planning report PDU/2292a/01 7 July 2010 Tottenham Hotspur Football Stadium

in the London Borough of Haringey planning application no. HGY/2010/1000

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

The proposal A revised hybrid (part detailed and part outline) application for the demolition and comprehensive mixed-use redevelopment to provide a new football stadium, a hotel, retail uses, a museum, offices and housing; and associated facilities, including the construction of new and altered roads, footways, public and private open spaces, landscaping and related works; with details of the ‘external appearance’ and ‘scale’ of the proposed residential and hotel buildings reserved for future consideration. The applicant The applicant is Tottenham Hotspur Property Company Ltd, and the architects are KSS and Make.

Strategic issues The principle of the redevelopment of White Hart Lane is supported. It would stimulate regeneration, contribute to London’s world city role, and accord with London Plan policies on sports facilities and hotels. The application is acceptable in relation to access/equal opportunities and climate change, although further information is required. The design of the new stadium and associated public realm is supported. The retention and refurbishment of statutory and locally listed buildings previously proposed for demolition, and their full integration into the revised scheme, is particularly welcome and would overcome one of the principal concerns over the previous application. Revisions have been made to the design of the supermarket.

Transport for London considers that unless substantial mitigation is provided to provide the additional transport capacity that is necessary to support this development, it remains unconvinced that the proposed mode shift can be achieved.

Recommendation

That Haringey Council be advised that from a land use point of view, with the exception of

page 1 transport matters detailed in paragraphs 53- 106 of the report, the application complies generally with the London Plan, but that adjustments are required to make it fully compliant, in particular that adequate transport mitigation should be provided.

Context

1 On 4 June 2010, the Mayor of London received documents from Haringey 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 15 July 2010 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 and 1C 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- “Development (other than development which only comprises the provision of houses, flats or houses and flats) which comprises or includes the erection of a buildings or buildings….outside Central London and with a total floorspace of more than 15,000 sq.m.”

1C- “Development which comprises or includes the erection of a building….more than 30 metres high and is outside the City of London.”

3 Once Haringey Council resolves how it intends 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) (England and Wales) Regulations 1999 has been taken into account in the consideration of this case.

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

6 The application site boundary encompasses a rectangular area of 11.5 hectares in the north-eastern corner of Haringey in north London. It comprises the existing Tottenham Hotspur Football Stadium in its south-eastern corner; the land between the western side of the stadium and the A1010 High Road (Tottenham); and all land to the north as far as Northumberland Park, and bounded on the west and east by High Road and Paxton Road/Worcester Avenue respectively.

7 The site is bounded on its northern side by Northumberland Park; on its south by Park Lane; and on its east by Paxton Road, which runs north into Worcester Avenue. On the west, the existing stadium is setback and separated from by the A1010 Tottenham High Road by a variety of buildings. An extension of Paxton Road traverses the site from east to west along the northern side of the stadium.

8 The surrounding area is predominately residential in character, though there is a significant amount of retail, commercial and industrial use within the vicinity of the site.

page 2 9 With a present capacity of 36,300, the existing stadium sits on the southern portion of the development site and is defined along its immediate north and east elevations by Paxton Road. The northern portion of the site contains a number of buildings fronting Tottenham High Road; the N17 Studios estate, light industrial buildings and offices on Wingate Trading Estate; further light industrial buildings between Wingate and Northumberland Park, and terraced homes to the west side of Worcester Avenue.

10 The new stadium would be sited in a more central location than the existing facility, encroaching on the northern half of the site.

11 The High Road is part of the strategic road network (SRN) and the other roads are borough roads. The nearest part of the Transport for London Road Network (TLRN) is the A10 at Bruce Grove. In addition the site is about 1km south of the A406/Fore Street junction, which is also part of the TLRN.

12 There are ten bus routes serving this area: routes 149, 279, 259, 341, 476, 123, 243, 318, W3 and 349 with bus stops on the High Road and on Northumberland Park. There are two national rail stations within reasonable walking distance of the site. White Hart Lane station is approximately 450m to the west and provides access to services on the Seven Sisters branch of the Lea Valley Line. Northumberland Park station is approximately 600m to the east and provides access to services on the Tottenham Hale branch of the Lea Valley line.

13 The nearest underground station is Tottenham Hale on the Victoria Line, approximately 2.2 km to the south-east. Although Seven Sisters is actually further away, at 2.3m to the south, it is perceived as being more accessible to this area, given the short bus interchange on Tottenham High Road and the direct walking route. Seven Sisters and Tottenham Hale also provide interchange opportunities between national rail services from White Hart Lane and Northumberland Park with the Victoria Line.

14 Information submitted with the assessment indicates that the site has a public transport accessibility level (PTAL) of 4 on a scale of 1 to 6, where 6 is classed as excellent.

Details of the proposal

15 This is a landmark development designed to transform the heart of Tottenham and kick- start the regeneration of one of the most deprived areas of London.

16 The proposals are a revised version of a scheme named the ‘Northumberland Development Project’, for which an application for planning permission was considered by the Mayor in December 2009. A copy of that report, referenced PDU/2269/01, is attached for ease of comparison. The amendments have been made principally to retain four key heritage assets that were previously intended for demolition.

17 The development is associated with the submission of the following four applications to Haringey Council:

 A hybrid planning application for the development described above.

 An application for Conservation Area Consent.

 An application for Listed Building Consent for the demolition of 774 High Road (Fletcher House).

page 3  An application for Listed Building Consent for alterations and demolition of the later additions to 744 High Road (Warmington House).

18 As with the initial proposal, the development can be analysed as three distinct but closely interlinked phases i.e. the northern development, the stadium redevelopment and the southern development:

The northern development

19 The principal land-use of the northern development remains a food store/supermarket complex with a gross external area of 22,009 sq.m. The building would offer a net retail sales area of 7,201sq.m. Its ground floor facade, to the south side of Northumberland Park, is now designed to contain active uses along its entire length, including a customer cafe/restaurant in the north- west corner, a taxi drop-off/waiting area in the north-east corner, 401 car parking spaces, an entrance lobby and escalators to the first floor.

20 The principal sales area would be retained at first floor level, but a new second floor club office and hospitality area (8,517 sq.m. in size and ancillary to the stadium) would be introduced in place of a ceiling void above the sales area of the store.

21 Above that, a third floor ‘Sky Bar’ (2,602 sq.m. in size) would be introduced near the southern edge of the roof, with a sheltered access link to the main stadium.

page 4 The proposed stadium

22 The capacity of the new stadium would be maintained at 56,250. The main changes to it are a reconfiguration of its west-facing main entrance, to improve its relationship with Tottenham High Road; the inclusion of a raised podium, accessed by a series of stairs and lifts, to link the stadium to the northern and southern developments; and internal alterations to improve access for people with impaired mobility.

The southern development

23 Following discussions with English Heritage and CABE, earlier proposals to demolish some heritage assets have been dropped. The applicant has now agreed to retain the following additional assets and to remodel the development and surrounding public realm, to provide an appropriate setting for those buildings:

 744 High Road, Warmington House (statutorily listed grade II)

 746 ‘Edmonton Dispensary’ (locally listed)

 748 ‘Redhouse Coffee Palace’ (locally listed)

 750 the former ‘White Hart Public House' (locally listed)

24 The buildings will now be retained, repaired and brought back into beneficial use, although later additions to Warmington House that detract from its character would still be removed. A large, semi-circular public space would be created by a podium designed to provide an appropriate setting to the retained historic buildings, and to accommodate the proposed club shop and museum. It is envisaged that the active ground floors of the historic buildings, the club shop and the museum would animate this portion of the site and the High Road on match days and non- events.

25 The office accommodation with state-of-the-art facilities for Tottenham Hotspur Foundation would remain in the location proposed in the original plans. The proposed 150-room hotel has, however, been relocated to the eastern portion of the site.

page 5 26 The form of the proposed residential development has also been revised from 434 units arranged over four blocks, orientated in a north-south direction; to a maximum of 200 units contained in a single, gently curved building above a two-storey podium, orientated in an east- west direction. The reduction in the quantum of residential accommodation has been motivated by the need to improve residential amenity and the setting of the retained historic assets. Case history

27 A series of pre-application meetings between the applicant’s representatives, Haringey Council and the GLA, together with a presentation to the Mayor and Deputy Mayor, took place between November 2008 and June 2009. A pre-application advice note on the proposals was issued on 12 June 2009.

