planning report PDU/2685/01 12 October 2010 Mayesbrook Park,

in the London Borough of Barking and Dagenham planning application no. 10/00804/FUL

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

The proposal Erection of community sports centre and new changing rooms (floor space 8,922 sq.m.), two external multi-purpose courts, associated facilities, landscaping; car parking; highway works and demolition of existing changing rooms, spectator seating, redundant football clubhouse, and redundant public toilets. The applicant The applicant is Ebbsfleet Community Sports Centre Ltd, and the architect is LRK Associates

Strategic issues The applicant has demonstrated that there are very special circumstances which justify the harm the proposal will have upon the Metropolitan Open Land.

Further information is required in relation to climate change and transport, to ensure compliance with strategic planning policy.

Recommendation

That Barking and Dagenham Council be advised that while the application is generally acceptable in strategic planning terms the application does not comply with the London Plan, for the reasons set out in paragraph 54 of this report; but that the possible remedies set out in paragraph 55 of this report could address these deficiencies. The application does not need to be referred back to the Mayor if Barking and Dagenham Council resolve to refuse permission, but it must be referred back if the Council resolve to grant permission.

Context

1 On 13 September 2010 the Mayor of London received documents from Barking and Dagenham 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 22 October 2010 to provide the Council with a statement setting out whether he considers that the application complies with the London Plan,

page 1 and his reasons for taking that view. The Mayor may also provide other comments. For this application the Mayor has delegated his planning function to Sir Simon Milton, Deputy Mayor for Policy and Planning. This report sets out information for the Deputy Mayor’s use in deciding what decision to make.

2 The application is referable under Categories 3C, 3D, 3E and 3F of the Schedule to the Order 2008:

 3C “Development which is likely to prejudice the use of a playing field of more than 2 hectares of land.”

 3D “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;”

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

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

3 Once Barking and Dagenham 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 Barking and Dagenham Council resolves to refuse permission it need not refer the application back to the Mayor.

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

5 The application site lies within the 45 hectare Mayesbrook Park, located in Dagenham, to the north of Upney underground station and south of Longbridge Road (A124). Mayesbrook Park was created to provide open space for Housing Estate built by , who presented the site to Barking Council in 1934. The park consists of a children's play area; football pitches (including Barking Football Club’s ground); cricket pitch and pavilion; athletics track; tennis courts; basketball court; boating lake with workshop and a fishing lake. The surrounding area is predominantly residential.

6 The application site covers 4.2 hectares of the park, towards its northern edge and adjacent to the athletics track. It currently consists of a group of buildings associated with the football club; disused public toilets and a car park, all located to the north east of the athletics track, together with to the south side of the track, a car and coach park; basketball courts; hockey pitch; ‘adizone’ fitness area; football pitch; athletics changing facilities and the athletics track stand.

7 Mayesbrook Park is designated as Metropolitan Open Land. The site sits within the northern section of Mayesbrook Park which is bounded by Lodge Avenue, a borough road, to the east. The site is also bounded to the east by the rear garden boundary of the residential properties to Lodge Avenue and to the west by Mayes Brook. In close proximity are the A13 Alfred’s Way,

page 2 1.5km south of site and the A124 Longbridge Road, 500m north of site. Upney and Becontree Underground stations are located 1.4km and 1.5km from the site respectively, and while they both offer services on the District Line, they are not considered to be within an acceptable walking distance of the site. There are also five bus routes located within 650m of the site, although not all of these are within what TfL would consider to be an acceptable walking distance. This generates a public transport accessibility level (PTAL) of 2, on a scale of 1-6 where 1 is low and 6 is high.

Details of the proposal

8 The application proposes the demolition of existing buildings (1038 sq.m.) and replacement of the existing pitches and the construction of a community sports centre and new changing rooms (total floor space 8,922 sq.m.); two external multi-purpose courts and associated facilities and landscaping; car parking; highway works and a relocated ‘adizone’ fitness area.

