planning report GLA/0543h/01 10 December 2019 Grahame Park Estate, Plots 10, 11 and 12 in the London Borough of Barnet planning application no. 19/5493/OUT
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 Estate regeneration comprising demolition and redevelopment to construct up to 2,088 residential units and up to 5,950 sq.m. of flexible non-residential use, within buildings ranging in height from 3 to 15 storeys, together with associated parking and landscaping The applicant The applicant is Choices for Grahame Park and the architect is Patel Taylor Strategic issues Principle of estate regeneration: The application complies with the requirement for the like for like replacement social rented floorspace and would provide an increase in terms of social rent accommodation by floorspace and habitable rooms (paragraph 21 to 33). Land use principle: Further housing intensification of the site is supported, as is the proposed quantum of flexible commercial and employment use. The approach to social infrastructure reprovision is supported, subject to further discussion on the wording of any Section 106 agreement. Amendments to Heybourne Park would result in a net loss of open space; however, this is acceptable given the overall net increase in open space proposed across the site and the comprehensive qualitative landscape improvements proposed to the park itself (paragraphs 34 to 48). Housing and affordable housing: 50% affordable housing by habitable room, comprising a 38:62 tenure split between social rent/London Affordable Rent and intermediate shared ownership is supported in principle, subject to this being verified as the maximum viable level of affordable housing and further discussion on any Section 106 agreement to ensure the affordable housing is secured in perpetuity. Early, Mid and Late Stage Viability Review Mechanisms should be secured given the size and timescales for the development. Affordability levels for shared ownership and low cost rent units should be confirmed and secured (paragraphs 49 to 61). Urban design and heritage: The design, layout, density, height and massing of the proposed scheme is strongly supported and the proposed development would not harm heritage assets. (paragraphs 62 to 76). Climate change: The applicant’s strategies in relation to energy, drainage and urban greening are supported subject to conditions and obligations being secured (paragraphs 77 to 80). Transport: Car parking and cycle parking would comply with the draft London Plan. A financial contribution of £900,000 is required to mitigate the impact on bus capacity (via two phased payments). A contribution of £160,000 is required towards improvements to Colindale station to mitigate the impact of the scheme. Conditions are required in relation to bus stop location and design, construction, deliveries, travel planning and car parking and cycle parking. (paragraph 81 to 89).
page 1 Recommendation That Barnet Council be advised that the application does not yet fully comply with the London Plan and draft London Plan, for the reasons set out in paragraph 93 of this report; however, the possible remedies set out in that paragraph could address those deficiencies.
page 2 Context
1 On 31 October 2019, the Mayor of London received documents from Barnet 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 must 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.
2 The application is referable under the following categories of the Schedule to the Order 2008:
• Category 1A: “Development which comprises or includes the provision of more than 150 houses, flats, or houses and flats.”
• Category 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 - outside Central London and with a total floorspace of more than 15,000 square metres.”
• Category 1C: “Development which comprises or includes the erection of a building of…more than 30 metres high and is outside the City of London.”
• Category 3A: “Development which is likely to— (a) result in the loss of more than 200 houses, flats, or houses and flats (irrespective of whether the development would entail also the provision of new houses or flats).”
3 Once Barnet 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 2017 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 is 13.3 hectares in size and is located within the Colindale/Burnt Oak Opportunity Area and comprises Plots 10, 11 and 12 of the Grahame Park Estate and the adjacent Heybourne Park open space. The site contains 630 existing residential units across 22 blocks ranging in height from 2 to 8 storeys, as well as non-residential ground floor retail, commercial, community and health uses located within the Concourse Neighbourhood centre. The site also includes a large energy centre building and the Greentops Centre within Heybourne Park which provides after school childcare provision. The site is bounded by Great Field and St Augustine’s Church to the north; Percival Avenue to the south; and Heybourne Crescent and Lanacre Avenue to the west. To the east the site is bounded by Corner Mead, residential properties adjacent to the Woodland Walk and St Margaret Clitherow Church. The site boundary is shown below in Figure 1.
7 The site is predominantly covered by Public Transport Access Level (PTAL) 2 (on a scale of 0 to 6b where 6b represents the highest level of access to the public transport), with areas of PTAL 3 found to the south and around the Quakers Close bus stop. This bus stop provides access to routes page 3 186, 204, 303 and N5. In addition to this, bus routes 632 and 642 can be accessed from Corner Mead to the north east. The nearest underground station is Colindale on the Edgware branch of the Northern Line, 800 metres to the south west. National Rail services can also be accessed from Mill Hill Broadway, 1.5 kilometres to the north. Burnt Oak station on the Edgware branch of the Northern line is a similar distance from the site to the west.
8 The site does not include any listed buildings and is not located within a conservation area; however, Watling Estate Conservation Area is located to the north and comprises a large expanse of inter-war housing built by London County Council during the ‘homes for heroes’ building programme which followed the First World War. The closest Statutory listed building to the site is the Grade II listed Royal Airforce Officers’ Mess Building to the south.
9 In terms of the existing and emerging context, a significant amount of development and regeneration has been undertaken within the Opportunity Area, including the development at the former Barnet College Site (Trinity Square development); Beaufort Park development; the Peel Centre (Colindale Gardens); and sites around Colindale Station. The adjacent Douglas Bader Park Estate to the west of Clayton Field is also the subject of redevelopment proposals. These proposals are being brought forwards by the owner of that site – Home Group (who are a registered provider) - and have been subject to public consultation.
Details of the proposal
10 The application seeks hybrid planning permission for the demolition and redevelopment of Plots 10-12 of the Grahame Park Estate to provide up to 2,088 residential units and up to 5,950 flexible non- residential use, within buildings ranging in height from 3 to 15 storeys, together with associated landscaping, car parking, cycle parking and public realm. This comprises two elements:
• Full (detailed) planning permission for the demolition and redevelopment of Plot A to construct 5 buildings between 3 and 11 storeys in height comprising 209 residential units and 440 sq.m. of flexible non-residential floorspace in Class A1, A2, A3 and B1 use.
• Outline planning permission for the demolition and phased redevelopment of the remaining Plots B to Q to construct up to 1,879 residential units and up to 5,510 sq.m. (GEA) of flexible non- residential floorspace within Class A1, A2, A3, A4, B1, D1 and D2 use, including a community centre, nursey within buildings ranging in height from 3 to 15 storeys.
Figure 1 – application site boundary showing outline and detailed phases
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11 The proposed development is underpinned by an indicative Masterplan prepared by Patel Taylor which covers both outline and detailed components. Subsequent detailed reserved matters applications (RMAs) will be brought forwards for Plots B to Q in relation to matters of scale, layout, landscaping and appearance, which would not be referred to the Mayor. The RMAs would be guided by a design guideline document and parameter plans, which set out mandatory and advisory design rules and specifications.
Background
12 The Grahame Park Estate was constructed in the 1970s by the GLC on the site of the former Hendon Aerodrome and is Barnet’s largest housing estate. Barnet Council is the freehold landowner of the site; however, it is subject to a development agreement with Notting Hill Genesis signed in 2002, who are the Council’s development partner. The applicant – Choices for Grahame Park – is a subsidiary company of Notting Hill Genesis. The original estate comprised 1,365 social rented homes. The wider Grahame Park Estate is shown below in Figure 2.
