planning report D&P/2734a/01 25 April 2016 Meridian Water Phase 1 in the London Borough of Enfield

planning application no. 16/01197/RE3

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

The proposal An outline planning application, with all matters reserved except access to the public highway. Development of Phase 1 of Meridian Water, comprising up to 725 residential units in buildings of up to 12 storeys (56m. AOD); new station building, platforms and associated interchange and drop-off facilities, including a pedestrian link across the railway; a maximum of 1,250 sq.m. retail (A1/A2/A3) floorspace; a maximum of 600 sq.m. of community (D1) floorspace; and a maximum of 750 sq.m. of leisure (D2) floorspace. Associated site infrastructure works include ground and remediation works; roads, cycle-ways and footpaths; utility works above and below ground; surface water drainage works; energy centre and associated plant; public open space and play areas; and various temporary ‘meanwhile’ uses without structures (landscaping and open space).

The applicant The applicant is the London Borough of Enfield, the planning agent is Arup and the architect is Karakusevic Carson.

Strategic issues The proposed residential-led mixed use development is strongly supported in strategic planning terms; however issues with respect to housing, affordable housing, urban design, transport, and climate change should be addressed before the application is referred back to the Mayor at decision making stage. Policies on retail and town centre uses, social infrastructure, public open space, and inclusive design are also relevant to this application.

Recommendation That Enfield Council be advised that while the application is generally acceptable in strategic planning terms, it does not yet comply with the London Plan, for the reasons set out in paragraph 97 of this report; but that the possible remedies set out in that paragraph could address these deficiencies.

page 1 Context

1 On 21 March 2016, the Mayor of London received documents from Enfield Council notifying him of a planning application of potential strategic importance to develop the above site for the above uses. Under the provisions of The Town & Country Planning (Mayor of London) Order 2008, the Mayor has until 29 April 2016 to provide the Council with a statement setting out whether he considers that the application complies with the London Plan, and his reasons for taking that view. The Mayor may also provide other comments. This report sets out information for the Mayor’s use in deciding what decision to make.

2 The application is referable under Categories 1A, 1B(c), 1C(c) and 2C of the Schedule to the Order 2008:

 1A “Development which comprises or includes the provision of more than 150 houses, flats, or houses and flats.”  1B(c) “Development (other than development which only comprises the provision of houses, flats, or houses and flats) which comprises or includes the erection of a building or buildings (c) outside Central London and with a total floorspace of more than 15,000 square metres.”  1C(c) “Development which comprises or includes the erection (c) a building of more than 30 metres high and outside the City of London.”  2C “Development to provide (d) a railway station or a tram station.”

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

4 The environmental information for the purposes of the Town and Country Planning (Environmental Impact Assessment) Regulations 2011 has been taken into account in the consideration of this case.

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

6 The site of approximately 8 hectares is an irregularly shaped piece of land in between the West Anglian Main Line (WAML) railway line and Meridian Way to the east; Leeside Road and Elm Trading Estate to the south; Kimberley Road to the west; and Ladysmith Road public open space, Angel Road (North Circular), and Pymmes Brook to the north. It lies to the west of the Lee Valley and is on the north-eastern border of LB Haringey. The site is made up of two separate parcels, with the majority to the west of the WAML, and a small parcel to the east of the WAML, associated with access arrangements to the new station. An element straddles the WAML, upon which it is proposed that the new rail station and platforms would be built. The site is within the Meridian Water Housing Zone, and the Upper Lee Valley Opportunity Area.

7 The site was previously used for gas production and housed six gasholders, which have been decommissioned and demolished. Remediation is expected to start shortly and is expected to run for approximately one year. A small area of land on the south-east boundary of the site is currently used as a Pressure Reduction Station managed by National Grid; however, this may be relocated as part of a later phase of Meridian Water development.

page 2 8 Planning permission was granted in 2015 for a new primary school on Ladysmith Road public open space adjacent to the northern boundary of the site, which will involve the relocation of the existing Meridian Angel Primary School at Dysons Road (west of the site). This involves the change of use of approximately 0.93 hectares from open space to education use.

9 More widely, to the west lies the predominantly residential area of Angel Edmonton. The Frederick Knights Sports Ground and a mix of industrial and residential uses are located to the south, with Kenninghall Open Space and a metal and waste recycling plant beyond the to the north. Angel Road Station also lies to the north, which will be decommissioned under the WAML improvements, to be replaced by the proposed Meridian Water station as part of this application. Tesco Extra and IKEA retail stores are located to the east beyond Meridian Way.

10 The highways that are used to access the site, namely Leeside Road and Willoughby Lane, are within LB Haringey. Meridian Way forms the nearest part of the Strategic Road Network (SRN). The nearest part of Transport for London Road Network (TLRN) is the A406, Angel Road (North Circular Road), which extends along the northern edge of the site. Four bus routes operate in close proximity to the site. Routes 192 and 341 are accessible from Glover Drive, approximately 200 m. to the east of the site and serving the major retail stores (Ikea and Tesco). Routes 34 and 444 are served by bus stops on the westbound on-slip of the A406 North Circular Road, on an elevated section of highway to the north of the site.

11 Hale is the nearest London Underground station, served by Victoria Line services, although it is 3 km. from the centre of the site. The nearest London Overground services are just over 1km. away at Silver Street. National Rail services are available at Angel Road station, located approximately 300 m. from the centre of the site; however those services are infrequent. The existing Angel Road Station will be replaced with a new station, proposed to be called Meridian Water, as part of this application. The site currently has a public transport accessibility level (PTAL) of 1b, which is rated as ‘very poor’, with 1a being the lowest accessibility; however, with the new rail station in place, and with four trains per hour, the PTAL is set to increase to 3.

