Car Park & Adjoining Land, Lion Green Rd, Coulsdon

planning report D&P/3098/02 7 May 2014 Car Park & adjoining land, Lion Green Rd, Coulsdon in the London Borough of Croydon planning application no. 13/02178/P

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

The proposal Demolition of existing buildings; erection of a building comprising a 4,679 sq.m. (GIA) supermarket, 932 sq.m. health facility and new storage building (for the existing scout hall); formation of vehicular access, provision of 213 car parking spaces and associated landscaping. The applicant The applicant is Croydon Urban Regeneration Vehicle (CCURV), the agent is Indigo Planning Ltd and the architect is EPR Architects Ltd.

Strategic issues At the consultation stage, Croydon Council was advised that the application is broadly acceptable in strategic planning terms, subject to the resolution of issues relating to retail/town centre use, historic environment, inclusive access, sustainable development, and transport, which have now been satisfactorily addressed.

The Council’s decision In this instance, Croydon Council has resolved to grant planning permission, subject to conditions. Recommendation That Croydon Council be advised that the Mayor is content for it to determine the case itself, subject to any action that the Secretary of State may take, and does not therefore wish to direct refusal or direct that he is to be the local planning authority.

Context

 3F “Development for a use, other than residential use, which includes the provision of more than 200 car parking spaces in connection with that use”.

2 On 28 August 2013, the Mayor considered planning report D&P/3098/01, and subsequently advised Croydon Council that the application is broadly acceptable in strategic planning terms, subject to the resolution of the issues set in paragraph 67 of that report.

3 A copy of the above-mentioned report is attached. The essentials of the case with regard to the proposal, the site, case history, strategic planning issues and relevant policies and guidance are as set out therein, unless otherwise stated in this report. Since then, the application has been revised in response to the Mayor’s concerns (see below) and further information provided. On 3 April 2014, Croydon Council decided that it was minded to grant planning permission, subject to conditions, for the revised application, and on 24 April 2014 it advised the Mayor of this decision. Under the provisions of Article 5 of the Town & Country Planning (Mayor of London) Order 2008, the Mayor may allow the draft decision to proceed unchanged, or direct Croydon Council under Article 6 to refuse the application. The Mayor has until 7 May 2014 to notify the Council of his decision and to issue any direction.

4 The decision on this case, and the reasons will be made available on the GLA’s website www.london.gov.uk.

Update

5 At the consultation stage, Croydon Council was advised that the application is broadly acceptable in strategic planning terms, subject to the resolution of the issues set out in paragraph 67 of the above-mentioned report:

 Retail/town centre use: The principle of the development does not present any strategic planning issues, although further information is required on the impact of the scheme on other investments in the catchment area and the impact on comparison goods retailers in the Coulsdon Primary Shopping Area.  Historic environment: Evidence of English Heritage agreement with the proposals is required before it can be determined if the proposal complies with London Plan policy.  Inclusive access: The proposals are supported in principle although further information is required on parking arrangements and shared surface segregation.  Sustainable development: It cannot yet be determined if the proposal complies with London Plan Policy 5.2. The applicant should provide further energy efficiency modelling information; further information on future connection to a district heating network; and further information on the proposed energy centre. The use of the large flat roof for climate change adaptation should also be considered.  Transport: The application does not accord with London Plan Policies 6.1, 6.3, 6.12 and 6.13. The Transport Assessment should be revised to only include the most comparable sites and further analysis of highway impacts, including revised modelling, is required. Appropriate mitigation measures may be required following this analysis. The Travel Plan should be revised to include positive travel planning measures for customers of the supermarket and should be secured, monitored and enforced through a section 106 agreement. A Construction Logistics Plan (CLP), Car Park Management Plan and a Delivery and Servicing Plan (DSP) should be secured by condition and approved prior to commencement of the development.

6 Since the Mayor made these initial representations, additional information has been provided and the application revised. An updated assessment against the issues raised previously is provided under the corresponding headings below.

Coulsdon Masterplan

7 In September 2012, Croydon Council adopted the Coulsdon Masterplan as interim planning guidance. Following adoption, the Coulsdon Masterplan was subject to a legal challenge and has subsequently been withdrawn. Therefore, the document is not relevant to the determination of the application; however this does not affect the conclusions of either the Council’s Committee Report, the Stage One Report or this Report. Principle of development - Retail/town centre use

8 The Stage One report identified that the applicant’s Retail Statement adequately analyses the limited impact of the scheme on other town and local centres; however, more information was requested on the impact of the proposal on existing, committed and planned public and private investment in Coulsdon. The Stage One report also requested further analysis of the effect on comparison goods retailers in Coulsdon town centre.

9 In response, the applicant has provided a detailed analysis on the impact of the proposed development on the Red Lion public house site; the 127 Brighton Road (Pinewood Motors) site; the land adjoining East Croydon Station site (outside Coulsdon); as well as the impact on comparison goods retailing within Coulsdon town centre. The analysis concludes that the proposal would not have significant adverse impacts on either the viability or vitality of Coulsdon town centre or pipeline schemes. This is accepted and the proposals now comply with London Plan policy in this respect.

