planning report PDU/1937/01 11 November 2009 The site, in the London Borough of planning application no.09/02856/P

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

The proposal A hybrid application for a mixed-use development, seeking: • Detailed planning permission for a single/two-storey building for use as a leisure centre, including swimming pool; erection of 187 new homes (including 23 perimeter houses); and the formation of vehicular access points onto Denning Avenue and Purley Way, with associated parking space. • Outline planning permission for a single/two-storey building comprising a maximum 2,567 sq.m. for use as a children’s education centre with ancillary facilities and associated car parking space. The applicant The applicant is Croydon Council Urban Regeneration Vehicle, and the joint architects are Levitt Bernstein and EPR.

Strategic issues The key issues relate to the need and principle of developing a leisure centre outside local town centre/edge-of centre sites, the loss of community facilities and open space associated with educational use. On the development itself, the principal issues are: housing, design, access/social inclusion, climate change, transport, the provision of a children’s educational centre and local environmental quality (air, noise etc).

Recommendation That Croydon Council be advised that whilst the application is generally acceptable in strategic planning terms, it does not fully comply with the London Plan for the reasons set out in paragraph 116 of this report; but that the possible remedies set out in paragraph 117 of this report could address these deficiencies.

Context

page 1 1 On 8 October 2009, the Mayor of London received documents from Croydon Council notifying him of a planning application of potential strategic importance to develop the above site for the above uses. Under the provisions of The Town & Country Planning (Mayor of London) Order 2008 the Mayor has until 18 November 2009 to provide the Council with a statement setting out whether he considers that the application complies with the London Plan, and his reasons for taking that view. The Mayor may also provide other comments. This report sets out information for the Mayor’s use in deciding what decision to make.

2 The application is referable under Categories 1A and 3E of the Schedule to the Order 2008:

1A- “Development which comprises or includes the provision of more than 150 houses, flats, or houses and flats.”

3E- “Development- (a) which does not accord with one or more provisions of the development plan in force in the area in which the application site is situated; and (b) comprises or includes the provision of more than 2,500 square metres of floorspace for a use falling within any of the following classes in the Use Classes Order—(xi) class D1 (non-residential institutions) and (xii) class D2 (assembly and leisure).”

3 Once Croydon Council has made a resolution as to which way it intends to determine the application, it is required to refer it back to the Mayor for his decision as to whether to direct refusal; take it over for his own determination; or allow the Council to determine it itself.

4 The environmental information for the purposes of the Town and Country Planning (Environmental Impact Assessment) ( and Wales) Regulations 1999 has been taken into account in the consideration of this case.

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

6 The 2.83-hectare site is on the eastern side of the A.23 Purley Way, to the immediate south-east of Fiveways Junction. It is bounded to the north by Denning Avenue and the rear of shop units that form Central Parade; on the east by a health centre and the wide, tree-lined residential Coldharbour Road, which also extends across the southern end of the site; and on the east by the dual-carriage Purley Way from London to Brighton. The southern boundary abuts two- storey residential properties in Charles Cobbs Garden, to which access is derived from Coldharbour Road.

7 The site is an amalgamation of four different premises listed from north to south, namely: ‘The Propeller’ Public House (excluding the Central Parade frontage), the former Waylands Day Centre, the Red Gates School, and Waddon Infant School. Buildings of the former public house and Waylands Day Centre were demolished in 2007 and 2008 respectively; the Red Gates School has been vacated, but not demolished; whilst Waddon Infant School will continue to function until December 2010.

page 2

Site location map- Courtesy of Tibbalds Planning and Urban Design

8 The site is bounded by Denning Avenue, which is a borough road and the A23 Purley Way which, at its junction with the A232 Stafford Road, forms part of the Transport for London Road Network (TLRN). Waddon train station is within an acceptable walking distance of the site, being located approximately 450 metres away, and offers regular train services to both central London and Surrey. Two bus routes serve the site, with stops located on both Denning Avenue and Purley Way. As such, it has been demonstrated that the site records an average Public Transport Accessibility Level (PTAL) of 3 to 4 on a scale of 1-6 where 6 is classed as excellent.

9 The site is approximately 2.4 km south-west of Croydon Town Centre. Its immediate surrounding comprises a mix of land uses, including housing to the east; the open space to the north-east, and a variety of retail and industrial uses to the west.

Details of the proposal

10 The proposal is to deliver:

• A leisure centre with a gross internal floor area of 4,134 sq.m., including a 25-metre six- lane swimming pool, a learner pool (13m), gymnasium, sports hall, dance studio, a crèche, café and energy centre to serve the facility and proposed residential units.

• 187 new homes, including 23 perimeter houses. The accommodation would be provided in two blocks (Block B: 6/7-storeys, Block C: 5/6-storeys) comprising 45 one-bed, 79 two-bed, and 30 three-bed flats; a 2/3-storey terrace of 23 four-bed houses; and a 2/3-storey building fronting Denning Avenue and comprising 10 two-bed flats and 59 sq.m. of community office space. • A children’s education centre, up to 2,567sq.m. in size, with multi-agency support services and a capacity for 40 pupils on full-time or respite basis.

page 3 • Associated car parking on the basis of 46 (including 8 staff) spaces for the leisure facility, 0.6 spaces per unit for residential use, and 33 spaces plus mini-bus drop-off for the children’s education centre.

• Associated landscaping and public realm improvements. Case history

11 Croydon Council resolved to grant planning permission in November 2005 for a residential development and community facilities (comprising a community hall, resource centre and disability centre) on the combined public house and Waylands day centre sites, but an associated legal agreement was never completed to allow the Council to issue the consent.

