 16/06432/FUL Warbank Crescent

Should either A or B above not be determined in accordance with the above outcomes, the planning application the subject of this report would be required to be referred back to Planning Committee for reconsideration (specifically around affordable housing delivery – in view of the tranche-wide nature of the affordable housing offer).

2.2 That the Director of Planning and Strategic Transport has delegated authority to issue the planning permission and impose conditions and informatives to secure the following matters:

Conditions

1) Legal agreement to secure the following planning obligations: a) Offsite delivery of affordable housing b) Provision of Travel Plan c) Local employment and training strategy d) Review mechanism regarding affordable housing delivery e) Any other planning obligation(s) considered necessary by the Director of Planning and Strategic Transport 2) Development implemented in accordance with submitted drawings 3) Details of materials to be submitted and approved 4) First floor windows in rear elevations of dwellings in Blocks A and B to be glazed with obscure glass and non-opening below 1.7m in height 5) No windows other than as shown 6) Remove Permitted Development for house extensions (Classes A to E) 7) Landscaping scheme including boundary treatment and maintenance strategy to be submitted and approved 8) Accordance with recommendations of Noise Report to include further information to be provided 9) Accordance with Air Quality report 10) Noise from air handling units 11) Low emissions strategy to be submitted 12) Details of mechanical ventilation to be submitted 13) Contaminated land assessment to be submitted and approved 14) Retention of car and cycle parking spaces 15) Provision of electric vehicle charging spaces 16) Implementation of Travel Plan 17) Approval of construction logistics plan 18) Submission of Arboricultural Method Statement 19) In accordance with mitigation measures of ecological survey 20) Water efficiency 21) Sustainable development 35% carbon dioxide reduction 22) Approval of detailed design of a surface water drainage scheme 23) Archaeology written scheme of investigation to be submitted 24) Development to commence within 3 years of the date of permission 25) Any other planning condition(s) considered necessary by the Director of Planning and Strategic Transport, and

Informatives

1) Community Infrastructure Levy (CIL) – Granted 2) Details with regard to donor site arrangement 3) Removal of site notices 4) Code of practice on construction sites 5) Standards for acoustic design 6) Boilers 7) Light pollution 8) Archaeology 9) Any other informative(s) considered necessary by the Director of Planning

2.3 That the Planning Committee confirms that adequate provision has been made, by the imposition of conditions, for the preservation or planting of trees as required by Section 197 of the Town and Country Planning Act 1990.

3 PROPOSAL AND LOCATION DETAILS

Proposal

3.1 Demolition of former care home and erection of a total of 24 houses, flats and maisonettes in the form of:

 Four terraced rows of houses comprising 6x2 bedroom 4 person houses over two storeys and 8x3 bedroom 6 person houses over three storeys.

 A three storey building comprising 5x1 bedroom 2 person flats at ground floor level and 5x2 bedroom 4 person maisonettes above. Two ground floor flats to be wheelchair accessible.

3.2 The buildings would have pitched roofs with external materials of light brick to the elevations with dark grey standing seam zinc roofs.

3.3 The existing access from Homefield Road would be relocated further westwards and widened and a new emergency vehicle exit would be formed onto the cul-de-sac to the north west of the site. 19 vehicle parking spaces would be provided within the site, one per new house in the form of either an integral garage or individual space to the front of each unit. The flatted development would have five parking spaces (between the ten units) with two designated for the wheelchair accessible units.

3.4 The houses and ground floor flats would have individual storage areas for bicycles and refuse. The upper storey maisonettes would have a communal bicycle store located in a purpose-built structure within the site.

3.5 All of the 24 units would be for private sale.

3.6 This application has been submitted as part of a wider programme of approximately 50 sites (‘Portfolio’) across the Borough of Croydon. The applicant has stated that they aim to deliver 1000 residential units of which half are intended to be delivered within affordable housing tenures. Each site is the subject of a separate planning application with the Portfolio as a whole divided into tranches. To date, three tranches of applications have been submitted, which amounts to applications on 28 sites for approximately 540 dwellings of which 235 are proposed as affordable housing tenures.

3.7 The affordable housing proposed is not balanced across all of the sites within tranches and portfolios, with some sites proposing more affordable housing and some less, with developments which are “minors” (which do not require affordable housing provision in policy terms) also proposing some affordable housing. As such, some sites act as “donor” sites in affordable housing terms and others are “beneficiaries” (ie they are sites which require affordable housing in policy terms which is being provided off-site or as a mixture of on- and off-site).

3.8 The site is within Tranche 2. The applicant proposes to deliver 44% of affordable housing across Tranche 2 in accordance with the donor site arrangement summarised above. This development would provide 24 residential units for market sale and would be a beneficiary of other donor sites.

3.9 The planning consideration for the donor site arrangement is set out in greater detail below.

Site and Surroundings

3.10 The application relates to Homefield House, a former care home located to the north east side of Homefield Road. The site has been vacant for a number of years. The building has a mostly ‘L’ shaped form comprising of one to three storeys with a flat roof over. The plot has an area of 0.47 hectares.

3.11 The existing vehicular access to the site is a narrow single track and has an in-out arrangement from Homefield Road onto the cul-de-sac to the north-west. This access is currently blocked up.

3.12 The surrounding area is predominantly residential, the housing typology typically comprising a mix of bungalows and two storey detached and semi-detached houses. Oasis Academy School is located directly to the south of the site with a car park and sports pitches that are situated to the rear. This building has a mix of one to four storeys and there are notable large areas of hardstanding. Immediately to the north is a small cul-de-sac which serves two detached dwellings. To the east, the site is located immediately adjacent to the boundary with the Metropolitan Green Belt.

3.13 The site is located approximately 0.3 miles from Coulsdon Road, which has a small parade of local shops and businesses including a convenience store and pharmacy. There are also bus stops within 0.1 miles of the site. Coulsdon South train station is 2 miles from the site. The site has a PTAL of 1b (poor access to public transport).

3.14 There are no land use constraints as identified on the Croydon Local Plan Policies Map. A number of trees on site including a group to the frontage are subject to Tree Preservation Orders.

