PLANNING COMMITTEE AGENDA 30 July 2015

PART 6: Development Presentations

1 INTRODUCTION

1.1 This part of the agenda is for the committee to receive presentations on proposed developments, including when they are at the pre-application stage.

1.2 Although the reports are set out in a particular order on the agenda, the Chair may reorder the agenda on the night. Therefore, if you wish to be present for a particular application, you need to be at the meeting from the beginning.

1.3 The following information and advice applies to all those reports.

2 ADVICE TO MEMBERS

2.1 These proposed developments are being reported to committee to enable members of the committee to view them at an early stage and to comment upon them. They do not constitute applications for planning permission at this stage and any comments made are provisional and subject to full consideration of any subsequent application and the comments received as a result of consultation, publicity and notification.

2.2 Members will need to pay careful attention to the probity rules around predisposition, predetermination and bias (set out in the Planning Code of Good Practice Part 5.G of the Council’s Constitution). Failure to do so may mean that the Councillor will need to withdraw from the meeting for any subsequent application when it is considered.

3 FURTHER INFORMATION

3.1 Members are informed that any relevant material received since the publication of this part of the agenda, concerning items on it, will be reported to the Committee in an Addendum Update Report.

4 PUBLIC SPEAKING

4.1 The Council’s constitution only provides for public speaking rights for those applications being reported to Committee in the “Planning Applications for Decision” part of the agenda. Therefore reports on this part of the agenda do not attract public speaking rights.

5 BACKGROUND DOCUMENTS

5.1 For further information about the background papers used in the drafting of the reports in part 8 contact Mr P Mills (020 8760 5419).

6 RECOMMENDATION

6.1 The Committee is not required to make any decisions with respect to the reports on this part of the agenda. The attached reports are presented as background information.

PLANNING COMMITTEE AGENDA 30 July 2015

PART 6: Development Presentations Item 6.1

1 DETAILS OF THE DEVELOPMENT

Ref: 15/01778/PRE Location: Fairfield Masterplan Area (bounded by George Street, - Brighton railway line, Barclay Road and Park Lane). Ward: Fairfield Description: Emerging proposals for a hybrid planning application for:

• Outline planning permission for demolition and redevelopment to provide: flexible class A1 (shops) and/or class A2 (financial and professional services) and/or class A3 (food and drink); class B1 (business); class C1 (hotel); class C3 (dwelling houses); class D1 (non-institutional institutions); public realm and landscaping; and associated car and cycle parking, servicing, and access arrangements; and

• Full planning permission for demolition including multi-storey car park and Barclay Road Annex, extensions and alterations to including ancillary class A3 (food and drink), erection of buildings for flexible class A1 (shops) and/or class A2 (financial and professional services) and/or class A3 (food and drink), class C3 (residential), class D1 (non-residential institutions), class D2 (assembly and leisure), public realm and landscaping; and associated car and cycle parking, servicing, and access arrangements.”

Drawing Nos: Overall - 19000-000, 19000-001 (Area & Heights Schedule),19000- 0002, 9000-003, 19000-004A,19000-004B,19000-005A,19000- 005B,19000-006A,19000-006B,19000-007,19000-008; Landscape – 981091-10-001-C, 981091-10-002-D, 981091-10-003-C, 2015.07.01 COLOUR PLAN PHASE 1, 2015.07.01 COLOUR PLAN PHASE 2, 2015.07.01 COLOUR PLAN PHASE 3; Fairfield Halls – 607 Gas 150630; Phase 1 Housing – 607 FF22-12000, 607 FF22-12001, 607 FF22-12002, 607 FF22-12003; Planning Position Statement & Pre- application Design Information. Applicant: LBC Housing Development & Regeneration Agent: Turley Case Officer: Graham Harrington

2 BACKGROUND

2.1 This proposed development is being reported to enable Members of the Planning Committee to comment upon it before a planning application is submitted. The emerging scheme does not constitute an application for planning permission and any comments made on it are provisional and subject to full consideration of any subsequent application, including the comments received as a result of consultation etc. 2.2 This is the first presentation to Planning Committee of emerging proposals for the Fairfield Masterplan Area (hereafter referred to as “the Area”). The purpose is to give the Members an early opportunity to comment on proposals that the Council (as a developer) is bringing forward.

2.3 Planning policy is established by the National Planning Policy Framework (NPPF), the London Plan (2015), the Local Plan Strategic Policies (CLP1), the saved policies in the Croydon Replacement UDP (CRUDP) and the emerging Croydon Local Plan: Detailed Policies (Preferred and Alternative Options 2013) (CLP2). The area is within the Croydon Metropolitan Centre (CMC) and is also within the London Plan Croydon Opportunity Area (COA). It is also identified as being within the Fair Field Masterplan Area, an Area of High Density and an Archaeological Priority Zone.

2.4 The Croydon Opportunity Area Planning Framework (2013) (OAPF) provides guidance for the COA as a whole and the Fair Field Masterplan (2012) (the Masterplan) provides area-specific guidance.

3 PROPOSAL AND LOCATION DETAILS

Proposal

3.1 The applicant has divided the area into six Development Zones as shown on the plan below. It is intended to submit a ‘hybrid’ planning application, where parts of the proposals are in outline form and parts are in detail. Those parts of the site that would be subject to detailed proposals are the Fairfield Halls, College Green and the multi-storey car park (parts of Zones 03 and 05). The rest of the area would be the subject of outline proposals. All matters would be reserved for the outline element, with the applicant proposing that future reserved matters applications would be informed by (a) a series of parameter plans which define minimum and maximum building envelopes, the range of uses and quantum of uses within each zone or part of a zone; (b) development guidelines; and (c) illustrative masterplan and landscape masterplan.

3.2 The form and nature of the application is under discussion with the Local Planning Authority (LPA), including the scope of plans and documents that are proposed to be submitted for approval and for information in relation to the outline element of a planning application. These elements have not yet been agreed.

3.3 Whilst identified as a Development Zone, the main building is not included in the emerging scheme at present. However, the applicant is investigating the potential for a new College campus in a new, smaller (in terms of floorspace) and more efficient building elsewhere in the Area and has identified land at the rear of Fairfield Halls and existing College Annex as a potential location for such a new building. The applicant is considering what alternative uses might be viable for Zone 06 if the main College building were to be converted or re-developed.

3.4 The proposed Development Zones are identified in the plan below.

3.5 The current proposal is to demolish all existing buildings within the area except for the Fairfield Halls (Zone 05) and the main College site (Zone 06) and to redevelop the resultant sites. The applicant sets out a range and quantum of proposed uses for all of the Zones except Zone 06. Taken together, this would allow for between approx. 176,500sqm and 201,000sqm (GEA) of development across Zones 01 to 05. Within this, the following range of uses are proposed:

• A1/A2/A3 (Shops/financial & professional services/restaurants & cafes); • B1 (Office, research & development & light industry); • C1 (Hotels); • C3 (Dwellings); • D1 (Non-residential Institutions); and • D2 (Assembly & leisure).

3.6 Vehicular access arrangements ass follows:

• College Road retained to provide access to adjoining sites and College East; • Phase 1 housing on multi-storey car park site (Zone 03) to be accessed via the Barclay Road car park ramp (reduced from four to two lanes). Emergency and occasional controlled maintenance to be at ground level via a new route between Fairfield Halls and the Courts building; • Phase 2 housing on multi-storey car park site and the Courts building and new D1 space at the rear of Fairfield Halls (Zones 03 and 04) to be accessed via the Barclay Road car park ramp. Emergency and occasional controlled maintenance to be via the ramp and College Road and a podium level route between Fairfield Halls and the Courts building; and • Existing Hazeldean Road vehicle access across railway bridge to be stopped up.

3.7 Pedestrian and cycle access at ground level would be via College Road, College Walk, Hazeldean Road railway bridge (with new stairs and lift) and new north-south routes between George Street and Barclay Road that would be created through redevelopment of the College Annex and Courts building.

3.8 The emerging scheme currently identifies proposed building footprints and the extent of public realm (including limits of deviation) in each Development Zone and minimum width assurances in relation to Zone 02.

3.9 The applicant has also identified minimum and maximum buildings heights for all Zones except Zones 05 (Fairfield Halls) and Zone 06 (the main College building) in terms of metres Above Ordnance Datum (sea level). Minimum and maximum storey heights above ground will vary depending on the use and design of individual buildings, but are indicated as follows:

• Zone 01: 7 to 9-storeys; • Zone 02: 13 to 28-storeys; • Zone 03: 4 to 21-storeys; and • Zone 04: 4 to 8-storeys.