12 The site is shown below, in relation to the wider Meridian Water Masterplan area to the east.

Site

page 3 13 The application represents the first phase of the regeneration of the wider area known as Meridian Water. The site is identified within the adopted Meridian Water Masterplan (2013) and Central Leeside Area Action Plan (AAP) Proposed Submission as within Zone 1 of the wider Meridian Water masterplan area ‘Meridian Angel’, with some elements of station access falling within Zone 2 ‘the Gateway’, as identified below.

14 Since the approval of the Meridian Water Masterplan in 2013, in response to a number of factors, the Council now has higher aspirations for the area, which have resulted in the announced review and update of the Central Leeside Area Action Plan and the proposals set out in the Council’s Local Plan Issues and Options Consultation Document (2015) to provide up to 8,000 new homes (increased from 5,000) and 3,000 new jobs within the Meridian Water boundary. As a result of these proposals, a review and update of the adopted Masterplan is currently taking place, which will provide for greater housing provision across the masterplan area.

Details of the proposal

15 This application is for outline permission, with all matters reserved except access to the public highway. Up to 725 residential units are proposed in buildings of up to 12 storeys (56m. AOD), and supporting retail and community uses in five development zones (A to E), with an additional development zone for the station (F). In addition to residential land uses, the proposal includes:  Up to 1,250 sq.m. of retail (A1/A2) floorspace;  A community centre (up to 600 sq.m.);  Up to 750 sq.m. of leisure (D2) floorspace;  A new station, including platforms and associated access;  A new pedestrian link, with 24 hour access across the railway line;  Car and cycle parking;  A minimum of 0.95 ha of public open space in six spaces across the site (Northern Community Park; the Southern Community Park; Brook Community Park adjacent to

page 4 Pymmes Brook; the Western Station Square; the Eastern Station Square; and a local play space to the rear of Kimberley Road), including a minimum 0.43 ha of public play space;  Up to 12,400 sq.m. of temporary ‘meanwhile’ uses (e.g. tree nursery), comprising vacant land to be subsequently developed through future planning applications;  Site infrastructure works, including ground and remediation works;  Roads, cycle-ways and footpaths;  Utility works above and below ground;  An energy centre, which will facilitate a future connection to the Lee Valley Heat Network.

16 Detailed designs for the individual development plots and internal road layouts will be submitted as part of Reserved Matters applications, which will come forward subsequent to this application. Internal road and infrastructure layouts may come forward as Reserved Matters applications separate to the individual development plots. The main vehicular access to Phase 1 is from Leeside Road, to the south of the site, which is owned and maintained by the LB Haringey. The proposed works to Leeside Road are excluded from the red line boundary for the planning application, and will be brought forward separately. The public realm and land use parameter plan is shown below.

17 This is the first in a series of phases as part of the wider Meridian Water proposed development. The Council considered it necessary to bring the application forward at this early stage to ensure that new development is integrated with existing communities to the west, particularly on Kimberley Road. In addition, the proposed station is expected to act as a catalyst for Meridian Water’s regeneration, supported by expected enhancements to the WAML railway. A new third track between Stratford and Angel Road has been approved, with

page 5 completion due in 2018, which will enable new services to run along this corridor, with the aspiration to deliver a minimum of four trains per hour at each station on the London element of the line. This capacity enhancement will support the delivery of the new Meridian Water station in 2018, which makes up part of this application.

18 The applicant is currently undertaking a competitive procurement exercise to appoint a development partner for the delivery of the proposal, which will be announced before the granting of consent. Once the development partner is selected it will complete the planning and development process working in partnership with the applicant and the local planning authority. It is expected that the Reserved Matters applications for the individual development plots will come forward from summer 2016, with construction of the first development plots commencing in late 2016. Housing Zone funding received requires the delivery of a number of homes for occupation by 2018.

Case history

19 On 16 November 2015, a pre-application meeting was held at City Hall for a hybrid planning application. Detailed planning permission was expected for site infrastructure works, including ground and remediation works; roads, cycle-ways and footpaths; utility works above and below ground; surface water drainage and public open space/play space; and various temporary meanwhile uses (car parking, open space, planting). Outline planning permission with all matters reserved was expected for circa 700 residential units; 1,250 sq.m. of A1-A3 uses; 1,500 sq.m. of B1 uses; 600 sq.m. of D1 uses; and 750 sq.m. of D2 uses.

20 The GLA’s pre-application advice report of 30 November 2015 concluded that the residential-led mixed use redevelopment was strongly supported, in accordance with London Plan policies, the Upper Lee Valley OAPF and the Meridian Water Masterplan. The masterplanning principles suggested were welcomed, with further refinement expected as the scheme moved forward. Further discussions were suggested in relation to viability and affordable housing, detailed design matters, public realm, transport, energy and inclusive design. Comments were subsequently provided on the draft design code.

Strategic planning issues and relevant policies and guidance

21 The relevant issues and corresponding policies are as follows:

 Housing London Plan; Housing SPG; Housing Strategy; Shaping Neighbourhoods: Play and Informal Recreation SPG; Shaping Neighbourhoods: Character and Context SPG  Retail/town centre uses London Plan; Town Centres SPG  Social infrastructure London Plan; Social Infrastructure SPG; Health Inequalities Strategy  Affordable housing London Plan; Housing SPG; draft interim SPG; Housing Strategy; draft Revised Housing Strategy  Density London Plan; Housing SPG  Urban design London Plan; Shaping Neighbourhoods: Character and Context SPG; Housing SPG; Shaping Neighbourhoods: Play and Informal Recreation SPG  Inclusive design London Plan; Accessible London: achieving an inclusive environment SPG  Transport London Plan; the Mayor’s Transport Strategy; Land for Industry and Transport SPG

page 6  Parking London Plan; the Mayor’s Transport Strategy  London Plan; Mayoral Community Infrastructure Levy; Use of planning obligations in the funding of Crossrail and the Mayoral Community infrastructure levy SPG  Climate change London Plan; Sustainable Design and Construction SPG; Mayor’s Climate Change Adaptation Strategy; Mayor’s Climate Change Mitigation and Energy Strategy; Mayor’s Water Strategy

22 For the purposes of Section 38(6) of the Planning and Compulsory Purchase Act 2004, the development plan in force for the area is the Enfield Core Strategy (2010), Enfield Development Management Policies (2014), and the 2016 London Plan (Consolidated with Alterations since 2011).

