Former British Gas Works, Purley Way, Croydon

planning report PDU/0442e/02 8 December 2010 Former British Gas Works, Purley Way, Croydon

in the London Borough of Croydon planning application no. 10/02407/P

Strategic planning application stage II 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 Variation of planning permission 05/05134/P on the site of the former gas works and development of Commercial House, Vicarage Road to deliver an additional 74 private residential units at New South Quarter, Purley Way, resulting in the erection of 11 blocks ranging from 3 to 9 storeys comprising a total of 496 residential class C3 units, a cafe (class A3), a shop (class A1) workspace (class B1, B2, & B8); opening up of River Wandle, provision of cycle, vehicular and pedestrian internal access routes and parking and contaminated land remediation works. The applicant The applicant is Barratt Homes Ltd., and the architects are Stanford Eatwell & Associates.

Strategic issues The concerns raised at the consultation stage regarding affordable housing, design, sustainable development and transport have been addressed and the proposal would now be consistent with the London Plan.

The Council’s decision

In this instance Croydon Council has resolved to grant permission subject to conditions and written conclusion of a Section 106 legal agreement. Recommendation That Croydon Council be advised that the Mayor is content for it to determine the case itself, subject to any action that the Secretary of State may take, and does not therefore wish to direct refusal or direct that he is to be the local planning authority.

Context

1 On 10 August 2010 the Mayor of London received documents from Croydon Council notifying him of a planning application of potential strategic importance to develop the above site for the above uses. This was referred to the Mayor under Category 1A of the Schedule to the Order 2008: ”Development which comprises or includes the provision of more than 150 houses, flats, or houses and flats.”

page 1 2 On 8 September 2010 the Mayor considered planning report PDU/0442e/01, and subsequently advised Croydon Council that the application did not comply with the London Plan, for the reasons set out in paragraph 70 of the above-mentioned report; but that the possible remedies set out in paragraph 72 of that report could address these deficiencies.

3 A copy of the above-mentioned report is attached. The essentials of the case with regard to the proposal, the site, case history, strategic planning issues and relevant policies and guidance are as set out therein, unless otherwise stated in this report. Since then, the application has been revised in response to the Mayor’s concerns (see below). On 4 November 2010 Croydon Council decided that it was minded to grant planning permission subject to conditions and written conclusion of a Section 106 legal agreement, for the revised application, and on 26 November 2010 it advised the Mayor of this decision. Under the provisions of Article 5 of the Town & Country Planning (Mayor of London) Order 2008 the Mayor may allow the draft decision to proceed unchanged, direct Croydon Council under Article 6 to refuse the application or issue a direction to Croydon Council under Article 7 that he is to act as the Local Planning Authority for the purposes of determining the application. The Mayor has until 9 December 2010 to notify the Council of his decision and to issue any direction.

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 decision on this case, and the reasons will be made available on the GLA’s website www.london.gov.uk.

Update

6 At the consultation stage Croydon Council was advised that the application did not comply with the London Plan, for the reasons set out in paragraph 70 of the above-mentioned report; but that the possible remedies set out in paragraph 73 of that report could address these deficiencies:

 Housing: While the proposed unit mix and density are acceptable in principle, the applicant must justify the percentage reduction in affordable housing as a result of the proposed private residential uplift. The applicant should, therefore, submit an affordable housing toolkit.  Urban design: While the design approach is broadly acceptable, the applicant is asked to improve certain elements including: a reconfiguration of blocks ‘F’ and ‘L’ to provide active frontages onto the boulevard, a reduction of car parking adjacent to block ‘L’, and use of the space recovered from car parking to provide gardens for block ‘L’. The applicant should submit revised plans which address these points.  Sustainable development: While the proposals are broadly acceptable in principle, the applicant should provide further information in relation to various technical points including: a break down of regulated and unregulated carbon dioxide emissions, further detail on the carbon dioxide savings from energy efficiency measures, further information on planned district heating networks within the vicinity of the development, detail on measures to passively cool dwellings and avoid overheating, further investigation of the use of renewable energy sources and their suitability for the scheme. A revised energy statement should be provided addressing these points.  Transport: While the proposals are broadly acceptable in principle, further information and commitments are sought on a number of points including: the proposed uplift in residential units should be car free, an appropriate contribution towards Tramlink capacity should be provided, a minimum of two cycle parking spaces for each 3 bedroom

page 2 unit should be provided, a travel plan, delivery and servicing plan and a construction logistics plan should be secured by planning condition.

7 Since the consultation stage the application has been amended and further information and commitments regarding these matters provided. These are addressed in the sections below. Housing

8 At the consultation stage the applicant was advised that while the proposed unit mix and density were acceptable in principle, further justification should be provided in respect to the percentage reduction in affordable housing as a result of the proposed uplift in private residential units. The applicant was advised to submit an affordable housing toolkit demonstrating the relationship between the financial viability of the scheme and affordable housing provision.