9 The community sports centre element has been selected as a preferred ‘games time training venue’ for the 2012 Olympic and Paralympic Games. The arena will be used as for handball training during the Olympic Games and for judo and rugby for the Paralympics. After the Games the facility will revert to a general sports and leisure facility. It will be operated as a private leisure facility housing a wide variety of sports and will sit alongside the two all weather outdoor courts which are proposed to be free for public use. The applicant propose that the facility will become a community resource on offer to all elements of the local population from the ages of 5 to 90 and state that it will have close links to local schools. The arena and associated car park will be bordered to the south by a landscaped berm.

10 In addition to the above the applicant proposes new replacement football changing rooms to the northern part of the site alongside a formalised car park. Case history

11 None. Strategic planning issues and relevant policies and guidance

12 The relevant issues and corresponding policies are as follows:

 Urban design London Plan; PPS1  Regeneration London Plan; the Mayor’s Economic Development Strategy  Parking London Plan; the Mayor’s Transport Strategy; PPG13  Green Belt/MOL London Plan; PPG2  Playing fields London Plan; PPG17, draft PPS Planning for a Natural and Healthy Environment  Biodiversity London Plan; the Mayor’s Biodiversity Strategy; PPS9; draft PPS Planning for a Natural and Healthy Environment  Access London Plan; PPS1; Accessible London: achieving an inclusive environment SPG; Planning and Access for Disabled People: a good practice guide (ODPM)  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

page 3  Tourism/leisure London Plan; Good Practice Guide on Planning for Tourism (DCLG)

13 For the purposes of Section 38(6) of the Planning and Compulsory Purchase Act 2004, the development plan in force for the area is the 2010 Core Strategy, the Barking and Dagenham Unitary Development Plan 1995 and the London Plan (Consolidated with Alterations since 2004).

14 The following is/are also (a) relevant material consideration(s):  The draft replacement London Plan, published in October 2009 for consultation.  The Borough Wide Development Policies and Proposals Map submission stage (June 2009). Metropolitan Open Land and the principle of development

15 London Plan policy 3D.10 (Metropolitan Open Land) gives statutory effect to the protection of MOL on principles similar to those accorded to the Green Belt (policy 3D.9). 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) and RPG9 (Regional Planning Guidance for the South East). These principles are reinforced in policies 7.16 (Green Belt) and 7.17 (Metropolitan Open Land) of the Mayor’s consultation draft replacement London Plan.

16 Mayesbrook Park is entirely designated as Metropolitan Open Land, the essential attribute of which is its openness. This national, regional and local 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.

17 PPG2 states that there is 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. The national planning guidance clarifies 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.

18 Whilst the proposed replacement changing facilities and revised outdoor sports pitches are of a scale and function that are appropriate to MOL land (the replacement changing facilities cover 1039 sq.m. whilst the existing facilities cover 199 sq.m.), the scale of the proposed sports arena falls outside the range of acceptable uses, as defined by PPG2, the London Plan and UDP policy. The only possible justification to allow this proposal would be if ‘very special circumstances’ could be demonstrated. There is no definition of ‘very special circumstances’ in the PPG and each planning application has to be judged on its own merits.

page 4 19 In this instance, the ‘very special circumstances’ are that the facilities are going to be a vital component of the forthcoming Olympic and Paralympic Games in 2012 and as post-Games legacy, providing an internal standard community sports facility for the local community. The facility would be one of the games time training venues located in and around London which will be used by athletes to help them train and make final preparations immediately prior to and during the London 2012 Olympic and Paralympic Games. Athletes will use the centre from the beginning of July 2012 when they move into the Athletes Olympic Village until the close of the Paralympic Games. The centre would then revert back to its use as a general leisure centre.

20 In order to achieve the status of a games time training venue, a facility has to meet strict criteria including a requirement to be no more than 30 minutes drive from the Olympic Village. Further, the requirement for the handball training facility is to provide a building capable of accommodating four handball courts, equating to a hall size of circa 100 x 50m with a clear height of 9.2m. The Mayesbrook proposal will be the only new build games time training venue.

21 It is understood that this venue was chosen by the Olympic Delivery Authority (ODA) and the London Organising Committee of the Olympic Games (LOCOG) after an extensive site serach exercise considering alternative locations within the required 30 minute radius, none of which were capable of satisfying all of the criteria set out by the International Olympic Committee (IOC). The only Olympic sized handball facility being available within this area, ‘Score’ in Leyton, has been secured solely for the use of the USA olympic team.

