QUOD Planning Statement
Land adjacent to Cockfosters Underground Station June 2021
Contents
Executive Summary ______1 Introduction ______7 Site Description and History ______8 Consultation ______14 Description of Proposed Development ______20 Planning Policy Context ______27 Planning Considerations ______45 Conclusions ______103 Appendix A: Housing Design Standards Checklist ______105 Appendix B: Draft Heads of Terms ______108 Appendix C: Education Impacts ______109 Appendix D: Environmental Impact Assessment Screening Opinion ______110
Quod | Land adjacent to Cockfosters Underground Station | Planning Statement | June 2021 1
1 Executive Summary
Introduction 1.1 Connected Living London (Cockfosters) Ltd (the ‘Applicant’) is submitting a full planning application to the London Borough of Enfield (LBE) on land adjacent to Cockfosters London Underground Station (the ‘Site’) for the following:
‘A residential-led mixed use scheme comprising residential dwellings (Class C3), a flexible ground floor unit (Class E and/or uses previously Class A4 (Sui Generis)), replacement Train Drivers’ Accommodation (Sui Generis), cycle parking, public realm and open space, car parking, hard and soft landscape works, access and servicing arrangements, plant, and associated works’ (the ‘Proposed Development’).
1.2 Connected Living London (CLL) is a partnership between Transport for London (TfL) and Grainger plc, the UK’s largest listed provider of private rental homes. This partnership will boost the number of new homes available across London, whilst also generating revenue, which TfL will invest in the capital’s transport network.
1.3 The Proposed Development would provide housing that would make a significant contribution towards the Mayor of London’s strategy for increasing the supply of new housing, in line with both national and local policy. Support in the London Plan for the redevelopment of car parks and public sector owned sites makes this location suitable for housing to contribute towards LBE’s projected housing need of 1,246 homes per year over the next 25 years.
1.4 The Proposed Development would positively influence the health of Londoners by improving the environment in which they live, providing well designed healthy homes, promoting active travel, improving air quality and contributing to vibrant neighbourhoods.
1.5 The Proposed Development has embedded sustainable design and is consistent with LBE’s Climate Action Plan (2020) and the National Planning Policy Framework (2019) (NPPF). The Proposed Development would contribute to local green infrastructure through new planting, green roofs and a net gain in tree coverage which all support biodiversity and reduce the urban heat island effect. The layout of the Proposed Development employs passive design strategies to reduce energy consumption and seeks to connect to the local District Heating Network which is an efficient system for minimising energy demand whilst also using solar photovoltaics as a source of energy. The Proposed Development would be resilient to anticipated severe weather and long-term climate change impacts through measures such as a drainage strategy which includes extensive use of sustainable drainage features. The homes target a 4 Star Home Quality Mark, ensuring the Proposed Development secures best practice sustainability standards.
1.6 The Proposed Development accords with the objectives of the Development Plan and the NPPF as well as other relevant material considerations in relation to sustainable development by:
• redeveloping a public sector brownfield site, currently occupied by surface car parks with poor quality public realm;
Quod | Land adjacent to Cockfosters Underground Station | Planning Statement | June 2021 2
• providing homes that are highly accessible and directly adjacent to existing public transport connections and easily accessible to local amenities and by sustainable travel modes; • providing a range of housing to support a mixed and balanced community; • respecting the local natural and built environment by providing buildings that appreciate the heritage setting, increase the amount of open space and vegetation and are sensitively designed in response to the local context.
Site Overview 1.7 The Site is located to the east and south of Cockfosters London Underground Station (the ‘Station’) and the Piccadilly Line railway tracks in the London Borough of Enfield (LBE). It comprises two car parks and a London Underground Ltd (LUL) staff and Train Drivers’ Accommodation (TDA) building. The Site is currently in use as a public car park and car wash, providing 407 spaces, 37 of which are for LUL staff and train drivers and 12 of which are for Blue Badge holders. The Site extends to 1.36 hectares (ha) and comprises two triangular shaped areas; one to the east of the station (Site A) of 1.15 ha and one to the south (Site B) of 0.21ha.
1.8 The A111 Cockfosters Road lies adjacent to the west of the Site and vehicle access is located at two points, one either side of Cockfosters London Underground Station.
Site A 1.9 Site A is approximately 1.15ha in size and is located to the east of the Station and the Piccadilly Line railway tracks (which are orientated northwest-southeast). Site A is currently in use as a car park providing 322 spaces and 12 spaces for Blue Badge holders. An additional 25 spaces are provided for LUL associated staff. A two-storey LUL staff and Train Drivers’ Accommodation building is located along the western boundary within Site A. A triangular vegetated area within the northern section of Site A is designated as Priority Habitat (deciduous woodland) and Local Open Space. Vehicle, cycle and pedestrian access is provided from the A111 Cockfosters Road just to the north of Cockfosters London Underground Station.
Site B 1.10 Site B is located adjacent to the south of the station and fronts onto the A111 Cockfosters Road, opposite an existing parade of shops. It is approximately 0.21ha in size and is currently in use as a hand car wash and a car park. The car park contains 48 spaces, 12 of which are for LUL staff. Vehicle, cycle and pedestrian access to Site B from the A111 Cockfosters Road is located towards the south of Site B.
Site Surroundings 1.11 The context of the area surrounding the Site is mixed in nature, with the commercial and residential centre of Cockfosters extending to the south and west of the Site and open space to the north.
1.12 The Station is Grade II listed, and the boundary of Trent Park Conservation Area - which excludes the Station - runs through Site A. Site A sits within an Area of Special Character associated with Trent Park and an Area of Archaeological Importance. Adjacent to the Site and demarcated by the northern and eastern boundaries is designated Green Belt which
Quod | Land adjacent to Cockfosters Underground Station | Planning Statement | June 2021 3
incorporates Trent Park. The historic landscape of the Grade II registered Park and Garden of Trent Park lies around 150m north of the Site.
1.13 Site A is bound to the north and east by belts of mature trees along the boundary of the adjacent cemetery and within Trent Park. To the east of Site A is an area designated as a Site of Metropolitan Importance for Nature Conservation, and to the south west of Site A, running along the edge of the railway tracks is a designated Site of Borough Importance for Nature Conservation. A wildlife corridor runs along the railway tracks near to the Site. Two trees with Tree Preservation Orders (TPOs) are found to the north of the entrance to Site A, within the garden of 120 Cockfosters Road. Along the northern boundary runs the London Outer Orbital Path (LOOP), a footpath extending the perimeter of outer London. The access to this footpath is taken from within Site A, opposite the northern entrance to the station.
1.14 Development along the A111 Cockfosters Road generally comprises office development interspersed with ground floor retail use with residential properties above. The Station building and Site B form part of the Cockfosters Local Centre designation which incorporates the high street along Cockfosters Road. The buildings along the high street are predominantly between two and five storeys in height interspersed with taller elements. Adjacent to the south west of the Site is a nine-storey building known as Blackhorse Tower. There is a resolution to grant planning permission for proposals to extend Blackhorse Tower by an additional storey, bringing it up to ten storeys (31.5m above ground level) and for additional floorspace fronting Cockfosters Road. The Blackhorse Tower application has been considered cumulatively in the context of the Proposed Development.
Proposed Development 1.15 The Proposed Development would comprise 351 units of Build-to-Rent accommodation in four buildings. The Pavilion (Block 1, Site A) would comprise 88 units, Station Mansion (Block 2, Site A) would comprise 94 units, Trent Mansion (Block 3, Site A) would comprise 107 units, and Station House (Block 4, Site B) would comprise 62 units. There would also be a flexible use (Class E and/or uses previously Class A4 (Sui Generis)) ground floor unit of 209sqm and a public cycle hub of 60 cycle spaces proposed to be located within Block 4 fronting Cockfosters Road. The existing Train Drivers’ Accommodation (TDA) would be re-provided at ground and lower ground floor level within Block 3.
1.16 Within Site A, the Proposed Development would create new areas of publicly accessible open space and public realm at the entrance to the Site and the LOOP (LOOP Place), as well as a new area of public realm on Site B, around the secondary pedestrian access points to the Station (Station Court).
1.17 The Proposed Development includes 40% affordable housing (by habitable room) amounting to 132 affordable units and comprises homes at a combination of Discounted Market Rent (DMR) and London Living Rent equivalent levels. The remainder of the homes would be for open market rent. The Proposed Development would include residential amenity areas such as a residents’ lounge, concierge and gym for use by all residents. All residents would have access to a 318sqm terrace on the roof of Block 2, and 3,950sqm of outdoor amenity space would be publicly accessible to all at ground level, including 300sqm of doorstep play for 0-5s, 250sqm of play space for 5-11 year olds and a further 650sqm of incidental play space for all ages. 80sqm of play space for the 12+ age group is provided on site, with further provision off- site within Trent Park.
Quod | Land adjacent to Cockfosters Underground Station | Planning Statement | June 2021 4
1.18 The residential development would be car free, with parking provided only for Blue Badge holders. 11 Blue Badge residential spaces are proposed (3% of the total number of homes), 9 on Site A and 2 on Site B, with the landscape scheme having been designed to allow for this provision to be extended by 24 residential Blue Badge spaces (10% in total, or a further 7%) up to 35 spaces in total, should the demand arise.
1.19 The Site would also provide a total of 47 publicly accessible car parking spaces on site A. This comprises 35 general use spaces and reprovision of the existing 12 Blue Badge spaces. A drop off/pick-up area comprising 7 spaces in close proximity to the station entrance and the new step-free access to the station would also be provided. One Blue Badge car parking space is proposed for LUL staff. A designated car club bay is also proposed for use by residents and the local community.
1.20 In order to encourage sustainable travel, and in line with London Plan requirements, the Proposed Development includes 597 long stay cycle parking spaces to be provided within the buildings (secure and covered) and 9 residential short stay cycle parking spaces to be provided outside the buildings. An additional 60 spaces are proposed to be provided within a public cycle hub adjacent to the station entrance on Site B, aimed predominantly at users of the Station.
1.21 Some existing back of house and operational areas, such as bin storage for the Station, are proposed to be relocated to accommodate a new public realm fronting onto Cockfosters Road, creating a more open and welcoming space around the Station. The Proposed Development would create new public spaces on both Site A and Site B, including new tree planting, soft landscape and public realm areas and seating. These works would improve this section of the footway along Cockfosters Road and enhance the setting of the Station. The entrance for pedestrians and cyclists into the London Outer Orbital Path (LOOP) is currently obscured and poorly signposted in this location. The public realm proposals for Site A would enhance the legibility of the LOOP and connections to Trent Park through the layout of the public realm and new signage.
The Application 1.22 The application seeks full planning permission for the Proposed Development.
1.23 The legislative and policy context makes it clear that local planning authorities should determine development proposals in accordance with the development plan when taken as a whole unless material considerations indicate otherwise. The NPPF paragraph 11 requires that ‘Plans and decisions should apply a presumption in favour of sustainable development. For decision-taking this means: c) approving development proposals that accord with an up-to- date development plan without delay…’
1.24 Pursuant to paragraph 11d) (and footnote 7) of the NPPF, Development Plan policies are considered out-of-date where, inter alia, the Housing Delivery Test finds that the delivery of housing in the Local Planning Authority (LPA) area was substantially below (less than 75% of) the housing requirement over the previous three years. The Housing Delivery Test figures issued by MHCLG in January 2021 confirmed that LBE is now ‘a presumption authority’. Therefore, in accordance with the NPPF, paragraph 11(d) footnote 7, the LBE policies most important for determining this application are out-of-date by virtue of the under delivery of
Quod | Land adjacent to Cockfosters Underground Station | Planning Statement | June 2021 5
housing in LBE over the past three years. Thus the ‘tilted balance' in paragraph 11d)ii of the NPPF is engaged.
1.25 An EIA Screening request was submitted to the LBE on 4 October 2019, and its response confirmed that the Proposed Development would not give rise to significant effects on the environment, such that there is no requirement for an EIA, having regard to the Town and Country Planning (Environmental Impact Assessment) Regulations 2017 (the ‘EIA Regulations’) (as amended). There is, therefore, no requirement for an Environmental Statement to accompany the application.
1.26 This Planning Statement is accompanied by the following technical reports:
• Design and Access Statement (Hawkins\Brown and Mae Architects, Jonathan Cook Landscape Architects) • Application Drawings (Hawkins\Brown and Mae Architects, Jonathan Cook Landscape Architects) • Housing Delivery Statement (Quod) • Viability Assessment Report (Savills) • Heritage Statement (Alan Baxter) • Townscape and Visual Impact Assessment (Alan Baxter) • Statement of Community Involvement (Concilio) • Health Impact Assessment (Quod) • Equality Statement (Quod) • Daylight and Sunlight Assessments (Internal and External) (GIA) • Air Quality Assessment (Atkins) • Noise and Vibration Assessment (Atkins) • Sustainability Statement (Atkins) • Energy Assessment (Atkins) • Detailed Circular Economy Statement (Aecom) • Phase 1 Geotechnical and Geoenvironmental Desk Study Report (Atkins) • Ecological Impact Assessment and Biodiversity Net Gain Assessment (Atkins) • Transport Assessment (Pell Frischmann) including: • Draft Outline Construction Logistics Plan • Car Parking Design and Management Plan • Servicing and Delivery Management Plan • Travel Plan • Flood Risk Assessment (Atkins) • Drainage Strategy (Atkins) • Arboricultural Impact Assessment and Method Statement (Atkins)
Quod | Land adjacent to Cockfosters Underground Station | Planning Statement | June 2021 6
• Fire Statement (Hoare Lea) • Wind Microclimate Desk Based Assessment (Urban Microclimate) • Archaeological Desk-Based Assessment (Atkins)
Conclusions 1.27 Paragraph 38 of the NPPF requires Local Planning Authorities to ‘approach decisions in a positive and creative way’. Decision-makers should seek to approve applications for sustainable development where possible.
1.28 This Planning Statement and accompanying reports and drawings demonstrate that the Proposed Development would represent sustainable development and accord with the development plan as a whole and, as such, benefits from the statutory presumption as set out in section 38(6) of the Planning and Compulsory Purchase Act 2004. It is therefore respectfully requested that planning permission should be granted without delay in accordance with the presumption in favour of sustainable development set out at paragraph 11 of the NPPF.
Quod | Land adjacent to Cockfosters Underground Station | Planning Statement | June 2021 7
2 Introduction 2.1 This document has been prepared by Quod on behalf of the Applicant who is submitting a full planning application to the LBE as the Local Planning Authority (‘LPA’) for the Proposed Development.
2.2 The purpose of this Planning Statement is to assess the Proposed Development of the Site against the development plan as well as other material considerations including national planning policy and relevant legislation. It provides an overview of the Site, its designations and the planning policy context. In particular, this document identifies and describes the key opportunities presented by the Proposed Development of the Site, which is currently in use as surface car parking, LUL staff and TDA building and a car wash. This Planning Statement also provides a comprehensive analysis of the relevant planning policy framework at national, strategic and local levels.
2.3 Section 7 of this Planning Statement provides a comprehensive assessment of the Proposed Development against the Development Plan and other relevant material considerations.
2.4 A series of project objectives have been established which underpin the Proposed Development, namely:
• to maximise the supply of housing; • to optimise and make efficient use of brownfield public sector land; • to deliver 40% affordable housing (by habitable room); • to create Healthy Streets; • to promote sustainable travel choices and provide car-free residential development; and • to deliver sensitive and sustainable design 2.5 This Planning Statement is structured as follows:
1 Executive Summary 2 Introduction 3 Site Description and History 4 Consultation 5 Description of the Proposed Development 6 Planning Policy Context 7 Planning Considerations 8 Summary and Conclusions
Quod | Land adjacent to Cockfosters Underground Station | Planning Statement | June 2021 8
3 Site Description and History
Site and surroundings 3.1 The Site is located at the northern terminus of the Piccadilly Line at the Station within the London Borough of Enfield. Site A to the north of the railway is used for car parking and houses a modular building used by LUL staff. Site B, to the south of the railway tracks, is smaller and used as a car park and car wash, which is currently obscured from the street by advertisement hoardings.
3.2 Between Site A and Site B lies the Piccadilly Line tracks and the Station, which opened in 1933 and was designed by Charles Holden, an architect who designed many of the underground stations constructed during that time. The Station was listed at Grade II in 1987.
3.3 Much of the commercial and residential areas of Cockfosters including Cockfosters Local Centre were built during the 1930s, this growth was catalysed by the arrival of the Station, representing an opportunity for suburban development. However, the establishment of the Metropolitan Green Belt in 1948 curbed further expansion north, leaving the Station unexpectedly isolated on the very edge of London’s urban border. This Green Belt designation is still in place today, directly adjacent to the northern and eastern boundaries of Site A.
3.4 Trent Park which is designated as a Grade II Registered Park and Garden is located 150m to the north of Site A. The Trent Park Conservation Area, within which Site A falls, historically comprised the Trent Park Estate, centred on Trent Park House and the special character and the appearance of the Conservation Area is strongly related to the surviving estate. Site A is also located within a designated Area of Special Character which encompasses the Trent Park Conservation Area, and an Area of Archaeological Importance.
3.5 To the east of Site A, the parkland is designated as a Site of Metropolitan Importance for Nature Conservation. A designated Site of Borough Importance for Nature Conservation lies to the south west of Site A, along the edge of the railway tracks. The tracks themselves are within a designated Ecological Corridor, which runs south along the railway line.
3.6 A small area of Site A (approx. 815sqm) forms part of a designated area of Local Open Space. The part of the Local Open Space that is within the Site is not easily accessible and generally comprises poor quality vegetation. It has been assessed for its ecological and arboricultural value as part of the evolution of the Proposed Development. In both instances, ecological and arboricultural value were found to be low.
3.7 The Site falls within an Air Quality Management Area (AQMA) which applies across the borough. The Site is entirely located within Flood Zone 1, meaning that there is a low flood risk.
3.8 The Site has a moderate to good Public Transport Accessibility Level (PTAL) of 3 and 4. It is also adjacent to a section of the LOOP which can be accessed from Site A, opposite the Station entrance and which runs along the boundary to the north of Site A before cutting into Trent Park. Site B is located within the designated Cockfosters Local Centre (see figure 6 below).
Quod | Land adjacent to Cockfosters Underground Station | Planning Statement | June 2021 9
3.9 In summary, the following planning designations and constraints have been identified on the Site:
• Site A is located partially within the Trent Park Conservation Area and Area of Special Character; • Site A is located within an Area of Archaeological Importance; • the Site is within an Air Quality Management Area; • part of Site A is designated as ‘Local Open Space’ (approx. 815sqm) • the Site has a PTAL rating of 3 and 4; and • Site B is located in the Cockfosters Local Centre. 3.10 The following planning designations and constraints have been identified adjacent to the Sites:
• the Site is located within the setting of a Grade II Listed Building (the Station); • the Site is located within the setting of the Trent Park Grade II Registered Park and Garden; • to the north and east, adjacent to Site A, is land designated as Green Belt; • the Site is adjacent to a ‘Site of Metropolitan Importance for Nature Conservation’, Site of Borough Importance for Nature Conservation and Wildlife Corridor; and • the Site adjoins the ‘LOOP’.
Figure 1: Trent Park Conservation Area (purple outline)
– Site to south west (red line boundary indicative) Figure 2: Archaeological Priority Area and Area of Special Character (grey stripes); Listed Building (yellow dot); Registered Park and Garden (red outline) (red line boundary indicative)
Quod | Land adjacent to Cockfosters Underground Station | Planning Statement | June 2021 10
Figure 3: Green Belt boundary (red line boundary Figure 4: Local Open Space (red line boundary indicative) indicative)
Figure 5: SMINC (red), SBINC (green), Wildlife Corridor (brown squares) (red line boundary indicative) Figure 6: Local Centre (blue) (red line boundary indicative)
Cockfosters Local Centre Health Check 3.11 Cockfosters is identified as a Large Local Centre in LBE’s Local Plan evidence-based document ‘A Study of Town Centres’ (2007). It is located 6km to the west of Enfield Town and is primarily a linear centre along Cockfosters Road running south from the Station.
3.12 At the time of our Site visit (June 2019), the local centre contained approximately 92 retail/commercial units and one vacant unit (representing approximately 1.09% of units). The vacant unit was formerly A2 use (Santander Bank). The centre was busy on the day of the Site visit, which provides a strong indicator of the health of the centre.
3.13 LBE’s ‘A Study of Town Centres’ (2007) states that in 2007 Cockfosters had 79 retail/service units (excluding non-retail Class A uses) which has since increased as evidenced by our visit
Quod | Land adjacent to Cockfosters Underground Station | Planning Statement | June 2021 11
in June 2019. The centre has a lower proportion of comparison retail uses when compared with the national average (GOAD, 2005 as referred to in the Study of Town Centres 2007). The proportion of convenience retailers is higher than the national average. The proportion of A2 service uses and Class A3/A5 uses are also higher than the national average and the proportion of A1 service uses is slightly lower than the national average. There are no pubs in the centre and the overall vacancy rate is 0.
Type of Unit Number of Units Proportion of Total Number of Units (%) Comparison Retail 18 20% Convenience Retail 16 17% Other A1 Services 11 12% A2 Services 8 9% A3 & A5 29 32% A4 0 0% D1 Services 3 3% Sui Generis 7 7% Services Vacant 0 0% Total 92 100 Table 1: Cockfosters Local Centre Use Class Mix by Unit (June 2019)
3.14 In 2019, the key multiple retailers in the centre are Co-op (now permanently closed) and Sainsbury’s Local with secondary retailers, such as Fio’s Continental Foods and the butchers and fishmongers. The comparison shopping offer is strong for a local centre and provides residents with a choice of fashion and homeware alternatives, despite not being a main shopping destination.
3.15 Cockfosters has a significant proportion of A3 units, including cafes, restaurants and takeaways, and also provides a range of other key retail and service facilities including post office services, dry cleaners, banks and estate agents. B1 and B2 units are minimal but Metro Point (1a Chalk Lane) and Churchwood House (Cockfosters Road) host B1 office space. This latter site is subject to a planning application (16/04133/FUL) which makes provision for residential, ground floor flexible units and a hotel.
3.16 Trent Church of England Primary School is located to the west of the local centre on Chalk Lane. Oaktree School (Special Educational Needs) is also located to the south of Cockfosters. The Southgate School, a comprehensive secondary school, lies to the east. Cockfosters Medical Centre on Heddon Court Avenue serves local residents.
Planning History 3.17 The following sets out the applications relevant to the Site and the surrounding area.
3.18 An Environmental Impact Assessment Screening Opinion Request was submitted on behalf of the Applicant in respect of the Proposed Development on 4 October 2019 (reference 19/03416/SO). The response from LBE confirmed that the Proposed Development, although
Quod | Land adjacent to Cockfosters Underground Station | Planning Statement | June 2021 12
constituting a Schedule 2 Development, would not be ‘EIA development' and, therefore, does not require an Environmental Statement because it is considered the Proposed Development:
• would not be of more than local importance; • would not involve development in a particularly environmentally sensitive or vulnerable location; • would not give rise to unusually complex and potentially hazardous environmental effects; and • there are no other relevant matters that would suggest significant adverse effects.
Train Drivers’ Accommodation Building 3.19 P14-00931PRI - Erection of a 2-storey building to provide train crew facility together with provision of associated car parking and ancillary works - Prior approval was granted in April 2014 for this development and the building is in situ within the Site, including the provision of staff car parking.
Cockfosters Station 3.20 18/04894/LBC – Listed Building Consent for the installation of lift shaft and canopy (approved February 2019) and 19/00016/P18PA – Approval of lesser works for installation of lift shaft and canopy (approved March 2019) – This is located within the secondary exit to the Station that leads directly into Site A. Works are now completed.
3.21 Other applications for listed building consent for minor works including replacement of non- original platform lights with heritage lighting, installation of card readers, leaflet rack, alterations to kiosk, and the installation of display screen, have been submitted and approved over the last 15 years as part of a series of works to refurbish the listed station interior as well as bringing it up to modern standards.
Recent adjacent schemes
Blackhorse Tower, Holbrook House and Churchwood House 3.22 Blackhorse Tower lies to the south of Site B and is currently an office building (Use Class E).
3.23 A number of applications for residential use of Blackhorse Tower have been submitted to LBE. In 2017, an application (REF: 16/04133/FUL) for change of use to residential (164 units) including an additional storey received resolution to grant by LBE’s Planning Committee.
3.24 The proposals involve basement and surface car parking, refurbishment of Blackhorse Tower and the addition of an extra floor which will provide 88 residential units. Holbrook House and Churchwood House will be demolished, and two new blocks will be constructed, one of 7 storeys (44 residential units) and one of part 7, part 4 storeys (part 64-bed hotel, part 32 residential units with flexible uses at ground and first floor levels). The proposals involve an increase in height by one storey to the existing 9 storey building. The existing building is 124m AOD and this would increase to 127.9m AOD.
Quod | Land adjacent to Cockfosters Underground Station | Planning Statement | June 2021 13
3.25 A number of prior approval applications for change of use from office to residential have since been submitted, along with an application for planning permission for external works to the building (Ref: 20/04025/FUL) which was refused in March 2021 and an appeal has now been lodged. It is understood that none of the prior approvals have yet been implemented and the building remains a vacant office building.
3.26 Whilst there is no extant or approved scheme that is currently being implemented, it is acknowledged that Blackhorse Tower may become a residential building in the future and that LBE has agreed to the principle of an additional storey of development.
Trent Park Cemetery 3.27 15/03331/FUL – Change of use from amenity grassland to lawn cemetery extension to south east of existing cemetery – LBE granted permission for this development in 2016. This site is located to the east of the Site and works are underway.
120 Cockfosters Road 3.28 18/01952/FUL - Erection of part single, part 2 storey, building with a basement level to provide offices, together with courtyard, associated landscaping and parking – The building was the former Trent Boys School House, and the application was approved by LBE in 2018 with the works currently underway.
Former Middlesex University Trent Park 3.29 Two applications were submitted to LBE, one for full planning permission (16/04324/FUL) for the phased redevelopment of the site to provide 262 residential units with museum, café and leisure uses. This was accompanied by listed building consent applications for the demolition of extensions to Mansion House and to the Orangery involving restoration (16/04375/LBD). The approvals for both applications were issued by LBE in October 2017 and works are underway.
Quod | Land adjacent to Cockfosters Underground Station | Planning Statement | June 2021 14
4 Consultation
Introduction 4.1 This section of the Planning Statement focuses on pre-application engagement with LBE and other statutory and non-statutory consultees. This application is also accompanied by the following reports that provide additional details of pre-application engagement:
• Statement of Community Involvement (Concilio, June2021); • Design and Access Statement (Hawkins\Brown, Mae and JCLA, June 2021); • Heritage Statement (Alan Baxter, June 2021); and • Transport Assessment (Pell Frischmann, June 2021). 4.2 LBE’s Statement of Community Involvement (2015) recommends that pre-application consultation undertaken by a developer should comply with the principles and approach of community involvement set out in the document. The approach to consultation for the Proposed Development has followed these principles as set out in the Statement of Community Involvement (Concilio) accompanying this application.
4.3 Paragraph 39 of the NPPF outlines that early engagement has significant potential to improve the efficiency and effectiveness of the planning application system for all parties. The Planning Practice Guidance (Paragraph: 007 Reference ID: 20-007- 20140306) encourages democratically elected members to participate at the pre-application stage and encourages pre-application engagement with the community where it will add value to the process and outcome (Paragraph: 010 Reference ID: 20-010-20150326).
4.4 The Applicant has undertaken extensive consultation and engagement activities throughout the pre-application phase of design development of the Proposed Development with statutory consultees and other key stakeholders. This engagement has taken place early in the process (as recommended by paragraph 39, NPPF) and has been agreed through a Planning Performance Agreement between the LPA and the Applicant, as suggested by paragraph 46 (NPPF) to ‘achieve a faster and more effective application process’.
4.5 The principal aims of the consultation were as follows:
• to consult with people who live and work in the area; • to carry out consultation from an early stage to inform emerging proposals; • to involve all sectors of the community by using a range of consultation methods; • to consult with all stakeholders; and • to provide timely and appropriate feedback to consultees.
People who live and work in the area 4.6 Within two months of the formation of CLL, the Applicant held a ‘Meet the Team’ event with the local community and key stakeholders. This took place in June 2019, prior to the appointment of the architects, and was an opportunity for the local community and businesses to meet the Applicant and their initial team and to understand the nature of the proposals and
Quod | Land adjacent to Cockfosters Underground Station | Planning Statement | June 2021 15
the principle of development. It was also an opportunity for the project team to gain an insight into the local area and understand what is important to local residents. A total of 129 people attended this event.
4.7 A second event then took place in January 2020 once initial development proposals had been progressed in consultation with LBE’s planning, conservation and urban design teams. A total of 469 people attended the event across two days (219 on day one and 250 on day two).
4.8 A wide area was identified to publicise the initial Meet the Team event, with invitations sent to 2,897 residential and business addresses within the vicinity of the Site. Information flyers and/or emails about events were sent to all invitees around two weeks before they took place to ensure sufficient warning. The extent of interest at the first event prompted a wider distribution of invitations to the second event, covering 4,775 residential and business addresses with additional information being sent to around 36,000 regular users of the Station as defined by Oyster card subscribers.
4.9 Members of the Applicant team have undertaken further consultation and engagement activities with local businesses along Cockfosters Road and within the Station.
4.10 The Applicant has also used an online platform to explain the proposals to the wider community and to seek further feedback on the emerging scheme. This has sought to attract a broad audience, including those not traditionally engaged by in-person events, but who may be interested in, affected by or benefit from the emerging proposals. The digital consultation was promoted through social media adverts between 17 and 31 January 2020. It was aimed at raising awareness of the proposals with a wider cross-section of the local community and reached 194,751 people (those who saw the digital adverts) based on their geographical location in relation to the Site. Of those, 7,034 people visited a dedicated project website and 1,057 voted in polls set up to elicit further feedback in relation to the scheme. A total of 746 people provided written feedback through any means. This has also been taken into account as part of the scheme design process.
4.11 A series of stakeholder briefings were also held with local MPs, local Councillors and representatives of local groups including Enfield Society, the Conservation Advisory Group, Cockfosters Local Area Residents Association (CLARA), the Friends of Trent Country Park, Christ Church, Trent Park Conservation Area and East Barnet Residents’ Association. These sessions provided an opportunity to share the advanced design proposals and for questions to be asked of the project team. A newsletter has also been sent from the Applicant to members of the community to provide an update on the progress of the proposals since the public consultation in January 2020.
4.12 The key responses to the proposals taken from engagement with people who live and work in the area, and how the proposals have addressed them through the planning application are set out in the accompanying Statement of Community Involvement (Concilio, June 2021).
4.13 The Applicant has kept elected representatives, local community groups, residents and anyone who has registered an interest in the Proposed Development informed. Prior to submitting this planning application, an update was distributed via post to over 4,500 households and businesses and a digital update was issued to around 700 people. The update was shared with local MPs, local Councillors and representatives of local groups.
Quod | Land adjacent to Cockfosters Underground Station | Planning Statement | June 2021 16
4.14 Following submission, the Applicant intends to continue to update the same personnel and issue a digital update to any registered Oyster Card holders in the local area or that used Cockfosters Underground station around the time of the second public exhibition.
Statutory and Non-Statutory bodies 4.15 In addition to public consultation, a number of pre-application meetings have been held with relevant stakeholders at LBE and other statutory and non-statutory bodies. A summary of these activities is as follows:
Date Consultation 05.06.2019 LBE PPA 1: Housing 11.07.2019 LBE PPA 2: Design and Heritage 06.08.2019 LBE PPA 3: Transport 28.08.2019 LBE PPA 4: Design and Heritage 09.09.2019 LBE Design Review Panel and MDA 27.09.2019 LBE: Heritage 23.10.2019 GLA pre-application meeting 1 29.10.2019 Twentieth Century Society 13.11.2019 LBE PPA 5: Design and Heritage 26.11.2019 LBE: Parks 28.11.2019 LBE Design Review Panel 2 04.12.2019 Historic England pre-application meeting 1 13.01.2020 LBE PPA 6: Design and Heritage 23.01.2020 TfL Spatial Planning: Transport 27.01.2020 LBE PPA 7: Design and Heritage 27.01.2020 Metropolitan Police: Designing Out Crime 30.01.2020 LBE: Drainage 24.02.2020 LBE PPA 8: Design and Heritage 03.03.2020 LBE Planning Members’ Briefing 09.03.2020 LBE PPA 9: Design and Heritage 30.03.2020 LBE PPA 10: Design and Heritage 20.04.2020 LBE PPA 11: Design and Heritage 28.04.2020 Historic England pre-application meeting 2 04.05.2020 LBE: Drainage 18.05.2020 LBE PPA 12: Planning 09.06.2020 GLA meeting 2 27.04.2021 Mayoral Design Advocates: Chair’s Review 05.03.2021 LBE Officer Briefing 12.05.2021 GLA and TfL Spatial Planning 4.16 The discussions have informed the design development and technical detail accompanying the planning application. The matters raised through the consultation process have been considered by the design team and incorporated in the evolution of the Proposed Development as appropriate (see the Design and Access Statement).