3.10 As regards the future of the Fairfield Halls, whilst the Council and the current operator is still developing the vision for the venue, the emerging detailed proposals currently include the following:

• Vehicular access and servicing – improved ‘get-in’ arrangements for the Concert Hall, and kitchen area via a reconfigured rear service yard and goods lift. Coach pick-up/drop-off would continue to be from the front forecourt area, but within a reduced area; • Works to Foyer – entrance improvements, comprehensive refurbishment and new restaurant seating area; • Works to Concert Hall – new mechanical choir seating and improved access and canopy remodelling to allow improved flying and access facilities; • Works to Ashcroft Theatre – extended flytower to enable a stage crew to quickly hoist scenery etc from the stage to an area above that is out of view of the audience (and vice versa); • Works to Arnhem Gallery – new multi-function gallery space, seating and bar space to upper level; • Northern extension – extension to provide single-storey cafe/restaurant and other uses and an extended stage area for the Ashcroft Theatre; and • Other Works – facade and signage improvements, the potential removal of later addition in south-east corner and improvements to the front forecourt.

3.11 Development is expected to come forward in three phases over the next 15 years. The refurbishment and extension of Fairfield Halls and reconfiguration of College Green and redevelopment of the multi-storey car park and College Annex are in Phase 1 (Years 0-5). The George Street and College sites, including the main College building if included are in Phase 2 (Years 5-10) and the Magistrates and Family Courts are in Phase 3 (Years 10-15).

The Site and Surroundings

The Masterplan Area

3.12 Area is roughly rectangular in shape and comprises around 6.5 hectares. It has road frontages onto George Street to the north, Barclay Road to the south and Park Lane to the west. To the east is the main London - Brighton railway line.

3.13 In the northern part of the Area fronting George Street are the office/retail buildings of Suffolk House, 96 George Street and Mondial House (4, 11 and 15-storeys respectively) and a 3-storey residential hostel – St. Matthews House. Land at 101 George Street is a cleared site that was occupied by the former Essex House office building. To the south of the above buildings and facing onto College Road is Croydon College (a part 5/part 6-storey plus basement locally listed building), which includes a basement car parking area at its eastern end.

3.14 At the south western corner of the area is the Fairfield Halls, a large theatre and conference centre dating from 1962. This is a locally listed building. There is a forecourt servicing area at the front of the Halls and a servicing area to the rear. In the south east corner is the part 4/part 5-storey Croydon Magistrates Court and Family Court. Between the theatre and Court is a vehicular access to the underground section of Fairfield Halls public car park and the 5-7-storey College Annex building.

3.15 Between Croydon College and the Fairfield Halls is an area of public open space known as College Green, which is designated as Local Open Land. This area comprises a podium that forms the roof to the Fairfield Halls public car park, which extends below this part of the area. To the east of the Green abuts an above ground 6-level multi storey section of the Fairfield Halls public car park and beyond that a large electricity substation. The car park can be accessed from Barclay Road and by a road bridge over the railway from Hazledean Road to the east. Adjacent to the car park and Croydon College is a series of vertical concrete panels known as the Arnhem Gate, referring to Croydon’s link to that town in the Netherlands.

3.16 Levels across the site are complicated, with the ground ramping down from George Street to serve the Croydon College basement parking area, the electricity substation and the adjoining Mondial House car park. There is a ramp down to a pedestrian subway under Park Lane and steps on the northern edge of Fairfield Halls down to the public car park and, via this area, the subway under Park Lane (linking to the west side of Park Lane and Queens Gardens).

3.17 There are signal-controlled surface level pedestrian crossing points immediately in front of the Fairfield Halls (across Park Lane) at the junction of Barclay Road and Park Lane, further along Barclay Road (between the Magistrates Court and Chatsworth Road) and at the junction of George Street and Park Lane. There are also two informal crossing areas on George Street (by 96 George Street and Mondial House) and a zebra crossing on College Road leading to the main College entrance.

3.18 The periphery of area (in particular) is well served by public transport, including and Tramlink on George Street and bus routes along George Street and Park Lane and Barclay Road. The whole Area has a PTAL accessibility rating of 6b (on a scale of 1a- 6b, where 6b is the most accessible), although this will be confirmed by a Transport Assessment that supports the proposed application.

3.19 There are trees along the George Street frontage, the space between Suffolk House and 96 George Street, on College Road by St. Matthews House, in and around College Gardens and to the front of Fairfield Halls. However, there is a general absence of tree cover in the area.

Ownership

3.20 The Council owns the Fairfield Halls (together with the Fairfield Trust), the College Green area and the Fairfield Car Park (which is operated by NCP). It is also responsible for managing and maintaining College Road. Other land in the Area is in a variety of ownerships.

The Surrounding Area

3.21 To the north of the site is the main office area of Central Croydon, including the scheme, which is under construction and East Croydon Station. To the east, on the opposite side of the London-Brighton railway cutting, is the part 4/part 5-storey Croydon County Court building and beyond that the 23-26-storey “Altitude 25” residential tower. To the south Is Barclay Road, which is fronted on its southern side by mainly 2-storey houses and a 4-9-storey office building on the corner with Park Lane (69 Park Lane). To the west is the busy Park Lane, which is part in underpass, beyond which is the 5-storey Segas House and 23-storey St. Georges House, Queens Gardens, Bernard Wetherill House and the Town Hall.

3.22 Segas House and the Town Hall are Grade II Listed buildings and Queens Gardens is on the Council’s Local List of Parks and Gardens. These buildings and spaces are within the Central Croydon Conservation Area and the area to the south of Barclay Road is within the Chatsworth Road Conservation Area. The Hospital of the Holy Trinity (Whitgift Hospital) (Listed Grade I) on the corner of George Street and North End and the Society of Friends Hall (Listed Grade II) are other nearby important heritage assets.

3.23 TfL is responsible for managing and maintaining Barclay Road and the local highway authority (LBC) is responsible for the adjoining Park Lane and George Street. There are bus stops serving various routes along George Street and Park Lane and bus stands on Park Lane outside the main College building. The surrounding streets are within the Central Croydon Controlled Parking Zone.

Planning History

3.24 There have been a number of planning applications across the site for an array of proposals including the erection of buildings, advertisements, temporary permissions and extensions; the ones listed below are of most relevance.

Former Essex House site, 101 George Street, Croydon, CR0 1PJ • 14/01594/P - Erection of two buildings of 17 and 32 storeys comprising 305 residential units, 4 commercial units (use classes A1-A5) and a gym (use class D2); provision of new public piazza and associated landscaping, car parking, cycle and refuse storage. Granted subject to completion of Section 106 Agreement.

• 11/00963/P - Erection of 17 storey building with basement parking area comprising a use within class A1 (retail) on ground floor and offices (business class A1) in remainder of building. Formation of vehicular access, landscaping, servicing and other associated works. This application was for renewal of an older consent. Granted but not implemented.

College East site • 14/01603/P - Full planning permission is sought for the erection of a part 16/38 storey building (plus basement and mezzanine levels) comprising 159 residential units and a 225 bedroom hotel and restaurant (within use class A3); provision of associated amenity area, landscaping and car/cycle parking. Granted subject to completion of Section 106 Agreement.

• 06/00854/P - Permission granted for erection of 29 storey building including 2 basement levels and plant areas at roof level providing a vocational college on the lower 10 floors, a fitness suite and plant area on 10th floor and 173 flats and a crèche on the upper floor; provision of associated parking in basement areas. Granted but now expired.

Mondial House 102 George St (13/02223/PRE) • Current pre-application proposal for the site proposing the erection of a building of part 36, part 13 and part 9-storeys in height to provide 209 flats and 231sqm of ground floor flexible commercial/retail space; 1,860sqm office space and provision of associated parking and landscaping.

Other major Town Centre Developments • 12/02542/P - Retail and residential development of the existing Whitgift shopping centre by Westfield/Hammerson. Granted.

• Ruskin Square (11/00631/P) - Retail/ residential/ office development granted. Phased outline scheme. One residential building under way another office building imminent.