12 Pre-application meetings were held between the applicant’s representatives and GLA officers on 9 June and 6 August 2009. The subsequent GLA officer advice included the issues of need and the appropriateness of a leisure facility in an out-of-centre location, the loss of community facilities, and the loss open space associated with an educational use. Strategic planning issues and relevant policies and guidance 13 The relevant issues and corresponding policies are as follows:

• Housing London Plan; PPS3; Housing SPG; Providing for Children and Young People’s Play and Informal Recreation SPG, draft Housing Strategy • Affordable housing London Plan; PPS3; Housing SPG, draft Housing Strategy • Density London Plan; PPS3; Housing SPG • Mix of uses London Plan • Urban design London Plan; PPS1 • Transport/parking London Plan; the Mayor’s Transport Strategy; PPG13; • Open land London Plan; PPG17; • Biodiversity London Plan; the Mayor’s Biodiversity Strategy; Improving Londoner’s Access to Nature: Implementation Report; PPS9 • Access London Plan; PPS1; Accessible London: achieving an inclusive environment SPG; Wheelchair Accessible Housing BPG; Planning and Access for Disabled People: a good practice guide (ODPM) • Equal opportunities London Plan; Planning for Equality and Diversity in Meeting the spatial needs of London’s diverse communities SPG; Diversity and Equality in Planning: A good practice guide (ODPM) • Ambient noise London Plan; the Mayor’s Ambient Noise Strategy; PPG24 • Air quality London Plan; the Mayor’s Air Quality Strategy; The Control of dust and emissions from construction and demolition BPG; PPS23 • Sustainable development London Plan; PPS1, PPS Planning and Climate Change Supplement to PPS1; PPS3; PPG13; PPS22; the Mayor’s Energy Strategy; Sustainable Design and Construction SPG

14 For the purposes of Section 38(6) of the Planning and Compulsory Purchase Act 2004, the development plan in force for the area is the Croydon Replacement Unitary Development Plan (The Croydon Plan) 2006 Saved Policies (as amended by the Government Office for London's Direction Schedule dated 10 July 2009) and the London Plan (Consolidated with Alterations since 2004).

page 4 15 Croydon Council’s Core Strategy (Issues and Options) Initial Report, the Mayor’s Consultation Draft Replacement London Plan and the council’s Leisure Centre Strategy (2007) are material planning considerations. Land use policies/the principle of a leisure centre on the site

16 The proposals require justification in strategic planning policy terms: firstly, in relation to the need for a leisure centre and the principle of siting it in a sequentially less preferable location, contrary to the national policy stated in PPS6 (Town Centres); secondly, in relation to the loss of community facilities previously located on the site; and thirdly, in relation to the loss of open space designated for educational use.

Need

17 Health and fitness centres are included in the list of main town centre uses identified in PPS6 (paragraph 1.8). The national policy further provides (at para.3.4) that applicants proposing town centre uses on out-of-centre sites, should demonstrate a need for the proposed development.

18 In the national context, a GLA report ‘A Sporting Future For London’ (April 2009) noted that London had the second lowest level of participation in sport, with Croydon falling within the lowest classification. From a strategic perspective, the October 2008 GLA report ‘The Provision of Public Swimming Pools and Diving Facilities in London’ noted that: of the 33 local authorities in London, Croydon (55%) ranked the ninth lowest in terms of population within 20 minutes walk time of a public swimming pool. The report concluded that six multi-use public pools needed to be built by 2012. This is significantly less than the 22 pools required by the Amateur Swimming Association target of 13 sq.m. of public water space per 1000 population.

19 In terms of local need, planning consultants Nathaniel Lichfield & Partners submitted a Leisure and Town Centre statement to support the application. It bases its conclusions on a series of demand modelling studies of swimming pools, health & fitness stations, and sports halls carried out by PMP Consulting in the northern, central and southern sectors of the borough in 2005 and 2006, to provide an evidence base for the Council’s Leisure Strategy.

20 For the centre of the borough, defined as a 15-minute drive time from Waddon, the demand modelling study concluded that the large unmet demand for sports hall courts (137) was sufficient to justify the provision of a sports hall as part of the proposed Waddon facility.

21 The assessment of demand for health and fitness facilities was less clear-cut. Although the facility audit and demand modelling of 2005 indicated that existing provision was good (with an oversupply of health and fitness provision), over 80% of the provision was in private membership clubs. The cost of those facilities meant that they were not accessible to a significant sector of the population.

22 The 2006 update indicated a demand for an additional 2,159 sq.m. of swimming pool water space in the central catchment area. That analysis included the existing Purley Pool and Recreation Centre, scheduled for closure in 2010. Excluding the Purley Pool and Recreation Centre from the demand modelling increased the shortfall to 2,484 sq.m. of pool water space. 23 The results of the demand modelling for sports halls, health and fitness facilities and swimming pools in the centre of the borough are shown in the table below:

page 5 Facility type Demand Supply Difference Swimming pools (sq.m. of water space) 7,239 4,755 - 2,484* Health and fitness stations 732 1330 +598 Sports halls (badminton courts) 197 60 -137

* Equivalent to eight 25m by 6-lane swimming pools- Source: PMP Consulting

24 It was against this background that the Council, in adopting its Leisure Centre Strategy in December 2007, included proposals for new wet and dry facilities (to include a 25-metre, 6-lane swimming pool, learner pool, four-court sports hall and health and fitness gym) in the centre of the borough to address the identified undersupply of sports halls and swimming pools.

25 It is also pertinent to note that, in qualitative terms, the Leisure Centre (in the northern sector) is the only modern, fully integrated ‘dry’ and ‘wet’ leisure centre in the borough. The Council’s strategy is to deliver more integrated public leisure centres to a specification that is consistent with Sport England guidance throughout the borough, in order to fulfil the need for improved quality and wider choice of such facilities for borough residents.