London Borough of Enfield 4.17 A Planning Performance Agreement (PPA) was entered into between the Applicant and the LPA, which has allowed the design proposals to be discussed and refined over the course of
Quod | Land adjacent to Cockfosters Underground Station | Planning Statement | June 2021 17
the pre-application stage. This included regular meetings to cover topics including design, affordable housing, heritage and transport. Further technical meetings were held in relation to parks and drainage proposals. Constructive discussions which have shaped the Proposed development have related specifically to the following:
• the principle of development and the provision of Build to Rent accommodation including the affordable housing offer; • the principle of redevelopment of the car parks; • the significance and setting of the listed station building, Trent Park Conservation Area and Trent Park Registered Park and Garden; • defining a proposed layout and massing that responds to the Site constraints and opportunities, ensuring an approach that balances impacts of the Proposed Development against the benefits; • the approach to public realm and the interface with Cockfosters Road; • the landscape strategy and provision of publicly accessible amenity and play space; and • environmental considerations and mitigation. 4.18 The concept of tall buildings was discussed from very early on in the pre-application process between the Applicant and LBE officers. In July 2019, CLL sought feedback from officers on a series of architectural options. Officers confirmed that buildings above two storeys would likely be perceived as ‘tall’ in this location and that this could be acceptable subject to design. Throughout the pre-application process, various design iterations were presented to officers of buildings ranging between 9 storeys and 15 storeys (refer to section 3.1.3 of the Design and Access Statement). LBE officers (planning, urban design and conservation) recognised the sensitive location of the Site and the need to balance that against the delivery of homes and viability among other constraints. They provided feedback on the arrangement and massing of the buildings, and comments sought to ensure that the proposals:
• Minimise harm to the setting of the heritage assets. • Ensure the amount visible sky is maximised in views behind the Station and avoid layers of buildings visible in various views by maintaining views through and between buildings. • Test options for taller, more slender buildings. • Are of a high-quality design and use high quality materials. 4.19 The views and feedback from officers were used to inform the design evolution over the course of nine design-focused pre-application meetings.
Enfield Design Review Panel
4.20 Two sessions were held with LBE’s Design Review Panel who gave general feedback on the emerging design concepts and proposals. The GLA’s Mayoral Design Advocates (MDAs) were also involved through this process of design review.
4.21 The general approach to design was supported at the second session in December 2019, with specific comments made considering further opportunities to maximise the landscape and
Quod | Land adjacent to Cockfosters Underground Station | Planning Statement | June 2021 18
green spaces, vary the building heights, and provide a more coherent site entrance and movement strategy. The improvements to public realm and civic spaces around the station were strongly supported. Since the session, the design has moved on considerably, and a summary of the feedback and responses in design terms has been prepared as part of the accompanying Design and Access Statement (Hawkins\Brown, Mae Architects and JCLA Landscape Architects, June 2021).
Planning Committee Technical Briefing
4.22 A briefing with Members of LBE's Planning Committee was held on 3 March 2020. This was to provide Members with the background to the Proposed Development including the need for homes and the Build to Rent product and to introduce the emerging design. A further briefing was held on 8 June 2021. The briefings were not a forum for discussion of the Proposed Development.
The Greater London Authority 4.23 Meetings were held with the GLA on 23 October 2019, 9 June 2020 and 12 May 2021. The GLA confirmed its strong support for the principle of residential Built to Rent development including 40% affordable housing. Comments indicated support for the principle of the development, the removal of the existing car parks and the overall scale and mass of the proposed development. Specific comments relating to the quality and extent of new public realm, ground floor active uses, providing a pedestrian focused environment and ensuring the internal quality of residential units have been addressed through the design development and these improvements are welcomed by GLA officers.
Transport for London 4.24 A pre-application meeting was held with TfL Spatial Planning on 23 January 2020. The removal of the existing car parks and proposed car-free development is supported as part of the Mayor’s target that 80% of journeys in London should be made by sustainable means by 2041. A further meeting on 12 May 2021 confirmed this position.
Mayoral Design Advocates 4.25 A design review session was held with the Mayoral Design Advocates (MDA) in April 2021. The masterplan principles and relationship of the tall buildings to the surrounding context was supported, and the legible layout considered to provide a clear addition to the existing townscape.
Historic England 4.26 A meeting was held on site with a Historic England Inspector in December 2019. Written feedback confirmed the extent of their remit to encompass the potential impact of the Proposed Development on the setting of the Trent Park Conservation Area, albeit comments have considered the proposals holistically in relation to the local heritage assets. Historic England considered the need to secure the recessive appearance of the buildings where they would be visible in views but appreciated that the Proposed Development would not be visible in the most sensitive views from Trent Park. They also acknowledged the proposed improvements to the public realm around the Station offer an improvement to its setting. Updates to the scheme since these meetings have been shared with Historic England and they have been provided with information as the scheme has evolved.
Quod | Land adjacent to Cockfosters Underground Station | Planning Statement | June 2021 19
Twentieth Century Society 4.27 A meeting was held with a representative from the Twentieth Century Society in October 2019 and written feedback referred to the Society’s concerns for the impact of the Proposed Development on the setting of the Station in terms of the relative scale and massing. They also referred to the potential impact of adjacent development on the internal daylight in the station and train shed, given the particular significance of this element of the listing. An assessment undertaken by daylight and sunlight consultants GIA (See Appendix to the accompanying report) in response to these concerns have demonstrated that the Proposed Development would have negligible impacts on the daylight within the Station.
Metropolitan Police: Designing Out Crime 4.28 A meeting was held with a Designing Out Crime Metropolitan Police officer in respect of the emerging scheme design and recommendations were made in relation to improvements for security, particularly to bike stores to improve residents’ experience. Recommendations were also made in relation to perimeter fencing and external spaces which have been incorporated into the landscape strategy to reduce opportunities for illicit behaviour.
Summary 4.29 The Proposed Development has been shared with and reviewed by a broad range of statutory and non-statutory consultees, including local residents and businesses, in a range of forums throughout the design development process. Feedback and comments have been taken into consideration where relevant.
4.30 The consultation has been undertaken in compliance with the National Planning Policy Framework, Planning Practice Guidance, London Plan (2021), LBE’s Statement of Community Involvement (2015) and TfL best practice.
Quod | Land adjacent to Cockfosters Underground Station | Planning Statement | June 2021 20
5 Description of Proposed Development
Overview 5.1 The Applicant seeks detailed permission for:
‘A residential-led mixed use scheme comprising residential dwellings (Class C3), a flexible ground floor unit (Class E and/or uses previously Class A4 (Sui Generis)), replacement Train Drivers’ Accommodation (Sui Generis), cycle parking, public realm and open space, car parking, hard and soft landscape works, access and servicing, plant, and associated works’.
5.2 This Planning Statement should be read alongside the Design and Access Statement (Hawkins\Brown, Mae Architects and JCLA Landscape Architects, June 2021) which establishes the design intent for the Proposed Development, and the various supporting documents including the Energy Strategy, Transport Assessment, Sustainability Strategy, Heritage Assessment and Townscape and Visual Impact Assessment. The following section provides an overview of the Proposed Development.
5.3 The Proposed Development is for a mixed-use residential-led development including a flexible ground floor unit. The proposed uses are as follows:
Use Amount Site Area 1.36ha (1.15ha Site A; 0.21ha Site B) Residential (C3) 351 units Flexible unit (Class E and/or uses 209sqm (GIA) previously Class A4 (Sui Generis)) LUL staff and TDA (Sui Generis) 715sqm (GIA) Density 258 units/ha • 35 general use spaces for the public • 12 public Blue Badge spaces (reprovision of existing) • 7 drop-off/pick-up spaces for the public • 11 Blue Badge spaces for residents Car Parking (with passive provision for further 7% (24 spaces)/ 10% total (35)) • 1 car club space for residents and the public • 1 LUL Blue Badge space • 1 taxi electric charging bay • 597 long stay residential spaces • 10 short-stay residential spaces • 8 short-stay public spaces (re-provided) Cycle Parking • 60 cycle hub spaces (public) • 2 long-stay commercial space • 6 short-stay commercial spaces
Quod | Land adjacent to Cockfosters Underground Station | Planning Statement | June 2021 21
• 22 re-provided LUL staff cycle spaces (in TDA) External Private Communal Amenity 318sqm in terrace Block 02 Space External Public Communal Amenity Space 3,950sqm Internal Communal Amenity Space 440sqm
Residential 5.4 The Proposed Development would include the construction of 351 residential units within four new buildings as follows:
Block 1 bed 2 beds 3 beds Total (DMR/Market) (DMR/Market) (DMR/Market) (DMR/Market)
1 53/0 19/0 16/0 88/0
2 0/55 0/34 0/5 0/94
3 21/41 11/20 12/2 44/63
4 0/41 0/21 0/0 0/62
Total 74/137 (211) 30/75 (105) 28/7 (35) 132/219 (351)
5.5 The whole residential element of the Proposed Development is proposed to be Build to Rent, which is a private rented sector product owned and managed by a professional landlord, in this instance the Applicant. All residents would be offered tenancy agreements of up to five years, on fair rental terms with reviews set out at the point of signing the tenancy agreement. Residents would also be given the flexibility to move within the Proposed Development, or across CLL’s portfolio of sites. The Proposed Development would include access for all residents to high speed Wi-Fi, and facilities such as a residents’ lounge, shared workspaces and a gym, as well as an on-site management team.
5.6 The Proposed Development includes 40% affordable housing (by habitable room), amounting to 132 affordable units to be let at Discounted Market Rents. As set out in the above table, the Proposed Development would provide a mix of 1, 2 and 3 bed properties.
Flexible Unit (Class E and/or uses previously Class A4 (Sui Generis)) 5.7 A unit of 209sqm would be provided within Block 4, fronting Cockfosters Road and the new public space proposed between the station entrance and the building. The unit is within the area designated as a Local Centre and would be occupied by a use complementary to the local offer such as a café, restaurant or retail unit (Class E and/or uses previously Class A4 (Sui Generis)) that would be open to the general public and accessed from the high street on Cockfosters Road.
Quod | Land adjacent to Cockfosters Underground Station | Planning Statement | June 2021 22
5.8 The unit has been designed to provide an active frontage and define the western boundary of Site B, continuing the uses found opposite on Cockfosters Road, and the proposed extension of the Local Centre by the adjacent Blackhorse Tower. The final use would likely provide a space open to the public that can contribute to the vibrancy of the area and the existing and proposed local community.
LUL Staff and TDA (Sui Generis) 5.9 The existing Site includes a building used by LUL staff and train drivers in support of the operation of the Station and the Piccadilly Line. The building contains office space and welfare facilities such as a canteen, staff changing rooms, and meeting rooms.
5.10 The existing facilities are proposed to be re-provided at lower ground and ground level within Block 3, segregated from the residential development by a separate entrance. These facilities are required for the continued effective and efficient operation of the London Underground services.
Design and Heritage 5.11 The four proposed buildings have been designed to form a coherent and characterful form of development. Early in the design process, the following eight masterplan objectives were established for the Proposed Development:
1. To be a heritage and landscape led proposal that responds positively to the character and views from Trent Park; 2. To provide a high quality residential Build to Rent scheme and amenity spaces; 3. To provide high quality, flexible commercial use (Class E and/or uses previously Class A4 (Sui Generis)) and LUL offices; 4. To relate to the neighbourhood; 5. To make a place people are proud to live in; 6. To ensure the highest quality design and environmental standards; 7. To develop the scheme based on transparent engagement; 8. To address and complete the high street. 5.12 The details employed in developing the appearance of the proposed buildings have included a palette of quality materials, derived from local cues and simple detailing. The massing of the taller elements of the buildings has sought to minimise and avoid impacts on immediate, mid- range and long-range views and the design of the elevations has evolved help the Proposed Development respond directly to its immediate context and present a high quality and well- integrated design when viewed from further afield.
Open Space and Play Space 5.13 The Proposed Development includes play space that complies with and exceeds the 10sqm per child minimum requirements set out in LBE’s Local Plan, the Shaping Neighbourhoods: Play and Informal Recreation SPG (2012) and the London Plan (2021). The GLA population yield calculator (v.3.2 October 2019) has been used to estimate the possible number of children that could be generated by the Proposed Development. The below table sets out the
Quod | Land adjacent to Cockfosters Underground Station | Planning Statement | June 2021 23
requirement and proposed amount of play space, as well as the maximum walking distance to the Site within which that play space must be provided:
Play space Child yield required Maximum walking Age (London; Proposed play space (10sqm per distance from site PTAL 3-4) child) 300sqm (doorstep play) Under 5 29 290sqm 100m
5-11 20 200sqm 400m 250sqm 80sqm 12+ 8 80sqm 800m
Total 57 570sqm n/a 650sqm
5.14 The Proposed Development includes play space in excess of the minimum required amount for all ages. In particular, 650sqm of incidental play is provided for children of all ages which has been designed to supplement and complement the nearby offering in Trent Park. The play spaces are created by informal features which instil imagination and creativity for children, tied to the adjacent network of streams, woodland and grasslands open for use by everyone.
5.15 The Proposed Development would additionally provide 3,950sqm of external amenity space open to use by both its residents and the general public. Areas of seating, orchards and informal planting have been designed, maximising the opportunity for south-facing landscape spaces created around and between the buildings. In order to maximise the amount of usable space, vehicular access has been confined to the periphery and reduced as far as possible in line with the Healthy Streets objectives. The proposed planting has been selected to increase the ecological connectivity with the adjoining park and Site of Importance for Nature Conservation.
Residential Amenity Space 5.16 All units would be provided with a minimum of 5sqm of private external amenity space in the form of a balcony directly accessible from each flat with an additional 1sqm for each additional occupant over 2 people. Proposed balconies would be well proportioned to enable practical and flexible use by residents.
5.17 All homes would also have access to 318sqm of additional shared external amenity provided to the roof of Block 2 (shoulder building, fifth floor) in the form of a terrace. This space would be open and accessible to all residents of the Proposed Development, offering seating and enclosed by planting, with views across Trent Park and into the Site’s own landscape.
Trees 5.18 The Site is currently bordered by trees, particularly along the northern and eastern boundaries of Site A, and the north-eastern boundary of Site B. There is also an area designated as Local Open Space, part of which falls within the boundary of Site A and is characterised by trees and poor quality self-seeded vegetation. The trees within and adjacent to the Site vary in terms of quality and contribution. As many trees as possible are proposed to be retained, but 17 trees (category C and U) and some trees within groups are proposed to be removed to facilitate the
Quod | Land adjacent to Cockfosters Underground Station | Planning Statement | June 2021 24
Proposed Development. No category A or B (high or medium quality) trees are proposed for removal.
5.19 The Proposed Development would involve the planting of 93 new trees, resulting in a net gain on the Site of 75 trees.
Ecology 5.20 The Site is dominated by hardstanding with some areas of shrubs and woodland planting. The core concepts of the proposed landscape build on a celebration of the strong character of the landscape surrounding the Site. The unique location is embraced in the design, with woodland, water and open grassland reaching in through the Site, towards the high street.
5.21 The landscape has been designed to offer rich biodiversity value including flower rich meadows, flowering and fruiting trees and shrubs and seasonally wet SUDS areas. All roofs are proposed as either brown or green roofs to maximise the opportunity for ecology and wildlife within the Proposed Development.
5.22 The Proposed Development would achieve an Urban Greening Factor score of 0.42 and a 447% net gain in terms of biodiversity as calculated using the Biodiversity Metric 2.0 Calculation tool.
Transport 5.23 The Site is used for NCP car parking on land owned by TfL. This car park would be closed to facilitate the Proposed Development, which would operate as a car free residential development (in line with national and local policy). The Site has a Public Transport Accessibility Level (PTAL) rating of 3 and 4 (good), meaning it is relatively well served by public transport including the regular services of the Piccadilly Line and four bus routes.
5.24 The existing Blue Badge parking provision for the Station (12 spaces) would be re-provided within the Proposed Development. The existing general purpose car parking would mostly be removed, replaced with 35 public use spaces, and a drop-off/pick-up area comprising 7 spaces within the Site, close to the Station entrance. One Blue Badge car parking space is proposed for LUL staff.
5.25 Residential Blue Badge parking spaces (11 spaces for 3% of units) would be provided within the Proposed Development and space for further residential Blue Badge bays (up to 35 spaces for 7% of units) has been allowed within the landscape design of the Site. A car club parking space is also proposed to be provided for use by future residents and the local community, allowing short-term use of a shared vehicle. The existing taxi charging bay would also be re- provided.
5.26 The Proposed Development would involve the provision of 607 new long and short stay (resident and visitor) cycle parking spaces to support the new residential development and the existing 8 cycle spaces would be re-provided for those accessing the station. A further 60 cycle parking spaces are proposed to be provided within a dedicated, secure cycle hub on the ground floor of Block 4, adjacent to the entrance to the station for use by commuters. Cycle storage provision would also be made for LUL staff within the TDA to replace existing and for the commercial unit in accordance with London Plan (2021) standards).
Quod | Land adjacent to Cockfosters Underground Station | Planning Statement | June 2021 25
5.27 The Proposed Development would provide one point of access each to Site A and Site B for Blue Badge holders, staff, and servicing and maintenance vehicles, as well as re-providing essential access for LUL to continue to operate and maintain the railway safely and efficiently. The accessibility of pedestrians and cyclists has been prioritised in the proposed design both within the Site, to the Station and to the LOOP.
Health 5.28 The Proposed Development would have a positive influence on the mental and physical health of Londoners by improving the environment in which they live, providing healthy homes, promoting active travel, improving air quality and contributing to vibrant neighbourhoods.
5.29 The layout of the Proposed Development also creates an environment supportive of walking and cycling and the healthy environment is exemplified by the big improvements in the Healthy Streets score resultant from the Proposed Development. Long term stewardship of the Site by CLL will involve dedicated onsite staff and quality facilities such as residents lounge, shared workspaces and concierge, and all apartments will be capable of accommodating desk-space to work from home. Shared facilities assist in creating a sense of community which supports health and wellbeing.
5.30 The accompanying Health Impact Assessment provides an assessment of the Proposed Development based on the themes set out by the HUDU Healthy Urban Development Checklist. This assessment shows that the Proposed Development is likely to have an overall positive impact on health as a result of high quality residential development and design, public realm, open space and play space. The contribution to urban greening and biodiversity net gain as well as minimising car dependency and maximising active travel would have a positive impact on health.
Climate Change 5.31 The Proposed Development is supported by the NPPF, and the Mayor of London and LBE’s action plans, to tackle climate change, minimise its impacts and ensure it is resilient to its effects. It employs strategies such as promoting sustainable travel, removing cars from the road, energy efficient systems and consumption reduction as well as enhancing and expanding the green infrastructure network through measures such as tree planting, biodiverse landscapes and green roofs. The design also accounts for the likely extreme weather events to be experienced in the future, such as higher temperatures and more rainfall and mitigates the effect that this would have on future residents and the local and wider community.
5.32 The Mayor of London’s target is to increase active and sustainable mode share across London to 80% by 2041. LBE adopted its Climate Action Plan in July 2020 setting out its vision for climate action to become a carbon neutral borough by 2040. This Action Plan sets out how LBE will meet its Climate Emergency Pledge signed in 2019 to tackle the impact of climate change and prevent catastrophic consequences as a result.
5.33 The report shows that the highest proportion of emissions in Enfield is from transport at 39% (by tonnes of CO2) compared with emissions from domestic (35%), waste (2%) and industry and commercial (24%) activities. LBE has set targets for ‘the journey to carbon neutrality’ involving 55% of trips in the borough to be made by sustainable means by 2022, reducing
Quod | Land adjacent to Cockfosters Underground Station | Planning Statement | June 2021 26
transport emissions by 35.7% by 2025, and requiring nearly 70% of trips to be made by sustainable means by 2040.
5.34 The vision is for the majority of journeys within the borough to be made my means that are either low carbon or do not emit carbon by 2040 which will be achieved through such things as encouraging active travel with improved pedestrian and cycle infrastructure, electric vehicle charging provision, and shared mobility options such as car clubs in order to significantly reduce the use of private vehicles.
5.35 The reduction of more than 90% of the existing car parking, and provision of infrastructure on site to support sustainable travel modes, such as walking, cycling and electric car charging will encourage a positive change to patterns of travel behaviour towards low and zero carbon modes. This will contribute towards Enfield’s promise to reduce travel by private car in the medium term.
Quod | Land adjacent to Cockfosters Underground Station | Planning Statement | June 2021 27
6 Planning Policy Context
Overview 6.1 This section provides the national, regional and local planning policy context of the Proposed Development and describes the designations affecting the Site. Section 38(6) of the Planning and Compulsory Purchase Act 2004 and Section 70(2) of the Town and Country Planning Act 1990 provide that planning applications should be determined in accordance with the Development Plan unless material considerations indicate otherwise.
6.2 Relevant policies and guidance are set out under the sub-headings below and Section 7 then goes on to provide a detailed assessment of the Proposed Development in the context of these policies.
6.3 The application is supported by technical reports which also set out the relevant policies considered for the purposes of the appraisal.
Development Plan 6.4 The Development Plan comprises:
• London Plan (2021); • The Enfield Plan Core Strategy (2010-2025); • Enfield Development Management Document (DMD) (2014) • Adopted Policies Map (2014) (together 'the Development Plan') 6.5 Other material considerations include the NPPF, Planning Practice Guidance (PPG), LBE and GLA Supplementary Planning Documents and the emerging Local Plan for Enfield (2018- 2036).
6.6 The NPPF paragraph 11 requires decisions to apply a presumption in favour of sustainable development. This presumption requires development proposals that accord with an up-to- date development plan to be approved without delay. Where the policies which are most important for determining the application are out-of-date, including when a local planning authority cannot demonstrate a five year supply of deliverable housing sites, permission should be granted unless (i) the application of policies within the NPPF provide a clear reason for refusing development; or (ii) any adverse impacts of doing so would significantly and demonstrable outweigh the benefits when assessed against the policies in the NPPF taken as a whole.
6.7 The Housing Delivery Test results published on 19th January 2021 show that Enfield delivered 56% of their housing delivery target over the past three years making them a ‘Presumption’ Authority. A briefing note prepared by Enfield Officers for the Regeneration and Economic Development Scrutiny Panel confirmed for Members that the Borough falls into the ‘presumption in favour of sustainable development’ category (Briefing Note: Housing Delivery Test dated 10th February 2021).
Quod | Land adjacent to Cockfosters Underground Station | Planning Statement | June 2021 28
London Plan (2021) 6.8 The new London Plan was published in March 2021 and sets out the overarching policy framework for how London will develop over the next 20-25 years. It should be afforded full weight in accordance with paragraph 28 of the NPPF. The London Plan (2021) is the most up to date of the development plan documents.
6.9 The new London Plan is underpinned by the principle of ‘Good Growth’, that is, growth that is socially and economically inclusive and environmentally sustainable (Paragraph 1.0.1). Paragraph 1.1.4 highlights the positive impact that good quality, affordable homes, better public transport connectivity, accessible and welcoming public space, and built forms that work with local heritage and identity will have on London. The key policies relevant to the Proposed Development are:
Policy Requirement To engage with stakeholders, create a positive physical environment which encourages social GG1: Building Strong and integration, is easy to move around and reinforce a Inclusive Communities sense of place, supporting people from all backgrounds and groups. To focus development in suitable locations, protecting green spaces and local character, prioritising sites GG2: Making the Best Use of which are well-connected by existing and planned Land infrastructure, and planning for sustainable travel, enabling car-free lifestyles that allow an efficient use of land. To support and create environments that are active GG3: Creating a Healthy City and healthy. To ensure that more homes and delivered and create GG4: Delivering the Homes mixed and inclusive communities with good quality Londoners Need homes that meet high standards of design and provide for identified needs. Development should take a town centre first approach and should capitalise on the availability of services SD7: Town centres: within walking and cycling distance and current and development principles and future public transport provision, including, for Development Plan documents example, comprehensive redevelopment of low- density supermarket sites, surface car parks, and edge of centre retail/leisure parks. Where a development is acceptable, but infrastructure D2: Infrastructure improvements are required to support it, these should Requirements for Sustainable be identified and a contribution towards the Densities improvements made.
Quod | Land adjacent to Cockfosters Underground Station | Planning Statement | June 2021 29
Policy Requirement Make the best use of land considering design to D3: Optimising Site Capacity determine the most appropriate form for the site’s through the Design-Led context and capacity. Approach Considering the form and layout, experience for residents and quality and character of places. Visual modelling and assessments can inform decision-taking. Design and access statement to demonstrate D4: Delivering Good Design compliance with the requirements of the Plan. Make use of the Design Review process. Avoid the potential for late design amendments or decisions about design through planning condition. Inclusive and accessible design, with consideration for the diverse population, facilitating social interaction D5: Inclusive Design and inclusion, convenient and welcoming and incorporating safe and dignified emergency evacuation. High quality design and adequately sized rooms with no difference between tenures. Maximise dual aspect, and only provide single aspect where it is considered a more appropriate design solution to optimise site capacity. D6: Housing Quality and Standards Dwellings should have sufficient daylight and sunlight, avoid overheating, minimise overshadowing, have sufficient storage space that supports the separate collection of dry recyclables and food waste as well as residual waste and meet the requirements for private internal and external space. 10% of dwellings must meet Building Regulation requirement M4(3) ‘wheelchair user dwellings’. The D7: Accessible Housing remainder must meet M4(2) ‘accessible and adaptable dwellings’. Create new public realm where appropriate. Ensure it D8: Public Realm is well-designed, safe, accessible and inclusive and maximises the contribution to active travel. Boroughs should identify locations (including identifying where tall buildings may be an appropriate form of development subject to meeting other D9: Tall Buildings requirements of the plan); impacts (visual, functional, environmental, cumulative); and incorporate free to enter publicly accessible areas.
Quod | Land adjacent to Cockfosters Underground Station | Planning Statement | June 2021 30
Policy Requirement Build in resilience and minimise potential risks from D11: Safety, Security and natural or other hazards and include measures to Resilience to Emergency design out crime. Achieve the highest standards of fire safety and D12: Fire Safety incorporate features which reduce risk to life. A Fire Statement should accompany proposals. Mitigate and minimise potential adverse impacts of D14: Noise noise on, from, within, as a result of or in the vicinity of new development. Housing delivery should be optimised on all suitable H1: Increasing Housing and available brownfield sites, especially with a good Supply PTAL, near a station, car parks and public-sector owned sites. Strategic target for 50%of all new homes delivered across London to be genuinely affordable on public H4: Delivering Affordable sector land, at least 50% affordable housing on each Housing site and public sector landowners with agreements with the Mayor delivering at least 50% affordable housing across their portfolio. Schemes should provide a range of unit sizes with regard to housing need and demand, delivering mixed use neighbourhoods. H10: Housing Size Mix A higher proportion of one and two bed units are appropriate close to a station or site with good public transport connectivity. Criteria for Build to Rent schemes requiring at least 50 units and a covenant to be held for 15 years. All units should be self-contained and let separately. H11: Build to Rent There is a unified ownership and management of all tenures, longer tenancies (3+ years) with break clauses, rent and service charge certainty and on-site management. To conserve the significance of an asset and avoid HC1: Heritage Conservation harm. To identify enhancement opportunities by and Growth integrating heritage considerations early in the design process. Increase opportunities for play and recreation with S4: Play and Informal good quality, accessible provision for all ages of at Recreation least 10sqm per child.
Quod | Land adjacent to Cockfosters Underground Station | Planning Statement | June 2021 31
Policy Requirement Protect and enhance networks of green and open G1: Green Infrastructure spaces and incorporate green infrastructure in new development. Development should not result in the loss of protected open space and where possible create areas of G4: Open space publicly accessible open space, particularly in areas of deficiency. A minimum target score of 0.4 for residential G5: Urban Greening development should be achieved. Sites of Importance for Nature Conservation should be protected. Development proposals should manage G6: Biodiversity and access to impacts on biodiversity and aim to secure net nature biodiversity gain informed by the best available ecological information. Existing trees of value should be retained. G7: Trees and Woodlands Any trees that are removed should be adequately replaced. No deterioration of air quality and seeking to improve air quality. Major development should be accompanied by an Air SI1: Improving Air Quality Quality Assessment. Construction and demolition phase must reduce emissions following best practice guidance. Major development should be net zero carbon and demonstrate how this will be met through an Energy Strategy. Minimum on site reduction of 35%, of which 10% SI2: Minimising Greenhouse through energy efficient measures (residential). Gas Emissions Contribution to carbon offset fund for any shortfall, agreed with the Borough. Unregulated emissions should be minimised. Whole life-cycle emissions should be calculated and reduced. In Heat Network Priority Areas, major developments SI3: Energy Infrastructure should connect to existing or planned heat networks. To minimise the use of mains water achieving SI5: Water Infrastructure consumption of 105 litres/person/day and achieve BREEAM excellent for the ‘Wat 01’ water category.
Quod | Land adjacent to Cockfosters Underground Station | Planning Statement | June 2021 32
Policy Requirement Incorporate smart metering, water saving and recycling measures. SI6: Digital Connectivity Provide sufficient ducting space for full fibre Infrastructure connectivity infrastructure. Resource conservation, waste reduction, re-use and SI7: Reducing Waste and recycling of materials. Supporting the Circular Promote circular economy outcomes and aim to be Economy net zero-waste. Development should minimise and mitigate for flood SI12: Flood Risk Management risk. Aim to achieve greenfield run-off rates and manage surface water as close to source as possible. SI13: Sustainable Drainage Follow the drainage hierarchy. Impermeable surfaces should be resisted. T1: Strategic Approach to Effective use of land, reflecting connectivity and Transport accessibility by public transport, walking and cycling. Facilitate and promote short, regular trips by walking or cycling. T2: Healthy Streets Deliver improvements that support the Healthy Streets indicators. Reduce car dominance. Submit a Transport Assessment or Statement. T4: Assessing and Mitigating Mitigate for adverse impacts on the public transport, Transport Impacts road network or walking and cycling facilities. Remove barriers to cycling and provide cycle parking T5: Cycling that is appropriately designed and sufficient for anticipated demand. Car-free development should be the starting point for sites well-connected by public transport. Disabled persons parking must be provided. T6: Car Parking Parking Design and Management Plan should be submitted. Adequate provision for deliveries and servicing. New residential development should not exceed the maximum parking standards set out in Table 10.3. All T6.1: Residential parking residential car parking spaces must provide infrastructure for electric or Ultra-Low Emission vehicles with at least 20% of spaces with active
Quod | Land adjacent to Cockfosters Underground Station | Planning Statement | June 2021 33
Policy Requirement charging facilities and passive provision for all remaining spaces. The maximum parking standards set out in Table 10.5 should be applied to new retail development which T6.3: Retail parking should avoid being car-dependent and follow a town centre first approach. T9: Funding Transport Planning obligations may be used to mitigate impacts Infrastructure Through from development, for example improved public Planning transport and cycle infrastructure.
6.10 The London Plan is supported by a number of Supplementary Planning Guidance documents which provide guidance on matters such as housing standards, play space and cycle design. Those relevant to the Proposed Development are referenced under material considerations (see paragraph 6.19).
Enfield Local Plan 6.11 The LBE Local Plan comprises: (i) the Enfield Core Strategy (2010); (ii) the Development Management Document; (iii) the Policies Map; and other supporting policy documents. Along with the London Plan, it forms the Development Plan for Enfield. The weight to be attached to the Development Plan depends upon the degree of its consistency with the NPPF. Whilst many of the policies align with the NPPF, others are inconsistent with it and are therefore out-of-date (as to which please see further below). The Proposed Development has been reviewed against the most relevant and up-to-date policies within the Development Plan as indicated within the assessment in Section 7 of this Planning Statement.
Enfield Core Strategy (2010) 6.12 The Core Strategy was adopted in November 2010 and sets out a spatial planning framework for the development of the Borough to 2025. It provides the broad strategy for the scale and distribution of development and supporting infrastructure, to guide patterns of development and ensure it is sustainable.
6.13 Strategic Objective 2 of the Core Strategy relates to environmental sustainability and states the following:
‘To promote a sustainable pattern of development integrating infrastructure and housing, reducing the Borough’s carbon footprint, minimising the need to travel and protecting the Borough’s green belt and biodiversity. To mitigate and adapt to the impacts of climate change, promoting energy efficiency and renewable sources of energy including exemplar schemes as part of regeneration of the Upper Lee Valley area. To manage and reduce flood risk and pollution, promote sustainable water management and retain sufficient waste management facilities in the Borough’.