Figure 2 – wider Grahame Park Estate Regeneration phases
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13 Stage A of the estate regeneration has been completed and include 685 new homes, Barnet and Southgate College, Colindale Library, a local supermarket and Barnet Council’s new offices on Bristol Avenue. Stage A also includes a number of smaller infill developments shown in yellow in Figure 2. In addition to this, part of the initial decant of social rented households from the estate was undertaken as part of the Adastral development which is also shown in Figure 2, to the west of the site. Stage B covers the remainder of the estate; however, this is also broken down into Plots 10 to 21, of which Plots 10 to 12 comprise the first phase. Whilst Plots 13 to 16 are expected to come forward over the longer term; Plots 17 to 21 are not expected to come forward for development.
Case history
page 6 14 On 23 November 2017, Barnet Council resolved to grant planning permission for the proposed redevelopment of Plots 10, 11 and 12 of the Grahame Park Estate over three phases (LPA ref: 17/2840/OUT; GLA ref: D&P/0543g). This hybrid application was submitted by Notting Hill Genesis and sought planning permission for the demolition of 630 residential units, health centre, community hall, library and retail units and the construction of 1,083 residential units; a community hub (comprising a community hall and workshop rooms, a daycare nursery, a GP health centre, community health facilities and ancillary office accommodation); along with cafe; retail space; a flexible ground floor space; a new energy centre; and associated car parking, open space, landscaping and access arrangements. In terms of affordable housing, this application proposed 39 social rent units, 153 London Affordable Rent units, 166 London Living Rent units and 294 shared ownership units. This represented an overall affordable housing offer of 60% by unit, with a 29:71 tenure split weighted towards intermediate housing provision.
15 On 18 December 2017, the Mayor issued a Direction to Barnet Council to refuse planning permission, for the following reasons:
• Affordable housing provision: The application demonstrably fails to replace the existing affordable housing on either a unit, floorspace or habitable room basis, and results in the loss of 257 existing social rented units. The proposals are therefore contrary to London Plan Policy 3.14, draft London Plan Policy H10, the Mayor’s Affordable Housing and Viability SPG and the Mayors draft Good Practice Guide to Estate Regeneration.
• Transport: In the absence of a planning obligation that provides a minimum of £840,000 to deliver additional bus capacity, the impact of additional peak hour trips on the bus network in this area remain unmitigated and are likely to have an unacceptable impact on the public transport network, as well as failing to ensure that alternatives to the private car are accessible and appealing, contrary to London Plan policies 6.3 and 8.2 and draft London Plan policies T3 and DF1.
16 In directing the Council to refuse the application, the Mayor set out his firm view that it is possible for the proposals to be successfully amended to better optimise the development and housing potential of the site and ensure that replacement social rented housing and necessary transport mitigation is secured. Since this time, the applicant has worked with Barnet Council and the GLA to bring forward a revised planning application to address the issues raised in the Mayor’s Stage 2 report. The applicant has commissioned a new design team (Patel Taylor) and planning consultant (hgh) to bring forward a revised masterplan which effectively doubles residential density of the refused scheme and seeks to ensure the like-for-like re-provision of affordable housing. This revised scheme has been subject to design review and has been developed through a series of informal pre- application meetings with GLA, TfL and Barnet Council officers during 2018 and formal GLA pre- application meetings during June and July 2019.
17 On 27 August 2019, a formal GLA pre-application advice was issued. In summary, this supported the principle of the redevelopment of the site, subject to further information being provided in relation to community uses, affordable housing and further details to verify the scheme’s compliance with the Mayor’s principles for estate regeneration. The revised affordable housing offer was considered acceptable in principle, subject to viability review mechanisms being secured and further scrutiny of the applicant’s Financial Viability Appraisal. The height, massing, density and overall layout and design of the revised scheme was strongly supported; however, the applicant was required to revisit the park edge conditions to ensure active frontages are provided. Further information and assessments are required in relation to residential quality, urban greening and play space provision. In relation to transport, compliance with the draft London Plan parking and cycle
page 7 parking standards is encouraged and further discussion was required in relation to public transport mitigation and bus infrastructure.
Strategic planning issues and relevant policies and guidance
18 For the purposes of Section 38(6) of the Planning and Compulsory Purchase Act 2004, the development plan in force for the area is Barnet’s Local Plan (Core Strategy) Development Plan Document (2012); the Local Plan (Development Management Policies) Development Plan Document DPD (2013); the Colindale Area Action Plan (2010); and the London Plan 2016 (The Spatial Development Strategy for London Consolidated with Alterations since 2011).
19 The following are also relevant material considerations: • The National Planning Policy Framework (2019) • National Planning Practice Guidance • The Grahame Park Supplementary Planning Document, (2016) • the Draft London Plan – Consolidated Suggested Changes Version (July 2019). The Panel of Inspectors appointed by the Secretary of State issued their report and recommendations to the Mayor and this was published on the GLA website on 21 October 2019. In line with paragraph 48 of the NPPF, the weight attached to the draft London Plan should reflect the stage of its preparation; the extent to which there are unresolved objections to relevant policies; and the degree of consistency of the relevant policies in the emerging Plan to the NPPF • the Mayor’s Good Practice Guidance Guide to Estate Regeneration (GPGER)
• The Mayor’s Affordable Housing and Viability SPG.
20 The relevant issues and corresponding strategic policies and guidance are as follows:
• Principle of estate London Plan; the Mayor’s Good Practice Guide to Estate redevelopment Regeneration (2018); • Housing and affordable London Plan; Affordable Housing and Viability SPG; Housing housing SPG; the London Housing Strategy (2018); • Play space London Plan; Children and Shaping Neighbourhoods: Play and Informal Recreation SPG; • Urban design London Plan; Shaping Neighbourhoods: Character and Context SPG; Housing SPG; • Historic environment London Plan; • Inclusive access London Plan; Accessible London: Achieving an Inclusive Environment SPG; • Climate change, flood London Plan; Sustainable Design and Construction SPG; the risk and drainage London Environment Strategy (2018); • Transport London Plan; the Mayor’s Transport Strategy (2018);
page 8 Principle of estate regeneration
21 Strategic policies relating to the replacement of existing housing and estate regeneration are set out within London Plan Policy 3.14, draft London Plan Policy H10, with further guidance provided in the Mayor’s Affordable Housing and Viability SPG and the Mayor’s Good Practice Guide to Estate Regeneration (GPGER). London Plan Policy 3.14 states that the loss of existing housing, including affordable housing, should be resisted unless it is replaced at existing and higher densities with at least equivalent floorspace. Policy H10 of the draft London Plan seeks to resist the demolition of affordable housing unless it is replaced by an equivalent amount of affordable housing floorspace, affordable housing floorspace reprovided on a like for like basis and integrated into the development to ensure mixed and inclusive communities. All estate regeneration schemes involving the demolition and replacement of affordable housing are required to follow the Viability Tested route and should seek to provide a net uplift in affordable housing in addition to minimum requirement for replacement affordable housing floorspace. GLA officers now afford draft London Plan Policy H10 significant weight in view of the conclusions of the Inspectors’ Panel Report.
