planning report PDU/2760/01 21 September 2011 341 Shooters Hill in the Borough of planning application no. 11/1765/F

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

The proposal Formation of a new equestrian centre including refurbishment of the existing farmhouse building, and the erection of arenas, stables, treatment centre, laboratory, classrooms, horse walker, shed yard office with parking. The applicant The applicant is Greenwich Council and the architect is Pellings.

Strategic issues The main strategic issue is whether ‘very special circumstances’ exist to justify the proposed sporting/education facilities on MOL.

Further information regarding design and transport is required.

Recommendation

That Greenwich Council be advised that the application does not comply with the London Plan, for the reasons set out in paragraph 103 of this report; but that the possible remedies set out in paragraph 104 of this report could address these deficiencies. The application does not need to be referred back to the Mayor if Greenwich Council resolve to refuse permission, but it must be referred back if the Council resolve to grant permission.

Context

1 On 15 August 2011 the Mayor of London received documents from Greenwich 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 25 September 2011 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 3D of the Schedule to the Order 2008:

page 1 ”Development (a) on land allocated as Green Belt or Metropolitan Open Land in the development plan, in proposals for such a plan, or in proposals for the alteration or replacement of such a plan; and (b) which would involve the construction of a building with a floorspace of more than 1,000 square metres or a material change in the use of such a building.” 3 Once Greenwich 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; or allow the Council to determine it itself, unless otherwise advised. In this instance if Greenwich Council resolves to refuse permission it need not refer the application back to the Mayor.

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

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

6 The 2.6 hectare site is located on the north side of Shooters Hill, approximately two kilometres south of town centre. The site is located on the A207 (Shooters Hill). The site is bound by Woodland Community Farm to the west; fields and a golf course to the north and a garden centre to the east. The site is adjacent to Oxleas Wood, which is ancient woodland and a Site of Special Scientific Interest and a Site of Metropolitan Nature Conservation Importance. The site is designated as Metropolitan Open Land (MOL), a site of Borough Nature Conservation Importance, and an Area of Special Character of Metropolitan Importance and part of the Green Chain in Greenwich’s UDP.

7 A two-storey former farmhouse and a number of smaller outbuildings such as greenhouses and sheds currently occupy the site. The farmhouse was previously used as residential flats and is now partly occupied by a charity providing facilities for adults with learning difficulties. The fields behind the house are used to keep donkeys.

8 The A207 Shooters Hill to the south, is a borough road. The closest sections of the Transport for London road network are located one kilometre south on the A2 (Rochester Road) and 1.5 kilometres to the west on the A205 Academy Road. Two bus routes directly serve the site. Rail Station is approximately 960 metres south of the site, while Woolwich Arsenal Rail Station, which provides links to the national rail and DLR services, is 2.5 kilometres north. The public transport accessibility level (PTAL) of the site is very poor and estimated at one (out of a maximum of one to six, where six is considered excellent).

Details of the proposal

9 The proposal is for an equestrian and therapy centre, to be used by Hadlow College (a further and higher education college) and commercial and community uses are also proposed.

10 The proposal includes:

 The refurbishment of the existing farmhouse to provide a tack room, reception, offices, kitchen, seminar rooms and staff accommodation;  A 60 x 20 metre indoor arena with viewing platform;  A 20 x 40 metre all weather outdoor arena;

page 2  20 stables;  Two isolation stables;  A horse therapy and treatment centre with four holding stables;  three classroom/lecture rooms and wet laboratory;  Additional outbuildings- including a horse walker, garage, yard office and hay barn;  21 car parking spaces including two accessible parking spaces  Three horsebox parking spaces, coach drop-off point and twelve cycle spaces;  Garage for tractor and 4 x 4 vehicle;  A horse crossing on Shooters Hill to enable hacking in Oxleas Wood and beyond.