9 Since the consultation stage the applicant has engaged in full and constructive discussions with both Croydon Council and the GLA, and an affordable housing toolkit has been provided.

10 The toolkit has been verified by an independent consultant whose assessment advised that the provision of a greater affordable housing contribution would render the scheme unviable at the present time. It should also be noted that the existing affordable housing offer of the scheme is dependant on a Home and Communities Agency (HCA) grant allocation of £22 million. The remaining balance of this grant (£11 million) is likely to be threatened if the scheme is delayed and fails to meet HCA contractual deadlines, this, in turn, would jeopardise the original affordable housing provision.

11 On the basis that an increase in affordable housing provision would not be viable in current market conditions, and further delay would jeopardise the existing affordable housing offer of the scheme, the reduced provision from 33% to 31% is accepted. The GLA is, therefore, broadly satisfied that the proposal complies with London Plan policy 3A.10. Urban design

12 At the consultation stage the applicant was advised that while the design of the scheme was broadly acceptable, further improvements could be made in the vicinity of blocks ‘F’ and ‘L’ in order to deliver the highest standards of design for the site.

13 Since the consultation stage revised plans have been submitted in response to the design comments made at the consultation stage, these are addressed below.

14 The architect has made a number of changes to the layout of building blocks ‘L’ and ‘F’, and their relationship to the area around the southern boulevard space. Block ‘F’ has now been redesigned to establish a main entrance on the eastern side of the building fronting onto the boulevard. This is welcomed in line with the GLA’s previous comments and will help to introduce greater activity along this route.

15 Revised plans also demonstrate a marked reduction in car parking adjacent to block ‘L’, with the only remaining provision allocated to blue badge holders. The recovered space has been used to expand the park area of the boulevard, and to provide defendable front garden space to the west side of block L. These amendments are also welcomed in line with previous comments.

16 The GLA welcomes above-mentioned amendments and is now satisfied with the overall design of the scheme.

page 3 Sustainable development

17 At the consultation stage the applicant was advised that while the energy proposals for the scheme were broadly acceptable, further information was required in order to verify carbon dioxide savings.

18 Since the consultation stage the applicant has engaged in full and constructive discussions with both Council and GLA energy specialists, and further information and commitments have been provided.

19 An updated energy statement has been provided setting out a breakdown of both regulated and unregulated carbon dioxide emissions, this is welcomed in line with previous comments. Further information has also been provided on carbon dioxide savings from energy efficiency measures alone. Savings in this regard equate to 6%, relative to a building regulations compliant development.

20 The applicant has also responded to requests for further information on planned district heating networks within the vicinity of the development. While it is noted that there are currently no existing or planned networks within the vicinity of the site, the GLA welcomes the fact that the scheme could potentially be connected to the Croydon District Heating network in the future.

21 The applicant has provided further information in relation to passive cooling measures for dwellings to avoid overheating. The updated energy statement demonstrates that cooling will be managed through whole house mechanical extract ventilation for each unit, acting in combination with trickle vents. This will provide sufficient air change rates to avoid the need for active cooling of dwellings. This approach is welcomed.

22 Following the consultation stage the applicant has also investigated the potential for further renewable energy provision in the form of photovolatic (PV) panels for the additional dwellings. The updated energy statement proposes 50 sq.m. of PV panels which would provide 6.5kW of peak power output. This proposal, and the additional carbon savings it will deliver, is a welcome response to the GLA’s previous comments.

23 On the basis of the further information and revisions provided, the GLA is broadly satisfied that the comments made at the consultation stage have been addressed, and the application complies with London Plan energy policies. Transport

24 At the previous consultation stage Transport for London (TfL) raised a number of transport concerns. Principally, these were that the proposed uplift in residential units should be car free, and that an appropriate Section 106 contribution should be provided towards the enhancement of Tramlink capacity. A provision of two cycle parking spaces for each of the 3 bedroom was also sought, along with the implementation of a travel plan, delivery and servicing plan (DSP), and construction logistics plan (CLP) to be secured through planning condition.

25 TfL notes that following comments made at the previous consultation stage the applicant is now proposing no overall increase in car parking at the site. This arrangement is welcomed in line with previous comments.

26 The Section 106 heads of terms reported to Croydon Council’s planning committee seek to secure a £57,100 contribution towards Tramlink capacity. This is welcomed in line with previous comments. The Council are advised, however, that TfL will require involvement in the full drafting of the agreement to ensure that the payment mechanism is appropriate.

page 4 27 The applicant’s commitment to provide 74 additional cycle spaces in response to previous comments and emerging minimum cycle parking standards in the draft replacement London plan is welcomed. TfL also welcomes the commitment detailed in the Council’s planning report to secure travel plan improvements, along with a DSP, and CSP, by planning condition.