Planning History

3.15 The following planning decisions are relevant to the application:

82/02682/P Erection of two storey extension to provide 18 additional bedrooms Granted 18/02/1983

89/03458/P Use of staff flat for domestic skills training facility for mentally ill persons and for office purposes. Granted 28/02/1990

4 SUMMARY OF KEY REASONS FOR RECOMMENDATION

4.1 There are no protected land use designations on the site and therefore the principle of development is acceptable, subject to assessment of other related planning considerations;

4.2 The proposed development would contribute positively to borough-wide housing targets and alongside other sites coming forward (as part of an overall tranche-wide delivery of housing across the borough) will contribute positively to the delivery of affordable housing across the various affordable housing tenures;

4.3 The development would create a mix of unit types (family and non-family) including 8 x 3 bedroom (6 person) and 11 x 2 bedroom (4 person) units.

4.4 Given the scale and appearance of the existing built-form on site and the adjacent Oasis Academy, the scale and density of development proposed would cause no harm with the visual amenities of the area;

4.5 The layout and design of development ensures that the proposal would not have a detrimental impact on the amenity of the neighbouring residents;

4.6 The development would provide an acceptable standard of living for future residents of the development in terms of internal accommodation and external amenity space;

4.7 The majority of mature high quality trees on site would be retained;

4.8 The development would not have a detrimental impact on highway safety and any parking demand can be accommodated on the surrounding road network.

4.9 A sustainable drainage strategy has been designed to ensure the development would cause no surface water flood risk issues.

5 CONSULTATION RESPONSE

5.1 The views of the Planning Service are expressed in the MATERIAL PLANNING CONSIDERATIONS section below.

5.2 The following were consulted regarding the application:

Lead Local Flood Authority (Statutory Consultee)

5.3 Objection to the initially proposed drainage strategy. The strategy has been subsequently amended to address the LLFA concerns. In relation to the amended scheme, the LLFA do not object and are satisfied that a SuDs scheme can be provided on the site through the imposition of planning conditions.

Historic England – Archaeology

5.4 The planning application lies in an area of archaeological interest (Archaeological Priority Area) identified for the Local Plan: Croydon Downs. An archaeological desk- based assessment submitted with the planning application has established that there is limited evidence for prehistoric activity in the area, with no evidence for Roman and early medieval activity. Appraisal of this application indicates the need for field evaluation to determine appropriate mitigation. A condition is recommended to require a two-stage process of archaeological investigation.

Thames Water

5.5 No objection with regard to sewerage infrastructure capacity. With regard to surface water drainage it is the responsibility of the developer to make appropriate provision for drainage to ground, water courses or suitable sewer. In respect of surface water it is recommended that the applicant should ensure that storm flows are attenuated or regulated into the receiving public network through on or off site storage. When it is proposed to connect to a combined public sewer, the site drainage should be separate and combined at the final manhole nearest the boundary. Connections are not permitted for the removal of groundwater. Where the developer proposes to discharge to a public sewer, prior approval from Thames Water Developer Services will be required.

6 LOCAL REPRESENTATION

6.1 The application has been publicised by way of 4 site notices displayed in the vicinity of the application site. The application has also been publicised in the local press. The number of representations received from neighbours, local groups etc in response to notification and publicity of the application were as follows:

No of individual responses: 13 Objecting: 13 Supporting: 0

6.2 Representations have been made from the following local groups/societies:

 Old Coulsdon Residents’ Association (objection)  East Coulsdon Residents’ Association (support subject to the condition that parking is provided for one vehicle per dwelling)

6.3 The following issues were raised in representations. Those that are material to the determination of the application, are addressed in substance in the MATERIAL PLANNING CONSIDERATIONS section of this report:

 Existing flood risk/drainage problems in the area will be exacerbated by any new development  Overdevelopment of the site  Lack of parking  Inadequate parking will lead to increased traffic problems on Homefield Road (which is already problematic at school times)  Homefield Road outside the site/school narrows and the proposal will increase highway safety concerns  Will not be able to manoeuvre in cul-de-sac serving 53A and 55 Homefield Road  Out of character in terms of size, density, massing, materials and style  Adverse impact on 55 Homefield Road in terms of loss of light and outlook and encroachment. Loss of access to drain  Noise and disruption from construction  Inadequate external amenity for proposed properties  Lack of green spaces  Unclear which trees are to be kept  Slow worms, badgers and bats seen in the area  Devaluation of my property (Officer comment: Not a material planning consideration)

6.4 Chris Philp MP and Councillor Bird have made representations (objecting) which are summarised as follows:

 Too dense and does not respect the pattern and layout of neighbouring houses or character of the area  Adverse impact on 55 Homefield Road (access to drain, overlooking, loss of light, difficulty accesses their property, garden plants will be destroyed)  Insufficient parking provision  Traffic issues at school times

7 RELEVANT PLANNING POLICIES AND GUIDANCE

7.1 In determining any planning application, the Council is required to have regard to the provisions of its Development Plan so far as is material to the application and to any other material considerations and the determination shall be made in accordance with the plan unless material considerations indicate otherwise. The Council's adopted Development Plan consists of the Consolidated London Plan 2015, the Croydon Local Plan: Strategic Policies 2013 (CLP1), the Croydon Replacement Unitary Development Plan 2006 Saved Policies 2013 (UDP) and the South London Waste Plan 2012.