11 A number of mature trees (approx 50) would be removed as part of the proposal, although no trees on the site have tree protection orders. Case history

12 A pre-application meeting was held with the applicant on 31 May 2011. Strategic planning issues and relevant policies and guidance

13 The relevant issues and corresponding policies are as follows:

 Green Belt/MOL London Plan; PPG2  Biodiversity London Plan; the Mayor’s Biodiversity Strategy; PPS9; draft PPS Planning for a Natural and Healthy Environment  Urban design London Plan; PPS1  Inclusive design London Plan; PPS1; Accessible London: achieving an inclusive environment SPG; Planning and Access for Disabled People: a good practice guide (ODPM)  Education London Plan; Ministerial statement July 2010  Sustainable development London Plan; PPS1, PPS1 supplement; PPS3; PPG13; PPS22; draft PPS Planning for a Low Carbon Future in a Changing Climate; the Mayor’s Energy Strategy; Mayor’s draft Climate Change Mitigation and Adaptation Strategies; Mayor’s draft Water Strategy; Sustainable Design and Construction SPG  Transport London Plan; the Mayor’s Transport Strategy; PPG13;

14 For the purposes of Section 38(6) of the Planning and Compulsory Purchase Act 2004, the development plan in force for the area is the 2006 Greenwich Unitary Development Plan and the London Plan (2011)

15 The Greenwich Core Strategy (Pre-Submission Stage) is also a material consideration. Principle of development/ MOL Sports facilities

16 London Plan Policy 3.20 ‘Sports facilities’ states that development proposals that increase or enhance the provision of sports and recreation facilities will be supported and the net loss of such facilities will be resisted. It also supports multi-use facilities where possible.

page 3 Additionally, the policy supports the use of floodlights where there is an identified need and no demonstrable harm to the local community or biodiversity but indicates that where sports facilities are proposed on existing open space, they will need to be considered carefully in light of policies on Green Belt and protecting open space.

17 The applicant states that the proposal for an equestrian centre on this site has evolved from a feasibility study carried out by Greenwich Council into opportunities to secure a legacy from the 2012 Olympic and Paralympic games. Part of this legacy is to provide equestrian facilities. The equestrian elements of the Olympic Games are being held in Greenwich and it is hoped that some of the equipment from the events can be re-used within the proposed facility. At the pre-application stage the applicant stated that it was in the process of securing funding towards the development from LOCOG. It is unclear from the submitted information whether or not LOCOG intends to fund the equestrian centre. LOCOG has written a letter supporting the application and it has stated that if the facilities are built in time, the centre will be used as a staging post when transporting horse to the Olympic and Paralympic venue at .

18 The applicant indicates that the centre will be as an education facility run by Hadlow College. However, it states that the facility will also offer training and support for the Charlton Riding for the Disabled team who has a centre in the Borough and that the facility will also be open to the wider community. At the pre-application stage, the applicant discussed the possibility private livery on the site, however, the details of this are absent from the planning submission.

19 The multiple use of the facilities is supported in principle but such facilities must be balanced against the impact on MOL. Furthermore, the applicant should clearly set out what the site will be used for and provide a breakdown of the level of access each group will have to the facilities, e.g. whether private horses will stabled at the facility, how many, and the level of community provision in terms of riding lessons or equestrian lessons at the college as requested at the pre-application stage. The applicant should produce a community use agreement which sets out clear commitments to community provision and this should be secured via condition.

Education facilities

20 London Plan Policy 3.19 supports the provision of education facilities to meet the demands of London’s growing and changing population and to enable greater educational choice. Policy 3.19 specifically supports developments that enhance education and skills provision. It encourages the extended or multiple use of educational facilities for community or recreational use. Part D of Policy 3.19 specifically encourages the co-location of services between schools and colleges to maximise land use, reduce costs and extend a school or college’s offer.

21 The applicant states that Hadlow College will deliver the educational part of the facility. Hadlow College of Further and Higher education is a land-based college with three sites in Kent delivering a wide range of land-based educational courses, including equestrian studies, to students aged fourteen and above. It teaches a range of courses including short courses, day release courses in conjunction with local schools for pupils in years 10 and 11 and degree level courses.

22 The applicant indicates that the centre would educate up to 62 full time pupils per year in further education Level one (such as horse welfare, basic riding and stable management); Level two (riding, husbandry and communication skills) and higher education scientific and veterinary courses. The centre would offer both full time and part time courses and students will spend one day a week at the main Hadlow College campus in Kent. Hadlow College operates

page 4 a schools link programme at its other campuses which allows pupils from local schools to attend one day a week to achieve a recognised qualification and the College intend to run a similar programme from the proposed site.

23 However, as discussed above, it is unclear how the commercial and community elements of the scheme will work in conjunction with the educational activities on the site. The applicant’s feasibility study indicates that the educational use will have priority above the community use. The applicant is required to set out how these different interests will work in reality and provide a breakdown of the level of access that each group will have and to which facilities.