28 In December 2009, the Deputy Mayor considered a referral from Haringey Council, of a planning application for the demolition of the existing stadium and other buildings, and a mixed- use redevelopment of the site to provide a new 56,250 capacity stadium, 434 residential units, a food store, a hotel, a club shop, a museum, offices, new public realm and other associated works.

29 The Mayor agreed with his officers’ conclusion that, on balance, the proposals did not comply with the policies in his London Plan, and that the following issues needed to be addressed to ensure compliance with the strategic planning policies:

 Transport matters raised by TfL in (paragraphs 72- 116) of his officers’ planning report.

 A financial assessment to justify the amount and tenure of affordable housing and if necessary, changes to the provision.

 Concern over the demolition of some locally listed buildings.

 Possible changes to the residential mix.

 Space standards within the new residential units.

 The provision and quality of children’s play space.

 Alterations to the design of the supermarket.

 Additional information in relation to access/equal opportunities as set out in (paragraphs 159 -175 of) the initial report to the Mayor.

 Additional information in relation to climate change mitigation and adaptation as set out (in paragraphs 176- 200 of) the initial report to the Mayor. Strategic planning issues and relevant policies and guidance

30 The relevant issues and corresponding policies are as follows:

 World city role London Plan  Mix of uses London Plan  Regeneration London Plan; Economic Development Strategy; Mayor’s draft replacement Economic Development Strategy  Transport/parking London Plan; the Mayor’s Transport Strategy; PPG13  Retail/town centre uses London Plan; PPG13, PPS4

page 6  Employment London Plan; PPS4; Industrial Capacity SPG  Housing London Plan; PPS3; Housing SPG; Providing for Children and Young People’s Play and Informal Recreation SPG, Housing Strategy; revised interim Housing SPG  Affordable housing London Plan; PPS3; Housing SPG, Housing Strategy; revised interim Housing SPG  Density London Plan; PPS3; Housing SPG; revised interim Housing SPG  Urban design London Plan; PPS1  Historic environment London Plan; PPS5  Access London Plan; PPS1; Accessible London: achieving an inclusive environment SPG; Planning and Access for Disabled People: a good practice guide (ODPM)  Equal opportunities London Plan; Planning for Equality and Diversity in Meeting the spatial needs of London’s diverse communities SPG; Diversity and Equality in Planning: A good practice guide (ODPM)  Air quality London Plan; the Mayor’s Air Quality Strategy; draft replacement air quality strategy; PPS23  Sustainable development London Plan; PPS1, PPS1 supplement; PPS3; PPG13; PPS22; draft PPS Planning for a Low Carbon Future in a Changing Climate; the Mayor’s Energy Strategy; Mayor’s draft Climate Change Mitigation and Adaptation Strategies; Mayor’s draft Water Strategy; Sustainable Design and Construction SPG

31 For the purposes of Section 38(6) of the Planning and Compulsory Purchase Act 2004, the development plan in force for the area is the 2006 Haringey Unitary Development Plan (Saved Policies Version, July 2009) and the London Plan (Consolidated with Alterations since 2004).

32 The following are material planning considerations:  The draft replacement London Plan, published in October 2009 for consultation.  Core Strategy (‘A New Plan for Haringey 2011- 2026’)- (Proposed Submission Consultation 10 May- 21 June 2010).  Site Allocations Development Plan Document (published for consultation10 May- 21June 2010).  Development Management Development Plan Document (published for consultation 10 May- 21June 2010).

Strategic land use policy and the principle of development

33 The application site has no specific land use designation in the London Plan or the consultation draft replacement London Plan. Part of the site is in use as a stadium, whilst the remainder is occupied by a mix of disused industrial/commercial properties. The Upper Lee Valley is, however, identified in the London Plan as an ‘Opportunity Area’, with capacity for a significant numbers of new jobs and homes; whilst large parts of Haringey, including Northumberland Ward, in which the site is situated, is identified as an ‘Area of Regeneration’ to which the benefits of new development in opportunity areas should be extended.

34 The proposal for a stadium-led mixed-use development of the site is supported by a number of strategic policies, including 2A.7 of the London Plan and 2.14 of its consultation draft replacement (Areas for Regeneration), that identify the locality as being in the top 20% most

page 7 deprived wards in London1 and where the Mayor will work with strategic partners to achieve sustained renewal by prioritising them for local action and investment.

35 The key elements of the scheme are also affected by the following strategic policies:

New Stadium

36 London Plan policy 3B.9 (The Olympic and Paralympic Games and sports facilities), which requires borough councils, in preparing their DPDs, to identify sites for a range of sports facilities to meet local, regional, sub-regional and wider needs; to ensure that facilities are accessible to all sections of the community by public transport, cycling and walking; and to ensure that multiple use of facilities is encouraged, including those of schools and community organisations.

37 Policy 3.20 (Sports facilities) of the consultation draft replacement London Plan affirms the Mayor’s Sports Legacy Plan, which aims to increase participation in and to tackle inequality of access to sport and physical activity in London, particularly amongst groups/areas with low level of participation.

38 More specifically, the policy states that development proposals that increase or enhance the provision of sports and recreational facilities will be supported; those that result in a net loss of sports and recreation facilities, including playing fields should be resisted. The draft policy adds that temporary facilities may provide the means of mitigating any loss as part of proposals for re- provision. It reiterates the objective that, wherever possible, the multi-use of facilities for sport and recreational activity should be encouraged.

The hotel

39 The proposed 150-room hotel is complementary to the stadium and supported by London Plan policy 3D.7 (Visitor accommodation and facilities) and policy 4.5 (London’s visitor infrastructure) of the draft replacement London Plan.

40 Those policies seek to support London’s visitor economy and to stimulate its growth in appropriate locations, with due regard for the needs of business as well as leisure visitors; to improve the range and quality of provision, especially in outer London; and to achieve 40,000 net additional hotel bedrooms by 2031, of which at least 10% should be wheelchair accessible.

41 In locations outside the Central Activities Zone, such as the application site, visitor accommodation should be focussed in locations where there is good public transport access into central London, and to national and international transport termini.

The food store

42 The proposed food store would be located just within the northern periphery of Bruce Grove/Tottenham town centre, which is identified in the London Plan strategic town centre hierarchy as one of five district centres in the borough (the others being Muswell Hill, Crouch End, Green Lanes and Seven Sisters/West Green Road).

43 The 2008 Borough Retail Study indicates that the majority of local residents close to Tottenham town centre rely heavily on facilities further afield for both their convenience and comparison shopping needs; with no large supermarkets or food superstores in the locality except a Sainsbury store located north-west of the site, close to the borough boundary, and three small food stores in Bruce Grove to the south.

1 Source: DCLG and Local Government Office of National Statistics Super Output Boundaries.

page 8 44 A retail assessment carried out on behalf of the applicant affirms suitability of the site, given the need for an effective anchor food store to underpin the other shops and services, its location in that part of the town centre least well served by food shopping facilities, and the lack of any sequentially preferable sites to accommodate the size and type of store presently proposed.

45 This justification for the store is supported by the objectives of London Plan policies 3D.1(Supporting town centres), 3D.2 (Town centre development) and 3D.3 (Maintaining and improving retail facilities); and by policies 4.7 (Retail and town centre development) and 4.8 (Supporting a successful and diverse retail sector) of the consultation draft replacement London Plan.

Residential development

46 From a strategic planning perspective, the principle of including of a residential component in mixed-use developments is specifically encouraged by policy 3A.1(Increasing London’s Supply), 3A.2 (Borough housing targets) and 3A.3 (Maximising the potential of sites).