23 The following are also relevant material considerations:  National Planning Policy Framework, Technical Guide to the National Planning Policy Framework and National Planning Practice Guidance.  Upper Lee Valley Opportunity Area Planning Framework (2013).  Enfield Council’s Local Plan Issues and Options Consultation Document (2015).  Enfield Council’s Central Leeside Action Plan Proposed Submission (2015).  Meridian Water Masterplan (2013).

Principle of development

24 As stated above, the site was previously used for gas production and housed six gasholders, which have been decommissioned and demolished, and remediation is expected to start shortly. It is not subject to any industrial use designations.

Residential

25 The site lies within the Upper Lee Valley Opportunity Area, as identified in London Plan Policy 2.13, Table A1.1, and the Upper Lee Valley Opportunity Area Planning Framework (2013), which states that the Opportunity Area is capable of accommodating at least 20,100 homes and 15,000 jobs up to 2031. London Plan Policy 3.3 ‘Increasing Housing Supply’ recognises the pressing need for new homes in London and Table 3.1 gives an annual monitoring target of 798 new homes per year in Enfield between 2015 and 2025.

26 The site is located in the Meridian Water Masterplan area, comprising a major part of Zone 1 and a small part of Zone 2. It is also within the Central Leeside Area Action Plan Proposed Submission (AAP) area. Both documents seek to deliver up to 5,000 new homes and 3,000 new jobs across the area, although Enfield Council’s aspiration to increase housing delivery to over 8,000 is noted and supported in principle. The Masterplan identifies Zone 1 as a continuation of surrounding residential uses, at relatively high densities, with the opportunity to provide employment as a buffer to the North Circular.

27 The residential proposals would contribute to these targets and are supported.

Retail and town centre uses

28 London Plan Policy 2.15 ‘Town Centres’ promotes town centres as the main focus for commercial development and intensification, including residential development. Policy 4.7 ‘Retail and Town Centre Development’ requires that retail, commercial, culture and leisure development should be focused on sites within town centres, or if no in-centre sites are

page 7 available, on sites on the edges of centres that are, or can be, well integrated with the existing centre and public transport (the sequential test). The NPPF defines edge of centre as within 300m. of a town centre boundary. Furthermore, Policy 4.7 requires proposals for new, or extensions to existing, edge or out of centre development to be subject to an assessment of impact.

29 Policies set out in the AAP and Meridian Water Masterplan provide for 2,000 sq.m. of retail floorspace as part of Meridian Water local centre, to the east of the site; however it is accepted that additional retail space is likely to be required in reflection of the expected increase in unit numbers from 5,000 to 8,000. No retail floorspace is allocated in the Masterplan for Zone 1, although it is not precluded and the Masterplan accepts that different layouts may be appropriate.

30 Retail, food & drink (up to 1,250 sq.m.) and leisure (up to 750 sq.m.) uses are proposed around the Western Station Square in plots B and D, with the potential for small retail spaces on plots A and C along the proposed north-south street. A Retail Impact Assessment (RIA) has been submitted, which assesses the likely impacts of increased provision of an additional 1,250 sq.m. of retail space, in addition to the proposed 2,000 sq.m. provided for in the AAP and the Masterplan within the future local centre. The RIA finds a current undersupply of ‘top-up’ convenience facilities and local retail services in the vicinity of the site. The proposed 1,250 sqm of retail floorspace currently occupies an ‘out-of-centre’ location in retail policy terms, being more than 300m. from the nearest town centre; although on development of the local centre in later phases, this floorspace will occupy an edge of centre location and will be well-connected to the local centre and to public transport, as required by Policy 4.7.

31 It is accepted that the Western Station Square is a desirable location to allocate additional retail floorspace above that set out in the AAP and the Masterplan, providing active uses, and contributing to job targets. It is also acknowledged that as this is the first phase of development at Meridian Water, a certain amount of supporting uses are needed to accompany the 725 residential units proposed and the provision of commercial and leisure uses on this site will also help to foster a sense of community. The applicant also cites consultation with existing communities around the site, which highlighted strong positive support for retail provision on the site. These uses are supported in line with Policy 2.15 and 4.7.

Social infrastructure

32 London Plan Policies 3.16 ‘Protection and Enhancement of Social Infrastructure’ and 3.17 ‘Health and Social Care Facilities’ support proposals that provide high quality health facilities in areas of identified need, particularly in places easily accessible by public transport, cycling and walking. Policy 3.16 also supports the provision of community uses.

33 Community uses (up to 600 sq.m.) are proposed in the north of plot A, adjacent to the proposed new Meridian Angel Primary School and close to existing communities. An assessment of the need for community centre provision in the vicinity of the site highlights that capacity is an issue in the local area and the provision of this space is supported in line with Policy 3.16.