26 To summarise, an audit of existing facilities indicates an unmet quantitative need for additional leisure space in the central and southern sectors of the borough. In particular, there is a need for additional swimming pools and sports halls, equivalent to 2,484 sq.m. of swimming pool water space and 137 badminton courts in the centre. Whilst in the south, there is a need for 1,287sq.m of swimming pool water space, 23 badminton courts and 11 health and fitness stations. The 2006 update also showed that there is an oversupply of nearly 600 health and fitness stations in the centre of the borough; though 80% of health and fitness stations are in private membership.

27 The Waddon application site is within the area of relative deficiency and capable of accommodating a leisure centre to meet both the quantitative and qualitative needs of the locality.

Sequential test

28 The London Plan policy (3D.1) aims to encourage retail, leisure and other related uses in town centres and discourage them outside town centres. Policy 3D.6 requires borough councils considering proposals for sports facilities to ensure that: • A sequential approach is applied.

• Sites have good access by public transport, cycling and walking; or improved access is planned.

• Facilities are accessible to all sections of the community, including disabled people.

• New provision is focused on areas with existing deficiencies in facilities.

• The multiple-use of facilities is encouraged, including those of schools and commercial organisations.

29 With regard to the sequential test, the search for alternative sites was determined from the 2006 demand modelling study, the Council’s Leisure Centre Strategy for the central and southern areas of the borough, and the geographical area of greatest relative deficiency in leisure centre provision.

page 6 30 The town centres within that area were: Croydon metropolitan centre, Purley town centre, Brighton Road () centre, and the South Croydon local centre. To provide a robust assessment of the site requirements, due consideration was given to the reuse of existing buildings in town centre or edge-of-centre sites; and the design and formatting of a new building (including the stacking of various floors), thereby producing a significantly smaller footprint alongside an appropriate provision of parking, access and servicing space. The threshold for site selection could thus be reduced from the 0.63 ha proposed in the application, to a more flexible 0.4 ha on which the Thornton Heath facility has been provided.

31 From an initial total of 19 identified sites, 6 were eliminated on grounds that alternative development had effectively commenced or the proposed development would be contrary to policy; and a further 4 sites were discounted because planning permissions had been implemented were no longer available for development. The remaining 9 were assessed against the criteria set out in PPS6 and policy LR2 of the Croydon Plan- i.e. that sites should be suitable, viable and available.

32 The Waddon site emerged as the most favourable in meeting those criteria in addition to those identified in policy 3D.6 of the London Plan

Loss of community facilities

33 Policy 3A.18 of the London Plan relates to the protection and enhancement of social infrastructure and community facilities, such as schools, children’s play and recreational facilities, facilities for young people, sports and leisure facilities, open space, community halls and meeting rooms. The policy further aims to resist the net loss of such facilities, and to seek increased provision to meet population growth and existing deficiencies.

34 Policy 3A.24, relates specifically to education facilities. It requires councils to reflect the demand for pre-school, school and community-learning facilities in their development plan documents, and devise a criteria-based approach to the provision and expansion of different education facilities. In particular, land already in educational use should be safeguarded (para. 3.114) and new sites identified to meet additional demands.

35 The Waylands Day Centre was a special unit for adults with learning difficulties built in the 1960s, but now surplus to requirements due to a shift in policy from sheltered workshops and day care provision, to more individualised services provided in Community Resource Bases. The latter is an outreach programme with an emphasis on semi-independent living and the training of clients within their own homes and communities rather than day centres like the Waylands. As a consequence, the day centre was closed and later demolished.

36 The demolition and permanent loss of the Red Gates and Waddon Infant Schools is contrary to the above policies. There are, however, mitigating circumstances to justify the loss i.e.: that the buildings and premises of both schools were so outdated and unsuitable for current purposes that the Council was compelled to relocate the former to updated and extended buildings on the previously redundant premises of Gilbert Scott Infant School in September 2009; and the latter to extended and refurbished buildings on premises of the nearby Duppas Junior School, with which it is due to merge under the new name Aerodrome Primary School. Waddon Infant School is expected to close in December 2010, and the new school to open in January 2011. Thus, in both these instances, the Council proposals represent a relocation and rationalisation of school sites rather than an outright loss of educational institutions.

page 7 Loss of educational open space

37 The relevant policies on this are in PPG17 ‘Planning for open space, sport and recreation’ and the London Plan (policy 3D.11). PPG17 provides that existing open space, sports and recreational buildings and land should not be built on unless an assessment has been undertaken which has clearly shown the open space to be surplus to requirements. Policy 3D.11 requires borough DPDs to identify broad areas of public open space deficiency and the priorities for addressing them on the basis of audits carried out as part of an open space strategy, and to ensure that future open space needs are considered in planning policies.

38 The Red Gates School site provides 0.36 ha of hard-surfaced external space, including a car park and sensory garden, whilst Waddon Infant School provides 1.14 ha of open space comprising a grassed area, hard-surfaced playground and car parking area. None of these areas fall within the PPG17 definition of a ‘playing field’, have been delineated for sports as a ‘playing pitch’ (minimum 0.4 ha) or been accessible for use by the public.

39 As part of its application to the Department for Communities, Schools and Families (DCSF) to dispose of the two school sites, the Council carried out an assessment of the open space needs of primary schools within an 800 m radius of the Waddon site and secondary schools within 1.6 km radius. This assessment shows that technically there are no schools in the local area, which suffer a deficiency of playing fields. Two other schools, (Parish C of E and St Andrews Secondary School) were consulted on the possibility of using the existing open space, but declined the offer on grounds of distance, safe accessibility and the availability of alternative sites.