7.2 Government Guidance is contained in the National Planning Policy Framework (NPPF), issued in March 2012. The NPPF sets out a presumption in favour of sustainable development, requiring that development which accords with an up-to-date local plan should be approved without delay. The NPPF identifies a number of key issues for the delivery of sustainable development, those most relevant to this case are:

 Section 4: Promoting sustainable transport  Section 6: Delivering a wide choice of quality homes;  Section 7: Requiring good design;  Section 8: Promoting healthy communities;  Section 10: Meeting the challenge of climate change and flood risk;  Section 11: Conserving and enhancing the natural environment;

7.3 The strategic and local policies that need to be taken into account as part of the Planning Committee deliberations are as follows:

7.4 Consolidated London Plan 2015 (LP):

 3.3 Increasing housing supply  3.4 Optimising housing potential  3.5 Quality and design of housing developments  3.8 Housing choice  3.9 Mixed and balanced communities  3.11 Affordable housing targets  3.12 Negotiating affordable housing on individual private residential and mixed use schemes  3.13 Affordable housing thresholds  5.1 Climate change mitigation  5.2 Minimising carbon dioxide emissions  5.3 Sustainable design and construction  5.11 Green roofs and development site environs  5.13 Sustainable drainage  6.9 Cycling  6.10 Walking  6.11 Smoothing traffic flow and tackling congestion  6.13 Parking  7.1 Lifetime neighbourhoods  7.2 An inclusive environment  7.3 Designing out crime  7.4 Local Character  7.6 Architecture  7.8 Heritage assets and archaeology  7.14 Improving air quality  7.19 Biodiversity and access to nature  7.21 Trees and woodland

7.5 Croydon Local Plan: Strategic Policies 2013 (CLP1):

 SP1.2 Place Making  SP1.3 Growth  SP2.1 Homes  SP2.3 & SP2.4 Affordable homes  SP2.5 Mix of homes  SP2.6 Quality and standard of homes  SP4.1 & SP4.2 Urban design and local character  SP4.13 Protection of heritage assets  SP5 Community facilities  SP5.2 Health and wellbeing  SP6.1 Environment and climate change  SP6.2 Energy and carbon dioxide reduction  SP6.3 Sustainable design and construction  SP6.4 Flooding  SP7.4 Biodiversity  SP8.3 & SP8.4 Pattern of development and accessibility  SP8.6 Sustainable travel choice  SP8.12 &SP8.13 Electric charging infrastructure  SP8.17 Parking outside of high PTAL areas

7.6 Croydon Replacement Unitary Development Plan 2006 Saved Policies 2013 (UDP):

 UD1 High quality and sustainable design  UD2 Layout and siting of new development  UD3 Scale and design of new buildings  UD6 Safety and security  UD7 Inclusive design  UD8 Protecting residential amenity  UD13 parking design and layout  UD15 Refuse and recycling storage  NC4 Woodland Trees and Hedgerows  EP1 Control of potentially polluting uses  EP2 and EP3 Land contamination  T2 Traffic generation from development  T4 Cycling  T8 Parking  H2 Supply of new houses  CS2 Loss of community facilitates

7.7 CLP1.1 &CLP2

 The Partial Review of Croydon Local Plan: Strategic Policies (CLP1.1) and the Croydon Local Plan: Detailed Policies and Proposals (CLP2) have been approved by Full Council on 5 December 2016 and was submitted to the Planning Inspectorate on behalf of the Secretary of State on 3 February 2017. Policies which have not been objected to can be given some weight in the decision-making process.

7.8 There is relevant Supplementary Planning Guidance as follows:

 London Housing SPG March 2016

 The London Mayoral (Draft) Affordable Housing SPG. This document is currently out for consultation which seeks to provide a more robust, transparent and clear approach to the delivery of affordable housing (both on and off site). The SPG also recognises a wider range of affordable housing tenures and how the value of these tenures might be maximised whilst ensuring overall affordability for Londoners to either rent a home or purchase a property. Whilst the London Mayor is encouraging all boroughs to adopt the approaches outlined by this draft SPG and it indicates a clear direction of travel, the weight to be afforded to this document is limited at present.

8 MATERIAL PLANNING CONSIDERATIONS

8.1 The main planning issues raised by the application that the committee must consider are:

1. Principle of development and density 2. Affordable housing and housing mix 3. Townscape and visual impact 4. Residential amenity 5. Living conditions of future occupiers 6. Highway safety and car parking demand and supply 7. Trees and biodiversity 8. Flood risk and sustainable drainage 9. Other planning matters

Principle of Development and Density

8.2 The proposed development would demolish a vacant care home and provide 24 residential units in the form of five buildings, the majority of which would be two and three bedroom terraced houses along with flats and maisonettes.

8.3 Homefield House is a former care home (Use Class C2). It is no longer in use and is in a dilapidated state. Adopted policy seeks the protection of existing community uses which still serve, or have the ability to serve the needs of the community. Emerging Policy SP5 in the Croydon Local Plan – Strategic Policies – Partial Review states that the borough has an over-provision of care homes, residential homes and nursing homes, with such uses no longer intended to be protected by policy. Notwithstanding this, the Croydon Local Plan – Strategic Policies – Partial Review was submitted to the Secretary of State 3rd February 2017 and currently carries little weight as a material planning consideration when assessing current proposals.

8.4 Homefield House, along with other care home sites, was included in the “new for old” scheme (“Homes for the Future Programme”) which aimed to renew care homes; an initiative which resulted in the planned closure of some sites based on their re-provision elsewhere. The closure of this building and several others resulted in new care homes/ day centres being opened at Addington Heights in New Addington, Frylands Court, and Morland Road. The existing community use has therefore been re-provided elsewhere and therefore in policy terms and in this particular case, the development would not result in a net loss of such facilities.

8.5 The appropriate use of land is a material consideration to ensure that opportunities for development are recognised and housing supply optimised, including providing a variety of housing types and unit mix.

8.6 The site is not subject to any policy designations that should be afforded weight in the determination of suitability of the land for use as residential, although the decision taker needs to also consider other related policies when determining overall planning merits. As the site is in a predominantly residential area, the principle of further residential development is appropriate. The adopted and emerging local plan and the adopted alterations to the London Plan have challenging housing targets and it is important that the borough maintains its 5-year housing supply and contributes positively to the supply of new housing (across all unit sizes and tenures).

8.7 33% (8 units) of proposed units on-site would be three-bedroom (6 person). 46% (11 units) would be 2 bedroom 4 person units. The scheme would therefore secure a relatively high level of family accommodation as envisaged by adopted policy. This proposed development would provide much needed family and non-family housing whilst facilitating the delivery of affordable housing (off site via a range of donor affordable housing sites) thereby maximising affordable housing delivery. These specific issues/benefits are further highlighted later in this report.