34 The assessment also considered the need for additional health services, and concluded that there is capacity within existing health care provision to cater for the increased demand from the site. The AAP sets out that Meridian Water will provide community and health facilities, with specific reference to a health centre. Work is currently being undertaken to consider future needs and provision, and it is likely that future phases of Meridian Water will provide health facilities. This approach is supported.

page 8 35 The NPPF gives the highest level of national policy support for school provision and London Plan Policy 3.18 ‘Education Facilities’ supports enhanced new build provision, in particular to address the current shortage of primary school places.

36 The assessment of education capacity and impacts is provided in the applicant’s socio- economic assessment, which forms part of the Environmental Impact Assessment. As stated above, planning permission has been granted for a new primary school at Ladysmith Road, adjacent to the site, which involves the relocation of the existing Meridian Angel Primary School and its increase from one form entry to two from entry. As a result, no additional provision is proposed.

37 With regard to secondary school places, the assessment finds evidence of surplus school capacity in secondary schools across the borough, and in proximity to the site, as well as in the neighbouring borough of Haringey. It is therefore considered, that the relatively small yield of secondary school pupils generated on this site will be catered for within the existing provision, and no additional provision is required. The assessment finds that there may be a requirement at later stages of the wider Meridian Water Masterplan and the Council’s Core Strategy identifies two new two form entry primary schools, and one new six form entry secondary school in later phases. Work is currently being undertaken to revise the education requirements and policy relating to future phases of Meridian Water, in line with revisions to the AAP.

38 This approach is supported, in line with Policy 3.18.

Public open space and meanwhile uses

39 London Plan Policy 7.18 ‘Protecting Open Space and Addressing Deficiency’ provides a strategic aim to address areas with a deficiency of open space. Although the site is not in an area with a deficiency of open space, the application secures a minimum of 0.95 ha of public open space, to be delivered in the form of 6 spaces, made up of the Northern Community Park; the Southern Community Park; Brook Community Park, adjacent to Pymmes Brook; the Western Station Square; the Eastern Station Square; and a local play space to the rear of Kimberley Road. Although the amount is below the Local Plan requirement for open space provision in relation to the expected population for the site, the proposal is of a higher density than is typical for the Borough and the open space proposed will be in close proximity to residents. The role of the open space in providing east-west linkages to existing residential areas in Kimberley Road and via the proposed ‘Causeway’ to the Lee Valley Regional Park to the east are also recognised. The proposed level of public open space is supported in line with London Plan policy and promoted in the OAPF.

40 The application seeks permission for three ‘meanwhile use’ plots of up to 12,400 sq.m. for landscaping purposes, including a tree nursery. It is not proposed that these spaces will be publicly accessible. In the longer term, these are future development plots that will be brought forward for residential-led development, potentially with some employment uses, through Reserved Matters applications. This approach is supported.

41 Overall, the proposed mix of uses is acceptable, in accordance with the London Plan, the Upper Lee Valley OAPF, and the Meridian Water Masterplan.

Housing

42 The application requires that the tenure mix of any Reserved Matters application should conform to the figures below:

page 9

3 bed + Total Affordable Min 25% 30% (min 25%) Market 70% Total 725 units

Affordable housing

43 London Plan Policy 3.9 ‘Mixed and Balanced Communities’ seeks to promote mixed and balanced communities by tenure and household income. Policy 3.12 ‘Negotiating Affordable Housing’ seeks to secure the maximum reasonable amount of affordable housing. The Council seeks to provide 40% of new housing as affordable.

44 The application aims to provide 30% affordable housing provision, with a minimum of 25%, dependent upon the final mix of affordable rented and intermediate housing. It is proposed that a range of tenures will be provided, including affordable rented and intermediate housing, as well as the potential for Starter Homes, dependent on the outcome of the Housing and Planning Bill 2016. Private Rented Sector (PRS) housing may also be provided. The illustrative scheme submitted as part of the application demonstrates achievement of a 70:30 ratio of market to affordable housing provision, which has been tested through the design process both for viability and design feasibility.

45 The inclusion of affordable and market housing on the same site is strongly supported in accordance with Policy 3.9. As required by London Plan Policy 3.12, the applicant has submitted an Affordable Housing Viability Assessment and the local planning authority should provide GLA officers with their independent assessment of this prior to the referral of any Stage Two application, in order to confirm that the proposal will provide the maximum reasonable amount of affordable housing in accordance with London Plan Policy 3.12.

46 Private rented sector (PRS) tenure is supported by London Plan Policy 3.8 ‘Housing Choice’. The applicant and the local planning authority should note the guidance provided in section 3.3 of the Housing SPG, in particular paragraph 3.3.7, which states that ‘clawback’ mechanisms should be included as part of the planning permission to recoup any loss if the market homes are sold out of the long term PRS market and to ensure schemes deliver the maximum reasonable level of affordable housing in line with Policy 3.12. Paragraph 3.3.10 of the Housing SPG also recognises that discounted market rent (DMR) could be used as the affordable housing offer, for example where viability appraisals show that covenanted PRS cannot support affordable or social rented units. However, to be considered as intermediate affordable housing, the DMR units must meet the NPPF definition of intermediate housing, and be affordable to those eligible for intermediate housing in London.

47 London Plan Policy 3.11 ‘Affordable Housing Targets’ sets out a strategic target for the affordable units to be split 60%:40% between social/affordable rent and intermediate tenures. The application states that it may not be possible to achieve these policy requirements; however this is subject to confirmation of the viability assessment review.