22 As set out in the draft London Plan, all estate regeneration schemes should take into account and reflect the following key principles set out in the Mayor’s Good Practice Guide to Estate Regeneration (GPGER) which apply to all estate regeneration schemes in London: • like for like replacement of existing affordable housing floorspace • an increase in affordable housing • full rights of return for any social housing tenants • fair deal for leaseholders/freeholders • full and transparent consultation and involvement.
Assessment of the existing social rented provision
23 The applicant has provided a detailed note setting out how the existing social housing provision has been assessed in terms of floorspace and habitable rooms. This information is based on a combination of measured floorplans by qualified surveyors and, where this information is not available, floorspace has been estimated based on current London Plan minimum space standards. This has been a significant undertaking given the size and age of the estate and GLA officers consider that the review undertaken by the applicant is robust and provides an accurate assessment of the existing social housing provision for the purposes of assessing compliance against Policy H10 of the draft London Plan.
24 The original Grahame Park Estate comprised 1,365 social rented properties in 2004. However, not all of these residential units are currently proposed for demolition or redevelopment and a number of social rented properties have been acquired under the Government’s Right to Buy scheme. The baseline requirement for social rent reprovision in Stage A and this application is set out below.
Table 1 – baseline requirement for reprovision across both Stage A and this application Habitable Homes Floorspace rooms Social rent homes on original estate (2004) 1,365 4,191 97,444 Homes within the estate which are not 635 2,321 49,525 proposed for redevelopment at this stage Right to Buys since 2004 42 135 3,141
page 9 Social rent requiring reprovision as part of 688 1,735 44,778 Phase A and this application
Like for like replacement
25 As set out above, the loss of existing affordable housing should be resisted unless it is replaced by an equivalent amount of affordable housing floorspace (with no overall net loss). This principle applies to all existing affordable housing floorspace including both occupied and vacant units, regardless of the quality of the current stock. Policy H10 of the draft London Plan confirms that replacement affordable housing must be provided at social rent levels, where it is being provided to facilitate a ‘right of return’ for existing social rent tenants. Where existing social rented floorspace is being replaced and there is no right of return for the existing residents, it may be re-provided as London Affordable Rent, for example, where the existing units are being used for temporary short term let accommodation, where the existing residents do not benefit from a ‘right to return’.
26 The applicant has provided the following information in relation to the reprovision of existing affordable housing across the entire Grahame Park Estate, which is set out below. This demonstrates that there would be a significant net increase in terms of existing low cost rented floorspace (social rent/LAR) and in terms of habitable rooms. This accords with the requirement for like for like re- provision in terms of floorspace, in line with Policy H10 of the draft London Plan and the Mayor’s Good Practice Guide. Whilst there would be a moderate net decrease of 4 units, the proposals comply with the key metric for assessing like for like re-provision (which is floorspace), as set out in Policy H10 of the draft London Plan. The proposed affordable housing provision includes the replacement affordable housing already delivered in Stage A and at the Adastral scheme and that proposed in this application, details of which are provided below.
Table 2 – Existing and proposed housing in social rent/London Affordable Rent (covering the entire Grahame Park Estate)
Existing Proposed Net change Floorspace (sq.m.) 44,778 47,578 +2,800 Habitable rooms 1,735 2,128 +393 Units 688 684 -4
Replacement social rent/London Affordable Rent provision
27 The total quantum of reprovided social rent/LAR includes: social rent/LAR units proposed within this application (Plots 10-12); social rent units completed in Stage A; social rent units completed within the Adastral scheme in 2004-5; and 8 market tenure houses within the estate which have been purchased by NHG and let by NHG at social rent. GLA officers have confirmed that the social housing provision at Adastral can count towards the like for like re-provision on the Grahame Park Estate, as it has been demonstrated that this site was part of the wider Grahame Park Estate regeneration programme and enabled the initial decanting of social rent tenants. The approach to purchasing market houses within the wider Grahame Park Estate (in locations which are not earmarked for redevelopment at this stage) is acceptable, subject to these being secured in social rent tenure and at target social rent levels in perpetuity. The applicant has stated that they would agree to this obligation being included in the Section 106 agreement.
Table 3 - Proposed affordable housing provision (across the entire Grahame Park Estate) page 10 Units Floorspace Social rent/London Affordable Rent in Plots 10-12 346 21,289 Stage A social rent 231 16,962 Adastral 99 8,580 Market houses acquired by Notting Hill Genesis and let as social rent 8 747 Total 684 47,578 Full right of return or remain for social tenants
28 The GPGER seeks to ensure that social tenants have a full right to return to a property on the regenerated estate of a suitable size, taking into account levels of overcrowding or under-occupancy within each household, and at the same or similar rent level, with the same security of tenure. The applicant has stated that there are 33 existing social rent units on secure tenancies who would benefit from a ‘right to return’ via a single move and with replacement properties provided to match individual household needs in terms of occupancy. This is acceptable. Target social rent levels would need to be secured by Section 106 agreement for all of these ‘right to return’ units. There are a further 350 social rented units which are let on short-term non-secure tenancies, where the existing residents do not benefit from a ‘right to return’. The remaining social rented accommodation are either vacant or occupied by property guardians, having already been subject to decant and buy back process which has been undertaken. All of the social rented accommodation which is currently let by non-secure social housing tenants, or is vacant or occupied by property guardians would be replaced by London Affordable Rent accommodation. This is acceptable, in accordance with Policy H10 of the draft London Plan.
Phasing of affordable housing delivery
29 In terms of phasing, the first phase of the proposed development (which is the detailed element – Plot A) would be 100% affordable housing, comprising all 33 social rent units and a further 149 shared ownership units. This would enable all of the existing social rented tenants who have a ‘right to return’ to move into a replacement home in one move and is strongly supported. As requested at pre-application stage, the applicant has set out the phasing programme for the remaining LAR units, which is set out below. This demonstrates that the remaining low cost rented floorspace in LAR tenure would be maintained across all phases which is acceptable. Appropriate phasing triggers should be included in any Section 106 agreement to ensure this is achieved.
Table 4 – affordable housing phasing programme Social Shared % affordable by Market Total rent/LAR ownership phase Phase 1 60 149 219 428 49% Phase 2 83 245 531 859 25% Phase 3 203 305 293 801 40% Total 346 699 1,043 2,088 50%
Figure 3 – Phasing plan
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Fair deal for leaseholders and freeholders
30 The GPGER seeks to ensure that leaseholders and freeholders affected by estate regeneration are treated fairly and fully compensated and sets out the Mayor’s preference that these units should be acquired by negotiation in the first instance and subject to an independent valuation paid for by the applicant. There are 20 leasehold properties on the estate which remain to be purchased. The applicant has confirmed that these properties would be subject to independent valuation, with leaseholders also provided with a statutory home loss payment of 10% for resident leaseholders and 7.5% for non-resident (landlord) leaseholders. In addition, the valuation, legal fees and stamp duty costs would be paid for by the applicant. This accords with the principles set out in the GPGER.
Full and transparent consultation
31 The GPGER sets out the Mayor’s aspirations for full and transparent consultation, and meaningful ongoing involvement with estate residents throughout the regeneration process, to ensure resident support. From 18 July 2018, the Mayor requires any landlord seeking GLA funding for estate regeneration projects which involve the demolition of existing affordable or leasehold homes to demonstrate that they have secured resident support for their proposals through a ballot, subject to certain specified exemptions and transitional arrangements.