24 Educational facilities are supported in principle but the benefit of such facilities must be balanced against the impact on MOL. The multiple-use of the educational facilities is also supported in principle. The applicant is, however, required to demonstrate how the educational use would operate alongside the commercial and community uses and the level of access each user will have.

Relocation of existing site users

25 The site is currently used by three different users: the farmhouse is used by a charity providing facilities for adults with learning difficulties; donkeys, which are used to provide donkey rides to children in Greenwich Park, are kept in the fields to the rear of the site by a private individual; and the strip of land to on the western side of the site is leased to the Woodland Farm Trust and is used for a local food project.

26 The applicant has stated that the existing uses will be relocated but has not given any further details. It is important that they are relocated in an appropriate way. The applicant should provide further details of where the existing users of the site will be relocated to. Furthermore, the discharge of the Councils duty under the Equalities Act needs to be engaged in considering the re-provision of the facilities for adults with learning difficulties.

MOL

27 Greenwich Council’s UDP designates the site as MOL. London Plan policy 7.17 Metropolitan Open Land (MOL) gives statutory effect to the protection of MOL on principles similar to those accorded to the Green Belt (policy 7.16). The essential features of both are their open character and permanence; and the principles that underpin their protection are well established and clearly affirmed by Central Government guidance issued in PPG2 (Green Belts).

28 The site is situated on MOL, the essential attribute of which is its openness. This national, local and strategic designation provides (in paragraph 3.4 of PPG 2) that the construction of new buildings on Green Belt (or MOL within London) is inappropriate, unless it is for one or more of the following purposes:

 Agriculture and forestry.  Essential facilities for outdoor sport and recreation; for cemeteries; and for other uses of land that preserve the openness of MOL.  Limited extension, alteration or replacement of existing dwellings.  Limited infilling or redevelopment of major existing developed sites identified in the adopted development plan.

page 5 29 Paragraph 30 of PPG17 specifically addresses sporting facilities within the Green Belt and states that “planning permission should be granted in Green Belts for proposals to establish or to modernise essential facilities for outdoor sport and recreation where the openness of the Green Belt is maintained. Development should be the minimum necessary and nonessential facilities (e.g. additional function rooms or indoor leisure) should be treated as inappropriate development. Very special circumstances which outweigh the harm to the Green Belt will need to be demonstrated if such inappropriate development is to be permitted.”

30 In July 2011 the Government published a ‘draft National Planning Policy Framework’ (DNPPF) for public consultation, which is intended to replace all existing national planning policy (PPGs and PPSs). The DNPPF maintains that inappropriate development should only be permitted where ‘very special circumstances’ exist. However, the description of development permitted in the Green Belt has been altered. The main difference relevant to this application is whereas PPG 2 refers to “essential facilities for outdoor sport and recreation”, the DNPPF refers to “appropriate facilities for outdoor sport and outdoor recreation.”

31 In this policy context and giving appropriate weight to the Government’s emerging policy direction, the proposed stables, outdoor arena and the various smaller outbuildings may be considered appropriate facilities. The refurbishment of the existing farmhouse would also be considered acceptable. However, the educational and therapy elements of the proposed development constitute inappropriate development.

32 PPG2 states a general presumption against inappropriate development on Green Belt/MOL. It states that such development should not be approved, except in very special circumstances (paragraph 3.1). However, very special circumstances to justify inappropriate development will not exist unless the harm by reason of inappropriateness, and any other harm, is clearly outweighed by other considerations. PPG2 that inappropriate development is, by definition, harmful to the Green Belt/MOL. It also places the onus firmly on the applicant to show why permission should be granted. The applicant has sought to demonstrate that the following ‘very special circumstances’ exist to justify the inappropriate development:

Olympic Legacy

33 The London Borough of Greenwich is one of the five host boroughs from the 2012 Olympic and Paralympic games. Greenwich will host nine events across three venues, including equestrian events which will take place in Greenwich Park.

34 Due to the historic and environmental nature of Greenwich Park, the equestrian facilities will be temporary and removed after the Olympics. However, the Council is keen to secure a permanent legacy from the Games which benefits residents from all backgrounds and across a number of areas including employment, health, training and social inclusion. The applicant is also keen to see a sporting legacy from the games.