40 Nonetheless, as the application site lies partially within an area identified in the saved policies of the UDP as being deficient in Local Park facilities, there is an opportunity for the proposed development to go some way in addressing this deficit. Housing

41 The London Plan sets a target for Croydon Council to facilitate the delivery of 1,100 new homes a year over the ten-year period between 2007/8 and 2016/17. Policy 3A.2 and 3A.3 requires borough Councils to adopt DPD policies which aim to exceed the London Plan targets, identify new sources of housing supply and maximise the potential of sites to an extent which is compatible with local context, sound design principles and public transport capacity. The Mayor’s Consultation Draft Replacement London Plan increases the target for Croydon to 1,330 homes a year between 2011/12 and 2020/21.

42 The application proposes a total of 187 new homes in a predominantly flatted development that also includes 23 houses. Based on a net site area of 1.72 hectares, the housing would be provided at a density of 363 habitable rooms per hectare (108 dwellings per hectare). This is well within the indicative range (200-450 hr/ha or 55-145 u/ha) identified in the London Plan for a site in an urban setting with a public transport accessibility level of 3, although the site has accessibility level of up to 4 and the capacity for a higher density. Affordable housing

43 London Plan Policy 3A.10 requires borough councils to seek the maximum reasonable amount of affordable housing when negotiating on individual private residential and mix-use schemes. In doing so, each council should have regard to its own overall target for the amount of affordable housing provision. Policy 3A.9 states that such targets should be based on an assessment of regional and local housing need and a realistic assessment of supply, and should take account of the London Plan strategic target that 35% of housing should be social and 15% intermediate provision, and of the promotion of mixed and balanced communities. In addition,

page 8 Policy 3A.10 encourages councils to have regard to the need to encourage rather than restrain residential development, and to the individual circumstances of the site. Targets should be applied flexibly, taking account of individual site costs, the availability of public subsidy and other scheme requirements.

44 Policy 3A.10 is supported by paragraph 3.52, which urges borough councils to take account of economic viability when estimating the appropriate amount of affordable provision. The ‘Three Dragons’ development control toolkit is recommended for this purpose. The results of a toolkit appraisal might need to be independently verified.

45 Policy 3.13 of the draft replacement London Plan establishes the approach to negotiating affordable housing on site, and states that: “The maximum reasonable amount of affordable housing should be sought when negotiating on individual private residential and mixed use schemes” taking account of a range of factors including local and regional requirements, the need to encourage rather than restrain development, and viability.

46 Policy H13 of Croydon Council’s Replacement UDP 2006 (Saved Policies) sets a target of 50% affordable housing on sites with a capacity of 30 or more residential units, and within that a ratio of 70% to 30% social rented to intermediate accommodation. Policy 3.12 of the Consultation Draft Replacement London Plan proposes a split of 60% social rented and 40% intermediate within the affordable housing offer.

47 A full breakdown of the proposed accommodation is provided in the table below:

Type Affordable housing Market housing Total Mix (%) social rented intermediate - - - units hab.rms units hab.rms units hab.rms units hab.rms units hab.rms 1 bed 12 24 16 28 25 50 53 102 28.4 16.4 2 bed 11 33 14 48 56 168 81 249 43.3 39.8 3 bed 13 58 0 0 17 78 30 136 16.0 21.8 4 bed 21 126 0 0 2 12 23 138 12.3 22.0 Total 57 241 30 76 100 308 187 625 100 100 %Tenure 30.5 38.6 16.0 12.2 53.5 49.2 100 100 - -

48 The Waddon site development proposes approximately 51% affordable housing by habitable room, within which there would be a split of 76% social rented and 24% intermediate accommodation. These fulfil the strategic aspirations of the London Plan and are therefore acceptable.

49 In terms of unit mix, the Mayor’s Housing SPG sets a London-wide requirement for 30% four-bedroom dwellings, 38% two to three-bedroom dwellings and 32% one-bedroom dwellings. The consultation draft London Housing Strategy sets a further aim of securing 42% of social rented and, by 2011, 16% of intermediate housing as three or more bedroom units.

50 Calculated by units, the application proposals provide 12.3% four-bed dwellings, approximately 59.3% two and three-bedroom dwellings, and 28.4% one-bedroom dwellings across all tenures. Within the affordable housing, however, 34% of social rented units would be three or more bedroom units. None of the intermediate housing would be large units of three or more bedrooms. On balance, the mix is considered acceptable, given that a reasonably large proportion (almost 44%) of the habitable rooms would be provided in three or four-bedroom dwellings.

page 9 51 With regard to room and unit sizes, a comparison between the specified unit areas for each dwelling type indicates that in all cases, the affordable housing units would exceed the minimum space standards provided in the Mayor’s Consultation Draft Replacement London Plan. The lower ends of the range for some market housing types were, however, marginally below the essential gross internal areas specified in the emerging plan. Children’s play space

52 Policy 3D.13 of the London Plan sets out that “the Mayor will and the boroughs should ensure developments that include housing make provision for play and informal recreation, based on the expected child population generated by the scheme and an assessment of future needs.” Using the methodology within the Mayor’s supplementary planning guidance ‘Providing for Children and Young People’s Play and Informal Recreation’ it is anticipated that there will be approximately 145 children within the development. The guidance sets a benchmark of 10 sq.m. of useable child playspace to be provided per child, with under-5 child playspace provided on-site. As such the development should make provision for 1,450 sq.m. of playspace.