48 As the development will be phased, GLA officers would normally expect there to be a review mechanism built into the section 106 agreement to enable later phases or sub-phases to include more affordable housing, should viability improve. The minimum level of affordable housing will also need to be secured in the section 106 agreement. As Enfield Council is both the applicant and the local planning authority, it should be clarified how the section 106 agreement will be structured.

page 10 Housing choice

49 London Plan Policy 3.8 ‘Housing Choice’ encourages a choice of housing based on local needs, while affordable family housing is stated as a strategic priority. The Council’s Local Plan gives targets for market housing of 20% one and two bed flats, 15% two bed houses, 45% three bed houses, 20% four-plus bed houses; and for social rented housing of 20% one and two bed units (1-3 persons), 20% two bed units (4 persons), 30% three bed units, and 30% four-plus bed units. The applicant states that it is unlikely that the policy aspirations for larger units will be met and that details of bedroom mix will comes forward as part of future Reserved Matters applications; however, there is an expectation for around 25% family-sized units and a minimum of 25% affordable family-sized units. The applicant cites evidence that the requirements within the Local Plan do not wholly reflect current housing needs, and that demographic trends and market demand in Enfield have changed to reflect a growing demand for smaller units.

50 The applicant states that further discussion (including confirmation from the Council’s housing team) is necessary in order to define appropriate parameters for the proposed mix, which reflect local needs and the Council’s housing requirements. Once this is determined, there should be a mechanism within the outline permission to ensure that housing is delivered broadly in accordance with the target mix.

Density

51 London Plan Policy 3.4 ‘Optimising Housing Potential’ states that taking into account local context and character, the design principles in Chapter 7 and public transport capacity, development should optimise housing output within the relevant density range shown in Table 3.2. At the present time, it is difficult to categorise the site and the future PTAL rating is uncertain, although a PTAL of 3 is expected to be achievable. Taking account of new transport links and the new development expected to come forward, the site could be considered to be within an ‘urban’ setting in the future, where the density matrix sets a guideline of 45-170 units per hectare with a PTAL of 2-3, although the London Plan notes that these ranges should not be applied mechanistically.

52 The density proposed is calculated as approximately 154 units per hectare, based on 725 units across 4.7 hectares, which excludes the areas that will be landscaped for meanwhile uses. This provides a reasonable estimate of the density of the proposed scheme and is considered acceptable as it is comfortably within the London Plan density range. As discussed below, no concerns are raised with regards to scale and massing and the generous provision of public open space is also acknowledged. The application makes reference to potential higher densities were Crossrail 2 to go ahead, which is supported.

Children’s play space

53 Policy 3.6 of the London Plan seeks to ensure that development proposals include suitable provision for play and recreation. Further detail is provided in the Mayor’s ‘Shaping Neighbourhoods: Play and Informal Recreation’ SPG, which sets a benchmark of 10 sq.m. of useable child play space to be provided per child, with under-5 child play space provided on-site as a minimum. At pre-application stage, the applicant was advised that given the amount of development expected to come forward across Meridian Water and the extent of open space proposed, there will be an expectation that play space requirements for all age groups will be met as part of the application.

54 The application states that based on the GLA child population calculator, a total of 0.43 hectares of play space would be required. The applicant should clarify the basis of this calculation in terms if unit sizes and tenures, which is not set out in the application materials.

page 11 Notwithstanding the uncertainty over the basis of calculation, the application indicates that all of this will be provided in the residential courtyards and public spaces across the site, including both formal and informal play areas. However, the Design Code only states that a minimum of 100 sq.m. of doorstep play will be provided in communal courtyards and local equipped play spaces should have a minimum area of 400 sq.m. and the parameter plans do not indicate minimum areas for play space. The applicant should clarify how the required level of play space is to be secured, and a commitment to meet the requirements of the Mayor’s SPG should also be provided.

Urban design

55 Good design is central to all objectives of the London Plan and is specifically promoted by the policies contained within chapter seven, which address both general design principles and specific design issues. London Plan Policy 7.1 sets out a series of overarching design principles for development in London. Other design polices in this chapter and elsewhere in the London Plan include specific design requirements relating to maximising the potential of sites, the quality of new housing provision, tall and large-scale buildings, built heritage, views, and the public realm. New development is also required to have regard to its context, and make a positive contribution to local character within its neighbourhood (Policy 7.4).

56 Due to the outline nature of the application, a series of parameter and illustrative plans are included in the application, together with a Design Code, which provides a framework for design against which future Reserved Matters applications will be assessed and be required to accord with. The Design Code sets out a series of design principles, including urban grain and street alignment; distribution of non-residential uses; parking; privacy; heights and setbacks; minimum unit sizes and design guidelines; access arrangements; public realm location, character and materiality; building appearance and architecture; and balcony design. The Design and Access Statement also includes an illustrative scheme in line with the parameters and Design Code.

Layout and public realm

57 The overall approach to layout is strongly supported and the application responds well to concerns raised at pre-application stage. The proposals consist of a legible network of streets that link well with surrounding streets and are well addressed with active frontages, either by the commercial uses or by apartments, terraced houses, and maisonettes with individual street entrances. The focus of the application on plots around the new station and adjacent to existing residential areas to the west is a logical approach which will exploit the benefits of the station and embed the development into the existing community. Similarly, the location of meanwhile use areas around the Pressure Reduction Station reflects the aspiration to relocate this at a later stage.

58 The Design Code secures active frontages of 90% for the Western Station Square and the north-south route, 80% for park frontages, and 75% for neighbourhood roads. Parking, with integral service access, will be concealed below podiums and the extent of this frontage is also controlled in the Design Code. Perimeter treatments to the meanwhile use areas will use integrated planting and level changes, such as a ‘ha-ha’, in order to maintain visual connection whilst restricting access.