28 In summary, following the above-mentioned amendments and commitments the GLA is satisfied that the application adequately addresses London Plan transport policies. Response to consultation

29 Croydon Council publicised the application by sending letters to 623 addresses in the vicinity of the site, and issuing site and press notices. The relevant statutory bodies were also consulted.

Public consultation

30 In response to the public consultation the Council received a total of 7 objecting representations and 1 comment.

31 In summary, the objecting representations cite reasons including: the development is too dense, the development is too tall, the development will adversely impact on traffic flow and inhibit the movement of emergency vehicles, the tram network will be overwhelmed, the height of the buildings will dominate the area and cause overlooking and privacy issues, the development will lead to overcrowding, the development will adversely impact on Wandle Park with tall buildings dominating the park, the block overlooking the children’s play ground will create overlooking / privacy issues, there is insufficient car parking, the increase in height will infringe on daylight levels, privacy, and visual amenity of existing residents at the site, and, the increase in density will reduce quality of life for residents.

32 In summary, the representation making comments suggested that the Council ask the developer to compensate existing residents at the site who have had their visual amenity / right to daylight impacted on as a result of the development.

33 Croydon Councillor Simon Hoar also made representations. These raised concern that the increased number of units at the site would be detrimental to neighbouring residents in Waddon Close and Vicarage Road due to over development and increased local traffic.

Responses from other organisations

34 Representations were received from the Environment Agency who raised no objection, but sought conditions relating to piling, contamination, and flood risk management. Thames Water raised no objection, but sought a condition relating to management of flow rate, and an informative relating to water pressure. London Tramlink raised no objection, but sought a condition relating to consultation on design and construction methodology, so as to prevent any interruptions to London Tramlink services. English Heritage and Natural England raised no objections to the development.

35 The statutory and non-statutory responses to Croydon Council’s consultation do not raise any material planning issues of strategic importance that have not already been considered by the Mayor at the consultation stage and/or in this report. Article 7: Direction that the Mayor is to be the local planning authority

36 Under Article 7 of the Order the Mayor could take over this application provided the policy tests set out in that Article are met. In this instance the Council has resolved to grant permission with conditions and a planning obligation, which satisfactorily addresses the matters raised at the

page 5 consultation stage, therefore there is no sound planning reason for the Mayor to take over this application. Legal considerations

37 Under the arrangements set out in Article 5 of the Town and Country Planning (Mayor of London) Order 2008 the Mayor has the power under Article 6 to direct the local planning authority to refuse permission for a planning application referred to him under Article 4 of the Order. He also has the power to issue a direction under Article 7 that he is to act as the local planning authority for the purpose of determining the application and any connected application. The Mayor may also leave the decision to the local authority. In directing refusal the Mayor must have regard to the matters set out in Article 6(2) of the Order, including the principal purposes of the Greater London Authority, the effect on health and sustainable development, national policies and international obligations, regional planning guidance, and the use of the River Thames. The Mayor may direct refusal if he considers that to grant permission would be contrary to good strategic planning in Greater London. If he decides to direct refusal, the Mayor must set out his reasons, and the local planning authority must issue these with the refusal notice. If the Mayor decides to direct that he is to be the local planning authority, he must have regard to the matters set out in Article 7(3) and set out his reasons in the direction. The Mayor must also have regard to the guidance set out in GOL circular 1/2008 when deciding whether or not to issue a direction under Articles 6 or 7. Financial considerations

38 Should the Mayor direct refusal, he would be the principal party at any subsequent appeal hearing or public inquiry. Government guidance in Circular 03/2009 (‘Costs Awards in Appeals and Other Planning Proceedings’) emphasises that parties usually pay their own expenses arising from an appeal.

39 Following an inquiry caused by a direction to refuse, costs may be awarded against the Mayor if he has either directed refusal unreasonably; handled a referral from a planning authority unreasonably; or behaved unreasonably during the appeal. A major factor in deciding whether the Mayor has acted unreasonably will be the extent to which he has taken account of established planning policy.

40 Should the Mayor take over the application he would be responsible for holding a representation hearing and negotiating any planning obligation. He would also be responsible for determining any reserved matters applications (unless he directs the council to do so) and determining any approval of details (unless the council agrees to do so).

Conclusion

41 The outstanding matters raised at the consultation stage have been addressed and the proposal is now consistent with the London Plan.

page 6

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] Graham Clements, Case Officer 020 7983 4265 email [email protected]

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planning report PDU/0442e/01 8 September 2010 Former British Gas Works, Purley Way, Croydon

in the London Borough of Croydon planning application no. 10/02407/P

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 applicant The applicant is Barratt Homes Ltd., and the architects are Stanford Eatwell & Associates.