53 This development provides 0.5 hectares of green space on site, of which 804 sq.m. is specifically designated for children’s play. A 400 sq.m. local equipped area for play of is provided within the public courtyard adjoining block B, and a 100 sq.m. local area for play in the public courtyard adjacent to block C. In addition, linear areas for imaginative play amounting to 300 sq.m. would be included within the public and communal courtyards.

54 The Waddon site is within 750 metres (actual walking distance rather than straight line measurement) of Duppas Hill Park and some 940 metres from the recently refurbished Purley Way playing fields. Both are neighbourhood equipped areas of play, each with 8-10 items of play equipment for children aged 2- 12 .The former provides 5 football pitches and a ball court; the latter provides 27 football pitches, a skate park and ancillary facilities, including changing rooms and toilets.

55 The overall provision is considered adequate to meet the requirements of strategic policy and the Mayor’s SPG. Urban design and architectural quality

56 Good design is central to all objectives of the London Plan and is specifically promoted by the policies contained within Chapter 4B which address both general design principles and specific design issues. London Plan Policy 4B.1 sets out a series of overarching design principles for development in London. Other design polices in this chapter and elsewhere in the London Plan include specific design requirements relating to maximising the potential of sites, the quality of new housing provision, tall and large-scale buildings, built heritage, views, and the Blue Ribbon Network.

Rationale

57 The applicant has undertaken a detailed assessment of the sites context and the surrounding environment, which has in turn informed the proposed building arrangements, uses, massing and heights of the buildings and spaces, which is welcomed.

Leisure Centre

58 The location of the leisure centre is supported along with the ambition to create a recognisable community building on the corner with Five Way Junction. At pre-application meetings a number of concerns in relation to the arrangement and design of the building were

page 10 identified, however, the applicant has since made a number of amendments to the scheme to address these concerns.

59 The proposed leisure building now incorporates a number of amendments, which are welcomed, in particular:

• The internal arrangement of the leisure centre achieves a high quality and accessible community space.

• The size and landscaping of the civic space in front of the building relates well to both the proposed use and the busy nature of the Five Ways Junction.

• The location of internal uses within the leisure building encourages overlooking of public spaces, namely the location of the fitness studios, café, pool, office space, however, further information is required to demonstrate that materials and glazing can be incorporated that allow interaction and a visual connection with the street.

• The elevations and material choice could add a level of interest to this area albeit the detailed design of these materials and colours will be significant in their success.

• The building design ensures that sites to the north and south retain future development opportunities.

60 To the rear of the leisure centre, the applicant proposes a new dog-walking area. Whilst the provision of a dog-walking exercise area is supported, the location at the rear of the building appears removed from the wider area. There is a concern that, given the surrounding uses and the poor level of surveillance over this space, it may become an unused area where anti-social behaviour is encouraged. Further management and design detail should be provided with the submitted application.

Permeability

61 The applicant has examined the potential to provide a connection to Coldharbour Road via the PCT building, which is supported. It is understood that this is outside the red line boundary of the site and as such is beyond the scope of what the applicant may be able to deliver at this stage. However, the detailed layout of the site and the in particular the leisure centre does not preclude the introduction of such a connection in the future, should the PCT building be redeveloped, which is acceptable.

Residential component

62 The approach taken for the residential building arrangements, including the heights, the massing as well as the location of the open spaces is broadly supported.

63 The residential element includes two U-shaped, courtyard blocks with central amenity spaces, which include the apartments and duplex units and are located on the Purley Way side of the site. The terraced houses are then located on the eastern, quieter side of the site and front onto a more traditional street. Since the pre-application meetings, the applicant has made a number of amendments to the terraced houses, which have simplified the building treatment. In addition, the treatment of the ‘courtyard’ residential blocks has a clear pattern and design treatment. The location and treatment of the residential buildings is supported.

64 Along Purley Way the residential buildings are predominately five storeys with two taller elements set at six and seven storeys. These taller elements help to mark key routes into the site and provide a level of visual interest along the Purley Way route. Building heights reduce to

page 11 between three and five storeys as you move east across the site towards the more suburban residential estates, with the proposed terraced housing at three-storeys backing onto existing suburban houses. The proposed building heights and the location of taller buildings are acceptable.

View from Five Ways Junction looking towards tallest seven-storey residential building

65 There is a clear attempt to minimise the number of single aspect units and to provide larger units for residents, which is welcomed. The proposed sizes of the affordable housing units and the larger two and three bed private units compare favourably with the space standards set out in the Consultation Draft Replacement London Plan table 3.3. However, the one-bed private units are smaller than these identified space standards.

Residential open spaces

66 The applicant has provided additional information on the detailed design of the open spaces, play spaces and in particular the courtyards at the base of the two U-shaped residential blocks. The design approach for the proposed open spaces is supported.

The education centre

67 Outline consent is sought for the education centre. The proposed approach is broadly supported. The design approach seeks to provide a strong building line to the new street. The height of the building is broadly consistent with the existing and proposed heights in the surrounding area. The applicant is seeking to retain the existing trees on site and to make features of these where possible. This is welcomed.

68 The applicant has now given due consideration to the size of school required, has demonstrated the quantum of space needed based on child needs and this level of space has been provided for on-site, which is supported. Inclusive design/access

page 12 69 The commitment to designing the access and facilities for disabled people in the leisure facility over and above the minimum requirements of the building regulations is welcomed. The provision of two large (3m by 2.5m) passenger lifts to the upper level sports hall, which can accommodate sports wheelchairs, is welcomed, as is the provision of a ‘Changing Places’ toilet facility demonstrating that the needs of diverse users have been considered and will be catered for. The plan also shows that consideration is being given to how people who find stairs difficult to negotiate can use the swimming pool independently and with dignity, by the installation of a self operating platform lift rather than having to depend on staff to operate a hoist.