6.14 The policies relevant to the Proposed Development are as follows:
Quod | Land adjacent to Cockfosters Underground Station | Planning Statement | June 2021 34
Policy Requirement Seek to exceed the housing target. Growth is planned Core Strategy Policy 2: other than in opportunity areas, where physical and social Housing Supply and infrastructure already exists or can be improved through Locations for New Homes planned development. Core Strategy Policy 3: Borough-wide target of 40% affordable housing units on Affordable Housing sites of more than 10 dwellings. Core Strategy Policy 4: High quality design and sustainability for all new homes Housing Quality and 10% suitable or easily adaptable for wheelchair users. To offer a range of housing sizes to meet housing need. Seeking a range of housing types in the intermediate sector determined on a site by site basis. Mix to be agreed Core Strategy Policy 5: taking account of all factors, between developers and the Housing Types Council. Density should balance the need to ensure the most efficient use of land whilst respecting the quality and character of existing neighbourhoods and accessibility to transport and other infrastructure. Core Strategy Policy 7: A pattern of land uses will be promoted to encourage Health and Social Care healthier lifestyles. Facilities Promoting accessibility for all members of the community Core Strategy Policy 9: to have access to good quality housing and other social Supporting Community facilities. Cohesion Contributing towards reducing crime, fear of crime and anti-social behaviour by designing out crime. Local Centres will be supported in providing core local shopping facilities and services for their respective Core Strategy Policy 17: communities, largely catering for a catchment area within Town Centres walking distance (Cockfosters defined as a Large Local Centre). Development should contribute towards opportunities for Core Strategy Policy 20: renewable or low carbon energy and decentralised energy Energy and Sustainability infrastructure. Development must ensure water supply, sewerage and Core Strategy Policy 21: drainage infrastructure is in place and include water Water Environment conservation and sustainable drainage measures. The Council will encourage inclusion of re-used and Core Strategy Policy 22: recycled materials, on-site reuse and recycling, and Delivering Sustainable require appropriate on-site provision for waste treatment, Waste Management storage and collection.
Quod | Land adjacent to Cockfosters Underground Station | Planning Statement | June 2021 35
Policy Requirement The Council will seek to deliver improvements to the road Core Strategy Policy 24: network to support regeneration and development, The Road Network improve safety and environmental quality, reduce congestion and provide additional capacity where needed. Core Strategy Policy 25: Prioritise pedestrian and cycle public realm improvements Pedestrian and Cycle that contribute to quality and safety. Infrastructure The Council will seek to ensure a safe, accessible, Core Strategy Policy 26: welcoming and efficient public transport network and Public Transport ensure developments demonstrate that public transport can accommodate development proposals. Core Strategy Policy 28: Directing development to areas of lowest flood risk. Managing Flood Risk Development should promote attractive, safe, accessible, Core Strategy Policy 30: inclusive and sustainable neighbourhoods, connecting and Quality of Built and Open supporting communities and reinforcing local Environment distinctiveness. Areas appropriate, inappropriate and sensitive to tall buildings will be mapped by the Council. Having special regard to the impacts of development on heritage assets and their settings. Ensuring that built Core Strategy Policy 31: development and interventions in the public realm that Built and Landscape impact on heritage assets have regard to their special Heritage character and are based on an understanding of their context. Development to reduce pollutant emissions and public Core Strategy Policy 32: exposure to pollution, minimise noise and light pollution Pollution and exposure to contamination. Improve air quality by reducing pollutant emissions. Core Strategy Policy 33: Development should protect and enhance the Green Belt Green Belt Seek opportunities to improve provision of good quality Core Strategy Policy 34: and accessible open space. Support improved access to, Parks and open space quantity and quality of publicly accessible open space. Core Strategy Policy 36: Protect, enhance, restore or add to existing biodiversity Biodiversity including green spaces and corridors. Core Strategy Policy 46: Development is required to make financial and in-kind Infrastructure contributions towards infrastructure and community contributions facilities.
Quod | Land adjacent to Cockfosters Underground Station | Planning Statement | June 2021 36
Enfield Development Management Document (DMD) (2014) 6.15 The DMD provides detailed criteria and standard based policies by which planning applications should be determined, in order to deliver the vision of the Core Strategy. The key policies relevant to the Proposed Development are:
Policy Requirement Borough-wide target of 40% affordable housing including DMD 1: Affordable a mix of tenures (70% social, 30% intermediate target). Housing Design must be ‘tenure blind’. DMD 3: A Mix of Different Mix of units in line with the targets in Core Strategy Sized Homes Policy5. Development must comply with the London Plan's density DMD 6: Residential matrix and have regard to existing character and be of a Character high quality of design. Proposed density should consider transport capacity and local facilities. Appropriate location, scale, bulk and massing. Preserve amenity and meet or exceed minimum space DMD 8: General standards with a flexible, functional layout. Residential Standards Meet the requirement for accessible housing. Consider effects on the street scene and impacts of hard standing. Good quality private external amenity is required or can be DMD 9: Amenity Space provided as communal amenity if it is of adequate standard. Provides standards for the distances between buildings, DMD 10: Distancing unless the proposal would not have inadequate daylight/sunlight or privacy. Proposals for new retail (A1) and A2-5 uses which provide DMD 25: Locations for local shopping and services for communities will be New Retail Development permitted within the boundaries of large local centres. Proposals involving a change of use from A class, leisure DMD 38: Large local or community uses within local centres will be refused centres, small local unless the proposed use provides a service that is centres and local parades compatible with an appropriate to the local centre. Development of A3, A4 and A5 will be permitted in local DMD 32: Managing Food centres, if they demonstrate no detrimental effect on local and Drink Establishments residents’ amenity, or access, servicing and parking arrangements. DMD 37: Achieving High Development must be suitable for its intended function Quality and Design-Led and improve an area through responding to the local Development
Quod | Land adjacent to Cockfosters Underground Station | Planning Statement | June 2021 37
Policy Requirement character, clearly distinguishing public and private spaces, and a variety of choice. Development should comply with the principles of Secured by Design. Design and Access Statements must be submitted to explain the site constraints, opportunities and context and DMD 38: Design Process how the design addresses them, and the relevant policy and guidance. New ground floor frontages should maintain visual interest DMD 40: Ground Floor and respect the rhythm, style and proportions of the Frontages locality. Restricts development of tall buildings within inappropriate areas, including conservation areas, sites within the immediate vicinity of a registered park and garden or listed building or sites which are adjacent to the Green Belt. Tall buildings that are substantially taller than their DMD 43: Tall Buildings surroundings, cause a significant change to the skyline or are larger than the threshold sizes for referral to the Mayor must demonstrate how negative impacts have been avoided. Suitability will depend on the context of the site and details of the proposed building. Developments should conserve and enhance the special DMD 44: Conserving and interest, significance or setting of a heritage asset. Enhancing Heritage Applications affecting heritage assets should include a Assets Heritage Statement. Proposals involving car parking are considered against the standards set out in the London Plan. Development should be fully accessible and maximise walkability and links for cyclists. For car free development, this must demonstrate that any DMD 45: Parking increase in on-street parking would not adversely affect Standards and Layout traffic flows, bus movement, road safety or the amenity of local residents or the local environment and may be required to contribute towards implementing parking controls. Car clubs are encouraged. Provision for pedestrians and cyclists should be included DMD 47: Access, New to ensure attractive, safe, clearly defined and convenient Roads and Servicing routes and links to surrounding streets and rights of way networks.
Quod | Land adjacent to Cockfosters Underground Station | Planning Statement | June 2021 38
Policy Requirement New access and service arrangements must be provided for. Major applications should be accompanied by a Transport Assessment and Travel Plan to identify how modal choice DMD 48: Assessing will be improved over time. Transport Implications Delivery and construction logistics plans are also encouraged for major development. As much as is feasible and viable, high sustainable design DMD 49: Sustainable and construction standards should be followed and Design and Construction demonstrated in the application. DMD 50: Environmental Development must demonstrate compliance with the Assessment relevant standards or rating towards zero carbon.
DMD 51: Energy CO2 emissions must be minimised following the energy Efficiency Standards hierarchy and demonstrated in an Energy Statement. Major development should contribute to the supply of DMD 52: Decentralised decentralised energy networks unless there are feasibility Energy Networks or viability reasons not to. Developments should make up for an identified shortfall of DMD 53: Low and Zero energy efficiencies against targets or provide a 20% Carbon Technology carbon reduction through low and zero carbon technologies. Where energy efficiency targets cannot be achieved, a DMD 54: Allowable financial contribution is required calculated on price per Solutions tonne of carbon. DMD 55: Use of Roof All available roof space should be used for low zero Space carbon technologies, green roofs and living walls. DMD 56: Heating and Reliance on mechanical cooling systems should be Cooling reduced by following the cooling hierarchy. Construction and other materials should be sustainably sourced. DMD 57: Responsible A Site Waste Management Plan should be provided to Sourcing of Materials demonstrate reduction of waste. Details of green procurement and construction should be provided. Achieve a maximum water consumption of DMD 58: Water Efficiency 80litres/person/day or the highest level of water efficiency. DMD 59: Avoiding and Locate development to areas of lowest risk and not Reducing Flood Risk increase flood risk on or off site.
Quod | Land adjacent to Cockfosters Underground Station | Planning Statement | June 2021 39
Policy Requirement DMD 60: Flood Risk For all development over 1ha in Flood Zone 1, an FRA Assessment must be provided. Follow the drainage hierarchy and maximise the use of SuDS. DMD 61: Managing Achieve greenfield run off rates (for 1 in 1 year and 1 in Surface Water 100 year events). Follow the SUDS management train for water treatment to improve water quality, biodiversity and amenity. DMD 63: Protection and Development adjacent to watercourses must not result in Improvement of their deterioration and should implement mitigation Watercourses measures where relevant. Developments must prevent or reduce and mitigate DMD 64: Pollution Control pollution and risk of pollution including during construction and Assessment and operation. There should be no adverse impact on air quality and an DMD 65: Air Quality assessment should be provided. DMD 66: Land Development proposals should demonstrate there are no Contamination unacceptable risks of contamination. Residents should not be exposed to unacceptable levels DMD 68: Noise of noise, and design should mitigate this. Development should reduce the adverse impact of light DMD 69: Light Pollution pollution. DMD 71: Protection and Inappropriate development or loss of local open space will Enhancement of Open be resisted, unless it can be adequately compensated for. Space DMD 72: Open Space Major development should improve open space provision. Provision DMD 73: Children’s Play Play space should be provided on sites in areas deficient Space of children’s play space. DMD 76: Wildlife Development that abuts a wildlife corridor should protect Corridors and enhance it. DMD78: Nature Maximise opportunities to improve access to nature. Conservation DMD 79: Ecological On-site ecological enhancements should be provided Enhancements subject to feasibility and viability. DMD 80: Trees on No loss or harm to trees of significant amenity or Development Sites biodiversity value or adequate replacement provided.
Quod | Land adjacent to Cockfosters Underground Station | Planning Statement | June 2021 40
Policy Requirement High quality landscaping that enhances the local DMD 81: Landscaping environment, benefits biodiversity, reduces water run-off and mitigates the impacts of climate change. DMD 82: Protecting the Inappropriate development within the Green Belt will not Green Belt be permitted. Proposed development next to the Green Belt will only be permitted where there is no increase in visual dominance of the built form, there is a clear distinction between Green DMD 83: Development Belt and urban area, and views and vistas and access Adjacent to the Green Belt points are maintained. Opportunities to improve land adjacent to the Green Belt through environmental improvements should be incorporated in development proposals. New development within Areas of Special Character will DMD 84: Areas of Special only be permitted if features or characteristics which are Character key to maintaining the quality of the area are preserved and enhanced.
6.16 The adopted Policies Map illustrates the relevant designations and policy constraints in respect of the Site. The extracts of the map are shown in Figures 5, 6, 7 and 8 in Section 3.
6.17 The designations relevant to the Site itself are as follows:
• Local Centre: The frontage of Site B and the Station are within Cockfosters Large Local Centre (Enfield Core Strategy Policy 17; Enfield DMD Policy 28);
• Conservation Area and Area of Special Character: Site A falls partially within Trent Park Conservation Area, centred on Trent Park House which is within a designated Area of Special Character (Enfield Core Strategy Policy 31; Enfield Policy DMD 28 and 44);
• Archaeology: Site A is within the Camlet Moated Site Archaeological Priority Area (Enfield Core Strategy Policy 31);
• Local Open Space: A small area of trees and shrub vegetation (approx. 815sqm) to the north of Site A is designated as local open space (Enfield Core Strategy Policy 34; Enfield Policy DMD 71 and 72);
• Flood Risk: The Site is located entirely within Flood Zone 1 (low risk) (Enfield Core Strategy Policy 28; Enfield Policy DMD 59 and 60); and
• Air Quality: The whole Borough of Enfield is a designated Air Quality Management Area (Enfield Policy DMD 65).
Quod | Land adjacent to Cockfosters Underground Station | Planning Statement | June 2021 41
6.18 The designations relevant to land adjacent to the Site are as follows:
• Green Belt: The north and eastern boundaries of Site A demarcate the edge of the Green Belt designation which encompasses Trent Park (Enfield Core Strategy Policy 33; Enfield Policy DMD 82);
• Listed Building: The Station is Listed at Grade II, located between Site A and Site B both of which are within its setting (Enfield Core Strategy Policy 31; Enfield Policy DMD 44);
• Registered Park and Garden: Trent Park is Registered at Grade II and Site A is within its setting (Enfield Core Strategy Policy 31; Enfield Policy DMD 44);
• Site of Importance for Nature Conservation (SINC): A Site of Metropolitan Importance for Nature Conservation (SMINC) adjoins Site A to the east and south. A Site of Borough Importance for Nature Conservation (SBINC) additionally extends adjacent to the south west boundary of Site A between the Site and the railway tracks and to the south of the Site (Enfield Core Strategy Policy 36; Enfield Policy DMD 76 and 78);
• Wildlife Corridor: Near to the Site, the railway tracks are designated as a wildlife corridor (Enfield Core Strategy Policy 36; Enfield Policy DMD 76); and
• Tree Preservation Order: There are two Tree Preservation Orders (TPOs) outside the Site to the north of Site A, within the garden of 120 Cockfosters Road (Enfield Policy DMD 80 and 81);
Other Material Considerations 6.19 Other material planning considerations include the documents listed below. These are referred to as appropriate in the Planning Considerations at Section 7 to this Planning Statement.
• the Planning (Listed Buildings and Conservation Areas) Act 1990 • National Planning Policy Framework (NPPF) (2019) • Planning Practice Guidance • Housing Delivery Test Results 2020 (MHCLG) • Affordable Housing and Viability SPG (2017) • London Plan Annual Monitoring Report 15 (AMR) (2017/18) • London Strategic Housing Market Assessment (SHMA) (2017) • London Housing SPG (2018) • London Housing Strategy (2018) • Shaping Neighbourhoods: Play and Informal Recreation SPG (2012) • Accessible London: Achieving an Inclusive Environment SPG (2011) • Mayor’s Transport Strategy (2018) • Healthy Streets for London (2017) • Mayor’s Vision Zero Action Plan (2018)
Quod | Land adjacent to Cockfosters Underground Station | Planning Statement | June 2021 42
• Sustainable Design and Construction SPG (2014) • London Environment Strategy (2018) • Enfield Climate Action Plan (2020) • Enfield Annual Monitoring Report and Housing Trajectory (2019) • Enfield Issues and Options Local Plan (Regulation 18 Consultation document, 2018) • Enfield Characterisation Study (2011) • Enfield Section 106 SPD (2016) • Enfield Decentralised Energy Network SPD (2015) • Making Enfield: Enfield Heritage Strategy (2019-24 adopted June 2019) • Enfield draft Housing and Growth Strategy (2020-2030) • Enfield Strategic Housing Market Assessment (2015) • Enfield Housing Action Plan (2019) • Trent Park Conservation Area Character Appraisal (2015) • Report on Location of Tall Buildings and Important Local Views in Enfield (March 2013) • The Setting of Heritage Assets: Historic Environment Good Practice Advice in Planning Note 3 (2015) • Managing Significance in Decision-Taking in the Historic Environment: Historic Environment Good Practice Advice in Planning 2 (2015) • Statements of Heritage Significance: Analysing Significance in Heritage Assets – Historic England Advice Note 12 (2019)
The National Planning Policy Framework 6.20 The NPPF was updated in February 2019 and sets out the Government’s planning policies for England. It is a material consideration in planning decisions carrying substantial weight.
6.21 The NPPF sets out the three overarching objectives for sustainable development: economic, social and environmental (Paragraph 8) which should be used to guide development towards sustainable solutions, ‘taking local circumstances into account, to reflect the character, needs and opportunities of each area’ (Paragraph 9).
6.22 Paragraph 11 requires that decisions apply a ‘presumption in favour of sustainable development’, approving development proposals that accord with an up-to-date development plan without delay (Paragraph 11c) or where there are no relevant development plan policies, or the policies which are most important for determining the application are out-of-date, granting permission unless there are clear reasons for refusing the development proposed (relating to protected areas or assets of particular importance); or any adverse impacts of doing so would significantly and demonstrably outweigh the benefits, when assessed against the policies in this Framework taken as a whole (NPPF Paragraph 11d)).
6.23 Policies are considered out-of-date where the Housing Delivery Test finds that the delivery of housing in the LPA area was substantially below the housing requirement over the previous
Quod | Land adjacent to Cockfosters Underground Station | Planning Statement | June 2021 43
three years. The Housing Delivery Test figures issued by MHCLG in January 2021 confirmed that Enfield is now ‘a presumption authority’. In accordance with the NPPF, paragraph 11(d) and footnote7, the LBE policies most important for determining this application are out-of-date by virtue of the under delivery of housing in Enfield over the past three years. The ‘tilted balance’ in the NPPF is engaged.
6.24 Paragraph 11 (d) requires that permission should be granted unless (i) the application of policies within the NPPF provide a clear reason for refusing development; or (ii) any adverse impacts of doing so would significantly and demonstrably outweigh the benefits when assessed against the policies in the NPPF taken as a whole.
6.25 Paragraph 48 sets out when weight may be given to relevant emerging plans. This depends on the stage of preparation, the extent to which there are unresolved objections and the degree of consistency with relevant policies in the NPPF.
6.26 Section 9 promotes sustainable transport and encourages development to be focused in locations which are sustainable, limiting the need to travel and offering a genuine choice of transport modes, to reduce congestion and emissions and improve air quality and public health. Paragraph 109 requires that development should only be prevented or refused on highways grounds if there would be an unacceptable impact on highway safety, or the residual cumulative impacts on the road network would be severe.
6.27 Paragraph 118 encourages multiple benefits from urban land including mixed-use schemes and opportunities to achieve environmental gains and gives substantial weight to the value of using suitable brownfield land for homes. Paragraph 119 encourages a proactive role to be taken by LPAs in bringing forward land suitable for meeting development needs, including those held in public ownership.
6.28 Section 12 of the NPPF relates to achieving well-designed places and requires planning decisions to ensure that developments will add to the overall quality of an area, be visually attractive as a result of good architecture, layout and appropriate and effective landscaping.
6.29 Section 16 of the NPPF relates to conserving and enhancing the historic environment which requires applications to describe the significance of a heritage asset affected, including any contribution made by their setting. Paragraph 194 states that any harm to, or loss of, the significance of a designated heritage including from development within its setting requires clear and convincing justification. Paragraph 196 sets out that proposals leading to less than substantial harm to the significance of a heritage asset should be weighed against the public benefits of the proposal including, where appropriate, securing its optimum viable use. Paragraph 193 requires that when considering the impact of a proposed development on the significance of a designated heritage asset, great weight should be given to the asset’s conservation. This is irrespective of whether any potential harm amounts to substantial harm, total loss or less than substantial harm to its significance.
Planning Practice Guidance 6.30 The Planning Practice Guidance (PPG) is published by the Government to provide further detailed guidance on the application of policies set out in the NPPF. It provides guidance in relation to (amongst other things), decision making, planning conditions and obligations, EIA, the historic and natural environment and design.
Quod | Land adjacent to Cockfosters Underground Station | Planning Statement | June 2021 44
Emerging Planning Policy
Enfield – Towards a New Local Plan 2036 - Issues and Options 6.31 LBE is preparing a new Local Plan to 2036 (the Emerging Local Plan). A consultation of the Issues and Options (Regulation 18) version was undertaken between December 2018 and February 2019. LBE have undertaken a ‘Call for Sites’ in 2018, and more recently in February 2021. The Regulation 18 Draft Enfield Local Plan was issued by LBE on 2 June 2021 for consideration by full Cabinet on 9 June 2021 ahead of an expected public consultation.
6.32 The Regulation 18 Draft Enfield Local Plan sets out a spatial planning framework for the development of the Borough from 2019 – 2039. It confirms at Strategic Policy SP SS1 that ‘provision will be made for at least 25,000 new homes up to 2039’ the majority of which would be provided in the four main placemaking areas. It also confirms that Green Belt should be protected from inappropriate development.
6.33 The Site is identified by draft Strategic Policy SP H1 for the delivery of homes, contributing towards the overall target. Allocated sites would contribute 23,610 homes towards the overall target.
6.34 The Site is allocated for housing, and SA31 identifies an estimated capacity of the Site for 316 new homes to be delivered over the next 5-10 years. It highlights the need to consider heritage and the archaeological priority area location.
6.35 Figure 2.3 identifies intensification around Cockfosters transport node, and Figure 7.2 identifies the Site as an area for ‘transformative’ change. The Site is identified as an appropriate location for tall buildings by Figure 7.5.
6.36 Draft Strategic Policy SP H1 allocates the Site for housing development accommodating 316 new homes (estimated capacity) over the next 5-10 years. The detail of this is set out at SA31 showing the boundary of the allocated Site.
6.37 Policy DM DE6 Tall Buildings outlines that the principle of tall buildings will be supported in appropriate locations, however they must be of sufficient design quality and relate well to the character of the immediate context and surrounding area.
Summary 6.38 The Proposed Development has been developed in the context of the requirements of the Development Plan and other material considerations. The next section provides an appraisal of the Proposed Development against the Development Plan and other material considerations in relation to the principle of development, housing, residential mix and density, design quality, townscape and heritage, residential quality and amenity, traffic and transport, environmental considerations, climate change and health.
Quod | Land adjacent to Cockfosters Underground Station | Planning Statement | June 2021 45
7 Planning Considerations
Introduction 7.1 This section provides an assessment of the Proposed Development against the relevant planning policies and guidance set out in Section 6. The following matters are considered in turn:
1 Principle of Development 2 Housing 3 Design Quality 4 Townscape and Heritage 5 Green Belt 6 Residential Quality and Amenity 7 Traffic and Transport 8 Environmental Considerations 9 Climate Change 10 Health 11 Planning Obligations
Principle of Development
Policy Context 7.2 The NPPF paragraph 11 c) requires that planning decisions should apply a presumption in favour of sustainable development by ‘approving development proposals that accord with an up-to-date development plan without delay’. The legislative and policy context makes it clear that Local Planning Authorities should determine development proposals in accordance with the development plan when taken as a whole. It is therefore clear that applications should be determined on the basis of the degree to which they comply with the Development Plan, unless ‘any adverse impacts would significantly and demonstrably outweigh the benefits’ (NPPF paragraph 11d)ii). The Housing Delivery Test results (19th January 2021) show that Enfield delivered 56% of their target over the previous three years, making them a ‘Presumption’ Authority.
7.3 Pursuant to paragraph 8 of the NPPF, the purpose of the planning system is to contribute to the achievement of sustainable development by:
• ensuring the right type of land is developed in the right places (economic objective); • supporting strong, vibrant and healthy communities with enough homes, accessible services and open spaces (social objective); and • protecting and enhancing the natural, built and historic environment including making effective use of land (environmental objective).
Quod | Land adjacent to Cockfosters Underground Station | Planning Statement | June 2021 46
7.4 In terms of the existing land use, the NPPF requires planning to ‘promote and support the development of under-utilised land and buildings, especially if this would help to meet identified needs for housing where land supply is constrained, and sites could be used more effectively (for example… car parks)’ (Paragraph 118). Paragraph 1.2.5 of the London Plan (2021) states that ‘all options for using the city’s land more effectively will need to be explored as London’s growth continues, including the redevelopment of brownfield sites and the intensification of existing places, including in outer London’. London Plan Policy GG2 requires development to prioritise sites that are well-connected by public transport, particularly for intensifying the use of brownfield and surplus public sector land and delivering additional homes.
7.5 Strategic Objective 2 of the LBE’s Core Strategy is to promote sustainable patterns of development by integrating infrastructure and housing, to reduce the Borough’s carbon footprint and minimise the need to travel.
7.6 In relation to housing, Paragraph 59 of the NPPF sets out the government’s objective to boost the supply of homes and the paragraphs following it set out the requirement for the supply of homes to meet the needs of different groups in the community, including for affordable housing. London Plan Policy GG4 supports this agenda, stating that planning and development must ‘A) ensure that more homes are delivered’. Paragraph 1.4.3 of the London Plan (2021) also states that ‘the lack of supply of homes that Londoners need has played a significant role in London’s housing crisis’. It requires planning to create mixed and inclusive communities and ensure that homes are built quickly.
7.7 London Plan (2021) Policy H1 stresses the importance of encouraging residential development on appropriate windfall sites, especially where they have a high PTAL rating (3-6) or are located within 800m of a Tube station, and/or involve the mixed-use redevelopment of car parks (Part B 2)b)) and public sector owned sites (Part B 2)(d)). LBE’s Core Strategy identifies that sustainable locations for development would be concentrated in town centres, on previously developed land and that new homes will be planned through the intensification of land uses (4.1 Spatial Strategy). LBE Policy DMD 8 requires new residential development to be appropriately located, taking into account the nature of the surrounding area and land uses and access to local amenities. This is echoed by LBE’s Emerging Local Plan within draft Policy H1 c) which states that development proposals must ‘make the most efficient possible use of land by promoting higher density development in suitable, accessible locations, taking into account local character and existing and planned infrastructure capacity’. The London Housing Strategy (2018) at paragraph 3.27 states that ‘incentives are needed to encourage landowners to redevelop sites that are currently used inefficiently – such as surface car parks…and to support quicker build out rates on sites’.
7.8 Paragraph 102 of the NPPF sets out objectives for considering transport issues in the planning process, including ensuring opportunities to promote walking, cycling and public transport. It requires development to be focused on locations which are sustainable and can offer a range of transport modes to help reduce congestion and emissions and improve air quality and public health (Paragraph 103 of the NPPF).
7.9 In relation to the proposed commercial unit, Policy E9 of the London Plan (2021) supports the development of convenience retail in town centres including Local Centres as well as their enhancement to secure inclusive neighbourhoods and a sustainable pattern of provision to create less need to travel. LBE Core Strategy Policy 17 seeks to support the provision of local
Quod | Land adjacent to Cockfosters Underground Station | Planning Statement | June 2021 47
shopping facilities within Local Centres serving the local community and largely catering for those living within walking distance.
Assessment 7.10 The Proposed Development accords with the Development Plan and the NPPF which promote sustainable patterns of development by redeveloping a public sector owned brownfield site, currently occupied by surface car parking with poor quality public realm, well connected by public transport.
7.11 There has been a strong policy shift towards the importance of optimising the capacity of housing, and prioritising this over other land uses, especially surface car parking, which is inefficient and encourages unsustainable modes of travel. The reuse of an inefficiently used site such as this, used for car parking is supported by London Plan Policy H1 (Part B 2)) and the London Housing Strategy, and NPPF paragraph 118.
7.12 The starting point for the Proposed Development was to provide only Blue Badge parking in accordance with London Plan Policy T6. However, as a result of feedback at pre-application stage, a small number (35) of general purpose public car parking spaces are proposed along with seven pick-up/drop-off spaces. The amount of car parking has been kept to a minimum to avoid encouraging car travel which contributes to congestion, air quality deterioration and public health problems. The terminus location and relatively good public transport connections, giving the Site a PTAL of 3-4 means that the minimum necessary parking ‘car-lite’ is proposed as required by London Plan Policy T6 Part B.
7.13 The residential development would be car-free, with the exception of residential Blue Badge parking spaces. A car club space is proposed to be provided on Site for use by residents and the wider public.
7.14 The Proposed Development meets the requirements of Policy GG2 of the London Plan (2021) for creating successful sustainable mixed-use places that make the best use of land by:
• enabling the development of brownfield land; • developing on surplus public sector land; • utilising a site on the edge of a (town) centre; and • utilising a site which is well-connected by existing public transport. 7.15 The Proposed Development offers an opportunity for more sustainable travel patterns by local residents, achieving the NPPF objective of allowing people to live, work and undertake day to day activities without the need to drive. The Site also supports those who find travel by means other than driving more difficult, such as Blue Badge holders to access the Station and local services in Cockfosters centre.
7.16 Cockfosters is defined in LBE’s Core Strategy as a large local centre, and the Development Plan supports the reinforcement and additional provision of retail in such locations, largely serving the local community. The proposed small commercial unit as part of the Proposed Development is, therefore, supported by policy.
Quod | Land adjacent to Cockfosters Underground Station | Planning Statement | June 2021 48
Conclusion 7.17 The Site is currently characterised by the clutter of private vehicles and signage, as well as advertisement hoarding, providing a poor setting for the listed station, and minimal, low quality vegetation. The Proposed Development would create a more welcoming public realm around the Station and improve the natural qualities of the Site tying into the adjacent park, SINC (SBINC and SMINC) and ecological corridor. The Proposed Development would provide additional homes, contributing towards a vibrant and diverse community, and counteracting the need for alternative sites to be found in Enfield, which may be in less sustainable locations to ensure sufficient homes are delivered.
7.18 The Proposed Development accords with the objectives of the Development Plan and the NPPF as well as other relevant material considerations in relation to sustainable development by:
• redeveloping a public sector owned brownfield site, currently occupied by surface car parks with poor quality public realm; • providing homes that are highly accessible and directly adjacent to existing public transport connections and easily accessible to local amenities and by sustainable travel modes; • providing a range of housing to support a mixed and balanced community; and • respecting the local natural and built environment by providing buildings that appreciate the heritage setting, increase the amount of open space and vegetation and are sensitively designed in response to the local context. 7.19 The benefits of the delivery of housing, including affordable housing, on a previously developed site are substantial and should be afforded significant weight in the planning balance in determining the application.
Housing
Policy Context 7.20 Policy H1 of the London Plan (2021) sets a ten year housing target for net completions of 522,870 across London. This target does not meet the full objectively assessed need identified in the London Strategic Housing Market Assessment (2017) (London SHMA) of 66,000. LBE Core Strategy Policy 2 sets an annualised housing delivery target of 395 dwellings per year.
7.21 LBE’s housing delivery target set by the London Plan (2021), based on the London SHMA (2017), is for a minimum of 1,246 dwellings per year to be delivered (Table 4.1) over the next 10 years. If calculated using the latest version of the MHCLG’s standard methodology (December 2020), the target would be 4,397 per annum. LBE’s draft Housing and Growth Strategy (2020-2030) confirms LBE’s ambition to deliver the higher targets set by the London Plan and identifies the importance of ‘the right kind of homes, in the right locations, for local people’. Housing delivery targets outlined in LBE’s Core Strategy Policy 2 have therefore been superseded by the most recent requirements.
7.22 According to LBE’s Housing Trajectory, cumulative completions over the next five years are projected to be 4,808 new homes (for the period 2018-2023). This is 961.6 per annum, falling short of the requirement in the London Plan (2021) for 1,246 homes per annum. Although this
Quod | Land adjacent to Cockfosters Underground Station | Planning Statement | June 2021 49
delivery will significantly contribute towards LBE’s minimum housing target, it is evident that additional provision will be required, particularly in light of the impact that the current pandemic is expected to have on housing delivery, especially in the short term.
7.23 LBE's Housing Action Plan (2019) recognises that the construction of more quality homes at affordable prices to meet residents’ needs is a top priority (paragraph 2.3). In Enfield, 1,314 homes were delivered over the period 2017 to 2020 (Housing Delivery Test 2020 Measurement published January 19 2021). This represents 56% of LBE’s housing requirement over the past 3 years. LBE’s under delivery of homes triggers the requirements of NPPF paragraph 11 d) meaning that the local policies which are most important for determining the application are out-of-date.
7.24 The GLA London Housing SPG (2018) seeks to ensure that planning prioritises the development of the right number and the right mix of homes, outlining a vision that delivers high quality homes and inclusive neighbourhoods, a fairer deal for private renters and genuinely affordable homes.