47 The first of these states a London-wide minimum target, which has since been updated by policy 3.3 of the consultation draft replacement London Plan, to provide 33,400 additional homes per year between 2011 and 20212. The second encourages the promotion of local policies to identify new sources of supply, such as a change of use of surplus industrial and commercial land to residential or mixed-use development, renewal and redevelopment in town centres, and the intensification of housing provision through development at higher densities where compatible with sustainable residential quality. The third seeks to ensure that development proposals achieve the maximum intensity of use compatible with local context, the principles of sound design and public transport accessibility. The latter is supported by policy 3.4 (Optimising housing potential) of the consultation draft replacement London Plan, which aims to optimise housing output rather than the use of land in general. World city role/the regeneration of Tottenham

48 The stadium redevelopment and local regeneration programme is consistent with the aims of policy 1.1 (‘London in its global, European and UK context’) and would contribute towards London’s unique strengths as a national and international centre of finance and commerce, and a diverse world city for arts, culture, sports and tourism.

49 Tottenham is recognised at the national, strategic London-wide and local government level as a priority area for regeneration. The area ranks high on all of the national indices of deprivation i.e. employment, income, housing, health, education and crime; and the northern part of the area, Northumberland Park ward, has the highest unemployment in London.

50 The borough UDP has subsequently affirmed Tottenham High Road as a strategic area for regeneration and specifically highlights the potential of a redeveloped Tottenham Hotspur Stadium, given that the club is one of Haringey’s largest businesses and most significant visitor attractions, as a catalyst for regenerating the northern end of the High Road.

51 Against that background, the draft Core Strategy document sets out the Council’s aspirations for the redevelopment of the stadium include:

 The provision of a mix of land uses, including redevelopment of the football stadium.

2 Source: The Consultation Draft Replacement London Plan, October 2009: Policy 3.3 Housing Supply, and Table 3.1 Annual Average Housing Provision Monitoring Targets 2011 –2021.

page 9  Provision of appropriate residential use.

 Provision of appropriate retail and leisure uses

 Appropriate contributions to employment and training schemes, community facilities, regeneration initiatives and open space.

 High quality sustainable design that respects its surroundings and preserves and enhances the areas historic environment.

 Improving community safety, including measures to reduce opportunities fro crime and anti-social behaviour. 52 The proposed development is in line with these aspirations. It would build on the key strengths of Tottenham Hotspur Football Club as a major visitor attraction, but also crucially, introduce a range of complementary uses, that can act as the basis of an economic and employment hub for the area. Its benefits would include:

 Securing the long term of Tottenham Hotspur Football Club in the area, able to compete on an even footing with Europe’s top football clubs

 340 full-time equivalent construction jobs, with a significant proportion on the application site.

 370 permanent and up to 1,000 temporary jobs in sport, leisure, retail and hospitality which match with local labour market needs.

 Environmental improvements and new visitor attractors capable of altering the image of the area, bringing up to two million annual visitors to Tottenham, and supporting the additional investment and employment expenditure within the locality.

 A wider local housing offer and new household expenditure, providing further support for the creation of a positive cycle of investment and expenditure in Tottenham.

 New facilities for Tottenham Hotspur Foundation, which would allow it to integrate further into the local community, work more creatively with partners, and expand its operations to address social exclusion and deprivation.

 A massive investment in the local environment, including a major increase in both the quality and quantity of public open space and children’s play space in an area of acknowledged deficiency.

Transport for London’s comments and related issues

Parking and Access

53 Approximately 900 car parking spaces are proposed in connection with the overall development. This comprises 400 spaces for the supermarket, 319 for the stadium, 130 for the residential and 40 for the hotel. Whilst parking levels should be informed by the capacity of the highway network to accommodate additional vehicular trips, TfL notes that parking levels are proposed to be relatively low compared to London Plan maximum standards. When event day controls are not in place there may be overspill parking in the local area and TfL therefore

page 10 welcomes the developer’s willingness to work to secure a non match day Controlled Parking Zone (CPZ).

54 For match days, the proposed CPZ boundaries have been further extended, in order to minimise vehicle trip generation and as a means of controlling the vehicular mode share. As the transport strategy is highly dependent on its implementation, the assessment should identify an alternative strategy should the CPZ extension not occur. Although TfL has worked with the developer to identify the likely levels of existing on street and off street parking available within reasonable distance that a spectator would walk to reach the stadium, it is still considered that the assessment may have significantly underestimated the capacity for parking at some of these potential off-street parking locations. Research into potential off street parking areas has identified around 8,500 parking spaces within a 30 minute walk of the stadium, on top of the on street pay and display and blue badge parking locations. Given TfL’s doubts about the effectiveness of the CPZ in minimising car use and influencing mode share, additional measures are expected to be provided by the applicant to address this, as further detailed later in this report.

55 For non-match days, TfL has concerns about the size of the supermarket car park. A parking accumulation analysis predicts that parking demand will exceed capacity for long periods. As the High Road/Northumberland Park junction is only 100 metres away from the proposed store access, even a relatively small queue will block the junction and create significant capacity issues. TfL is concerned about the potential for delays and safety issues for cars, buses and vulnerable road users on the SRN. Unless this matter is satisfactorily resolved the developer should consider whether the size and format of the store is appropriate for this location.

Trip Generation and Mode share

Match days

56 The developer is assuming a significant reduction in the car mode share from 40% to around 23%. This is a significant reduction in this location and accordingly a hugely ambitious target. As stated above, it is largely dependent on the proposed extension to the CPZ and forecasts a significant reduction in car use, though not as ambitious as the reduction achieved at the Emirates. Whilst the extended CPZ is welcomed as a measure in itself, to be effective there will need to be tangible improvement in the public transport offer in order to encourage spectators to move away from car use.

57 For TfL to have confidence in the mode share targets, the relative attraction of competing modes such as rail and underground should be fully understood. Despite previous requests, no information has been provided in the assessment on current waiting times for spectators at key transport hubs. Although future waiting times are predicted, TfL is unable to compare the current and future scenarios; if waiting times will be significantly increased this could encourage spectators to travel by car. Without this information, TfL cannot agree that the development will have a nil detriment impact on the highway.

58 In response to TfL’s concern about the robustness of survey data for the underground, additional surveys were undertaken in March 2010, which are welcomed. However, it is not clear how these were used to inform the revised assessment and whether they were compared with the previous data from 2008. Furthermore, station counts were only carried out at Seven Sisters and not at Tottenham Hale. As with the previous assessment, the raw data has not been properly used to inform the current modal split which underestimates the demand for interchange from Underground to rail and Underground to buses, and refers to the final mode only. As comparisons with the 2008 data and previous years will therefore be invalid, TfL requests that the developer review this material as a proper understanding of the mode share for the underground is critical to

page 11 determining future impact on this mode. TfL suggests that the developer should refer to the existing mode splits that are currently published on the club website, as they appear to be more realistic.

59 Although the assessment assumes that all departures from the stadium occur within 60 minutes of the final whistle, spectator retention is a key element of the developer’s transport strategy. Retention measures are expected to keep 15,000 spectators in the local area post match. As ‘peak spreading’ will be critical to managing the additional travel demand from the development, there should be robust targets to ensure that this is achieved. The use of financial mechanisms, such as targets linked to mode split, should be considered if these retention levels are not achieved. The failure to meet retention targets will result in longer queues at public transport hubs and with the effect that car-based travel will be more attractive.

60 TfL welcomes the developer’s willingness to provide a monitoring programme for modal split, pedestrian movements, parking and traffic flow and any other benchmarks that are considered necessary. TfL requests involvement in the development of this monitoring programme to ensure that it complied with its requirements.

Non-match days

61 For the proposed foodstore, the assessment had only used data from the existing nearby Sainsbury’s store in order to assess trip generation. As this was considered wholly unrepresentative of the proposed retail store, TfL welcomes the sensitivity test undertaken using car trip rates from various retail developments. Confirmation is however required as to whether the trips from the Sainsbury store have been deducted from the site’s existing trips as their inclusion would significantly overestimate existing trips. In addition TfL questions the limited survey period for deriving trip rates from the existing store. Such a survey will result in limitations when trying to determine the cumulative peak hours for the development proposals and understanding the level of car parking demand throughout the day.