Historic environment

10 The site is adjacent to an earth embankment that once formed part of the Surrey Iron Railway and is a Scheduled Ancient Monument (SAM). The applicant provided a Historic Environment Assessment, which concludes that the proposal will have negligible impacts on underground heritage assets and significant benefits to the visibility and appreciation of the SAM. As requested at Stage One, the applicant has provided evidence of meetings and correspondence with English Heritage confirming that it is satisfied with the proposals. Detail of the landscape works and development affecting the heritage assets have been secured by condition. The proposals now comply with London Plan policies on the historic environment. Inclusive access

11 Fourteen blue badge parking bays have been provided for the foodstore element adjacent to the lifts, in line with London Plan Policy 6.13 ‘Parking’ and Table 6.2. As requested at Stage One, the applicant has confirmed that the car park layout is designed so that if additional adaptable spaces are required, they can be easily accommodated within the existing layout.

12 The applicant has also provided further information on the layout of the new access road, including two parking bays, in front of the health centre. At the junction with Lion Green Road, flush kerbs are proposed in order to allow for the smooth transition of the pedestrian crossing point. The use of granite upstand kerbs, granite flush kerbs, bollard protection areas and pedestrian access routes will ensure that the area is safe, usable and navigable for disabled people and the proposals now meet London Plan accessibility requirements.

Sustainable development

Energy

13 As requested at Stage One, the applicant has provided a BRUKL output document from the modelling undertaken, which supports the claimed level of savings from energy efficiency in the energy assessment.

14 The applicant has also confirmed that the development is designed to allow both the retail store and the healthcare facility to connect to a district heating network should one become available.

15 At Stage One, the applicant was requested to investigate serving both the retail store and the health centre from a single energy centre. However, as all building uses are adjacent to Lion Green Road, it is accepted that a single energy centre will not facilitate connection to a district heating network any more than separate plant rooms.

16 As the energy efficiency saving figures have been evidenced by modelling and the results accepted, the proposal now comply with London Plan energy requirements.

Climate change adaptation

17 As requested at Stage One, surface water management measures have been secured by planning condition.

18 The Stage One report suggested that the large expanse of flat roof over the supermarket retail area presents opportunities for skylights to further reduce the need for artificial lighting, and for green or brown roofs. In response, the applicant has amended the application drawings to extend the green roof by 10%, to increase its overall size to approximately 1,400 sq.m., which is welcomed.

19 However, the applicant states that it is not possible to include fixed skylights as this will reduce the flexibility of internal space planning as internal arrangements would be dictated by the position of skylights and Waitrose has specified a full suspended ceiling to the sales area in order to raise the ambience and environment for customers. This is accepted and the applicant also points out that the Lion Green Road elevation to the travelator area includes extensive vertical glazing and the back-of- house warehouse and staff accommodation areas are provided with roof lights, which is welcomed.

Transport

20 At Stage One, TfL requested further details and conformation in respect of Electric Vehicle Charging Points (EVCP’s), cycle parking, a Car Park Management Strategy, a Construction Logistics Plan, a Delivery and Servicing Plan and a Travel Plan. Importantly, further work was requested on highway modelling and mitigation measures, and TfL’s role in the section 106/ section 278 works. These have all been agreed and have been secured by condition or obligation.

21 Further information was submitted to address concerns regarding trip generation, highways impact and modelling, and has been reviewed by TfL. This further work is acceptable and details regarding the site vehicular access have been secured by condition.

22 TfL has considered the cumulative impact of local developments on the highway network, and requested mitigation measures to address these impacts. An improvement scheme at the Lion Green Road/Chipstead Valley Road junction has been developed that would mitigate the impact of the additional traffic generated, and this is considered acceptable to TfL. This has been secured by condition and will be delivered prior to the store opening through an appropriate highway agreement with the Council. It should be noted that VISSIM modelling will be required for the detailed approvals for both the site access and the junction improvements.

We request that the Council consult with TfL on the detailed design and approval of these works.

23 The estimated Mayoral CIL payment is £123,429.29, and this has been agreed by the applicant and the Council. The payment should be finalised in accordance with the implemented floor space figures.

24 TfL is now satisfied that the application is in accordance with the transport policies of the London Plan subject to the above.

Response from statutory bodies and other organisations

25 The Environment Agency made no objection to the scheme, subject to appropriate conditions.

26 English Heritage stated that the proposals are considered to have a neutral impact on the setting of the SAM and recommended a condition for archaeological investigation work to be undertaken prior to work starting on site.

27 Natural England made no objection.

28 Reigate & Banstead Borough Council objected on highway grounds and net loss of long stay car parking.

29 Tandridge Borough Council objected to the scheme on highway grounds.

30 Surrey Council County Council stated that the County Highway Authority (CHA) has assessed the impact of the proposal on highways in Surrey and concluded that the impact of the proposal is acceptable.

31 Thames Water made no objection to the scheme subject to conditions.

Response to public consultation

32 The application was publicised by way of eight site notices displayed in the vicinity of the application site. In response, 424 representations were received, 401 objecting, twelve supporting, and eleven commenting. In addition, three petitions were received, one with 944 signatories (objecting); one with 257 signatories, including 80 detailed comments (objecting); and one with 53 signatories (objecting) and one with 44 signatories from local businesses, including 30 objecting, 8 in support and 6 with no view. Ten objections were received from local groups. Crispin Blunt, the MP for Reigate also made representations objecting.

33 The following issues were raised in objection:

 Increased traffic congestion - junctions are already at capacity.  Transport Assessment fails to adequately address all issues, including cumulative impact and modelling is flawed.  Objection to access from Cane Hill site onto Portnalls Road.  Would worsen rat running situation.  Increased traffic near to schools.  Amendments do not address the issues of parking and traffic. The mitigation measures are very limited.  Transport Assessment is flawed, out of date and deficient.  Southern access on Cane Hill is necessary in traffic terms.