59 The Design Code also secures the quality of the proposed public realm, including a network of six new public open spaces. Concerns raised at pre-application stage about the quality of the Western Station Square have been resolved, and the space is now enlivened by a playable water feature, groups of tree planting, seating, and surrounding active uses.

page 12 Residential quality

60 The application confirms that the proposed housing typologies meet or exceed the minimum space standards identified in the London Plan. The Design Code secures that at least 60% of the units will be dual aspect. The site’s orientation means that some single aspect north-facing units are unavoidable; however the Design Code secures that these will be less than 2% of the units and will always face onto a large open space. All single aspect units will be less than 7 metres in depth, with none facing the railway line. No more than eight units will be accessed per core and all corridors will be naturally lit, with a minimum width of 1.5 metres. The ground floor residential units will achieve a minimum of 2.8 metres floor to ceiling height, other than those blocks immediately adjacent to existing residential streets. The applicant should consider including a requirement that floor to ceiling heights will achieve a minimum floor to ceiling height of 2.5 metres in order to secure a good standard of ventilation and light, although the requirement for habitable rooms to meet BRE Average Daylight Factor requirements is recognised and welcomed.

Height and massing

61 The scale of the proposed development plots respond well to the existing context of the area. To the west, the proposed blocks adjacent to existing development on Kimberley Road and Willoughby Lane are 2-3 storeys in height and align with the existing streets. The proposed north-south terrace behind Kimberley Road is mainly of 2-4 storeys, with some 6 storey elements to the south, which appropriately mark to entrance to the site. The four perimeter blocks to the east are not in close proximity to any existing development and are generally of up to 8 storeys, each having a taller element of up to 12 storeys, which the Design Code limits to key routes and public open public spaces, taking account of wind and overshadowing impacts. The Design Code also requires the east-west blocks, including those enclosing the Western Station Square to incorporate at least one 11m. break, which will avoid overbearing massing and allow sunlight into spaces to the north.

62 The overall approach to the height and massing is supported.

Architecture and materials

63 As an outline application with all matters reserved except access to the public highway, limited detail is provided on architecture and materials; however the Design Code provides sufficient information to ensure that a good quality of architecture, materials and detailing will be achieved. This is demonstrated further in the applicant’s illustrative proposals. The Design Code secures that materials will be of brick and masonry, with no render or panel treatments on primary facades, and trim and detailing will be of metal not plastic. The Code also secures details such as a minimum of 210mm window reveals, rooftop services to be hidden, solid drained balcony floors, and all drainage and downpipes to be hidden, which indicate a good quality of detailing will be achieved. GLA officers strongly encourage the local planning authority to consider securing retention of the architect through to delivery.

Inclusive design

64 The aim of London Plan Policy 7.2 ‘An Inclusive Environment’ is to ensure that proposals achieve the highest standards of accessibility and inclusion (not just the minimum). Inclusive design principles, if embedded into the development and design process from the outset, help to ensure that all, including older people, disabled and Deaf people, children and young people, can use the places and spaces proposed comfortably, safely and with dignity.

page 13 65 The site does not pose any particular challenges for inclusive assess, other than the existing railway line. Pedestrian access across the railway line is committed to as part of this application, providing 24-hour access for pedestrians and cyclists, including lift access, which is welcomed.

66 Policy 3.8 ‘Housing Choice’ requires that ninety percent of new housing meets Building Regulation requirement M4(2) ‘accessible and adaptable dwellings’ and ten per cent of new housing meets Building Regulation requirement M4(3) ‘wheelchair user dwellings’, that is, designed to be wheelchair accessible or easily adaptable for residents who are wheelchair users. The application indicates that all of the units have been designed to meet Building Regulation requirement M4(2) and 10% will meet Building Regulation M4(3). Indicative layouts have been provided for the wheelchair accessible units. The Council should secure M4(2) and M4(3) requirements by condition.

Transport

Transport Assessment, Trip generation and modelling assumptions

67 The Transport Assessment (TA) takes a strategic multi-modal approach to help inform planning decisions on Phase 1, which explains how the current phase will work as a standalone development, as well as the wider area in the longer term. The modal spilt used to estimate trip generation is not considered to be sufficiently representative, and the applicant should consider spatial data from the Census and/or other data sources.

Strategic transport assessment

68 TfL has requested a strategic transport assessment in order to understand the wider strategic implications, to plan for them in subsequent phases, and to ensure that the current proposals do not fetter the ability to deliver transport links in the area in the longer term. This is particularly important as Phase 1 includes the site of the new rail station, which will be subject to further enhancement related to rail upgrades and eventually Crossrail 2. Discussions are ongoing with Enfield Council in this regard, as the modelling has implications for the future operation of highways within both LB Haringey and LB Enfield and is informed by emerging proposals for the wider Masterplan.

Car parking

69 The proposed parking ratio of 0.4 spaces per residential unit is considered reasonable. This restrained approach should be promoted to potential residents and the wider community through measures such as car clubs, which will enable car free urban realm, provide support for public transport improvements, and reduce any overspill effects.

Cycle parking and cycle network

70 The level of proposed cycling parking is supported, in line with London Plan standards. The design of access to cycle parking and of cycle parking in the public realm should be based on TfL’s London Cycle Design Standards.

71 The predicted level of cycling trips is reasonable; however it is suggested that for later phases the proportion will increase significantly, creating destinations for residents within cycling distance, which may require an enhanced cycling offer on this site. The proposed pedestrian/cycle link to the east over the rail line does not currently meet the desired standard,

page 14 and it is suggested that a step-free/no dismount is design solution is needed. The applicant should discuss this with TfL.