7.25 The London Plan (2021) Policy H1 requires housing delivery to be optimised on sites that have good public transport accessibility (PTAL 3-6), mixed-use redevelopment of car parks and public sector owned sites. This is echoed in the emerging Enfield Local Plan which identifies the need to intensify development areas around key overground and underground rail stations and redevelop underutilised and low-density land such as surface car parks. The emerging Local Plan also recognises the need to ‘genuinely commit to deliver sufficient new housing to address our needs’, for example related to 'size and tenure’.
7.26 Around 40% of Enfield is designated Green Belt, making development in the area challenging. Enfield is one of the least densely populated areas of London as a result. The London Plan (2021) (Policy G2) restricts development in the Green Belt in accordance with the NPPF and therefore opportunities for the provision of housing are limited and should be directed to inefficiently used brownfield sites in order to protect the Green Belt.
Residential Mix 7.27 London Plan (2021) Policy H10 encourages a full range of housing choice, stating that boroughs should not set prescriptive dwelling size mix requirements for market and intermediate homes. It also encourages boroughs to set out the preferred housing mix for all tenures as part of a site allocation. Town centre housing at higher densities close to public transport facilities is identified as being especially suitable for one and two person households (GLA London Housing SPG 2016 paragraph 7.4.9). Guidance on the approach to unit size mix in BtR schemes is also set out in paragraph 4.31 of the GLA’s London Affordable Housing and Viability SPG (2017) which requires local policies on unit mix to be applied flexibly to Build to Rent schemes in locations on the edge of town centres or near transport nodes (this is also set out at paragraph 3.3.11 of the Housing SPG 2016). It recognises that demand in the rental sector, such as Build to Rent is much greater for one and two beds than in owner-occupied or social/affordable rented sector.
7.28 The emerging LBE Local Plan identifies that providing a range of different dwelling types and sizes supports the creation of mixed, balanced and sustainable communities. The London SHMA outlines that the strongest growth in households is among one person households and other childless household types. The annualised requirement for new homes (2016-2041)
Quod | Land adjacent to Cockfosters Underground Station | Planning Statement | June 2021 50
shows a need for 55% of new homes to be 1-bed, 16% 2-bed and 14% 3-bed. LBE Core Strategy Policy 5 does not set unit mix requirements for intermediate tenures, and LBE Policy DMD 3 requires development to provide a mix of different sized homes, including family sized accommodation. It should be noted that LBE Core Strategy Policy 5 and LBE Policy DMD 3 are out-of-date.
Build to Rent 7.29 The GLA Affordable Housing and Viability SPG (2017) sets out the intention to invest more in affordable housing and bring forward more public land for affordable homes. Some of the benefits of Build to Rent (BtR) are outlined at paragraph 4.4 of the SPG as follows:
• offering longer-term tenancies and more certainty over long-term availability; • ensuring a commitment to, and investment in, place making through single ownership; and • providing better management standards and higher quality homes than other parts of the private rented sector 7.30 The GLA London Housing SPG (2016) also notes that Build to Rent can be particularly suited to higher density development within or on the edge of town centres or transport nodes (paragraph 3.3.11).
7.31 LBE’s adopted Core Strategy and Development Management Document are silent on BtR. The Enfield Regulation 18 Local Plan (2021) supports the provision of BtR development subject to a number of considerations. The requirements of this draft policy echo the London Plan (2021). The relevant policy requirements for BtR schemes are set out in London Plan Policy H11 and within national planning policy and guidance (NPPF Annex 2, PPF Build to Rent). Policy H11 requires Boroughs to take a positive approach to the BtR sector ‘to enable it to better contribute to the delivery of new homes’. It outlines the benefits of BtR and the ways in which developments can increase housing supply. Paragraph 5.6.5 of LBE’s Emerging Local Plan states that LBE supports BtR and will positively promote the housing product through policy making, anticipating that it will become an important component for delivering a choice of housing. This is reinforced by draft Policy H5, and LBE’s draft Housing and Growth Strategy (page 14) which state that LBE will work to proactively increase the quality and affordability of the private rented sector through BtR housing products offered at a range of rental levels.
7.32 The suitability and benefits of BtR are as follows:
• BtR is forward funded and therefore less impacted by economic uncertainty and cycles than private sale. It has improved deliverability, meaning the delivery of much needed new homes and affordable homes is more likely; • BtR can be delivered and occupied quickly to address the existing shortfall in Enfield; • BtR schemes provide a long-term income stream that the Applicant can use to re- invest in long-term place making/maintenance of the Proposed Development to ensure it remains attractive for renters and the public, as well as London’s public transport network; and
Quod | Land adjacent to Cockfosters Underground Station | Planning Statement | June 2021 51
• longer-term tenancies and placemaking provide more impetus for renters to stay longer, and the provision and breadth of supporting amenity spaces supports a sense of community. 7.33 The relevant policy requirements for affordable housing delivered by Build to Rent schemes are set out in Policy H11 of the London Plan (2021) and Annex 2 of the NPPF.
Affordable Housing and Tenure 7.34 LBE Policy DMD 1 sets a borough-wide affordable housing target of 40%. LBE’s draft Housing and Growth Strategy (2020-2030) outlines LBE's aspiration to ‘develop more homes that are genuinely affordable to local people, so that more people can live in a home where they spend a more reasonable proportion of their household income on housing costs’ (page 13).
7.35 Policy H5 of the London Plan (2021) sets a strategic target for 50% of all new homes delivered across London to be affordable and Policy H6 sets a threshold for 50% affordable housing for public sector land. The Site forms part of a portfolio of sites owned by TfL being brought forward to deliver new homes. The TfL portfolio as a whole is required to deliver at least 50% affordable housing. The CLL BtR Sites as part of that portfolio are required to deliver a minimum of 40% affordable homes (by habitable room) as part of the overarching 50% target.
7.36 LBE Policy DMD 1 requires development to provide the maximum amount of affordable housing, having regard to the borough-wide affordable housing target of 40% (set by LBE Core Strategy Policy 3) and the need to provide an appropriate mix of tenures. For each development, LBE will plan for balanced and sustainable communities and work to agree an appropriate figure with developers as set out by LBE Core Strategy Policy 3.
7.37 In 2016/17, 30% of housing completions in LBE were affordable, whilst in 2017/18 only 7% of housing completions were affordable, amounting to 37 units in total being delivered. The target 40% affordable housing delivery is therefore not currently being met in the Borough.
7.38 In terms of tenure, LBE Policy DMD 1 sets a borough-wide target for affordable tenure mix and requires that negotiations should take into account the specific nature of the site, development viability and the need to achieve more mixed and balanced communities. The borough-wide target is for 30% intermediate tenure units.
7.39 The London Plan (2021) Policy H11 allows development proposals that are BtR and meet the relevant criteria to provide a sole DMR offer at a genuinely affordable rent, preferably London Living Rent levels, and for homes to be secured in perpetuity. Para 4.11.1 of the London Plan (2021) requires Boroughs to take a positive approach to the BtR sector.
7.40 The Mayor’s Housing Strategy sets out the definition for ‘genuinely affordable’ homes and the advantages of delivering a range of development models, sites and types of homes. The London Plan (2021) expects at least 30% of DMR homes to be provided at an equivalent rent to London Living Rent at the time of first letting, with the remaining 70% at a range of genuinely affordable rents (Policy H11 Part C)). LBE’s Core Strategy does not provide tenure requirements for covenanted BtR schemes.
7.41 The Housing Delivery Statement (Quod, June 2021) which accompanies this application demonstrates that there is a significant need in Enfield to increase the delivery of intermediate
Quod | Land adjacent to Cockfosters Underground Station | Planning Statement | June 2021 52
tenures to meet emerging housing need. Since preparation of the Enfield Strategic Housing Market Assessment (SHMA) in 2015, affordability has become more challenging in Enfield as house prices rose well beyond the England average. At the same time, eligibility for the housing waiting list was tightened in 2012 following the introduction of the Localism Act (2011). Consequently, there are now around 68,000 households (approximately 52%) in Enfield who have incomes meaning they would be ineligible to be allocated social housing from LBE’s waiting list but cannot afford to buy. These households are typically first-time buyers and key workers including police officers, teachers, nurses and other health professionals. The existing rental housing stock is mainly low-quality, of which only 1% is intermediate and 18% private rented in the local ward. The current amount of private rented homes is insufficient in both amount and quality to meet growing housing need and is reducing due to national changes in the stamp duty and capital gains tax regimes. There is therefore a large local demand for housing from those who would be eligible for intermediate housing.
7.42 Analysis of the London SHMA identifies population projections finding that around 70% of newly forming households between 2011 and 2035 will be 1 and 2 person households without children, partly due to recent growth in concealed and overcrowded households. The Cockfosters Ward is largely dominated by owner occupied housing and the area already has a high proportion of 3+bed family houses. The evidence therefore shows that there is a local need for intermediate properties and smaller unit sizes to provide a more mixed and balanced community.
Assessment 7.43 Enfield has a substantial borough-wide need for all sizes, types and tenures of housing including affordable housing. The Site is well located for the delivery of housing due to its good levels of public transport connectivity and proximity to a local centre. It would contribute towards the current shortfall in housing delivery within the Borough, particularly affordable housing. It should be noted that given that the policies in the Local Plan are out-of-date in accordance with paragraph 11(d) of the NPPF, the London Plan is the most relevant document to consider the Proposed Development against.
7.44 The Proposed Development of 351 units is fully compliant with the definition of a BtR scheme in accordance with Policy H11 (London Plan (2021) and Policy H5 of LBE’s Emerging Local Plan. The location of the Site partially within Cockfosters Local Centre and at a transport node means Build to Rent development is particularly suited to this Site (London Housing SPG 2016, para 3.3.11).
7.45 The Proposed Development includes 60% one bed, 30% two bed and 10% three bed units. The mix of sizes takes into account: i) growing demand for smaller homes; ii) high number of large family houses available in the area; iii) the Site’s highly accessible location; and iv) the positive role one and two bedroom homes play in providing housing for down sizers and overcrowded concealed households, as recognised in the London SHMA. In a BtR scheme adjacent to an Underground station (as is the case with the Proposed Development) one and two bed units are generally considered to be more appropriate (London Plan Policy H10, Affordable Housing and Viability SPG and London Housing SPG).
7.46 The offer is supported by London Plan and the Emerging LBE local plan policies, which seek to encourage the delivery of this type of residential provision. All residents would have the option for tenancy agreements of between 1 and five years, on fair rental terms with reviews
Quod | Land adjacent to Cockfosters Underground Station | Planning Statement | June 2021 53
set out at the point of signing the tenancy agreement. Residents would also have the flexibility to move within the existing building or to another site operated by CLL. This alternative offer would allow local residents who cannot afford to stay in the borough or who live in poor quality private rented accommodation, an opportunity to stay in the local area, and builds a sense of community. It can also be delivered more quickly than private sale schemes to clawback some of the under-provision of housing experienced in the borough against their housing targets.
7.47 The Proposed Development would deliver 132 new affordable homes which amounts to 40% affordable housing (by habitable room) or 38% affordable housing (by unit). The Proposed Development would maximise the delivery of affordable housing on the Site based on the viability of the scheme . This application is accompanied by an open book viability appraisal which sets out the viability of the Proposed Development and demonstrates that the proposed level of affordable housing exceeds the amount that the Proposed Development can viably deliver. LBE Core Strategy Policy 3 sets a borough-wide target of 40% affordable housing, and requires LBE to work with developers to agree an appropriate figure for each site, with consideration for grant availability and viability assessments as well as other priorities and obligations. The Proposed Development therefore meets the requirements of London Plan and Local Plan policies for the proportion of affordable housing provided.
7.48 The Site forms part of a portfolio of sites owned by TfL which are being brought forward to support the Mayor’s ambition of increasing the proportion of new homes that are affordable. In line with the London Plan (2021), the TfL portfolio agreement is to deliver a minimum of 10,000 homes across London, all BtR sites are required to deliver a minimum of 40% affordable homes. The Proposed Development would provide 40% affordable housing (by habitable room) on-site which is in excess of the London Plan (2021) minimum requirement. The proposed affordable proportion has been agreed with the GLA as part of that portfolio of sites to be delivered by TfL and secures grant funding for affordable housing units. The Proposed Development therefore provides the maximum reasonable amount of new affordable homes and meets the relevant London Plan policy requirements.
7.49 The Proposed Development offers a range of rental types within the affordable provision, all of which would be at Discounted Market Rent (DMR) levels. Of those affordable units, 30% (40 units) would be at London Living Rent equivalents (based on LLR levels at the time of the planning application as a discount to the market rent) and 70% (92 units) at Discount Market Rent set at 65-70% of Open Market Rent, subject to the GLA’s DMR income caps in place at the time of letting (Housing Delivery Statement, Quod, June 2021).
7.50 The mix of tenures is compliant with Policy H11 Part C of the London Plan (2021). In addition, the provision of DMR in an area with existing low levels of intermediate housing (around 1%) would assist in creating a more mixed and balanced community in accordance with LBE Policy DMD 1. This also aligns with LBE’s now out-of-date Core Strategy Policy 5 which requires development to deliver a range of housing types in the intermediate sector, to be determined on a site by site basis.
7.51 The proposed rents and tenures would ensure that 40% of the new the homes would be ‘genuinely’ affordable to many local frontline workers such as nursing, health and welfare professionals or teaching and educational professionals who cannot easily afford private for sale or private rented homes but are not eligible for social housing.
Quod | Land adjacent to Cockfosters Underground Station | Planning Statement | June 2021 54
Conclusion 7.52 The Proposed Development would make a substantial contribution to local housing need. LBE policies are silent on BtR and out-of-date and, therefore, should not be relied upon. The amount and type of housing proposed addresses an identified need for more and higher quality private rented housing in Enfield, particularly intermediate housing, which accounts for only 1% of existing stock. The Proposed Development accords with the strategic affordable housing targets set out in the London Plan (2021), as part of a portfolio of public sector land sites being brought forward by TfL, and the intermediate tenure and proportions accord with the London Plan and GLA Housing SPG requirements. The Proposed Development would make a significant contribution towards the BtR and affordable housing offer within Enfield and fully complies with relevant and up to date development plan housing policies in the London Plan 2021.
7.53 The proposed mix of units is appropriate in accordance with the Policy H10 of the London Plan (2021) and will meet an identified demand for one and two bed units and contribute to a mixed and diverse community in an area currently dominated by three bed and larger housing provision.
7.54 The Proposed Development accords with the outline housing mix requirement identified by the Mayor's Affordable Housing and Viability SPG. The Proposed Development would comply with the relevant local and national policies in relation to housing delivery.
Design Quality
Policy Context 7.55 Paragraph 122 of the NPPF states that in respect of development density, consideration should be given to whether a place is well designed and ‘the desirability of maintaining an area’s prevailing character and setting…or of promoting regeneration and change’. Chapter 12 (Achieving well-designed places) goes on to set out the need for good design as the key to sustainable development. At Paragraph 127, it states that planning decisions should ensure that developments:
a) Will function well and add to the overall quality of the area, not just for the short term but over the lifetime of the development;
b) are visually attractive as a result of good architecture, layout and appropriate and effective landscaping;
c) are sympathetic to local character and history, including the surrounding built environment and landscape setting, while not preventing or discouraging appropriate innovation or change (such as increased densities);
d) establish or maintain a strong sense of place, using the arrangement of streets, spaces, building types and materials to create attractive, welcoming and distinctive places to live, work and visit;
e) optimise the potential of the site to accommodate and sustain an appropriate amount and mix of development (including green and other public space) and support local facilities and transport networks.
Quod | Land adjacent to Cockfosters Underground Station | Planning Statement | June 2021 55
7.56 LBE Policy DMD 6 refers to the now superseded Density Matrix in the 2016 London Plan. The London Plan (2021) does not provide such a matrix, rather Policy D3 requires development to optimise and make the best use of land, considering design, to determine the most appropriate form for the site’s context and capacity. This is echoed by LBE Policy DMD 8 which requires proposals to be in an appropriate location and of a suitable scale, bulk and massing.
7.57 The London Plan (2021) Policies D1 and D2 seek to ensure that new developments are well- designed and fit into the local character of an area. Policy D3 of the London Plan (2021) requires developments to optimise capacity through a design-led approach, by responding to a site’s context, capacity for growth and supporting infrastructure capacity, which is echoed by Policy GG2 of the London Plan (2021). New buildings and spaces should respond to the form, style and appearance to successfully integrate into the local character of an area, have a positive relationship with the natural environment and respect and enhance the historic environment. London Plan Policy D8, LBE Core Strategy Policies 9 and 25, and LBE Policy DMD 37 require new developments to deliver new public realm wherever possible. New public realm should be of high quality, easy to understand, safe, attractive, uncluttered and effective. Public spaces should prioritise movement by pedestrians and cyclists to encourage active travel, and improvements at and around public transport interchanges are particularly supported to improve safety, security and wayfinding.
7.58 London Plan Policy D4 requires development proposals to demonstrate that they meet the design requirements of the London Plan. Design should be thoroughly scrutinised by borough planning, urban design and conservation officers and expert advice where appropriate. The design review process should be used to assess and inform design options early in the planning process. The scheme meets the criteria to require that the Proposed Development must have undergone a local borough process of design scrutiny in accordance with London Plan Policy D4 (Part E). LBE Policy DMD 38 requires design and access statements to clearly document the design evolution. It states that the advice of the design review panel will be a material consideration when assessing applications.
7.59 LBE Policy DMD 37 sets out the requirements for achieving high quality design including ensuring proposals are appropriate to their context and have appropriate regard to their surroundings.
7.60 London Plan (2021) Policy D9 (Part A) requires Development Plans to define what is considered a tall building for specific localities. LBE Policy DMD Paragraph 6.4.1 states that tall and large are those that are substantially taller than their surroundings, cause a significant change to the skyline or are larger than the threshold sizes set for the referral of planning applications to the Mayor. Referable applications are those including development over 30m in height.
7.61 London Plan (2021) Policy D9 (Part B) requires Development Plans to identify on maps, locations where tall buildings may be an appropriate form of development. LBE has not yet prepared such a map that meets the requirements of Policy D9.
7.62 LBE Policy DMD 43 states that tall buildings in areas classified as inappropriate are unacceptable. The policy applies to buildings over 30m in height or a building defined as ‘tall’ by the local planning authority's development plan. The areas identified include those within and adjacent to the Green Belt, within the boundary or in the immediate vicinity of Conservation
Quod | Land adjacent to Cockfosters Underground Station | Planning Statement | June 2021 56
Areas, Listed Buildings and Registered Parks and Gardens. The onus is placed on the developer to demonstrate how the proposal avoids negative impacts in accordance with this policy. Part 4 to DMD 43 sets out criteria which development must meet to assess the suitability of individual sites. London Plan (2021) Policy D9 requires development proposals for tall buildings to address visual, functional, environmental and cumulative impacts. It also states that tall buildings should reinforce the spatial hierarchy of the local and wider context, be constructed of high quality materials and ensure the architectural integrity of the buildings can be maintained in perpetuity.
7.63 LBE’s Emerging Local Plan Policy D2 states that LBE will seek to contribute to the growth agenda by ‘a) ensuring more tall buildings and higher density development are realised in appropriate places in the borough through innovative high quality design, taking into account local character and context. Tall buildings are defined as substantially taller than their surroundings’.
7.64 When read as a whole, the Development Plan supports the optimisation of sites that are previously developed, located in local centres and well connected by public transport, as is the case here. However, the importance of sensitive design is also given weight in determining whether the specific proposals are appropriate for their location. Given the out-of-date polices of the LBE DMD and the limited weight attributed to emerging Local Plan Policies in accordance with the NPPF paragraph 48, the Development Proposals should be considered in the context of up-to-date policies including the London Plan (2021) as required by NPPF paragraph 11d) and footnote 7.
Assessment 7.65 The Proposed Development has undergone a process of design scrutiny at pre-application stage, including two reviews by the Design Review Panel (DRP), and Mayoral Design Advocates (MDA). The process is set out in Section 4 to this Statement. The process meets the requirements of London Plan Policy D4 as the buildings are defined as ‘tall buildings’. The advice of the DRP and MDA supported the strategic approach to scale and massing and made recommendations for refinements including variation in height of the buildings and creating a slimmer profile. The comments were taken on board as part of the design evolution.
7.66 This section provides an overview of the changes to design that were made to respond to all site constraints, policy considerations and advice received at pre-application stage from nine design-focused meetings with LBE officers. The Design and Access Statement provides a summary of how the scheme achieves high quality design.
7.67 At present, the area around the Station is predominantly low density in nature with taller buildings opposite and adjacent to the Site at Metro Point and Blackhorse Tower with a resolution to grant planning permission for 10 storeys. The car-oriented community and a lack of smaller units and flats mean there is an opportunity for a greater mix of unit types and greater density at this Site, given its location partially within a Local Centre and at a transport and service node as highlighted by the London Plan (2021) Policy SD7, the GLA’s Housing SPG and the Mayor’s Affordable Housing and Viability SPG. The prevailing heights immediately adjacent to the Station are taller and the good connectivity provided by the station in particular provides an opportunity for a more optimum use of the Site.
Quod | Land adjacent to Cockfosters Underground Station | Planning Statement | June 2021 57
7.68 The Proposed Development achieves the following densities, which are required to be provided by paragraph 3.3.22 of the London Plan (2021):
• Number of units (351) per hectare (1.36) = 258 units/ha • Number of habitable rooms (877) per hectare = 644 hr/ha • Number of bedrooms (526) per hectare = 387 bedrooms/ha • Number of bedspaces (1,007) per hectare = 740 bedspaces/ha 7.69 Policy H10 of the London Plan (2021) promotes higher density development in locations with a good PTAL score and in close proximity to a local centre in order to ensure the most efficient use of land and to optimise the provision of housing.
Layout, Scale and Massing 7.70 The Site is in a sensitive location, partly within a Conservation Area, Area of Special Character, adjacent to the Green Belt, Sites of Importance for Nature Conservation and listed heritage assets. There are a significant number of mature trees and tree belts surrounding the Site to the north and east and within Trent Park registered park and gardens which obscure the views of the Site from the surrounding park. To the west and south, adjacent buildings Metro Point at four storeys and Blackhorse Tower at nine storeys, obscure views from the adjoining residential area. In 2017, LBE’s planning committee resolved to grant approval for the redevelopment of Blackhorse Tower including increasing the height by an additional storey to 10 storeys. An understanding of the topography and landscape features which provide a buffer between the urban and rural surroundings has been the starting point for the Proposed Development of the Site to provide new homes.
7.71 The layout and massing for the Proposed Development has evolved through an extensive and iterative pre-application process which enabled a thorough assessment of the design at each stage of its development to achieve a balance between the need for homes against the scheme impacts. The Site capacity has been optimised, whilst taking a heritage and landscape-led approach, balancing against the other constraints of the Site (such as tree protection areas, Thames Water easements and LUL requirements for maintaining the functioning of the Underground. The critical moves that have balanced this approach are:
• A reduction in the number of units from 400 to 351 to reduce the bulk and massing of development; • A reduction in the number of buildings from six to four improve the separation distance between them, and the listed station, resulting in an increase in the number of units in each building. • The massing on Site B was reduced to align with the adjacent Blackhorse Tower and the context of Cockfosters Road and more height accommodated on Site A. • Fewer buildings allow taller and more slender built forms at upper storeys so that development appears more elegant in the skyline. To deliver sufficient numbers of units, larger ‘shoulder’ buildings of up to six storeys which are obscured by mature tree belts accommodate more units at lower levels. • The arrangement at ground level evolved to move massing away from the station building and provide a sensitive response which does not reduce internal daylight levels in the ticket hall and train shed.
Quod | Land adjacent to Cockfosters Underground Station | Planning Statement | June 2021 58
• The arrangement avoids the appearance of bulk behind the station when viewed from Cockfosters Road and the layout and massing has been arranged so that sky appears between each building in most views, particularly those from Trent Park to avoid the forms coalescing in the skyline. • This layout provides a landscape arrangement which minimises the amount of hardstanding and provides high levels of sunlight within communal amenity spaces. 7.72 The resulting layout and massing improve the setting of the heritage assets and minimise the appearance of built form in key views, particularly from Trent Park Registered Park and Garden and the designated Green Belt whilst balancing against residential amenity.
7.73 The heritage context has informed the amount and arrangement of development on the Site. The heritage context and analysis are provided in more detail under the Townscape and Heritage section below.
Design and Materials 7.74 The design has sought to create buildings that sit comfortably next to the listed Station and celebrate its location at the gateway to London. The Proposed Development recognises that the buildings would be visible in some views and glimpsed in others and has sought to mitigate the impacts by employing.
7.75 The design and materials have been considered within the site context and how the buildings will be seen in kinetic views. The principle of a simple, calm, gridded façade has been used for each building, with variety of detailing to create a family of buildings. Site A take cues from the nearby heritage features of Christ Church and 19th Century cottages along Cockfosters Road using light tones of brick and pre-cast concrete. On Site B, Block 4 uses darker reddish-brown brick to tie into the listed station and the surrounding urban context including the adjacent Cockfosters Parade. The ground floor plinth providing a commercial unit creates an active frontage that integrates into the townscape of Cockfosters Road, whilst reading at a human scale in relation to the single storey station building as required by LBE Policy DMD 40.
Public Realm 7.76 The Proposed Development involves the delivery of new areas of public spaces around the Station, along the part of the high street within the Site, and throughout the Proposed Development. The design accords with the requirements of London Plan Policy D8.
7.77 Existing poor quality, cluttered spaces including advertisement hoarding will be removed and replaced with a clear and accessible streetscape, including around the two secondary entrances to the Station, one of which provides new step-free access (to the north of the Station within Site A). The spaces have been designed based on an understanding of desire lines and how the spaces will function as set out by London Plan Policy D8 (Part D and E). The proposals will provide easy access between transport modes including the general purpose car parking, Blue Badge spaces (Site A) and cycle hub (Site B) as well as short stay cycle parking in the public realm. Seating would be provided around the Site in sheltered locations and substantial green infrastructure including new tree planting is proposed to provide environmental and visual benefits. Pedestrians and cyclists will be prioritised with clear demarcation between vehicles and people. Lighting and CCTV will also be integrated into the detailed design to provide a sense of safety and security.
Quod | Land adjacent to Cockfosters Underground Station | Planning Statement | June 2021 59
7.78 The Build to Rent nature of the Proposed Development means that management and maintenance of publicly accessible landscape spaces will be secured in perpetuity. On-site concierge and management will contribute to feelings of safety and security, and relationships between the internal and external uses have been considered to provide natural surveillance.
Tall Buildings 7.79 Paragraph 3.9.1 of the London Plan (2021) states that tall buildings ‘can form part of a plan- led approach to facilitating regeneration opportunities and managing future growth’ and identifies the opportunity for them to contribute towards making the optimum use of sites which are well-connected by public transport and have good access to services and amenities.
7.80 The proposed buildings are a range of 10, 13 and 14 storeys at their tallest point and exceed 30m, therefore being classified as ‘tall buildings’ in accordance with the London Plan (2021) definition (Policy D4) and LBE Policy DMD 43. The massing and heights have been designed to work with the existing landscape buffer to minimise the visibility from Trent Park and the setting of the registered park and garden. Each building also has a lower element of between 5 and 6 storeys to respond to this context and benefit from the mature landscape to screen the amount of built form visible from longer range views. The development of the Site, which is currently tarmac, would also provide an opportunity to improve the physical surroundings of the listed Station, the appearance and setting of the Conservation Area and extend the greenery of the adjoining Trent Park into the Site. The building on Site B has been reduced in scale to 10 storeys to tie into the datum of the approved scheme to increase Blackhorse Tower by one storey and taller elements of the Proposed Development are focused on Site A.
7.81 Whilst planning policy takes a cautious approach to the introduction of new tall buildings, it also recognises the need to optimise the capacity, particularly of brownfield sites in sustainable locations. Policy D3 of the London Plan (2021) requires proposed developments to take a design-led approach to optimising capacity, having regard to local character and distinctiveness and Policy D9 recognises the role that taller buildings can play in achieving this. The emerging LBE Local Plan acknowledges the need to ‘exhaust all reasonable opportunities on brownfield land, making underused land work harder and optimising densities’ which remains a ‘first principle’ of the document (paragraph 2.4.1).
7.82 The design of the buildings has been considered in line with the requirements and guidance of London Plan Policy D9 of the London Plan and supporting text, and the criteria set out at LBE Policy DMD 43 section 4. The location of the Site falls under the definition of ‘areas inappropriate for tall buildings’ set out by LBE Policy DMD 43, however the LBE Regulation 18 Local Plan expected to be published for consultation in June 2021 identifies the Site as an appropriate area for tall buildings (up to 45m), however this has not yet been through public consultation or involved engagement with neighbouring boroughs as required by London Plan Policy D9. Paragraph 3.9.2 of the London Plan also requires that locations should be identified for growth as part of London Plan Policy D1 which includes following a design-led approach to establish optimised site capacities. In the absence of defined locations, it is material to consider the advice provided by the Local Planning Authority during the pre-application process. Feedback from meetings confirmed that LBE Officers consider the bulk, scale, massing and design of the Proposed Development to be generally positive following testing of numerable options for the Site and in the balance of housing need in the Borough.
Quod | Land adjacent to Cockfosters Underground Station | Planning Statement | June 2021 60
7.83 Furthermore, LBE Policy DMD 43 sets out locations that may be appropriate for tall buildings as those with good access to public transport, contain existing tall buildings and within designated town centres or activity hubs. It also, however, outlines locations that may be appropriate for tall buildings which includes areas with good access to public transport, contain appropriate clusters of tall buildings and/or are within designated town centres, activity hubs or regeneration areas. The Site meets these criteria and given the location of the Site next to the Station and as a previously developed site, there is a strategic justification for buildings of the proposed scale in this location, particularly in the context of the significant need for housing in LBE.
7.84 The design of the buildings has been assessed against the requirements and guidance of Policy D9 of the London Plan (2021) and supporting text. The table below provides an analysis of the Proposed Development against the requirements of Policy D9. LBE Policy DMD 43 section 4 also requires the design of developments involving tall buildings to consider a set of criteria.
Definition
A Based on local context, Development • The Proposed Development involves ‘tall Plans should define what is considered a buildings’ in accordance with LBE DMD tall building for specific localities, the Paragraph 6.4.1 and London Plan height of which will vary between and Paragraph 3.9.3. within different parts of London but should not be less than 6 storeys or 18 metres measured from ground to the floor level of the uppermost storey.
B Locations
1) Boroughs should determine if there are • LBE does not have any up-to-date locations where tall buildings may be an policies which formally identify suitable appropriate form of development, subject locations for tall buildings and have not to meeting the other requirements of the engaged with neighbouring boroughs. Plan. This process should include engagement with neighbouring boroughs that may be affected by tall building developments in identified locations.
2) Any such locations and appropriate tall • LBE does not have any up-to-date building heights should be identified on policies which formally identify suitable maps in Development Plans. locations for tall buildings.
3) Tall buildings should only be developed • Specific suitable locations have not been in locations that are identified as suitable identified by LBE. in Development Plans. • The location of the Site falls within the definition of a ‘sensitive location’ in accordance with LBE Policy DMD 43 being partly located within a conservation area, adjacent to the Green Belt, sites of importance for nature conservation and
Quod | Land adjacent to Cockfosters Underground Station | Planning Statement | June 2021 61
listed heritage assets. The proposals therefore comprise tall buildings which DMD 43 acknowledges could be supported provided that certain criteria are met. • Pre-application advice from LBE is a material consideration in this instance, and confirms LBE support for Proposed Development.
C Development proposals should address the following impacts:
1) Visual impacts1
a) the views of buildings from different • The design determinants and analysis of distances: height and mass are set out at section 3.1.6-3.1.8 of the DAS.
i. long-range views – these require • The bulk of the building mass has been attention to be paid to the design of the located below the tree line. top of the building. It should make a • The taller elements which are visible positive contribution to the existing and above this have reduced mass, which emerging skyline and not adversely affect helps create a more elegant skyline to local or strategic views. avoid adverse impacts on local or strategic views. • Special attention has been paid to the tops of the buildings as described by Chapter 4 of the Design and Access Statement to create a recessive appearance against the sky. • The Site layout has ensured that there is visible separation between buildings from the park and behind the listed station. This minimises the impact on designated heritage assets and the Green Belt.
ii. mid-range views from the surrounding • The scale and mass of the buildings has neighbourhood – particular attention been informed by a response to the should be paid to the form and dense tree belt which screens the Site proportions of the building. It should and mass at a lower level. make a positive contribution to the local • The materials for each building have been townscape in terms of legibility, selected to relate to and strengthen the proportions and materiality. surrounding neighbourhood and the specific contexts of Site A and Site B as set out at Chapter 4 of the DAS.