Strategic issues The principle for the use of the employment site for a major mixed-use proposal is established by an existing consent and is accepted. Further work and discussion is, however, required in relation to affordable housing, design, sustainable development and transport before the application is referred back to the Mayor. Recommendation That Croydon Council be advised that the application does not comply with the London Plan, for the reasons set out in paragraph 70 of this report; but that the possible remedies set out in paragraph 72 of this report could address these deficiencies.

Context

42 On 10 August 2010 the Mayor of London received documents from Croydon 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 20 September 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.

page 8 43 The application is referable under Category 1A of the Schedule to the Order 2008: ”Development which comprises or includes the provision of more than 150 houses, flats, or houses and flats.”

44 Once Croydon 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.

45 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.

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

47 The site is located within the Wandle Valley corridor, approximately two kilometres west of Croydon town centre. The application site forms part of a wider area of land which was formerly a gas works owned by British Gas and has since been partially developed in line with approved planning permission 05/05134/P.

48 The site is situated south of the Purley Way Retail Park, between the A23 Purley Way (which is part of the Transport for London Road Network [TLRN]) on the west, and the Croydon Tramlink to the east. Wandle Park is situated to the immediate east of the tramline and the site is bisected on an east-west axis by a culverted section of the River Wandle. The area surrounding the southern portion of the site is predominantly residential in character.

49 In addition to the retail park, the area surrounding the northern portion of the site includes blocks ‘A’, ‘B’ and ‘K’ which form part of the approved planning permission for the wider site. Blocks ‘A’ and ‘B’ have already been built out, while block ‘K’ is under construction. The completed blocks comprise a mixture of commercial and residential uses, as well as housing the energy centre for the development.

50 Block ‘M’ is also under construction, and forms one half of a planned circus of private residential units at the centre of the application site.

51 The site is served by five bus routes calling at bus stops on Purley Way, Trafalgar Way and Waddon Road. The site is also a 12 minute walk from Waddon train station where frequent services run to Croydon and Central London, and a 10 minute walk from Wandle Park tram stop. The Public Transport Accessibility Level (PTAL) of the site ranges from 3 at the centre of the site to 4 at the eastern end, on a scale of 1 to 6 where 6 is considered as excellent. Site visit

52 A site visit was carried out by the GLA case officer on 2 September 2010.

Details of the proposal

53 The proposal is for an uplift of residential units pursuant to planning permission 05/05134/P.

54 The scheme, as permitted under permission 05/05134/P, is to provide two buildings ranging from 3-9 storeys comprising units within Use Classes B1(b) and (c), B2, B8, D1 (medical

page 9 centre) an energy centre at lower floors with 364 flats, the erection of 3-7 storey building comprising a day nursery and 51 flats, and the erection of 9 buildings ranging from 3 to 5 storeys comprising 256 flats, 25 houses a cafe and shop. The scheme will also provide formation of vehicular access from Purley Way and Turners Way, opening up of the River Wandle, provision of associated parking spaces and contaminated land remediation works, and formation of cycle and pedestrian accessways.

55 Blocks ‘A’ and ‘B’ have been completed and provide 364 residential units, a medical centre, energy centre and proposed employment floorspace. Block ‘K’ is under construction and will provide 51 residential units and a nursery, with a proposal for a further 12 units (dealt with under separate planning application 10/00433/P).

56 The proposed uplift relates to the remainder of the site, and comprises an additional 74 private residential units resulting in the erection of 11 blocks ranging from 3 to 9 storeys giving a total of 496 residential class C3 units. Table 1 below outlines the net difference in residential accommodation by block, between consented application and the proposal.

Table 1 – Net difference in residential units between consented and proposed

Block Studio One-bed Two-bed Three-bed Four-bed C +6 D -5 -9 E +3 -3 F -6 +8 G -3 H -1 -5 -14 J -1 +10 +15 L +2 +9 +6 M +22 +24 N -4 +10 -1 P +2 +12 +2 -5 Sub-total 0 +29 +45 0 0 TOTAL 0 +74 0 0

Case history

57 In December 2003, the previous Mayor considered an application for redevelopment of the site to provide approximately 20,000 sq.m. of industrial and warehouse space, and a 2,800 sq.m. car dealership. He commented that the proposed land uses were acceptable in principle but expressed concern over the details, including a new access from Purley Way, the retention of a culvert over a section of the River Wandle through the site, and the scope to maximise the development potential of the site.

58 To address those concerns and, in particular, to meet the abnormal cost of de-culverting the River Wandle, the Mayor suggested the inclusion of an enabling residential development within the site. Whilst it was intended that the scale of enabling development would, as far as practicable, be commensurate with the cost of the suggested environmental improvements, Croydon Council resisted the introduction of a residential use on the site on planning policy grounds, i.e. its UDP designation for industrial employment purposes.