8.8 Table 3.2 of the London Plan and the related Policy 3.4 deals with density of development (linked to PTAL levels) and advises that “suburban” areas are characterised by predominantly lower density development such as detached and semi-detached houses, small building footprints and typically buildings of between two and three storeys. The scheme contains 83 habitable rooms which would equate to 177hr/ha. Table 3.2 advises that density of residential development within “suburban” locations with PTALs of 0-1 can range from between 150-200 hr/ha. Therefore, the proposed density is considered to be appropriate for the area.

8.9 The principle of the proposed use is considered to be acceptable subject to other material considerations as addressed below.

Affordable Housing

8.10 The provision of affordable housing is a necessary pre-requisite to providing a diverse variety of homes that meets a range of housing needs. All major schemes should provide affordable housing and where the maximum policy compliant affordable housing level is not 50%, a viability appraisal should be undertaken to justify the more limited levels proposed. CLP Policy SP2 makes a presumption, outside of the Metropolitan Centre, that affordable housing will be delivered on site. However, the London Plan envisages that there may be circumstances where affordable housing is provided off-site as part of a donor site arrangement where it allows for the delivery of higher levels of affordable housing, or other benefits. Overall it is clear that the London Plan acknowledges that it may be necessary for a flexible approach to be taken towards the provision of affordable housing to encourage residential development.

8.11 The applicant has so far submitted 28 planning applications across the Borough, seeking to deliver an ambitious and progressive housebuilding programme (including the delivery of significant levels of affordable housing) across the portfolio and has indicated that it intends to deliver these schemes across a series of tranches. The applicant has confirmed their intention to adopt a donor site arrangement across the Portfolio to deliver affordable housing, with the sole purpose to maximise the amount of affordable housing that can be delivered across each tranche. This approach can be supported if it secures the delivery of more affordable housing than the normal policy approach.

8.12 This site forms part of Tranche 2 which comprises of 13 sites, of which seven constitute “major” developments; with policy requiring these sites to provide up to 50% affordable housing, subject to viability. Due to limitations on scale of development and the number of units proposed, no affordable housing is required (in policy terms) to be delivered on the other six sites. The sites in Tranche 2 are as follows:

Applicant’s affordable housing proposal – Tranche 2 Proposed tenure Shared Application Private Affordable Total No Name Ownership Number units Rent units of Units units 16/06276/FUL Drovers Road 0 0 9 9 16/06366/FUL Academy Gardens 900 9 16/06273/FUL Coldharbour 0 0 8 8 16/06400/FUL Homefield House 24 0 0 24 16/06438/FUL Marston Way 12 0 0 12 16/06422/FUL Malling Close and Stockbury Road 27 0 14 41 16/06372/FUL Tollgate (C) 0 0 1 1 16/06337/FUL Thorneloe 10 0 0 10 16/06343/FUL Cheriton House 0 3 24 27 16/06275/FUL Eagle Hill 8 0 0 8 16/06374/FUL Ravensdale (site A + B) 28 0 0 28 16/06375/FUL Ravensdale (site C) 200 2 16/06432/FUL Warbank Crescent 0 20 16 36

TOTAL 120 23 72 215

8.13 The seven “major” sites (Thorneloe Gardens, Cheriton House, Harold Road and Ravensdale Gardens, Homefield House, Malling Close and Stockbury Road, Warbank Crescent, and Marston Way) comprise a total of 178 units of accommodation which in policy terms, would equate to 139 units of affordable accommodation (50% of their provision). If the 50% is split between affordable rent and intermediate products on a 60:40 ratio (in favour of affordable rent) and delivered on-site, 83 units of affordable rent accommodation and 56 units of shared ownership accommodation would be required.

8.14 Affordable housing policy makes clear that the delivery of affordable housing should take into account site viability considerations to ensure that affordable housing requirements do not result in schemes overall being undeliverable (in viability terms). In such circumstances, it can be acceptable to deliver less than 50% affordable housing (including delivery of an alternative affordable tenure mix).

8.15 The viability of the seven “major” schemes were reviewed by an independent viability consultant. This concluded that, after taking into account a number of different factors and contingencies, the seven major applications might well be able to support the following provision of affordable housing at a policy compliant mix (60:40 in favour of affordable rent)

Viable levels of affordable housing on major sites Proposed tenure Shared % Application Private Affordable Name Ownership Affordable Number units Rent Units Units provision 16/06400/FUL Homefield House 24 0 0 0% 16/06422/FUL Tollgate (A & B) 23 11 7 44% 16/06438/FUL Marston Way 32 0 0 0% 16/06337/FUL Thorneloe 10 0 0 0% 16/06343/FUL Cheriton House 12 9 6 56 16/06374/FUL Ravensdale (site A + B) 23 3 2 17% 16/06432/FUL Warbank Crescent 11 15 10 69%

TOTAL 115 38 25 38%

8.16 The applicant has challenged a number of the assumptions that informed this independent review, including the value of affordable rent units, existing land values and the final sales values. Notwithstanding the applicant’s concerns, officers consider that the review output is a reasonable position and should not be as easily discounted. However, as with all such exercises, there are a number of assumptions made which are invariably open to interpretation and further analysis (especially where sales values and land values are difficult to determine, with general lack of comparables). In this instance, there is a fair degree of uncertainty, as some of the sites are in locations where there have not been a high number of sales of comparable units to use to benchmark valuations. Consequently, whilst officers are broadly content at this stage to accept the applicant’s viability case, with such uncertainty, it is recommended that a review mechanism is utilised to allow for a review of the scheme viability at the point of commencement to determine whether there is scope to either increase the level of on-site delivery and/or to modify the mix of affordable housing accommodation to bring delivery closer to the 60-40 affordable housing split (in favour of affordable rent) as envisaged by policy.

8.17 Notwithstanding the applicant’s concerns, the independent viability review has demonstrated significant differences in levels of viability for the different sites, based in part on their location, site constraints and the prices which tend to be achieved in the local area. It shows that some sites could support a fair amount of affordable housing and others could not support any. Taking viability and the maximum policy position into account, the amount of affordable housing which the major sites could support, if assessed individually as opposed to as a tranche, would be 34 units of affordable rent and 21 units of shared ownership, which would equate to an average of 31% affordable housing (across the major applications) .