1 Also required by Enfield Policy DMD 43 Part 4 (c)(e)(f)
Quod | Land adjacent to Cockfosters Underground Station | Planning Statement | June 2021 62
iii. immediate views from the surrounding • Site A creates a pedestrian scale streets – attention should be paid to the environment from immediate viewpoints base of the building. It should have a along Cockfosters Road and within the direct relationship with the street, Site. Stepped massing and tree belts maintaining the pedestrian scale, provide a transition from the open spaces character and vitality of the street. Where of Trent Park to the Proposed the edges of the site are adjacent to Development. buildings of significantly lower height or • Site B relates directly to the high street parks and other open spaces there should with commercial uses at ground floor and be an appropriate transition in scale the height relates to adjacent Blackhorse between the tall building and its Tower. surrounding context to protect amenity or privacy. b) whether part of a group or stand-alone, • Building heights have responded to the tall buildings should reinforce the spatial character and scale of the local area. hierarchy of the local and wider context • B2 provides an entrance marker to Site A and aid legibility and wayfinding. and provides wayfinding for the Station which is currently a low rise building, not particularly legible along Cockfosters Road. c) architectural quality and materials • The materials proposed are of a high should be of an exemplary standard to quality and have been selected following ensure that the appearance and a detailed review of the local context. architectural integrity of the building is maintained through its lifespan. d) proposals should take account of, and • Height and massing strategy informed by avoid harm to, the significance of viability, the need for homes and heritage London’s heritage assets and their assets. settings. Proposals resulting in harm will • Setting of the Station would be enhanced, require clear and convincing justification, with gateway buildings and improvements demonstrating that alternatives have been to the public realm. explored and that there are clear public benefits that outweigh that harm. The • Impact on the heritage assets is reduced buildings should positively contribute to as far as practicable. the character of the area. • 17 viewpoints have been agreed for the TVIA, 8 of which have helped to iteratively test 11 design options. • The Proposed Development would lead to very limited less than substantial harm, but lead to a number of important benefits to the designated heritage assets. • The Proposed Development has significant public benefits. e) buildings in the setting of a World • Not applicable to this Site. Heritage Site must preserve, and not
Quod | Land adjacent to Cockfosters Underground Station | Planning Statement | June 2021 63
harm, the Outstanding Universal Value of the World Heritage Site, and the ability to appreciate it.
f) buildings near the River Thames, • Not applicable to this Site. particularly in the Thames Policy Area, should protect and enhance the open quality of the river and the riverside public realm, including views, and not contribute to a canyon effect along the river.
g) buildings should not cause adverse • The proposed buildings would be reflected glare. constructed of matt materials and the glazing specified to reduce the risk of glare.
h) buildings should be designed to • The facades have been arranged to minimise light pollution from internal and provide a suitable ratio of glazing to external lighting. brick/concrete with consideration for daylight sunlight, overheating and minimisation of light pollution. • The residential nature of the Proposed Development at upper floors means that curtains/blinds will usually be drawn during hours of darkness which minimises potential light pollution.
2) Functional impacts2
a) the internal and external design, • The design has considered access including construction detailing, the arrangements to meet the needs of building’s materials and its emergency everyone and the Fire Strategy sets out exit routes must ensure the safety of all the approach to evacuation including occupants. provision of fire evacuation lifts
b) buildings should be serviced, • The Build to Rent nature of the Proposed maintained and managed in a manner Development means there will be 24/7 that will preserve their safety and quality, on-site management and the Site will be and not cause disturbance or maintained by the Applicant in perpetuity. inconvenience to surrounding public realm. Servicing, maintenance and building management arrangements should be considered at the start of the design process.
c) entrances, access routes, and ground • The architecture and landscape have floor uses should be designed and placed been designed in tandem and define clear to allow for peak time use and to ensure routes in and around the Site and to each
2 Also required by Enfield Policy DMD 43 Part 4(a)(b)(g)
Quod | Land adjacent to Cockfosters Underground Station | Planning Statement | June 2021 64
there is no unacceptable overcrowding or building as described by the DAS isolation in the surrounding areas. (Chapter 5). • Building entrances are recessed to provide generous internal and external lobbies (see drawings). • Access to cycle stores is via the building lobby to avoid provision of secondary entrances. d) it must be demonstrated that the • The Transport Assessment provides an capacity of the area and its transport assessment of public transport capacity network is capable of accommodating the confirming that additional trips as a result quantum of development in terms of of the Proposed Development can be access to facilities, services, walking and accommodated. cycling networks, and public transport for • The Proposed Development will involve people living or working in the building. improvements to local walking and cycling networks directly associated with the Site. • The Proposed Development includes a commercial unit and cycle hub for users of the Site and the Station. • Appropriate contributions would be agreed through a Section 106 towards increasing capacity of local facilities (e.g. health and education) as needed to support the Proposed Development. f) jobs, services, facilities and economic • The Proposed Development provides a activity that will be provided by the commercial unit which will contribute development and the regeneration towards the existing high street offer. It potential this might provide should inform has been designed with consideration for the design so it maximises the benefits commercial uses proposed along these could bring to the area, and Cockfosters Road for the redevelopment maximises the role of the development as of Blackhorse Tower. a catalyst for further change in the area. • The provision of a cycle hub and residential and visitor cycle parking, and improved access to Trent Park via the LOOP support pedestrian and cycle movement. • The Proposed Development would provide a net increase in employment on the Site. g) buildings, including their construction, • The Proposed Development would not should not interfere with aviation, have any adverse impacts. Details of the navigation or telecommunication, and construction would be dealt with through should avoid a significant detrimental a detailed Construction Management Plan to be agreed with LBE.
Quod | Land adjacent to Cockfosters Underground Station | Planning Statement | June 2021 65
effect on solar energy generation on adjoining buildings.
3) Environmental impacts3
a) wind, daylight, sunlight penetration and • Assessments have been undertaken to temperature conditions around the confirm that there would be no building(s) and neighbourhood must be unacceptable adverse impacts on the carefully considered and not compromise communal open space within the Site and comfort and the enjoyment of open surrounding public open spaces or spaces, including water spaces, around buildings (Daylight and Sunlight report, the building. GIA). • The Wind Microclimate report (Urban Microclimate Ltd) confirms that pedestrian level wind conditions in and around the Site would remain safe and comfortable. • There would be no adverse impacts on the comfort and enjoyment of open spaces as a result of the Proposed Development.
b) air movement affected by the • The proposed buildings are appropriately building(s) should support the effective space and would not have any adverse dispersion of pollutants, but not adversely impacts. affect street-level conditions.
c) noise created by air movements • The Proposed Development would not around the building(s), servicing detract from the comfort and enjoyment of machinery, or building uses, should not open spaces as a result of any noise detract from the comfort and enjoyment of impacts. open spaces around the building.
4) cumulative impacts4
a) the cumulative visual, functional and • The Proposed Development has been environmental impacts of proposed, considered in the context of adjacent consented and planned tall buildings in an Blackhorse Tower and potential additional area must be considered when assessing stories to this building as well as Metro tall building proposals and when Point opposite (refer to the Townscape developing plans for an area. Mitigation and Visual Impact Assessment, Alan measures should be identified and Baxter (June 2021) for more details). designed into the building as integral • The Proposed Development is considered features from the outset to avoid retro- to respond positively to the context and fitting. no mitigation measures are required beyond those already considered in the scheme design.
3 Also required by Enfield Policy DMD 43 Part 4(h) 4 Also required by Enfield Policy DMD 43 Part 4(d)
Quod | Land adjacent to Cockfosters Underground Station | Planning Statement | June 2021 66
Public access
D Free to enter publicly-accessible areas • The ground level amenity space would be should be incorporated into tall buildings publicly accessible. where appropriate, particularly more • The residential nature of the Proposed prominent tall buildings where they should Development means that it is not normally be located at the top of the appropriate to provide public access building to afford wider views across within the buildings. London. • A roof terrace within B2 is provided and accessible to all residents which affords views across London and Trent Park.
7.85 In accordance with Policy D9 of the London Plan (2021) and the criteria set out at LBE Policy DMD 43 a thorough assessment of the visual, functional, environmental and cumulative impacts of the Proposed Development as the design has developed has informed the layout and massing to minimise adverse effects and prevent any compromise to the comfort and enjoyment of the spaces around the buildings. Visual assessments have informed the layout, massing and design to minimise adverse impacts on long-range, mid-range and immediate views. The proposed building footprints are influenced by the irregular shapes of the development sites, and the opportunity to step the massing using set-backs and ‘shoulder’ blocks that frame taller elements, purposefully responding to the geometry of the surrounding landscape and townscape whilst negotiating on-site constraints. The form and proportions of the building have considered the appearance on the skyline, including the integration of plant equipment on the roof, concealed behind a finessed parapet. The need to maximise the amount of sky visible between the buildings and from the street has informed the positioning of buildings, and the base of the building is activated by its use and frontages which interact with the landscape, defining routes through and around the buildings. The Proposed Development complies with the criteria of London Plan Policy D9 in relation to impacts and public access.
7.86 The Proposed Development successfully balances the need for new homes on an under- utilised, well-connected brownfield site against the Site’s setting and character. It reconciles an appropriate quantum of new homes to make a substantial contribution to housing need, against the sensitivities of the heritage assets, adjoining Green Belt and nature conservation sites in order to optimise the potential of the Site in accordance with local and national policy when read as a whole.
Conclusion 7.87 The Proposed Development has taken account of the significance of its setting and seeks to provide buildings that balance the local character and history of the Site and its surroundings against the need for innovation and change to optimise the Site’s potential. On the edge of the urban area, the design of the buildings and the landscape support an appropriate amount of development and optimised the Site through sensitive design and detailing and effective landscaping, in accordance with policy requirements and in particular LBE Policy DMD 32, DMD 38 DMD 40, and DMD 43; London Plan Policies D1, D4, D3, D8, D9, SD7; and Paragraphs 122 and 127 of the NPPF.
Quod | Land adjacent to Cockfosters Underground Station | Planning Statement | June 2021 67
7.88 The density of the Proposed Development in terms of use, scale and massing is proportionate to the sustainable location of the Site, given its proximity to the underground station and bus connections as required by Policy D2 of the London Plan (2021).
7.89 The materials and design proposed are of a high quality and have been devised with a clear rationale relating to the immediate context as well as considering the appearance of the Proposed Development from longer distance views. The Proposed Development would comply with the relevant local and national policies in relation to design.
Townscape and Heritage
Policy Context 7.90 The Planning (Listed Buildings and Conservation Areas) Act 1990 requires that considerable importance and weight should be given to the desirability of preserving the setting of listed buildings (section 66(1)) and preserving or enhancing the character or appearance of an area for proposals within conservation areas. The NPPF requires that development proposals identify and describe the significance of any heritage assets affected, including any contribution made by their setting (paragraph 189, NPPF). Paragraph 193 requires great weight to be given to an asset’s conservation when considering the impact of a proposed development on the significance of a designated heritage asset. Any harm to, or loss of, the significance of a designated heritage asset should require clear and convincing justification (paragraph 194, NPPF).
7.91 A number of heritage assets have been identified for assessment in relation to the Proposed Development. The Station was listed as Grade II in 1987. The primary significance of the station lies in the design of its lofty ticket hall and train shed (Heritage Statement, Alan Baxter, June 2021). The main entrance building is a single-storey brick structure and is of less significance than the interior spaces. The car parks and streetscape surrounding the Station currently detract from the Station’s setting due to their low townscape quality. This setting conceals the Station entrance building in views along Cockfosters Road.
7.92 To the north of the Site lies Trent Park, a Grade II Registered Park and Garden. The significance lies in its character as a rare surviving country estate on the outskirts of London and the special interest of the Conservation Area is strongly related to the surviving estate of Trent Park. Key views generally comprise the designed views of the manor house or picturesque landscape, alongside wider vistas across the large open expanses of parkland. Site A itself lies within Trent Park Conservation Area, however the character of the Site, which sits outside of the registered park boundary, has a more urbanised, fringe character which is derived from physical factors such as glimpsed views of development in Cockfosters (this is set out in more detail in the Heritage Statement).
7.93 Where proposed development leads to less than substantial harm, paragraph 196 requires that this harm should be weighed against the public benefits of the proposal including securing its optimum viable use. Paragraph 200 of the NPPF states that: ‘Local Planning Authorities should look for opportunities for new development within Conservation Areas and World Heritage Sites, and within the setting of heritage assets, to enhance or better reveal their significance. Proposals that preserve those elements of the setting that make a positive contribution to the asset (or which better reveal its significance) should be treated favourably’.
Quod | Land adjacent to Cockfosters Underground Station | Planning Statement | June 2021 68
7.94 London Plan (2021) Policy HC1 requires development proposals which affect the setting of heritage assets to be sympathetic to their significance and appreciate their surroundings. Harm should be avoided, and enhancement opportunities taken where they arise. LBE Core Strategy Policy 31 requires proposals to have special regard to the potential impact on heritage assets and their setting. LBE Policy DMD 44 requires proposals that fail to conserve and enhance the special interest, significance or setting of a heritage asset to be refused, however these policies are superseded by the NPPF which at paragraph 194 requires such proposals to be justified.
7.95 LBE’s Emerging Local Plan Policy HE4 requires an assessment of the impact of development on views and states that proposals will only be acceptable where it can be demonstrated that it does not harm the views identified. To note, the Report on Location of Tall Buildings and Important Local Views in LBE (March 2013) refers to views from Trent Park mansion across the ornamental lakes to the obelisk, but does not identify any sensitive views that would be impacted by the Proposed Development.
7.96 LBE’s Emerging Local Policy D2 states that LBE will refuse poor quality replications of historic design precedents. LBE’s Emerging Local Plan policy HE2 requires that proposals must be sympathetic and respond to the setting of local heritage assets.
7.97 Any harm resulting from proposals should be supported by clear and convincing justification, demonstrate the alternatives that have been explored and set out the public benefits that outweigh the harm. This requirement aligns with the NPPF at Paragraph 196.
Assessment 7.98 The accompanying Heritage Statement (Alan Baxter, June 2021) provides an assessment of the significance of existing heritage assets and impacts as a result of the Proposed Development following appropriate best practice guidance set out in Historic England’s Conservation Principle, Policies and Guidance (2009) and the NPPF (2019).
7.99 The Proposed Development is heritage-led, designed to optimise the capacity of the Site and to ensure the efficient reuse of previously developed land, whilst having cognisance of the significance of the surrounding heritage assets. The Proposed Development has sought to respond to both the immediate, medium and long-range setting of the Grade II listed Station, the Trent Park Grade II registered park and garden and the Trent Park Conservation Area (heritage assets).
7.100 The following key heritage considerations were identified at the outset of design development and have been considered throughout in accordance with London Plan Policy HC1 Part C which requires heritage considerations to be integrated early on in the design process:
• minimising the loss of light entering the sub-surface ticket hall and train shed; • arranging buildings on Site A to keep the site open to allow surrounding green space to filter in, while providing opportunity for multiple views towards Trent Park from the new homes; • varying height and massing to create a varied backdrop to the station and avoid a wall or plateau of development;
Quod | Land adjacent to Cockfosters Underground Station | Planning Statement | June 2021 69
• making a visual transition between the single-storey station building and Blackhorse Tower on Site B; and • improving the setting of the station by providing public realm to the northern and southern station entrances. 7.101 Paragraph 7.71 of this Planning Statement sets out the critical moves that have balanced the approach to optimising the capacity of the Site against the heritage considerations through the evolution of the scheme design. These moves have resulted in a scheme which has embedded heritage in the design, in accordance with Policy HC1 Part C of the London Plan
7.102 The amount of development has been established by a number of parameters:
• heritage-led design and the above considerations; • the need for housing, including a minimum provision of 40% affordable housing in line with TfL’s Mayoral commitment; and • viability and the minimum amount of development required to achieve a viable scheme. 7.103 The Proposed Development has been influenced from the early stages of feasibility and design development by an understanding of the significance of the heritage assets as well as the character of the surrounding landscape and townscape.
7.104 The Proposed Development has evolved from an extensive process of challenging and amending the design including a reduction in the quantum of development (from 400 units to 351) and testing alternatives for massing, height and layout to achieve a design that successfully mediates between and responds to the radically different settings of the designated heritage assets. This has developed in response to the assessment of 17 key views, which were chosen as a representative sample of views from different character areas in the locality, such as within open landscape areas or residential locations with clear views of the Site. The views selection and methodology, was reviewed, refined and agreed with officers of LBE, Historic England and other stakeholders (refer to accompanying TVIA for more detail).
7.105 A Heritage Assessment has been undertaken providing an assessment of the heritage impacts and heritage benefits of the Proposed Development for each of the three identified heritage assets, namely: (i) Grade II Listed Cockfosters Underground Station; (ii) Trent Park Conservation Areas; and (iii) Trent Park registered Park and Garden. This assessment has been undertaken according to the up-to-date requirements of the London Plan (2021) and the NPPF, and against the Planning and Listed Buildings Act (1990), and provides a balancing exercise of the anticipated level of harm to the relevant heritage assets against the heritage and public benefits.
Grade II Listed Cockfosters Underground Station 7.106 In relation to the Station, the Proposed Development represents an opportunity to greatly enhance the townscape quality of the area around the Station and provide a more coherent distinction between the rural and urban landscapes (please see the TVIA submitted in support of this application). The placement of the buildings has been carefully managed to respect the appearance of the single storey external station building. In addition, daylight and sunlight testing has ensured that the Proposed Development would not have a detrimental impact on
Quod | Land adjacent to Cockfosters Underground Station | Planning Statement | June 2021 70
the appreciation of the double height interior of the station train shed, where its highest significance is found.
7.107 The heritage assessment of the Proposed Development find that it would have a negligible impact to the significance of the Station but to have some small, less than substantial degree of harm to the Station’s setting by reason of the change and visibility of the Proposed Development above and behind the Station building. However, the replacement of elements that currently detract from the Station’s setting (the car parks and boundary treatments) with high quality buildings that act as both a gateway to London as an enhanced landmark signposting people towards the Station together with improved public realm and landscaping at Station Court and LOOP Place offered by the Proposed Development would represent a heritage benefit overall. Overall, after carefully reviewing the impacts to the setting of the listed station, it has been determined that there would be an enhancement of the setting of the Grade II listed station and Paragraph 196 is not engaged.
Trent Park Conservation Area 7.108 Due to the massing of the buildings, they would be visible in some limited views from Trent Park and the Proposed Development would cause some harm at the lower end of the scale of less than substantial harm to the Conservation Area as a whole. However, the contextual, high quality design that considers the heritage of the area, the new buildings would replace the existing poor quality public realm and greatly enhance this part of the Conservation Area and its setting. The character of the wider Trent Park Conservation Area is not consistent and the impacts of the development would be experienced differently in different parts of the conservation area. Heritage benefits are offered by the proposal in terms of substantial improvements to visual appearance of the Site and its immediate surroundings. Within the wider urban fringe, the impact of the development to the character and appearance of the conservation area is relatively minimal with urban development characteristic of the character of the conservation area. Further north, where the conservation area and registered park coincide, the Proposed Development would be notable and this perception would detract from character. As such, some less-than-substantial harm co-exists with some benefit to the character and appearance of the different parts of the conservation area. For much of the open conservation area, the impact to character would be neutral. Again, weighing up these various elements, the overall effect to the character of the conservation area is neutral and paragraph 196 is not engaged.
Trent Park Registered Park and Garden 7.109 The Proposed Development would give rise to adverse effects upon the landscape character of the more rural areas to the north and east of the Site, specifically the Trent Park Grade II registered park and garden (from views Q and P, as detailed within the TVIA) where the introduction of development above the tree line would be harmful, notwithstanding the high- quality design of the buildings and their careful placement and response to this designated heritage asset to mitigate any adverse impact These likely adverse effects should be considered in the context of: (i) the sensitive design, prepared through vigorous testing and iteration of schemes, to minimise the visual impact of the Proposed Development from the key views (as agreed between the Applicant and LBE (as well as Historic England)); (ii) the high- quality design and materiality of the Proposed Development; and (iii) that the character of the urban fringe character area to the east of the Site which would not be fundamentally changed
Quod | Land adjacent to Cockfosters Underground Station | Planning Statement | June 2021 71
by the increased visibility of built form. The degree to which the park’s prevailing character would be reduced as a result of the visibility in a view static viewpoints would be minimal.
7.110 The nature of the Site, and the way the Proposed Development has responded to its context, has avoided the likelihood of buildings appearing in views from the most sensitive locations within the registered park and garden and the layout, design, materiality and landscaping would result in no harm. The height and massing would cause some less than substantial harm which has been minimised by virtue of the high-quality sensitive design of the buildings . Overall, the level of harm to the setting and significance of the registered park and garden is at the very lower end of less than substantial and is outweighed by the many public benefits provided by the application. Fundamentally, the Proposed Development does not significantly change the open and semi-rural character of Trent Park nor the urban fringe character of the Site by the increased visibility of built form from within Trent Park.
Heritage Balance 7.111 Overall, Proposed Development does result in some harm to the significance of Trent Park. However, the level of harm to the heritage assets has been assessed as being at the very lower end of the scale of ‘less than substantial harm’ as a result of the clear design mitigation that ensures minimal visual intrusions and high design quality is achieved (Heritage Statement, Alan Baxter). The improvements delivered by the Proposed Development to replace the poor quality public realm with high-quality landscape, and contextual design of the buildings provides substantial heritage benefits and successfully preserves the setting of the Listed Building and preserves and enhances overall, the character of the Listed Building and the Conservation Area in accordance with the Planning (Listed Buildings and Conservation Areas) Act 1990.
Public Benefits 7.112 The heritage assessment identifies less than substantial harm (at the very lower end of the scale) to the setting and character of the conservation area and registered park and gardens, and in accordance with paragraph 196 of the NPPF, this harm should be weighed against the public benefits of the Proposed Development.
7.113 Substantial public benefits resulting from the Proposed Development are identified as follows and explained in further detail below:
• delivering much needed homes; • provision of affordable housing; • BtR development; • financial benefits to LBE; • reducing traffic and improving air quality; • increasing and improving open space provision; • improving and enhancing public realm; • contributing to urban greening; • improvements to the setting of the Grade II listed station;
Quod | Land adjacent to Cockfosters Underground Station | Planning Statement | June 2021 72
• improvements to the quality and appearance of the Trent Park Conservation Area; and • securing the optimum viable use of the heritage asset.
Delivering Much Needed Homes 7.114 As set out in Section 2 of this Statement, the NPPF and London Plan (2021) seek to significantly boost the supply of homes. Paragraph 59 of the NPPF sets out the Government’s objective to boost the supply of homes and the following paragraphs seek to ensure that supply meets the needs of different groups in the community including for affordable housing. Policy GG4 of the London Plan (2021) supports this agenda stating that planning and development must ‘A) ensure that more homes are delivered’ and ‘B) support the delivery of the strategic target of 50 per cent of all new homes being genuinely affordable’.
7.115 Policy GG2 of the London Plan (2021) requires development to ‘B) prioritise sites which are well-connected by existing or planned public transport’. It requires planning to ensure that more homes are delivered; create mixed and inclusive communities and ensure that homes are built quickly. Policy H1 of the London Plan (2021) stresses the importance of encouraging development on appropriate windfall sites, especially where they have a high PTAL rating (3 to 6) or are located within 800m of a Tube Station, and/or involve the mixed-use redevelopment of car parks, and/or involve the redevelopment of surplus utilities and public sector owned sites.
7.116 The Proposed Development would include 1, 2 and 3-bed units therefore providing an offer which is not usually available in the local area. The London Plan (2021) (Paragraph 1.1.1) supports the need for diverse communities and planning for communities that make new connections and erode inequalities. The Proposed Development would therefore support a more diverse local community.
7.117 The Proposed Development for the provision of 351 homes on this Site would therefore make a significant contribution towards LBE’s and London’s housing needs over the next 5 years. The benefits of providing new homes ensures that LBE and London are able to meet the needs of their growing population, and the delivery of those homes on a previously developed site protects other greenfield areas of the borough and metropolitan areas from development. Further details of the contribution towards housing need are set out in the section relating to housing need above.
Provision of Affordable Housing 7.118 The delivery of housing also facilitates the delivery of affordable housing. The London Plan (2021) sets a strategic target for half of new homes to be genuinely affordable or, in the case where sites are part of a portfolio agreement, a minimum of 35%. The NPPF defines affordable housing as housing for sale or rent for those whose needs are not met by the market. The LBE Core Strategy requires 40% of new homes to be affordable (subject to viability) and the Emerging Local Plan commits to delivering new and sufficient housing to meet local needs, with a priority for affordable family homes (Paragraph 1.11.2). The Proposed Development would deliver 40% affordable (by habitable room), comprising approximately 132 new affordable homes. The delivery of affordable housing would allow local residents who cannot afford to stay in the borough or who live in poor quality private rented accommodation, an opportunity to stay in the local area, and builds a sense of community.
Quod | Land adjacent to Cockfosters Underground Station | Planning Statement | June 2021 73
Build to Rent Development 7.119 The proposed BtR scheme would provide high quality private rented accommodation. Paragraph 4.11.1 of the London Plan (2021) supports the delivery of BtR in order to accelerate delivery on individual sites, offer longer-term tenancies and more certainty over long-term availability, and ensure a commitment to, and investment in place-making through single ownership. This means that the local area and public realm would be well maintained and create a sense of belonging and wellbeing for residents of the Proposed Development and the wider local community. The Applicant would also be providing on-site management and a concierge service as well as a residents’ lounge, workspace and gym which provides an offer of much better quality homes than the mainstream private rented sector and raises the standards more generally. More detail is provided within the housing section as set out above.
Financial Contributions 7.120 The Proposed Development would generate a Community Infrastructure Levy of approximately £4million. New homes on this Site would increase annual council tax revenue collected by LBE. Based on the average council tax rate (Band D) for 2021/22, the new homes would generate £630,000 annually in council tax. Of this approximately £500,000 would go to LBE and £130,000 would go to the GLA.
7.121 An additional £684,000 would also be collected by LBE in New Homes Bonus, which would top up the council tax collected on the new homes in the first year (based on the national average for council tax for 2021/22).
7.122 These financial contributions could be spent on local priorities as LBE sees fit, such as local schemes or public realm improvements outside of the red line application boundary which will directly benefit the local community.
7.123 The households in the new homes delivered as part of the Proposed Development would also generate approximately £5.3 million per year in additional spending5, a proportion of which would be captured by local business and services in LBE.
Reducing Traffic and Improving Air Quality 7.124 The Site currently comprises two car parks and the Proposed Development seeks to remove most of the existing spaces, retaining less than 10% of the existing public car parking and all existing Blue Badge car parking to provide homes. This change in use of the land would result in an estimated c.1,200 net fewer two-way vehicle movements generated by the Site each day. The removal of car parking and car-free residential development (except for Blue Badge parking) would therefore assist in encouraging sustainable modes of travel such as walking, cycling and public transport and improve air quality and congestion by reducing the number of vehicles on the road. The importance of improving air quality is highlighted by the location of the Site in an Air Quality Management Area (which covers the whole of LBE) where road traffic is a major source of pollution. Air pollution including from vehicles is highlighted in the Foreword to the LBE Climate Action Plan (2020) as linked to a 15% increase in the death rate.
5 Based on the London average household expenditure of £290 per week (Office for National Statistics, 2021. Household Expenditure Survey 2018-2020).
Quod | Land adjacent to Cockfosters Underground Station | Planning Statement | June 2021 74
7.125 The reduction in vehicle movements associated with the Site has a direct public benefit to local residents both in terms of public health and environmental sustainability as set out in the section below titled ‘Environmental Considerations’.
Increasing and Improving Open Space Provision 7.126 Improving open space provision by increasing both access to and the quantity and quality of open spaces is supported by Policy GG3 of the London Plan (2021) and LBE Core Strategy Policy 34. There is an existing entrance to the LOOP adjacent to the entrance to the Station building which is currently hidden and not clearly marked by signage. The Proposed Development would better reveal this entrance and provide clearer signage to demarcate the entrance to the park. Overall, the Proposed Development would improve pedestrian access from the Station to Trent Park and the LOOP for the local community and visitors.
7.127 The Proposed Development would contribute a significant area of publicly accessible external amenity space within the Site and retain and reinforce the perimeter planting of the Site. Substantial new green spaces on an existing area of hard landscaping with low ecological value would contribute to the green setting of the area and provide a functional space which contributes to the community.
Improving and Enhancing Public Realm 7.128 As set out above, the Grade II listed Station currently has a poor setting as a result of low townscape quality and boundary treatment such as hoarding within Site B and palisade fencing which detract from the Station building’s significance. The Proposed Development seeks to improve the setting of the listed Station building by providing a new area of public realm to the south of the Station adjoining Cockfosters Road (Station Court). The building on Site B would be set back from the frontage, providing a clearer view of the Station entrance, which is currently concealed. To the northern entrance there is currently a poor quality townscape created by large LUL bins and surface treatment. The Proposed Development would relocate the bins and provide a more welcoming townscape, again revealing the significance of the Station and giving it prominence as a transport hub with planting, seating and facilities such as cycle parking for use by local residents and visitors to the Station or local centre. This aligns with the requirements of Paragraph 200 of the NPPF which requires Local Planning Authorities to look for opportunities for new development within Conservation Areas and World Heritage Sites, and within the setting of heritage assets, to enhance or better reveal their significance. The Proposed Development would better reveal the significance of the listed Station through improved public realm, which provides a public benefit in accordance with the NPPF.
7.129 This would improve the look and feel of the local area and contribute towards improvements from a Healthy Streets perspective including providing shade and shelter, places to stop and rest, alternative choices of walking, cycling or public transport and things to see and do.
Contributing to Urban Greening and Biodiversity 7.130 The Proposed Development will deliver substantial improvements to the local natural environment as a result of the replacement of existing hard standing with large amounts of landscaping. The provision of 93 new trees, resulting in a net gain of 75 trees on site, and a biodiversity net gain of 447% contribute positively to the local environment compared to the existing use of the Site.
Quod | Land adjacent to Cockfosters Underground Station | Planning Statement | June 2021 75
Improvements to the setting of the Grade II listed station 7.131 The appearance and experience of the area around the Station and in particular the two subsidiary entrances to the north and south of the Station building are currently poor due to low quality townscape and poor accessibility. The Proposed Development would replace the existing poor townscape with high quality public realm and sensitively designed buildings which would represent an improvement to the setting of the Station building. This would enhance the understanding of the Station’s originally intended use and represent a major public and heritage benefit (further details are set out in the Heritage Statement, Alan Baxter June 2021).
Improvements to the quality and appearance of the Trent Park Conservation Area 7.132 Part of Site A is located within the Trent Park Conservation Area. It currently makes a neutral contribution to the character and appearance which would be replaced with high quality buildings. The design and materials proposed respond to the local historic character of the area including Christ Church and the Victorian cottages along Cockfosters Road (which are within the Conservation Area). The approach would greatly enhance the character and appearance of this part of the conservation area (further details are set out in the Heritage Statement, Alan Baxter June 2021).
Securing the optimum viable use of the heritage asset 7.133 In accordance with paragraph 196 of the NPPF, the proposals would retain the current use of the Listed Station and do not seek to alter the listed fabric. The Development Proposals support further the originally intended purposes of the Station to provide a hub for residential development in the outer suburbs for London. The Development Proposals therefore reinforce and secure the optimum viable use of the Station.
Heritage balance 7.134 The Proposed Development has been designed to optimise the capacity of the Site and to ensure the efficient reuse of previously developed land, whilst having cognisance of the significance of the surrounding heritage assets. Analysis of the heritage impacts show that the predicted harm to the heritage assets overall is less than substantial, with the development appearing in some views from the adjoining landscape. The setting of the listed Station would be enhanced by replacing the Station car parks which currently detract from its setting, with gateway buildings and improvements to the public realm. The Proposed Development avoids impact on the heritage impacts as far as practicable.
7.135 There are significant heritage benefits and public benefits associated with the Proposed Development which more than outweigh the harm that is at the lower end of the scale of less than substantial harm and, therefore, accord with paragraph 196 of the NPPF.
Conclusion 7.136 The Proposed Development has been designed iteratively and has been informed by a set of overriding design principles, informed by the heritage and other constraints of the Site. The height, massing and materiality of the buildings is informed by the balance between the viability of the scheme (Viability Assessment, Savills), the need for new homes and the sensitivities in relation to the setting of the heritage assets in which the Site is situated. The Proposed Development would create a new backdrop to the Station and be visible in some views from Trent Park Grade II registered park and garden. However, great care has been taken to ensure
Quod | Land adjacent to Cockfosters Underground Station | Planning Statement | June 2021 76
that design results in the Proposed Development being visible only from less sensitive locations, or where there is already built form visible. The new buildings would change the setting of the Station by creating a new backdrop to the station entrance building, but would cause some harm to the significance of the Station (Heritage Statement, Alan Baxter (June 2021)) as a result of reducing the modest street presence of the building. This very limited harm is greatly mitigated by the fact that the setting of the main Station entrance makes only a minor contribution to the significance of the Station as a whole. Those areas of highest significance, namely the ticket hall and train shed interiors, would be preserved as a result of the Proposed Development. The appearance of built form in the context of the Station has been carefully crafted to maximise views of the sky and frame the single storey listed Station, whilst the Proposed Development delivers some enhancements to its setting. The use of high- quality materials and a purpose-designed landscape would improve the setting of the Station at closer range, particularly around the north and south entrances which are currently constrained and under-utilised.