• Former Post Office 105 Addiscombe Road (13/03126/P) - Demolition of existing building; erection of three buildings ranging from 8 to 21 storeys to provide a total of 201 flats up to 1,760 sqm of retail floor area (use classes A1-A5) at ground floor level; formation of vehicular access, landscaping, works to public realm and associated works. Granted

• St Georges House, Park Lane (12/03491/P) - Conversion, extension, re-cladding of exterior and partial demolition of the existing building to provide 288 flats, A3 floorspace up to 404 sqm (GIA) with provision of accessible car parking and car club spaces and cycle parking. The extension includes up to an additional 5 storeys on Building A, including roof gardens at levels 23, 25 & 28 and an additional 3 storeys, including roof gardens at levels 6 and 8 on Building B. The demolition is for removal of the existing bridge link of Building B over St George's Walk and for the removal of links between Buildings A & B from first floor level upwards. Granted

(14/00196/P) - Demolition of existing building; erection of 5 buildings ranging from 6 to 32 storeys comprising 420 residential units and 2 retail units (within class A1-A3); provision of landscaping (new and re-landscaping of Queens Gardens), servicing, parking and new access. Granted. Subject to pre application discussions for an alternative form of development.

4 MATERIAL PLANNING CONSIDERATIONS

4.1 The main planning issues raised by the development that the Planning Committee should be aware of at this stage are:

1. Principle of proposed uses; 2. Affordable housing; 3. Design and townscape; 4. Access, movement and parking; 5. Amenities of future and adjoining occupiers; 6. Environment and sustainability; 7. Relationship with alternative schemes; and 8. Other matters

Principle of proposed uses General

4.2 London Plan Policy 2.13 identifies the centre of Croydon and its immediate surroundings as an Opportunity Area; an area which is capable of accommodating large scale development including significant amounts of employment and new housing. Annex 1 to the London Plan sets indicative employment capacity of the Croydon Opportunity Area (COA) of 7,500 jobs and at least 7,300 new homes up to 2036. London Plan Policy 2.16 identifies Croydon as a Strategic Outer London Development Centre for offices and higher education.

4.3 CLP1 Policy SP1.2 states that the COA will be the primary location for growth and Policy SP3.8 promotes and supports the development of all B1 uses, retail, leisure, visitor accommodation and housing and community facilities within the CMC. Policy CP3.9 makes clear that CMC will remain the principal location in the borough for office, retail, cultural and hotel activity.

4.4 Saved CRUDP Policy H3 identifies mixed-use sites with a housing element in the CMC, with Sites CMC2/H68 (Fairfield Halls) being allocated for office/ leisure/ residential (900 additional homes) and CMC8/H74 (College Road/George Street) being allocated for office/residential (40 additional homes).

4.5 The OAPF defines the site as being within the Mid-Croydon and Fair Field zone, which is identified as suitable for civic, community, residential and leisure uses, as well as small scale commercial uses.

4.6 The Masterplan is based on six objectives, including optimising development potential to enable a new mix of uses and ensuring a vital mix of activities giving opportunities for local enterprise. 4.7 The above policy and guidance generally supports a mixed-use development of sites within the area.

Business (B1) Offices

4.8 London Plan Policy 4.2 supports the renewal and modernisation of office stock, with justifying text (4.12) referring to Strategic Outer London Development Centres and particularly the strategic office centre of Croydon as being one of the most viable locations.

4.9 CLP1 Policy SP3.13 states that the Council will promote and support the development of new and refurbished office floor space up to 95,000 sqm in the CMC.

4.10 The OAPF (4.51) seeks to focus new office space around New Town and East Croydon. However, it goes on to make clear in paragraph 4.52 that it still encourages a flexible approach and that new/converted office space should be permitted in any of the other character areas. The Masterplan envisages offices being part of mixed- use development on the four sites along George Street (FF1, FF2, FF3 and FF7).

4.11 The emerging scheme proposes B1 office use on the ground and upper floors of buildings on most of the George Street sites (but not 101 George Street) (Zone 01) and the Mondial site (Zone 02). Depending on the range and quantum of other proposed uses on these sites, this could include between about 115,000 and 135,100sqm of office space. The principle of office use in this location is in accordance with policy and guidance and is acceptable. However, it should be noted that the emerging scheme seeks a high degree of flexibility between B1, C1 (hotel) and C3 (residential).

Retail (A1/A2/A3)

4.12 London Plan Policy 2.15 makes clear that town centres should be the focus for commercial development and intensification and identifies Croydon as a Metropolitan Town Centre. London Plan Policy 4.7 states that sites in town centres should be the focus for retail and other commercial uses and that the scale of these uses should be related to the size, role and function of the town centre.

4.13 CLP1 Policy SP3.10 provides that a flexible approach will be adopted to retail and leisure within the CMC and explains that this approach is supplemented by the OAPF. Saved CRUDP Policy 2013 SH3 is a borough wide policy that seeks to control retail development outside designated centres across Croydon, including the CMC Primary Shopping Area (PSA). The area is outside the PSA and in accordance with paragraphs 24-27 of the NPPF, a sequential and impact assessment would need to demonstrate the acceptability of proposed retail space. However, the emerging CLP2 proposes an extension of the PSA to include that part of the area that is north of College Road (although little weight can be attached to this, given the early stage of the emerging plan.

4.14 The OAPF sets out specific high street aspirations, including retaining the diverse character and form of George Street to the west of Wellesley Road, improving the streetscape and ensuring that there are day and evening options for eating and leisure for employees and residents travelling to and from East Croydon station. The Masterplan envisages retail as being part of mixed-use development on the four sites along George Street (FF1, FF2 and FF3). 4.15 The emerging scheme proposes flexible A1 (shops), A2 (financial & professional services) and A3 (cafes & restaurants) floorspace on the ground floors of buildings on all the George Street sites (Zone 01), with a minimum of approximately 3,850sqm and a maximum of approximately 4,400sqm. It also proposes approximately 4,750sqm of flexible A1, A2 and A3 space on the ground floor of the Mondial site (Zone 02). The way that the emerging scheme is being promoted means that all of the proposed A1/A2/A3 floorspace on the above sites could, subject to market and viability conditions, be used for any of the proposed uses (i.e. up to approximately 9,150sqm of space as A1, or A2 or A3).

4.16 This part of the site is currently outside of the designated PSA and a planning application that included the prospect of the above levels of A1 space would need to be supported by a sequential test appraisal and retail impact assessment to ensure that the Council’s shopping policy objectives are not undermined, including the objectives for the Retail Core as outlined in the OAPF. However, the Council has consulted on a proposal to extend the PSA designation to include the George Street sites and the northern half of the Mondial site and subject to satisfactory sequential test appraisal and assessment, officers consider that A1space here would be acceptable in principle and help to ensure active frontages along George Street and a key pedestrian route into the wider area. The proposed A2 and A3 uses are acceptable in principle in both these Zones, subject to satisfactory safeguards on residential amenity being in place (hours of uses, ventilation etc.) and other considerations to ensure an appropriate balance between the uses.

4.17 The emerging scheme also proposes flexible A2 and A3 floorspace on the ground floor of a mainly residential building on the multi-storey car park site (Zone 03) of between approximately 2,500 and 5,050sqm and an as yet unquantified amount of such space on the ground floor of extensions to the north side of Fairfield Halls. Either or both of these uses would be acceptable in principle in these Zones and would help to enliven the pedestrian route that runs alongside the main College building and College Green and strengthen the Fairfield Halls offer. Again, this is subject to satisfactory safeguards on residential amenity being in place and other considerations. Servicing is likely to be a particular issue for these areas.

Hotel (C1)

4.18 London Plan Policy 4.5 supports visitor infrastructure and seeks to achieve 40,000 net additional hotel rooms by 2036, focussing such accommodation in the Central Activities Zone, town centres and opportunity areas.

4.19 CLP1 Policy SP3.8 promotes and supports visitor accommodation in the CMC and Saved CRUDP Policy HT1 states that large hotels (of 50+ bedrooms) will only be permitted in CMC.

4.20 The emerging scheme proposes C1 (Hotel) use on the Mondial site (Zone 02). The size of a hotel in terms of floorpace or number of bedrooms is unclear at present. The way that the emerging scheme is currently constructed means that, in theory, all the floorspace in a new building or buildings on this site could be used as a hotel. However, in all probability a hotel would be provided in combination with one or more of the other proposed uses (A1, A2, A3, B1 and C3 residential).

4.21 A hotel in this highly accessible location virtually opposite East Croydon Station is in accordance with policy and guidance as is acceptable in principle, subject to servicing, drop-off/pick-up and other considerations. It would also be compatible with all of the other proposed uses that could be included in a building or buildings on this site. However, officers are keen to agree with the applicant an upper limit of C1 (Hotel) floorspace on this site, to ensure satisfactory mixed-use development.

Non-Residential Institutions (D1)

4.22 London Plan Policy 3.16 states that proposals which would result in a loss of social infrastructure in areas of defined need for the type of infrastructure without realistic proposals for re-provision should be resisted and supports enhanced facilities that help meet need. London Plan Policy 3.18 states that proposals which result in the net loss of education facilities should be resisted, unless it can be demonstrated that there is no ongoing or future demand and supports additional provision to meet growing demands.