22 The precise post games operation of the sports arena is unclear from the information submitted, that is except as a multi-purpose leisure centre, suitable for a variety of sports and encompassing an extensive gym. The applicant does state that there is keen interest from a range of national sporting bodies ready to use the centre but no further evidence for this is given. The applicant has however stated that, “Community use is enshrined in the terms of the lease and the proposed S106 agreements for the site” (Barking and Dagenham Council are the landowners). The detail of this, such as pricing and time and length of community use must be secured in the section 106 agreement.

23 There is no doubt that the construction would have a materially greater impact on the openness of the Green Belt than the present situation. To mitigate against this the applicant is proposing extensive landscaping works, including the introduction of a 3 metre high berm to the south of the sports arena topped by trees. This and other measures should assist in minimising the negative visual impact of the sports arena and maintain the perception of openness which is central to the enjoyment of Green Belt.

24 This proposal will also enhance the environment around the immediate area of the arena, creating additional landscaping and new fencing to the rear of the Lodge Avenue residential properties, and providing general improvements such as upgrading the hard surfacing and the car park adjacent to the football club. Accordingly, the overall environment created by this proposal would represent an improvement on the existing by removing the existing dilapidated changing rooms, toilet and track side stand and replacing them with new facilities, whilst also enhancing safety through natural surveillance and CCTV (identified by local residents as key drawback to the use of the park through the Mayesbrook restoration project) and hopefully encourage public use. This in some way mitigates against the impact of the new buildings on the openness of the Green Belt in encouraging greater access to green space and recreation.

25 A planning application to improve Mayesbrook Park, part of the Mayor’s ‘Help a London Park’ is expected to be submitted soon, the aspiration being to restore the park to ensure greater safety and to provide more attractions and amenities. The application will incorporate the opening up of Mayes Brook from its concrete channel, its realignment and the creation of marsh and

page 5 wetland areas; extensive tree planting; ground modeling to introduce a variety of levels and viewing mounds and the creation of more formalized garden and recreational areas. To reflect this the landscaping to the south of this proposed scheme has been tied in to reflect the overall Mayesbrook Park restoration scheme. Integration between the proposal and the park improvement project should be secured during both the construction and operation phases. A commitment in this regard by the applicant should be sought.

26 On balance, it is considered that there are in this instance very special circumstances which overcome the presumption against inappropriate development of MOL. The provision of Olympic Times Training Venues are an essential component of London’s hosting of the Olympic and Paralympic Games, providing athletes the training facilities they require for this global sporting event. The lack of suitable and accessible (in particular handball) facilities in the city or its surrounds would serve to undermine the quality of these Games to the detriment of London and the rest of the UK.

27 Notwithstanding the above the applicant has designed a scheme which will improve the environment in the vicinity of the arena and serve to encourage greater public use of the park and its facilities. Moreover, it will provide the local community and this part of London with an international sports facility which has regeneration benefits and will be accessible to all sections of the community, serving to increase participation in sport and physical activity. The security that the local community will benefit from the new facilities as drafted in the s106 and the lease provides greater assurance that this centre will have a lasting legacy in east London.

Urban Design

28 Good design is central to all objectives of the London Plan and is specifically promoted by the policies contained within Chapter 4B which address both general design principles and specific design issues. London Plan Policy 4B.1 sets out a series of overarching design principles for development in London. Other policies in Chapter 4B and elsewhere in the London Plan set out design requirements relating to specific issues. The draft replacement London Plan reinforces these principles, with new development required to have regard to its context, and reinforce or enhance the character, legibility and permeability of the neighbourhood (Policy 7.1).

29 This application proposes the re-configuration of the open space and buildings within the site. The purpose of which is to provide a larger sports complex for the Olympics. The building is shielded behind newly proposed landscaping and is also located behind some existing residential homes. In this regard, whilst the proposed building is larger than the existing buildings on site, the impact of the building on views across the site from the surrounding area is kept to a minimum. The issues of development on MOL have already been discussed in the previous sections of this report.