7.137 This opportunity to deliver new homes in a sustainable location can only come forward if the Site can be optimised in a way that allows it to be delivered in a viable way. The viability analysis has demonstrated that a scheme comprising a reduced number of units could not viably deliver 40% affordable housing (by habitable room), which would mean that the Applicant could not deliver the Proposed Development.
7.138 Analysis of the heritage impacts show that the predicted harm to the heritage assets overall is less than substantial, with the development appearing in some views from the adjoining landscape. The setting of the listed Station would be enhanced by replacing the car parks which currently detract from its setting, with gateway buildings and improvements to the public realm. The Proposed Development reduces the impact on the heritage impacts as far as practicable, whilst still being able to deliver a scheme within the defined viability envelope and securing the optimum viable use of the Station.
7.139 Overall, there are significant public benefits associated with the Proposed Development which more than outweigh the harm that is at the lower end of the scale of less than substantial harm and, therefore, accord with paragraph 196 of the NPPF and the Development Plan when read as a whole.
Green Belt
Policy Context 7.140 Site A is located directly adjacent to the Green Belt boundary, the designation of which encompasses Trent Park to the north and east. As a result, the Site defines the northern boundary of the urban area of London and the transition to Green Belt. Chapter 13 of the NPPF sets out the overarching policies for the protection of Green Belt land. Draft Policy GI2 of the emerging Local Plan states that LBE will support development that improves access to the Green Belt for beneficial uses such as outdoor sport and recreation. LBE Policy DMD 83 states that development next to the Green Belt will only be permitted if (a) there is no increase in the visual dominance and intrusiveness of the built form by way of height, scale and massing, on the Green Belt; (b) there is a clear distinction between the Green Belt and urban area; (c) views and vistas from the Green Belt into urban areas and vice versa, especially at important access points, are maintained. LBE Policy DMD 83 also requires proposals to maximise opportunities to incorporate measures to improve the character of land adjacent to the Green Belt through
Quod | Land adjacent to Cockfosters Underground Station | Planning Statement | June 2021 77
environmental improvements and to increase opportunities for public access. LBE Core Strategy Policy 33 seeks to continue to protect and enhance LBE’s Green Belt.
7.141 LBE’s emerging Local Plan is proposing to review Green Belt boundaries to promote sustainable patterns of development, although it also reiterates the need to support the protection of Green Belt (Paragraph 9.3.4). The London Plan (2021) strongly supports the continued protection of the Green Belt set out by the policies within the NPPF, and its purpose to assist in urban regeneration by encouraging the recycling of derelict and other urban land as set out by Paragraph 134, part (e) of the NPPF. The requirements and purposes of the Green Belt are clearly dealt with in more recent policy than the LBE DMD, that focus on preventing or limiting the need to develop land within the Green Belt. Therefore, LBE will need to support the redevelopment of urban sites to ensure they are contributing to housing targets and to minimise any need to develop on designated Green Belt sites.
Assessment 7.142 The Proposed Development accords with the requirements of the NPPF which restricts development of land within the designated Green Belt, but not adjacent to it. The fundamental aim of Green Belt Policy as set out at NPPF paragraph 133 is to prevent urban sprawl by keeping land permanently open. As discussed in the previous section, the Proposed Development would be visible from some parts of the adjacent Trent Park, which also fall within designated Green Belt land. In relation to the requirement of LBE Policy DMD 83 that development should not be visually dominant or intrusive, the accompanying TVIA illustrates that the Proposed Development would appear in some views, although changes are nuanced and vary dependent upon the viewpoint. However, the impacts of this have been mitigated so that the intrusion of the appearance of built form is minimal. The varied height and massing and high design quality reduces the visual impact. In many views identified by the TVIA, visibility of the buildings is largely obscured by the nature of the undulating landscape and vegetated buffers to the Site. Where buildings are visible, these are glimpsed, or are seen within the context of the existing built forms already visible from the Green Belt (namely Blackhorse Tower). The use of massing studies to inform the design has been important for establishing the parts of the Site where height is more or less visible from a range of views and has informed the positioning, scale and mass of buildings.
7.143 The Proposed Development involves improvements to the existing access to the LOOP which provides pedestrian and cycle access directly into the Green Belt from this Site, providing opportunities to enhance the beneficial use of the Green Belt as required by NPPF paragraph 141. Further improved connections could also be facilitated by the Proposed Development, which are supported and encouraged by Policy GI2 of the London Plan (2021) and supported by LBE Policy DMD 83. Furthermore, the improvements to the nature of the site by way of introduction of significant landscaping, green roofs and planting represents measures to improve the character of the land as it sits adjacent to the Green Belt, as encouraged by LBE Policy DMD 83, whilst providing a clear distinction between the Green Belt and urban area.
Conclusion 7.144 The minimal encroachment of built form into views from the Green Belt proposed by the Proposed Development has been reduced through the design, and does not conflict with up to date policies in the NPPF and London Plan (2021). In relation to LBE Policy DMD 83, the appearance of the Proposed Development would not be so visually dominant or intrusive,
Quod | Land adjacent to Cockfosters Underground Station | Planning Statement | June 2021 78
particularly in important views, that the presence would not be outweighed by the public benefits. These have been set out by paragraphs 7.90-7.140 above in relation to the heritage assessment. In any event, LBE Policy DMD 83 is out-of-date in accordance with the requirements of paragraph 11(d) and footnote 7 of the NPPF. The extension of the green edge to the urban area, which is currently defined by unsightly hard standing and car parking, as well as the opportunities provided to much improve access into the Green Belt via the LOOP comply with the aspirations of the LBE DMD, London Plan (2021) and NPPF to increase opportunities for public access.
7.145 The Proposed Development accords with the aims of LBE’s emerging Local Plan as it would improve access to the Green Belt for beneficial uses. The location of the Proposed Development adjacent to the Green Belt also takes pressure off the requirement for additional land within the Borough to be developed to facilitate the delivery of homes in accordance with the projected housing need. The Proposed Development would comply with the relevant local and national policies in relation to the Green Belt when read as a whole.
Residential Quality and Amenity
Policy Context 7.146 Chapter 12 (Achieving well-designed places) of the NPPF identifies good design as a key aspect of sustainable development, stating that ‘the creation of high-quality buildings and places is fundamental to what the planning and development process should achieve’ (paragraph 124 of the NPPF). Paragraph 127 of the NPPF states that developments should:
• Function well and add to the overall quality of the area for the lifetime of the development; • Be visually attractive as a result of good architecture, layout and appropriate and effective landscaping; • Be sympathetic to local character and history; • Establish a strong sense of place and create attractive, welcoming and distinctive places; • Optimise the potential of the site to provide an appropriate mix and amount of development, green and public space, local facilities and transport networks; and • Create safe, inclusive and accessible spaces with a high standard of amenity and where crime or fear of crime does not undermine community cohesion or quality of life. 7.147 Policy D6 of the London Plan (2021) sets out housing quality and design standards that housing developments must take into account, to ensure they provide adequate and functional spaces, sufficient daylight and sunlight, avoid overheating and maximise the provision of private outside space without differentiating between tenures. Housing should also maximise the provision of dual aspect dwellings and normally avoid the provision of single aspect dwellings except where it is considered a more appropriate design solution to optimise site capacity. In the instance of single aspect dwellings, it should be demonstrated that they will have adequate passive ventilation, daylight and privacy, and avoid overheating. London Plan (2021) Table 3.1 sets out the internal minimum space standards for new dwellings and Table 3.2 provides qualitative design aspects that should be addressed in housing developments.
Quod | Land adjacent to Cockfosters Underground Station | Planning Statement | June 2021 79
7.148 LBE Core Policy 4 seeks high quality design and sustainability for all new homes, and DMD8 requires development to preserve amenity and meet or exceed minimum space standards with a flexible, functional layout. Appendix 4 of the LBE DMD sets out minimum space standards required for proposed housing developments, as well as standards pertaining to dwelling functionality, daylight and sunlight and disturbance.
7.149 The Homes for Londoners Affordable Housing and Viability SPG (2017) refers specifically to Build to Rent development and highlights that this type of offer can be ‘particularly suited to higher density development… near transport nodes’ (para 4.31). It requires local policies to be applied flexibly to Build to Rent schemes and encourages Local Planning Authorities to ‘take into account the value of on-site management and purpose-built design’ (para 4.33), for example in relation to applying design standards flexibly, such as the number of homes per core per floor and the number of single aspect homes.
7.150 The London Plan (2021) and accompanying adopted Shaping Neighbourhoods: Play and Informal Recreation SPG (2012) requires development proposals to increase opportunities for play and informal recreation, and incorporate good-quality, accessible play provision for all ages with at least 10sqm of play space per child. LBE Policy DMD 72 requires all new major residential development proposals to improve open space provision, reflecting additional open space needs generated by the development. LBE Policy DMD 72 relates to the protection and enhancement of open space, stating that development involving the loss of open space (other than Metropolitan Open Land) will be resisted unless replacement open space can be provided in the same locality and of better quality.
7.151 New developments are required to support mixed and inclusive communities, which includes a minimum provision of 10% wheelchair accessible and wheelchair adaptable units, as well as an environment that is welcoming and accessible by all (Policy D5 and D7 of the London Plan (2021) and Core Policies 4 and 9).
7.152 In terms of fire safety, London Plan (2021) Policy D12 requires developments to be designed to incorporate appropriate features to reduce risk to life and Policy D5 requires proposals to ensure safe and dignified emergency evacuation for all building users. A Fire Statement must be submitted to accompany all major development proposals.
Assessment 7.153 The proposed layout and massing have been developed to optimise the capacity of the site whilst delivering high quality homes. The scheme has been designed to be tenure blind, meaning that all dwellings have been designed to the same standard both internally and externally and with equality of access to all shared amenity space.
Tenure Distribution 7.154 The affordable housing provision needs to be managed by an appointed Registered Provider, meaning that the affordable accommodation should be located together for management purposes. 40% of the units (by habitable room) are affordable. Affordable units are located in buildings B1 (to the north east of Site A) and building B3 (south of Site A). 100% of the units in B1 are affordable; 44% of the units in B3 are affordable, and the remaining 56% are market tenure units. All homes will have the same access to shared amenities and play spaces, meaning that the development will promote a mixed and inclusive community. The distribution
Quod | Land adjacent to Cockfosters Underground Station | Planning Statement | June 2021 80
of tenures and the design specification of the homes is therefore fully consistent with all relevant planning policies and design guidance.
Residential comfort 7.155 The proposed residential units would meet and often exceed the minimum internal space standards required by Table 3.1 of the London Plan (2021) and comply with the qualitative design aspects to be addressed in housing developments required by Table 3.2.
7.156 All units would be provided with a minimum of 5sqm of private external amenity space in the form of a balcony directly accessible from each flat which are well proportioned to enable practical and flexible use by residents. All residents would have access to in excess of 4,260sqm shared external amenity including a roof terrace.
7.157 Overall, the scheme achieves provides 61.3% of units as dual aspect. 59% of one bed units are dual aspect and 67.2% of two and three bedroom units are dual aspect. 7.4% of units are single aspect north facing (defined as within 45 degrees from north, this includes north west and north east facing units). No single aspect units face directly north.
7.158 The layout and massing of the development has evolved through an iterative design process, taking a heritage and landscape-led approach. These predominant needs have been balanced against the other constraints of the site (such as tree protection areas, Thames Water easements and LUL requirements) to inform the Proposed Development.
7.159 The iterative pre-application process allowed a thorough assessment of the design at each stage of its development, seeking to balance the anticipated harm to heritage assets (Cockfosters Station, Trent Park Conservation Area and Trent Park Registered Park and Garden) against residential amenity, and reducing the amount of north facing single aspect homes. The critical moves that have balanced this approach are set out in relation to heritage above.
7.160 The resulting layout taking account of all of these factors, and having regard to residential amenity has led to a good proportion of dual aspect units. The layout and massing have sought to improve the setting of the heritage assets and minimise the appearance of built form in key views, particularly from Trent Park Registered Park and Garden whilst balancing against residential amenity.
7.161 Other amenity considerations including ventilation, daylight and privacy (as set out at DMD Appendix 4) have been considered in the context of dual aspect and single aspect proportions to achieve a good quality scheme that balances a range of needs and achieves high levels amenity for future residents.
7.162 A Daylight and Sunlight Assessment of the proposed units have been undertaken which demonstrates that approximately 90% of habitable rooms will meet or exceed the recommended daylight quantity (ADF) and 98% of habitable rooms will meet or exceed the recommended sky visibility (NSL). The majority of the rooms within the development will therefore achieve the relevant BRE guidance.
Quod | Land adjacent to Cockfosters Underground Station | Planning Statement | June 2021 81
7.163 The overheating assessment provided within the submitted Energy Strategy confirms that all proposed units can achieve a suitable internal environment using natural ventilation and mechanical ventilation with heat recovery.
7.164 The Air Quality Assessment (Atkins) confirms that the local air quality is consistent with the proposed residential use for the site and no specific mitigation in the building design has been necessary.
7.165 The Noise and Vibration Assessment (Atkins) confirms that internal noise levels within dwellings will not result in an adverse effect on health and quality of living for occupants, subject to suitable sound insulation. Some balconies are anticipated to experience noise levels above the values typically considered desirable in external amenity areas. However, residents will have access to substantial amounts of quiet, protected external amenity which experiences good levels of sunlight. A variety of private shared and publicly accessible spaces are provided within the development, accessible to all residents. In accordance with the relevant environmental noise criteria, the Proposed Development is not anticipated to cause or be exposed to adverse effects.
Units per core 7.166 All floors which share a single core within the proposals have 8 or fewer units (Housing SPG Standard 12). A number of floors include two cores and are explained as follows.
• of the 12 floors of B1 include 9 units sharing a single core. • 4 of the 12 floors of B2 have between 10 and 12 units, which include two stair cores and two lifts serving every floor. • 5 of the 13 floors in B3 have between 11 and 12 units also include two stair cores and two lifts serving every floor. • A stair is provided centrally to each part of the building meaning residents would not usually pass more than one or two other front doors before reaching their own. • Within all buildings at sixth floor level and above, there are only six units per floor/core. 7.167 The corridors have been designed with windows at either end to provide daylight and opportunities for cross ventilation. Within B2, the building has been designed to allow easy access from each floor directly to the rooftop amenity, without the need to go down to ground floor level.
7.168 The access to homes is also served by the concierge which would manage the development from building B2, and an entry phone and fobbed access system is proposed. The Build to Rent housing includes shared internal amenity spaces which fosters a sense of community between residents and feeling of security. The proposals therefore meet the criteria in terms of applying the standard of 8 units per core more flexibly.
7.169 On balance it is considered that this approach enables the design to meet or exceed the residential amenity standards, whilst also ensuring the scheme responds to heritage and landscape sensitivities and securing 40% affordable housing.
Quod | Land adjacent to Cockfosters Underground Station | Planning Statement | June 2021 82
External Amenity and Play Space 7.170 The Proposed Development additionally would provide 3,950sqm of external amenity space open to use by both residents of the development and the public. Areas of seating, orchards and informal planting have been designed, maximising the opportunity for south-facing landscape spaces created around and between the buildings. In order to maximise the amount of usable space, vehicular access has been confined to the periphery and reduced as far as possible in line with the TfL’s Healthy Streets objectives. Allowance for future provision of Blue Badge car parking of up to 10% has been considered and can be accommodated within the periphery of the site, with a minor reduction to the amount of external amenity whilst retaining its quality. These spaces would only be provided as required by residents as and when they are necessary.
7.171 318sqm of additional shared private external amenity would be provided to the roof of Block 2 (shoulder building, 6th floor) in the form of a terrace. This space would be open and accessible to all residents of the Proposed Development, offering seating and enclosed by planting, with views across to Trent Park and into the Site’s own landscape.
7.172 The external amenity spaces are fully accessible and have been designed to a high standard to provide opportunities to sit, play, relax, meet and dwell outside. Areas of new public realm, previously used for car parking, waste storage and a car wash, with poor quality surface treatment and unclear movement routes, have been created around the listed Station building, providing clear and improved pedestrian and cycle movement routes in the area.
7.173 An area of approximately 815sqm of the Site as existing is designated as Local Open Space. This area is currently not easily accessible or usable and comprises poor-quality vegetation and therefore does not make a strong contribution to open space provision. The trees within this parcel are of poor quality (category C or U). LBE Policy DMD 71 allows for the loss of open spaces (other than Metropolitan Open Land) if replacement open space can be re-provided in the same locality and is of better quality. The new publicly accessible amenity spaces within the Site amount to 3,950sqm and form part of a comprehensive landscape scheme that would provide accessible public realm that can be used by the local community. The Proposed Development would involve tree planting which more than compensates for the removal of existing poor quality trees (refer to section relating to trees for more detail). The proposals more than compensate for the loss and accord with LBE Policy DMD 71.
7.174 The Proposed Development includes play space that complies with the requirements set out in the Local Plan for a minimum of 10sqm per child. The GLA population yield calculator has been used to estimate the possible number of children that could be generated by the Proposed Development.
7.175 A total of 300sqm of doorstep play space for under 5s would be provided (against the minimum requirement of 290sqm), and 250sqm of play space for 5-11 year-olds would be provided compared to a minimum requirement of 200sqm. An area of 80sqm of 12+ age play facilities are proposed within the Site with additional facilities off-site within 800m walking distance as required for 12+ year olds.
7.176 An area of 650sqm of incidental play is provided for children of all ages which has been designed to supplement and complement the nearby offering in Trent Park and therefore include play space in excess of the minimum required amount for all ages. The play spaces
Quod | Land adjacent to Cockfosters Underground Station | Planning Statement | June 2021 83
would be created by informal features which instil imagination and creativity for children, tied to the adjacent network of streams, woodlands and grasslands. Overall, the proposed landscape includes 1200sqm of play space which will be publicly accessible, far in excess of the minimum requirement of 570sqm.
7.177 The Proposed Development includes 10% of units as wheelchair accessible (M4(3)) and 90% as wheelchair adaptable (M4(2)) as required by Policy D7 of the London Plan (2021). The design is inclusive and accessible, with consideration for the diverse population, facilitating social interaction and inclusion (Policy D5 of the London Plan (2021)) and accords with LBE Core Strategy Policy 9, encouraging development to provide access for all members of the community.
7.178 A Fire Statement has been submitted to accompany the application, outlining the fire safety features and evacuation procedures in accordance with Policy D5 and D12 of the London Plan (2021) and to secure the safety and security of future residents.
7.179 A Housing Standards Policy Checklist is provided in Appendix A, signposting the relevant information within the planning application documents to demonstrate compliance with the Development Plan, with the only exceptions outlined above.
Neighbour impacts 7.180 The Site is adjoined by open space or transport infrastructure on the northern and southern flanks, meaning that there is a limited potential to impact on the amenity of any neighbouring residents. A daylight and sunlight assessment has been undertaken to assess the potential effect of the Proposed Development on the amenity of neighbouring properties. This demonstrates that any impact on neighbouring properties would be acceptable. Similarly, a wind assessment has been carried out which demonstrates that the Proposed Development would not impact on the microclimate conditions of the surrounding area. The Proposed Development would comply with Policy D6 of the London Plan (2021) as it would ensure the provision of sufficient daylight and sunlight to new and surrounding housing and maximise the usability of outside amenity space.
Conclusion 7.181 The Proposed Development complies with all relevant and the most up to date standards and requirements to ensure that future residents would have suitable standards of amenity that as a minimum meet, and often exceed, the requirements of the London Plan (2021). The design of the development is tenure blind, with no distinction in terms of quality between private and affordable units. The Affordable Housing and Viability SPG recommends that Local Planning Authorities take into account the value of onsite management and apply design standards flexibly, in particular in relation to units per core and dual aspect in the context of Build to Rent development.
7.182 The layout and massing of the proposals have been developed in order to optimise the site’s capacity, in a highly sustainable location on brownfield land. All units are proposed to meet and, in most cases, exceed the internal space standards for unit size and the plans demonstrate how furniture can be accommodated within the spaces. Private external amenity is provided for every unit with a minimum of 5sqm for 1-2 person dwellings with an additional 1sqm per additional occupant.
Quod | Land adjacent to Cockfosters Underground Station | Planning Statement | June 2021 84
7.183 The site’s heritage and landscape constraints as well as tree root protection areas, LUL requirements and Thames Water easements has informed the design development to result in a scheme which balances the delivery of affordable homes, minimising heritage harm and residential amenity.
7.184 The affordable housing provision has been focused within two buildings to meet the Registered Provider requirements, and the proposals are tenure blind meaning there is no distinction between market and affordable units in terms of quality, design or space standards. Access is provided for all residents to the shared roof terrace and amenity spaces in B2, as well as all external amenity space at ground level which is also publicly accessible. All units have good outlook with a large proportion of units, especially at upper floor levels benefitting from views towards adjacent green spaces at Trent Park.
7.185 All units meet the required standards with a good outlook towards the adjacent green spaces and corridor of trees lining either side of the railway, good amenity in terms of noise and mitigation for overheating, and excellent levels of daylight and sunlight.
7.186 Additionally, whilst some levels of buildings B1, B2 and B3 exceed the recommended number of units per core of 8 (London Housing SPG), in a highly managed development such as Build to Rent, with an active concierge, controlled access, two stair cases and at least two lifts per core and with natural ventilation and daylight within the corridors, this recommendation can be applied flexibly and is acceptable in accordance with Appendix 4 to the LBE DMD, the London Plan and Housing SPG.
7.187 The proposed homes have been designed in accordance with all required policies and standards and therefore represent a good quality development, with high levels of residential amenity.
7.188 The Proposed Development would comply with the relevant local and national policies in relation to residential quality and amenity when read as a whole.
Traffic and Transport
Policy Context 7.189 The Mayor’s Transport Strategy and Policy T1 of the London Plan (2021) set out an ambition for 80% of journeys to be made by sustainable transport modes - by foot, cycle or public transport - by 2041. The Policy states that development should support this aim by making the most effective use of land, reflecting its connectivity and accessibility by sustainable travel modes. Furthermore, the Mayor’s ‘Healthy Streets Approach’ to create fairer, sustainable and attractive urban spaces, seeks to reduce car dominance, ownership and use, whilst increasing walking, cycling and public transport use. Compliance with these principles calls for design of streets to ensure they are easily accessible for all users.
7.190 Policy T2 of the London Plan (2021)requires development to facilitate and promote short, regular trips by walking or cycling and reduce car dominance, and similarly LBE Core Strategy Policy 25 requires development to prioritise pedestrian and cycle public realm improvements that contribute to quality and safety. LBE Core Strategy Policy 24 requires development to deliver improvements to the road network, and LBE Core Strategy Policy 26 requires development to ensure a safe, accessible, welcoming and efficient public transport network.
Quod | Land adjacent to Cockfosters Underground Station | Planning Statement | June 2021 85
LBE Policy DMD 45 sets parking standards and layout requirements, including criteria for determining appropriate car parking standards. Limited parking or car free housing developments must demonstrate that there is an adequate number of disabled parking spaces and public transport infrastructure has sufficient capacity to accommodate any increase in demand anticipated.
7.191 Policy T6 of the London Plan (2021) sets out the requirement for car-free development to be the starting point for all sites well-connected by public transport. Developments elsewhere should be designed to provide the minimum necessary parking (‘car-lite’). Where development is car-free, provision must be made for disabled persons parking and adequate space for deliveries and servicing. Policy T6 of the London Plan (2021) further states that an absence of local on-street parking controls should not be a barrier to new development (Policy T6). Policy T9 of the London Plan (2021) states that impacts from development may be migrated through the use of planning obligations.
7.192 As part of a planning application, the transport impacts of a proposal are required to be assessed and mitigated for. However, the prominent thrust of adopted and emerging policy is to prioritise travel by public transport or active modes such as walking and cycling, and these must take dominance over vehicular provision. This is supported by Chapter 9 (Promoting sustainable transport) of the NPPF which requires planning to promote sustainable transport and recognises the benefits of sustainable travel to reducing congestion, emissions and improving air quality and public health (Paragraph 103).
7.193 NPPF paragraph 109 states that: ‘Development should only be prevented or refused on highways grounds if there would be an unacceptable impact on highway safety, or the residual cumulative impacts on the road network would be severe’. Developments should give priority to pedestrian and cycle movements, facilitate access to high quality public transport and encourage public transport use (NPPF, paragraph 110 a)).
Assessment
Parking 7.194 The Site is currently in use as a surface level car park providing a total of 407 parking spaces. The Proposed Development seeks to take a ‘car-lite’ approach, substantially reducing the amount of parking it provides. General purpose public car parking would reduce from 360 spaces to 35, 9.7% of the existing amount (or a 91% reduction). Blue Badge car parking would not be impacted in terms of numbers, although it would be improved in terms of location and accessibility to the Station. A new drop-off/pick-up area accommodating seven spaces would be provided along with residential Blue Badge spaces and a car club for use by residents and the local community.
7.195 The amount and provision of car parking has been based on the policy requirement to reduce reliance on the private car and encourage travel by other means. The Site has a good PTAL rating and is well served by existing public transport networks and local amenities and is therefore suitable for lower car parking standards in accordance with LBE Policy DMD 45. TfL has confirmed that these networks have capacity to accommodate the Proposed Development.
7.196 Surveys used to inform the accompanying Transport Assessment (Pell Frischmann, June 2021) found that 78% of car park users started their journey outside the M25. Only 10.5% of
Quod | Land adjacent to Cockfosters Underground Station | Planning Statement | June 2021 86
trip origins were within the London Borough of Enfield and 8% from the London Borough of Barnet. 94.6% of users have a London Underground, Overground or National Rail station closer to their home than Cockfosters Underground Station. Only 2.6% of those surveyed started their journey inside the M25 and more than 960m from a station or 640m from a bus stop which serves Cockfosters Station. These distances are in line with those used in the calculation of the PTAL. The data therefore shows that nearly all of the survey respondents have alternatives to parking at the Station available to them to complete their journeys.
7.197 The existing car park therefore attracts substantial amounts of traffic travelling long distances from outside the local area, which has a detrimental impact on the highway network causing congestion and pollution. Survey data used to inform the Transport Assessment also shows that the majority of vehicles typically park for between 6 and 9 hours at a time, suggesting the car park is generally used for long stay park and ride, with only a very small proportion used to support the local economy. As the proposals evolved, ‘car-free development’ was a starting point in accordance with the requirements of Policy T6 of the London Plan (2021) and following feedback from local residents and groups, a small number (35) of parking spaces are now proposed to be re-provided for general use parking by the public and to support the local area and the 12 existing public Blue Badge spaces re-provided. Additionally, following feedback during pre-application consultation, a drop-off/pick-up area, predominantly serving users of the end of line underground station with 7 short stay spaces is proposed in close proximity to the Station entrance with step-free access (within Site A).
7.198 NPPF paragraph 103 identifies the benefits to limiting the need to travel by locating residential developments in sustainable locations as reducing congestion and emissions, and improving air quality and public health. A reduction in car parking capacity would also encourage sustainable transport choices as required by LBE Core Strategy Policy 24.
7.199 Given the good PTAL score, adequate public transport capacity and in line with the requirements of Policy T6.1 of the London Plan (2021) and the Mayor’s Transport Strategy, the Proposed Development would be car-free for residents, with the exception of Blue Badge provision.
7.200 The existing and proposed car parking provision as part of the Proposed Development is set out as follows:
Car Parking General Drop-off/ Public LUL Residential Car Taxi Total purpose Pick-up Parking (Blue (Blue Club charging parking (Blue Badge) Badge) Badge)
Existing 360 0 12 37 0 0 1 410
Proposed 35 7 12 1 11 (+ 24 1 1 68 (+24 passive) passive)
7.201 In line with Part G of London Plan Policy T6.1, 11 Blue Badge resident parking spaces would be provided for 3% of dwellings (with provision for an additional 24 should these be required in the future). A Car Parking Design and Management Plan has been prepared and submitted with the application as required by Paragraph 10.6.11 of the London Plan (2021) to
Quod | Land adjacent to Cockfosters Underground Station | Planning Statement | June 2021 87
demonstrate how initial and future provision of disabled persons parking spaces would be implemented, managed and enforced.
7.202 The existing amount of Blue Badge car parking (12 spaces) would be re-provided in close proximity to the Station entrance on Site A. In addition, a car club parking bay would be provided on Site for use by local residents and residents of the Proposed Development.
7.203 The Proposed Development would include infrastructure for electric and Ultra-Low emission vehicles, with 20% of residential, commercial and car club spaces having active charging facilities, and passive provision for 80% of those spaces in line with Part C of Policy T6.1 of the London Plan (2021).
7.204 No parking is proposed to support visitors to the retail unit on Site B, in accordance with Policy T6.3 of the London Plan (2021) which encourages retail development to avoid being car dependent. However, a cycle parking hub and visitor cycle parking would be provided on the Site as set out below.
7.205 The potential of the Proposed Development to result in an increase in on-street parking within the local area has been carefully considered. It is proposed that a Section 106 agreement (see Appendix B) would include a commitment to monitoring of parking in the nearby area that can identify whether the Proposed Development (once complete) leads to a demonstrable change in parking habits in the local area and action taken as necessary to mitigate any such changes. The Proposed Development would be advertised as car-free to prospective residents and a Travel Plan would be used to provide residents with information regarding sustainable travel options (as described below). Residents would also have access to an on-site car club and therefore have a private vehicle available to them for essential journeys. These measures would suitably mitigate any potential adverse impacts of the car-free residential scheme as required by LBE Policy DMD45.
7.206 The use of existing services and local shops is not generally reliant on the existing car park and there would be no change to the provision of short stay and unrestricted parking in place along Cockfosters Road. It is therefore considered unlikely that the Proposed Development would have an impact on local car parking availability. It would accord with the requirements of London Plan Policy T9, LBE Policy DMD 45 and the Mayor’s Transport Strategy.
Cycle Parking 7.207 An existing cycle route is located on Cockfosters Road and the proposals will contribute to improving the section of this which is within the Site.
7.208 The Proposed Development would increase the amount of public cycle parking provided re- providing the current 8 spaces, and adding a new cycle hub providing 60 spaces which would be secure and undercover, adjacent to the entrance to the underground on Site B.
7.209 Residents would be provided with secure and undercover cycle parking which is distributed within each building in accordance with London Plan (2021) standards set out by Policy T5. 5% of these spaces have been designed for wider or adapted cycles. Short stay visitor cycle parking would be accommodated within the landscape around the Site.
Quod | Land adjacent to Cockfosters Underground Station | Planning Statement | June 2021 88
7.210 LUL have 7 secure covered Sheffield stands and 4 other stands in the car park south of the building which would be re-provided by the Proposed Development.
Delivery and Servicing 7.211 Policy T7 of the London Plan (2021) requires developments to facilitate safe, clean and efficient deliveries and servicing and that adequate space is provided off-site. Provision is made within the Proposed Development for service and maintenance vehicles as necessary for both Site A and B in accordance with the proposed uses on each, as set out in the accompanying Delivery and Servicing Management Plan. This is intended to ensure that the operational efficiency of the Site is increased by minimising the time spent by goods and delivery vehicles on the highway.
Trip generation 7.212 The existing public car park currently generates approximately 1,650 daily vehicle movements into and out of the car park. Taking into account the reduced provision in car parking and the estimated amount of residential delivery, servicing and maintenance vehicles, the anticipated daily two-way trip generation is approximately 421 journeys. This results in a net reduction of around 1,200 daily two-way vehicle movements to the Site representing a huge improvement on the local road network.
7.213 The reduction in the number of vehicles on the road as a result of the removal of most of the existing car parking will support the aspirations of LBE Core Strategy Policy 24 for reducing congestion on the local road network and contributing to improved air quality.
Public Transport capacity 7.214 The Site has a PTAL rating of 3 to 4 and is adjacent to the London Underground Station with access to the Piccadilly line and good bus connections. In terms of the impact on existing public transport capacity, the Transport Assessment has identified a potential average increase of 4 people on each bus service during the morning and evening peaks respectively. This would have a negligible impact on the public transport capacity and aligns with the requirements of LBE Core Strategy Policy 26 to ensure public transport can accommodate development proposals. TfL has also confirmed that the public transport network has sufficient capacity to accommodate this increase.