 No access onto Portnalls Road for Cane Hill development.  Car park should be a Community Asset.  Waste of money for by pass - as Coulsdon will be congested.  Junction improvements - full assessment needs to undertaken and other possibilities looked at.  More data and details on pedestrian crossing should be submitted.  Scheme made worse for pedestrians.  TfL have been ignored.  Together with Cane Hill there will be a chaotic situation in Coulsdon.  Should provide more car parking.  Inadequate parking for users, commuters, and people using the high street and no staff parking.  No provision for coach parking, recycling parking, parent & child spaces.  Local businesses use car park - no parking for local workers.  Local people use as commuter parking.  Car park used for other community uses - such as coaches.  Will be no parking for school times.  Displaced commuter parking on surrounding roads.  Lack of parking during construction.  Coulsdon will have no public parking.  Supermarket floor area must be reduced - local shops will be affected and be in competition with town centre.  The closure of Waitrose could have a detrimental impact on town centre.  Town will be in danger of dying.  Lack of a sequential test.  Better location for a supermarket in town centre.  Inadequate provision for the disabled at health centre.  Noise and disturbance.  Loss of recycling facilities.  How will the well be secured.  No detail on health facility.  Loss of outside area to Richmond Hall would be detrimental to young people.  Poor pedestrian links to town centre.  Building too big - loss of light and view.  Size of building - could be constructed smaller with more parking.  Proposal is an underdevelopment.  Layout – waste of space.  Does not accord with NPPF.  Safety issues with access to SAM.  Could be a magnet for anti-social behaviour.  Lack of synergy between the two applications (Cane Hill & Lion Green Road).

34 The following issues were raised in support:

 Well-designed building.  Consideration to be given to public art on the theme of railway.  Facilities will be an asset to community.  Welcome health and scout facilities.  Supermarket will help Coulsdon and create new jobs.  Current Waitrose site cramped and many use Banstead - taking too many shoppers away from Cousldon.

 Make sure walking links are in place.  Supermarket and health centre are massive improvement for Coulsdon.  Clean up area.  Stops travellers making mess of car park.  Development is of paramount importance.  Massive beneficial knock on effect to Coulsdon.

35 Strategic issues raised by objectors have been considered in this report and the Stage One report, and local issues have been considered in the Council’s committee report. In particular, the transport assessment modelling has been revised to satisfy concerns of both TfL and the local highway authority, including reference to other proposed major schemes in the vicinity, notably Cane Hill and the former Red Lion public house sites.

36 In June 2013, a local resident wrote to the Mayor objecting to both this application and the Coulsdon Cane Hill application (Ref: D&P/2108d/01). Objections included the impact of traffic congestion on the road network and associated safety concerns; the lack of local school places for new homes; procedural objections to the Cane Hill developer presenting the proposals to the Mayor; and concerns over GLA land interests in the sites. These issues have been responded to in correspondence with the objector, and issues relating to traffic have been addressed by TfL as stated above.

37 More recently, the Chair of Coulsdon Liberal Democrats wrote to the Mayor on 17 April 2014 asking for a review of both this application and the Coulsdon Cane Hill application (Ref: D&P/2108d/01). Their objections focussed on the Cane Hill application, however concerns were also raised about the effect that the removal of a large, all day, parking facility will have on existing businesses, and also the impact of traffic congestion on the road network. Car parking was dealt with in the Stage One report and issues relating to traffic have been addressed by TfL as stated above.

Legal considerations

38 Under the arrangements set out in Article 5 of the Town and Country Planning (Mayor of London) Order 2008, the Mayor has the power under Article 6 to direct the local planning authority to refuse permission for a planning application referred to him under Article 4 of the Order. He also has the power to issue a direction under Article 7 that he is to act as the local planning authority for the purpose of determining the application and any connected application. The Mayor may also leave the decision to the local authority. In directing refusal the Mayor must have regard to the matters set out in Article 6(2) of the Order, including the principal purposes of the Greater London Authority, the effect on health and sustainable development, national policies and international obligations, regional planning guidance, and the use of the River Thames. The Mayor may direct refusal if he considers that to grant permission would be contrary to good strategic planning in Greater London. If he decides to direct refusal, the Mayor must set out his reasons, and the local planning authority must issue these with the refusal notice. If the Mayor decides to direct that he is to be the local planning authority, he must have regard to the matters set out in Article 7(3) and set out his reasons in the direction. Financial considerations

39 Should the Mayor direct refusal, he would be the principal party at any subsequent appeal hearing or public inquiry. Government guidance emphasises that parties usually pay their own expenses arising from an appeal.

40 Following an inquiry caused by a direction to refuse, costs may be awarded against the Mayor if he has either directed refusal unreasonably; handled a referral from a planning authority

unreasonably; or behaved unreasonably during the appeal. A major factor in deciding whether the Mayor has acted unreasonably will be the extent to which he has taken account of established planning policy.

41 Should the Mayor take over the application he would be responsible for holding a representation hearing and negotiating any planning obligation. He would also be responsible for determining any reserved matters applications (unless he directs the Council to do so) and determining any approval of details (unless the council agrees to do so). Conclusion

42 Further information and clarification has been provided in relation to retail/town centre use, historic environment, inclusive access, sustainable development, and transport, which together with conditions imposed by Croydon Council, address the outstanding issues that were raised at Stage One. On this basis there are no sound reasons for the Mayor to intervene in this particular case.