8.18 Taking this information, it can be compared against the applicant’s tranche-wide affordable housing offer:

Affordable % Affordable Name Shared Units Total units Units provision

Viable major sites (capped at 50%) 34 21 55 31

Tranche-wide offer 23 72 95 44

8.19 Whilst the tranche-wide approach would deliver 11 fewer affordable rent units and would be reliant on delivery across a range of donor sites, it would also result in an additional 40 affordable housing units overall (although all of this uplift would be shared ownership tenures rather than affordable rent tenures). This would represent a 70% increase over and above what would be expected for the major applications (albeit with a very different tenure split).

8.20 It is considered that this increased supply of shared ownership affordable housing would meet an identified need for affordable accommodation and would go some way towards meeting the affordable housing requirements set out in the London and Local Plans and as such, the supply of an additional 40 shared ownership units outweighs the deficit of 11 affordable rent units.

8.21 The donor sites in Tranche 2 are spread throughout the Borough and support the delivery of “mixed and balanced communities” which is one of the objectives of the London Plan policy requiring on-site delivery. The applicant has demonstrated on a Ward by Ward basis that the provision of shared ownership tenure accommodation would be desirable, especially as shared ownership tenures are under-represented in the areas that have been identified for housing growth across Tranche 2.

8.22 The method of delivery of affordable housing is innovative and demonstrates a flexible approach to securing affordable housing which is supported by the London Plan. Whilst it is not fully in accordance with the provisions of the development plan, off site affordable housing provision is anticipated by planning policy documents. Taking this approach would facilitate a significant uplift in affordable housing delivery, over and above standard policy requirements. These benefits of a tranche-wide, donor site approach to affordable housing provision in this particular case (being the provision of an amount of affordable housing above policy requirements, a demonstration that the maximum viable amount and mix of affordable housing on major sites is being secured and that this approach allows sites to be developed that would otherwise be unviable) would outweigh any harm caused by the failure to deliver affordable housing on a site by site basis. Subject to the use of a subsequent viability review (prior to commencement of development), officers find the approach proposed by the applicant to be acceptable.

8.23 As the applicant currently has no ownership interest in the land the subject of this proposed development, it is recommended that a planning condition be imposed preventing any development from taking place on site unless and until all parties with a legal interest in the land (including the applicant) have been joined as parties to a legal agreement under S.106 of the Town and Country Planning Act 1990, with specific covenants specified to prevent occupation of a percentage of private sale units on site until such time as prescribed levels of on and off site affordable housing across Tranche 2 have been completed and are available for occupation/hand-over. The required heads of terms (including the requirement for a viability review) will be set out within any condition. This recommended approach (using a planning condition to require a later S.106 Agreement to be completed) has been successfully tried and tested by the London Legacy Development Corporation in relation to sites near the former Olympic Stadium and a similar approach was recommended by your officers in relation to the College Green/Fairfield Halls submission, which was accepted by the Planning Committee in February 2017. This approach will ensure that this important tranche of developments and the significant amount of affordable housing will be delivered.

8.24 Planning applications have been submitted for all sites within Tranche 2. Four applications are being reported to Planning Committee concurrently, with others proposed to be determined under delegated powers or at a later Planning Committee. The affordable housing analysis set out above covers all of the sites in the tranche, so should an application be refused by Planning Committee or under delegated powers, the figures above would change. The RECOMMENDATION to Committee sets out a mechanism for reporting applications back to the Committee, should this be necessary.

Townscape and Visual Impact 8.25 The existing building on site is of no visual merit; it has an irregular footprint which occupies a large area of the site and is in a dilapidated state. Whilst the existing building is at odds with the scale and appearance of the residential development found to the north and west of the site, it is significantly less prominent in mass in comparison to the Oasis Academy complex which is located directly to the south east. This site therefore forms a transition between building type.

8.26 The proposed residential units would have a greater density and scale than the adjacent residential properties which are generally detached or semi-detached one or two storey dwellings. However, the existing built form on site and that of the Oasis Academy creates an opportunity to increase density and alter appearance in comparison to the existing dwellings and have a positive impact on the visual amenities of the area.

8.27 Like the existing building on site, the proposed buildings would comprise a maximum of three storeys. Pitched roofs have been introduced to give the buildings a domestic appearance which allow them to have some resonance with the existing residential built-form.

8.28 Block C follows the existing front building line along Homefield Road. The plans have been amended so that these proposed units face Homefield Road with their external amenity space being contained mostly within the front garden area. This amendment allows the development to have an active frontage onto Homefield Road, respecting the rhythm of the street scene. Whilst the plans show 1.8m high boundary treatment along the Homefield Road frontage, officers are of the opinion that such boundary treatment is inappropriate and require a treatment with a less prominent scale to be sought by condition. Treatment of areas of defensible space could be provided further back within the site to create private garden areas for these units without harming the visual amenity of the area.

8.29 The other proposed buildings would be situated further back within the site and at an angle to the highway and therefore their visual prominence within the street scene would be significantly reduced. The three storey blocks would be located adjacent to the boundary with Oasis Academy, Block D located in a similar position to the existing main three storey part of the current building. The buildings to the rear would be subservient in scale, better respecting the height of the residential properties to the north.

8.30 The majority of properties in the surrounding area have light coloured render to their elevations. The proposed buildings would have external materials of light coloured brick to the elevations and a standing seam zinc metal roof. The tone of brick has been chosen to reflect the colour of the elevation treatment of the adjacent buildings.

8.31 Overall, whilst the scale of built form would be greater than the adjacent residential properties, the existing development on site and location adjacent to the Oasis Academy has created the potential of the site to create a density development which would cause no significant harm to the character or appearance of the area.

Impact on residential amenity

8.32 Directly to the north west of the site is 53 Homefield Road, a detached bungalow with access from its south side. An existing vehicular access track is located to the south side of this property. The proposed development would be located 9.5m from the south side elevation of 53 Homefield Road and this layout and separation would ensure that the property would not be unduly overbearing or cause any loss of outlook to this property. No windows are proposed in the side elevation of Block C and therefore there would be no direct loss of privacy. The rear Block A would be positioned at an angle from 53 Homefield Road and given the distance between the buildings, there would be no harmful overlooking of the rear windows.