4.23 CLP1 Policy SP5.3 states the Council and its partners will encourage the creation of healthy and liveable neighbourhoods by (b) protecting existing community facilities that still serve, or have the ability to serve, the needs of the community. Saved CRUDP Policy CS2 states that development which would lead to the loss of community facilities, including education, will not be permitted unless it has been demonstrated that there is no need for them or there are no alternative community uses which could make use of the buildings. The justifying text for CRUDP Policy CS2 makes clear that the Council will need to be satisfied that the potential for alternative community uses have been fully explored before any change of use is accepted. CLP1 Policy SP5.12 makes clear that the Council will support the growth and improvement of further and higher education in the borough and in particular seek to bring a university or ‘multiversity’ to Croydon.

4.24 The OAPF makes clear that a key part of the vision for the COA is to achieve a new university presence, preferring the concept of a ‘multiversity’ (whereby a range of further and higher education courses and qualifications is offered, possibly from a number of institutions across the borough and beyond). The Annex building forms part of site FF22 in the Masterplan which is identified for housing.

4.25 The emerging scheme would result in the loss of a significant amount of community (D1) floorspace by demolishing the Croydon College Annex (approx. 1,800sqm) and the Croydon Magistrates and Family Courts (floorspace currently unknown). The College Annex was formerly used as an art school and has been vacant since September 2012. The Courts building, on the other hand, comprise busy judicial courts dealing with criminal and children’s cases and is it is understood to have some functional links with the nearby County Court (further east along Barclay Road). It is also unclear at the moment whether St. Matthews House on George Street, which would also be demolished, includes a place of worship and this is being investigated.

4.26 Such a loss could be partially mitigated if D1 space that is proposed by way of a new building at the rear of Fairfield Halls/College Annexe site (Zones 05 and 03) and/or on the ground floor of a building facing College Walk on the multi-storey car park (Zone 03) was delivered. The proposals for these sites include the potential for between approx.12, 500sqm and 17,050sqm of D1 space. However, this space has been included in the emerging scheme to provide potential replacement space for the main College building; should the Council’s investigations lead to the College deciding to vacate this building and move to a more efficient replacement facility and so would be accompanied by potentially a further significant loss of D1 space. 4.27 With whichever development scenario comes forward, there would be a significant and as yet unquantified net loss of D1 floorspace. Such a loss would need to be considered against the relevant policies and criteria and is likely to represent a formal departure from the development plan. Such a loss would need to found acceptable in the context of the overall merits of the proposals before planning permission could be granted.

4.28 The loss of the existing College Annex building and Courts building is anticipated by the Masterplan and would help to deliver the objective of better connections to and through the area, including creating a pedestrian/cycle route between George Street and Barclay Road and facilitating a reconfiguration of College Green. Clearly the development of new high-quality teaching space that delivered an improved College offer, coupled with the conversion/re-development of the existing main College building for suitable uses, could have real benefits and deliver a key planning policy objective.

4.29 It should be noted that the D1 Use Class includes a range of education and other non-residential institutional uses including health facilities, crèches and day nurseries, schools, art galleries and places of worship.

Assembly &Leisure (D2)

4.30 CLP1Policy SP3.8 promotes and supports the development of leisure and other town centre uses within the CMC.

4.31 The emerging scheme proposes up to 180sqm of D2 space as a potential use of the proposed modest extensions to the north side of Fairfield Halls to help strengthen the Halls’ offer. This small amount of leisure space is supported by policy objectives and is acceptable in principle.

Housing

4.32 London Plan Policy 3.3 recognises the pressing need for more homes in London and makes clear that boroughs should seek to achieve and exceed their minimum housing targets (Croydon’s target being 14,348 additional homes between 2015 and 2025). Policies 2.13 and 2.15 referred to above make clear that opportunity areas and town centres should be the foci for housing delivery and intensification. London Plan Policy 3.4 states that development should optimise housing output for its location in accordance with a density matrix. The area is within a Central Location with excellent public transport accessibility and the identified indicative density range for sites with such characteristics is 650-1100 habitable rooms per hectare (hrh).

4.33 CLP1 Policy SP1.3 and SP1.4 encourage growth in homes, jobs and services in sustainable places. Policy SP2.1 states that the Council will apply a presumption in favour of development of new homes provided applications meet policy requirements and Policy SP2.2 seeks to deliver a minimum of 20,200 homes between 2011 and 2031. Saved CRUDP Policy H3 identifies mixed-use sites with a housing element in the CMC, with Sites H68 (Fairfield Halls) being allocated for 900 additional homes and H74 (College Road/George Street) being allocated for an additional 40 homes.

4.34 The OAPF supports the development of at least 7,300 homes in the COA (as also outlined in CLP1 Policy SP2.2b) and the benefits that a larger residential community would bring, in terms of helping to create a more lively and vibrant place and supporting demand for retail, leisure and other uses.

4.35 The Masterplan envisages housing being part of mixed-use development on the four sites along George Street (FF1, FF2, FF3 and FF7), the multi-storey car park (FF22) and the Magistrate’s Court (FF23).

4.36 Of all the proposed uses included in the emerging scheme, housing is likely to be the largest component, with up to 177,000 sqm of floorspace being proposed across all sites in Zones 01, 02, 03 and 04. The overall number of new homes that the proposed floorspace would deliver would depend on dwelling mix and size of homes being provided and is generally unknown at this stage. The exception to this relates to the multi-storey car park site (Zone 03) (which is mainly in detail, but partly in outline) where the applicant has advised that this element could provide between 256 and 284 homes and the Courts building (Zone 04) which the applicant has advised could provide between 137 and 157 homes.

4.37 Key relevant policy and guidance encourages additional housing on these sites. The area has excellent public transport accessibility and its character makes it suitable for a range of housing, including high density accommodation.

4.38 It should be noted that the emerging scheme would result in the loss of existing housing (6 flats) in St. Matthews House on George Street. However, whilst the likely overall number of proposed homes is unknown, it is safe to say that the emerging scheme would result in a very significant net gain in the amount of housing, making this loss acceptable in policy terms.

4.39 CLP1 Policy SP2.5 seeks to secure the provision of family housing and states that the Council aspiration for 20% of all new homes within the COA having three or more bedrooms and 35% of all two bedroom homes having four bed spaces. The OAPF indicates that developments within the Fair Field zone should aim to provide 20% of units with 3 bedrooms or more.

4.40 The Masterplan also identifies the site as suitable for a mix of new housing, including family homes on the multi-storey car park site.

4.41 The applicant is yet to propose an overall dwelling mix range for the proposed outline element of the emerging scheme, although there are emerging detailed proposals for new homes on the Phase 1 housing site (multi-storey car park site, forming part of Zone 03). These are discussed in detail below. Officers will continue to seek to ensure that the qualities of the outline element of emerging scheme, which would contain the majority of new housing, are based on housing typologies and amenity/play space that enable 20% family-sized housing.

Affordable Housing

4.42 London Plan Policies 3.10-3.13 require the maximum reasonable amount of affordable housing.

4.43 CLP1 Policy SP2.4 states that the Council will negotiate to achieve up to 50% affordable housing, with a minimum requirement within the COA of 15% for the first three financial years of the plan period post adoption and thereafter reviewed every three years in the Croydon Monitoring Report via a Dynamic Viability Model. Therefore, the first COA minimum requirement review will come into force on 1st April 2016 and the revised minimum requirement would apply to any application determined post 1st April 2016. CLP1 Policy SP2.4 also indicates a 60:40 tenure split within the affordable housing provision (between affordable rent and intermediate housing - including shared ownership).

4.44 It should be noted that the 15% minimum requirement for affordable housing in the COA set out in CLP1 Policy SP2.4 is due to be reviewed during this financial year (2015/16) and could change before a subsequent planning application is determined.

4.45 The applicant states that it intends to maximise the area’s potential contribution to affordable housing and that high-level viability assessments are currently being undertaken to inform the emerging scheme in tandem with the design process. It also confirms that an affordable housing viability statement would be submitted to support any planning application. Officers have yet to see any viability information but welcome the approach that is being taken.

4.46 The applicant also states that its current target is to deliver 30% of the homes on the multi-storey car park site (Zone 03) as ‘affordable’, including 30% as family-sized homes. Whilst the tenure and location of affordable housing on this site is not yet known, the applicant has stated that it is considering the option of the Council delivering and managing it.

Design and Townscape Layout

4.47 London Plan Policy 7.5 states that development should make the public realm comprehensible at a human scale and help people find their way.