70 The commitment to meeting Lifetime Home Standards and the provision of at least 10% of homes that can be occupied by a wheelchair user is also welcomed. However, the applicant must provide a detailed plan demonstrating the location of the 10% wheelchair accessible rooms and must also set out how each of the 16 Lifetime Homes standards are being addressed. This information does not seem to have been provided as part of the submitted application. These measures should then be secured by an appropriate planning condition.

71 The applicant has now provided additional detail on the design of the public realm, which demonstrates that the public spaces will ensure easy and convenient access and movement for all disabled people. However, the applicant should provide additional detail on the design and quality of the public realm in the wider area, in particular providing detail on road crossing points and the quality of bus stops in the surrounding area. Transport for London’s comments

72 Despite TfL’s pre-application advice, the outline application has retained the same residential parking ratio, equivalent to 0.6 spaces per unit, which is disappointing. Whilst this level of parking provision may be acceptable in policy terms, as it is within the London Plan maximum, these sections of the A23 and A232, and the Fiveways junction in particular, already suffer from significant levels of congestion. As such, TfL strongly re-iterates its previous request to reduce this ratio further, in order to keep the potential impact on the Transport for London Road Network to a minimum. TfL would also be looking to minimise the amount of car parking provided on site for all other land uses on site for the same reason.

73 TfL welcomes the ‘car park management plan’ and the mechanisms suggested to help manage parking, and recommends it to be secured by condition in accordance with the London Plan policy 3C.23 ‘Parking Strategy’ and the consultation draft replacement London Plan policy 6.13 ‘parking’. The applicant should also provide charging points for electric vehicles in line with the Mayor's essential standard, as set out in the ‘Electric Vehicle Delivery Plan for London’ (May 2009), and policy 6.13 of the consultation draft replacement London Plan.

74 As further detailed in TfL’s letter, concerns still remain regarding the proposed access arrangements for the site. The proposed southern access on Purley Way raises significant safety issues, which need to be addressed. TfL therefore requires a road safety audit to be undertaken before the application is determined, and secured by condition. The subsequent narrowing of the southbound traffic lane on the A23 by 1 metre to only 3 metres is unacceptable to TfL, particularly in terms of the potential impact on cyclists. As such, TfL would request that a minimum lane width of 4 metres be incorporated into the design to accord with policy 3C.16 ‘Road scheme proposals’ of the London Plan and draft revised London Plan policy 6.12 ‘Road network capacity’.

75 Clarification on a number of points related to the modal split methodology, traffic growth assumptions and validity of modelling exercise for the proposed new pedestrian crossing on Purley Way and the Fiveways junction, as further detailed in TfL’s letter, is also required before any likely impact on the TLRN and public transport network can be fully determined by TfL.

page 13 76 Serious concerns exist over the potential impacts of the development on the Fiveways junction in relation to the proposed signalised pedestrian crossing on Purley Way, and TfL would therefore require these to be mitigated. A “Provisional Scheme” notification is recommended for submission to TfL’s Network Assurance Team to begin the required process as early as possible, in order to overcome any design difficulties arising in the near future.

77 Given the number of additional bus trips the development is expected to generate, it is considered unlikely that it will have a negative impact on the bus network. However, as part of the application, it is proposed to relocate bus stops on both Denning Avenue and Purley Way. While TfL has no objections to this ‘in principle’, some concerns however remain, as further detailed in TfL’s letter, and should therefore be appropriately addressed to accord with the London Plan policy 3C.20 ‘Improving conditions for buses’’ and draft revised London Plan policy 6.7 ‘buses, bus transits, trams’. As stated at the pre-application stage, TfL requires both of the relocated stops to be fully compliant with TfL’s current accessibility standards, and any required upgrades to be funded by the developer. Alongside this, TfL has identified other bus stop accessibility improvements required within the vicinity of the site, and for which an additional £19,000 contribution should be secured.

78 As requested at the pre-application stage a pedestrian audits (PERS) of the site and surrounding area has been undertaken, which is welcomed. However, in accordance with the London Plan policy 3C.21 ‘Improving conditions for walking’ and draft revised London Plan policy 6.10 ‘Walking’, TfL would expect the conclusion to include suggested measures to improve the environment for pedestrians. Given that legibility for pedestrians with sensory impairments also scored poorly, TfL would also recommend that a financial contribution is secured towards installing the correct tactile paving and rotating cones at all crossings in the audit area, along with funding any identified areas for improvement on the local borough roads. While the soft landscaping and extension of the public realm along the western edge of the site are supported, those should be shown on any drawings and plans for this strip of land clarified.

79 Cycle parking is proposed for all land uses in accordance with TfL’s cycle parking standards, which is welcomed- although clarification on the exact number of spaces to be provided is still required. All cycle-parking spaces are expected to be provided in a secure and well lit location with showering and changing facilities also recommended for staff cycling to the leisure centre and child services centre, in accordance with the London Plan policy 3C.22 ‘Improving conditions for cycling’ and draft revised London Plan policy 6.9 ‘Cycling’.

80 Whilst the submitted travel plan is generally of a good standard, additional information is needed. An action plan should be provided with timescales for the appointment of each of the travel plan coordinators, and the monitoring programme should include iTRACE-compliant surveys for staff and TRAVL surveys for the whole site.

81 In accordance with the London Plan policy 3C.25 ‘Freight Strategy’ and draft replacement London Plan policy 6.14 ‘Freight’ a Construction Logistics Plan (CLP), and a Delivery and Servicing Plan (DSP), should be secured for the site by condition. Further information on what these plans should contain is included in TfL’s letter.