59 The Council subsequently refused planning permission for the development, however, permission was granted on appeal by the Secretary of State in November 2004.

page 10 60 A revised application (05/05134/P) was submitted in late 2005 (a description of which is provided in paragraph 13 of this report), and on 5 July 2006 the previous Mayor issued his initial consultation response. A number of issues were raised and subsequently addressed by the applicant, and following the Mayor’s decision to allow the Council to determine the case itself, the application was granted on 3 December 2007.

61 Following the approval of the above application, the site adjacent to the former gas works known as Commercial House, Vicarage Road was acquired by Barratt Homes and an application submitted for demolition of the vacant warehouses and erection of 41 apartments (08/01457/P). The GLA was not consulted. The council granted permission on 12 March 2009.

62 In January 2010 a further planning application (10/00433/P) was submitted for the construction of an additional story on block ‘K’ as part of intended improvements to application 05/05134/P. The proposals comprised an increase of 12 units to a total of 63 for the block. The GLA was not consulted. The council made a resolution to grant permission on 10 June 2010 subject to the completion of the Section 106 legal agreement. Strategic planning issues and relevant policies and guidance

63 The relevant issues and corresponding policies are as follows:

 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; Interim Housing SPG; Housing SPG EiP draft  Affordable housing London Plan; PPS3; Housing SPG, Housing Strategy; Interim Housing SPG; Housing SPG EiP draft  Density London Plan; PPS3; Housing SPG; Interim Housing SPG; Housing SPG EiP draft  Urban design London Plan; PPS1  Access London Plan; PPS1; Accessible London: achieving an inclusive environment SPG; Planning and Access for Disabled People: a good practice guide (ODPM)  Sustainable development London Plan; PPS1, PPS1 supplement; PPS3; PPG13; PPS22; draft PPS Planning for a Low Carbon Future in a Changing Climate; the Mayor’s Energy Strategy; Mayor’s draft Climate Change Mitigation and Adaptation Strategies; Mayor’s draft Water Strategy; Sustainable Design and Construction SPG  Transport and parking London Plan; the Mayor’s Transport Strategy

64 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 saved policies of the 2006 Croydon Unitary Development Plan and the London Plan (Consolidated with Alterations since 2004).

65 The following are also relevant material considerations:  The draft replacement London Plan, published in October 2009 for consultation.  The Croydon Core Strategy ‘Towards Preferred Options’ stage (further Regulation 25 report published in February 2010 for consultation.)

page 11 Principle of development

66 The principle for the use of the employment site for a major mixed-use proposal is established by the existing consent and does not need to be revisited.

67 This report, therefore, deals primarily with the design changes and proposed uplift of 74 residential units, and addresses policy changes which have occurred since permission for the New South Quarter (NSQ) site was granted. However, consideration will also be given to the wider site, and comments made on other key elements of the application. Housing

68 The applicant has submitted an accommodation schedule to provide a detailed comparison of residential units approved through planning permissions 05/05134/P (796 units), 08/01457/P (41 units) and 10/00433/P (12 units) and the 72 unit uplift associated with this application.

Housing mix

69 Table 1 (paragraph 15 of this report) demonstrates how the uplift associated with the proposal is designed in terms of housing mix. Of the additional 74 units proposed, 29 are one- bedroom flats and 45 are two-bedroom flats. While the proposals result in a reshuffling of certain other units between blocks, there is no net change in the overall provision of studio, three- bedroom or four-bedroom units as a result of this application.

70 When looking at the scheme holistically (including blocks ‘A’ and ‘B’, and considering the 12 unit uplift at block ‘K’) it is apparent there is some internal restructuring, but ultimately the net difference in housing mix remains similar to the permitted scheme. Ultimately there is one less studio; 29 additional one-bed units; 59 additional two-bed units; one less three-bed unit; and the 25 four-bedroom houses remain the same.

71 Given that the new units are proposed to be located on upper levels of existing blocks, and on existing floorplates (in order to preserve the desired configuration of the site, de-culverted river and other amenities) the net additional provision of only one and two-bedroom units is justified, and the overall housing mix at the site remains acceptable.

Affordable housing

72 No additional affordable housing is proposed as part of the residential uplift, therefore the total number of affordable units across the site (excluding Barratt’s Homebuy Direct units) remains unchanged at 259. As a result the overall percentage of affordable housing at the NSQ site has decreased from 31% to 28% by unit and 33% to 31% by habitable room.

73 The applicant has stated that the uplift of private units has been proposed in order to maintain the financial viability of the scheme, and therefore argues that to provide further affordable housing as part of this application would be impossible. While it is accepted there are exceptional costs associated with the development (not least in respect to the decontamination works and de-culverting of the River Wandle through the site), an affordable housing toolkit should be provided in order to adequately justify the percentage reduction in affordable housing as a result of the private residential uplift, in line with London Plan policy 3A.10.