4.48 CLP1 Policy SP4.1 states that developments should be of a high quality which respects and enhances local character and Saved CRUDP Policies UD2 and UD3 require development to be of a high quality and visually appropriate design which respects the existing development pattern.

4.49 The OAPF identifies six key principles to improve the COA’s public realm network, including creating a permeable core by breaking down large urban blocks and creating a network of high quality routes and public spaces.

4.50 The Masterplan notes that the area is currently convoluted, has complicated level issues and minimal route options that all serve to discourage people from walking and cycling. The Masterplan includes the objectives of delivering animated and well- used public realm that complements surrounding spaces and better connections to and through the area. It goes on to identify three key routes to make the overall public realm inclusive to all users and to reinforce the grid of pedestrian movement across the site. These are a link from East Croydon station to College Green, a link from Barclay Road to College Green and a link from Hazeldean Road to College Green.

4.51 Zone 1 would comprise two large buildings between George Street and College Road, with a pedestrian/cycle route between and centred on the main entrance to Croydon College (similar in location and width to the existing route). These buildings would be between 7 and 9-storey (6-8 storey frontages, with additional storeys set back) and include a continuous two-storey colonnade along the George Street and Park Lane frontages. Active ground floor uses would be provided to all frontages, with office and/or housing above.

4.52 Development in Zone 2 would be based on re-shaped landownership boundaries that would enable a single large building footprint abutting the railway line to create a 17m+ wide predominantly pedestrian/cycle route from George Street into College Green via a secondary public square. The building would be between 13 and 28 storeys high and a two-storey colonnade would be included along the George Street frontage. Active ground floor uses would be provided along George Street and the newly created route with office, housing and/or hotel space above.

4.53 Development in Zone 3 would comprise two linear buildings along the eastern perimeter of the area, adjacent to the railway line, at 8/10 and 21 storeys. Further into this Zone, two residential blocks comprising 4 and 8-storeys buildings would be developed around a residential courtyard. The northern most building would include active ground floor uses fronting the east-west pedestrian cycle route that would run along the southern side of the main College building. However, the majority of this Zone would be housing around a central courtyard and a north-south courtyard space, with the latter forming part of a pedestrian/cycle route between George Street and Barclay Road as and when Zone 04 is redeveloped.

4.54 Zone 04 comprises the existing Courts building that would be redeveloped by way of north-south linear and an ‘L’-shaped residential buildings that would complete the George Street/Barclay Road route referred to above and frame and new pedestrian/cycle route and replacement College Green space between this Zone and Zone 05 (Fairfield Halls). Buildings would be between 4 and 8-storeys.

4.55 Fairfield Halls would be refurbished and extended as summarised above. The rear service yard and ‘get-in’ at the rear (eastern end) could be partially built over with a replacement College building that would front College Green to the north and the proposed north-south route and some replacement College Green space to the east. This building would bridge over this space and land in Zone 03 to the east. Building heights are still being considered for this area and at ground and lower ground levels.

4.56 The overall layout of the emerging scheme generally complies with guidance in the Masterplan and (over time) would deliver the three key routes across the area that it identifies. The proposed ground floor uses should also ensure that there are active frontages that enliven these routes and help make sure that they are safe and attractive to use. Further work is needed on developing a practical solution for ramp access between George Street and an amended podium level, the layout of and access to the basement level and the refinement of draft parameter plans. Officers are working with the applicant to progress these and other issues.

4.57 However, the proposed inclusion of a continuous double height colonnade along the George Street and Park Lane frontages (Zones 01 and 02) needs further consideration. Whilst the Masterplan suggests that an arcade/colonnade arrangement for the East College site may allow for a more generous north-south circulation space, it does not promote a colonnade approach along other frontages.

Scale and Massing 4.58 London Plan Policies 7.4 and 7.6 state that new development should be complementary to the established local character. Policy 7.7 states that proposals for large or tall buildings should meet a number of specified criteria

4.59 CLP1 Policy SP4.5 supports high quality high density development in the COA that is tailored to and help to protect or establish local identity. Policy SP4.5 encourages proposals for tall buildings in the COA, with Policy SP4.6 setting out criteria for localities that are sensitive to them. Saved CRUDP Policy UD11 seeks to ensure that development does not have an adverse impact on designated panoramas, local views and landmarks.

4.60 OAPF identifies the area as falling within an ‘edge area’ where building heights will vary, with scope for some new tall buildings where justified and more mid-rise and infill buildings. The Masterplan provides specific guidance on scale and massing and design for each of the identified sub- areas.

4.61 It is not possible to provide comments at this stage on the acceptability of the proposed minimum and maximum parameters. Officers are working with the applicant to identify constraints and opportunities, to carry out fuller character appraisal, develop the draft development principles and use the assessment of relevant designated panoramas, local views and landmarks and other agreed views from within the area as a design tool to help determine appropriate scale and massing. The parameters that emerge from this work would also need to be tested in terms of wider environmental considerations, including daylight and sunlight, overshadowing and wind microclimate etc.

Above Ground Heritage Assets

4.62 London Plan Policy 7.8 requires the protection of heritage assets and CLP1 Policy SP4.13 states that the Council will protect and promote improvements to heritage assets and their settings (including Statutory Listed Buildings; Conservation Areas and Local List of Buildings).

4.63 Saved CRUDP Policy CS2 states that in considering schemes affecting buildings on the Local List, substantial weight will be given to the benefit of protecting and conserving the particular interest that accounts for their designation. Justifying text to this policy makes clear that where demolition is proposed, it should be demonstrated that “all reasonable attempts have been made to retain the building.” The Local List of Buildings SPD provides guidance on the interpretation of this saved policy.

4.64 The NPPF advises that the effect of an application on the significance of a non- designated heritage asset (such as a locally listed building or buildings) should be taken into account in determining the application. It goes on to state that in weighing applications that affect directly or indirectly non designated heritage assets, a balanced judgement will be required having regard to the scale of any harm or loss and the significance of the heritage asset. It goes on to state that LPAs should not permit loss of the whole or part of a heritage asset without taking all reasonable steps to ensure the new development will proceed after the loss has occurred.

4.65 Works to Fairfield Halls will need to safeguard and where possible enhance its architectural, historic, technical and townscape value. In addition, proposed development in other Zones in the area would need to safeguard and where possible enhance the setting of this building. The applicant has acknowledged that a replacement College building at the rear of the Halls presents a challenge as well as an opportunity in this respect. Officers are working with the applicant to ensure that the emerging scheme as a whole, including this potential element, fully respects the setting of this important building.

4.66 The main College building (Zone 06) is also locally listed and proposed development in other Zones needs to safeguard and where possible enhance its setting.

4.67 If the College decides to vacate its main building and relocate to a new building in the area or elsewhere, there is a presumption against its demolition. The first step in considering its future would be to determine whether it could be used in whole or in part, with alterations if necessary, for another D1 use (as discussed elsewhere in this report, policy resists the loss of existing D1 floorspace) or converted to an alternative acceptable use or uses. If this was demonstrated not to be possible, officers would want to explore whether those parts of the building that have the greatest architectural, historical, technical and/or townscape value could be retained.

4.68 Whilst not locally listed, the Arnhem Gate at the eastern end of College Walk (erected to acknowledge links between Croydon and Arnhem forged at the end of World War II) has some architectural, historical and townscape value. The Masterplan encourages the Gate to be preserved and celebrated through public realm improvements. Officers accept that the Gate could not be retained in its current location. The applicant is considering whether it is technically feasible and desirable to incorporate the Gate or elements of it within proposals for College Green.

4.69 Due to the proposed nature and scale of the emerging scheme, taller elements are likely to have an effect on the setting of nearby statutory and locally listed buildings, conservation areas and open spaces identified in paragraphs 3.12 – 3.22 above. Officers are working with the applicant to test the likely effects on key views from the surrounding area and an application would be accompanied by a Visual Impact Assessment and Heritage Statement to help the LPA and third parties consider likely effects on historic assets within the area and beyond.

Public Realm Areas and Landscaping

4.70 London Plan Policy 7.5 states that development should make the public realm comprehensible at a human scale and help people find their way. London Plan Policy 7.19 calls for development to protect and make a positive contribution towards biodiversity and Policy 7.21 seeks to protect existing trees of value, with any loss being replaced following the principle of ‘right place, right tree.’

4.71 CLP1 Policies SP4.7 and SP4.8 seek to improve areas of public realm and respect and to create local character and distinctiveness. Saved CRUDP Policy UD14 states that landscape should be an intrinsic part of the overall design concept and Policy NC4 states that the loss of trees of value should only be accepted where a development will bring significant regenerative benefits.