32 In this instance, GLA funding is involved in the scheme; however, the GLA has exempted the scheme from undertaking a ballot as the funding was committed prior to 18 July 2018. GLA officers also note that a historic ballot did take place in 2003 which informed the scope of the proposals. Furthermore, as requested at pre-application stage, the applicant has provided further details of public consultation which has been undertaken with residents between 2015 and the present day, both as part of the wider regeneration programme, the preparation of the Grahame Park SPD, and as part of this application. GLA officers consider the approach accords with the key principles set out in the GPGER. Whilst considerations around ballots and funding conditions are not planning issues, the Mayor encourages landlords to use ballots as widely as possible in line with his Good Practice Guide.
Conclusion – Principle of estate regeneration
33 In summary, GLA officers welcome the applicant’s response to the Mayor’s SPG, draft London Plan and GPGER, which is considered to comply with this policy and guidance and overcome the previous reason for refusal concerning the loss of social rented housing. The revised development page 12 proposals comply with the requirement for the like for like replacement social rented floorspace, and provide an increase in existing social housing provision in terms of floorspace and habitable rooms, in accordance with London Plan Policy 3.14 and Policy H10 of the draft London Plan.
Land use principle
Local Plan context
34 The site is within the Colindale/Burnt Oak Opportunity Area and falls within the Colindale Regeneration and Growth Area, set out in the Barnet Local Plan (2012) and is also covered by the Grahame Park SPD (adopted in July 2016) and Colindale Area Action Plan (adopted in March 2010). Collectively, the Barnet Local Plan, AAP and SPD promote the phased redevelopment of the majority of the estate to provide a significant net uplift in housing provision and to create a vibrant and inclusive mixed use and mixed tenure neighbourhood, based around a clearer street network, including replacement commercial and community uses, enhanced open spaces and with improved pedestrian, cycle and public transport connections.
Opportunity Area context
35 The London Plan identifies the Colindale/Burnt Oak Opportunity Area as having an indicative capacity to accommodate 12,500 homes and 2,000 jobs (covering the period 2011 to 2031). The draft London Plan sets the Opportunity Area an indicative capacity guideline for 7,000 homes and 2,000 jobs to 2041. These updated figures are based on updated development capacity studies which reflect the number of approved homes now completed in the opportunity area. In line with London Plan Policy 2.13 and draft London Plan Policy SD1, the proposed development should optimise potential residential and non-residential development capacity, provide an appropriate mix of uses and support wider regeneration and provision of mixed and inclusive communities. The proposed development responds positively to these broad policy objectives and would make a substantial contribution towards achieving the strategic planning aspirations in terms of housing delivery and employment.
Housing supply
36 To achieve housing targets, both London Plan Policy 3.3 and Policy H1 of the draft London Plan emphasise the need to optimise potential housing delivery on brownfield sites through higher density residential development. This extends to include the sensitive intensification of brownfield sites in residential use, subject to a scheme’s compliance with London Plan and draft London Plan policies which cover estate regeneration and redevelopment of the existing housing stock. The proposed scheme would provide a substantial net uplift of 1,458 net additional homes, more than doubling the number of existing residential units on site and thereby making a significant contribution towards achieving local and strategic housing targets.
Non-residential uses
37 In terms of the non-residential commercial, community and employment uses, the following indicative minimum and maximum floorspace thresholds are proposed:
Table 5 – non-residential floorspace proposed (GEA)
page 13 Land use - Use Class Minimum sq.m. Maximum sq.m. Commercial (A1-A3) 600 1,500 Community (D1/D2) 1,200 3,100 Employment (B1) 0 1,100 Drinking establishment (A4) 0 250 Total 5,950
Commercial uses
38 The estate currently accommodates a range of retail premises (a number of which are vacant) which are located within the designated neighbourhood centre on the Concourse and which the Grahame Park SPG seeks the replacement of. These units provide approximately 1,430 sq.m. of retail floorspace. In total, the application seeks hybrid planning permission for up to 1,500 sq.m. of Class A1 to A3 retail and cafe/restaurant use. This is comparable with the quantum of existing commercial retail floorspace on site and is supported.
Employment uses
39 In addition to this, up to 1,100 sq.m. of B1 employment use is proposed, which the applicant has stated would provide small workspace units suitable for micro, small and medium sized businesses. This is strongly supported, in accordance with London Plan Policies 4.1 to 4.2 and Policies E1 to E2 of the draft London Plan.
Public house use
40 Redevelopment of the Concourse would necessitate the demolition of the existing Hind and Hart public house. As requested at pre-application stage, the applicant has widened the scope of land uses covered in the application to include provision for up to 400 sq.m. of Class A4 drinking establishment use. This is welcomed and should be secured by condition, in line with London Plan Policy 4.8 and Policy HC7 of the draft London Plan.
Community facilities
41 London Plan Policies 3.16-3.18 and Policies S1-S3 of the draft London Plan support the provision of high quality, new and enhanced including healthcare, education, childcare and community uses in accessible locations. The loss of social infrastructure in areas of defined need should only be permitted where replacement infrastructure is provided; or where proposals form part of a wider infrastructure delivery and investment programme to meet future population needs and improve services. Replacement facilities should be operational before existing facilities are demolished to ensure continuity of social infrastructure provision.
42 A number of existing community facilities are located within the Concourse, including a community centre, a library (which has closed), a health facility, a nursery/children’s centre, which are proposed for demolition as part of the development. A replacement library has already been delivered within Stage A of the wider Grahame Park Estate scheme, as part of the new Barnet & Southgate College development to the south. The applicant is proposing to reprovide the community centre, health centre and nursery, as part of Phase 2 of the development which forms part of the outline element of the scheme, with further details to be finalised at reserved matters stage. These uses would be clustered at the centre of the scheme in accessible locations along the new north-south avenue. The
page 14 proposed phasing allows for the replacement uses to be provided before the existing facilities are demolished to ensure continuity of provision. This phasing approach is supported and should be secured appropriately by the Council.
43 In relation to health care infrastructure provision, GLA officers understand that the local CCG is proposing to deliver a large new health centre at Colindale Gardens development (former Peel Centre) to the south, which would potentially cater for the Grahame Park Estate. Should this proposal come forward, an additional health centre would not be required within Grahame Park; however, at this stage, the CCG has not confirmed their preferred development strategy. Given this uncertainty, the Council should secure the reprovision of the existing health centre facility within the application site as a baseline fall back position, in the event that the CCG’s proposals at Colindale Gardens either do not come forward or are not as large as anticipated, with appropriate degree of flexibility for this requirement to fall away where the anticipated investment strategy is delivered at Colindale Gardens.
Open space
44 In addition to Heybourne Park, the Grahame Park Estate includes a relatively generous amount of open green space which is undesignated and is distributed across the site in the form of amenity lawns and landscaping areas located in between the residential blocks and adjacent to parking areas and movement routes. As is typical with post-war housing estates, many of these smaller open spaces do not appear to have a clear function or sense of ownership in relation to the adjacent properties, lack overlooking and are dominated by paving, railings and car parking.
45 Through the applicant’s masterplan the open space within the estate would be rationalised and reconfigured to provide more formal open space framework comprising landscaped tree lined streets and civic spaces with a clearer public function, alongside Heybourne Park and the retained Woodland Walk, with more clearly defined and usable communal open space within residential courtyards. This overall approach is strongly supported. Although there would be a moderate net reduction in public open green space, the overall quality and functionality of the open spaces proposed would be significantly enhanced. There would also be a substantial increase in terms of the quantum of communal open space within residential blocks.
