Barham Park Estate, Sudbury - Greater London Authority

planning report PDU/2466/02
22 February 2010
Barham Park Estate, Sudbury
in the London borough of Brent
Planning application no. 09/2350
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
Hybrid planning application for the demolition and redevelopment of the entire Barham Park
Estate, comprising full planning permission for the erection of one part 4/part 5-storey block and
two part 6/part 8-storey blocks, containing in total 119 residential units, 422 sq.m. of retail
floorspace (Use Class A1 and A2) and a 121 sq.m. community facility (Use D1), with associated
parking, landscaping and amenity space; and outline planning permission for the erection of a
further 216 residential units (matters to be approved: land use, quantum of development and
means of access, with layout, scale, appearance and landscaping reserved).
The applicants
The applicants are Notting Hill Housing Trust and Countryside Properties, and the architect
is PRP.
Strategic issues
The issues raised at the consultation stage relating to affordable housing, children’s
playspace, urban design, access and inclusion, transport and energy matters have now
been adequately addressed through the submission of further information and the use of planning
conditions and/or the section 106 agreement.
Recommendation
That Brent 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 30 November 2009 the Mayor of London received documents from Brent 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”.
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2 On 6 January 2010 the Mayor considered planning report PDU/2466/01, and subsequently
advised Brent Council that the application did not comply with the London Plan, for the reasons
set out in paragraph 94 of the above-mentioned report; but that the possible remedies set out in
paragraph 95 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 3 February 2010 Brent Council
decided that it was minded to grant planning permission, and on 4 February 2010 it advised the
Mayor of this decision, although the referral was not received complete until 12 February 2010.
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 Brent Council under Article 6
to refuse the application or issue a direction to Council under Article 7 that he is to act as the
Local Planning Authority for the purposes of determining the application and any connected
application. The Mayor has until 25 February 2010 to notify the Council of his decision and to
issue any direction.
4 The decision on this case, and the reasons will be made available on the GLA’s website
www.london.gov.uk.
Update
5 At the consultation stage Brent Council was advised that the application did not comply with
the London Plan; but that the following possible remedies could address these deficiencies:
• Affordable housing: Further information on viability is required to determine that the
proposals are delivering the ‘maximum reasonable amount’ of affordable housing in line
with London Plan policy 3A.10. The proposed off-site arrangements should be secured as
part of the section 106 agreement if they are to be considered as part of this application.
• Children’s playspace: Further information is required in relation to the proposed
playspace areas and how existing adjacent areas will be improved as part of the overall
contribution.
• Urban design: Further detail on the proposed use of materials and the car parking
strategy are required.
• Access and inclusion: The services of a specialist access consultant should be secured
through the section 106 agreement or appropriate condition to ensure compliance of
reserved matters applications relating to landscaping and public realm.
• Transport: Further information should be provided in relation to the walking, cycling and
parking elements. A number of matters should also be addressed through the use of
planning conditions or the section 106 agreement.
• Climate change: Further information should be provided on the district heating elements,
the proposed combined heat and power, cooling of commercial and renewable options of
the proposal.
6 The applicant has provided further information on the proposals to address the deficiencies
identified, as set out in paragraphs 7 to 23 below.
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Affordable housing
7 Further information was previously requested on the viability of the estate regeneration to
determine whether the proposals are delivering the ‘maximum reasonable amount’ of affordable
housing in line with London Plan policy 3A.10. Clarification has since been provided on the levels
of social housing grant included within the toolkit and the applicants have confirmed that no
additional ‘kick start’ funding is required to deliver the proposals in addition to the proposed use of
social housing grant. An overage agreement has also been included within the development
agreement to ensure that of any surplus project income from the private sale accommodation, 25%
is provided to both the council and the housing trust, leaving 50% for the developer.
8 It was noted previously that in addition to the redevelopment proposals, the applicants intend
to use social housing grant to secure 91 off-site social rented dwellings for use as part of the
decant strategy, although it was unclear whether these units would be directly linked to the
Barham Park Estate regeneration proposals. The applicants have confirmed that of the 91 proposed
off-site units, social housing grant has only been secured for 23 units and that their delivery is not
to be secured through the section 106 agreement. Instead, the applicant has noted that “it is
proposed that the off-site affordable housing units will be secured through continued close working
between Brent Council and Notting Hill Housing Trust. Brent Council’s housing team is fully
supportive of this approach.”
9 Brent Council’s housing department has confirmed its satisfaction with this approach and to
the general housing mix of the proposals. However, as these off-site units are required as part of
the decant strategy to allow delivery of the proposal, it is disappointing that their delivery has not
been secured as part of the section 106 agreement.
10 On balance, the affordable housing issues have been adequately resolved.
Children’s playspace
11 The proposal has been revised to ensure that all playspace requirements can be met on-site,
negating the need to provide for section 106 improvements to the adjacent play area on the
Maybank Open Space. Using the methodology set out in the Mayor’s ‘Providing for Children’s
Information recreation’ SPG the applicants have confirmed that the proposal generates a need for
1,750 sq.m. of playspace and have demonstrated that a total of 1,949 sq.m. of informal and formal
playspace will be provided within the proposed podium garden, the central quadrant and the phase
1A courtyard to meet the needs of all the child age groups on the site.
12 As such, the playspace matters have been adequately addressed in line with London Plan policy
3D.14.
Urban design
13 The applicants have provided further information in relation to the proposed use of materials
and have confirmed that Brent Council’s Crime Prevention Design Officer is content with the safety
aspects of the proposed car parking provision. As such, the urban design matters have been
suitably addressed.
Access and inclusion
14 The applicants have commented that the services of a specialist access consultant are not
necessary due to the in-house experience of the appointed architects. But, as reserved matters
applications are not be referable to the Mayor for comment, reassurance was previously sought
that the highest levels of accessibility would be achieved as part of the proposals. This is
particularly important in the context of the level changes across the site and it is disappointing that
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a commitment to best practice has not been made to ensure that the detailed design stage delivers
a truly accessible proposal.