8.33 To the north of the site is 55 Homefield Road (Homefield Cottage) which is a detached two-storey house located on a back-land plot. The north-east and north-west boundaries of the application site are immediately adjacent to the boundary with Homefield Cottage. The proposed units which back onto this dwelling are part two and part single storey. The single-storey elements are 3.2-3.7m from the boundary and the two storey elements approximately 7.5m from the boundary. The units have been designed so that no windows would overlook this property. The only first floor windows in the rear elevation serve the stairwell and bathroom and therefore these windows can be conditioned to be glazed with obscure glass.

8.34 Proposed Block A would be located adjacent to the front elevation of Homefield Cottage. The original front elevation of the cottage has an entrance porch with rooms to either side, one of which is a dining room and one an office. This part of the house is set back from the boundary and outlook to the properties front courtyard would be retained. Existing outlook beyond this is of the flat roof single storey element of the former care home and therefore the proposal would not significantly affect outlook in comparison to the existing situation. Homefield Cottage has also been extended to the side and existing windows in the front elevation of the extension are situated behind and in close proximity to existing boundaries and therefore outlook from these rooms would not be affected.

8.35 An area of open space is proposed adjacent to the side elevation of Homefield Cottage and the rear elevation of proposed Block B would face onto the rear garden of this neighbouring property. Block B, like Block A has no main habitable windows that would overlook this garden. The main habitable rooms of Homefield Cottage are located in the rear elevation and therefore outlook would not be affected.

8.36 A Daylight and Sunlight Assessment has been undertaken using BRE guidance which tests for compliance against the British Standard Code of Practice. The report concludes that in terms of daylight, of the 46 windows tested, all will continue to meet the target values set out in BRE guidelines. For sunlight, of the 22 windows tested, 21 will continue to meet the annual target. A ground floor window of 55 Homefield Road would not meet the target for winter sunlight but would easily meet the 25% Probable Sunlight Hours (PSH) target at 37%. Whilst the winter months target of 5% PSH is not achieved (at 3%), directly to the south of the window is the entrance porch to the property which already restricts light. Further, the adjacent window in the property serves the same room and meets both targets, mitigating the losses to the subject window.

8.37 The occupiers of Homefield Cottage are also concerned that the proposed development would restrict the ability for vehicles to manoeuvre to and from their property in forward gear. All of the proposed development would be located on land outside of the control of Homefield Cottage. This matter is discussed further below in the highways section of this report. Access into the application site for maintenance of drains and landscaping is a legal matter between the neighbour and the land owner. 8.38 The site abuts Oasis Academy to the south and east. To the south is the access road to the academy and to the east the car park. The proposals would have no adverse impact on this facility.

8.39 Overall, the proposal has been designed to ensure there would be no significantly harmful impact on the amenities of any adjacent residential properties.

Living Conditions of Future Occupiers

8.40 Policy SP2.6 requires that all new homes meet the needs of the residents, by achieving the minimum standards set out in the Mayor of London’s Housing Supplementary Planning Guidance. The Nationally Described Space Standards (NDSS) provide minimum technical space standards for new dwellings in terms of the internal amenity space. All of the proposed units meet the minimum required internal space standard. Two wheelchair accessibly units are proposed on the ground floor of Block D and can be accessed from the wheelchair parking bays which are proposed to be provided adjacent to each unit.

8.41 In terms of internal daylight, all of the proposed windows meet the BRE target values. With regard to internal sunlight, 38 transgressions are noted. 26 of the 38 transgressions relate to bedrooms which the BRE guidelines state are less important as are generally mostly occupied at night time. Of the remaining 12 transgressions, 5 (in Blocks A and B) meet the annual target values and receive some winter sunlight. The other 6 occur to the ground floors of Block A and B serving 1 kitchen diner and 5 lounges. Overall, these transgressions are not so significant to warrant refusal of the application. All affected units have other habitable rooms with acceptable daylight and sunlight levels and all units proposed would be dual aspect.

8.42 With regard to external amenity space, the London Housing SPG states that a minimum of 5sqm of private outdoor space should be provided for 1-2 person dwellings and an extra 1sqm for each additional unit. UDP Policy UD8 requires development proposals to provide residential amenity space to be considered as an integral part of the design of the overall development concept. Each unit has an external amenity space which accords with the standards and an area of communal amenity space would be provided between Blocks A and B.

8.43 Of the 21 areas tested for permanent overshadowing, all but 4 would meet and exceed BRE targets. The failures occur in garden areas, falling short of the target for 50% of the area to receive 2 hours sunlight on 21 March (properties that would lie closest to Homefield Cottage with narrow rear gardens). Whilst these failures are noted, these units are located close to the communal green space which could provide additional external amenity if required.

8.44 A Noise Impact Assessment has been undertaken which recommends that due to the close proximity of Homefield Road and the access road to Oasis Academy, further noise assessment modelling is required to determine appropriate noise mitigation measures to control external noise. This would be required by condition.

8.45 A Contaminated Land assessment has been undertaken which finds that exceedances of the human health screening criteria were found and therefore remedial action/risk management will be required. Further investigations and any required mitigation can be secured through the use of planning condition, which would be imposed on any permission granted. Highway Safety and Car Parking Demand and Supply

Access

8.46 The number of trips expected to be generated by mode by the proposed scheme has been calculated using a combination of trip databases TRICS and TRAVL together with 2011 Census information. The trip generation analysis has indicated that the proposed scheme would generate a low level of vehicular traffic in the peak periods: 12 car trips in the AM peak and 11 in the PM peak. This would equate to a total of one vehicle every four to five minutes during the peak hours. Vehicle movements would be less frequent outside of peak hours. This level of trip generation is expected to be able to be accommodated within the existing highway network.

8.47 The existing narrow accesses into the site would be removed/reconfigured. A new shared access would be created from Homefield Road and a new street created within the site. The proposed entrance is more than 6m wide to allow refuse vehicles and fire pumping appliances to access the site and the access has adequate visibility splays. A turning head would be provided within the site and a gated access would be created to the north to provide emergency vehicle access only, to allow fire pumping appliances to leave the site in forward gear. This would also enable emergency vehicles to access 53A and 55 Homefield Road.