Table 6 – Open space provision Existing green Proposed green space space Net change Public open amenity space 54,160 53,950 - 210 Road side open amenity space 3,880 2,910 - 970 Semi-private/communal open space 3,237 5,399 + 2,162 Total 61,277 62,259 + 982
46 The outline element of the scheme proposes improvements to Heybourne Park, which is identified as a Local Park in Barnet’s Local Plan. Whilst the placement of Blocks B and C would result in a loss of 700 sq.m. of the land within the existing park, this moderate net loss is acceptable in strategic planning terms, given the wider package of open space and green infrastructure improvements proposed.
Table 7 - Heybourne Park amendments
hectares Existing Heybourne Park 4.54 page 15 Proposed Heybourne Park 4.47 Net change - 0.07
47 Indicative design proposals presented seek to enhance the function, usability and level of activity within the park by providing a more diverse mix of spaces and activities, including formal sports, play space and multi-use games areas, SuDs and open water features, rest gardens/pocket gardens and community growing gardens. Biodiversity enhancements are also proposed through the provision of extended wetland, woodland and meadow grassland areas and avenue tree planting. The existing Greentops nursery would also be incorporated within the revised layout of the park. These proposals are being informed by ongoing engagement with the local community and Barnet Council and would be subject to Reserved Matters Applications. The overall to the redesign and use of the open space is supported.
Conclusion – Land use principle
48 In land use terms, the further housing intensification of the site is supported, as is the quantum of flexible commercial and employment use. The approach to social infrastructure reprovision is supported, subject to further discussion on the wording of the Section 106 agreement. In terms of open space, the amendments to Heybourne Park would result in some net loss of open space; however, this is acceptable given the overall net increase in open space proposed across the site and the comprehensive qualitative improvements proposed to the park itself.
Housing and affordable housing
49 In gross terms, the proposed development would provide a total of 2,088 residential units, of which 50% would be affordable by both habitable room and by unit. In terms of tenure mix, the scheme proposes a 38:62 tenure split between social rent/London Affordable Rent and intermediate shared ownership by habitable room; and 33:67 by unit. Once the requirement for 346 replacement social rent/LAR units within the site is accounted for, the application would provide 50% affordable housing on the net uplift in housing (46% by habitable room), which would comprise entirely of intermediate housing.
Table 8 – affordable housing proposed Habitable % by habitable Units % by unit Rooms room Social rent/LAR 346 1,038 50% 50% Shared ownership 699 1,680 Market 1,043 2,672 50% 50% Total 2,088 5,390
Affordable housing and viability
50 London Plan Policies 3.11 and 3.12 and draft London Plan Policy H5 seek to maximise the delivery of affordable housing, with the Mayor setting a strategic target for 50% of all new homes to page 16 be affordable. Barnet Council Local Plan Policies CS4 and DM10 set a borough wide target of 40% affordable housing and states that the Council will seek a tenure split of 60% social rent and 40% intermediate.
51 As set out in Policy H6 and H10 of the draft London Plan, all estate regeneration schemes which propose demolition are not eligible for the ‘Fast Track Route’ and are required to follow the ‘Viability Tested Route’. These applications are expected to provide an uplift in affordable housing in addition to the baseline requirement for like for like replacement of existing affordable housing floorspace. A Financial Viability Appraisal (FVA) has been submitted as part of the application, which is currently being scrutinised by the Council and GLA officers to ensure the scheme provides the maximum viable amount of affordable housing.
52 The applicant’s FVA indicates that, based on the assumed revenue and costs, the scheme is expected to generate a substantial viability gap, with a residual profit level of 8.1% expected on the total Gross Development Value of the scheme and 12.7% on the private sale element (including commercial and parking). Having reviewed the FVA, GLA officers do not accept all of the assumptions applied, particularly in relation to the assumed profit level on market tenure units (20%) which GLA officers do not consider to be appropriate. Further information and justification is required in relation to the assumed construction and site assembly costs, capital values for social rent and LAR units as well as a number of other issues. These issues are set out in more detail in the GLA viability team’s technical comments have been sent to the applicant and the Council alongside this report and should be responded to. The applicant should provide an updated FVA, taking into account these comments to demonstrate that affordable housing provision and affordability levels and tenures across the scheme has been maximised.
Viability Review Mechanisms
53 As with all schemes which follow the ‘Viability Tested Route’, the applications will be subject to both early implementation and late stage viability reviews, in accordance with Policy H6 of the draft London Plan. Given the size and long-term phasing of the scheme, GLA officers consider that mid-term review mechanisms should be secured. Early and mid-stage review mechanisms should ensure that any additional affordable housing is provided on-site where sufficient surplus profit is generated, in line with the Mayor’s Affordable Housing & Viability SPG.
Tenure mix
page 17 54 In terms of tenure split, Policy H7 of the draft London Plan sets out the Mayor’s preference for at least 30% low cost rent (social rent or London Affordable Rent) and 30% as intermediate housing products, with the remaining 40% to be determined by the Council. As set out above, the scheme proposes a 38:62 tenure split between social rent/London Affordable Rent and intermediate shared ownership by habitable room. This complies with the minimum tenure expectations set out in Policy H7 of the draft London Plan but does not comply with the Council’s Local Plan tenure mix requirements. However, in this instance there would be an appropriate degree of flexibility in applying tenure mix requirements, given that the scheme complies with the requirement for like-for-like re-provision of social rented accommodation, and taking into account the need for intermediate housing to support the viability of scheme and also deliver a mixed and balanced community.
Housing affordability
55 The provision of low cost rented housing in the form of social rent is strongly supported and this should be secured in any Section 106 agreement by reference to Social Target Rent levels and any affordable rent units should comprise low cost rented accommodation at the London Affordable Rent benchmarks set out in the Mayor’s affordable housing funding guidance (2016)1, which are updated annually. Further discussion is required to confirm the affordability of the proposed offer in terms of rent levels. The potential service charges should also be fully considered and subject to appropriate caps to ensure the overall affordability of the proposed low cost rent units.
56 Shared ownership units should be available to households on a range of incomes below the maximum income threshold set out in the draft London Plan (£90,000 a year). In addition to this, annual housing costs (including service charges, rent and any interest payment) should be no greater than 40% of net household income. These requirements will need to be secured in any Section 106 agreement, in accordance with London Plan Policy 3.10, Policy H7 of the draft London Plan and the Mayor’s Affordable Housing & Viability SPG.
Housing choice
57 London Plan Policy 3.8 states that new development should provide a mix of housing sizes and types, taking into account local and strategic housing requirements, the needs of different groups, the strategic priority for affordable family housing provision and the need to support the private rented sector. Policy H12 of the draft London Plan states that schemes should generally consist of a range of unit sizes and sets out a number of factors which should be considered when determining the appropriate housing mix on a particular scheme. This includes housing need and demand, the nature and location of a site and the requirement to optimise housing potential and deliver mixed and inclusive neighbourhoods.