15 However, this matter is not of sufficient strategic importance to recommend a direction to
refuse and it is accepted that Brent Council will work to secure the necessary level of accessibility
at the detailed design stage.
Transport
16 At the consultation stage Transport for London (TfL) raised a number of concerns regarding
the details of the proposed development and transport assessment work.
17 Whilst the overall parking provision was agreed, it was requested that 20% of the parking
provision (32 spaces) be designated as electric charging bays. Only two spaces have been offered.
18 A planning condition has been secured regarding the details of the cycle parking, but a
pedestrian audit has not been provided and nor have improvements to pedestrian facilities been
offered. TfL accepts that this relates to the local network and is content for any pedestrian
improvements to be agreed with the Council at a later stage.
19 A travel plan has been secured within the draft section 106 agreement. Reference is made to
the setting up of a car club to be secured by a planning condition, with further details such as the
financial package for residents membership still to be provided. However, TfL is happy for this to
be agreed with the Council.
20 On balance, TfL considers that the development proposals are generally acceptable in transport
terms, although it is disappointing that the number of electric vehicle charging points do not meet
the Mayor’s electric vehicle delivery plan or the draft replacement London Plan (October 2009). It
is requested that the local authority and the applicants continue to work with TfL in relation to the
section 106 commitments and discharge of the relevant planning conditions.
Climate change
21 The applicants have provided further information on the district heating elements, the
proposed CHP, cooling of commercial uses and the proposed renewable options. These elements
are now acceptable. In addition, Brent Council has included a requirement within the draft section
106 agreement in order to deliver the approved energy strategy as follows:
“[The applicant is required to] Offset 20% of the site's carbon emissions through onsite site wide
heat network in conjunction with high performance building fabric as approved in the Energy
Statement (11 November 2009), with compensation should it not be delivered”.
22 As such, the climate change matters have been satisfactorily addressed.
Response to consultation
23 The application was advertised by site and press notices and consultation letters were sent to
some 460 neighbouring properties. As a result of this consultation, seven letters of objection were
received, which set out the following concerns:
• The demolition of 89 Central Road to create an access is unacceptable.
• Proposed emergency access should not be used in the future as an access road.
• Impact on local property values (not a material planning consideration).
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• The provision of retail uses will have a negative impact on existing businesses on Harrow
Road, Sudbury.
• The proposals will result in a loss of light, privacy and outlook to properties which are north
of the site on the opposite side of the railway.
• The number, size and design of the buildings is unacceptable and increased population will
lead to increased noise levels.
• Traffic congestion and public transport issues.
• The proposal fails to improve or enhance the character of the area.
• Lincoln Harford Solicitors have objected on behalf of 50 existing residents to the proposed
purchase of their properties by Notting Hill Housing Trust.
24 The Barham Park Residents’ Association also provided detailed comments on the proposals and
while it supports the regeneration of the estate, its letter sets out a number of issues relating to
design, wheelchair housing, parking, public transport and the proposed community centre. These
are on the whole local issues which have been adequately dealt with by the Brent Council through
the use of planning conditions. Other statutory consultees have responded as follows:
• Network Rail: no objection but request conditions/informative be attached.
• Thames Water: No objection subject to informatives.
• Environment Agency: No objection subject to conditions.
Article 7: Direction that the Mayor is to be the local planning authority
25 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 that matters raised at stage
I, therefore there is no sound planning reason for the Mayor to take over this application.
Legal considerations
26 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
27 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
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Other Planning Proceedings’) emphasises that parties usually pay their own expenses arising from
an appeal.
28 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.
29 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
30 The issues raised at the consultation stage relating to affordable housing, children’s playspace,
urban design, access and inclusion, transport and energy matters have now been adequately
addressed through the submission of further information and the use of planning conditions
and/or the section 106 agreement.
for further information, contact Planning Decisions Unit:
Colin Wilson, Senior Manager – Planning Decisions
020 7983 4783 email colin.wilson@london.gov.uk
Justin Carr, Strategic Planning Manager (Development Decisions)
020 7983 4895 email justin.carr@london.gov.uk
Shelley Gould, Case Officer
020 7983 4803 email shelley.gould@london.gov.u
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planning report 2466/01
6 January 2010
Barham Park Estate, Sudbury
in the London borough of Brent
Planning application no. 09/2350
Strategic planning application stage 1 referral (new powers)
Town & Country Planning Act 1990 (as amended); Greater London Authority Acts 1999 and 2007;
Town & Country Planning (Mayor of London) Order 2008
The proposal
Hybrid planning application for the demolition and redevelopment of the entire Barham Park
Estate, comprising: Full planning permission for the erection of 1 part four-/part five-storey block
and 2 part six-/part eight-storey blocks, comprising in total 119 residential units, 422 sq.m. of
retail floorspace (Use Class A1 and A2) and a 121 sq.m. community facility (Use D1), with
associated parking, landscaping and amenity space; and Outline Planning Permission for the
erection of a further 216 residential units (matters to be approved: land use, quantum of
development and means of access, with layout, scale, appearance and landscaping reserved).
The applicant
The applicants are Notting Hill Housing Trust and Countryside Properties, and the architect
is PRP.
Strategic issues
The principle of the redevelopment of the estate is supported.
The proposals do not currently meet strategic planning guidance in terms of unit mix or tenure
split and an additional off-site solution is proposed as part of the affordable housing offer.
Further information is required to determine that the proposals are delivering the ‘maximum
reasonable amount’ of affordable housing in line with London Plan policy 3A.10.
Further detail is required in relation to the children’s playspace, urban design and access and
inclusion elements, given the outline nature of the future phases.
Some further clarification and the use of section 106 agreement or planning conditions is required
in relation to transport and climate change matters.
Recommendation
That Brent Council be advised that while the application is generally acceptable in strategic
planning terms the application does not comply with the London Plan, for the reasons set out in
paragraph 95 of this report; but that the possible remedies set out in paragraph 94 of this report
could address these deficiencies.