43 Having regard to the details of the application, the matters set out in Croydon’s committee report and its draft decision notice, this scheme is acceptable in strategic planning terms.

for further information, contact Planning (Development & Projects) Unit: Colin Wilson, Senior Manager – Development & Projects 020 7983 4783 email [email protected] Justin Carr, Strategic Planning Manager (Development Decisions) 020 7983 4895 email [email protected] Martin Jones, Case Officer 020 7983 6567 email [email protected]

planning report D&P/3098/01 28 August 2013 Car Park & adjoining land, Lion Green Rd, Coulsdon in the London Borough of Croydon planning application no.13/02178/P

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

The applicant The applicant is Croydon Urban Regeneration Vehicle (CCURV), the agent is Indigo Planning Ltd and the architect is EPR Architects Ltd.

Strategic issues The proposed development is supported in strategic planning terms, however issues with respect to retail/town centre uses, urban design, historic environment, inclusive access, sustainable development and transport should be resolved before the application is referred back to the Mayor.

Recommendation That Croydon Council be advised that the application broadly complies with the London Plan, however there are some outstanding issues that need to be resolved before the application is referred back to the Mayor. These issues and their potential remedies are set out in paragraph 67 of this report.

Context

1 On 24 July 2013, 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 3 September 2013 to provide the Council with a statement setting out whether he considers that the application complies with the London Plan, and his reasons for taking that view. The Mayor may also provide other comments. This report sets out information for the Mayor’s use in deciding what decision to make.

2 The application is referable under Category 3F of the Schedule to the Order 2008:

 Category 3F “Development for a use, other than residential use, which includes the provision of more than 200 car parking spaces in connection with that use”.

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

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

5 The 1.4 hectare site is located within Coulsdon District Centre (Croydon Local Plan Strategic Policies 2013) and on the western edge of the Primary Shopping Area.

6 The majority of the site is currently a 216 space Council-owned car park, used mainly by commuters to the nearby Coulsdon South train station, and by shoppers visiting Coulsdon town centre. The site also contains a small public recycling collection point; the GLA owned Sovereign House, a vacant building in poor condition; an electricity sub-station, which has been de-commissioned and is currently being rebuilt outside the boundary of the site; and a number of storage containers used by the neighbouring scout hut. The site slopes down from the rear towards Lion Green Road. Some trees on the site are subject to Tree Preservation Orders.

7 The site is bounded to the east by Lion Green Road, with a two storey residential terrace opposite; to the south by a residential building and an access road to Coulsdon Area Farm; to the west by an earth embankment that once formed part of the Surrey Iron Railway and is a Scheduled Ancient Monument (SAM); and to the north by a scout hut, a post office depot and service yard, and two cottages. Further south and west are open areas, including the grounds of the former Cane Hill Hospital, some of which is designated as Green Belt, and including a major development site expected to deliver a significant residential-led mixed use development.

8 The site is less than 300 metres from the A23 (Farthing Way), which forms part of the Transport for London Road Network (TLRN). It is served by four high frequency daytime bus routes along Brighton Road and Chipstead Valley Road and one night bus route. In addition, the site is within walking distance of Coulsdon South National Rail station. This generates a public transport accessibility level (PTAL) of 3 (on a scale of 1 to 6, where 6 is the most accessible).

Details of the proposal

9 The proposal seeks to demolish Sovereign House and associated outbuildings and erect a two-storey building containing a 4,679 sq.m. Waitrose food retail store at first floor level, a 932 sq.m. health facility, and a 190 space car park at ground floor level beneath the food store. The Waitrose store will be accessed via a travelator and lifts, accessed from Lion Green Road. Waitrose currently operates from a 912 sq.m. store on nearby Brighton Road, which would close if the proposal goes ahead. The health centre on ground and first floors, will front onto a new access road to the north of the site.

page 10 10 A new two-storey 160 sq.m. storage building will be constructed for the existing scout hall, together with other improvements to the scout hall, including security fencing, vehicular access and eleven drop-off parking bays. Also proposed is a new access road, including twelve on-street parking bays, and associated landscaping and public realm works. Lion Green Road will be widened on the application site to allow a dedicated right turn into the new development. Case history

11 On 18 January 2013, a pre-planning application meeting was held at City Hall and on 4 February 2013 a pre-application advice report was issued to the applicant. This report concluded that the proposed supermarket and community uses were likely to be acceptable in strategic planning terms. However, further discussion and information was required regarding retail impact, heritage, design, inclusive access, transport, climate change and trees. Strategic planning issues and relevant policies and guidance

12 The relevant issues and corresponding policies are as follows:

 Urban design London Plan; Shaping Neighbourhoods: Character and Context, draft SPG; Housing SPG; London Housing Design Guide; Shaping Neighbourhoods: Play and Informal Recreation SPG  Transport London Plan; the Mayor’s Transport Strategy  Crossrail London Plan; Mayoral Community Infrastructure Levy; Crossrail SPG  Parking London Plan; the Mayor’s Transport Strategy  Retail/town centre uses London Plan; draft Town Centres SPG  Biodiversity London Plan; the Mayor’s Biodiversity Strategy; draft Tree and Woodland Strategies  Access London Plan; Accessible London: achieving an inclusive environment SPG; Planning and Access for Disabled People: a good practice guide (ODPM)  Historic Environment London Plan; World Heritage Sites SPG; Circular 07/09  Health London Plan; Health Inequalities Strategy  Sustainable development London Plan; Sustainable Design and Construction SPG; Mayor’s Climate Change Adaptation Strategy; Mayor’s Climate Change Mitigation and Energy Strategy; Mayor’s Water Strategy

13 For the purposes of Section 38(6) of the Planning and Compulsory Purchase Act 2004, the development plan in force for the area is the 2013 Croydon Local Plan Strategic Policies, the Croydon Replacement Unitary Development Plan (2006) and the 2011 London Plan.