62 The proposed floor area for the club shop, offices, museum and other land uses has increased from the previous proposals, however the trip rates associated with these uses have not been revised to reflect the changes. It is recommended that trips are increased on a pro rata basis. Similarly the developer should clarify why car trips associated with these land uses have only increased by 20% when the floorspace has increased by 40%.

Public Transport

63 With the previous proposals TfL requested that the developer undertake a demand forecasting approach to assessing public transport capacity. This would enable a comparison between various scenarios, including the 2016 stadium flows with background growth on the network. In order to facilitate this assessment, TfL provided details of background growth at Seven Sisters station. It is disappointing therefore that the travel demand from the stadium has not been integrated into the base case. The developer considers that the format of their capacity assessments is ‘not easily transferable’ into the format provided by TfL. As this information is critical to understanding the impact of spectator demand and in order to identify what mitigation will be necessary, further discussion is invited in order to explore how this data can be produced.

Underground

64 TfL was critical about the quality of survey data used to support the previous assessment of underground capacity. Additional surveys were accordingly undertaken at Seven Sisters station in March 2010. It is not apparent however, as to how this data has been used to inform the

page 12 assessment and future analysis. Whilst further clarification is therefore welcomed on this, they should be compared with RODS (Rail Origin and Destination) data and the previous surveys in order to demonstrate the appropriateness of the original data sets to represent a typical matchday. TfL welcomes that the assessment now follows London Underground standards although the reference to the Green Guide’ (Dept. Culture, Media and Sport (2009) Guide to Safety at Sports Grounds) in connection with pedestrian flows is still considered inappropriate. The assessment continues to present the existing mode splits incorrectly. Underground interchange to rail and bus is not captured from the survey data and therefore underground trips are still under-represented.

65 TfL welcomes the principle that the development should make greater use of Tottenham Hale Underground Station as it is relatively underused on match days, whereas Seven Sisters is operating with station control. Currently the percentage use of the Tottenham Hale station for midweek departures is only 8% with the remainder of Underground trips being split amongst other stations. The developer’s commitment to capacity enhancements at Tottenham Hale to deal with an expected increase in demand is welcomed in principle. Demand forecasting, as stated above, will be essential in identifying a reasonable level of contribution. The assessment predicts that the gateline will be the main capacity constraint; however it identifies specific improvements including potential reconfiguration of the ticket hall and introduction of an additional escalator. This is unachievable within the current station configuration and would require complete station reconfiguration. TfL therefore requests that contributions be provided for Tottenham Hale interchange which incorporates the station but does not specify the proposed improvements. Furthermore, the development will increase all interchange movements at Tottenham Hale, not just underground. For example, there will be a significant impact in terms of queuing outside the station and crowds will need to be managed in order to prevent conflicts with other modes such as bus movements.

66 The developer’s commitment to assist London Underground with the development of an operational plan at Tottenham Hale and a revised plan for Seven Sisters is welcomed. The developer should contribute to any measures identified in the plans such as improved signage and additional staff on event days in order to manage and control spectators. At both Seven Sisters and Tottenham Hale stations, spectators who are interchanging from rail and underground are given priority over those who are arriving from outside. Given that TfL will seek to ensure that all queuing is maintained outside the station complex to ensure safety, it is requested that any necessary additional staff be funded by the developer. TfL welcomes further discussions to identify the level of crowd management support and the duration of the support. As well as providing details of service level improvements, the club communication strategy should provide ongoing travel information for the pre and post match periods.

67 For a concert scenario, TfL notes that the assessment predicts a higher mode share for underground together with a more peaked arrival and departure profile than for a typical match day. The assessment also indicates that ‘the transport network is at the limit of what is likely to be an acceptable outcome in terms of queues and delays’. Unless, the assessment can demonstrate that there will be sufficient capacity, TfL questions whether this will be a suitable concert venue and accordingly whether planning conditions should be imposed to restrict or limit such activity.

68 As with the previous assessment there has been no consideration of the impact on the wider network (including stations such as Finsbury Park and Kings Cross). No assessment has been made in terms of the wider dispersal of spectators from Seven Sisters or Tottenham Hale stations. Once these matters have been fully assessed and agreed, TfL may request contributions to mitigate the impact at these stations and to ensure their safe operation during the pre and post match period.

page 13

Rail

69 TfL remains of the view that the assessment uses the most favourable assumptions to examine capacity and demand for rail travel in the weekday matchday peak. Given the significant additional rail demand that is forecast, significant overcrowding of rail services is expected. TfL is therefore disappointed that further to its previous comments, the assessment does not show that ‘rail service provision is forecast to satisfy the demand on trains’. Notwithstanding this, TfL notes and agrees some changes to the assessment. For example the rail mode split now seems reasonable as it concurs with the observed numbers for existing events. In addition, TfL also welcomes the revisions to the assessment to clarify that they are not reliant on extra capacity delivered by four tracking the West Anglia main line.

70 For other elements of the assessment TfL still has concerns. The peak hour assessment of travel demand predicts that there will be a maximum of 3678 spectators per hour arriving at White Hart Lane station on northbound services. Spread amongst six trains, this averages 600 additional passengers per train, in addition to the normal commuter demand. For midweek matches, the peak hour for travel to the stadium is consistent with the commuter peak. Whilst there are also up to 1697 spectators arriving northbound at Northumberland Park station in the mid week peak hour, there is more likely to be sufficient capacity with the longer trains. TfL requests that the assessment clarifies this matter and clearly sets out background demand against spectator demand.

71 TfL has concerns about the method of assessing station capacity. For example, it assumes that once a train departs Seven Sisters, the platform is completely cleared. This is unlikely as the station serves two rail corridors; Cheshunt and Enfield Town. Platform capacity has therefore been overestimated and assessed using 0.66 people per square metre, which is an exceptionally low level of density. To allow for the edge effects at the front and back of the platform, TfL recommends the use of 0.8 square metres per passenger and would therefore question why this standard was not used. TfL also requests that the assessment considers how long it takes for the rail platforms at Seven Sisters to clear and accordingly what mitigation may be required. In addition to direct services from Liverpool Street, there will also be considerable demand for rail services from Tottenham Hale with spectators interchanging with other modes. As with the other stations, crowding analysis should be undertaken particularly as the existing conditions report advises that weekday evening peak services are already operating at or near capacity.

72 TfL nevertheless welcomes the developer’s commitment to mitigate additional rail demand. The improvement of walk routes together with signage will improve the journey experience and encourage use of rail. Although improvements to station facilities are also welcomed; clarification should be provided as to what improvements will be provided at Seven Sisters station. The assessment refers to Network Rail’s proposal to widen the staircase from the southbound platform to the underground station. As it is understood that this remains unfunded and expected that spectator demand will increase, the developer should contribute towards its implementation together with platform decluttering. The developer’s attempts to secure additional match day services are welcomed given the concern about capacity constraints. As with the previous proposals, TfL seeks assurance that selective door opening will enable 12 car services to continue to stop at Northumberland Park. If the commitment to refurbish and provide step free access at White Hart Lane is dependent on the developer’s adoption of the station, then evidence that this is a realistic proposal should be provided. Additional Oyster readers would be welcomed at this station but are not required at Northumberland Park. As the four tracking proposals are not committed, the developer should also commit to keeping the level crossing closed during peak periods for an indefinite period. As with the underground stations, the developer should explore with Network Rail, the funding of additional staff to manage crowds during the peak period.

page 14

Buses

73 TfL considers that, as with the previous proposals, the assessment should determine the impact of the development as opposed to trying to place demand where there is excess capacity on the network.

74 The assessment predicts very high demand increases for the Tottenham High Road bus corridor (routes 149, 259, 279 and 349). An additional 2016 passengers in the peak hour equates to an additional 14 buses per hour that would be required in the inter peak period, as well as additional weekend services. Accommodating this demand would necessitate a massive frequency increase on this corridor. The requirement for an additional 3.5 buses per hour on each route would also not be possible in some cases as the peak frequencies are similar to the off peak frequencies.