Bus network and infrastructure

72 Contrary to the statement in Section 4.4 of the TA, bus services will need to be upgraded to support the development of Phase 1, including the provision of bus stops on the loop road east of the station, and the provision of two new bus stops on Leeside Road. Within this phase, the early delivery of the pedestrian/cycle route (with lifts) over the rail line to the Glover Drive stops is supported. Due to the importance of this link, a condition is requested limiting first occupation of Phase 1 until the pedestrian/cycle link is committed. Should the improvements to the bus stops on Glover Drive proposed in later phases of the Meridian Water Masterplan take longer than two years after first occupation of Phase 1, an interim bus upgrade scheme will be necessary. Furthermore, the introduction of 4 trains per hour is expected in 2018, although to mitigate against the risk of delay, the applicant should bring forward bus route changes from later phases of the wider transport strategy.

Meridian Water Masterplan bus strategy

73 In discussion with TfL, the longer term bus strategy for the wider site is still emerging and will be subject to ongoing review as the wider Meridian Water Masterplan is implemented. It relies on delivery of the ‘Causeway’, which includes an east-west bus route connecting to the Eastern Station Square within Phase 1. On the wider network, there will be a need to provide bus priority to support the strategy.

74 For Phase 1, the emerging strategy has identified a need to provide an additional bus service to Seven Sisters London Underground Station, which involves changes to routes 341 and 476. The estimated cost is £240,000 per annum and 5 years funding is requested to be secured through the section 106 agreement. The ability to turn buses at Glover Drive would need to be maintained. As indicated above, the trigger point for this depends on the timing of rail improvements.

75 For later phases, major route changes and enhancement could be introduced as part of the Causeway project, although elements of these changes could be brought forward using Glover Drive to turn buses. The cost of the next stage of bus works is circa £1.2 million per annum and TfL would seek five year funding to pump prime these changes.

Pedestrian network

76 The PERS audit shows that pedestrian routes surrounding the site are a mixture of good and average quality. No link was identified as sub-standard; however the lack of footway provision on the northern side of Leeside Road is highlighted as a safety issue for pedestrians and is particularly relevant to Phase 1. It is also noted that the wider highway network represents a significant severance issue; however for the A406, no measures are proposed to help improve the pedestrian environment or reduce its severance effect. The applicant should clarify how this will be addressed in relation to both Phase 1 and in the longer term.

Highway assessment

77 The applicant should confirm that no works or piling will impact on A406 structures.

78 The additional bus stops required should be designed in accordance with TfL’s Bus Stop Accessibility Guidance and considered by the highway authority.

page 15

79 The modelling results show that Meridian Way junctions will be operating over capacity and the proposed solution is implementation of SCOOT. This should have significant benefits; however it is unsafe and undesirable to have junctions operating over capacity, particularly given that this is the first phase of a long term transport strategy for the area. The applicant should discuss this further with TfL.

Highway safety review

80 The TA indicates that most of the highway safety concerns can be addressed via softer measures; however this may not be sufficient as the proposals will in effect create a new residential community next to the A406. The applicant should consider the need for measures to improve the physical environment, legibility, security and future safety of residents.

Crossrail 2

81 In order to support the development of Crossrail 2, work is underway to identify potential sites along the route where development could be intensified or different land-uses implemented. As part of this work, this site has been identified as a potential location for high density housing in the future. The submitted documentation makes reference to the potential for higher development densities to be implemented were Crossrail 2 to go ahead, which is supported.

Freight

82 A draft construction logistics plan and draft delivery and servicing plan would normally be expected as part of the TA, although the frameworks provided are acceptable in this instance. The final versions should be secured by condition. During the construction phase, the applicant should confirm that no works will impact on the operation of the local bus network or the A406.

Community Infrastructure Levy (CIL)

83 The Mayor has introduced a London-wide Community Infrastructure Levy (CIL) to help implement the London Plan, particularly policies 6.5 and 8.3 towards the funding of Crossrail. The rate for the borough of Enfield is £20 per square metre.

Climate change

Energy

84 A range of passive design features and demand reduction measures are proposed to reduce the carbon emissions of the proposal. Both air permeability and heat loss parameters will be improved beyond the minimum backstop values required by building regulations. Other features include active building thermal controls and variable speed drives on pumps and fans where appropriate.

85 In order to limit the overheating risk during summer, the facade design is currently being developed to determine the optimum glazing ratios while at the same time achieving the required levels of daylighting in the apartments. The demand for cooling will be minimised through high efficiency heat recovery from ventilation systems. Given the outline form of the application and the absence of a fixed design, the strategy is accepted; however evidence of how Policy 5.9 has been addressed to avoid overheating and minimise cooling demand should be provided at Reserved Matters Stage and this should be secured by condition.

page 16

86 The development is estimated to achieve a reduction of 10 tonnes per annum (1%) in regulated CO2 emissions from this first stage of the energy hierarchy (‘Be Lean’), compared to a 2013 Building Regulations compliant development.

87 The applicant has identified that the Lee Valley Heat Network (LVHN) is within the vicinity of the development and is proposing to connect. The applicant has provided information on the LVHN’s carbon intensity and has demonstrated that a connection agreement has been received.

88 A reduction in regulated CO2 emissions of 656 tonnes per annum (46%) will be achieved through this second part of the energy hierarchy (‘Be Clean’). However, the applicant should provide further information to demonstrate how the savings from connection to the LVHN have been calculated, including the site’s anticipated space heating and domestic hot water demand, as well as any rationale behind the savings’ analysis.

89 The applicant has investigated the feasibility of a range of renewable energy technologies and is proposing to install 345 sq.m. of photovoltaic (PV) panels on the Phase1 development. The applicant has stated that an estimated 98 MWh/year of renewable energy will be generated; however this is considered high for the area of PV proposed. The applicant should confirm the net area of PV panels proposed and explain the methodology used in order to calculate the electricity generated, including the estimated panel efficiency etc.