Travel Plan 7.215 A draft Travel Plan has been submitted with the application in accordance with Policy T4 of the London Plan (2021), which demonstrates that the Proposed Development is compliant with the TfL guidance, and sets out a draft strategy for further increasing the sustainable travel movements of future residents and visitors to the Site, and encourages a shift towards active modes such as cycling. This is in addition to the Proposed Development being a car-free residential development which will mean that only Blue Badge holders would be able to park on-site. These measures designed into the Proposed Development and set out by the Travel Plan would encourage sustainable travel by future residents and would be enforced by planning condition or obligation, as necessary.
Quod | Land adjacent to Cockfosters Underground Station | Planning Statement | June 2021 89
Healthy Streets and Active Travel 7.216 A Healthy Streets Design Check has been conducted as required by Policy T2 of the London Plan (2021). This requires developments to reduce the dominance of vehicles and deliver improvements that support the ten Healthy Streets Indicators (see Figure 10.2 of the London Plan (2021)). Two checks have been carried out for the Site. The first for the proposed areas of public realm on Site A and Site B which shows an improvement of 20 points. Key improvements as a result of the provision of areas of public realm at the entrances to Sites A and B relating to the provision of shade and shelter, reduction in noise, and provision of things to see and do. The second check for Site A against the proposed layout shows an improvement of 29 points from 51 to 80. For the Site layout, the biggest improvements are of places to stop and rest and things to see and do as well as provision of shade and shelter.
7.217 Proposals for the provision of new public realm and the opening up of the secondary entrance within Site B, currently hidden behind hoarding support the requirements of LBE Core Strategy Policy 26 to ensure a safe, accessible and welcoming public transport network.
7.218 An Active Travel Zone assessment has been carried out in accordance with the recommended TfL methodology. This demonstrates that in general the local streets are good places to walk and cycle around. The reductions in the vehicular movements as a result of the removal of the car park would benefit the local area and therefore the Proposed Development would improve the health of the streets. The existing condition of local streets and proposed improvements to the Site are collectively anticipated to encourage walking and cycling by existing and future local residents.
7.219 The Proposed Development aligns with TfL’s core principles of promoting healthy streets and active travel as required by the London Plan (2021).
Construction Logistics 7.220 Part K of Policy T7 of the London Plan (2021) requires that: ’During the construction phase of development, inclusive and safe access for people walking or cycling should be prioritised and maintained at all times’. A draft Construction Logistics Plan has been prepared in support of the application, developed in line with TfL guidance as required by paragraph 10.7.6 of the London Plan (2021).
Conclusion 7.221 The Site is well-connected by existing public transport infrastructure, and the residential component of the Proposed Development would be car-free and include provision of cycle parking in line with policy requirements. The Proposed Development provides the policy compliant amount of Blue Badge car parking for residents and re-provides the existing amount of Blue Badge spaces for the public as well as providing a Blue Badge space for LUL staff. The Proposed Development, as a starting point, proposed a car-free Site (other than Blue Badge) but following public engagement and due to the terminus location with a PTAL of 3-4, a small amount (35) of public car parking spaces and a pick-up/drop-off area comprising seven spaces is proposed to be provided, which would represent a reduction in car parking of more than 90%. This would result in a substantial reduction in vehicle movements generated by the Site whilst supporting local trips and travel by those less able to travel by other means. The existing taxi charging bay would also be re-provided, and a new car club bay for use by residents and the public included on-Site. It is anticipated that the number of spaces and
Quod | Land adjacent to Cockfosters Underground Station | Planning Statement | June 2021 90
management such as restrictions on length of stay, would deter drivers arriving from outside of London who contribute to local congestion and poor air quality.
7.222 The Proposed Development would not only reduce the number of cars on the road as a result of the removal of a large number of car parking spaces, reducing car dominance (in accordance with Policy T2, London Plan (2021)). It would also actively promote sustainable travel modes and improve the health of the streets by reducing congestion, providing enhanced public realm and improving air quality. The Proposed Development, in respect of car and cycle parking, delivery and servicing, is in accordance with the requirements of the London Plan (2021) standards.
7.223 The Proposed Development would have a negligible impact on local public transport capacity as required by LBE Core Strategy Policy 26, and would improve accessibility around the Station to create a more welcoming and pleasant environment for all users and in particular pedestrian and cycles. These changes align with Policies 25 and 26 of the LBE Core Strategy.
7.224 The Proposed Development is in full compliance with Policy GG2 and T6 of the London Plan (2021), both of which promote car-free development as the starting point, and paragraph 103 of the NPPF which encourages development to limit the need to travel, reduce congestion and emissions and improve public health. Any off-site impacts as a result of the Proposed Development can be mitigated through planning obligations in line with Policy T9 (London Plan (2021)).
7.225 The Proposed Development in relation to traffic and transport implications is in accordance with local and national planning policy.
Environmental Considerations
Policy Context 7.226 The NPPF maintains the presumption in favour of sustainable development, including environmental sustainability.
7.227 The NPPF requires planning to support the transition to a low carbon future in a changing climate, assisting in reducing greenhouse gas emissions, minimising vulnerability, encouraging the reuse of existing resources and supporting renewable and low carbon energy infrastructure (Paragraph 148, NPPF).
7.228 Policy G1 of the London Plan (2021) recognises the importance of London’s network of green features in the built environment and requires them to be protected and enhanced. Part A of the Policy states that this green infrastructure ‘should be planned, designed and managed in an integrated way to achieve multiple benefits’.
Energy and Sustainability
Policy Context 7.229 All residential schemes are required to achieve net zero carbon with at least an on-site 35% reduction in carbon emissions beyond Part L of 2013 Building Regulations, with the same target applied to non-domestic developments.
Quod | Land adjacent to Cockfosters Underground Station | Planning Statement | June 2021 91
7.230 Paragraph 153 of the NPPF requires new developments to comply with local requirements for decentralised energy supply and minimise energy consumption by taking account of landform, layout, building orientation, massing and landscaping.
7.231 Policy SI2 of the London Plan (2021) sets a target for all development to achieve net zero carbon. This should be achieved by reducing CO2 emissions by a minimum of 35% on-site, of which at least 10% should be achieved through energy efficiency measures for residential development (or 15% for commercial development).
7.232 In addition, LBE Policy DMD 55 and Paragraph 9.2.3 of the London Plan (2021) require all available roof space to be used for solar photovoltaics.
7.233 Where the zero carbon target cannot be achieved once the energy hierarchy has been followed, any shortfall should be recouped through payments to LBE's carbon off-set fund at a rate of £60/tonnes per year for a period of 30 years (LBE S106 SPD 2016)).
Assessment 7.234 A detailed Energy Assessment (Atkins, 2021) has been prepared to support the application. The Proposed Development has followed the London Plan regulated carbon emissions reduction priority hierarchy of Be Lean (use less energy), Be Clean (supply energy efficiently), Be Green (use renewable energy) and Be Seen (monitoring).
7.235 Be Lean measures include efficient building fabric including highly insulated walls, floors and roofs, efficient glazing, high levels of air tightness, heat recovery systems and low energy lighting.
7.236 Be Clean measures are achieved by connection to the Energetik district heating network on the basis that agreement can be reached with Energetik for the supply heat to be extended to the Proposed Development in the required timeframes. There would be a contractual agreement with the Applicant to carry out detailed design and construction works to enable a connection.
7.237 The Oakwood Heat Network that the Proposed Development would connect into is currently served by an energy centre that generates heat using gas Combined Heat and Power and boilers. The network connection is proposed in accordance with the requirements of Policy SI3 of the London Plan (2021) and LBE Policy DMD 52 requiring major development to connect to existing heat networks unless there are feasibility or viability reasons not to. The Heat Network seeks to connect to the Meridian Waste Heat Network which recovers low carbon energy from industrial facilities, in the long term, presenting the opportunity for further carbon reductions in the future. In the event that a connection to the DHN is not possible, an Air Source Heat Pump (ASHP) energy strategy has also been designed for as a fallback position which can be implemented as an alternative sustainable energy source could be provided without requiring a redesign in accordance with London Plan requirements to prioritise local energy sources.
7.238 In addition, the Proposed Development would include the installation of 30sqm of solar photovoltaic panels (PV) on the area of roof not occupied by amenity space or plant, or overshadowed by parapets or other buildings. Provision of PV has been maximised as far as possible in the context of the available roof space and within the parameters of the scheme’s viability.
Quod | Land adjacent to Cockfosters Underground Station | Planning Statement | June 2021 92
7.239 The Energy Assessment clearly demonstrates how the strategy follows the energy hierarchy and implements the relevant measures towards achieving zero carbon. The carbon emission reduction model demonstrates that the emission reduction from the baseline (Part L 2013) as
a result of the Be Lean, Be Clean and Be Green measures will achieve 49% CO2 savings compared to the 35% minimum required by Policy SI2 (London Plan 2021). The alternative ASHP strategy would result in savings of 54% on-site.
7.240 Should the future decarbonisation plans presented by Energetik to LBE come to fruition to replace the existing source of heat with an alternative technology designed to emit less carbon
per tonne of heat, this would increase to 79% CO2 savings.
7.241 Following all measures towards zero carbon on site, the Proposed Development would result
in a shortfall of 6,276.4 annual tonnes of CO2 emissions over 30 years against the zero carbon target based on the District Heating Network strategy. This shortfall would be offset through
monetary payments to the Borough’s carbon offset fund of £60/tonne CO2/annum, which has been estimated to be approximately £376,582 in accordance with the LBE Section 106 SPD.
The ASHP scenario would result in a shortfall of 4,768.3annual tonnes of CO2 emissions over 30 years against the zero carbon target equating to an offset payment of approximately £286,098.
7.242 The Applicant proposes to monitor and report the energy consumption and generation upon occupation as required by Policy SI2 of the London Plan (2021) using a suitable metering strategy.
7.243 In addition to the policy requirements, the Proposed Development has been considered against the requirements of the Home Quality Mark (Building Research Establishment), a customer focused, third-party certification scheme which assesses new homes against best practice standards that are often above those required by regulation, giving a star rating system (ratings range from 1 to 5 Star) to give an overall picture of the proposed home’s quality. The Proposed Development is targeting a 4 Star rating.
Conclusion 7.244 The Proposed Development is a highly sustainable scheme which complies with and exceeds the requirements of the Development Plan, focusing on the use of low and zero carbon technologies and local energy sources. The connection to a local district heating network and inclusion of PV energy generation means that the Proposed Development would exceed the minimum required on-site targets for carbon reduction of 35% by achieving a 49% reduction. An alternative energy strategy using ASHPs would achieve a 54% reduction on site. The shortfall against the zero carbon target is to be offset through financial contributions secured through a Section 106 agreement, and the energy generation and carbon emissions will be monitored over time.
7.245 The energy strategy approach achieves the requirements of London Plan Policy SI 2, and the Proposed Development supports the requirements and aspirations of local, London and national planning policies for minimising greenhouse gas emissions and the contributions of development to climate change. It also supports the Enfield Climate Action Plan 2020.
Quod | Land adjacent to Cockfosters Underground Station | Planning Statement | June 2021 93
Archaeology
Policy Context 7.246 Paragraph 184 of the NPPF requires heritage assets to be conserved in a manner appropriate to their significance. Paragraph 189 requires applicants to describe the significance of a heritage asset sufficiently to ‘understand the potential impact of the proposal on their significance’. Policy HC1 of the London Plan (2021) requires development proposals to ‘identify assets of archaeological significance and use this information to avoid harm or minimise it through design and appropriate mitigation’.
Assessment 7.247 The Site is located within the extent of the Camlet Moated Site Archaeological Priority Area which covers the scheduled medieval site and surrounding parkland. An Archaeology Assessment has been prepared which accompanies the planning application in accordance with the requirements of the NPPF.
7.248 The archaeological potential for the Site is low and it is unlikely that any archaeological remains survived after the construction of the Station. Any groundworks on the Site would be monitored to confirm the presence or absence of archaeological remains within the Site and be dealt with by an approved Written Scheme of Investigation.
7.249 The Proposed Development therefore complies with the relevant policies in relation to below ground heritage potential.
Flood Risk and Drainage
Policy Context 7.250 Policy SI 12 of the London Plan, (2021) requires development to ensure flood risk is minimised and mitigated and that residual risk is addressed.
7.251 The Site is located within Flood Zone 1 meaning that the sequential test does not apply to the Proposed Development. The Proposed Development involves a change of use to a ‘More Vulnerable’ use class (Flood Risk Table 2) which is acceptable in Flood Zone 1, without the requirement for the Exception Test to be passed, in accordance with Flood Risk Table 3 (vulnerability and flood zone ‘compatibility’) set out in the Planning Practice Guidance (Paragraph: 067 Reference ID: 7-067-20140306).
7.252 Policy SI13 of the London Plan (2021) relate to sustainable drainage. The preference is to reduce surface water discharge from the Site to greenfield run off rates. Where this is not feasible and robust justification is provided, a discharge rate of three times the greenfield rate may be acceptable.
Assessment 7.253 A Flood Risk Assessment (Atkins, June 2021) assessing all sources of flood risk in relation to Policy SI12 of the London Plan (2021) has been prepared to support the planning application. This has demonstrated that the Site is at a low risk of flooding from all sources with the only residual risk from surface water that is dealt with by the accompanying Drainage Strategy to
Quod | Land adjacent to Cockfosters Underground Station | Planning Statement | June 2021 94
ensure that the Proposed Development would not increase flood risk to surrounding areas (Atkins, June 2021).
7.254 The drainage design process has been carried out in accordance with the London Plan (2021) Drainage Hierarchy, prioritising the use of SuDS elements and discharging into natural water courses before any public sewer connections. Infiltration is not considered to be a viable option for the drainage solution.
7.255 A site investigation would be completed prior to the commencement of construction work to determine the potential for ground water flooding, for which mitigation measures such as the use of suitable construction techniques and basement waterproofing can be implemented to avoid any potential residual impacts should this be required.
7.256 The Proposed Development would decrease the impermeable area within the Site as a result of the removal of a large proportion of the existing car parking hardstanding and replacement by areas of green roof, soft landscaping and permeable paving. Sustainable drainage systems (SuDS) and the restriction of the discharge rates to greenfield runoff rates, taking into account an allowance for climate change, ensures that the development provides betterment of the existing situation.
7.257 SUDS drainage hierarchy as required by Policy SI13 (B) requires the integration of SUDS into the landscape to provide amenity and water quality benefits. The landscape strategy includes a number of sustainable drainage measures including green and brown roofs, porous paving, swales, channels and rills, an attenuation pond, tree pits and rain gardens. These measures have been incorporated into the landscape to provide a playable space that creates interest as well as a practical solution for treating and reducing run off. As a result, surface water discharge volumes are significantly reduced and provide a significant reduction in downstream flood risk.
Conclusion 7.258 The Proposed Development is fully compliant with local and national policy in relation to flood risk and drainage and would provide a significant improvement to surface water quality and quantity both on and off site.
Ecology and Biodiversity
Policy Context 7.259 The Site is adjacent to a SMINC and SBINC, and near to a Wildlife Corridor which runs along the Piccadilly Railway Line tracks. The Site is currently of low biodiversity and ecological value, with the exception of vegetation to the periphery of the Site, and an area of woodland to the north of Site A which forms part of an area of designated Local Open Space.
7.260 Paragraph 170 of the NPPF requires planning decisions to protect and enhance sites of biodiversity value, providing net gains for biodiversity and establishing resilient ecological networks. Policy GG2 of the London Plan (2021) requires development to ‘protect and enhance… designated nature conservation sites and local spaces and promote the creation of new infrastructure and urban greening, including aiming to secure net biodiversity gains where possible’. This is echoed in Policy G6 of the London Plan (2021) which requires developments to manage impacts on biodiversity and secure a net biodiversity gain. LBE Core
Quod | Land adjacent to Cockfosters Underground Station | Planning Statement | June 2021 95
Strategy Policy 36 requires development to protect, enhance, restore or add to existing biodiversity including green spaces and corridors.
7.261 The draft Environment Bill, published by the UK Government in October 2019, includes proposals to make biodiversity net gain (BNG) a mandatory requirement within the planning system in England. If the Environment Bill is passed in a form similar to that introduced in October 2019, developments such as the Proposed Development would be required to achieve at least 10% gain in quantitative biodiversity relative to the Site's baseline biodiversity.
7.262 Policy G5 of the London Plan (2021) relates to urban greening, recognising the benefits urban greening has to improved health, climate change adaptation and biodiversity conservation. In the absence of an LBE requirement, the Policy sets out a minimum score of 0.4 for predominantly residential developments.
Assessment 7.263 The Site is largely dominated by hardstanding and other habitats of low ecological value. The Proposed Development has been informed by a Phase 1 habitat survey of the Site and an ecological desk study. Mitigation is proposed during the construction and operational phases to avoid residual adverse effects.
7.264 Proposed landscaping would replace habitats lost from the Site and introduce substantial new planting and green infrastructure including tree and shrub cover as well as urban woodland, flower rich meadows, flowering and fruiting trees and shrubs and seasonally wet SUDS areas and both green and brown roofs. All planting is selected to maximise biodiversity and feature native or near native species which will help to reinforce the established nature of the adjoining SBINC and SMINCs.
7.265 The Proposed Development has been assessed to achieve an Urban Greening Factor score of 0.42. A biodiversity net gain assessment was undertaken using Natural England’s Biodiversity Metric 2.0 Calculation. The Proposed Development is expected to result in a 447% biodiversity net gain which is far in excess of the requirements of the forthcoming Environment Bill, and also demonstrates compliance with the requirements of the NPPF (Para 170) and Policy G6 of the London Plan (2021) for development to deliver biodiversity net gain.
Conclusion 7.266 The Proposed Development complies with the requirements of national and local policies which require development to protect and enhance the natural environment. The extent of new planting and soft landscaping would provide a significant benefit to the local area amounting to a 447% biodiversity net gain, which is significantly more than the suggested the minimum requirements. The landscape strategy also ensures that the Proposed Development would exceed the minimum requirement for Urban Greening on-site.
Trees
Policy Context 7.267 Policy G7 of the London Plan (2021) requires existing trees of value to be retained, and any removal to be compensated by adequate replacement, based on the existing value of benefits. Planting of new trees, especially those with large canopies, should be included within
Quod | Land adjacent to Cockfosters Underground Station | Planning Statement | June 2021 96
development proposals. LBE Policy DMD 80 requires that developments do not result in any loss or harm to trees of significant biodiversity or amenity value, or adequate replacement must be provided. LBE’s Emerging Local Plan outlines the benefits that trees offer to people and the environment by improving air quality, reducing noise pollution, contributing to climate change adaptation and reducing the urban heat island effect.
Assessment 7.268 The Proposed Development would involve the removal of 17 trees, as well as a number of trees within groups, all of which are low or poor quality (Category C or U), and none are Category A or B (good or high quality). A total of 93 new trees are proposed to be planted at part of the Proposed Development, representing a net gain of 75 trees. This would mean an overall increase in tree canopy cover on the Site. Additionally, a large number of shrubs and other planting would contribute to greening of the Site.
7.269 Proposed below ground utilities and drainage infrastructure has been designed to avoid Root Protection Areas to protect the integrity of retained trees. Protection measures have been outlined within the accompanying outline Arboricultural Method Statement to ensure the feasibility of retaining all identified trees.
7.270 The Proposed Development is fully compliant with the Development Plan in relation to trees and there would be an overall improvement in the amount and quality of trees on the Site as a result of the Proposed Development.
Air Quality
Policy Context 7.271 The Site is located within an Air Quality Management Area which is borough wide. LBE Air
Quality Action Plan identifies local cans/lorries/cars and buses and significant sources of NO2 pollution. Policy SI1 of the London Plan (2021) set out the requirements relating to improving air quality. Policy requires that development proposals must be at least Air Quality Neutral and use design solutions to prevent or minimise increased exposure to existing air pollution.
7.272 The same policy requires developments to consider how they will reduce the detrimental impact to air quality during construction and seek to reduce emissions from the demolition and construction of buildings.
7.273 Paragraph 103 of the NPPF recognises that development proposals which directly address transport issues and promote sustainable means of travel can have a direct positive benefit on air quality and public health by reducing congestion and emissions.
7.274 LBE Policy DMD 65 requires development to have no adverse impact on air quality and provide improvements where possible.
Assessment 7.275 An Air Quality Assessment has been submitted in compliance with Policy SI1 of the London Plan (2021). This demonstrates that future residents of the Proposed Development would not be exposed to unacceptable levels of pollution. Furthermore, the Proposed Development is forecast to result in a net reduction of approximately 1,200 daily two-way vehicle movements
Quod | Land adjacent to Cockfosters Underground Station | Planning Statement | June 2021 97
entering and exiting the car park each day6, which is expected to involve an improvement to local air quality as required by paragraph 103 of the NPPF (refer to the accompanying Air Quality Assessment, Atkins, June 2021 for more details), as well as tackling the causes of climate changed by reducing the release of greenhouse gases.
7.276 Mitigation measures for construction dust have been identified to ensure no adverse impacts on air quality from the construction stage as required by Policy SI1 of the London Plan (2021).
7.277 The Proposed Development is expected to contribute to an overall improvement in air quality and contribute to achieving the aims of the LBE Air Quality Action Plan. It therefore complies with the Development Plan and the NPPF in relation to air quality.
Wind Microclimate
Policy Context 7.278 Policy D9 of the London Plan (2021) requires developments to consider the wind and microclimatic conditions around proposed buildings and ensure that they are carefully designed so that they don’t compromise the comfort and enjoyment of the surrounding open space. Air movement affected by developments should support the effective dispersion of pollutants, but not adversely affect street-level conditions. Policy D3 and Policy D8 of the London Plan (2021) also reference wind and microclimate conditions and re-emphasise the importance of considering these factors.
Assessment 7.279 A wind microclimate assessment comprising an experience-based desk study has been prepared to inform the design development and guide principles such as the positioning of buildings, doorways and landscape features to ensure the Proposed Development would provide a comfortable environment. The Proposed Development is not expected to materially affect existing local conditions around the Site. Within the Site, changes to microclimate conditions as a result of the development are expected to be appropriate for the proposed use and for play, sitting and recreational activities.
7.280 The Proposed Development would not therefore cause any harm to the amenity of the area in respect of wind and microclimate in accordance with the London Plan (2021).
Waste
Policy Context 7.281 The environmental objective of the NPPF refers to the importance of waste management and resource efficiency. Policy SI7 of the London Plan (2021) encourages waste minimisation and waste prevention through the reuse of materials and using fewer resources. Referable applications should promote circular economy outcomes and aim to achieve net zero-waste.
6 Based on an existing utilisation rate of 90%. Please refer to the accompanying Transport Assessment (Pell Frischmann, June 2021 for more details).
Quod | Land adjacent to Cockfosters Underground Station | Planning Statement | June 2021 98
7.282 Core Strategy Policy 22 ‘Delivering Sustainable Waste Management’ states that in all new developments, LBE will encourage the inclusion of re-used and recycled materials and encourage on-site re-use and recycling of construction, demolition and excavation waste.
Assessment 7.283 A Site Waste Management Plan is provided to accompany the application (Sustainability Statement, Atkins). This addresses the likely waste generated from the construction of the Proposed Development and sets out a strategy to divert a minimum of 95% of construction, demolition and excavated waste from landfill which meets the requirements of Policy SI7 (London Plan, 2021). Waste management during construction would be in line with the waste hierarchy to minimise as much as possible the amount of waste being sent to landfill or similar disposal routes.
7.284 The Delivery and Servicing Management Plan accompanying the application details the operational waste requirements. This includes access arrangements for waste vehicles and base calculations of bin numbers for waste storage. The plan includes estimates for the quantity of dedicated recycling bins required for the dwellings.
7.285 The Proposed Development will seek to minimise waste generation as much as is feasible during both the construction and operational phase and use sustainable construction and waste disposal methods as much as possible in accordance with the Development Plan.
Climate Change 7.286 LBE Council adopted its Climate Action Plan in July 2020 setting out its vision for climate action to become a carbon neutral borough by 2040. This Action Plan sets out how LBE will meet its Climate Emergency Pledge (signed in 2019), declaring a state of emergency and agreeing to the establishment of a Climate Emergency Task force to tackle the impact of climate change and prevent catastrophic consequences as a result.
7.287 The report shows that the highest proportion of emissions in LBE is from transport at 39% (by tonnes of CO2) compared with emissions from domestic (35%), waste (2%) and industry and commercial (24%) activities. LBE has set targets for ‘the journey to carbon neutrality’ involving 55% of trips in the borough to be made by sustainable means by 2022, reducing transport emissions by 35.7% by 2025, and requiring nearly 70% of trips to be made by sustainable means by 2040.
Policy Context 7.288 Paragraph 150 of the NPPF requires new developments to ‘be planned for in ways that a) avoid increased vulnerability to the range of impacts from climate change… and b) can help to reduce greenhouse gas emissions, such as through its location, orientation and design’. In July 2019, LBE’s Cabinet declared a state of climate emergency and committed to making the authority carbon neutral by 2030 or sooner. The key themes of the Sustainable Enfield Action Plan relate to energy, regeneration, economy, environment, waste and health.
7.289 The London Plan (2021) and LBE’s Emerging Local Plan both make reference to the need for development to limit its impact on climate change while adapting to the consequences of environmental changes. The London Plan (2021) seeks to lead the way in tackling climate change by moving towards a zero-carbon city by 2050.
Quod | Land adjacent to Cockfosters Underground Station | Planning Statement | June 2021 99
Assessment 7.290 The proposals to replace the existing car park with a car-free development of new homes aligns with the aspirations of adopted and emerging planning policy, and LBE’s commitment to becoming a carbon neutral borough by 2040.
7.291 The Proposed Development would start to tackle climate change by removing the opportunity for and subsequently reducing the reliance on private motor vehicles, easing traffic and congestion as identified by Policy T2 of the LBE’s Emerging Local Plan. The Proposed Development scores highly against the Healthy Street indicators, demonstrating they would provide an overall improvement in the local environment that will encourage and help Londoners to use cars less and walk, cycle and use public transport more. This would consequently reduce the use of cars or polluting vehicles and emission of greenhouse gases (carbon dioxide, methane and nitrous oxides) which contribute to climate change.
7.292 The Proposed Development would minimise the impacts of climate change, contributing to local green infrastructure through new planting, green roofs and a net gain in tree coverage which all support biodiversity and reduce the urban heat island effect. These green networks would connect to existing ecological corridors and open spaces, particularly along the Piccadilly Line railway tracks.
7.293 The layout of the Proposed Development includes passive design strategies to reduce energy consumption and proposes the use of efficient processes and appliances, energy efficient fabric, insulation and glazing, as well as efficient lights, hot water storage and mechanical ventilation with heat recovery. The proposed energy strategy seeks to connect to the District Heating Network which is an efficient system for minimising energy demand. In addition, PV panels would be installed, and energy consumption and generation will be monitored and reported with a view to reducing over time.
7.294 The Proposed Development would also seek to be resilient to the severe weather and long- term climate change impacts by adapting to the consequences of environmental change through measures such as a flood risk and drainage strategy which reduces run off and accounts for rainfall events with an allowance for climate change, and a proposed Site layout which includes both passive and designed measures to avoid overheating.
Conclusion 7.295 The Proposed Development accords with London Plan and LBE’s Action Plan to tackle climate change, minimise its impacts and ensure development is resilient to its effects. It employs strategies such as promoting sustainable travel, removing cars from the road and significantly reducing vehicle movements generated by the Site, utilising efficient systems and energy consumption reduction as well as enhancing and expanding the green infrastructure network through measures such as tree planting and green roofs. The design also accounts for the likely extreme weather events to be experienced in the future such as higher temperatures and rainfall and mitigates the effect that would have on future residents and the local and wider community.
Quod | Land adjacent to Cockfosters Underground Station | Planning Statement | June 2021 100
Health
Policy Context 7.296 One of the key aims of the London Plan (2021) is to create a healthy city. Paragraph 1.3.1 (London Plan (2021)) identifies that the mental and physical health of Londoners is to a large extent determined by the environment in which they live. There are a number of determinants of health including transport, housing, air quality, green space, climate change and social and community networks. Policy GG3 of the London Plan (2021) requires development to promote more active and healthy lives, use the Healthy Streets approach and ensure development supports and improves mental and physical health and wellbeing.
7.297 The Healthy Urban Development Unit have prepared a Healthy Urban Planning Checklist (2017) against which proposed developments can be assessed in order to ensure they are contributing to and enhancing the health of future residents and the local community.
Assessment 7.298 The Proposed Development involves the creation of healthy homes which have been designed to be consistent with the minimum space standards for both internal and private external spaces and include suitable insulation and overheating mitigation to ensure a healthy and relaxing home environment. All apartments will be capable of accommodating desk-space to work from home. The Proposed Development includes the provision of a mix of housing sizes at a range of affordability thresholds, including 10% wheelchair accessible homes, with the remainder designed to be adaptable to wheelchair use if needed. Residents would be provided with facilities such as a gym, lounge and workspaces, contributing to their overall health and wellbeing.
7.299 The proposed removal of the existing car park promotes active travel by minimising car use as acknowledged by Paragraph 1.0.10 of the London Plan (2021), as a positive means of improving Londoners’ health and making the city ‘a better place to live’. The layout of the Proposed Development also creates an environment supportive of walking and cycling and the healthy environment is exemplified by the significant improvements in the Healthy Streets score resultant from the proposed development.
7.300 The supporting documents including the Health Impact Assessment (Quod, June 2021) have assessed the likely effects of the Proposed Development on air quality, noise and considered the impacts from construction. Overall and with mitigation, there are not anticipated to be any adverse impacts that cannot be managed. Air quality is expected to improve as a result of removing the car park and the introduction of soft landscaping and sustainable drainage systems would reduce the chance of surface water flooding and the amount of runoff from the site. There would overall be an improvement to the health of the existing community and future residents resulting from the environmental improvements.
7.301 The Proposed Development includes the provision of two new areas of public realm adjacent to the Station entrances as well as public external amenity and play space for future residents. Shared facilities assist in creating a sense of community which supports health and wellbeing. The Site is well connected with good access to services such as a local schools, health services and shops. The Proposed Development would therefore contribute to creating and enhancing a vibrant neighbourhood, providing additional facilities for existing residents, and including services for future residents that support their health and wellbeing.
Quod | Land adjacent to Cockfosters Underground Station | Planning Statement | June 2021 101
Conclusion 7.302 The Proposed Development would have a positive influence on the mental and physical health of Londoners by improving the environment in which they live, by providing healthy homes, promoting active travel, improving air quality and contributing to vibrant neighbourhoods. It, therefore, accords with policy.
Planning Obligations
Policy Context 7.303 In accordance with paragraph 56 of the NPPF and Regulation 122 of the Community Infrastructure Levy Regulations 2010 (as amended), planning obligations should only be used where they meet the following tests:
• Necessary to make a development acceptable in planning terms; • Directly related to the development; • Fairly and reasonably related in scale and kind to the development.
Community Infrastructure Levy 7.304 Community Infrastructure Levy (CIL) is a non-negotiable charge which is levied on new development and is intended to assist in financing the cost of additional infrastructure required to support new development. This contributes towards broader strategic infrastructure needs.
7.305 The Enfield Infrastructure Funding Statement (2019/2020) states that ‘In Enfield, 15% of CIL receipts have been ringfenced to spend on local projects… The neighbourhood portion of the CIL must be spent on the improvement, replacement, operation or maintenance of infrastructure or anything else concerned with addressing the demands that development places on an area… Views will be sought from local community groups and stakeholders on how the neighbourhood portion should be spent.’
7.306 The Applicant supports the use of a proportion of the CIL contributions to be spent on local priorities undertaken in consultation with the local community. A proportion of the CIL charge of approximately £4m could therefore be used to support any requirements to improve local infrastructure.
7.307 Mayoral CIL is also relevant to the Proposed Development. LBE falls within Zone 3 rates and is index-linked using Building Cost Information Service (BCIS) figures.
7.308 A CIL Form 1 has been prepared and submitted with this application.
Section 106 SPD 7.309 A Section 106 Agreement is required in addition to CIL to secure planning obligations which would mitigate site-specific matters (such as environmental improvements, traffic management schemes or to secure affordable housing) and make the Proposed Development acceptable in planning terms.
7.310 To ensure viability, the costs of any requirements likely to be applied to Proposed Development, such as requirements for affordable housing, infrastructure contributions or
Quod | Land adjacent to Cockfosters Underground Station | Planning Statement | June 2021 102
other requirements should, when taking account of the normal cost of development and mitigation, provide competitive returns to a willing landowner and willing developer to enable the Proposed Development to be deliverable.
7.311 The recommended Heads of Terms for the relevant Section 106 Agreement is provided at Appendix B and will be discussed and agreed with LBE prior to any Planning Committee.
Quod | Land adjacent to Cockfosters Underground Station | Planning Statement | June 2021 103
8 Conclusions 8.1 The Proposed Development has been designed in the context of the relevant local, London and national planning policy.