58 The applicant’s proposed housing mix is shown below and predominantly comprises one and two bedroom units. A total of 199 family sized units would be provided in social rent/LAR and market tenures, including 22 four bedroom social rented units. This is supported. Overall, 22% of the replacement social rent/LAR units would comprise family sized accommodation and has been informed by a housing needs assessment for the social rented households who are eligible for a ‘right to return’. As such, the proposed housing mix is acceptable in strategic planning terms.
1 Mayor of London, 2016, Affordable Homes Programme 2016-21 Funding Guide https://www.london.gov.uk/what-we-do/housing-and-land/homes-londoners-affordable-homes-programme- 2016-21 page 18
Table 9 – proposed housing mix by tenure Social Shared Market Total % Rent/LAR ownership Studio 0 0 75 75 4% 1-bedroom 123 417 430 970 46% 2-bedroom 147 282 415 844 40% 3-bedroom 53 0 123 176 8% 4-bedroom 22 0 0 22 1% 5-bedroom 1 0 0 1 0% Total 346 699 1043 2,088 100% % 3+ bedroom 22% 0% 12% 10% 10% by tenure
Children’s play space
59 Policy 3.6 of the London Plan states that development proposals that include housing should make provision for play and informal recreation, based on the expected child population generated by the scheme and an assessment of future needs. Policy S4 of the draft London Plan states residential developments should incorporate high quality, accessible play provision for all ages, of at least 10 sq.m per child. Play space provision should normally be provided on-site; however, off-site provision may be acceptable where it can be demonstrated that this addresses the needs of the development and can be provided nearby within an accessible and safe walking distances, and in these circumstances contributions to off-site provision should be secured by Section 106 agreement. Play
60 The applicant’s proposed enhancement to Heybourne Park would significantly improve the existing play space provision for all ages, with further doorstep play space provision proposed to be distributed across the site within residential courtyards and other public spaces and green corridors. This overall strategy is supported. Play space provision has been assessed using the updated GLA play space calculator (2019) and GLA officers can confirm that the overall level of proposed play space provision exceeds the requirements generated by the updated GLA calculator. In total, 9,150sqm of play space will be provided across the masterplan area within a mix of public and communal/ semi- private play space areas. This is broken down as follows:
• Doorstep Play / Local Areas for Play (LAP) = 2,745sqm
• Locally Equipped Areas for Play (LEAP) = 3,660sqm
• Neighbourhood Equipped Areas for Play (NEAP) = 2,745sqm.
page 19 61 Play space provision within podium level courtyard amenity spaces should be available to all housing tenures within the immediately adjacent blocks to promote social inclusion. Within the detailed phase, residents within Block A2 should have access to the podium level play space facilities within Block A3 to promote inclusion between housing tenures and avoid exclusion, as discussed at pre-application stage. The GLA expects the design guidelines to ensure that segregation between housing tenures in terms of access to play space facilities is avoided where units face the same podium level courtyards. A range of doorstep, local and neighbourhood play provisions would be provided within publicly accessible facilities which would be well-distributed across the site within Heybourne Park, ‘play streets’ and along the green corridor, which his supported.
Urban design
Density and design review
62 London Plan Policy 3.4 seeks to optimise housing density, with Policies D1 to D1B of the draft London Plan placing greater emphasis on a design-led approach to ensure development makes the best use of land, with consideration given to site context, public transport, walking and cycling accessibility and the capacity of surrounding infrastructure. Taking into account the existing and emerging context, and mindful of the requirement to ensure the like-for-like replacement of affordable housing floorspace with the scheme, GLA officers consider the site lends itself to the provision of a well-designed high density scheme, which makes the most of the site’s location and key assets such as Heybourne Park. As set out above, the previous application was not considered to have fully optimised the housing potential of the site. In contrast, the revised scheme proposes approximately double the number of residential units. This has been achieved through the a more efficient layout and design of the proposed and blocks and through moderate changes and refinement to the height, scale and massing of the scheme, particularly where blocks line the park and address key street corners.
63 The net residential density of the scheme would be 238 residential units per hectare/ 614 habitable rooms per hectare (not including the land on Heybourne Park). Whilst this does not trigger the requirement for a design review as set out in Policy D2 of the draft London Plan, the scheme has nevertheless been subject to a CABE design review which was undertaken at an appropriately early stage, which GLA officers were involved in. This has led to further design changes and refinements in response to the panels’ comments and following an iterative series of GLA pre-application meetings during 2018 and 2019. Overall, the proposed density is supported and has been arrived at as part of an appropriately design-led process, which also ensures the like-for-like replacement of social rented accommodation, alongside improvements in terms of open space provision, walking and cycling and public transport and social infrastructure. This is strongly supported.
Design, layout, public realm and landscaping
64 London Plan Policies 7.1 to 7.5, together with Policies D1-D3, D7 of the draft London Plan and the Housing SPG (2016) apply to the design and layout of development and set out a range of urban design principles relating to the quality of public realm, the provision of convenient, welcoming and legible movement routes, the importance of designing out crime by, in particular, maximising the provision of active frontages and minimising inactive frontages.
page 20 65 The existing estate is inward facing in its design and isolated from the surrounding area, having been designed in line with Radburn layout principles. Consequently, the estate lacks a clear street hierarchy and many of the movement routes are lacking in legibility and natural surveillance and are dominated by car parking, garages and the sides and backs of residential properties. This layout has also resulted in numerous left over open spaces which are under-utilised and lacking in ownership, with consequential management and maintenance issues.
66 The overall urban design framework set out in the masterplan is strongly supported, in particular, the objective to better integrate and connect Grahame Park with Colindale, Heybourne Park and the surrounding areas through the provision of a clear and legible street network. This would be structured around a new north-south central spine route (Bristol Avenue), with this route re-aligned away from the existing Lanacre Avenue alignment to allow blocks to be provided facing both sides of the street. This Avenue would form a key movement route for pedestrians, cyclists and buses and would be lined by mixed uses at ground floor level, street trees and landscaping.
66 The park would be fronted by mansion blocks and wrapped with secondary streets. The applicant has responded positively to concerns raised by GLA officers at pre-application stage in relation to the design coding of park edge conditions in terms of ensuring pedestrian permeability and active frontages along these important routes. The design guideline document submitted alongside the application (which would be applied to future reserved matters applications) has appropriately addressed these concerns. In line with GLA pre-application advice, visually permeable active frontages would now be required along the main buildings facades fronting the park. Primary entrances to the adjacent residential blocks would also be provided along these routes facing the park. Appropriate design rules have also been included to ensure front door entrances can be provided, together with a 2 metre deep privacy set-back for any ground floor units. The secondary streets adjacent to the park would include perpendicular parking; however, a 4 metre deep landscape boundary would ensure parking screened is screened from view from within the park. The design guidelines envisage these routes would be designed as continuous shared surface/ home zones, which is supported.
67 The applicant has also responded positively to the GLA and design review panel’s comments in relation to optimising the potential routes and views leading to the park, with the mansion blocks lining the park now broken up into four separate blocks. GLA officers support the provision of an additional block to line the south-eastern boundary of the park (Block Q), given this is currently an area which is lacking in terms of activity and natural surveillance. The layout of the main Avenue has been refined to address comments made during the CABE design review to provide slight kinks in the road and allow landmark buildings to mark key corners and the entrance to the park. Other key features of the masterplan are also strongly supported, including the retention of the Woodland Walk and the design of side streets. Overall, GLA officers consider that the scheme responds positively to the design objectives set out in the London Plan and Draft London Plan.