75 For clarification, the assessment should be revised to state that the planning capacity of route 149 will be scaled down to 70 from 105 passengers, as from next year the bendy bus is being phased out.

76 TfL welcomes the developer’s commitment to increase the frequency on route 279 to provide sufficient capacity. However, additional capacity would be required for the whole day as the interpeak frequency cannot exceed the peak frequency. In accordance with usual practice, the contribution should be provided for a period of at least five years. TfL expects the contribution to be substantial figure and welcomes further discussion about this matter. For clarification, route 279 is not a shuttle and will not be operated as such. If a shuttle bus type operation is required, the developer should continue to investigate its feasibility. The provision of a shuttle bus may be included within the travel plan measures as a means to improve the public transport mode share but should not in any case conflicts with local services.

77 In general, TfL expects the developer to fund all bus enhancements generated by these proposals. The analysis clearly indicates that existing capacity is exceeded at various times during the day and mitigation will therefore be needed for these instances. The matchday impact has to be mitigated at all times and not just on matchdays as TfL does not provide ad hoc services or schedules because of consistency and scheduling restrictions.

78 TfL has entered into discussions with the developer in order to divert buses to the east of the development and to reduce journey time diversion timings. It is expected that this will be implemented in the 2010-2011 season and the developer should monitor the results in order to inform the stadium proposals and event day management.

79 All other alterations to bus infrastructure that are required in connection with these proposals, including new bus stops and stands on the High Road should be provided at the developer’s expense and secured through the section 106 process.

Highways

80 The assessment does not provide sufficient information on existing vehicular conditions for both the match day and non-match day scenarios. In order that the impact of any future traffic growth from the development can be assessed, the submission of an existing base model that has been validated to an acceptable standard is critical. TfL has worked with the borough and the developer in order to resolve this matter. Regrettably however, there are still fundamental concerns about the saturation flow measurements and how the flows used in the models have been derived.

page 15 TfL has requested further information and until this matter is resolved, impact of this development on the TLRN cannot be verified and subsequently accepted.

81 The assessment highlights 560 accidents at a number of junctions on the TLRN. Further analysis should therefore be undertaken to identify the specific safety issues and consider whether development traffic could worsen conditions.

82 The assessment predicts that of 32 local junctions that will experience changes in vehicular trips, 7 are likely to be affected by the development. For robustness, further modelling should be undertaken using the higher food store trip rates. TfL is involved in ongoing discussions with the developer about this matter and a detailed modelling note will be provided direct to them in due course.

83 The developer will be required to model a number of future scenarios in order to determine the change in predicted traffic flows, including with and without the development and with additional mitigation. As stated above, until the base model is validated to an acceptable standard, before this work can be properly reviewed and understood.

84 As stated above, TfL has concerns about the parking accumulation study. The analysis should be revised so that it is based on the agreed survey data. Assuming these higher trip rates are likely to show that parking problems will occur for a much longer period, with the consequent effect on the adjacent junction. Furthermore, as background traffic on a weekday will be greater, a parking accumulation should be carried out for that period.

85 As part of the package of mitigation, the development provides alterations to junctions along the High Road, which are expected to improve capacity and therefore reduce bus delays. Unless the junction modelling work, referred to above, has been agreed, this cannot be verified and subsequently accepted.

Walking and cycling

86 TfL notes that the proposals are expected to increase pedestrians in the local area by over 55% or around 20,000 additional walking trips compared to the existing stadium. In response to previous comments, a PERS audit has been undertaken, which is welcomed. TfL has provided detailed comments on this direct to the developer. A PERS audit for the matchday scenario should also be undertaken which would capture spectator desire lines. For example the pedestrian pinch point on Lansdowne Road has not been identified in the non match day review. TfL also requires clarification as to how the results have been used to inform the assessment and how any deficiencies will be remedied as part of the package of transport mitigation.

87 An interim review of pedestrian capacity between the stadium and various transport nodes uses flow rates based on the ‘Green Guide’ which should be used for flows inside stadia and not on the highway. It indicates that there are numerous pinch points on Tottenham High Road leading to Seven Sisters station. Although measures such as decluttering, signage and crowd management are welcomed, the developer should consider whether footway widening is feasible. Further discussions with TfL are therefore invited. In principle, further interventions to improve pedestrian capacity and manage crowds along Tottenham High Road are welcomed. TfL assumes that improvements that have been identified will be secured under section 106 agreement. Any package of developer- funded improvements should, however, be agreed with TfL to ensure that they are compatible with the proposed Tottenham gyratory and interchange proposals.

88 A comprehensive signage strategy for the above area should be developed, consistent with a ‘Legible London’ style signage system. The strategy should include all four stations that are used by spectators.

page 16 89 The area outside Seven Sisters station is a key link for supporting pre and post match crowds. In the evening peaks, this is also an important area for underground to bus interchange. TfL expects that the increase in pre match crowds will have a detrimental effect on the bus waiting areas. The PERS assessment should consider this matter and advise as to what improvements will be necessary.

90 The development provides 28 cycle spaces adjacent to the food store with access to additional spaces across the site. To accord with TfL’s cycle parking standards, a minimum of 93 spaces should be provided. The proposals should clearly identify where the additional spaces will be located as cycle parking that is remote from the food store will not be acceptable.

91 In order to improve the conditions for cyclist on matchdays and non matchdays, the developer’s commitment to developing a cycle strategy is welcomed. However, mitigation should be secured across a wider area as proposed improvements are currently limited to Northumberland Park. As above, significant areas of the adjacent highway are within TfL’s control. A contribution of £240,000 is requested in order to implement the extension of the cycle superhighway route 1 beyond Bruce Grove.

Taxis

92 As with the previous proposals, TfL is disappointed that the development does not make provision for taxis as the mode share could be up to 1.5% on matchdays and 3% for a concert scenario. With the increased size of the stadium that can account for a substantial number of trips that would merit a dedicated taxi rank. In addition taxi access to the proposed hotel should be encouraged in order to minimise private vehicular use and should be promoted through the travel plan. Further discussion about this matter is welcomed.

Coaches

93 TfL welcomes the club’s willingness to work with supporter clubs, coach operators and TfL to develop a new coach strategy that will seek to attract far more spectators to use this cost- effective travel option. The measures that are proposed for home fans appear satisfactory, however for away fans, further clarification is required with regard as to how the club will ‘actively promote and encourage away fans to travel by coach, including implementation and management of segregated coach parking when necessary’. Ongoing work to develop the coach strategy should include the CPT (Confederation of Passenger Transport) and the respective fan clubs. Measures to promote coach travel should be a key element of the travel plan.

94 A coach pick up set down facility should be provided in close proximity to the proposed hotel entrance.

Servicing and Construction

95 TfL requires submission of a Delivery and Servicing Plan (DSP) which should seek to rationalise servicing with the aim to reduce the total number of trips made and to avoid critical times on the road network. TfL welcomes the inclusion of the assessment of construction traffic, however there is no inclusion of mitigation measures that would reduce the impacts of construction traffic and/or reduce the number of construction vehicles such as a consolidation centre or reduction of waste and waste return journeys. Both plans should be secured through section 106 agreement by the borough.

page 17 Travel Planning

96 Six travel plans have been submitted in support of the development: an event day travel plan (EDTP) and five travel plans for the various land uses that will exceed TfL thresholds. Whilst TfL generally welcomes their submission there are still some specific comments;

97 As each individual travel plan relates to a particular land use or scenario, TfL queries why they are referred to as framework travel plans. Accordingly, each travel plan should be evaluated and have passed TfL’s ATTrBuTE tool. Clarification of this matter as well as the respective roles of the Sustainable Travel Manager and the Travel Plan Coordinators should be provided.

98 The monitoring procedure for each plan should be strengthened, particularly for the food store travel plan. TfL is also concerned about the reliance on the completion of infrastructure for the food store, given that the store is expected to open 5 years before the rest of the development. The travel plan should acknowledge that the phasing of foodstore in relation to the other uses. In view of the extensive build out period, a comprehensive monitoring strategy should be devised that takes this into account; TfL can provide examples of best practice upon request.