35 A feasibility study carried out by the applicant states that an Equestrian Centre within the Borough could provide both the physical sporting and educational legacy for the 2012 Games that the Council would like to achieve.

36 The Council’s desire to create a high quality equestrian education facility to fulfil these aims and provide a permanent Olympic Legacy is commendable. However, as discussed above the applicant has not provide sufficient information regarding the proposed use mix or the users of the facility to demonstrate that such aims will be achieved through this proposal. The applicant should provide further information regarding the breakdown of uses on the site, the level of commercial activity on the site, the level of community access and the role of Hadlow College.

page 6 Participation in sport

37 The applicant states that the Greenwich Strategy (2006-2015) highlights the need to capitalise on the 2012 Games in terms of physical health and encouraging physical activity. The Council is keen to increase physical activity by 1%, provide sport, employment and training opportunities, engage with schools and promote sports facilities which are accessible to disabled residents.

38 The applicant states that the proposal would increase opportunities for equestrian activity in the Borough, particularly because it will be accessible to schools and riding can be offered as part of the physical education curriculum.

Education

39 The applicant states that a key objective of the proposal is to broaden the range of educational opportunities available to residents in the Borough and that the centre will provide vocational and skills training to the local community, which will be delivered by Hadlow College, an experienced provide of equestrian and land based education.

40 As discussed above, the applicant indicates that Hadlow College would operate a programme in conjunction with local schools as it does across its other sites.

Community benefit

41 The applicant states that the proposal would help achieve one of its aims to increase equestrian activity amongst the local community, particularly in target groups such as deprived socio-economic groups, children and disabled people.

42 The applicant indicates that the proposal is supported by the British Equestrian Federation (BEF) and its primary objective is for a sustainable facility which has community use as its primary focus.

43 According to the applicant, Hadlow College also plan to offer a range of community based options as part of its partnership with Greenwich Council and the BEF. This will include riding lesson for target groups as well as the general public, and also demonstrations and low/medium level competitive events.

44 Again, whilst these aims are welcomed, there is insufficient information included in the submission documented to demonstrate how all the proposed uses will work together in reality and how community use of the site will be protect given the other competing objectives of the proposed facility. For example, it is unclear how the BEF’s objective for a sustainable facility which is primarily for community use will sit along site Hadlow College requirements for an education focused facility.

Lack of alternative sites

45 The applicant’s feasibility study assesses the potential of two locations for the Equestrian Centre in significant depth. The locations considered are the proposed site and the site of a former meat abattoir which is 200 metres northeast of the Shooters Hill site. The study also considers the utilising both sites for the centre.

46 The study sets out is detail the strategic, physical and geographical, developmental and operational advantage and disadvantage of the three options. It concludes that the abattoir site is not large enough to accommodate the educational uses on the site and that spitting the centre

page 7 across the two sites would be difficult logistically. The study concludes that due to the size, accessibility and visibility of the proposal site, it is the most appropriate place to locate the centre.

47 The study adequately assesses the potential of the two sites and why the proposal site was chosen but it does not explain the rationale behind why only these two sites were investigated. Whilst it is accepted that the site must be within Greenwich, located in an area with access to open space appropriate for riding and viable for the Council to run, the applicant is required to explain the rationale and methodology used to discount other sites within the Borough.

Financial viability

48 The applicant indicates that the equine centre would provide an asset for training and employment, would be an economic asset for the Borough, and it will be a legacy for the 2012 games by supporting the health and wellbeing of horses in the south east.

49 Furthermore, the applicant states that the commercial elements of the educational and equine therapy facilities will underpin the viability of the scheme and secure the longevity of the development and, that without the equine therapy centre, the equestrian centre would not be financially viable.

50 Whilst the equine therapy facility may contribute positively to the Borough and have educational benefits, it is an unusual facility to incorporate into a community/educational equestrian centre. The applicant has not provided any information regarding the therapy centre or level of commercial activity it is likely to generate and without this information there are concerns that this commercial activity may overshadow the other appropriate uses on the site that it is intended to enable. Furthermore, the applicant has not provided any financial information to support its assertion that the equestrian facility would not be viable without the therapy centre. The applicant is required to provide further information regarding the therapy centre and provide financial information supporting its assertion that the equestrian centre is unviable without the commercial revenue from the therapy centre.