14 The following are also relevant material considerations:  The National Planning Policy Framework and Technical Guide to the National Planning Policy Framework.  The draft Revised Early Minor Alteration to the London Plan.  The draft Coulsdon Masterplan (2013)

page 11 Principle of development – Retail/town centre use

15 The site is within Coulsdon Town Centre, identified in London Plan Table A2.1 as a District Centre with medium growth potential, having moderate levels of demand for retail, leisure or office floorspace and with physical and public transport capacity to accommodate it. London Plan Policies 2.15 ‘Town Centres’, 4.7 ‘Retail and town centres’, 4.8 ‘Supporting a successful and diverse retail sector’ and 2.7 ‘Outer London’ provide the strategic policy context in which the proposals are considered. More specifically, Policy 4.8Bb supports the expansion of convenience retail in District Centres. Further guidance is provided in the London Plan draft supplementary planning guidance ‘Town Centres’.

Retail - need

16 The need for additional convenience retail space, including a supermarket, is demonstrated in the draft Coulsdon Masterplan, which has been through consultation and is expected to be adopted in Autumn 2013. The site is one of five identified for potential new or relocated supermarkets in the draft Masterplan and a strategic objective is to increase the range of retail activity to make Coulsdon an attractive destination with a full range of high street uses, including a larger supermarket. It also states that the low level of convenience retail within the town centre has been identified by previous studies. More specifically it identifies the site for mixed use redevelopment including retail, with potential for a supermarket, car parking and community uses.

Retail - scale

17 London Plan Policy 4.7Ba requires the scale of retail development to be related to the size, role and function of a town centre and its catchment area. The applicants’ Retail Assessment states that the scale of the proposal is appropriate to Coulsdon town centre but does not provide any justification. The proposal will add approximately 3,500 sq.m. of retail floorspace, comprising 2,450 sq.m of convenience goods floorspace (or a net addition of 1,538 sq.m. accounting for the closure of the existing store) and 1,050 sq.m. of comparison goods floorspace (a 70/30 split). The Table below shows the indicators and thresholds stated in the London Town Centre Healthcheck (2009) for a district centre; the latest available figures for Coulsdon, showing an under-provision of convenience goods space and an over-provision of comparison goods space; and the effect of the proposed development. It is noted that the data should be treated with some caution due to the date of the baseline figures (2008).

District Coulsdon Coulsdon (existing) 3 Centre1 (existing)2 plus proposal Total town centre floorspace (retail, 10-50,000 14,612 18,112 service, leisure) Total retail floorspace 6,000+ 7,656 11,156 Total comparison goods retail floorspace 4,000+ 6,395 7,445 Total convenience goods floorspace Not given 1,261 2,799 Comparison goods retail as percentage of <60% 83% 67% total retail floorspace Convenience goods retail as percentage Variable 10- 8% 25% of total retail floorspace 60%

1 From Table 4.2 of the London Town Centre Health Check (2009) 2 From Croydon Borough-wide Retail Needs Study Update (2008) 3 From Croydon Borough-wide Retail Needs Study Update (2008)

page 12 18 This indicates that the proposed retail space would address an under-provision of convenience retail space in Coulsdon town centre, which is welcome, and would overall help to rebalance the proportion of convenience space in the town centre.

Retail - sequential test

19 Although the site is within the town centre boundary, it is described as ‘edge of centre’ in the draft Coulsdon Masterplan. This is in line with the NPPF definition of edge of centre, which states “for retail purposes, a location that is well connected and up to 300 metres of the primary shopping area”, which in this case is Coulsdon Primary Shopping Area, as defined in the Croydon Local Plan. Furthermore, in line with the NPPF, London Plan Policy 4.7Bb requires retail development to be “focussed on sites within town centres, or if no in-centre sites are available, on sites on the edges of centres that are, or can be, well integrated with the existing centre and public transport”. In response to this, the applicants’ Retail Statement contains a sequential test, which has examined all four of the sites identified as suitable for supermarkets in the draft Coulsdon Masterplan. The Statement concludes that two of the sites are unsuitable as they are too small to accommodate the proposal, as well as being unavailable as they are wholly or partly in current use; one is currently being redeveloped for a residential led scheme; and the other is the existing Waitrose site, which is also too small to accommodate the proposal. Vacant shop units in the town centre have been discounted as they are also too small to accommodate the proposal. The sequential test is appropriate.

20 The Town Centres SPG provides further information on assessing how sites are ‘well integrated’, including the scope for physical integration with the existing centre; promotion of inclusive access, cycling and public transport; and the promotion of connections, vitality and viability across the centre. Inclusive access and transport are dealt with in paragraphs 36 to 38 and 49 to 60 respectively and indicate good integration. The site already has good physical integration with the town centre, with the potential for improved pedestrian crossing points across Lion Green Road. The inclusion of an atrium on Lion Green Road, with entrances facing towards both Chipstead Valley Road and Brighton Road, orientates the scheme towards the existing town centre. It is proposed that car parking in the development will also allow use by visitors to other shops in the existing centre. In addition, the site’s location between Coulsdon Primary Shopping Area and the Cane Hill development site gives it an important linking role, benefiting vitality and viability across the town centre. In conclusion, the site can be described as well integrated, with potential for improvement, with the existing centre and public transport and the sequential test conforms to the requirements of the NPPF and Policy 4.7.