Height and massing
68 The proposed height and massing of the scheme is supported. This has been appropriately refined so that the mansion blocks adjacent to Heybourne Park are staggered in height between 9 and 15 storeys, with building heights also concentrated along the central spine route ranging from 14 to 7 storeys. Building heights are stepped down towards the east to allow the provision of three storey townhouses to address the low-rise context. This approach is supported and would contribute towards creating a legible street network with building heights varied both across the site and within individual blocks and appropriate specifications and design rules are set out in the design guidance document to inform RMAs.
page 21 Residential quality
69 London Plan Policy 3.5 and draft London Plan Policy D4 promote quality in new housing provision, with further standards and guidance set out in the Mayor’s Housing SPG (2016). Minimum quantitative standards for private internal space, private outdoor space and floor to ceiling heights apply to all tenures and types of self-contained housing in Class C3 use within London. In addition, residential and mixed use developments should maximise the provision of dual aspect units and normally avoid single aspect units that are north facing or exposed to significant adverse noise impacts.
70 Overall, the detailed element of the scheme would achieve a good standard of residential design in accordance with the Mayor’s housing quality standards. Single aspect units would be east and west facing, with dual aspect units provided on building corners and no north facing single aspect units proposed. Private open space would be provided for all of the residential units within the scheme, as well as communal amenity space within a raised podium level courtyard. Whilst the proposed unit per core per floor ratio would be 9, which exceeds the indicative benchmark (8) in the Housing SPG, this is acceptable in this particular instance given the block dimensions and taking into account potential service charge implications of adding an additional lift core. In terms of the outline element of the scheme, the layout of blocks appears to avoid north facing single aspect units and ensure that single aspect units would be east-west facing, which is supported. Compliance with the Mayor’s housing standards in terms of internal space and private outdoor space should be secured by condition for all RMAs. A range of building typologies are proposed including mansion blocks, linear and courtyard blocks and traditional terraced houses, which is strongly supported.
Architectural appearance
71 In terms of the detailed element of the scheme, the proposed architectural approach would comprise a mix of different tones of red and beige colour brick materials which responds positively to the existing and surrounding context. Additional detailing and articulation of the proposed building would be achieved by the use of stone balcony bases, bronze metal balconies and brickwork recesses and reveals. This is supported. An appropriate degree of design control is provided in the design guidelines document in relation to block typologies, building facades, windows and fenestration and the materials palette to ensure the provision of a visually cohesive and architecturally interesting scheme. As such, the application complies with London Plan Policy 7.6 and Policies D1 to D2 of the draft London Plan.
Inclusive design
72 As set out in London Plan Policy 3.8 and Policy D5 of the draft London Plan, all the new self- contained homes should meet the Building Regulations M4(2) standard for ‘accessible and adaptable dwellings‘, with at least 10% of homes designed to meet the M4(3) standard for ‘wheelchair user dwellings’. The latter should generally be distributed across tenures types, flat sizes and floors to give disabled and older people similar choices to non-disabled people, subject to the scheme being required to meet the specific needs of existing social rented households. The overall approach to the public realm, landscaping and streetscape design as set out in the design documents submitted as part of the hybrid application demonstrates that a high standard of inclusive design would be secured.
Fire safety and resilience
74 In line with Policy D11 of the draft London Plan, a fire statement should be prepared by a third party suitably qualified assessor demonstrating how the development proposals would achieve page 22 the highest standards of fire safety, including details of construction methods and materials, means of escape, fire safety features and means of access for fire service personnel.
Heritage
75 London Plan Policy 7.8. and Policy HC1 of the draft London Plan states that development should conserve heritage assets and avoid harm. The Planning (Listed Buildings and Conservation Areas) Act 1990 sets out the statutory duties for dealing with heritage assets in planning decisions. In relation to listed buildings, all planning decisions should “have special regard to the desirability of preserving the building or its setting or any features of special architectural or historic interest which it possesses”. The NPPF states that when considering the impact of the proposal on the significance of a designated heritage asset, great weight should be given to the asset’s conservation and the more important the asset, the greater the weight should be. Significance can be harmed or lost through alteration or destruction of the heritage asset or development within its setting.
76 Where a proposed development will lead to ‘substantial harm’ to or total loss of the significance of a designated heritage asset, local planning authorities should refuse consent, unless it can be demonstrated that the substantial harm or loss is necessary to achieve substantial public benefits that outweigh that harm or loss. Where a development will lead to ‘less than substantial harm’, the harm should be weighed against the public benefits of the proposal, including securing its optimum viable use. Having considered the application documents and site and surroundings, GLA officers consider that the proposals would not give rise to any harm in relation to the surrounding heritage assets set out in paragraph 8 of this report.
Climate change
77 Based on the energy assessment submitted, an on-site reduction in CO2 emissions of 36% beyond 2013 Building Regulations compliant development is expected on the domestic element of the scheme and 35% on the non-domestic element (this is the case for both detailed and outline elements of the hybrid application). This exceeds the minimum on-site requirement for reductions in CO2 emissions as set out in Policy SI2 of the draft London Plan and would be achieved through a range of energy efficiency measures, solar panels and with a low carbon heat network provided via air source heat pumps from three energy centres, with additional heating capacity provided by high specification gas boilers. Solar panels are also proposed. Overall, the energy hierarchy has been followed and the scheme also complies with the London Plan and draft London Plan. The required carbon offset payment should be secured in any Section 106 agreement, together with an obligation to connect the scheme to the proposed Colindale District Heating Network.
Flood risk and sustainable drainage
78 The site is located within Flood Zone 1 and the majority of the site has a ‘very low’ risk of surface water flooding. The applicant’s drainage strategy would achieve a greenfield rate of run-off, taking into account an allowance for climate change. A range of Sustainable urban Drainage (SuDs) measures are proposed including green and brown roofs, rainwater harvesting, open water features such as swales, rain gardens and ponds, soft landscaping, permeable paving, swales and below ground attenuation tanks. This approach accords with the drainage hierarchy and, as such, the application complies with London Plan Policies 5.12 to 5.13 and Policies SI.12 to SI.13 of the draft London Plan.
page 23 Trees and Urban Greening
79 GLA officers note that the revised street layout proposed does not allow for the retention of a number of mature existing trees within the estate, which is accepted as an unavoidable constraint in this instance, given that the priority is to fundamentally redesign the layout of the estate. The applicant is proposing to replace trees which need to be removed on a 2:1 basis, which is supported, in line with London Plan Policy 7.21 and Policy G7 of the draft London Plan.
80 In line with pre-application advice, the applicant has undertaken an Urban Greening Factor (UGF) assessment of the existing estate and proposed development. Excluding Heybourne Park, the existing estate has a score of UGF 0.28 and includes substantial areas of hard landscaping and paving. The proposed development (excluding Heybourne Park) would have a UGF score of 0.4 which complies with the Policy G5 of the draft London Plan. Once Heybourne Park is included, the UGF score for the entire site boundary increases to 0.55, which is strongly supported. As such the application accords with London Plan Policy 5.10 and 7.21 and Policies G5 and G7 of the draft London Plan. The proposed improvements in relation to urban greening, tree planting and Heybourne Park should be secured by condition.