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Context
1 On 30 November 2009 the Mayor of London received documents from Brent
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 8 January 2010 to
provide the Council with a statement setting out whether he considers that the
application complies with the London Plan, and his reasons for taking that view. The
Mayor may also provide other comments. This report sets out information for the
Mayor’s use in deciding what decision to make.
2 The application is referable under Category 1A 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”.
3 Once Brent 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 Mayor of London’s statement on this case will be made available on the GLA
website www.london.gov.uk.
Site description
5 The site is 2.82 hectares and is located in Sudbury, 1.6 kilometres west of Wembley
town centre. It is bound on the east side by Harrow Road, to the north by the railway line
which serves the Sudbury and Harrow Road railway station and to the east by the
Maybank open space. To the south of the site are the rear gardens of residential properties
which run along Central Road.
6 The site is currently a housing estate of large panel construction, a pre-fabricated
building system developed in the early 1970s. The estate comprises 214 dwellings within
28 separate blocks in buildings up to three storeys high. The existing dwellings are in a
poor state of repair and regeneration is required to address the issues of deprivation and
poor housing quality. The site also includes a car showroom and garage that fronts onto
Harrow Road.
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7 Figure 1: The proposed development site (source: DAS, PRP Architects)
8 The site is located to the west of Harrow Road (A404), part of the Strategic Road
Network (SRN) whilst the site is remote from the Transport for London Road Network
(TLRN). The site is served by six bus routes on Harrow Road adjacent to the site and is
located 380 metres from Sudbury and Harrow Road rail station and 450 metres from
Sudbury Town underground station (served by the Piccadilly Line). A footbridge over the
railway lines is located at the western end of the site providing a north / south pedestrian
route.
9 The site has a good level of public transport accessibility (rating of 4 on a scale of 1 to
6, where 6 is excellent).
Details of the proposal
10 The estate is currently managed by Brent Housing Partnership, the Council’s Arms
Length Management Organisation. The Council embarked on an options appraisal exercise
for the Barham Park Estate in 2003 and concluded, with residents, that complete
redevelopment was the best option. The Council undertook a selection process for a social
housing partner in late 2003 and selected Notting Hill Housing Trust and Countryside
Properties as its preferred partner in December 2004.
11 The proposed redevelopment area includes the estate itself, plus two adjacent areas of
land owned by Notting Hill Housing (the garage and car showroom). The proposals seek
planning permission for a 'hybrid' planning application comprising the demolition of the
existing buildings and the construction of 335 residential units (Use Class C3) including
56% affordable as follows:
• Full Planning Application for Phases 1A and 1B of the development involving
the construction of 119 residential units, 422 sq.m. retail floor space (Use Class
A1 and A2) and a 121 sq.m. community facility (Use Class B1 and D1) with
associated parking landscaping and amenity space
• An Outline Planning Application for Phases 2 and 3 of the development
involving the construction of 216 residential units (for which approval of
proposed land uses, quantum of development and means of access is sought,
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with Reserved Matters proposed to comprise layout, scale, appearance and
landscaping).
Case history
12 A pre-application meeting was held with the applicants and Brent Council in
September 2009 to discuss the proposals. The applicants were advised that the principle of
the redevelopment was acceptable, but that further information was required to ensure
that the level of affordable housing and the reprovision of social rented units on the site
would be in line with strategic planning guidance; and that the proposed unit mix and
tenure split would meet local housing need. Issues were also raised in relation to the urban
design, accessibility and climate change matters.
Strategic planning issues and relevant policies and guidance
13 The relevant issues and corresponding policies are as follows:
• Estate regeneration London Plan; Housing SPG; draft Interim revised Housing
SPG; draft Housing Strategy
• Affordable housing London Plan; PPS3; Housing SPG; Providing for Children
and Young People’s Play and Informal Recreation SPG; draft
Interim revised Housing SPG; draft Housing Strategy
• Urban design
London Plan; PPS1; Draft Housing Design Guide
• Open land
London Plan; PPG17; East London Green Grid network SPG
• Access
London Plan; PPS1; Accessible London: achieving an
inclusive environment SPG; Planning and Access for Disabled
People: a good practice guide (ODPM)
• Climate change London Plan; PPS1, PPS3; PPG13; PPS22; the Mayor’s
Energy Strategy; Sustainable Design and Construction SPG
• Transport
London Plan; the Mayor’s Transport Strategy; PPG13
14 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 Brent Unitary Development Plan 2004
and the London Plan (Consolidated with Alterations since 2004). The draft Core Strategy
has been submitted to the Secretary of State and the Examination in Public is expected to
commence in January 2010.
Principle of development
16 The proposed development site allocated as a 'Major Estate Regeneration Area' in the
adopted Brent UDP and as such, the principle of the development is supported. The
approach employed by the GLA when assessing estate renewal is to take into account the
regeneration benefits to the local community, the proportion of affordable housing in the
surrounding area, and the amount of affordable housing being, or planned to be, provided
elsewhere in the borough and these matters are dealt with in the following sections of this
report.
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Affordable housing
17 The Mayor’s Housing SPG notes that estate regeneration and redevelopment schemes
should be undertaken on the basis that a) there is no net loss of housing provision and b)
there is no net loss of affordable housing provision. The proposal is for the demolition of
the 214 existing properties and their replacement with approximately 332 new residential
units (as set out in Table 1 below). Of the replacement units, 56% by unit will be
affordable, although this does not include like-for-like reprovision of existing social rented
properties, with a tenure spilt of 65:35 between the social rented and intermediate
elements.
Justification of proposed tenure split and unit mix
18 There is no intermediate housing on the site at present and Table 2 above
demonstrates that the proposals will introduce an element of intermediate accommodation
(19% of the total offer). Paragraph 20.2 of the Housing SPG notes that “replacement of
social rented units by intermediate provision may be acceptable where this can be justified
by a requirement to achieve a wider range of types of provision in a neighbourhood”. The
applicants have noted that this comparatively higher intermediate offer is justified due to
viability constraints and has been provided to meet the aspirations of local residents
wishing to move from social rented to intermediate accommodation. The applicants have
also noted the intention to utilise social housing grant to secure an additional 91 social
rented dwellings as part of an off-site solution, although it is unclear that these units will
provide additional affordable housing directly linked to the Barham Park estate
regeneration proposals.