8.48 Refuse storage – each house would have a separate refuse storage area either built into its frontage or within the garage. The flats would have a purpose built store oppose the building. Swept path analysis demonstrates that refuse vehicles could access the new road and manoeuvre using the turning head provided.

8.49 The neighbours at Homefield Cottage have raised concern that access to their property would be restricted. Whilst the proposal would reduce the width of the existing access layout, it would still be possible to manoeuvre in and out of this property. The development is entirely situated on land outside of the neighbour’s control.

8.49 A preliminary Construction Logistic Management Plan has been submitted with the application. As the development is at planning application stage, a contractor has not yet been appointed and the applicant has not been able to provide full details of site layout and management or the numbers or timing of deliveries. Prior to the appointment of the Principal Contractor a Construction Management Plan should be developed alongside the pre-commencement Health and Safety Information (PCI), also required by the Construction (Design and Management) regulations 2015 (CDM 2015).

Parking

8.50 The site is located within an area with a public transport accessibility level (PTAL) rating level of 1B which is considered to have poor access to local transport links. The nearest train station is Coulsdon South which is 2.4km from the site. The closest bus stop is 100m north of the site on Homefield Road, providing one service per hour.

8.50 London Plan parking standards state that one to two bed units should have less than one parking space per unit while three bed units should have a maximum of 1.5 parking spaces per unit. Based on the unit types the proposal would demand a maximum of 28 parking spaces.

8.51 The Transport Assessment shows that average car ownership in the vicinity of the site is calculated at 1.33 vehicles per household (based against 2011 census). On this basis, it is assumed future users would generate 32 additional vehicles. The overnight parking stress survey indicates 39% stress with an average of 81 unrestricted spaces available during the survey period (within a 200m walk of the application site). The site is next to the Oasis Academy school and surveys were conducted at the beginning and end of the school day and the peak parking demand was found to be at 3:45pm where 105 unrestricted parking spaces were available within 200m of the site (21%), which was lower than average overnight stress.

8.52 The development proposes one vehicle parking space per house in the form of either an integral garage or parking space to front of the each unit. The larger block comprising 5x1 bedroom flats and 5x2 bedroom maisonettes would be provided with five spaces. The two ground floor accessible units would each have access to an adjacent parking space, and the remaining 8 units would be provided with three spaces between them. Whilst the development would not provide one parking space per unit, the parking stress survey demonstrates that there is space within the surrounding road network for any additional vehicles to park.

8.53 It is noted that objections from neighbouring residents have been received, concerned that the lack of on-site parking would lead to increased traffic problems on Homefield Road which becomes narrow to the south of the site and where traffic is already problematic at school times. This is a residential development and therefore is it not considered that main parking demands created by the development would conflict with school drop-off and collection times. Peak parking demand would be overnight when the school is closed. Whilst vehicles parked on Homefield Road narrow the width of the carriageway, this road as existing is unrestricted in terms of parking and there is still adequate space for vehicles to manoeuvre.

8.54 To support a reduced level of car parking at the development, a Travel Plan Statement has been prepared for the site. The Travel Plan Statement includes measures to help and encourage residents to travel by sustainable modes. The implementation of the Travel Plan can be secured by legal agreement.

8.55 Cycle storage is proposed to be provided in accordance with London Plan Requirements. Each house and ground floor flat would have a cycle storage area within its private garden area. The upper storey maisonettes would have a separate bike store within a timber clad purpose built structure and also a visitor parking space would be provided.

Trees and Biodiversity

8.56 This site is the subject of a tree preservation order. All of the mature trees to the front of the site and several trees along both side boundaries are included in the order.

8.57 The Arboricultual Report identifies that a total of 33 arboricultural items, including 5 groups and 28 individual trees, have been recorded within the study area. To facilitate the design and as originally proposed, 4 groups of trees and 14 individual trees were identified as requiring removal. These comprised of one Category A individual tree (trees of high quality), one Category B individual tree (trees of moderate quality), 11 Category C individual trees and three Category C tree groups (trees of low quality) and one Category U individual tree and one Category U group (trees of poor quality unsuitable for retention). The plans have been amended to secure the retention of the Category B tree and one of the Category C trees at the front of the site (therefore 12 subsequently proposed to be removed). 8.58 One Category A individual tree, two Category B individual trees and three Category C arboricultural items located within the application boundary have portions of their calculated Root Protection Areas (RPAs) within the development zones. In addition, one Category C individual tree, located on third party land adjacent to the proposed scheme boundary will also suffer a minor RPA breach.

8.59 The Council’s Tree Officer, whilst having no objection to the majority of tree removals, raised concerns to a number of aspects of the initially proposed plans. It was considered that the Grade A and B trees to the front of the site would be likely to dominate the proposed gardens and dwellings on Block C. The application has been amended so that the proposed dwellings in Block C have been altered so that the green space fronting Homefield Road acts as a front garden providing access into the site. The internal layout has been amended so that any main habitable living rooms are located to the eastern side of the units so that they are not overshadowed by the existing trees, which would reduce potential future pressure to remove them.

8.60 Concern was also raised as the proposed hard surfacing within the site to provide parking bays would be located within the root protection area of the mature Grade B Horse Chestnut (T1), as would the location of the access close to a grade B Pine tree (T4), which could compromise their health. The applicant has agreed that hardstanding or other construction within the root protection areas should be constructed using no dig or hand digging methods, details of which can be secured by condition.

8.61 The Tree Officer accepts the removal of the Yew (T3), finding its categorisation as a Grade A tree overly generous. Its removal is acceptable as the remaining mature trees of merit along the site frontage are to be retained.

8.62 As originally proposed the mature Grade B Ash tree (T25) towards the rear southern boundary of the site was shown to be removed to facilitate car parking. Its removal was considered unacceptable and therefore the plans have been amended to retain the tree. The parking bays would be constructed using no-dig or hand-digging methods.

8.63 The loss of trees on site would be mitigated by way of the planting of 25 new trees. Full details of the proposed new landscaping and its maintenance would be secured by condition.