Openness of MOL

51 Further to making a case for special circumstances, the applicant should indicate how the redevelopment will impact on the openness of the MOL. The site is occupied by a farmhouse (529 sq.m.) which is located towards the front of the site. Whilst there are no other permanent buildings on the site, there are a number of temporary, relatively large structures, such as greenhouses and storage sheds on the eastern portion of the site and in the middle of the site and significant hard standing. The fields to the north of the site have never been developed and will remain open as part of the current proposal.

52 The applicant is proposing eight new structures on the site with a total footprint of 3,005 sq.m. and the existing farmhouse with a footprint of 529 sq.m. will be retained. The built footprint on the site will therefore increase from 2% to 13.8% of the total site area.

53 The applicant has provided wire line visualisation of the proposal from various views but this is insufficient to assess the impact of the proposal on the surrounding MOL. The applicant should provide accurate visual representation of the impact of the proposal on views into the site.

Summary

54 In conclusion, the applicant’s aim to provide a multi-use facility providing high quality education and community facilities as an legacy for the 2012 Games is supported in principle, however, it is unclear how all the elements of the scheme will work together, and very little

page 8 information has been submitted by the applicant to demonstrate the extend of the commercial activities that will take place on the site and how so many competing uses will function together in reality. It is a concern that the community elements of the scheme may be overshadowed by the educational and commercial side of the development. The current submission does little to ensure the community benefits will continue in perpetuity and the facility will not become a solely commercial facility. The applicant should secure the educational community benefits offered by Hadlow College and a minimum amount of access to the site by the wider community in a community use agreement.

55 Furthermore, the benefits of the proposal must be weighed against the impact on MOL. The proposed stables, outdoor arena and the various smaller outbuildings may be considered appropriate facilities. The refurbishment of the existing farmhouse is also acceptable. However, the equine therapy centre and classrooms are inappropriate development on MOL and the applicant has sought to demonstrate ‘very special circumstances’ exist to justify harm by reason of inappropriateness to MOL.

56 Without further information regarding how all uses contained within the centre will function together it is difficult to assess the very special circumstances arguments put forward regarding the Olympic legacy, increasing participation in sport, education and community benefit. In terms of the lack of alternative sites, the applicant is required to explain the rationale and methodology behind choosing this site and why other sites within the Borough were discounted. In addition, financial information supporting its assertion that the equestrian centre is unviable without the commercial revenue from the therapy centre should be provided. Furthermore, without accurate visual representation of the impact of the proposal on views into the site, it is difficult to assess the impact of the proposal on the openness of the MOL.

57 Further information is required to determine whether the proposal complies with London Plan Policy 7.17 and whether the principle of the development is acceptable. The applicant should submit further information regarding: the nature and extent of commercial activities on the site; how the different function will work together in reality; a community use agreement; further details of where the existing users of the site will be relocated to; the rationale and methodology behind choosing the site and why other sites were discounted; financial information supporting its assertion that the equestrian centre is unviable without the commercial revenue from the therapy centre; and accurate visual representation of the impact of the proposal on views into the site. Biodiversity

58 The site is within the , Shooters Hill Golf Course, Dothill Allotments and Woodlands Farm Site of Borough Importance for Nature Conservation and is adjacent to the Shooters Hill Woodland Site of Metropolitan Importance for nature conservation and the Oxleas Wood Site of Special Scientific Interest.

59 London Plan policies indicate that such sites should be given protection commensurate with their importance. London Plan policy also sets out that if development is permitted the following hierarchy should apply: avoid adverse impact to the biodiversity interest: minimize impact and seek mitigation; only in exceptional cases where the benefits of the proposal clearly outweigh the biodiversity impacts, seek appropriate compensation.

60 London Plan Policy 7.21 ‘Trees and woodlands’ states that existing trees of value should be retained and any loss as the result of development should be replaced following the principle of ‘right place, right tree’. Furthermore, wherever appropriate, the planting of additional trees should be included in new developments, particularly large canopied species.

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61 Oxleas Wood Site of Special Scientific Interest has been identified in the London plan as a Site of Metropolitan Importance. However, the proposed development itself would not have any direct adverse impact on the site as the woodland is separated from the development site by a busy road. The development might result in horses being exercised and/or ridden in Oxleas Wood and this activity in Oxleas Wood could contribute to increased trampling and damage to the woodland understory. Therefore, the use of the wood by horses and riders should be regulated and permitted routes identified and enhanced to obviate any adverse impact on the woodland.