19 The proposals have been justified in the context of local housing need information, but
Brent Council’s housing team should provide confirmation that the proposed tenure and
unit mix are acceptable in terms of local housing circumstances.
Tables 1 and 2 below set out the existing and proposed housing mixes.
Table 1: Existing housing mix
Unit Tenure
Total by Total by
Housing
Market Affordable Unit Type Unit Type
Unit Type
SPG
(%)
Intermediate Social
Studios 0 0 0 0 0% 1%
1-bed 5 0 78 83 39% 31%
2-bed 8 0 52 60 28%
3-bed 16 0 55 71 33% 38%
4-bed 0 0 0 0 0% 30%
Total by Tenure 29 0 185 214 100% 100%
Total by Tenure (%) 14% 0% 86% 100%
Tenure split 0% 100%
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Table 2: Proposed housing mix
Unit Tenure
Market
Unit Type
Affordable
Total by
Unit Type
Total by
Unit Type
(%)
Housing
SPG
Intermediate Social
Studios 0 0 0 0 0% 1%
1-bed 42 19 48 109 33% 31%
2-bed 74 43 18 135 40%
3-bed 31 2 27 60 18% 38%
4-bed 1 1 29 31 9% 30%
Total by Tenure 148 65 122 335 100% 100%
Total by Tenure (%) 44% 19% 36% 100%
Tenure split 35% 65%
Loss of affordable housing
20 London Plan Policy 3A.15 ‘Loss of housing and affordable housing’ notes that DPD
policies should prevent the loss of housing, including affordable housing, without its
planned replacement at existing or higher densities (draft replacement London Plan policy
3.15 ‘Existing housing’ also states that the loss of affordable housing should be resisted
unless it is replaced at existing or higher densities with at least equivalent floorspace).
21 The redevelopment will result in the reprovision of the existing 187 affordable housing
units currently on the estate, by providing 122 social rented units and 65 intermediate
units. This results in an overall affordable housing offer of 56% through the
redevelopment, but a net loss of 65 social rented units. Paragraph 3.75 of the London
Plan notes that “where redevelopment of affordable housing is proposed, it should not be
permitted unless it is replaced by better quality accommodation, providing at least an
equivalent floorspace.” The applicants have provided information to demonstrate that the
proposals are for equal or more generous units and represent an increase in affordable
floorspace on the site, as well as a significant improvement on the standard of current
accommodation.
22 However, information on the current unit mix on the estate indicates that there are 83
x 1-bedroom units (39%), 60 x 2-bedroom units (28%) and 71 x 3-bedroom units (33%).
The proposals will result in an overall unit mix of 109 x 1-bedroom units (33%), 135 x 2-
bedroom units (40%), 60 x 3-bedroom units (18%) and 31 x 4-bedroom units (9%). While
the provision of larger 4-bedroom units is welcomed as is the overall increase in 3- and 4-
bedroom units compared with the existing provision from 71 units to 91. But the proposed
proportion of family-sized units including the addition of 31 x 4-bedroom units as part of
the estate regeneration does not represent an overall increase in the proportion of family
housing from the current offer (33% existing vs. 27% proposed). Current strategic
guidance is that 30% of all units should have 4-bedrooms or more.
23 There is some concern that an off-site solution is referred to in order to meet the
housing needs of the existing residents. Information has been provided on the proposed
off-site solution, which suggests that 91 additional social rented units will be delivered
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through the purchase of 38 market units for social rent and the purchase and repair of a
further 53 properties. Table 3 (below) sets out the detail of the off-site solution will
include some 22 3-bedroom and 4 bedroom units and suggests that the overall number of
affordable housing units associated with the scheme will, in fact, be 278 units.
Table 3: The proposed off-site solution
24 However, it is not clear how these sites are to be linked to the development proposals
to ensure that the existing residents’ needs are met or that these units are representing
true additionality in terms of affordable housing provision. If these additional off-site
units that have been secured through HCA social housing grant are not to be fully
incorporated within the proposals for the Barham Park estate redevelopment through a
legal agreement, then the proposed on-site unit mix should be revised to better reflect this
guidance. This is particularly important given the higher number of 2-bedroom units
proposed within the affordable offer and the stated need for increased levels of familysized
affordable housing in Brent.
Viability
25 The applicants have provided detailed viability information, including the levels of
social housing grant that are expected to be achieved, to justify the proposed tenure split
and to demonstrate that the site is delivering the ‘maximum reasonable amount’ of
affordable housing in line with London Plan policy 3A.10. The toolkit suggests that the
proposals will result in a £14 million deficit and that the redevelopment is, in fact,
unviable. The submitted information does raise a number of queries and the applicants
should provide further information on the following matters:
• Further information should be provided on the future lease payment arrangements
to Brent Council and any proposed overage arrangements for the private sale
accommodation.
• Confirmation should be provided that the £2.585 million acquisition cost noted in
the toolkit is inclusive of any grant/discount provided by Brent Council.
• Clarification should be provided on the assumed levels of grant included within the
toolkit as currently two different figures are provided, the confirmed level of
£17,995,000 in the supporting information and £28,756,339 in the toolkit itself.
26 The applicant should also provide further information on the additional ‘kick start’
grant funding that has been sought to meet the scheme deficit.
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Density
27 The density matrix set out in Table 3A.2 of the London Plan notes that an acceptable
range for an urban site with a public transport accessibility level of 4 to 6 (on a scale of 1
to 6 where 6 is the most accessible) should be between 200 and 700 habitable rooms per
hectare and the proposed density of the scheme falls comfortably within this range.
28 A number of matters require further clarification before it can be determined whether
the proposals comply with London Plan policy and strategic planning guidance relating to
housing and affordable housing.