Transport
Car parking
81 Overall, a car parking ratio of 0.41 spaces per residential unit is proposed across the site. This complies with the maximum parking standard set out in the draft London Plan for Outer London Opportunity Areas (0.5 spaces per residential unit) and is supported. The applicant has provided a schedule setting out the proposed standard and disabled blue badge parking by Plot. This demonstrates that the proposed level of overall and disabled parking would comply with the draft London Plan by individual development plot. The approach to Electric Vertical Charging Points is in accordance with the draft London Plan.
82 Commercial land uses are proposed to be car-free, in line with the draft London Plan, with 9 car parking spaces proposed for the community and health care uses. This is supported. A micro Controlled Parking Zone (CPZ) is proposed for the site, which is supported. A Parking Design and Management Plan should be secured by planning condition or within Section 106 agreement to ensure overall and disabled parking is provided within individual development plots, in accordance with the outline application. Subject to this being secured, the application accords with London Plan Policy 6.13 and Policy T6 to T6.1 of the draft London Plan.
Cycle parking
83 Cycle parking would be provided in accordance with the minimum standards set in the draft London Plan which is welcomed. Cycle parking would be provided in secure and accessible facilities at ground floor level within blocks and under podiums. The design of cycle parking provision should also accord with the London Cycle Design Standards (LCDS). The LCDS requires a minimum of 5% of long-stay stands to be on wider spaces to accommodate larger cycles (for example cargo cycles, tricycles or cycle trailers) and cycles adapted for disabled cyclists. The provision of two-tier racks or vertical racks should be minimised and where these are provided, the space requirements in LCDS should be followed. Compliance with these design requirements should be secured by condition, in accordance with London Plan Policy 6.9 and Policy T5 of the draft London Plan.
page 24 Walking, cycling and Healthy Streets
84 The overall approach of the masterplan in terms of pedestrian, cycle and vehicle access, traffic calming and streetscape design is supported in terms of the overall Healthy Streets approach set out in the draft London Plan. Further details of the bus route and the proposed bus stops should be secured by condition to ensure that bus stops are fully accessible in line with TfL guidelines and to ensure that the proposed locations and design do not raise any highways safety concerns, in line with the Mayor’s Healthy Streets and Vision Zero approach.
Bus capacity mitigation
85 Grahame Park is a busy point on the bus network with around 600,000 boarding passengers per annum (based 2016/17 figures). As such, it is important that the impact of the scheme on existing bus operations and bus passengers is mitigated (both during construction and on completion) to ensure that the capacity of existing bus services is improved to address the additional demand from the development. The proposed development generates 118 AM and 186 PM bus trips during peak time hours, and 1,437 daily two-way trips. Accordingly, financial contributions should be secured to increase the bus frequency to provide two additional buses per hour to serve the needs of this development, to be paid in two tranches. The cost of funding one additional bus for five years is £450,000 on services that serve the site.
86 As such, a combined financial payment of £900,000 should be secured by Section 106 agreement to mitigate the impact of the development, which should be paid in two instalments. It is recommended that the first £450,000 payment should be paid in full once 630 residential units have been constructed; with the second £450,000 payment required once approximately,1,100 residential units have been constructed. Further discussion is required to agree the trigger points and the wording of any Section 106 agreement. Safe routes to the bus stops during construction should also be secured by condition.
London Underground mitigation
87 Major upgrades to Colindale Station are proposed by TfL and work on the station is due to commence in summer/autumn 2020. These works will provide step free access alongside increased capacity and circulation to cater for growth in the Colindale area. Whilst the majority of funding required for this scheme has been secured, there currently remains a funding gap of up to £2 million. Colindale Station currently caters for 2,230 (2017) weekday AM and PM peak only trips; however, this is forecast to increase by 3,540 trips between 2017 to 2041.
88 Based on the trip generation assessment provided in the applicant’s Transport Assessment, the proposed development is expected to generate 296 London Underground trips during peak hours (207 net additional trips). This application would therefore contribute between 8% to 6% of the anticipated increase in London Underground trips between 2017 and 2041 (3,540). To mitigate this, and to ensure the timely delivery of the Colindale Station improvement scheme, a financial contribution of £160,000 is sought towards the existing funding gap set out above, in accordance with London Plan Policies 6.2 to 6.4 and Policies T3 to T4 of the draft London Plan. This should be secured by Section 106 agreement, with further discussion required to establish the appropriate phasing and trigger points for this payment.
Travel Plan, Servicing, Deliveries and Construction
page 25 89 The approach to the Travel Plan, Deliveries and Servicing and Construction Logistic Planning is acceptable and should be secured by condition or Section 106 agreement.
Local planning authority’s position
90 GLA officers understand that Barnet Council planning officers are supportive of the application and are targeting a planning committee in the New Year.
Legal considerations
91 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
Financial considerations
92 There are no financial considerations at this stage.
Conclusion
93 London Plan and draft London Plan policies on estate regeneration, retail and employment uses, social and health care infrastructure, housing and affordable housing, urban design, inclusive design, heritage, climate change, flood risk and sustainable drainage and transport are relevant to this application. The application does not yet fully comply with the London Plan and draft London Plan. The below issues should be addressed to ensure the proposal complies with the London Plan and draft London Plan:
• Principle of estate regeneration: The application complies with the requirement for the like for like replacement social rented floorspace and would provide an increase in terms of social rent accommodation by floorspace and habitable rooms.
• Land use principle: Further housing intensification of the site is supported, as is the proposed quantum of flexible commercial and employment use. The approach to social infrastructure reprovision is supported, subject to further discussion on the wording of any Section 106 agreement. Amendments to Heybourne Park would result in a net loss of open space; however, this is acceptable given the overall net increase in open space proposed across the site and the comprehensive qualitative landscape improvements proposed to the park itself.
page 26 • Housing and affordable housing: 50% affordable housing by habitable room, comprising a 38:62 tenure split between social rent/London Affordable Rent and intermediate shared ownership is supported in principle, subject to this being verified as the maximum viable level of affordable housing and further discussion on any Section 106 agreement to ensure the affordable housing is secured in perpetuity. Early, Mid and Late Stage Viability Review Mechanisms should be secured given the size and timescales for the development. Affordability levels for shared ownership and low cost rent units should be confirmed and secured.
• Urban design and heritage: The design, layout, density, height and massing of the proposed scheme is strongly supported and the proposed development would not harm heritage assets.
• Climate change: The applicant’s strategies in relation to energy, drainage and urban greening are supported subject to conditions and obligations being secured.
• Transport: Car parking and cycle parking would comply with the draft London Plan. A financial contribution of £900,000 is required to mitigate the impact on bus capacity (via two phased payments). A contribution of £160,000 is required towards improvements to Colindale station to mitigate the impact of the scheme. Conditions are required in relation to bus stop location and design, construction management and logistics, deliveries and servicing, travel planning and car parking and cycle parking.
for further information, contact GLA Planning Unit (Development Management Team): Juliemma McLoughlin, Chief Planner 020 7983 4271 email: [email protected] John Finlayson, Head of Development Management 020 7084 2632 email: [email protected] Allison Flight, Deputy Head of Development Management 020 7084 2820 email [email protected] Nick Ray, Team Leader, Special Projects page 27 020 7983 4178 email: [email protected] Andrew Russell, Principal Strategic Planner (case officer) 020 7983 5785 email: [email protected]
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