Ecology

8.64 An Ecological Assessment has been submitted with the application. The site is located within 500m of an SSSI and seven sites of SINCs are located within 2km, the closest of these, Coulsdon Common is just under 45m south and east of the site.

8.65 The assessment of the trees and structures present on site found potential for the trees to support roosting bats, but the derelict main building had moderate potential to support roosting bats. Subsequent dusk emergence and dawn re-entry surveys of the building confirmed the presence of common pipistrelle and Soprano pipistrelle species roosting within the main building. As such, the demolition of the building would need to be conducted under the prescriptions of a Natural England European Protected Species derogation licence. The buildings would need to be demolished in winter through a soft-strip methodology under ecological supervision, in accordance with a method statement, with suitable alternative roosting provision provided within the new structure on site (pending approval from Natural England). Lighting and landscaping would need to ensure mitigation for bats to meet the European Protected Species Licence standards.

8.66 A common reptile presence/likely absence survey was conducted on the site and no reptiles were observed and therefore common reptiles are likely to be absent from the site.

8.67 The site has potential to support common nesting birds. Appropriate timing of vegetation removal/pre-works checks and replacement trees will ensure there is no impact on nesting birds.

8.68 Foxes are confirmed to be using the site and it is recommended that supervised hand clearance of scrub and use of one-way mammal gates will prevent harm to this species.

8.69 Enhancements are proposed for nesting birds including bird boxes within the proposed buildings. In addition, invertebrate hotels are proposed to be included on the biodiverse roofs.

8.70 The mitigation and enhancement measures outlined above can be secured by condition.

Flood Risk and Sustainable Drainage

8.71 The Environment Agency Flood Map for Planning (rivers and the sea) shows that the entirety of the proposed scheme is located within Flood Zone 1 and as such accords with the key aim of the NPPF, in locating development in the lowest areas of flood risk. The proposed scheme is considered to have no risk of flooding from fluvial or artificial sources and the risk of sewer flooding is low. The Croydon Surface Water Management Plan (SWMP) shows the site is not in a Critical Drainage Area (DCA) and the Croydon Strategic Flood Risk Assessment (SFRA, 2015) maps one recorded surface water flooding incident approximately 600m north-west and south of the proposed development site, with a large number of incidents approximately 750m north-west of the site. A recent historic flood register that Croydon Council holds maps two further recorded surface water flooding events within 500m of the site to the north and north east.

8.72 To ensure that the proposed scheme does not detrimentally affect surface water flood risk in its local drainage catchment a drainage strategy is proposed that will implement forms of SuDS appropriate to site specific constraints.

8.73 The Lead Local Flood Authority (LLFA) initially raised an objection to the originally proposed scheme which did not provide sufficient information to demonstrate that the proposal would not cause surface water drainage concerns. The drainage strategy has therefore been amended and subsequently the LLFA has removed their objection. Proposed catchments have been developed to utilise infiltration blanket locations for storage and to limit discharge to proposed deep bore soakaways. Runoff rates discharged to ground would be reduced post-development with attenuation storage provided on site. The drainage proposals also make use of tanked permeable paving and soft landscaping. The principle of the Drainage Strategy has been agreed with the LLFA, however further design details would need to be submitted and approved by condition.

Other Planning Matters Sustainable construction

8.74 The applicant has submitted an Energy Statement which outlines that sustainable design and energy management measures have been incorporated to meet the requirements of Policy SP6 – 35% reduction in carbon emissions over the Building Regulations 2013. Energy use will be minimised through demand reduction and passive measures such as high levels of insulation and high efficiency glazing and lighting and the use of natural ventilation (17.3% carbon reduction). 76 roof mounted Solar PV panels will generate 22.88kW of electrical energy (28.5% carbon reduction). Water fittings are specified to meet a target of 105 litres per person per day or less. These measures can be secured by planning condition.

Archaeology

8.75 The planning application lies in Croydon Downs, an area of archaeological interest (Archaeological Priority Area). An archaeological desk-based assessment submitted with the planning application has established that there is limited evidence for prehistoric activity in the area, with no evidence for Roman and early medieval activity. The assessment established some evidence for medieval and post-medieval activity in the area, with the site presumed to be in use as farmland or common land during these periods.

8.76 Historic England have commented that the historic maps provided as part of the desk based assessment do not demonstrate that the ground disturbance on site would have been comprehensive. Instead it is possible that modern ground disturbance may be limited to the footprint of the recent buildings, with greater survival elsewhere on site. In addition, whilst the evidence for archaeological activity in the surrounding area is generally low, it should be remembered that much of the surrounding landscape remains undeveloped, with a lack of modern ground disturbance perhaps limiting the extent to which archaeological deposits have been encountered.

8.77 Appraisal of this application using the Greater London Historic Environment Record and information submitted with the application indicates the need for field evaluation to determine appropriate mitigation. However, although the NPPF envisages evaluation being undertaken prior to determination, in this case consideration of the nature of the development, the archaeological interest and/or practical constraints are such that requirements can be sought by condition. The condition will require a two- stage process of archaeological investigation.

Community Infrastructure Levy

8.78 The development would be CIL liable. The levy amount has been calculated to ensure that the development contributes to meeting the need for physical and social infrastructure, including educational and healthcare facilities.

Conclusions

8.79 Taking all of the above planning considerations into account, it is recommended that planning permission should be granted.

8.80 Given the existing built-form on site and presence of the adjacent Oasis Academy, the scheme maximises the housing potential of the site (including the delivery of a high level of family housing and off-site affordable housing) without harming the visual amenities of the area. The layout and scale of built-form has been designed to ensure there would be no significant adverse impact on the residential amenities of the surrounding properties. Whilst the loss of some mature trees is acknowledged, the scheme proposes to retain the significant specimens of merit and has been amended to ensure this. There is adequate available on-street parking in the surrounding area to accommodate any overspill vehicles and given the proposed use of the site this would not exacerbate existing traffic issues recognised during peak school times. Whilst residents’ concerns regarding flooding in the area are noted, the site is not located in a flood risk area. A sustainable drainage strategy has been designed to ensure the development would cause no surface water flood risk issues.

8.81 All other relevant policies and considerations, including equalities, have been taken into account.