Children’s play space
29 Policy 3D .13 of the London Plan sets out that “the Mayor will and the boroughs
should ensure developments that include housing make provision for play and informal
recreation, based on the expected child population generated by the scheme and an
assessment of future needs.” Using the methodology within the Mayor’s supplementary
planning guidance ‘Providing for Children and Young People’s Play and Informal
Recreation’ it is anticipated that there will be approximately 175 children within the
development. The guidance sets a benchmark of 10 sq.m. of useable child playspace to be
provided per child, with under-5 child playspace provided on-site. As such the
development should make provision for 1750 sq.m. of playspace.
Age split
Total by age split
0-5 21.5 39.1 68.6
05-11 9.8 58.6 65.1
12+ 5.1 41.9 42.2
36.38 139.6 175.98
30 The proposal includes private amenity space in the form of gardens for all family-sized
units and an on-site doorstep play space for the under 5s, which is located mid-way along
Roundtree Road. To ensure compliance with strategic planning policy, the applicants
should confirm the size of this proposed doorstep play area and confirm that that the
adjacent play areas of the Maybank public open space are suitable to meet the needs of
the older children of the development prior to any improvements that will be made
through the allocated section 106 contributions. The site also incorporates four areas of
public amenity space providing a total of 2, 538 sq.m. of public amenity space and this
should contribute towards informal play space provision.
31 Further information is required on how the playspace requirements will be met on the
site to determine compliance with London Plan policy 3D.13.
Urban design
32 The master plan concept for the site generally responds appropriately to the
surrounding residential development on the southern and the western edges of the site.
The increased scale of development along the Harrow Road frontage on its eastern edge
will create a prominent feature for the site, while the inclusion of the community centre
and retail uses at the ground floor level in this block will encourage activity along this
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important frontage. However, there is concern over the proposed height of block G, which
will be discussed in more detail later in this section.
33 As shown in Figure 2, the site is bound to the east by the Maybank public open space
and the orientation of the block AB takes advantage of views into this space, and provides
overlooking to the public footpath located on the southwestern part of the site. The
rationale of introducing a green link to connect the Maybank open space to Barham park
is strongly supported.
Fgure 2 – Proposed block layout
Layout, scale, appearance and residential quality
Source: Design and access statement
Block AB (Phase 1A – full planning application)
34 Block AB is located at the west end of the site and its context is varied in character and
nature. The railway line to the north is a source of noise and pollution. The pedestrian
bridge lands within this part of site, connecting to the established Public Right of Way,
which then runs across the site, connecting to Central Road and further south. Maybank
open space, located west of the site, offers the facilities of public open space and visual
amenity. To the east, additional residential units will be completed in the next phase of the
development.
35 The rationale of introducing a perimeter block configuration to provide a central
courtyard for the residents of this block is supported. As shown in Figure 3, the private
front doors to the maisonettes and communal entrances to the apartments are all arranged
around the outside perimeter of the block to create an active frontage. This configuration
also helps to improve the quality of the environment at the footbridge landing, and the
access route into Maybank open space, which is welcomed.
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36 The rationale of arranging larger family dwellings on the lower levels to benefit from
access to private amenity space, and with their own private entrances off the street, is
strongly supported. The concept of providing private roof terrace to the apartment on the
top floor is also welcomed. Whilst some single aspect flats have been included in this
block, single aspect north facing units have been avoided. Balconies and large windows to
this block has been configured to maximise views onto this amenity space. The majority of
the proposed units are of dual aspect and this is welcomed.
37 The proposed height of a 4/5-storey block for this location is considered appropriate.
The 5-storey element will form part of the key frontages along the railway boundary to the
north of the site, providing a strong identity to the site.
Figure 3 – Proposed layout to block AB Figure 4 – proposed perspective view facing railway line
Source: Design and access statement November 2009
38 As shown in Figure 4, the ‘wraparound’ cladding proposed to the top three floors of
the block is varied in colour and creates an interesting facade facing onto the railway line.
The external finish to the 4-storey element is calm and will create a warm domestic feel
along the street frontage. The application of a light facing material to the inner side of the
block will also lighten up the courtyard. The applicant should clarify how noise issues will
be dealt with within the building design.
39 The quality of public and private amenity space to the residents of this block is good.
The proposal of retaining existing trees in the southern part of the site is welcomed. The
ground floor units are provided with gardens or patios and all the apartments on the upper
levels will have a balcony providing private amenity space. All of the units within the block
will also share a communal landscaped courtyard. There is concern, however, over the
parking provision in the southern corner of the site and whether the parking in this
location will function effectively within the wider public realm strategy.
Block GH (Phase 1B - full planning application)
40 As shown in Figures 5 and 6, the strategy of assigning an energy centre, commercial
space and community facility to the ground level of block GH facing the Harrow Road
frontage is welcome and the rationale of providing retail facilities along Harrow Road to
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link the existing commercial activities on the north and south of the site is supported. This
proposed retail space will contribute to the improvement of the public realm as well as the
creation of an active street frontage. The location of the main entrance to the retail at the
junction of Harrow Road and Saunderton Road will also create a ‘gateway hub’ at the main
entrance into the site.
41 The orientation of the block enables the majority of the apartments to have dual
aspects and views towards Barham Park. The roof terraces also provide high quality private
amenity space for the apartments on the top floors.
42 The rationale of applying varying elevational treatments to break down the mass of
this linear block is supported. The frontages are of a high quality design that symbolise the
regeneration of the site. The proposed building frontage facing Harrow Road responds
well to the context of the busy Harrow Road. There is concern that the white render at
ground floor level of this block will encourage graffiti, as there is already an existing
problem of graffiti in the vicinity. The applicant is therefore asked to address this issue in
the next revision.
Figure 5 – Proposed layout to block GH Figure 6 – proposed perspective view to Harrow Road
frontage (Source: Design and access statement November 2009)
43 It is appropriate to include taller elements along the Harrow Road frontage to
emphasise the importance of this built edge and the rationale of including an 8-storey
block along Harrow Road is supported as it is adjacent to the elevated railway and
opposite an existing open space to the east of Harrow Road.