Retail - impact assessment

21 In line with the NPPF, London Plan Policy 4.7Bc also requires that proposals for new edge of centre development to be subject to an assessment of impact. This should test the impact of the proposal on existing, committed and planned public and private investment in centres in the catchment area of the proposal; and the impact on town centre vitality and viability, including local consumer choice and trade in the town centre and wider area, up to five years ahead. The Retail Statement defines the catchment area as that used for Coulsdon town centre in Croydon’s Borough-wide Retail Needs Study Update (2008), which is appropriate. Although the analysis of impact on other town and local centres is limited, taking into account the relatively small size of the new retail offer, this is adequate.

22 However, in terms of the impact of the proposal on existing, committed and planned public and private investment, the Retail Assessment states that the impact will be wholly beneficial to Coulsdon as it may attract further investment and will attract more shoppers. This is considered inadequate and the applicant should consider other impacts, including that on the

page 13 possible development of the former Red Lion public house site. The impact of pipeline schemes identified in Figure 2.3 and Appendix A of the draft Town Centres SPG should also be assessed if relevant.

23 In addition, as stated in paragraph 17, the applicant is proposing a 70/30 floorspace split between convenience and comparison goods. The analysis of the effect of this on comparison goods retailers in Coulsdon town centre is very limited and the applicant should consider this in more detail.

Car parking

24 The current 216 space car park is said to be used mainly by commuters to the nearby Coulsdon South train station and by shoppers to Coulsdon town centre. A strategic objective of the draft Coulsdon Masterplan is to provide in-town parking to support the town as a retail destination. The applicants’ Transport Statement identifies the new 190 space car park beneath the supermarket to provide short-stay parking for customers using the store and for linked visitor trips to the town centre. It is envisaged that this would be enforced through a pay and display system, which would discourage long-stay parking opportunities. Long-stay car parking is expected to redistribute to Coulsdon South rail station, where capacity for parking has been increased. The retention of parking for town centre shoppers is welcomed, however Transport for London have some transport concerns (see paragraphs 49 to 60).

Health/community facilities

25 London Plan Policies 3.16 ‘Protection and enhancement of social infrastructure’ and 3.17 ‘Health and social care facilities’ support proposals that provide high quality healthcare facilities in areas of identified need, particularly in areas easily accessible by public transport, cycling and walking. Croydon’s Local Plan states that community facilities are encouraged within close proximity of Coulsdon District Centre. The draft Coulsdon Masterplan identifies the need for a new health/GP facility to be located in the town centre and identified uses for the site include community uses. The provision of a health facility and improvements to the existing scout hut facilities is in conformity with London Plan policy and is strongly supported. Biodiversity

26 There are no statutory or non-statutory sites of nature importance within the proposal boundary. The applicant has provided an Ecology Report and an Aboricultural Impact Assessment as requested during pre-application advice. The proposal will involve the removal of nine trees subject to Tree Preservation Orders (TPO) and three non-native mature trees along Lion Green Road. In accordance with London Plan Policy 7.21 ‘Trees and Woodlands’, these will be replaced following the principle of ‘right place, right tree’, which is welcomed.

Urban design

27 The proposed scheme has been commented on at the pre-application stage where it was felt that the scheme was generally well designed and raised no strategic design concerns.

28 The creation of a food store in this location will help to anchor both Brighton Road and Chipstead Valley Road, creating a retail loop linking the two. It also responds well to its ‘edge of town’ context by creating a seamless transition between the urban and rural characters either side of the site.

page 14 29 On the urban edge, the proposal creates a strong building line providing a good level of enclosure to surrounding streets, which is welcomed. The screening of the servicing area and car parking behind the health centre and supermarket entrance ensures an active frontage facing the public realm making it feel safe and well used, which is strongly supported.

30 On the rural edge, the scheme takes advantage of the change in levels so that it is hidden behind the Scheduled Ancient Monument, minimizing its visual impact on the neighbouring open land, which is welcomed.

31 The proposal creates a new access street perpendicular to Lion Green Road, providing access to the scouts hall, car park, servicing of the supermarket and pedestrian access to the SAM. The improved access to the scouts hall is particularly welcomed. The health centre will provide good quality frontage on to the new street and the street’s alignment will allow the sites fronting it to the north to be redeveloped in the future if necessary.

32 The architecture of the scheme has been carefully considered and officers are content that its appearance presents no strategic design concerns.

Historic environment

33 The site is adjacent to an earth embankment that once formed part of the Surrey Iron Railway and is a Scheduled Ancient Monument (SAM). London Plan Policy 7.8 ‘Heritage assets and archaeology’ states that development affecting heritage assets and their settings should conserve their significance by being sympathetic to their form and scale. The draft Coulsdon Masterplan states that development of the site should improve the visibility and setting for the SAM, encourage public accessibility and views from Lion Green Road, and make it an integral part of the town centre.

34 The applicant has provided a Historic Environment Assessment, which concludes that the proposal will have negligible impacts on underground heritage assets. Above ground, the applicant states that the proposal would significantly enhance the setting of the SAM by:  Opening a viewing corridor to the SAM from Green Lion Road along the new access road;  Providing views from the first floor public café;  Providing a range of views via the new public footpath to the Cane Hill development;  Enhanced landscaping adjacent to the SAM;  Providing interpretation boards and information to enhance public awareness and understanding of the SAM.