99 TfL remains concerned that the travel plans will be successful in securing mode share targets, particularly for the events use of the stadium. Although the plans include a considerable number of measures, it is assumed that many of these have already been implemented at the current site. A site wide comprehensive travel plan marketing strategy should also be developed.

100 As with the previous suite of travel plans, TfL is concerned that the respective plans are not sufficiently distinctive; they contain too many generic measures. Accordingly the weaknesses of the travel plans tend to be repeated across each plan. Further discussions are invited in order to further develop these plans. As stated above, TfL also expects the plans to include financial penalties to enforce mode share targets.

101 The submission of a local area management plan (LAMP) is fully supported by TfL in order to assist with mitigation on event days. Further clarification is however required about how the measures to mitigate the development will be secure and how the management of the stadium car park, and the communications strategy, will be implemented.

Mitigation

102 The transport strategy as set out in the various transport assessments provides a number of ‘soft measures’ that will manage the impact of this development. Whilst they are welcomed in principle, they should not be relied to secure modal shift. TfL emphasises that the development must provide increased public transport capacity that should be secured through the section 106 process.

103 Nevertheless, the supporting plans and strategies that have been outlined to deliver the local area management plan should be secured by the borough through by section 106 agreement or planning conditions. They include coach parking and coach strategy, communications plan, signage strategy, controlled parking zone (CPZ) including the extension, stadium car park management strategy, match day staffing and stewarding to the public highway and to rail and underground stations. The mode share targets should also be supported by financial penalties if those targets are not achieved and particularly if the car mode share was not reduced. Funding should be available for public transport improvements above and beyond what is currently provided, as part of any section 106 contributions.

page 18 104 The developer should enter into discussions with TfL about measures to satisfactorily mitigate the development on the existing network; including contributions towards additional bus capacity, public realm and highway improvements together with a substantial contribution towards improvements to Tottenham Hale interchange.

Summary

105 The developer states that their aspiration is for the stadium is ‘to be seen clearly by its visitors as a public transport destination’. If the reduction in car mode split from 40% to 20% is to be achieved, there will have to be a substantial improvement in the public transport offer; both physically and perceptually. Much has been made of the comparison with the Emirates stadium; however this ignores the attraction to drive to Tottenham with excellent links to the main road network.

106 The developer has put forward very ambitious mode shift targets. TfL considers that they can only be achieved if the developer is committed to substantial obligations to deliver the necessary mitigation. The conclusions in the transport assessment alone do not give sufficient confidence that these mode shifts can be achieved, however TfL is committed to the ongoing discussions with the developer and borough to identify the necessary transport improvements that will be key to securing this significant regeneration opportunity. Housing issues

107 The consultation draft replacement London Plan has set an updated housing target of 820 new homes a year in Haringey between 2011 and 2021 (8,200 over the ten year period)3.

108 Proposals for a residential development on the site would contribute to meeting this annual target, however, one of the key differences between the previous application and the revised scheme is a significant reduction in the number of new homes from 434 to 200 units. The latter would be contained in a single, crescent-shaped (east-west orientated) building on the southern portion of the site, rather than the four separate north-south oriented blocks originally proposed.

109 The residential block would sit above a podium designed to contain 121 car parking spaces, cycle parking, waste and recycling facilities. Access would be available from Park Lane. A series of three storey townhouses would line the podium along Park Lane. Access to the podium level adjacent to the residential building would be by a staircase and lift at the eastern and western ends of the block.

110 Strategic policy aims to maximise the development potential of sites, with due regard to the principles of sound design and public transport accessibility. The reduction in the quantum of residential accommodation is contrary to that objective, but has been attributed to the need to revise the application plans to allow the retention of four additional heritage assets; to improve the mix of in favour of larger family units, as suggested in the strategic Housing SPG; and to improve the residential quality (especially space standards and amenity) in line with the Mayor’s Interim Housing SPG (April, 2010).

Residential density

111 The proposed housing would be built at a residential density of approximately 400 habitable rooms per hectare, which is just above midway within the indicative range of 200-700

3 The Consultation Draft Replacement London Plan, Oct. 2009: Table 3.1 Annual Average Housing Provision Monitoring Targets 2011-2021.

page 19 hr/ha suggested in the London Plan density matrix (table 3A.2) for a site in an urban setting, with a public transport accessibility level of four. The proposed density is, therefore, acceptable.

Housing mix

112 Permission is sought in outline form for the residential component of the scheme, with ‘scale’ and ‘external appearance’ reserved for future consideration. An indicative mix of the proposed new housing is as follows:

Number of bedrooms Number of units Percentage 1 56 28 2 56 26 3 49 24.5 4 39 19.5 Total 200 100

113 As the table indicates, 44% of the total accommodation would be family-sized units with three or more bedrooms per unit.

Affordable housing

114 London Plan Policy 3A.10 requires borough councils to seek the maximum reasonable amount of affordable housing when negotiating on individual private residential and mix-use schemes. In doing so, each council should have regard to its own overall target for the amount of affordable housing provision. Policy 3A.9 states that such targets should be based on an assessment of regional and local housing need and a realistic assessment of supply, and should take account of the London Plan strategic target that 35% of housing should be social and 15% intermediate provision, and of the promotion of mixed and balanced communities. In addition, Policy 3A.10 encourages councils to have regard to the need to encourage rather than restrain residential development, and to the individual circumstances of the site. Targets should be applied flexibly, taking account of individual site costs, the availability of public subsidy and other scheme requirements.

115 Policy 3A.10 is supported by paragraph 3.52, which urges borough councils to take account of economic viability when estimating the appropriate amount of affordable provision. The ‘Three Dragons’ development control toolkit is recommended for this purpose. The results of a toolkit appraisal might need to be independently verified

116 Haringey Council has set an indicative site-specific capacity of 500 new homes across the White Hart Lane Stadium site in its UDP policy SSP13 and Table 4.1; and a borough-wide target of 50% affordable housing provision in both the UDP (policy HSG 4) and its Core Strategy (Proposed Submission) document. The threshold above which affordable housing would be sought is on sites with a capacity of 10 or more units in the UDP, and sites with a capacity of 5 units in the proposed Core Strategy.

117 The application has been submitted on the basis that 50% of the total housing provision would be affordable, with a social rented to intermediate (including key worker housing) ratio of 70:30 split in favour of rented tenure. This is in line with the London Plan and UDP policy requirements, though it has not been verified by an appraisal of financial viability that it is also the maximum reasonable amount that could be provided.

page 20 Children’s play space

118 Policy 3D.13 of the London Plan sets out that “the Mayor will and the boroughs should ensure developments that include housing make provision for play and informal recreation, based on the expected child population generated by the scheme and an assessment of future needs.” Using the methodology within the Mayor’s supplementary planning guidance ‘Providing for Children and Young People’s Play and Informal Recreation’ it is anticipated that there will be approximately 165 children within the development. The guidance sets a benchmark of 10 sq.m. of useable child playspace to be provided per child, with under-5 child playspace provided on-site. As such the development should make provision for 1,650 sq.m. of playspace.

119 The submitted plans indicate some private garden/amenity space between the residential block and Park Lane, away from the stadium side of the block. The applicant has indicated in the accompanying planning statement that the scheme would meet or exceed the play space requirements of the Mayor’s SPG (‘Providing for Children’s and Young People’s Play and Informal Recreation’), however, the amenity areas adjacent to the ground floor duplex family flats have not been quantified to allow a proper verification of this against the Mayor’s SPG. Details of all play areas and equipment proposed for those areas should be submitted for assessment prior to any further referral of this application to the Mayor. Urban design and architectural quality Stadium

120 The design of the stadium remains largely unchanged and is supported. It will provide an outstanding iconic new stadium for London. Internally, the stadium is likely to provide a first class environment for watching football that will ideally surpass the existing atmosphere of White Hart Lane.

Listed and non-listed buildings

121 The previous proposal involved the demolition of various listed and non-listed buildings on Tottenham High Road, although a row of listed Georgian terraced houses were to be retained.