Blocks C, D, E, and F (Outlined application)
44 As shown in Figure 7, the arrangement of these blocks creates a hierarchy of buildings
and open spaces which provides interest along the street. It also helps to form part of the
key frontage to the railway line and the neighbouring areas to the north.
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Figure 7 – Proposed aerial view Source: Design and access statement November 2009
45 As shown in Figures 8 and 9, the proposed heights of 6-storey to Blocks C and E are
appropriate. However, the sitings of these two blocks are considered to be poor as they
are too close to the railway line. The applicant is therefore asked to create a larger set back
distance from the railway line to eliminate potential amenity issues.
Figure 8 – Proposed Roundtree Road view
at end of vistas
Source: Design and access statement
Figure 9: Proposed Roundtree Road view from
Gateway square
Source: Design and access statement November
46 These blocks support a good dwelling type mix, comprises of both family sized
maisonettes located on ground and first floors and smaller flats on the upper floors. The
rationale of locating some larger single level family dwellings on the top floor to benefit
from private roof terraces is welcomed. All the entrances to the buildings are located on
Roundtree Road which will help to generate an active street frontage and a strong building
line. Whilst most of the apartments in these blocks have been designed to maximise views
to the south, the submitted drawings fails to illustrate whether there will be any single
aspect north-facing apartments to these blocks.
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Blocks K, L, M, W, N, J and P, Q, S, T, R, U (Outline application)
47 Blocks K, L, M, W, N, J and P, Q, S, T, R, U are arranged as two perimeter blocks
located in the centre of the development. These blocks share a similar configuration and
consist of both houses and apartments. The rationale of arranging the apartment blocks to
serve as bookends with frontages facing east and west, and terraced housing units with
frontages onto south and north to form the infill element, is supported. This arrangement
supports a secure layout and an active frontage onto the streets.
48 The rationale of providing an undercrofted car park beneath the communal space is
strongly supported, as it provides a good response to the topography of the existing site.
This form of parking is secure and helps to minimise adverse impact to the streetscene.
The provision of amenity space and outlook are of good quality. The private or shared
outdoor amenity spaces, in the form of either back to back gardens or shared courtyards,
are provided on the inside of the blocks. All the apartments in blocks PU and NW will also
have dual aspects.
49 The proposed heights of the blocks are considered to be appropriate. These blocks will
help to form a strong frontage onto the street, since blocks A and B, located opposite, are
open at this end. All private and communal entrances to the dwellings flats in blocks K and
L will face the street, and there is an enclosed communal garden at the back.
50 The proposed heights of 3-storey to blocks J, M, Q, R are considered to be
appropriate. Their massing and location within the scheme will provide a balanced and
gradual increase in the buildings scale towards the north. The 3-storey houses on
Saunderton Road relate well to the scale and proportions of the existing houses in Central
Road, while the 4-storey corner elements create interest and articulation along the street.
The 3-storey houses on Roundtree Road also relates well to the 4 storey blocks along the
railway, with a good separation distance in between. The rationale of introducing taller
buildings to serve as markers to break down the length of the street is supported. All
houses will have frontages onto the street and a private garden at the back.
Elevational treatment
51 At present the information on the elevation treatment to all the proposed blocks are
limited to CGI drawings only. Whilst the proposed colour scheme to the elevations of the
blocks appears to have been designed to a good standard, there is concern that there is
excessive use of white render throughout the scheme. Considering the size of the site,
whilst a degree of similarity in elevational treatment will enhance the identity of the site, it
is also important to avoid uniformity and repetition across the scheme. The applicant
should provide further information on the following:
• Specific information on the palette of facing materials;
• Sizes, types and locations of fenestrations; and
• Balcony types.
Landscape and open spaces
52 The rationale of creating a landscape route along Saunderton Road to establish a
green link between the Maybank open space and Barham park is supported. The proposed
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massing of the blocks and the landscape design on the Harrow Road frontage will provide
a well defined built edge and a visually prominent entrance to the site.
53 The proposed Gateway Square, an enclosed open space created by blocks D, E and F,
will provide a main focal point for the development from Harrow Road. This open space
will be relatively ‘civic’ in nature with strong design lines reflecting the architecture from
the buildings and offer a change in material at ground level.
54 The rationale of introducing semi-mature trees with a strong canopy form to the
scheme is welcomed as they will frame the space and break up the urban elements from
the buildings.
55 The proposed layout of the blocks near the pedestrian foot bridge allows for a
pedestrian arrival point providing active frontages and natural surveillance to this area.
This arrival point will have a good level of natural surveillance by the residential units. The
proposed planting and landscape features will also enhance the quality of this space. The
orientation of the proposed block facing Maybank open space provides a positive response
to the relationship between the site and the open space.
56 The massing, streetscape and open space strategy are generally well considered and
help to facilitate a vibrant environment with a sense of hierarchy, safety and security.
Car Parking
57 The car parking arrangement to this scheme has generally been designed to a good
standard. Whilst recognising the high density requirements of the site, the proposals
provide adequate parking provision at street level. These parking areas are provided in the
form of informal road alignment and screened by planting. The rationale of breaking up
the parking bays into smaller groups to minimise adverse visual impact on the streetscene
is supported.
58 In summary, the design proposal for the Barham Park Estate regeneration offers an
opportunity to deliver a much improved design quality proposal than the existing.
Access and inclusion
59 All units will meet lifetime homes criteria and this has been demonstrated on plan. The
proposals also allow for 10% wheelchair adaptable units and these have been distributed
across the tenures and unit types. There are thought to be three existing residents who
require a wheelchair home and this will be accommodated within the proposals. It is
disappointing however, that many of the wheelchair adaptable homes will not be available
for wheelchair using residents due to the need to re-provide for existing residents.
60 Given the level change across the site and the proposed outline nature of future
phases of the development, the landscaping proposals should be developed in
consultation with a specialist access consultant and this should be secured through the use
of a planning condition or section 106 clause, to ensure that the highest standards of
access and inclusion are met, in line with strategic planning policy.