4.72 The Masterplan sets out detailed guidance in relation to a public realm palette of materials, lighting, landscape, wayfinding and biodiversity.

4.73 The emerging scheme would result in the loss of a number of existing mature trees. A tree survey is needed so that the health and townscape significance of these trees can be assessed and a judgement made as to whether any adjustments to building footprints should be made.

4.74 The nature of the site, with its large podium structure, is likely to be a constraint to proposals for hard and soft landscaping in this area. The emerging proposals take account of this, but officers are keen to ensure that the potential is fully explored for forest trees that ‘grow out of’ the podium as a way of ensuring good tree cover and introducing natural light into the basement area.

4.75 The character of different public realm areas needs to be defined. It is likely that all public realm areas, including College Green, will need to be multi-functional spaces that incorporate opportunities for play for children living in the proposed new homes as well as continued use of by the wider skateboarding community and for opportunities for rest and reflection.

4.76 The detailed elements of the emerging scheme should include detailed landscape proposals and appropriate parameters would need to be established for the proposed outline element. In all cases, high quality design and use of materials, lighting and street furniture needs to be secured and opportunities taken to improve the biodiversity value of the area.

College Green

4.77 London Plan Policy 7.18 states that the loss of protected open spaces must be resisted unless equivalent or better quality provision is made within the local catchment area.

4.78 CLP1 Policy SP7.2 states that the Council will protect and safeguard the borough’s local green spaces. Saved CRUDP Policy RO8 states that development on Local Open Land will not be permitted unless it is for outdoor activity or limited extension to existing facilities

4.79 In addition, the Croydon Local Plan: Detailed Policies (Preferred and Alternative Options) 2013 (CLP2) consulted on College Green being designated as a ‘Local Green Space’. The NPPF (paragraph 76) states ‘By designating land as ‘Local Green Space’ local communities will be able to rule out new development other than in very special circumstances’ which is comparable with Green Belt. Whilst the proposed designation was not objected to during the consultation, due to the early stage of CLP2 the proposed designation would currently carry very limited weight when determining applications.

4.80 The Masterplan considers the College Green as three sub-areas: Park Lane Square (FF14), College Green West (FF15) and College Green East (FF16). In doing so it makes clear that the existing ‘green’ space should be maintained and enhanced, both in terms of quantity and quality within the overall scheme and (in summary) encourages the creation of:

• A multi-functional green open space near Park Lane (FF14) between Fairfield Halls and Croydon College; • A central gathering space (FF15) as a formal entrance to the College, capable of accommodating temporary art installations, markets and performances; and • Communal space for adjacent residential development (FF16).

4.81 In addition, the Masterplan calls for a robust continuous new walkway across the entire south face of Croydon College (FF13).

4.82 The emerging scheme includes developing parts of the existing College Green Local Open Land to accommodate the following: (a) extensions to the north side of Fairfield Halls (described below) (Zone 05), (b) a new Education (D1) building that would provide replacement space for the main College building (should Croydon College decide to vacate its existing building) (Zone 03 & 05), and (c) part of the mixed-use development that would replace the multi-storey car park (Zone 03).

4.83 Over time, the proposed development could reconfigure College Green so that it includes a north-south section linking on to Barclay Road. The applicant makes clear that all of the reconfigured space would be publicly accessible and useable and that the resultant space would be no less than existing. However, it should be noted that whilst all of the relevant development is identified as falling within Phase 1, this is most unlikely to happen simultaneously. The indicative phasing for each of the three phases is five years, which suggests that there would be a temporary loss of space for up to five years.

4.84 College Green is currently an underused resource that is in need of improvement. The above approach is broadly consistent with guidance in the Masterplan and has a number of benefits, including facilitating development and helping to create a key north/south route. The proposed replacement open space would be provided adjacent to the existing College Green and its location is considered to be suitable in principle. However, to enable officers to advise the Planning Committee on the acceptability of such an approach, the following matters need to be addressed in more detail:

• Identification of areas that would need to be lost for construction purposes in addition to the proposed permanent losses; • Definition of the replacement space (to ensure that it does not include semi-public areas, such as cafe/restaurant sitting out areas): • The length of time that temporary loss is likely to last and the mechanism for ensuring that there is no net loss of space in the longer term; and • The character and quality of the proposed replacement space, with further development of concept designs.

4.85 The London Plan is the most up-to-date part of Croydon’s ‘development plan’ and as such its policies carry the greatest weight. Policy 7.18 states that the loss of protected open spaces must be resisted unless equivalent or better quality provision is made within the local catchment area. Whether the replacement open space will be equivalent or better to what would be lost is unclear at the moment.

Detailed Design of Phase 1 Housing

4.86 The Phase 1 housing site is part of the CMC2/H68 Fairfield Halls Proposals Map allocation for office/leisure/ residential with 900 additional homes (Saved CRUDP Policy H3).

4.87 The Masterplan sets out detailed guidance for sub-area FF22. This seeks a residential-led mixed use development that improves the vitality of the area and provides replacement community (D1) floorspace for that lost from the demolition of the College Annex. It encourages a mix of townhouses and apartment blocks, with any taller tower elements being located where their shadows have least impact on residential amenity and open space. It encourages access to private car parking below and servicing to be from the north and seeks an appropriate mix of surface level amenity space, play space and semi-public/semi-private space. The illustrative masterplan shows a tall tower at the north-east corner of the site, with lower courtyard buildings to the west and south.

4.88 The emerging detailed proposals are for 256 new homes, flexible A2/A3/D1 space on the ground floor of the block next to the pedestrian/cycle route that runs along the south side of the main College building and 136 car parking spaces at basement level. It is generally in accordance with guidance in the Masterplan in that it presents an active frontage to the pedestrian/cycle route, is centred on a courtyard and semi- public/semi-private space and anticipates the redevelopment of the Courts building to the south (Zone 04), including the provision of a pedestrian/cycle route on to Barclay Road.

4.89 The proposed scale and massing described above generally accords with guidance in the Masterplan. The proposal is for a range of 1 to 4-bed flats and maisonettes, including 69 x 3-bed and 6 x 4-bed homes. At 29.5%, this family-sized accommodation exceeds the 20% called for by Policy SP2.5 and is welcome. It is not yet known what percentage of the proposed 95 x 2-bed homes would have 4-bed spaces.

4.90 This detailed design of this part of the emerging scheme is at a relatively early stage and it is too early for officers to fully assess its acceptability. However, officers are working with the applicant to address a number of issues, including the public/private nature of spaces both in the short-term before the Courts building is developed and after; the location/ quantity and quality of amenity and play space; ensuring adequate separation between facing habitable rooms (the north-south blocks are currently only about 14-15m apart); the level of car parking (which at 53% is considered too high for such an accessible location); servicing and floorspace/amenity space/accessible housing standards. There is also a need for the emerging detailed scheme to be tested in terms of daylight/sunlight and wind microclimate, amongst other things.

Works to Fairfield Halls

4.91 CLP1 Policy SP3.4 states that the Council will promote the remodelling of the Fairfield Halls for its retention and on-going development as a performance facility.

4.92 The Fairfield Halls is a cultural asset synonymous with Croydon and is also of regional importance. The Council has allocated £12m from its Capital Programme over the three years 2015/16 to 2017/18 for the Fairfield Halls modernisation element of the emerging scheme, which is described in summary at the beginning of this report. Officers are working with the applicant to develop a package of proposed works which would improve the cultural and commercial offer of Fairfield Halls and safeguard and enhance this important locally listed building.

Inclusive Design, Safety and Security

4.93 London Plan Policy 7.1 calls for development to be designed and managed around the concept of ‘lifetime neighbourhoods’ and Policy 7.2 requires development to meet the highest standard of inclusive and accessible design. Policy 7.3 seeks to ensure that development designs out crime and Policy 7.13 seeks to ensure a secure environment that is resilient against emergencies.

4.94 Saved CRUDP Policy UD6 states that the Council will require that issues of safety and security are intrinsic considerations in the detailed design and layout of buildings and spaces around them and Policy UD7 expects development to be designed with ease of access as a prime consideration.

4.95 The nature of the Area, with its difference in levels and large podium and basement, presents particular challenges for creating an inclusive, safe and secure environment – some of which have been referred to in earlier sections. Officers will be working with the applicant to ensure that these issues are addressed and that appropriate types and amount of accessible housing is delivered.