8.2 The Site is a previously developed site which is currently underutilised, where the development for housing is fully supported at all levels of policy (e.g. as per the Paragraph 59 of the NPPF and Policy GG2 and H1 of the London Plan (2021).
8.3 The delivery of 351 new homes would optimise the use of a sustainably located brownfield site and make a significant contribution towards meeting both the LBE’s and the Mayor’s annualised housing targets. The homes meet the Mayor’s definition of BtR and would provide a range of benefits not offered by the existing buy-to-let dominated private rental sector. The provision of 40% affordable housing (by habitable room) would contribute significantly towards local and strategic housing need and targets.
8.4 The provision of DMR at a range of discounts, including those equivalent to London Living Rent levels, meets the policy requirements for BtR housing and responds to a specific need in the Borough for small units for middle-income earners. This also responds to the demonstrable need for 1 and 2 bed units, especially in an area currently dominated by 3 bed plus private housing supply.
8.5 The Proposed Development is a heritage-led scheme which successfully responds to its context. The removal of car parking and provision of new areas of public realm and extensive external landscape accessible to everyone would encourage a move towards active travel and the use of public transport in line with the Mayor’s Transport Strategy for Healthy Streets. The landscape proposals include clearer signposting and accessibility to the LOOP and Trent Park and a more welcoming public realm around the secondary entrances to the Station, as well as providing an important contribution towards biodiversity and habitat creation on a site of current low ecological value.
8.6 Optimisation of the Site has also considered the requirements for residential space standards, private external amenity, play space and creating mixed and inclusive communities through the provision of wheelchair accessible and adaptable units. The Proposed Development would provide more than the minimum policy requirements for each of these items in most areas for future residents and the local community.
8.7 The Proposed Development has been developed iteratively and has been informed by a set of overriding design principles, including the heritage and other constraints of the Site. The proposed height, massing and materiality of the buildings is informed by the balance between the viability of the Proposed Development, alongside the need for new homes and the sensitivities of the setting of the heritage assets in which the Site is situated. The Proposed Development would create a new backdrop to the Station and would be visible in some views from Trent Park. However, great care has been taken to ensure that the design results in the Proposed Development being visible only from less sensitive locations in Trent Park, and where it is visible, the buildings appear as slender elements on the skyline. The buildings have been designed with high quality parapets that break up the massing and reduce visual impact through use of a palette of recessive materials that further reduce visual impacts. The iterative design process has demonstrated significant moves to mitigate as far as possible the harm
Quod | Land adjacent to Cockfosters Underground Station | Planning Statement | June 2021 104
caused to the significance and setting of Trent Park and its Conservation Area, and the Station. The level of harm has been reduced through key design moves to result in less than substantial harm that is clearly outweighed by the significant public benefits associated with the Proposed Development.
8.8 The Proposed Development would:
• maximise the supply of housing; • optimise and make efficient use of brownfield public sector land; • deliver 40% affordable housing (by habitable rooms); • deliver Healthy Streets; • promote sustainable travel choices and provide car free residential developments where appropriate; and • deliver sensitive and sustainable design. 8.9 The legislative and policy context makes it clear that Local Planning Authorities should determine development proposals in accordance with the Development Plan when taken as a whole. Paragraph 11(c) of the NPPF requires LPAs to approve proposals that accord with an up-to-date development plan without delay. The Proposed Development accords with the Development Plan when taken as a whole, although it does conflict with certain policies within it and therefore should be approved in accordance with the presumption in favour of sustainable development.
8.10 The Proposed Development should be seen in the context of the London Plan (2021) as well as the LBE DMD and Core Strategy. However, in accordance with the requirements of NPPF paragraph 11(d) and footnote 7, these Local Plan policies are out of date by virtue of the under delivery of housing in Enfield over the past three years7. The Enfield emerging Local Plan which went through a preliminary consultation period between December 2015 and February 2016 and therefore this Plan is given some limited weight in accordance with NPPF paragraph 48.
8.11 Paragraph 11(d) requires applications to be approved where the policies which are most important for determining the application are out-of-date unless any adverse impacts of doing so would significantly and demonstrably outweigh the benefits. The Proposed Development accords with the Development Plan when taken as a whole. This Statement has identified those policies relevant to the Proposed Development and provided an assessment against them, demonstrating that there would be no adverse impacts that would significantly and demonstrably outweigh the benefits. Overall, therefore, the Proposed Development should be granted planning permission without delay in accordance with the presumption in favour of sustainable development set out at Paragraph 11 of the NPPF.
7 The Housing Delivery Test results from January 2021 highlighted that the London Borough of Enfield met 56% of its housing requirement over the last three years.
Quod | Land adjacent to Cockfosters Underground Station | Planning Statement | June 2021 105
Appendix A: Housing Design Standards Checklist
This schedule sets out a summary of the current housing standards made up of the London Plan (2021) and Housing SPG (March 2016), and LBE’s requirements set out in their DMD and Core Strategy.
Planning Report Design Standards ref. Defining Good Places Demonstrate that the built form, massing and height of the development is Design and Access 1 appropriate for the surrounding context, having considered alternative Statement (DAS) arrangements. The layout including spaces between and around buildings should form a Design and Access 2 coherent, legible and navigable pattern of streets and blocks. Statement (DAS) Supporting a Mixed Community Public Open Space Public Realm should be designed in accordance with London Plan (2021) Policy D8, and be well-designed, safe, accessible, inclusive, attractive, well-connected, related to the local and historic context and easy to 3 DAS Chapter 5 understand, service and maintain. Landscape features should be good quality and sustainable. The design should demonstrate an understanding of how people use the public realm and respond to barriers to movement. DAS Chapter 5 4 Appropriate shade, shelter and seating should be provided (Policy D8). (Sections 5.4.3, 5.4.13 and 5.4.14) Boundary treatments should not dominate the street and the height 5 DAS Section 5.4.1 should not normally exceed 1m in line with DMD Policy 8. Make appropriate play provision in accordance with DMD Policy 73 and 6 DAS Section 5.4.10 the Mayor’s Play and Informal Recreation SPG. Accessibility 90 per cent of new build housing should meet Building Regulation requirement M4(2) ‘accessible and adaptable dwellings’ with the remaining 10 per cent meeting Building Regulation requirement M4(3) DAS Chapter 6: 7 ‘wheelchair user dwellings’ (London Plan 2021 policy D5). DMD Policy 8 Inclusive Design requires 10% of all units to be wheelchair accessible or easily adapted for wheelchair users. The building as a whole and communal areas should be designed so as DAS Chapter 6: 8 not limit access or use by wheelchair users. Inclusive Design Wheelchair user dwellings should be distributed throughout a DAS Chapter 6: 9 development to provide a range of aspects, floor level locations, views Inclusive Design and unit sizes. Dwelling amenity standards Street to doorstep The arrival experience via footpaths, entrances and shared circulation 10 DAS Section 6.1.5 spaces should be comfortable, accessible and fit for purpose. There should be sufficient levels of secure, covered and accessible 11 DAS Section 6.1.4 storage for deliveries and bulky items Recycling and waste disposal and storage should be convenient in their 12 operation and location, appropriately integrated and designed to work DAS Section 6.1.4 efficiently. Internal space standards All new developments should meet the minimum space standards including storage space (DCLG. Technical housing standards – nationally 13 described space standard. 2015), London Plan 2021 standards (table DAS Section 4.3 3.1), London Housing Design Guide and table 4.1 at Appendix 4 of LBE DMD. The minimum floor to ceiling height must be 2.5m for at least 75%
Quod | Land adjacent to Cockfosters Underground Station | Planning Statement | June 2021 106
Planning Report Design Standards ref. of the GIA of each dwelling (London Plan 2021 policy D4). Areas with less than 1.5m headroom are not counted within the GIA. Housing should include adequate and easily accessible storage space for 14 the separate collection of dry recyclables and food waste as well as DAS Section 6.1.4 residual waste. Individual dwellings should be orientated to optimise opportunities for 15 DAS Chapter 3 visual interest through a range of immediate and longer-range views. Private outdoor space A minimum 5 sqm of private outdoor space for 1-2 person dwellings should be provided with an extra 1 sqm for each additional occupant 16 DAS Section 4.3.5 (Policy D6, London Plan 2021). This does not count towards internal space standards. Private amenity space should be usable and have a balance of openness DAS Section 4.3.5 and 17 and protection, appropriate for its outlook and orientation. 5.4.9 The minimum depth and width of all balconies and other private external 18 DAS Section 4.3.5 spaces should be 1500mm (London Plan 2021 Policy D6). Minimum standards for good quality private amenity space set out by DAS Section 4.3.5 and 19 DMD Policy 9 and London Plan 2021 Policy D6. 5.4.9 Communal outdoor space Communal outside amenity should provide sufficient space to meet the 20 requirements of the number of residents and be located to be appreciated DAS Chapter 5 from the inside and should be overlooked. Development should make appropriate play provision in accordance with DMD Policy 73 and the Mayor’s Play and Informal Recreation SPG and provide a minimum of 10sqm per child either on-site or within an 21 DAS Section 5.4.10 appropriate walkable distance as defined by the SPG. Communal play space provision should meet the requirements of Policy S4 (London Plan 2021) and the SPG. Home as a Place of Retreat Privacy Demonstrate how habitable rooms within each dwelling are provided with DAS Chapter 4 and 22 an adequate level of privacy in relation to neighbouring property and the section 4.3.3 street and other public spaces (table 3.2). Dual Aspect Housing should maximise the provision of dual aspect dwellings and normally avoid the provision of single aspect dwellings (Policy D6). If 23 single aspect dwellings are proposed, it must be demonstrated that the DAS Section 3.1.13 units will have good levels of ventilation, daylight and privacy will be provided to each habitable room and the kitchen (DMD Appendix 4). Daylight and sunlight Daylight and Sunlight The design should provide sufficient daylight and sunlight to new and 24 Assessment (GIA, surrounding housing that is appropriate for the context (Policy D6). June 2021) DMD Policy 10 sets standards for minimum distance between buildings in 25 DAS Section 3.1.11 new development. Noise Development Proposals must mitigate and minimise potential adverse Noise and Vibration impacts of noise on, from, within, as a result of or in the vicinity of new 26 Assessment (Atkins, development. Any adverse impacts should be controlled through good June 2021) acoustic design principles (London Plan 2021 Policy D14) Overheating Energy Strategy 27 Dwellings should avoid overheating (London Plan 2021 Policy D6). (Atkins, June 2021) Safety, Crime and Fear of Crime Protection
Quod | Land adjacent to Cockfosters Underground Station | Planning Statement | June 2021 107
Planning Report Design Standards ref. The layout should engender street based activity and provide a sense of safety, maximising active frontages onto public facing sides of a 28 development. Active frontages should be maximised, and inactive DAS Section 6.1.8 frontages minimised on the ground floor of buildings facing publicly accessible space, in order to provide natural surveillance and activity. Fire Development Proposals must achieve the highest standards of fire safety Fire Statement (Hoare 29 and incorporate features which reduce risk to life (Policy D5 and D12, Lea, June 2021) and London Plan 2021). A Fire Statement should accompany all proposals. DAS Section 6.1.6
Quod | Land adjacent to Cockfosters Underground Station | Planning Statement | June 2021 108
Appendix B: Draft Heads of Terms
Topic Scope Timescale Build to Rent 15 years 15 years from first occupation Details of affordable housing products
Affordable Proposed ranges and rent levels (London Living Rent based on LLR levels at the n/a Housing time of the planning application as a discount to the market rent) Monitoring and implementation (or financial Local Parking contribution towards the implementation of) 2 years Impact any necessary mitigation measures that are identified. Carbon Offset In accordance with the London Plan (2021) TBC payment
Quod | Land adjacent to Cockfosters Underground Station | Planning Statement | June 2021 109
Appendix C: Education Impacts
Quod | Land adjacent to Cockfosters Underground Station | Planning Statement | June 2021
Appendix C
Cockfosters Station Development – Education Impacts
1 Policy and Legislation Context 1.1 The London Borough of Enfield (LBE) Section 106 Supplementary Planning Document (SPD) sets out that LBE will seek financial contributions for education at a rate of £2,535 per dwelling regardless of unit size1 although it also acknowledges that child yields can vary according to the tenure of dwellings provided. 1.2 Planning regulations are in place to discourage the use of this kind of tariff-based approach to planning obligations and to ensure that obligations are only sought where mitigation is necessary to make a development acceptable in planning terms. Regulation 122 of the Community Infrastructure Levy Regulations (2010 as amended) sets out limitations on the use of planning obligations with which the planning authority must comply. It states:
(1) This regulation applies where a relevant determination is made which results in planning permission being granted for development.
(2) A planning obligation may only constitute a reason for granting planning permission for the development if the obligation is:
a) necessary to make the development acceptable in planning terms;
b) directly related to the development; and
c) fairly and reasonably related in scale and kind to the development. 1.3 In the context of education contributions, this means that the amount of mitigation requested should not exceed the cost of meeting the likely education demand from the development; and should be necessary to do so. If there is existing surplus capacity in education facilities that could meet this need without additional capital costs being required, this means that education obligations may not be justified under the terms of Regulation 122. Overprovision of education can also present cost and management challenges for schools and local authorities, so should be avoided for those reasons as well.
2 S106 and the Community Infrastructure Levy (CIL) 2.1 Borough CIL is levied on all residential development in Enfield (except at Meridian Water). LBE has indicated it expects to spend its CIL revenue on infrastructure at Meridian Water (repaying the Housing Infrastructure Fund (HIF) grant), public realm, open space and sustainable transport2 although there is no statutory limitation on what CIL can be spent on (provided it meets the definition of “infrastructure”) so LBE CIL revenue could be spent on education.
1 London Borough of Enfield (2016) Section 106 Supplementary Planning Document Para 9.11. 2 LBE, Infrastructure Funding Statement, 2019/20.
Quod | Land adjacent to Cockfosters Underground Station | Education Impacts | June 2021 1
3 Child yield from Development Methodology 3.1 The total population and number of children expected to live in the Proposed Development has been calculated using the GLA Population Yield Calculator (v3.2 October 2019)3. Quod has manually adjusted the age brackets to align with primary and secondary educational years. 3.2 This model estimates child yield based on PTAL and geography. For the Proposed Development a PTAL rating of 3 and 4 is assumed (the Site is located within PTAL 3 and 4). 3.3 The relevant characteristics of the Proposed Development for child yield assumptions are:
o All units are flats; o All units are Build-to-Rent o Most units are smaller units (90% 1 and 2 bedroom flats); o Adjacent to a London Underground station. 3.4 The Proposed Development is a Build-to-Rent (BtR) development. The most recent and comprehensive study of the demographics of BtR developments (undertaken by BPF, London First and UKAA)4 showed BtR developments particularly attract sharers and couples (making up a total of 71% of residents), with fewer families than the Private Rented Sector (PRS) overall – just over 10% of households in BtR were families with children, according to the study. The Mayor’s Affordable Housing and Viability SPD (2017) aligns with this, stating that, “Build to Rent schemes in these locations [edge of town centres or near transport nodes] reflect demand for new rental stock, which is much greater for one and two beds than in owner-occupied or social/ affordable rented sector5”. 3.5 Additionally, a large proportion – 79% - of residents in BtR housing were under age 34. Based on the age and household composition, it is therefore very likely that the Proposed Development will have a much lower child yield than a typical Outer London development. 3.6 Issues have been identified with the GLA Population Yield Model particularly for the geographical aggregation Outer London. The model is based on case studies and due to small sample size for Outer London of this PTAL, ‘outliers’ are prone to distort the output. 3.7 Therefore Quod has applied the assumption of ‘London’ as the geographical aggregation.
Child Yield
3.8 The Proposed Development will deliver 351 homes. All of the homes will be either market or intermediate tenures (at Discount Market Level). Note that intermediate and private tenures are treated the same in the Population Yield Calculator. The unit mix is set out in Table 3.1.
3 GLA, 2019. GLA Population Yield Calculator (v3.2). Available online: https://data.london.gov.uk/dataset/population-yield-calculator 4 BPF, London First and UKAA, 2021. Who Lives in Built to Rent? 5 GLA, 2017. Affordable Housing and Viability SPD para 4.31.
Quod | Land adjacent to Cockfosters Underground Station | Education Impacts | June 2021 2
Table 3.1 Unit mix of the Proposed Development Unit size Number of homes in private or intermediate tenures
1B 211
2B 105
3B 35
Total 351
3.9 The estimated population generated by the Proposed Development is 626. Of these, it is expected that there will be 49 children under 16. 3.10 It is estimated that there will be 20 children of primary school age (4-10), and six children of secondary school age (11-15). 23 children are estimated to be under age 4, of which a proportion may need local childcare. 3.11 These projections are gross population yields. Some families may already live in the area and may already have a place at a local school. A proportion could also be expected to go to private school. Some local authorities apply a discount to adjust for this. Because of LBE’s tariff approach, it is not clear if the local authority already makes adjustments for this. 3.12 Not all children under 4 would be expected to need a place in an early years setting and most children who do will take a part time place. In 2018, only 73% of parents of children aged 0-5 used formal childcare6. Many of those places are part time, only part of the week or part of each day which means one physical place in an early years setting can provide a part time place for more than one child. LBE’s statutory requirement to provide childcare extends to: • 15 hour per week entitlement for the most disadvantaged two-year-olds: • 15 hour per week entitlement for parents of three- and four-year-olds (the universal entitlement); • 30 hour per week entitlement for working parents of three- and four-year-olds (the extended entitlement)7. 3.13 The projected gross child yield is set out in Table 3.2.
Table 3.2 Population Yield of the Proposed Development Projected number of people
Total population yield 626
Total child yield (under 16 years) 49
6 LB Enfield, Childcare Sufficiency Assessment 2018 p. 11 7 DfE, 2018. Early education and childcare, Statutory Guidance for Local Authorities.
Quod | Land adjacent to Cockfosters Underground Station | Education Impacts | June 2021 3
Children under 4 23
Children of primary school age (age 4-10) 20
Children of Secondary school age (age 11-15) 6
Children of sixth form age (16-17) 3
* Figures do not sum due to rounding.
4 Early Years/ Childcare sufficiency 4.1 Childcare sufficiency has been reviewed qualitatively by assessing LBE’s most recent Childcare Sufficiency Assessment (2018)8. 4.2 This is the most up to date information, as comprehensive statistics about take up, provision and capacity at early years institutions is not comprehensively collected or published. 4.3 In August 2020 there were 6,826 places at Ofsted Registered Childcare Providers in Enfield9. There is no published dataset on the surplus capacity of early years settings. Provider types/settings are very mixed including private nursery schools, small scale child minders and local authority-run settings. Provision is largely market led (local authority owned/ managed settings only make up a small proportion of overall provision) although local authority funded places can be delivered by any Ofsted registered provider. 4.4 The evidence provided in the Childcare Sufficiency Assessment from 2018 and its update in 2019 does not establish a clear picture of deficiency or surplus in LBE (likely for the reasons of diversity in take-up and provision outlined above). The total population of children aged 0-5 in the borough is expected to decrease between 2019 and 2020 (Table 4 of the 2019 update). However, the assessment finds that the “South West Enfield Sub Local Authority Area” (which includes Cockfosters ward) should remain a priority for childcare planners within the borough” from the perspective of local demographics as well as planned housing growth. 4.5 Based on the GLA child yield model, there could be an estimated 23 children under age four living in the Proposed Development, a proportion of which may need a local nursery place. This is not of a scale to support provision of a dedicated early years setting.
5 Primary School 5.1 Primary schools are usually assessed within a 1km catchment. This reflects approximately 15 minutes’ walking distance and is the typical catchment within which primary provision is assessed within urban areas. However, given that a large proportion of the northern end of this catchment area is made up of open space (Trent Park) the assessment has been slightly extended.
8 LB Enfield, 2018. Childcare Sufficiency Assessment 2018. 9 Ofsted, 2020. Childcare providers and inspections. Table 1.
Quod | Land adjacent to Cockfosters Underground Station | Education Impacts | June 2021 4
5.2 The capacity calculations have been carried out using the Annual School Census data (2020)10 and Published Admission Numbers (PAN) for state-funded primary and secondary schools in LB Enfield11 and LB Barnet12 for 2019 with adjustments to take account of expansions, bulge years or admissions reductions. 5.3 LBE’s most recent school place planning strategy document was produced in 201913 and forms the evidence base for future needs. Existing Primary school capacity 5.4 There is one primary school within 1km of the Site, which is in LB Barnet. There are two further primary schools just outside the catchment area (approximately 1,050 – 1,100m from Site) which have also been considered within the assessment, one in Barnet and one in LB Enfield. Their locations are set out in Figure 4.1. Figure 4.1 - Primary Schools within 1km of the Site
10 Department for Education (2020) Schools, Pupils and their Characteristics. (Annual School Census Data, 2020). 11 LB Enfield (2018) Applying for a Primary School in Enfield September 2019 and Your Guide to Secondary Schools in Enfield September 2019 12 LB Barnet (2018) A guide to Primary Education in Barnet September 2019 and A guide to Secondary Education in Barnet September 2019. 13 Executive Director of Resources and the Executive Director of People, 2019. Update Strategy and Approach to Delivering Pupil Places.
Quod | Land adjacent to Cockfosters Underground Station | Education Impacts | June 2021 5
5.5 Based on Annual Schools Census data and Local Authority PANs, the surplus capacity across the three schools is approximately 5% (61 places) – all spare capacity is located within De Bohun Primary School, in LBE. The nearest school to the Site, Trent Church of England Primary School, is in LBB and currently has no surplus capacity. 5.6 It is standard practice to maintain a surplus capacity of 5% in schools to accommodate mid- year admissions and facilitate flexibility for parental choice and accommodate short term peaks in demand. 5.7 Table 4.1 sets out the detailed capacity of local primary schools. Table 4.1 Capacity within local primary schools as of September 2019 intake Map Current Surplus Surplus Borough School Name NOR Ref Capacity places Capacity
1 Danegrove Primary Barnet 629 630 1 0% School
2 Enfield De Bohun Primary School 360 420 60 14%
3 Trent C of E Primary Barnet 211 210 0 0% School
Total 1,200 1,260 61 5%
Demand 5.8 The primary school baseline in London has changed significantly since the last publicly available projections (although we know that LBE will be constantly monitoring this). The birth rate has peaked and in many places authorities are seeking to rationalise primary school places rather than expand provision. For LBE, previous projections on primary school demand have been revised downwards (as in much of London). As a whole the borough is expecting to have an over provision of 10 Forms of Entry (FE) by 202114. 5.9 Enfield has six primary school areas, although it is not fully clear in which the Site is located as no map is provided. Based on the descriptions is assumed to be in the “West Central” planning area (we welcome clarification from LBE on this point). Forecasting data notes that demand in this area already exceeds capacity, although notes that “the North Central Area has a surplus of places which can be offered to children in this area”. 5.10 There is strong evidence that across the borough there is overprovision of primary places and no further capital investment to primary expansion should be required at this time. Even if the surplus is located mainly in other parts of the borough, this will work its way through neighbouring areas and is likely to reduce pressure on school places in the borough generally.
14 LBE, November 2019, Update Strategy and Approach to Delivering Pupil Places 2019/20-2022-23
Quod | Land adjacent to Cockfosters Underground Station | Education Impacts | June 2021 6
6 Secondary schools 6.1 To allow for pupil choice and because older students are more willing and able to travel further to school, secondary education (for academic years 7 to 11) has been assessed at a borough wide level. Given the Site’s proximity to LB Barnet, both of these have been considered within the assessment. 6.2 It is not possible to assess sixth form and higher education capacity in this way because of the wide range of educational and workplace settings in which this takes place. 6.3 There are 20 secondary schools in LB Enfield – additionally, there are 27 in LB Barnet – a total of 47 secondary schools. Their locations are set out in Figure 4.2. Figure 4.2 Secondary schools
6.4 Table 4.2 sets out the detailed capacity of secondary schools across LB Enfield and LB Barnet. 6.5 Based on Annual Schools Census data and Local Authority PANs, the current surplus capacity at the secondary schools within LBE is 8%. The combined surplus capacity across the two boroughs is 7%. 6.6 It is standard practice to maintain a surplus capacity of at least 5% in schools to accommodate mid-year admissions, facilitate flexibility for parental choice and meet short term peaks in
Quod | Land adjacent to Cockfosters Underground Station | Education Impacts | June 2021 7
demand – an 8% surplus in LBE and 7% across the two boroughs is above this benchmark and indicate that some surplus is available. 6.7 The closest schools to the Site are Southgate School, East Barnet School, JCoSS and Ashmole Academy. These are marked in Green in Table 4.2. 6.8 There are four secondary schools in LBE that are significantly undersubscribed, of which three are rated Good by Ofsted. Aim North Academy North London opened in 2019 to replace the Nightingale school. The school currently has 318 surplus places and the academy operators have set out an ambitious plan for attainment. 6.9 Several schools have recently opened or expanded and therefore the capacities set out below do not represent the full capacity of the school in coming years. New schools and expansions (and reductions), once fully implemented, will provide an additional 1,561 places in LB Enfield (this does not include the proposed One Degree Academy, which is planned to open in 2023) and 1,601 additional places in LB Barnet. Combined, this will provide 3,162 additional school places across the two boroughs. This is based on the latest publicly available information and LBE may hold more up to date information on school admissions plans which could be shared with the applicant if relevant. Table 4.2 Secondary school capacities as of September 2019 intake Map School Name NOR Current Surplus Surplus Ref Capacity Capacity places
Enfield
E1 AIM Academy North London 582 900 318 35%
E2 Ark John Keats Academy 909 900 - 0%
E3 Aylward Academy 1,197 1,200 3 0%
E4 Bishop Stopford's School 708 930 222 24%
E5 Broomfield School** 732 1,095 363 33%
E6 Chace Community School 996 1,120 124 11%
E7 Edmonton County School 1,352 1,350 - 0%
E8 Enfield County School for Girls 903 930 27 3%
E9 Enfield Grammar School 881 900 19 2%
E10 Heron Hall Academy* 820 810 - 0%
E11 Highlands School 1,209 1,200 - 0%
E12 Kingsmead School* 1,237 1,230 - 0%
E13 Oasis Academy Enfield 759 900 141 16%
E14 Oasis Academy Hadley 870 900 30 3%
E15 Southgate School 1,238 1,250 12 1%
Quod | Land adjacent to Cockfosters Underground Station | Education Impacts | June 2021 8
Map School Name NOR Current Surplus Surplus Ref Capacity Capacity places
E16 St Anne's Catholic High School for Girls 896 900 4 0%
E17 St Ignatius College* 855 912 57 6%
E18 The Latymer School* 959 942 - 0%
E19 The Lea Valley Academy 847 1,200 353 29%
E20 Winchmore School 1,191 1,200 9 1%
N/A One Degree Academy Will take 210 children per year from 2023
N/A Wren Academy Enfield (currently at temporary Taking 240 children per year from 2020 premises adjacent to E1 – AIM Academy North London)
Total 19,141 20,769 1,682 8%
Barnet
B1 Ark Pioneer Academy* 171 180 9 5%
B2 Ashmole Academy* 1,272 1,276 4 0%
B3 Bishop Douglass School Finchley 598 900 302 34%
B4 Christ's College Finchley 640 900 260 29%
B5 Copthall School* 747 1,050 303 29%
B6 East Barnet School 1,120 1,080 - 0%
B7 Finchley Catholic High School 884 900 16 2%
B8 Friern Barnet School 787 810 23 3%
B9 Hasmonean High School for Boys 498 375 - 0%
B10 Hasmonean High School for Girls 447 375 - 0%
B11 Hendon School* 1,026 1,000 - 0%
B12 JCoSS* 992 960 - 0%
B13 London Academy 1,042 1,050 8 1%
B14 Mill Hill County High School* 1,240 1,209 - 0%
B15 Queen Elizabeth's Girls' School 900 913 13 1%
B16 Queen Elizabeth's School, Barnet 944 900 - 0%
B17 Saracens High School* 306 300 - 0%
B18 St Andrew the Apostle Greek Orthodox School 692 750 58 8%
Quod | Land adjacent to Cockfosters Underground Station | Education Impacts | June 2021 9
Map School Name NOR Current Surplus Surplus Ref Capacity Capacity places
B19 St James' Catholic High School* 986 960 - 0%
B20 St Mary's and St John's CofE School* 770 780 10 1%
B21 St Michael's Catholic Grammar School* 512 480 - 0%
B22 The Archer Academy* 787 762 - 0%
B23 The Compton School 1,051 1,050 - 0%
B24 The Henrietta Barnett School* 515 479 - 0%
B25 The Totteridge Academy 572 900 328 36%
B26 Whitefield School 652 750 98 13%
B27 Wren Academy 915 900 - 0%
Total 21,066 21,989 1,432 7%
All total 40,207 42,758 3,114 7%
* These schools have recently opened or expanded. The capacities represent capacity for 2019/20 and therefore will be lower than the capacity of the school when the expansion has worked through every year group (new schools/expansions tend to be implemented from the bottom up with each new reception year feeding through each year).
** Broomfield School reduced its capacity from 230 per year to 175 per year in 2019; and has increased it again for the September 2020 intake 6.10 When the most recent secondary school projections were published there was uncertainty about the opening time of the Wren Academy at Chase Farm, but as the school is now open, no further deficit in school places has been identified by LBE. Borough wide secondary demand will be met and exceeded by this school and the opening of the One Degree Academy (Secondary part) in September 2023. 6.11 There is currently no shortfall of secondary school places in Enfield, with two new schools having recently opened (Wren Academy) or will be opening in the near future (One Degree Academy), anticipated to exceed demand.
7 Special Educational Need provision 7.1 The S106 SPD does not refer to SEN. Across England, 14% of children have a special educational need and 9% of them require a specialist school place (which may be in a dedicated unit in mainstream setting, or in a special school) – equating to just over 1% of the total school population. At the scale of the Proposed Development and based on these estimates, the demand generated from the proposals would equate to less than one (0.49) SEN place. As such, it is not anticipated that LBE will require SEN contributions.
Quod | Land adjacent to Cockfosters Underground Station | Education Impacts | June 2021 10
110
Appendix D: Environmental Impact Assessment Screening Opinion
Quod | Land adjacent to Cockfosters Underground Station | Planning Statement | June 2021 ENVIRONMENTAL IMPACT ASSESSMENT NOT REQUIRED
Susie Byrne Please reply to: Evie Learman Ingeni Building Telephone: 02083794785 17 Broadwick Street Email: [email protected] London k W1F 0DE My ref: 19/03416/SO Date: 19 November 2019
Dear Sir/Madam
Town and Country Planning Act 1990
Town and Country Planning (Environmental Impact Assessment)(England & Wales) Regulations 2011, as amended 2015
LOCATION: Cockfosters Underground Station Cockfosters Road Barnet EN4 0DZ REFERENCE: 19/03416/SO PROPOSAL: Environmental Impact Assessment Screening Opinion Request under Part 2, Regulation 6 of the Town and Country Planning (Environmental Impact Assessment) Regulations 2017 in relation to the development of approximately 400 residential units, 600sqm commercial use, re-provision of train drivers accommodation (782 sqm); parking and associated works, including provision of local open space including replacement of existing area of designated open space.
I write in relation to the above project and your letter received 4 October 2019 in respect of a request for screening opinion on the need for an Environmental Impact Assessment, pursuant to Regulation 5 of the Town and Country Planning (Environmental Impact Assessment) Regulations 2011 (as amended) the EIA Regulations.
I have now considered your proposal and conclude the following:
1 The proposed development, although constituting a Schedule 2 Development, is not 'EIA development' and an Environmental Statement is not required in connection with any application for the redevelopment of the site as set out in the above description. This is because it is considered the development proposed will not:
(a) be of more than local importance; (b) does not involve development in a particularly environmentally sensitive or vulnerable location; (c) does not give rise to unusually complex and potentially hazardous environmental effects. (d) Moreover, there are no other relevant matters that would suggest significant adverse effects.
Thus, the proposal would not give rise to significant effects on the environment such that it would trigger the requirement for an Environmental Impact Assessment having regard to the above Regulations, Planning Practice Guidance and relevant case law.
This letter represents the Council’s formal screening opinion. However, this opinion does not in any way prejudice the Local Planning Authorities assessment of any environmental impact arising from the proposed development and does not preclude further detailed consideration of such impact when determining any planning application.
Dated: 19 November 2019
Authorised on behalf of:
Mr A Higham Head of Development Management Development Management, London Borough Enfield, PO Box 53, Civic Centre, Silver Street, Enfield, Middlesex, EN1 3XE
If you have any questions about this decision, please contact the planning officer [email protected]
List of plans and documents referred to in this Notice:
Title/Number Version TYPE
Letter from Matt Sharpe, Quod dated 03 October 2019, reference Supporting Information Q100012.AHW.001
Evie Learman Senior Planning Officer