61 The proposals are not fully compliant with London Plan policy 4B.5 relating to access
and inclusion and further reassurance is required in relation to the reserved matters
proposals.
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Transport
62 The site is currently accessed from a left in/left out priority junction onto Harrow road
via Saunderton Road. This junction arrangement is proposed to remain, however, the
estate roads within the site are due to be modified to provide a loop road and an
additional emergency access route created onto Central Road at the south western corner
of the site.
63 The proposed access arrangements and provision of an emergency access is welcomed.
The proposed car parking provision is 162 spaces (0.5 spaces per unit) with 7 spaces for
the retail element. It is considered that this level of parking is acceptable given the sites
good public transport accessibility.
64 Disabled bays are proposed for 10% of the spaces with two bays assigned to the retail
unit and this is welcomed. Electric charging points should also be provided for 20% of the
total provision to meet targets within the draft replacement London Plan Policy 6.13 and
Mayor’s guidance on electric vehicles.
65 531 cycle parking spaces are provided within the scheme which is above Transport for
London’s (TfL) minimum standards and is welcomed. Further details of the cycle parking
will be required to ensure that they are safe, secure and weatherproof. This can be
addressed through a relevant planning condition.
66 The proposals include a loading bay at the rear of the retail unit which can
accommodate up to 10 metre rigid vehicles. A draft Service area Delivery & Service Plan
has been produced which is welcomed. The final document should be secured through the
S106 agreement and should include details of a booking system for the residential
deliveries to prevent failed deliveries.
67 A Construction & Logistics Plan will be required and should be secured through the
S106 agreement.
Walking and cycling
68 It is requested that a PERS Audit is undertaken to identify any deficiencies in the
pedestrian environment within the vicinity of the site. This audit should be accompanied
by walking isochrone figures detailing the routes to both stations and detailing the
locations and routes to local schools and amenities. It is expected that improvements to
the pedestrian environment will be required to ensure that walking is maximised as part of
the aims of the Travel Plan in line with London Plan policy 3C.21 ‘improving conditions for
walking’. A plan detailing the local cycle routes will also be necessary and the need for any
improvements to the routes identified in line with London Plan policy 3C.22 ‘Improving
conditions for cycling’.
69 Trip Generation and Transport Impact
70 It is considered that the trip generation methodology is acceptable and that the level
of additional trips that has been estimated is reasonable. Given the relatively low
numbers of additional trips by each mode it is accepted that there would not be a
significant impact on the operation of the bus, rail and underground services. It is also
considered that the development would not result in a significant impact on the highway
network.
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71 A construction management plan should though, be prepared to address any issues
arising during construction, and to ensure that the proposed development complies with
London Plan Policy 3C.25 (and Policy 6.14 of the London Plan consultation draft
replacement, October 2009). As part of this plan there should be provision to encourage
consolidation of loads and waste wherever possible.
Travel plan
72 A draft Travel Plan has been provided and the final document should be secured
through the S106 agreement in line with London Plan policy 3C.2 ‘Matching development
to transport capacity’. It is considered that a car club should be set up as part of the Travel
Plan and that two spaces on the site should be dedicated for car club use.
73 The Travel Plan must be adjusted to include an agreed way forward with a car club
operator including membership funding for one member per household for 10 years from
first occupation for all dwellings without a dedicated parking space. This car club package
should be secured through the S106 and referred to in the Travel Plan.
Summary
74 In principle, TfL does not have any objection to the proposed development subject to
the matters noted above being satisfactorily addressed through the provision of additional
information or the use of planning conditions/section 106 clauses, where appropriate to
ensure compliance with strategic planning policies 3C21, 3C.22, 3C.2, 3C.25 and draft
replacement London Plan Policy 6.13.
Climate change
75 The London Plan promotes five principles in policy 4A.9 to promote and support the
most effective adaptation to climate change. These are to minimise overheating and
contribute to heat island effects; minimise solar gain in summer; contribute to flood risk
reduction, including applying sustainable drainage; minimising water use; and protect
and enhance green infrastructure. Specific policies cover overheating, living roofs and
walls and water. The London Plan Consultation Draft Replacement Plan also includes
policies to ensure the development makes the fullest contribution to London’s
adaptation to climate change.
BE LEAN
Baseline carbon dioxide emissions (policy 4A.4 of London Plan)
76 A satisfactory approach has been undertaken to the calculation of the baseline
emissions, which on a whole energy basis, have been calculated by the applicant using
building regulations approved software to be 858 tonnes per annum.
Energy efficiency standards (Policy 4A.3 of the London Plan)
77 A combination of passive design and energy efficiency measures are proposed which
will collectively reduce carbon emissions by 13% beyond the overall development baseline.
The passive design features include optimisation of the orientation of the buildings,
improved fabric insulation U-values and improved air tightness beyond building
regulations minimum requirements. Other energy efficiency measures include improved
controls and heat recovery systems.
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78 While it is accepted that there is limited scope to go further than the 20% reduction in
regulated emissions envisaged for the dwellings, commitment should be made to measures
that will reduce non-regulated emissions in dwellings and further consideration should be
given to the energy efficiency measures to be adopted in the non-domestic buildings.
79 Paragraph 6.14 refers to a 20.3% saving for the dwellings over the ‘notional building’
through energy efficiency. The applicant should confirm that this saving is, in fact, over
the target emissions rate.
BE CLEAN
District heating (policies 4A.5 and 4A.6 of the London Plan)
80 The dwellings in Phase 1 of the development will be heated by communal heating fired
by boilers located in the basement of each block of flats. It is accepted that due to the
physical distances between the blocks in Phase 1 (they are at opposite ends of the
development site), together with demolition and construction works in the centre of the
site, that it is not practical to connect the blocks during Phase 1.
81 Upon completion of Phase 2, the blocks in Phase 1 and Phase 2 will be connected in a
wider district heating network for the site and served from a central energy centre, with
the original boilers in the basement of blocks acting as backup. The commitment to
develop a heat network across the development site is welcomed and should be secured
through the section 106 agreement or through the use of a planning condition.