82 In conclusion, while initial assessment would suggest that the development is unlikely to impact on the capacity of the public transport network, additional information is required before TfL can accurately determine all of the potential impacts of the development, particularly on the strategic highway network, and confirm that the proposals are in general compliance with the London Plan policies 3C.16, 3C.20, 3C.21, 3C.22, 3C.23, 3C.25 and the consultation draft replacement London Plan policies 6.7, 6.9, 6.10, 6.12, 6.13 and 6.14.

page 14 83 The developers and their representatives are reminded that a grant of planning permission, does not discharge the requirements under the Traffic Management Act 2004. Formal notifications and approval may be needed for both the permanent highway scheme and any temporary highway works required during the construction phase of the development. Climate change mitigation

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

Energy

85 Policies 4A.1 to 4A.8 of the London Plan focus on how to mitigate climate change, and the carbon dioxide reduction targets that are necessary across London to achieve it.

Be Lean

(Policy 4A.3) Energy efficiency standards

86 The proposals include qualitative descriptions and quantitative values of the energy efficiency measures that would be adopted. The measures described include improved insulation values, and improved air-tightness standards, together with mechanical and heat-recovery ventilation systems in some of the residential units. The combined effect of the energy efficiency measures is estimated to be a 5% reduction against the baseline emissions.

87 The measures proposed are welcomed, but further information is required to understand whether further reduction in the demand for energy could be achieved. For instance, the lighting energy requirements of the base case and the energy efficient scenario are very similar.

88 Additionally, the energy assessment should also set out a strategy of how non-regulated energy and carbon dioxide emissions will be reduced through the use of energy efficient appliances and equipment, controls, good management practice, etc.

Be Clean

(Policies 4A.5 and 4A.6) District heating policies

89 The applicant has acknowledged the plans for future district heating networks within the vicinity of the proposed Waddon development. Hence, and in order to support the potential future growth of any heat networks within Croydon, it is proposed that enough space will be allocated within the Waddon development to install a suitable interface to connect to a district heating network.

90 A communal/district heating network is planned for the development and this is welcomed. As in the current proposals the communal heat network would supply all elements of the scheme (domestic and non-domestic) with space heating and domestic hot water and it would be supplied with heat generating plant installed in a central energy centre located on the ground floor of the Leisure centre.

page 15 91 In addition, the applicant has concluded that there is a Health Centre (PCT) just outside the site boundary, which once its boiler plant has reached the end of its life, could benefit from connecting to the proposed communal heat network for the Waddon development.

Combined heat and power

92 A circa 220 kWe combined heat and power (CHP) unit with thermal storage will be installed in the energy centre, supplying around 51% of the heat requirements and reducing emissions by a further 26%.

93 The applicant should provide indicative drawings to demonstrate that enough space has been allocated for a sufficiently large energy centre and that allows for the installation of all the required heat generating plant, including CHP unit, top-up boilers, thermal store, etc.

Cooling

94 The energy strategy should provide further information in relation to the potential risk of overheating. The use of external shading devices and/or other suitable strategies should be maximised in order to reduce the risk of overheating as far as possible, and further detail should be provided as to the type of devices and how they will be integrated into the design of the buildings.

95 Where a demand for cooling still exists, the applicant should clarify how this would be provided.

Be Green

96 The applicant has considered a range of renewable technologies. There is limited technical potential for renewables due to identified site constraints e.g. lack of wind speed. However, the energy strategy proposes the installation of 293 sq.m. of photovoltaic (PV) panels reducing emissions by a further 1.6%. Including the savings from renewables, the development should provide a combined reduction of 27.7% in carbon emissions over the baseline.

Summary

97 The applicant has applied the energy hierarchy in Policy 4A.1. The proposals are considered acceptable, subject to further clarification. Climate change adaptation

98 Developments are required to be adaptable to the climate they will face over their lifetime and address the five principles set out in policy 4A.9 of the London Plan. These are: to minimise overheating and contribution to heat island effects; minimise solar gain in summer; contribute to flood risk reductions, including the application of sustainable drainage principles; minimise water use; and protect and enhance green infrastructure. Specific policies cover overheating, living roofs and walls, and water conservation.

99 Chapter 5 of the consultation draft replacement London Plan also considers climate change adaptation, specifically in policies 5.9 through to policy 5.15.

Flood risk

100 The nearest surface water features are the Waddon Ponds, which lie approximately 500m north of the site and the , some 800m further north-west. The site is located in Flood Zone 1 on the Indicative Floodplain Map produced by the Environment Agency and has a low

page 16 probability (less than 1 in 1000) of flooding. A Flood Risk Assessment is nonetheless required, given that the site exceeds the 1hectare threshold stated in PPS24. This has not been submitted with the application and should be provided.

Surface water run-off

101 Run-off from the site from construction wastewater, large parking areas and the cumulative impacts of the development, have the potential to contaminate and change surface water quality and overload the recipient sewers, thereby increasing the flood risk in other locations.

102 It is proposed that implementation of best practice measures during construction would minimise the risk of contaminated run-off into the drainage system. A detailed assessment of the foul and surface water flows is also proposed to ensure that diversions of existing sewers are designed and phased appropriately; and a planned drainage strategy would reduce flood risk once the development is completed.

103 Porous paving finishes would be used extensively throughout the development to reduce surface water discharge rates. The latter would be controlled further by surface water attenuation to limit the maximum surface water discharge rate.

Water use and conservation

104 In addition to internal water control measures within each of the facilities on site, external water use will be reduced through the provision of water butts to the perimeter housing and rainwater collection from the flats. Ambient noise

105 Areas of the proposed development (i.e. residential units fronting onto Purley Way) fall within noise exposure category C as defined by PPG 24 and in which, national guidance is that planning permission should not normally be granted. However, the guidance states that where it is considered that planning permission should be given e.g. because there are no alternative, quieter sites available, planning conditions should be imposed to ensure a commensurate level of protection against noise.