35 The applicant states that English Heritage have been involved in the proposal from an early stage and are satisfied with all aspects of the development. Evidence of this should be provided before the application is referred back to the Mayor. Subject to English Heritage agreement, the benefits associated with the landscape proposals are accepted and should be secured by condition or agreement.

Inclusive access

36 The Design and Access Statement shows how disabled people access each of the entrances. It also confirms that fourteen blue badge parking bays have been provided adjacent to the lifts, in line with London Plan Policy 6.13 ‘Parking’ and Table 6.2. However, the applicant should confirm

page 15 that a further 4% of spaces will be provided as ‘enlarged standard spaces’, which can be adapted for future provision.

37 Two of the parking bays are located on the new access road in front of the health centre, which is welcomed, however, the applicant should confirm that the bays will be an appropriate size, and provide the necessary dropped kerbs to ensure level access to the entrance points.

38 It is not clear what level of segregation is proposed to the road and footpath where the shared surface is proposed on the new access road. The applicant should provide further details on the design features that will be incorporated to ensure that the areas are safe, usable and navigable for disabled people.

Sustainable development

Energy

39 A range of passive design features and demand reduction measures are proposed to reduce the CO2 emissions of the proposed development. Both air permeability and heat loss parameters will be improved beyond the minimum backstop values required by building regulations. Other features include energy efficient lighting and mechanical ventilation with heat recovery. The demand for cooling will be minimised through the natural ventilation.

40 The development is estimated to achieve a reduction of 48 tonnes per annum (25%) in regulated CO2 emissions compared to a 2010 Building Regulations compliant development (‘Be Lean’). This appears high and should be evidenced by modelling. Modelling sheets should be submitted showing the effect of energy efficiency measures alone (i.e. excluding renewables) on regulated CO2 reductions.

41 The applicant has carried out an investigation and there are no existing district heating networks within the vicinity of the proposed development. The applicant has, however, provided a commitment to ensuring that the retail store is designed to allow future connection to a district heating network should one become available. This commitment should extend to both the retail store and the healthcare facility in order to ensure that they are both capable of future connection to a network should one become available.

42 The applicant should investigate serving both the retail store and the health centre from a single energy centre. Details of the location and floor area of the energy centre should be provided.

43 The applicant has investigated the feasibility of CHP but has not proposed to install it. This is acceptable in this instance.

44 The applicant has investigated the feasibility of a range of renewable energy technologies and is proposing to install 5kWp PV on the roof of the health care facility. Air source heat pumps are proposed to supply the health care facility. A reduction in regulated CO2 emissions of 2 tonnes per annum (1%) will be achieved through this third element of the energy hierarchy (‘Be Green’).

45 Based on the energy assessment submitted at stage 1, a reduction of 50 tonnes of CO2 per year in regulated emissions compared to a 2010 Building Regulations compliant development is expected, equivalent to an overall saving of 26%. However, the applicant should provide updated figures taking into account comments on energy efficiency in paragraph 40 above before it can be determined if the CO2 savings comply with the targets set in Policy 5.2 of the London Plan. Climate change adaptation

page 16 46 The applicant has set out some proposed climate change adaptation measures within the Design and Access Statement and the Sustainability Statements, including facade shading, biodiversity roof, underground water attenuation, and permeable surfaces in line with London Plan Policies 5.9 to 5.15. The main measures to restrict surface water discharge are stated as attenuation tanks of approximately 530 cubic metres. Whilst more natural or open SUDS techniques are the preferred method, this proposal is in line with London Plan Policy 5.13. The surface water management measures should be secured via an appropriate planning condition.

48 The large expanse of flat roof over the supermarket retail area presents opportunities for skylights to further reduce the need for artificial lighting, and for green or brown roofs. The applicant is requested to provide information on the feasibility of these opportunities before the application is referred back to the Mayor.

Transport

49 It should be noted that the development is close to the A23, which is an important strategic road for TfL. The site is also close to a number of other sites that are currently being promoted for development, including Cane Hill. A number of other sites are also included in the draft Coulsdon Masterplan and the cumulative impact of these sites must be taken into account and mitigation agreed that addresses those impacts. In addition other schemes, such as pedestrian improvements at Chipstead Valley Road / Lion Green Road vehicle capacity also require further consideration.

50 TfL has reviewed the transport assessment and has a number of concerns about the methodology, including trip rates, which will need to be reviewed before an acceptable approach to transport modelling can be agreed. Further discussions between the applicant and the Council are required before the assessment can be considered acceptable. A number of the TRAVL and TRICS sites used are not comparable to the characteristics of the site.

51 Further information is required by TfL to establish the weekend peak period and associated trip generation in order to identify the period that generates the greatest demand. In addition, weekday AM peak trip generation analysis should be presented to TfL for review. Further clarification has also been sought from TfL about the impact of displaced commuter related parking; the potential for the car park to reach capacity and queuing traffic to block the highway; traffic reassignment and whether the existing priority access junction will have sufficient capacity to accommodate the level of forecast trips. A TRANSYT model has been submitted, but given the issues raised above in relation to cumulative impacts and wider network constraints TfL recommends a VISSIM model is developed to include modelling of Brighton Road / Marlpit roundabout for the Saturday peak as this junction is adjacent to the new access for Cane Hill. All modelling will need to be audited by TfL

52 A total of 213 car parking spaces across the site are proposed. This is comprised of a 190 space car park to serve the food store, twelve car parking spaces to serve the health centre and eleven car parking spaces to serve the scout hall. Whilst the proposed car parking quantum is in accordance with London Plan Policy 6.13, further analysis of the highway impact as detailed above is required.