122 The previous report advised that GLA officers were satisfied with the case made by the applicants for the demolition of Warmington House and Fletcher House. However, opinion was divided by the applicant’s assertion that the loss of the locally listed buildings (the Red House and the Tottenham and Edmonton Dispensary) and the contribution they make to the Conservation Area was outweighed by the benefits in terms of the setting of the new stadium.

123 The applicant has now revised the scheme to include the retention and re-use of Warmington House; the Red House; the Tottenham and Edmonton Dispensary and 'Valentinos'. Fletcher House and an adjoining terrace (752a - 766 High Road) would still be demolished.

124 The retention of the buildings is welcomed, as it would retain a frontage and focus to Tottenham High Road, which for most of the year will not have football supporters milling about. Additionally, it provides an excellent link with the club's history in the case of the Red House. This will be reinforced by the relocation of the Bill Nicholson gates between 'Valentinos' and the Red House and the relocation of the club's emblem - a Golden Cockerel statue - to a plinth outside Warmington House. The new proposals would enhance the setting of the listed building of Warmington House and the conservation area. Given the wider heritage benefits, the loss of a single listed building (Fletcher House) is considered acceptable and the applicant’s revisions to the scheme are welcomed.

page 21 Public realm

125 The previous approach to the public realm was broadly welcomed although there was concern that the idea of the ‘interactive light poles’ would be an alien concept that was unrelated to football or more especially to Tottenham Hotspur.

126 The proposal has been revised to include a podium at the northern and southern end. It would be approximately 4.5 metres above street level and would be accessed via steps, lifts and ramps from the High Road and Worcester Avenue. The creation of the podium would deliver several benefits to the proposal, including providing space for the club shop and museum. The revised design would also allow continuous pedestrian access all around the stadium - something that the previous proposal did not facilitate. However, to walk around the stadium, various level changes would be required.

127 It is proposed that the podium would be able to host various events such as markets, a temporary ice rink and local community events, all of which should help integrate the space become into the fabric of the area.

128 The detailed design and use of materials would be a crucial factor in determining its success of the podium. A large expanse of tarmac must be avoided.

129 The podium would also allow the creation of a courtyard to the rear of the retained listed buildings. This would provide an entrance to the club shop and museum, contain a pub and cafe and provide another vibrant area to complement the podium above.

Residential development

130 This aspect of the proposal has been submitted in outline so therefore only limited information has been provided.

131 The residential element has been altered from the previous proposal but would still be located at the southern end of the stadium.

132 The new design features a crescent-shaped block, which would enclose the podium level space. It would range in height from 23 metres to 36 metres - this is the equivalent of around 12 storeys (reduced from 13 to 19 storeys).

133 The architects have advised that it would be curved to echo the form of the stadium and to reduce its presence on Park Lane. The entrances to the homes would be from Park Lane and are intended to function securely on both match and non-match days. There would be private garden space on Park Lane for the sole use of residents together with balconies and upper terraces.

134 The architects have advised that there would be no single-aspect north-facing units, only dual-aspect or single-aspect south-facing units. The detailed illustrative layouts have been tested to ensure that GLA space standards and ‘Lifetime Homes’ requirements can be met. It would be beneficial to have copies of this material before any future referral of this scheme back to the Mayor.

135 Buildings would be split into three horizontal massing elements consisting of street zone, main elevation, and upper set back or articulation.

136 Previously, the overall approach to the design of the residential part of the proposal was supported. To respond to the new stadium, a bold approach had to be taken to create a residential development that would be attractive in its own right and not too dissimilar in terms of bulk and

page 22 massing. It was recognized, however, that the scale of buildings would be very different from the existing residential surrounding. The overall height, scale and mass of the revised scheme has been reduced as a consequence and the new design and layout simplified to form a slim, elegant crescent-shaped building that has a better relationship with the new football stadium and the existing buildings to the south.

Hotel development

137 This aspect of the proposal has also been submitted in outline so only limited information has been provided.

138 When the Deputy Mayor considered the previous proposal, he specifically requested alterations to the design of the elevation of the hotel. The location of the hotel part of the proposal has been moved from the south -western side of the development to the south - eastern side. It would be 10-storeys with reception and bar areas on lower floors and entrances on both Worcester Avenue and from the podium level. Indicative sketches show that it is likely to have a curved exterior with articulation through a series of layers. The scale of the hotel is similar to that of the stadium and the maximum height of the residential block; and the three buildings should work well together in the townscape. The indicative approach to bulk, massing and design is supported.

Supermarket development

139 The previous proposal was designed as a large glazed elevation, split into bays by the building’s structure. The previous report stated that it was disappointing that the supermarket would not contain more active uses along its frontage or make more use of the roof space including the potential for residential development.

140 The revised proposal is 2-storeys high on Northumberland Park and 3-storeys high next to the stadium. The new proposal would have the food store (around 8,000 sq.m.) and a restaurant at ground floor level. The upper floors would be used as offices for the football club as well as amenity and hospitality areas.

141 The massing and bulk is an appropriate response to the location. The building has also been refined to provide greater articulation and interest - not only by the use of the upper floors but also the introduction of vertical glazed bays.

142 The absence of residential uses on the upper floors on this frontage, forming a veneer to the Sainsbury’s store is disappointing; however, balanced against the other significant design benefits elsewhere in the scheme, it is considered acceptable.

143 Overall, the spaces and buildings within the site have a far clearer relationship with each other and their neighbours than was previously the case. The retention of listed and locally listed buildings and their integration into the masterplan is a significant benefit, and the scheme would inject a much-needed lift to the local environment. Inclusive design and access

144 Inclusive design principles, if embedded into the development and design process from the outset, help to ensure that all of us, including older people, disabled and deaf people, children and young people, can use the places and spaces proposed comfortably, safely and with dignity. The aim of London Plan Policy 4B.5 (Policy 7.2 in the draft replacement London Plan) is to ensure that proposals achieve the highest standards of accessibility and inclusion (not just the minimum).

page 23 145 The design and access statement (DAS) submitted with this application clearly sets out the design thinking behind the application and demonstrates that the principles of inclusive design, including the specific access needs of disabled people, have been taken into account in the proposed development - the DAS makes reference to CABE’s Principles of Inclusive Design and the LDA’s Inclusive Design Toolkit and states that an inclusive design philosophy has been adopted.

146 The applications have appointed an access consultant at the masterplan stage, which is welcomed as close collaboration between the access consultant and the design team can help to ensure that inclusive design principles are embedded from the outset and implemented throughout the design process. This commitment to inclusive design has also been demonstrated by the willingness of the applicants to consult with disabled people by setting up a Consultative Access Group (CAG) with representatives from the National Association of Disabled Supporters (NADS), local Tottenham disabled supporters and local community and disability organisations. This engagement has already resulted in some changes in the design to improve accessibility, including the provision of additional lifts to ensure that a large public passenger lift is located beside each of the proposed external staircases in the public realm. The role, function and terms of reference for this Consultative Access Group should be tied down by planning condition or Section 106 agreement and should ideally be based on similar agreements made for other successful strategic access groups such as at Stratford City and the Olympic Park, to include for example consulting the Consultative Access Group prior to submission of any reserved matters applications.

147 Although the DAS includes much constructive information about accessibility, a detailed Inclusive Access Strategy, which sets out the arrangements to implement, monitor and review the commitments to inclusive access should be prepared, in consultation with the Consultative Access Group, and submitted to the Local Planning Authority for approval, to ensure that the inclusive access commitments are met and followed through in the detailed design, construction and management arrangements for the development. This Inclusive Access Strategy should addresses issues such as how accessible the local public transport connections are, including local rail and tube stations and bus links; the provision of an adequate number of suitably located blue badge bays for both visitors, employees and residents for all the buildings within the development (a parking management plan should address how these BB bays will be monitored and reviewed to ensure future demand can be met and how they will be managed to stop abuse by non badge holders); how the key features of wheelchair accessible housing are to be met in the design of the new housing units - the commitment to fully meet the Lifetime Homes Standards is welcomed (the applicant should note that the revised LTH standards were published by Habinteg Housing Association on 5 July see www.lifetimehomes.org.uk ); how the hotel development will achieve at least 10% of hotel bedrooms as wheelchair accessible; the detailed design of the public realm including street furniture and lighting; the number, location, design, sightlines and flexibility of use of the wheelchair spaces and amenity seats in the stadium and the ability to expand their numbers in the future to meet demand.