Density

74 The proposals result in an increase in density at the site from 402 habitable rooms per hectare to 448 habitable rooms per hectare. This is at the upper limit of the London Plan indicative

page 12 range for an urban site with a PTAL of 3, but, never the less, represents an acceptable density for the site.

Space standards

75 In order to promote best practice, and in view of the emerging London Plan policy, the proposal has also been assessed against the space standards expressed in Table 3.3 of the draft replacement London Plan, and supported through the Housing SPG EiP draft and Interim London Housing Design Guide. Table 2 below provides a comparison of emerging space standards against those in the proposal in terms of gross internal floor area (GIA).

Table 2 – Comparison of emerging space standards against those proposed

Dwelling type Essential standard (GIA sq.m.) Proposal (GIA sq.m.) 1-bedroom flat 50 48 2-bedroom flat 61-70 56-110 3-bedroom flat 74-100 85-130 4-bedroom house 106-113 110

76 Table 2 demonstrates that while the proposed GIA for 3-bedroom flats and 4-bedroom houses exceeds those expressed by the emerging space standards, the range of unit sizes for 2- bedroom flats falls below the standards by 5 sq.m. for a number of units (33%), and those for 1- bedroom flats are 2 sq.m. below the emerging standard.

77 The applicant has stated that the nature of the development (essentially placing new levels of housing on top of previously consented blocks) limits the extent to which the foorplates of the new units can be adjusted. This argument is accepted, and on that basis the proposed gross internal floor area of the development is acceptable in view of the emerging space standards. Design

78 The additional unit numbers at the site have been accommodated on the upper floors of the approved development. Additional height has been located on blocks at the central and northern part of the site with increases to the height of blocks ‘J’, ‘N’ and ‘M’ of between 1 and 4 storeys and partial increases to blocks ‘C’, ‘D’ and ‘H’ of one story. Block L at the southern boundary of the site has seen a reduction in height of one storey.

79 The key height alterations appear within the central circus with the tallest elements located on the north side of the de-culverted river. Heights on the northern portion of the circus (block ‘M’) range from 5 to 9 storeys (including plant), while those on the southern portion (block ‘N’) range from 4 to 7 storeys (including plant). Block ‘J’, south of the de-culverted river towards the eastern boundary of the site with the tramlines and Wandle Park, accommodates an increase in height of between 1 and 3 storeys resulting in a range of 4 to 7 storeys (including plant) across the block as a whole. The remodelling of this block, and the adjacent estate road has also allowed an additional area of amenity space to be provided next to the River Wandle.

80 This approach maintains the strategy of a graduated decrease in height from north to south across the site. This helps to reflect the change in character of the locality, sensitively responding to the residential areas to the south and making the most of views across Wandle Park to the east. On this basis the approach is acceptable.

page 13 81 While the layout of the scheme has remained largely similar to the existing consent, the concentration of height within the circus has enabled a revised approach to amenity space to be adopted at the site.

82 A park or ‘boulevard’ to the south of the site has been proposed which creates 750 sq.m. of new amenity space within the development and offers properties fronting onto Waddon Close an improved outlook. The route from the boulevard leads directly into the core of the circus with the proposed bridge over the de-culverted river aligned to facilitate a more legible and direct north-south route.

83 Enhancements have also been made to the access of the central area of the circus which the new boulevard exploits. In the previous consent access to the circus was achieved via a single storey corridor. In contrast, the current proposals provide a 2 storey ‘arch’ directly aligned with the boulevard and river bridge. This provides a clear visual route into the circus and directly links the new boulevard amenity space with the amenity space within the circus.

84 The improvement of the archway and provision of the new amenity space is welcomed, and represents a significant enhancement to the south of the site. The applicant is, however, asked to improve the design further by considering the reconfiguration of blocks ‘F’ and ‘L’ in order to provide front doors onto the boulevard which will to introduce and encourage greater activity along the route.

85 The applicant should also look to enhance the nature of this space by reducing and reconfiguring the car parking on either side of the access road adjacent to block ‘L’. The applicant is asked to provide more typical parallel street parking, and to use the recovered space to provide gardens to block ‘L’ of a similar nature to those on the opposite side of the boulevard at block ‘F’.

86 The revised design also offers a number of other improvements to the site including a wider landscape buffer between the estate road and the southern boundary. The consolidation of car parking for Commercial House within the NSQ site improves the proposed frontage along Vicarage Way and creates a further area of green amenity space behind Commercial House.