62 Although part of a Site of Borough Importance, the development site itself comprises the grounds of a former farmhouse and the current nature conservation interest of the site consists primarily of the presence of mature trees and regeneration scrub. These provide a valuable, albeit not critical, part of the ecological interest of the surrounding area. The development proposals include provision for landscaping and planting to strengthening of the wildlife corridors adjacent to the site. The landscaping proposals are consistent with London Plan Policy.

63 The proposals broadly comply with London Plan policies 7.19 ‘Biodiversity and Access to nature’ and 7.21 ‘Trees and woodlands’ in respect of site protection.

Urban design

64 Good design is central to all objectives of the London Plan, in particular the objective to create a city of diverse, strong, secure and accessible neighbourhoods to which Londoners feel attached whatever their origin, background, age or status. Policies contained within chapter seven specifically look to promote development that reinforces or enhances the character, legibility, permeability and accessibility of neighbourhoods by setting out a series of overarching principles and specific design policies related to site layout, scale, height and massing, internal layout and visual impact.

65 The site and surrounding area is characterised by its rural setting. Shooters Hill, the main route through the area is lined with trees enclosing the public realm on both sides and providing glimpses of the farm, golf course and park beyond. The layout, height and massing of the proposed development should aim to enhance and preserve this.

66 As outlined in the pre-application report, existing development on the site successfully enhances the areas character by having a single building set back approximately 25 metres from the street and screened with a plethora of trees and planting. Only small glimpses of the building are seen from the public realm and its setting is in a soft landscaped garden, isolated from other development. This character should be preserved and further information to illustrate this is required.

67 The location of the proposed development at the rear of the existing building is supported. This allows the area between to road and the buildings to continue to act as a visual buffer, screening new buildings and maintaining the rural character of the area. Visualisations from the public realm illustrating how effective this strategy will be once the new car-parking and servicing arrangements are put in place should be provided to ensure the approach will be effective.

68 The pre-application report raised the lack of clarity in how the area between the indoor arena and the road is to be used and suggested it be used for grazing. This is still encouraged as the presence of horses would contribute to the rural character of the area and provide a clear indication of the use of the site.

page 10 69 The size and scale of the indoor arena is likely to make it the most visible of the new buildings and the more critical in terms of visual impact. It is also the building that extends the closest to the main road. A clear strategy of how the visual impact of this building will be mitigated form the public realm should be provided. The pre-application report requested more information on the types of planting, the elevational treatment and the materials used. Whilst some of this information has been provided it is still unclear what the visual impact of the indoor arena will be on the public realm, 3d visualisations illustrating materials and planting is required.

70 The materials used for the surfacing of the car parking and the internal roads will play a significant role in the character of the development and its impact on the surrounding area. Soft and natural materials should be used as an alternative to asphalt and tarmac to enhance the rural nature of the area. The current materials proposed are unclear. Further information on their visual impact is required.

71 Further information is required to determine whether the application complies with London Plan design policies. The applicant should provide the additional information regarding materials, the use of the open space fronting onto Shooters Hill and the visual information requested.

Inclusive design

72 Inclusive design principles if embedded into the development and design process from the outset help to ensure that all of us, including older people, disabled and deaf people, children and young people, can use the places and spaces proposed comfortably, safely and with dignity. The aim of London Plan Policy 7.2 is to ensure that proposals achieve the highest standards of accessibility and inclusion (not just the minimum). The design and access statement should therefore explain the design thinking behind the application and demonstrate how the principles of inclusive design, including the specific access needs of disabled people, have been integrated into the proposed development and how inclusion will be maintained and managed. Furthermore, educational establishments have a duty under the Equalities Act 2010 to ensure that their facilities and services are accessible for disabled students.

73 As the centre will offer training and support to the Charlton Riding for the Disabled team based in the Borough, it is essential that the highest levels of inclusive design and accessibility are achieved. At the pre-application stage, a number of suggestions were put forward to make the scheme more accessible and inclusive. In the current submission, the applicant has broadly addressed all of the point raised.

74 The applicant has illustrated the number of blue badge parking bays on the plans. Furthermore, the gradients of the routes to the reception, office, classrooms, stables and to both the indoor and outdoor arenas and the arrangements for disabled people to view the activities in the indoor arena are also clearly shown on plans.