106 Although it is not unusual to permit development in London in such cases, London Plan policy 4A.20 requires that noise-sensitive developments should be separated from major sources of noise wherever practicable. The preferred remedy is for habitable rooms to be placed on quieter facades, or where this is not possible, for sound insulation to be incorporated within the development.

107 Given the London Plan policy, it would be strongly preferable to avoid placing noise- sensitive habitable rooms on the noisiest facades and further consideration should be given to how this could be achieved. It is essential that to enable this, an acoustic study be undertaken in accordance with PPG 24, to determine how road traffic noise will impact the residential elements of the development and to propose appropriate mitigation before consent is granted. This is in line with the Mayor’s Ambient Noise Strategy.

108 Irrespective of the above, where external noise levels are such that windows need to be kept closed to achieve acceptable internal noise levels, some form of acoustically attenuating ventilation needs to be provided as an alternative to opening the windows. This should enable a positive flow of air – ideally using a system such as a passive stack, rather than energy consuming mechanical ventilation. Suitable glazing and ventilation should be required by condition.

page 17 109 Demolition and construction noise and vibration cannot be predicted in detail at this stage of the planning process, but given the scale of the development and the proximity of sensitive receptors could at times cause adverse impacts without mitigation.

110 A range of measures is likely to be required to address both construction noise and vibration impacts. Croydon Council has powers under the Control of Pollution Act to agree or impose limits on the hours of work and noise and vibration levels. It should be possible, with these measures, to reduce the impacts to acceptable levels. Air quality

111 Given its location along the busy A23 Purley Way, the site may be subject to high levels of air pollution from traffic. The relevant policy to address this is London Plan policy 4A.19, which aims to promote sustainable design and construction, and to ensure that, at the planning application stage, air quality is taken into account along with other material considerations.

112 The borough of Croydon is an Air Quality Management Zone. The key areas of concern arising from this proposal are: dust nuisance from demolition and construction activities, and the impact on local residents of introducing gas-fired CHP and of traffic generated by the proposed development. Whilst measures are proposed to mitigate the impact of demolition and construction, a more robust response is required in respect of the gas-fired CHP and traffic if these proposals are to be referred back to the Mayor. Local planning authority’s position

113 It could not be ascertained at the time of writing when this application would be reported to the Croydon Council planning committee, or what the officers’ recommendation would be. Legal considerations

114 Under the arrangements set out in Article 4 of the Town and Country Planning (Mayor of London) Order 2008 the Mayor is required to provide the local planning authority with a statement setting out whether he considers that the application complies with the London Plan, and his reasons for taking that view. Unless notified otherwise by the Mayor, the Council must consult the Mayor again under Article 5 of the Order if it subsequently resolves to make a draft decision on the application, in order that the Mayor may decide whether to allow the draft decision to proceed unchanged, or direct the Council under Article 6 of the Order to refuse the application, or issue a direction under Article 7 of the Order that he is to act as the local planning authority for the purpose of determining the application and any connected application. There is no obligation at this present stage for the Mayor to indicate his intentions regarding a possible direction, and no such decision should be inferred from the Mayor’s statement and comments. Financial considerations

115 There are no financial considerations at this stage. Conclusion

116 London Plan policies on out-of-centre leisure facilities, education facilities, housing, architectural quality, inclusive design, children’s play space, transport, energy, climate change, noise and air quality are relevant to this application. Whilst the application is broadly acceptable in strategic planning terms, it complies with some policies but not with others, for the following reasons:

page 18 • Transport: TfL has identified various areas of non-compliance in paragraphs 72 to 82 of this report, and the London Plan policies to which they relate.

• Energy: Whilst the energy hierarchy has been applied, additional details and clarification is required to ensure full compliance with policies 4A.1 to 4A.8 of the London Plan.

• Noise: Measures to mitigate the impact of traffic noise on residents have not been adequately specified or secured by condition to ensure full compliance with the objectives of policy 4A.20 of the London Plan.

• Air quality: The impact on local air quality from the proposed gas-fired CHP and additional traffic generated by the development, have not been adequately addressed to satisfy the requirements of policy 4A.19 of the London Plan.

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

• Transport: Secure the car and cycle parking, sustainability, road safety, bus infrastructure and other improvements specified in paragraphs 72-82 of this report, together with the additional information and financial contributions sought to fulfil the requirements of London Plan (policies 3C.16, 3C.20, 3C.21, 3C.22, 3C.23, 3C.25) and the consultation draft replacement London Plan (policies 6.7, 6.9, 6.10, 6.12, 6.13 and 6.14) • Energy: Provide the additional information required in paragraphs 86 to 95 of this report and confirm the applicant’s acceptance of the GLA officers’ draft planning conditions proposed to ensure compliance with the energy policies of the London Plan. • Noise: Specify the design and other noise attenuation measures required to fulfil the aims of London Plan policy 4A.20, which the Council should secure by appropriate planning condition (s). • Air quality: Provide a more robust response to the air quality implications of the gas-fired CHP plant and additional road traffic, to fulfil the requirements of London Plan policy 4A.19, as indicated in paragraphs 111 and 112 of this report.

for further information, contact Planning Decisions Unit: Colin Wilson, Senior Manager - Planning Decisions 020 7983 4783 email [email protected] Justin Carr, Strategic Planning Manager (Development Decisions) 020 7983 4895 email [email protected] David Blankson-Hemans, Senior Strategic Planner (Case Officer) 020 7983 4268 email [email protected]

page 19