Access, Movement and Parking Access and Movement

4.96 London Plan Policy 6.1 covers the strategic approach to transport across London, including encouraging patterns and nodes of development that reduce the need to travel, especially by car. Policies 6.3 and 6.11 require likely traffic effects to be fully assessed, for traffic flow to be ‘smoothed and congestion tackled and Policy 6.14 seeks to improve servicing and deliveries. Policy 6.7 promotes bus and tram networks and Policies 6.9 and 6.10 encourage cycling and walking.

4.97 CLP1 Policies SP8.3, SP8.6, SP8.7 and SP8.8 encourage patterns of development that encourage public transport, walking and cycling and improvements to Tramlink. Saved CRUDP Policies T2 and T8 require that development is not permitted if it would result in significant traffic generation which cannot be accommodated on surrounding roads.

4.98 The OAPF anticipates a comprehensive range of measures to facilitate expected growth up to 2031, including additional public transport capacity enhancements, reorganising bus standing arrangements, targeted highway interventions, improvements to walking and cycling and servicing arrangements and travel demand management.

4.99 The Masterplan includes a number of detailed movement parameters for street and basement level.

4.100 The applicant is still developing its access and movement strategy and very little detail has been submitted at this stage. College Road would remain and provide vehicular access to adjoining sites, Croydon College and the basement area to the south. The existing bridge over the railway that currently provides vehicular access to the multi-storey car park from Hazeldean Road to the east would remain, but would be adapted to provide pedestrian and cycle access only (with steps and a lift between the bridge and podium level). These features of the emerging scheme are welcome.

4.101 The existing Fairfield Hall vehicular ramp from Barclay Road would continue to provide access to the basement area but would be reduced in width from four to two lanes. Whilst this is welcomed in principle, the applicant will have to demonstrate that the proposed reduction is feasible in operational terms, including barrier faults and break-downs, and would not lead to spill over queues on Barclay Road and the Park Lane gyratory.

4.102 The proposed detailed improved servicing arrangements and coach pick-up/drop-off arrangements for the Fairfield Halls (summarised in Section 3 of this report) are welcome in principle. However, further work is needed to demonstrate that the proposed detailed arrangements meet functional requirements.

4.103 The proposed layout would allow for the creation of ground level north-south pedestrian/cycle routes between George Street and Barclay Road via College Green and the rear of Fairfield Halls and (in the longer-term) across the current Courts site. Improvements to the existing pedestrian subways under Park Lane will be required to ensure that the Area is appropriately connected with the surrounding area and officers consider that these should be included within the application Area.

4.104 The emerging strategy is generally in accordance with the OAPF and Masterplan and is welcome. However, this is a complicated area with a large basement and a number of significant changes in level. The applicant needs to further develop its strategy, particularly in relation to the following:

• Ensuring a high quality pedestrian and cycle link between George Street and basement and ground levels; • Vehicular servicing at basement and podium level, including specific routes for emergency and occasional controlled maintenance vehicles; • The role that the basement area and connecting subways would play for pedestrians and cyclists; and • Managing the difference in levels between the Hazeldean Road railway bridge and the area to the west to ensure an attractive and accessible east-west route for pedestrians and cyclists.

4.105 The emerging scheme will also increase demand for public transport and impact on Barclays Road, which forms part of the strategic road network. It is important, therefore, that the applicant fully engages as soon as possible with TfL.

4.106 It should be noted that necessary highway works secured as part of permitting the redevelopment of the (12/02542/P) is likely to require some re- modelling of the Park Lane/Barclay Road junction that could impact on the Fairfield Halls forecourt area.

Loss of Existing Multi-storey Car Park

4.107 CLP1 Policy SP8.16 makes clear that the Council will aim to reduce the overall amount of surplus car parking spaces in the COA in accordance with the OAPF parking strategy.

4.108 The OAPF sets out two scenarios for off-street public parking. The Council has adopted Scenario 2 that assumes that new major investment is likely and proposes that the overall amount of parking remains broadly as existing at around 7,150, but that it is better located to serve demand. This provides for the further reduction of 159 spaces from the Fairfield Car Park (over and above the 466 lost in 2012). In contrast, the consented Whitgift Centre scheme includes 3,530 car parking spaces; providing a net increase of about 438 spaces in the PSA. 4.109 The multi-storey car park forms part of site FF22 in the Masterplan, which identifies the site of the multi-storey car park for housing (mix of townhouses, apartment blocks and taller apartment blocks).

4.110 According to the NCP Car Parks who manage the Fairfield Car Park, it currently has 960 car parking spaces. The applicant states that the multi-storey element that would be demolished accommodates 330 spaces, meaning that 630 public parking spaces would remain. The OAPF reports on occupancy studies undertaken in 2010 and 2011 (when the car park had a total of 1,428 spaces) revealed peak occupancy of 43% during the week and 22% occupancy rate at weekends. This suggests that the public spaces that would remain under the emerging scheme would be sufficient (630 spaces for a peak demand of 614).

4.111 The multi-storey car park is unattractive and represents an underuse of an accessible site in the COA. The loss of these spaces and the redevelopment of the site for housing are acceptable in principle. However, a robust Transport Assessment will be required that takes account of other relevant development proposals. Furthermore, an up-to-date occupancy and capacity survey would also required to verify that the number public spaces that would remain would be appropriate and be consistent with the Council’s overall off-street public parking strategy for the COA.

Other Parking

4.112 London Plan Policy 6.13 sets maximum standards for car parking (but inclusive of electric charging points) and minimum standards for cycle parking. CLP1 Policies SP8.12 and SP8.13 encourage electric charging infrastructure and Policy SP8.15 encourages car-free developments in town centres with high levels of PTAL.

4.113 In addition to the multi-storey car park, there is a significant amount of other existing car parking within the Area. The table below sets out the applicant’s estimate of other existing car parking and proposed car parking that is included in the emerging scheme.

Area Other existing Proposed car car parking parking* Lower ground level parking (public & private) 833 750-800** East College site (private) 49 10-15 Mondial site (private 26 10-15 College Road (public) 34 25-34 Fairfield Halls (public) 0 4-6 942 799-870 * To include ‘blue badge’ and electric charging. ** Includes the proposed private car parking for the Phase 1 housing.

4.114 Officers will need to consider the acceptability of the proposed level and type of car parking in detail, once the emerging scheme develops and the proposed uses and quantum of development become clearer. They will also be ensuring that there is a good supply of secure and covered cycle parking spaces for occupiers and visitors, in line with relevant standards.

Amenities of Future and Adjoining Occupiers 4.115 London Plan Policy 3.5 states that new residential units should have minimum floor areas in accordance with set standards. Saved CRUDP Policy UD8 of the Croydon Plan states that external amenity space should be provided to serve new residential units at a level which is commensurate with that provided in the surrounding area.

4.116 London Plan Policy 3.6 states that new housing should make provision for play and informal recreation for children and young people. According to Housing SPG standard 1.2.2, this should at least satisfy a benchmark of 10 sqm per child.

4.117 London Plan Policy 3.8 states that all new housing should meet ‘Lifetime Homes’ standards and that 10% of new homes should be wheelchair accessible or ‘easily adaptable’. The London Housing SPG provides further details on these and other housing quality issues.

4.118 CLP1 Policies SP4.1 and SP4.2 seek to respect and enhance character to create sustainable communities. CLP1 Policy SP.2 supports the minimum standards in the Mayor of London Housing SPG and Saved CRUDP Policy UD8 states that the residential amenity of adjoining occupiers should be protected.

4.119 The OAPF aims to create a place where families are willing to live by ensuring that places are designed to accommodate children – including providing a minimum of 1,340sqm of on-site play space in the Mid Croydon and Fairfield areas.

4.120 The applicant has given a number of commitments and identified a number of development principles to inform scheme design. These include complying with minimum London Plan space standards, providing individual outdoor external spaces, ensuring dual-aspect homes facing the railway and minimising north or south-facing single aspect homes across the area, providing all homes to Lifetime Homes standards and 10% as wheelchair housing and ensuring that layout and design takes into account noise sensitive relationships between the Fairfield Halls service yard ‘get-in’, proposed commercial uses or the adjoining railway line.