75 The raised viewing platform within the indoor arena will double as a raised platform to facilitate mounting and dismounting for disabled riders.

76 The design and access statement states that the residential accommodation meets Lifetime Home standards but that it is not ideal for a wheelchair user to use the accommodation as the bathrooms cannot be adapted for wheelchair use.

77 The applicant has consulted the Greenwich Association of Disabled People Centre for Independent Living, Oxleas Trust and Riding for the Disabled Association. The Greenwich Association of Disabled People Centre for Independent Living has written a letter supporting the principle of the development and requesting further consultation regarding the design. It is

page 11 unclear whether this consultation has taken place. Oxleas Trust has also written a letter supporting the development and stating its interest in being a non-financial partner in the centre.

78 As discussed at the pre-application stage, the applicant has now included a fully accessible changing facility on the ground floor of the farmhouse and incorporated a platform lift into the existing building to allow inclusive access to the upper floors.

79 The applicant states that as the proposal is an Olympics legacy project rather than an Olympics facility, it is not required to meet the ODA’s inclusive design standards or LOCOG’s access file standards.

80 The changes to the scheme are welcomed and go a significant way to addressing the issues raised at the pre-application stage. The application broadly complies with London Plan Policy 7.2.

Climate change

81 The London Plan climate change policies set out in Chapter 5 collectively require developments to make the fullest contribution to the mitigation of, and adaptation to, climate change, and to minimise carbon dioxide emissions. London Plan Policy 5.2 ‘minimising carbon dioxide emissions’ sets out an energy hierarchy for assessing applications, London Plan Policy 5.3 ‘Sustainable design and construction’ ensures future developments meet the highest standards of sustainable design and construction, and London Plan Policies 5.9-5.15 promote and support effective adaptation to climate change. Further detailed policies on climate change mitigation and adaptation are found throughout Chapter 5 and supplementary guidance is also given in the London Plan sustainable design and construction SPG.

Energy efficiency standards

82 A range of passive design features and demand reduction measures are proposed to reduce the carbon emissions of the proposed development. Heat loss parameters will be improved beyond the minimum backstop values required by building regulations. Other features include variable speed pumps, time controls and energy efficient lighting.

83 Through energy efficiency alone, the new build element of the development is estimated to achieve a reduction of 3 tonnes per annum in regulated CO2 emissions compared to a 2010 Building Regulations compliant scheme.

District heating

84 The applicant has investigated whether there are any existing or planned district heating networks in the vicinity of the development; however, this did not reveal any opportunities. The main part of the new development is unheated with only the education centre (244 sq.m.) requiring heating. Additionally, the existing building is some distance from the new building, so the applicant is not proposing a site heat network due to the relatively small loads and large distances involved. This is accepted in this instance.

Combined Heat and Power

85 As the intended use of the buildings will not provide an all year round demand for heating or hot water, the use of combined heat and power is not proposed. This is accepted in this instance.

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Cooling

86 No active cooling is planned for the new development. The only active cooling required on site will be for the server room in the existing building. The applicant should provide further information on the passive measures that will be adopted to avoid the need for active cooling.

Renewable energy technologies

87 For the new building 34 sq.m. of photovoltaic panels is proposed. A roof drawing showing the proposed location of the photovoltaic panels has been provided. A reduction in regulated carbon dioxide emissions of two tonnes per annum (12%) will be achieved through this third element of the energy hierarchy.

88 The applicant is also proposing to install an additional 17 sq.m. of photovoltaic panels to contribute to reducing the carbon emissions of the existing building, providing a further one tonne reduction in carbon dioxide emissions.

Summary

89 The estimated regulated carbon emissions of the new build development are 14 tonnes of carbon dioxide per year after the cumulative effect of energy efficiency measures and renewable energy has been taken into account. This equates to a reduction of 5 tonnes per year in regulated emissions compared to a 2010 Building Regulations compliant development, equivalent to an overall saving of 25%.

90 The application complies with London Plan Policy 5.2. The energy strategy should be secured via condition.

Transport

91 Having considered the transport assessment submitted by the applicant and given the scale, nature and location of the proposals, it is accepted that the estimated number of trips generated by the proposed development is unlikely to have a significant impact on either the highway network or public transport services.