148 Further consideration needs to be given to some aspects of the public realm to ensure that the highest standards of accessibility have been achieved, including the detailed design of the stairs up to podium level (e.g. handrails, step nosings, depth and height of treads). It is appreciated that the proposed vehicular ramps leading up to both the north and south podiums cannot be designed to be fully wheelchair accessible due to the height of the level change, they are however a welcome addition as many people including some powered wheelchair and mobility scooter users, and people with prams and pushchairs may wish to use these ramps instead of the lifts or stairs. Their design should therefore be as pedestrian friendly and as gentle as possible – particularly as the route on the south side is likely to be used by local people going to and from the school on the other side of the site and by many disabled people visiting the new offices of the Tottenham Hotspur Foundation whose entrance is proposed at podium level. Use of these ramps by vehicles will need to be carefully managed to ensure they remain accessible and safe to

page 24 pedestrians at all times. The detailed design of the entrance into the Foundation should be further considered to ensure that there is no conflict between trying to achieve a stepped but accessible viewing area of the adjacent flexible play/ sports space and an inclusive entrance into the Foundation’s offices. The VIP entrance into the stadium on the high road appears to be stepped with no alternative ramped route and should be further considered. The security barrier elements in the public realm should be designed so that they are not potential hazards to visually impaired people and the seating should be easily used by all. The detailed design of the shared surface in Worcester Avenue may need to consider installing tactile paving or some other suitable delineator to ensure that pedestrians using this road can identify a ‘safe’ zone to provide confidence for visually impaired pedestrians.

149 Debate has already taken place at the first meeting of the CAG on the number, location and design of the dedicated wheelchair spaces and amenity (easy access) seats in the stadium. The DAS confirms that the current proposals will meet the minimum standards set out in Accessible Stadia and in the Building Regulations. However, disabled members of the CAG are keen to ensure that not only is the current waiting list of disabled supporters met in the new development but that there is flexibility to ensure that future demand from disabled supporters (both home and away fans) are met. This issue should therefore be further considered and issues such as how the dedicated spaces are distributed between general admissions, hospitality and the media etc and how flexibility to allow groups of disabled people or families with one or two disabled members can sit together comfortably with suitable sightlines to the field of play.

150 The improvements to make the four listed buildings more accessible are welcomed. Three of these buildings will now have ramped or level access to their ground floors. The proposals do not however, enable the ground floor of Warmington House to be made wheelchair accessible. Although the remodelling of the entrance steps to have gentler easy access steps is welcomed further discussions with the CAG to consider if there is any possibility of future proofing the design to enable access to be improved at a later date if needed should be considered. Climate change mitigation

Energy

151 The proposed energy strategy has been retained from the previous application and is likely to satisfy the requirements of the London Plan energy policies if the following issues were addressed before any further referral of this case back to the Mayor:

 The applicant is still using benchmarks that do not relate to a Building Regulations 2006 compliant building. The applicant should update the baseline figures in line with a 2006 compliant development.

 Savings at each stage of the energy hierarchy have been estimated. Where possible, the applicant should also relate the development to 2010 building regulations by providing an indication of the savings over a 2010 Part L compliant building at each stage of the energy hierarchy.

 It is not clear from the submitted load profiles what proportion of the heat would be met from combined heat and power (CHP) and biomass boilers. The applicant should provide monthly heat profiles showing this to demonstrate that CHP has been optimised prior to the consideration of renewable forms of provision.

page 25  The applicant has indicated that cooling would be met from a district-cooling network fed from CCHP and absorption chillers. The applicant should however provide details of how the need for active cooling would be minimised. Air quality implications

152 London Plan policy 4A.19 (Improving air quality) seeks to ensure that air quality is taken into account in planning applications along with other material planning considerations, and that formal air quality assessments should be undertaken where appropriate, particularly in designated Air Quality Management Areas (AQMAs). Draft Replacement London Plan policy 7.14 Improving air quality states that development proposals should aim to be ‘air quality neutral’ and not lead to further deterioration of existing poor air quality, that offsetting should be used to ameliorate negative impacts associated with development proposals, and that increased exposure to existing poor air quality should be minimised.

153 The air quality assessment submitted by the applicant has been reviewed and is considered robust. However, there are implications for local air quality should this development proceed, and air quality within an Air Quality Management Area for NO2 and PM10 would be affected. Further information is sought from the applicant prior to stage two application regarding the on site energy centres.

154 Policy 8 within the Mayor's draft Air Quality Strategy (currently released for public consultation) requires abatement technology for PM10 to be fitted as standard in AQMAs to address the cumulative effect of individual developments. As Haringey Council has declared a borough-wide AQMA for PM10, this policy would be applicable for the proposed development. Further evidence should be provided by the applicant to show that PM10 abatement technology has been included for the biomass combustion within the scheme. Additionally, the assessment shows that the on site diesel generators contribute significantly to exceedances of the hourly NO2 objective at two receptors. As NO2 is a concern within Haringey Council, it is considered that the mitigation measures included in the assessment are not yet sufficient. More evidence is required to show how the emissions will be minimised and controlled, including consideration of other energy sources for match days.

Local planning authority’s position

155 The date for reporting this application to the Council’s planning committee had not been ascertained at the time of writing.

Legal considerations

156 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

page 26 157 There are no financial considerations at this stage. Conclusion

158 London Plan policies on land use, the mix of uses, regeneration, transport, retail and town centre development, employment, housing, urban design, inclusive access, air quality and energy are relevant to this application. The application complies with some of these policies but not with others, for the following reasons:  Principle of development/world city role/regeneration/sports facilities/hotel/retail: Compliance with London Plan policies 1.1 (‘London in its global, European and UK context’); 2A.7 (‘Areas for regeneration’); 3D.6 (‘The Olympic and Paralympic Games and sports facilities’) and 3D.7 (‘Visitor accommodation and facilities’).  Transport: See paragraphs 53- 106 above.  Housing: Compliance with London Plan policies 3A.1 (‘Increasing London’s supply of housing’); 3A.5 (‘Housing choice’) following significant change to the housing mix in favour of larger family–sized units, and 3A.10 (‘Negotiating affordable housing in individual private residential and mixed-use schemes’). The proposed children’s play space needs to be located and quantified to ensure full compliance with policy 3D.13 (‘Children and young people’s play and informal recreation strategies’).  Urban design: Compliance with London Plan policies 4B.1 (‘Design principles for a compact city’), 4B.2 (‘Promoting world class architecture and design’) 4B.3 (‘Enhancing the quality of the public realm’), 4B.5 (‘Creating an inclusive environment’) ; 4B.6 (‘Safety, security and fire prevention and protection’) and 4B.10 (‘Large scale buildings – design and impact’)

Significant revisions have been carried out the design of the supermarket, which now complies with the aims of the London Plan design policies.

 Access/equal opportunities: Some additional work, described in paragraphs 145 to 151 of this report, would need to be carried out to ensure full compliance with London Plan policy 4B.5 (‘Creating an inclusive environment’).

 Climate change: Compliance with London Plan policies 4A.1 (‘Tackling climate change’); 4A.4 (‘Energy assessment’); 4A.7 (‘Renewable Energy’); 4A.9 (‘Adaptation to Climate Change’), although further information (highlighted in four bullet-points in paragraph 152 above) is required.

 Air quality: Additional information is required to address the air quality concern identified in paragraphs 153 to 155 above, and to ensure full compliance with London Plan policy 4A.19 (Improving air quality).

for further information, contact Planning Decisions Unit: Colin Wilson, Senior Manager - Planning Decisions 020 7983 4783 email [email protected] Justin Carr, Strategic Planning Manager (Development Decisions) 020 7983 4895 email [email protected] David Blankson-Hemans, Senior Stratgeic Planner (Case Officer) 020 7983 4268 email [email protected]

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