4.121 These commitments and principles are welcome and officers will be seeking to ensure that these and others are followed in developing the detailed element of the scheme and are formally incorporated in to a planning application as commitments for the outline element. Following the Government’s new technical housing standards (March 2015) that include ‘optional’ standards for accessible housing, the Mayor of London has consulted on Minor Alterations to the London Plan (MALP). The MALP revise internal space standards, remove reference to ‘Lifetime Homes’ and require 90% of homes to meet Building Regulation M4(2) ‘accessible and adaptable dwellings’ and 10% to meet Regulation M4(3) ‘wheelchair accessible’ or ‘wheelchair adaptable. The Mayor has also consulted on an interim draft Housing SPG that addresses this and other issues. The Council supports the MALP standards

4.122 In providing improved servicing arrangements for the Fairfield Halls, it is important that the opportunity is taken to safeguard the amenities of existing residents on the south side of Barclay Road and future residents of proposed housing to the east. The applicant has acknowledged this and notes that works may incorporate an acoustic barrier and visual screening, depending on noise and visual assessment carried out as part of the EIA process. The development of a replacement Croydon College building would provide the potential for the enclosure of an improved service yard; something that officers support in any event. 4.123 Officers are working with the applicant over the emerging detailed proposals for the Phase 1 housing (discussed above) and will seek to ensure that the qualities of the outline element of emerging scheme, which would contain the majority of new housing, provide for acceptable residential amenity for future residents.

4.124 The EIA process will also help officers ensure that the amenities of people living in homes in adjoining streets are adequately safeguarded.

Environment and Sustainability Sustainable Design & Construction and Energy

4.125 London Plan Policies 5.2 and 5.3 state that development should minimise carbon dioxide emissions and exhibit the highest standards of sustainable design and construction. For the period 2013-2016, a reduction in carbon dioxide emissions of 40% over the Target Emission Rate in the 2010 Building Regulations is required for housing (equivalent to Code for Sustainable Homes Level 4) and a 40% reduction for non-residential uses. London Plan policy 5.5 states that boroughs should seek to create decentralised energy networks and Policy 5.6 requires development proposals to connect to an existing heating network as a first preference if one is available. London Plan Policy 5.7 encourages on-site renewable energy generation.

4.126 CLP1 Policy SP6.2 requires developments to make the fullest contribution to minimising carbon dioxide in line with the London Plan Policy and requires high density residential developments of 20 or more units to incorporate site wide communal heating systems and major development to be enabled for district energy connection. Policy SP6.3 requires new housing to comply with Code for Sustainable Homes Level 4 or equivalent and new non-residential space of 500 sqm or more to meet BREEAM ‘Excellent’ standard or equivalent.

4.127 The OAPF expects new development to help deliver and connect into a Croydon Central Area Heat and Power Scheme.

4.128 Following the Government’s new technical housing standards in March 2015, the Mayor of London has consulted on Minor Alterations to the London Plan (MALP) which would change these targets for the period 2014-2016 to 35% over the TER in the 2013 Building Regulations for both housing and non-residential uses. The Council supports the MALP standards.

4.129 The applicant has yet to develop energy, district energy, environmental sustainability or waste strategies and no commitments or details have been submitted at this stage. It is important that strategies for these important issues are developed before engaging with the GLA. Officers will be seeking to ensure that the proposed detailed elements of the emerging scheme are informed by such strategies and that appropriate parameters and commitments are developed for the proposed outline element.

Flooding and Sustainable Drainage

4.130 London Plan Policy 5.12 makes clear that proposals must comply with national requirements on flood risk and Policy 5.13 calls for development to utilise Sustainable Urban Drainage Systems (SUDS) unless there are practical reasons for not doing so. 4.131 CLP1 Policy SP6.4 requires Flood Risk Assessment for major proposals in Flood Zone 1 and the utilisation of SUDS to reduce surface water runoff.

4.132 The area is within Flood Zone 1, which is defined as having a low probability of flooding. However, because of its size, an application will need to be accompanied by a Flood Risk Assessment to demonstrate how proposals would reduce the risk of flooding, including by the incorporation of SUDS. The part of the area that comprises a large basement and podium may pose particular challenges for the incorporation of SUDS and the applicant is encouraged to develop an appropriate SUDS strategy as soon as possible.

Relationship with Alternative Schemes

4.133 There are a number of land interests within the area and the applicant is in ongoing discussions with these parties to understand their development objectives, future aspirations and timescales. The applicant aims to work with all landowners to implement a comprehensive scheme for the area. As outlined in Section 3 (Planning History), there are alternative proposals for the north-east corner of the area. The Council (as the LPA) has resolved to grant permission for major mixed-use schemes on the 101 George Street site (14/01594/P) and East College site (14/01603/P) and is holding pre-application discussions with the owners of the Mondial site on George Street (13/02223/PRE). The emerging scheme for the Mondial site was presented to Planning Committee at its meeting of 16 July 2015.

4.134 All of these alternative schemes fall within Zone 02 of the emerging scheme. At the request of officers, the applicant has shown how these alternative schemes relate with its emerging scheme, in an effort to demonstrate that (in the event that the emerging scheme for the Mondial site were also to be approved) these three schemes could, individually or collectively, be developed to sit alongside proposed development in Zones 01 and 03.

4.135 The applicant claims that its emerging scheme would provide a greater quantum of floorspace at its maximum extent for Zone 02, with lesser building heights.

4.136 CLP Policy SP1 makes clear that when considering development proposals, the Council will take a positive approach that reflects the presumption in favour of sustainable development contained in the NPPF. It is not for the Council as LPA to favour one acceptable scheme over another. The Council can and frequently does grant a number of permissions for a particular site and it is ultimately up to the market to decide which, if any, alternative acceptable schemes comes forward. The challenge here will be to manage the process and secure an acceptable outcome should the emerging scheme be permitted and part implemented alongside one or more of the approved alternative schemes, or other independent scheme(s) that may come forward in the future.

Other Matters Environmental Impacts

4.137 London Plan Policy 5.21 supports the remediation of contaminated sites and Policies 7.14 and 7.15 seek to safeguard and improve air quality and the acoustic environment. Policy 7.7 also refers to microclimate, wind turbulence and overshadowing as particular potential adverse effects associated with tall buildings.

4.138 CLP1 Policy SP6.3 requires development to positively contribute to improving air, land, noise and water quality by minimising pollution. Saved CRUDP Policy EP1 states that development that may cause or be affected by pollution of water, air or soil, or pollution through noise, dust, vibration, light, heat or radiation will only be permitted if the health, safety and amenity of users is not put at risk and the quality and enjoyment of the environment would not be damaged or put at risk. Saved CRUDP Policies EP2 and EP3 seek ensure that the land is suitable for the proposed use and that an investigation into the extent of any possible contamination is required.

4.139 Proposed development of the Area will need to be the subject of Environmental Impact Assessment (EIA). The Council will be able to use the EIA Scoping process to ensure that this assesses the likely significant effects of proposed development and helps to reduce likely adverse effects and maximise likely positive effects. There may be the need to assess a number of different development scenarios for the Area that take account of likely phasing and the potential implementation of approved alternative schemes in Zone 02.

Community Infrastructure Levy and Planning Obligations

4.140 London Plan Policy 8.2 makes clear that the Mayor will take account of economic viability when considering applications of strategic importance and expect such proposals to address strategic as well as local priorities in planning obligations. These are cited as affordable housing, Crossrail and other public transport improvements, climate change, air quality, social infrastructure and the provision of small shops.

4.141 CLP1 Section 8.1 includes Section 106 agreements as one of a number of strands for delivering the Council’s planning objectives and policies.

4.142 The Mayor of London’s Crossrail Community Infrastructure Levy (CIL) Charging Schedule sets a CIL rate of £22.97 per square metre for Croydon (excluding health, education and social housing uses). Croydon’s CIL Charging Schedule sets a CIL rate for the CMC area of £0 for residential, residential institutions and non-residential institutions (C3, C2 and D1) and £133.62 per square metre for other uses. These rates are reviewed annually.

4.143 To ensure compliance with all relevant planning policies, planning obligations will be required. It is a matter of law the Council cannot enter into a Section 106 Agreement with itself and an appropriate mechanism for securing obligations in this case is being investigated. It is too early to identify all necessary obligations, but the following are likely:

• Affordable housing; • Provision of replacement Local Open Land; • Provision of pedestrian and cycle routes; • Maintenance of public realm areas; • Distribution of land uses; • Financial contributions towards public transport improvements; • Implementation Strategy; • Local Employment Strategy; • TV Reception mitigation strategy; • No access for residents to on-street car parking permits and appropriate limitations on the use of public car parking spaces by residents and occupiers of non-residential accommodation ; and • LBC monitoring costs.

Archaeology

4.144 London Plan Policy 7.8 requires the protection of heritage assets and archaeology. CLP1 Policy SP4.13 states that the Council will protect and promote improvements to heritage assets and their settings (including Archaeological Priority Zones). Saved CRUDP Policy UC11 requires an archaeological assessment to accompany an application to develop in an APZ.

4.145 An application is expected to be accompanied by a Heritage Statement that assesses likely archaeological assets and recommends appropriate management and mitigation measures.