87 On the whole, the design approach adopted for the development is acceptable, however, the applicant is asked to address the points raised above in order to deliver the highest standards of design for the site. Sustainable development

88 In summary, the proposals comprise a number of efficiency measures and the connection of the additional quantum of development into the existing biomass site heating network. The applicant has broadly followed the energy hierarchy set out in London Plan policy 4A.1 and sufficient information has been provided to understand the proposals as a whole. Further revisions and information are, however, required in order to verify carbon dioxide savings.

89 The whole site carbon emissions are estimated to be 2,132 tonnes of carbon dioxide per annum based on a 2006 Building Regulations compliant development. This includes 194 tonnes of carbon dioxide per annum due to the 86 additional dwellings.

90 The applicant should, however, provide a breakdown of the regulated and unregulated emissions for the baseline and at each stage of the energy hierarchy.

page 14 Be lean

91 A range of passive design features and demand reduction measures are proposed to reduce the carbon emissions of the proposed development. Both air permeability and heat loss parameters will be improved beyond the minimum requirements set by building regulations. Other features include energy efficient lighting and ventilation.

92 Further information is required on the regulated and unregulated carbon dioxide emissions after the application of energy efficiency measures. Information should also be provided on the savings from energy efficiency alone relative to a building regulations compliant development. It is possible, using best practice, for developments to achieve a 20% reduction compared to the target emissions rate of a 2006 Building Regulations compliant development through energy efficiency alone. This should be the aim for the additional dwellings included in the development.

Be clean

93 A site-wide heat network, served from an energy centre, supplies heat to the existing consented scheme. The applicant is proposing that the additional dwellings be connected to the site network. This approach is supported.

94 The applicant should provide further information regarding whether there are any existing or planned district heating networks, external to the whole development, to which the site heat network could be connected in the future. If an external network exists or is planned, the applicant should investigate the possibility for connection.

95 The applicant should also provide further information on the coverage of the existing heat network, including a schematic drawing, and the plans to expand the scheme further to supply other buildings in the vicinity.

96 No information is provided on how the dwellings will be passively cooled. Further information on the techniques that will be used to avoid the need for active cooling should be provided.

Be green

97 The existing district heating network is supplied by a 360 k.W. biomass boiler, along with 4 top up gas boilers. The biomass boiler meets 52% of the consented scheme’s heat load. The applicant is not proposing to increase the biomass boiler capacity and, as a result, the overall proportion of heat supplied by biomass will drop to 47%.

98 As currently proposed, no additional carbon reduction will be achieved through renewable energy. The applicant should, therefore, consider the potential for other forms of renewable energy which are complementary to the overall energy strategy. In particular, the potential for photovoltatic cells should be investigated. Information on the roof area available for panels, the amount of electricity that could be generated and carbon saved should be provided.

99 Based on the currently proposed scheme, the estimated carbon emissions of the whole development are 1,070 tonnes of carbon dioxide per year after the cumulative effect of energy efficiency measures and renewable energy has been taken into account. For the whole development, this equates to a claimed reduction of 50% compared to a 2006 Building Regulations compliant building. Further clarification is required on the reductions relating to the 86 additional dwellings.

page 15 100 On this basis, the proposals are acceptable in principle, subject to further information and revisions.

Transport

101 Given the congested nature of the A23 Purley Way and the availability of 630 consented car parking spaces for the entire site, TfL does not support the provision of an additional 34 spaces for the purpose of this application. Although the proposed parking ratio of 0.46 car parking spaces per residential unit is within the maximum car parking standards contained in the draft replacement London Plan, this level of parking is likely to exacerbate further the volume of congestion already present on Purley Way. This is particularly relevant given Croydon Council’s aspiration to deliver the Wellesley Road Master Plan which, as the result of reducing traffic capacity, will see traffic reassignment along other routes, including Purley Way. With respect to London Plan policy 3C.21 and 3C.23, and draft replacement London Plan policy 6.11 and 6.13, TfL strongly recommend that the applicant proposes a car free arrangement for this application. Further to this, TfL would also advise that any Blue Badge parking necessitated by this application should be allocated from the already consented parking spaces for the NSQ site. TfL supports the applicant’s commitment to disallow the eligibility of residents to apply for parking permits for use in the surrounding controlled parking zone and this should be secured through a planning condition.

102 The applicant proposes 74 additional cycle parking spaces to serve the uplift of 74 units (1 space per apartment). Since the residential units will consist of one, two and three bedroom apartments, TfL requires that the applicant provides a minimum of two cycle parking spaces for each of the 3 bedroom apartments proposed, in line with TfL minimum cycle parking standards set out in Table 6.2 contained within the draft replacement London Plan. In order to reduce bicycle theft, TfL also recommends that the cycle parking area is covered by CCTV.