82 According to the energy statement, there are 23 individual houses planned for the
development. Further clarification needs to be provided on whether these will be heated
by district heating and, if not, how heating will be provided.
83 The potential to connect to existing district heating networks, external to the site, has
been investigated using the London Heat Map. It appears that there are no heat networks
within the immediate vicinity, so connection to an external network is not an option for
this development at this stage. However, the site heat network will be designed in a way
that allows future connection to external heat networks. Further detail demonstrating that
the Harrow Road Energy Centre is large enough in size to accommodate the CHP, boilers
and associated plant should be provided.
Combined Heat and Power (Policy 4A.6)
84 The applicant proposes to install a 100kWe gas fired CHP unit in the Harrow Road
Energy Centre at the end of Phase 2, when the cumulative size of the heat load will make
it more technically and economically viable. This will produce a 26% reduction in emissions
over those due to energy efficiency measures.
85 The size of the CHP is in line with that which would be expected for a new build
development of this size and nature. However, further details should be provided of the
proposed strategy for CHP electricity sales e.g. to whom will the CHP electricity be sold,
what price is envisaged, etc.
Cooling (Policies 4A.6 of the London Plan)
86 The dwellings are being designed to avoid the need for mechanical cooling; most flats
will be designed to be dual aspect and shading devices will be used to minimise unwanted
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solar gain. Mechanical Cooling will be required in the retail unit, as heat gains from lights
and equipment will be more significant. However, further details of the approach adopted
to minimise cooling demand in the non-domestic buildings should be provided.
BE GREEN
Renewable energy technologies (policy 4A.7)
87 Across the phases, the applicant is proposing to install 392 sq.m. of photovoltaic cells
(PV), reducing overall emissions by 1.6%. While PV is compatible with the use of CHP, the
overall reduction achieved from renewable energy is low, especially when compared
against the London Plan 20% target. The applicant is, therefore, asked to consider
whether there is further scope to install more PV within the development, perhaps as part
of a phased approach.
88 In terms of renewable heat technologies, it is accepted that solar thermal will compete
for the base heat load supplied by the CHP and biomass boilers would adversely affect the
air quality in the vicinity of the development (which is located within an air quality
management area). It is also acknowledged that other on-site renewable technologies are
not suitable for this development given its particular characteristics.
89 The proposals are broadly acceptable in principle subject to further information being
provided to ensure compliance with London Plan policies 4A.5, 4A.6 and 4A.7.
Sustainable design and construction (policy 4A.9)
90 The London Plan promotes five principles in policy 4A.9 to promote and support the
most effective adaptation to climate change. These are to minimise overheating and
contribute to heat island effects; minimise solar gain in summer; contribute to flood risk
reduction, including applying sustainable drainage; minimising water use; and protect and
enhance green infrastructure. Specific policies cover overheating, living roofs and walls and
water. The London Plan Consultation Draft Replacement Plan also includes policies to
ensure the development makes the fullest contribution to London’s adaptation to climate
change.
91 The applicant has assessed the proposal against London Plan policy and the
sustainability assessment checklist from the Mayor’s Essential and Preferred Standards in
the Sustainable Design and Construction SPG and the results of this are generally
acceptable.
Local planning authority’s position
92 Brent Council is currently reviewing the proposals but supports the principle of the
estate redevelopment.
Legal considerations
93 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
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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
There are no financial considerations at this stage.
Conclusion
96 London Plan policies on estate regeneration, housing, children’s playspace, urban
design, access and inclusion, transport and climate change are relevant to this application.
The application complies with some of these policies but not with others, for the following
reasons:
• Estate regeneration: The principle of the redevelopment of the estate is
supported.
• Affordable housing: The proposals do not meet strategic planning guidance in
terms of unit mix or tenure split. Further information is required to determine that
the proposals are delivering the ‘maximum reasonable amount’ of affordable
housing in line with London Plan policy 3A.10.
• Children’s playspace: It is not clear that the proposals comply with London Plan
policy 3D.13.
• Urban design: Further information is required to ensure compliance with London
Plan policy 4B.1.
• Access and inclusion: The proposals comply with London Plan policies 3A.5 and
4B.5 in terms of housing provision, but the reserved matters applications will
require further consideration to ensure future compliance.
• Transport: The proposals do not fully comply with London Plan policies 3C.3,
3C.21, 3C.22 and 3C.25.
• Climate change: Further information is required to determine compliance with
London Plan policies 4A.5, 4A.6 and 4A.7.
Whilst the application is broadly acceptable in strategic planning terms, on balance, the
application does not comply with the London Plan. The following changes might, however,
remedy the above-mentioned deficiencies, and could possibly lead to the application
becoming compliant with the London Plan:
• Affordable housing: Further information on the viability elements is required to
determine that the proposals are delivering the ‘maximum reasonable amount’ of
affordable housing in line with London Plan policy 3A.10. The proposed off-site
arrangements should be secured as part of the section 106 agreement if they are
to be considered as part of this application.
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• Children’s playspace: Further information is required in relation to the proposed
playspace areas and how existing adjacent areas will be improved as part of the
overall contribution.
• Urban design: Further detail on the proposed use of materials and the car parking
strategy are required.
• Access and inclusion: The services of a specialist access consultant should be
secured through the section 106 agreement or appropriate condition to ensure
compliance of reserved matters applications relating to landscaping and public
realm.
• Transport: Further information should be provided in relation to the walking,
cycling and parking elements. A number of matters should also be addressed
through the use of planning conditions or the section 106 agreement.
• Climate change: Further information should be provided on the district heating
elements, the proposed CHP, cooling of commercial and renewable options of the
proposal.
for further information, contact Planning Decisions Unit:
Colin Wilson, Senior Manager - Planning Decisions
020 7983 4783 email colin.wilson@london.gov.uk
Justin Carr, Strategic Planning Manager (Development Decisions)
020 7983 4895 email justin.carr@london.gov.uk
Shelley Gould, Case Officer
020 7983 4803 email shelley.gould@london.gov.uk
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