90 A reduction in regulated CO2 emissions of 51 tonnes per annum (4%) will be achieved through this third element of the energy hierarchy (‘Be Green’).

91 Based on the energy assessment submitted, a reduction of 717 tonnes of CO2 per year in regulated emissions is expected, compared to a 2013 Building Regulations compliant development, equivalent to an overall saving of 50%. The carbon dioxide savings exceed the target set within Policy 5.2 of the London Plan; however, the comments above should be addressed before compliance with London Plan energy policy can be verified.

Climate change adaptation and flooding

92 A Flood Risk Assessment (FRA) has been provided, which confirms that the site is within Flood Zone 2 and contains some areas of low surface water flood risk. The FRA confirms that the site is protected to a high degree against flooding, but that there is a residual risk of flooding in the 1 in 100 year plus climate change event. The majority of the proposed buildings will be constructed with finished floor levels 300-600 mm above the modelled flood level. Where this is not possible due to existing street levels, flood resilient/resistant construction will be investigated. The FRA also confirms that compensatory flood storage will be provided, the majority of this being in sub-surface crates underneath open space within the development. A flood emergency plan is also proposed for the site. Given the nature of the risk, the flood risk mitigation proposals are an acceptable response and the proposals are considered to comply with London Plan Policy 5:12 ‘Flood Risk Management’.

93 There are surface water risks affecting the site within the local vicinity, and therefore it is important that the proposal fully complies with London Plan Policy 5:13 ‘Sustainable Drainage’, in order to manage and reduce surface water run-off. The FRA states that the site will achieve a greenfield run-off rate up to a 1 in 100 year storm, which will be achieved by applying surface water attenuation at 14 points across the development and by using green infrastructure and green/blue roofs. The residual surface water will be released to the adjacent Pymmes Brook at greenfield rates, via an existing surface water sewer. This is acceptable in terms of London Plan

page 17 Policy 5:13; however, a suitable planning condition should be applied to any planning permission, requiring details of a sustainable drainage regime to be submitted and approved by the local planning authority, in consultation with the Borough’s Lead Local Flood Authority.

Local planning authority’s position

94 The local planning authority’s position is not yet known. Legal considerations

95 Under the arrangements set out in Article 4 of the Town and Country Planning (Mayor of London) Order 2008, the Mayor is required to provide the local planning authority with a statement setting out whether he considers that the application complies with the London Plan, and his reasons for taking that view. Unless notified otherwise by the Mayor, the Council must consult the Mayor again under Article 5 of the Order if it subsequently resolves to make a draft decision on the application, in order that the Mayor may decide whether to allow the draft decision to proceed unchanged, or direct the Council under Article 6 of the Order to refuse the application, or issue a direction under Article 7 of the Order that he is to act as the local planning authority for the purpose of determining the application and any connected application. There is no obligation at this present stage for the Mayor to indicate his intentions regarding a possible direction, and no such decision should be inferred from the Mayor’s statement and comments. Financial considerations

96 There are no financial considerations at this stage. Conclusion

97 London Plan policies on retail and town centre uses, social infrastructure, public open space, housing, affordable housing, urban design, inclusive design, transport and climate change are relevant to this application. The application complies with some of these policies but not with others, for the following reasons:  Retail and town centre uses: The proposed retail and town centre uses are supported in line with London Plan Policies 2.15 and 4.7.  Social infrastructure: The proposed social infrastructure is supported in line with London Plan Policies 3.16, 3.17, and 3.18.  Public open space: The proposed public open space is supported in line with London Plan Policy 7.18.  Housing: The provision of up to 725 residential units is strongly supported. The expected choice of units is generally acceptable; however the permission will need to appropriately define parameters for the proposed mix. The density of the scheme is within the London Plan density range and is supported. The applicant should clarify the calculation of child play space requirements; how the required space will be secured; and a commitment to meeting the play requirements of the Mayor’s SPG.  Affordable housing: The Council should provide their independent assessment of viability, in order to confirm that the proposal will provide the maximum reasonable amount of affordable housing, as required by London Plan Policy 3.12.  Urban design: The proposals are well considered and broadly reflect the design aspirations of the OAPF, the Masterplan and the draft AAP. The parameters and Design Code appropriately secure the quality, including residential quality, of the scheme; however

page 18 the applicant should consider a commitment to achieving a minimum floor to ceiling height of 2.5 metres.  Inclusive design: The proposals are supported in line with London Plan Policies 7.2 and 3.8. The Council should secure M4(2) and M4(3) requirements by condition.  Transport: The applicant should reconsider the modal split used to estimate trip generation; promote the restrained approach to residents through measures such as car clubs; consider a step-free/no dismount design for the pedestrian/cycle link over the rail line; reconsider the Phase 1 and longer term bus strategy; provide contributions for an additional bus service; clarify how the pedestrian network will be improved; confirm that no works will impact the A406; consider the need for measures to improve the physical environment, legibility, security and future safety of residents; and the final construction logistics plan and delivery and servicing plan should be secured by condition.  Climate change: The carbon dioxide savings exceed the target set within Policy 5.2 of the London Plan; however evidence of how Policy 5.9 has been addressed should be provided at Reserved Matters Stage and secured through a condition; provide further information to demonstrate how the savings from connection to the LVHN have been calculated; and confirm the net area of PV panels proposed and explain the methodology used in order to calculate the electricity generated. The proposals are acceptable in terms of London Plan Policies 5:12 and 5:13; however a suitable planning condition should be applied regarding the details of the drainage proposals.

98 On balance, while the application is generally acceptable in strategic planning terms, it does not yet comply with the London Plan; however the possible remedies set out above could address these deficiencies.

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

page 19