103 The applicant’s transport assessment demonstrates that, of the public transport modes serving this development, most journeys are forecast to be made by tram. Given the limited capacity currently available on Tramlink services to accommodate the additional demand generated by the proposed scheme, TfL will be seeking tram capacity enhancement, particularly in the context of cumulative impact posed by the neighbouring site and specifically the previously consented New South Quarter scheme. In line with draft replacement London Plan policy 6.2 an appropriate contribution should be pooled, with monies secured from other developments, towards procuring new trams as required. TfL would welcome further discussions with the council and developer on this matter, in order to determine the exact level of contribution to be secured in the Section 106 agreement.

104 TfL notes the applicant’s proposal to provide acoustic glazing solutions to mitigate the noise impact to bedrooms overlooking the Croydon tram link at blocks J and P. Further to this, TfL also requires that the developer provides the recommended acoustic glazing solution for both bedrooms and living rooms to be accommodated on blocks J and P, in line with the Railways and Other Guided Systems (Noise Insulation) Regulations.

105 TfL requests the submission of a delivery and servicing plan (DSP) which should seek to rationalise servicing with the aim of reducing the total number of trips made and to avoid critical times on the highway network. Details should include booking systems, consolidated or retimed trips and secure off street loading and drop facilities. TfL notes that the applicant proposes to undertake servicing on-street. With respect to this TfL advise that it is preferable for all servicing arrangements to occur off-street, but if this is not possible, the applicant must provide measures within the DSP to set out how any on-street servicing will be managed to avoid congestion on the local road network.

page 16 106 TfL also requests the submission of a construction logistics plan (CLP), which should seek to minimise highway and traffic impact to the highway network during the course of construction. Details should include booking systems, consolidated or retimed trips and secure off street loading and drop facilities. Both the DSP and CLP should be secured through planning condition or a Section 106 agreement, and respond to the situation on the rest of the site. Due to the possible adverse impacts to Tramlink operations during the construction phase (such as vibration from piling), TfL would encourage the applicant to consult London Tramlink when preparing the CLP to ensure the appropriateness of any mitigation measures proposed. It is also advised that, during construction and whilst the development is operational, the developer should be committed to procuring environmentally sustainable firms, including those that can demonstrate willingness to adopt sustainable measures in logistics such as TfL’s freight operator recognition scheme.

107 The travel plan submitted does not currently comply with TfL guidance and further information is required in order for it to accord with London Plan policy 3C.2 and draft replacement London Plan policy 6.3. The applicant should include the number of staff, residents, visitors and deliveries expected on the application site, along with details of the phasing of the build out of the site. This phasing programme should then inform the targets and monitoring. Although mode share targets have been identified for all land uses, the applicant should clarify the time scales for which these targets are to be met. Further to this, a baseline mode split should be made clear along with interim targets for years three and five for each individual land use (timescales will vary depending on build out). An outline action plan, with more defined timescales, setting how and when the objectives of the travel plan will be completed should be produced. The budget for the travel plan measures should also be identified, along with a confirmation that the travel plan is funded through the development’s service charge. Local planning authority’s position

108 The view of the local planning authority is not known at the time of writing of this report. Legal considerations

109 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

110 There are no financial considerations at this stage. Conclusion

111 London Plan policies on employment, housing, affordable housing, density, urban design, sustainable development and transport are relevant to this application. The application complies with some of these policies but not with others, for the following reasons:

page 17  Employment: The principle for the use of this employment site for a major mixed-use proposal is established by the existing consent and is accepted.  Housing: While the proposed unit mix and density are acceptable in principle, the applicant is asked to submit an affordable housing toolkit adequately justifying the percentage reduction in affordable housing as a result of the proposed private residential uplift.  Urban design: While the design approach adopted is broadly acceptable, the applicant is asked to address the points raised in the urban design section of this report.  Sustainable development: While the proposals are broadly acceptable in principle, the applicant should address the points raised in the sustainable development section of this report providing further information as requested.  Transport: Further work and information is required to ensure the proposals accord with London Plan transport policies, the applicant is asked to address the points raised in the transport section of this report.

112 On balance, further information and work is required, and as a result the application does not yet comply with the London Plan.

113 The following changes might, however, remedy the above-mentioned deficiencies, and could possibly lead to the application becoming compliant with the London Plan:  Housing: The applicant should provide an affordable housing toolkit adequately justifying the percentage reduction in affordable housing as a result of the proposed private residential uplift.  Urban design: The applicant should address the comments made in the urban design section of this report.

 Sustainable development: The applicant should address the comments made in the sustainable development section of this report.

 Transport: The applicant should address the comments made in the transport section of this report.

for further information, contact Planning Decisions Unit: Colin Wilson, Senior Manager - Planning Decisions 020 7983 4783 email [email protected] Justin Carr, Strategic Planning Manager (Development Decisions) 020 7983 4895 email [email protected] Graham Clements, Case Officer 020 7983 4265 email [email protected]

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