30 The proposed building design is simplistic and functional and has been designed to accommodate the needs of the sporting facilities. The building adopts a terracotta green tile for the upper part of the building with some windows of varying sizes and location that achieve an interesting design feature. The success of the building will be dependent of the detailed design and materials, and it is important that these be secured by planning condition.

31 However, along the ground level of the building there is limited attempt to achieve a similar level of interest or ground level activity, which is disappointing. It is recommended that the applicant should propose a higher quality material for the base of the building and that further detail on this should be secured by an appropriate planning condition.

page 6 32 In the interest of encouraging way finding on the site the scheme introduces a large, highly glazed entrance, which is a welcome addition to the front elevation of the building.

33 The proposed building location retains the ability for north south movement within this area of MOL, which is supported.

Access

34 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 4B.5 is to ensure that proposals achieve the highest standards of accessibility and inclusion (not just the minimum).

35 The scheme includes 16 blue badge accessible car parking spaces, which is welcomed. Each changing room will be designed with a wheelchair accessible changing room/shower facility and a disabled toilet. Changing rooms will also incorporate specially designed lockers for wheelchair access. All doors within the development will be 1200 mm wide to accommodate sports wheelchairs. In addition, all facilities, including the bar and refreshment areas, are designed to provide unrestricted access. In addition, communication aids will be installed through the building and measures incorporated for the visually impaired. The proposed inclusive design measures are welcomed. Climate Change mitigation

Energy efficiency standards

36 ‘A range of passive design features and demand reduction measures are proposed to reduce the carbon emissions of the proposed development. Both air permeability and heat loss parameters will be improved beyond the minimum backstop values required by building regulations. Other features include energy efficient lighting and heat recovery from air handling units.

37 It is not clear from the information provided whether or not the development will exceed 2010 Building Regulations compliance through energy efficiency alone. Using 2010 Building Regulations compliance software, the applicant should model, and commit to, measures that can be adopted to enable the development to exceed 2010 Building Regulations compliance through energy efficiency alone. The applicant should also provide a table comparing the proposed values for energy efficiency parameters to those used in the 2010 Building Regulations notional building.

38 The applicant should provide the annual regulated carbon dioxide emissions after energy efficiency measures have been applied.

BE CLEAN

District heating

39 The applicant has investigated whether there are any external district heating networks in the vicinity of the development. However, no networks are close to site. Given the low density nature of the surrounding area, it is accepted that, in this case, the potential for connecting to an external network is likely to be low.

page 7 40 The heating for the sports hall will be provided through air handling units; however, the heat source for their heater batteries is unclear. The applicant should clarify how the heat for the air handling units will be provided.

41 Heating to other areas, such as changing facilities, ancillary spaces and recreation areas, will be provided via low temperature hot water underfloor heating.

Combined Heat and Power

42 A 200kWe CHP plant will be installed to contribute to the domestic hot water and space heating demands of the development. The applicant should provide load profiles illustrating the sizing of the CHP. The annual regulated carbon dioxide emissions of the development after the incorporation of CHP should also be provided.

Cooling

43 Shading devices/features have been incorporated within the design of the building. Low emissivity glazing will also be adopted to minimise the active cooling requirement. The applicant should provide further details of how the residual active cooling demand will be met.

BE GREEN

Renewable energy technologies

44 The applicant is proposing the installation of 175 sq.m. of photovoltaic (PV) panels sited above the main entrance canopy. This is projected to reduce emissions by 2%. Given the lack of compatibility between solar thermal and CHP, the applicant should investigate whether additional roof space could be allocated to PV. The panel area allotted to PV should be secured by condition. A 30kW ground source heat pump is also proposed to contribute to the heating of the changing rooms. The applicant should provide further details of how this be effectively controlled in collaboration with the CHP. The annual regulated carbon dioxide emissions of the development after the incorporation of renewable energy should also be provided.