53 Electric Vehicle Charging Points (EVCP’s) must be installed for the retail spaces (and be accessible for other uses) at a ratio of 10% active and 10% passive provision. The level of use of active (implemented) charging points should be monitored through the travel plan and implemented when demand exceeds supply. The provision of EVCP’s should be secured by planning condition in accordance with London Plan Policy 6.13.

page 17 54 A Car Park Management Strategy should be secured by condition for all site uses. Through this, the function of the car park for town centre users should be promoted, to increase linked trips.

55 TfL consider that the demand from this development can be accommodated on the bus network, however TfL have concerns regarding operational impacts of the proposed development on the journey time reliability of bus services. These concerns should be considered and addressed through the additional traffic modelling.

56 A total of 48 cycle parking spaces are proposed to serve the food store, of which 38 cycle parking spaces would be located by the southern entrance area and 10 cycle parking spaces would be available for staff use in a sheltered area, the details of which should be secured by condition. It is proposed to provide a further six cycle parking spaces to serve the health centre. Showers and changing facilities are included. The application is in accordance with London Plan Policy 6.3.

57 TfL welcomes the submission of an Interim Travel Plan. Whilst TfL’s analysis demonstrates that in its current form the travel plan is not acceptable, it suggests several ways in which this could be improved, including measures for customers associated with the supermarket. TfL expects the travel plan to be revised and secured, monitored and enforced through the section 106 agreement.

58 A Construction Logistics Plan (CLP) should be secured by condition and approved prior to commencement of the development. The CLP should include the impact of construction traffic, likely construction trips generated and mitigation proposed. Details should include site access arrangements, booking systems, construction phasing, vehicular routes and scope for load consolidation in order to reduce the number of road trips generated.

59 A Delivery and Servicing Plan (DSP) should be secured by condition and approved prior to commencement of the development. The DSP should identify efficiency and sustainability measures to be undertaken once a development is operational.

60 It is imperative that road safety measures, including for cyclists, are considered at the application stage and preventative measures delivered through the construction and operational phases of the development. TfL encourages the use of contractors who are registered on the FORS system. In addition, details of the consideration of routes, any conflict points identified on these routes, safe loading and unloading facilities, traffic and pedestrian management equipment and cycle specific safety equipment should be provided through a CLP and DSP. Contractor vehicles should include side-bars, blind spot mirrors and detection equipment to reduce the risk and impact of collisions with other road users and pedestrians.

Community Infrastructure Levy

61 The Mayor has introduced a London-wide Community Infrastructure Levy (CIL) to help implement the London Plan, particularly Policies 6.5 and 8.3. The Mayoral CIL formally came into effect on 1 April 2012, and it will be paid on commencement of most new development in Greater contribute towards the funding of Crossrail.

62 The Mayor has arranged boroughs into three charging bands. The rate for Croydon Council is £20/sq.m. The required CIL should be confirmed by the applicant and the Council once the components of the development or phase thereof have themselves been finalised. In accordance with Table 2 of the Mayor’s CIL charging schedule, the applicant is advised that the health floorspace within the development will not be chargeable.

page 18 63 London borough councils are also able to introduce CIL charges which are payable in addition to the Mayor’s CIL. Croydon Council has adopted a scheme. See the council’s website for more details. Local planning authority’s position

64 Croydon Council expect to take the proposal to Committee on 3 October 2013. Legal considerations

65 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

66 There are no financial considerations at this stage. Conclusion

67 London Plan policies on retail/town centre use, biodiversity, urban design, historic environment, inclusive access, sustainable development, and transport are relevant to this application. The application complies with some of these policies but not with others, for the following reasons:  Retail/town centre use: The principle of the development does not present any strategic planning issues, although further information is required on the impact of the scheme on other investments in the catchment area and the impact on comparison goods retailers in the Coulsdon Primary Shopping Area.  Biodiversity: The proposals comply with London Plan policy.  Urban design: The design of the proposal has been carefully considered and it raises no strategic concerns.  Historic environment: Evidence of English Heritage agreement with the proposals is required before it can be determined if the proposal complies with London Plan policy.  Inclusive access: The proposals are supported in principle although further information is required on parking arrangements and shared surface segregation.  Sustainable development: It cannot yet be determined if the proposal complies with London Plan Policy 5.2. The applicant should provide further energy efficiency modelling information; further information on future connection to a district heating network; and further information on the proposed energy centre. The use of the large flat roof for climate change adaptation should also be considered.

page 19  Transport: The application does not accord with London Plan Policies 6.1, 6.3, 6.12 and 6.13. The Transport Assessment should be revised to only include the most comparable sites and further analysis of highway impacts, including revised modelling, is required. Appropriate mitigation measures may be required following this analysis. The Travel Plan should be revised to include positive travel planning measures for customers of the supermarket and should be secured, monitored and enforced through a section 106 agreement. A Construction Logistics Plan (CLP), Car Park Management Plan and a Delivery and Servicing Plan (DSP) should be secured by condition and approved prior to commencement of the development.

68 The application is broadly acceptable in strategic planning terms, subject to the resolution of the issues set out above.

for further information, contact Development & Projects: Colin Wilson, Senior Manager – Development & Projects 020 7983 4783 email [email protected] Justin Carr, Strategic Planning Manager (Development Decisions) 020 7983 4895 email [email protected] Martin Jones, Case Officer 020 7983 6567 email [email protected]

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