92 21 car parking spaces are proposed on site, of which two would be designated blue- badge parking bays. In addition to this, parking is to be provided for one coach and three horse boxes. This is appropriate given the site’s low PTAL and the nature of the proposed uses.

93 Whilst there are no specific parking standards for equestrian centres in the London Plan, the applicant should consider the provision of electric vehicle charging points (both active and passive provision) as part of the proposals.

94 The 16 cycle parking spaces for general use are welcomed. However, the applicant should ensure that at least 2 cycle parking spaces are designated for use by the permanent residents of the development and that all cycle parking is secure, covered and easily accessible.

95 The submission of a Full Travel Plan is welcomed and meets the required criteria to comply with London Plan Policy 6.3 ‘Assessing Effects of Development on Transport Capacity’. The travel plan should be formally secured via condition.

page 13 96 Whilst there is no objection to the introduction of a proposed Pegasus crossing, linking the bridle paths on either side of the A207, the applicant needs to be aware that such arrangements could require large maintenance costs and that further advice should be sought from TfL Directorate of Traffic Operations prior to any implementation. Should this application be granted planning permission, the developer and their representatives are reminded that this does not discharge the requirements under the Traffic Management Act 2004. Formal notifications and approval may be needed for both the permanent highway scheme and any temporary highway works required during the construction phase of the development.

97 The applicant should provide a delivery and servicing plan, in line with the London Plan Policy 6.14 ‘Freight’, to be secured via condition. This should outline the expected volume of deliveries and encourage the use of off highway delivery and collection, along with reducing the number of vehicles, and off peak use.

98 Similarly, a construction logistics plan, as referred to in London Plan Policy 6.14 ‘Freight’, which identifies efficiency and sustainability measures to be undertaken while developments are being built, should also be submitted to and approved by Greenwich Council, in consultation with TfL, before construction work commences on site. The submission of a delivery and servicing plan and a construction and logistics plan should be secured via appropriate planning conditions.

99 Whilst TfL does not object to the principle of the development, further information is required in order to comply with the transport policies of the London Plan. Further information regarding electric vehicle charging points and the Pegasus crossing is requested. In addition, a delivery and servicing plan and a construction and logistic plan should be prepared and secured via condition, along with the travel plan.

Local planning authority’s position

100 The local planning authority’s position is unknown. Legal considerations

101 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. 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

102 There are no financial considerations at this stage. Conclusion

103 London Plan policies on are relevant to this application. The application complies with some of these policies but not with others, for the following reasons:

page 14  Principle of development: Further information is required to determine whether the proposal complies with London Plan Policy 7.17 and whether the principle of the development is acceptable.

 Biodiversity: The proposals broadly comply with London Plan policies 7.19 and 7.21 in respect of site protection.

 Urban design: Further information is required to determine whether the application complies with London Plan design policies.   Inclusive design: The changes to the scheme are welcomed and go a significant way to addressing the issues raised at the pre-application stage. The application broadly complies with London Plan Policy 7.2.

 Climate change: The application complies with London Plan Policy 5.2. The energy strategy should be secured via condition.

 Transport: Whilst TfL does not object to the principle of the development, further information is required in order to comply with the transport policies of the London Plan.

104 On balance, the application does not comply with the London Plan. The following changes might, however, remedy the above-mentioned deficiencies, and could possibly lead to the application becoming compliant with the London Plan:

 Principle of development: The applicant should submit further information regarding: the nature and extent of commercial activities on the site; how the different function will work together in reality; a community use agreement; further details of where the existing users of the site will be relocated to; the rationale and methodology behind choosing the site and why other sites were discounted; financial information supporting its assertion that the equestrian centre is unviable without the commercial revenue from the therapy centre; and accurate visual representation of the impact of the proposal on views into the site.

 Urban design: The applicant should provide the additional information regarding materials, the use of the open space fronting onto Shooters Hill and the visual information requested.

 Transport: Further information regarding electric vehicle charging points and the Pegasus crossing is requested. In addition, a delivery and servicing plan and a construction and logistic plan should be prepared and secured via condition, along with the travel plan.

for further information, contact Planning Decisions Unit: Colin Wilson, Senior Manager – Planning Decisions 020 7983 4783 email [email protected] Justin Carr, Strategic Planning Manager (Development Decisions) 020 7983 4895 email [email protected] Gemma Kendall, Case Officer 020 7983 6592 email [email protected]

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