Overview

45 Using 2010 Building Regulations compliance software, the applicant should estimate the regulated emissions after all proposed measures have been applied and the overall savings in regulated emissions compared to a 2010 compliant development. Climate Change adaptation

46 The London Plan promotes five principles in policy 4A.9 to promote and support the most effective adaptation to climate change. These are to minimise overheating and contribution to heat island effects, minimise solar gain in summer, contribute to flood risk reductions, including applying sustainable drainage principles, minimise water use and protect and enhance green infrastructure. Specific policies cover overheating, living roofs and walls and water. Chapter 5 of the draft replacement London Plan considers climate change adaptation.

47 The applicant has confirmed that water conservation measures will be given high priority in the construction. Such measures should be conditioned. The applicant should also explore the provision of green roofs and walls where feasible.

page 8 Transport

48 In light of the nature of the proposed development, it is accepted that the likely impact of the proposals on both the public transport and the strategic highway network will be limited. The London Plan does not include parking standards for D2 uses, however TfL considers the provision of 205 car parking spaces (including 96 spaces retained from the existing use) to be in general conformity with car parking standards provided within Planning Policy Guidance 13: Transport. TfL questions whether this level of provision is necessary given the specific characteristics of the car trip generation figures presented in the Transport Assessment, and would recommend that the number of spaces is reduced, in accordance with the predicted peak level of demand. TfL requires the applicant to provide on-site electric vehicle charging points in accordance with the Mayor’s Electric Vehicle Delivery Plan and policy 6.13 of the draft replacement London Plan.

49 TfL supports the provision of 56 cycle parking spaces along with changing facilities for staff and visitors, as compliant with London Plan cycle parking standards. These spaces should be provided in a secure location, and given the peak period for visitors will be in the evening, TfL would expect that good lighting is provided in all the cycling parking areas. TfL notes that although coaches can drop off passengers at the lay-by provided, there is no proposed dedicated on-site coach parking space. TfL therefore advises that the applicant provides a designated coach parking bay on the site or identifies, with the permission of the operator, nearby coach parking spaces off-site that can be used by this development. This is to ensure general conformity with London Plan policy 3C.23 ‘Parking Strategy’ and draft replacement London Plan policy 6.13 ‘Parking’. In addition, the travel plan could secure a booking system whereby a coach can be booked to use one of the drop-off areas as a parking bay for its duration of stay.

50 In accordance with London Plan policy 3C.25 ‘freight strategy’, and draft replacement London Plan policy 6.14, ‘Freight’, this development should be supported by a construction logistics plan and a delivery and servicing plan, both of which should be secured by use of planning condition. A development of this size would also need to be supported by a travel plan, which should be produced in line with TfL’s ‘Guidance for workplace travel planning for development’ (March 2008). A full travel plan should be provided prior to occupation of the development and should be secured, managed, monitored and enforced through an s106 agreement. Local planning authority’s position

51 Not known. Legal considerations

52 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

53 There are no financial considerations at this stage.

page 9 Conclusion

54 London Plan policies on metropolitan open land; community facilities; urban design; inclusive access; climate change and transport are relevant to this application. In general, the application complies with these policies, for the following reasons:

 Metropolitan Open Land: The applicant has demonstrated that in this instance, a very special circumstance exists to provide an essential facility for the London 2012 Olympic and Paralympic Games and one will also have a positive legacy for all sections of the local community.

 Community uses: A detailed strategy for the community use of the facilities must be demonstrated and secured in the section 106 agreement.

 Urban Design: The proposed building design is simplistic and functional in keeping with its use. The impact of the building on local views will not be significant given the location and the proposed landscaping. The success of the building design will be dependent on the detailed design and materials.

 Access: The design is fully inclusive in keeping with London Plan aspirations.

 Climate Change: The approach is generally supported although further detail is required.

 Transport: As set out in the main body of this report. 55 Notwithstanding that the application complies with the London Plan, it would be improved by the following changes:

 Climate Change: Further detail is required as set out in paragraphs 35 to 46 of this report.  Transport: As set out in the main body of this report.

for further information, contact Planning Decisions Unit: Colin Wilson, Senior Manager - Planning Decisions 020 7983 4783 email [email protected] Justin Carr, Strategic Planning Manager (Development Decisions) 020 7983 4895 email [email protected] Paul Roberts, Case Officer 020 7983 4317 email [email protected]

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