SITE DESIGNATIONS

Relevant site designations:

Listed Building No

Conservation Area (CA) No

Archaeological Priority Areas N/a

Protected View (LVMF) N/a

LAND USE DETAILS

Site area 1,939sqm

Use Class Use Description Floorspace (Gross External Area)

Existing C2 Sheltered Housing Scheme

1,939sqm

Proposed Sui generis Short-term homeless housing

1,939sqm

RESIDENTIAL DETAILS

Residential Type No. of bedrooms per unit

Studio 1 2 3 4 5+

Existing Private flats 0 0 0 0 0 0

Private houses 0 0 0 0 0 0

Social rented flats 2 22 0 0 0 0

Proposed Private houses 0 0 0 0 0 0

Social rented flats 0 2 22 0 0 0

ADDRESS: Flats 1 - 24 Elderberry Grove And 4 And 10 Elder Road, SE27

Application Number: 16/07138/RG3 Case Officer: Ms Ruth Croll

Ward: Knights Hill Date Received: 22 December 2016

Proposal: Change of use from sheltered housing scheme (Use Class C2) to short term hostel (Use Class Sui Generis).

Drawing numbers: OS Map (647/090/01 C); 647/090/02 C; 647/090/03 C; 647/090/04 C; 647/090/05 C; 647/090/06 B; 647/090/07 B; 647/090/38 A; 647/090/39 A; 647/090/040 A; 647/090/41 A; 647/090/42 A; 647/090/043 A; 647/090/044; 647/090/45 A Documents: Planning Statement, “Summary of standards for flats & houses in multiple occupation”

RECOMMENDATION:

1. Resolve to grant conditional planning permission for the change of use.

2. Agree to delegate authority to the Assistant Director of Planning and Development to:

Finalise the recommended conditions as set out in this report including such refinements, amendments, additions and/or deletions as the Assistant Director of Planning and Development considers reasonably necessary

Applicant: London Borough of Lambeth

Agent: Mr Graham Burkle, Pellings LLP

PARKING DETAILS

Car Parking Spaces

(general)

Car Parking Spaces

(Disabled)

Bicycle Spaces

Motorbike Spaces

Existing 0 0 0 0

Proposed 0 0 0 0

EXECUTIVE SUMMARY The report relates to an application for planning permission for change of use of the premises from sheltered housing for older persons to short-term homeless housing provision. Pursuant to Section 38(6) of the Planning and Compulsory Purchase Act 2004, the application has been assessed in accordance with the development plan and material considerations including responses received following public notification and consultation on the application.

The closure of the Elderberry Grove was part of the Council’s wider older people’s housing programme, where the local housing authority has assessed and agreed that this sheltered housing accommodation is not fit for purpose and needs to be re-provided in new accommodation on the same site. The older people’s housing strategy has been informed by the changing requirements for older people’s specialist housing and accommodation with care provision. Elderberry Grove was decommissioned in June 2016 and all residents are understood to have been rehoused in appropriate alternative accommodation at New Cheviot Gardens. The Elderberry Grove site is proposed to be redeveloped at a later date as part of the Older People’s Housing Programme to provide additional extra care units. According to the applicant’s supporting planning statement, the Council has over the last 3 years continued to experience a high demand for temporary accommodation for homeless persons. This proposal is part of the Council’s strategy to meet its statutory duty towards homeless households. Pending its redevelopment, the proposed change of use of Elderberry Grove would enable more homeless households to be accommodated temporarily within the borough. The proposed change of use meets the provisions of relevant planning policy, where existing housing that met an identified need is no longer required for its current lawful use and, the proposed accommodation meets another identified priority local need. The site has good access to public transport and will afford convenient access to shops, services, community facilities and social networks appropriate to the needs of the intended occupiers. The proposed development would not give rise to unacceptable parking conditions on local roads or to traffic congestion in the area. The proposal involves no external alterations to the fabric of the buildings on the site and as such will not result in any loss of daylight, sunlight, outlook, openness or privacy. The use would remain residential albeit temporary in nature and as such is consistent with the predominantly residential character of the surrounding area.

Overall, the proposal is considered acceptable, and is recommended for approval subject to the recommendations made on the cover sheet to this report.

OFFICERS REPORT Reason for referral to PAC: The applications are reported to the Planning Applications Committee in accordance with (1) (iii) of the Committee’s terms of reference as it relates to the site having an area of 1 hectare or more. 1 SITE AND SURROUNDINGS

1.1 The application relates to land and buildings located on a 0.19ha site situated on the northern side of Linton Grove and the western side of Elder Road, in the Knights Hill Ward. The site is occupied by several single and 2-storey buildings. The buildings had previously been used to provide sheltered housing for older persons but were decommissioned in June 2016. The site is currently occupied by resident guardians.

1.2 To the immediate north west of the site is a substantial Grade II listed building, which historically accommodated West Norwood Congregational Church. The building is now understood to be in use as a day nursery. The site entrance on Linton Grove is adjacent to, but not within, the Elderwood Conservation Area. The site is also within close proximity to the Grade II listed St Luke’s Church of England Primary School. The site is bounded to the west and north by two storey residential properties. Adjacent to no. 4 Elder Road is a car repairs garage.

2 PROPOSAL

2.1 The application seeks full planning permission for the change of use of Elderberry Grove from sheltered housing for older persons (Use Class C2) to a short term hostel to house homeless households (Use Class Sui Generis).

2.2 There are currently 26 self-contained units comprised in 20 x 1 bedroom and 2 x studio units, each with its own kitchen and bathroom. The 1 bedroom units also benefit from a living room. Whilst no external alterations or internal remodelling to the units is proposed as part of this application, the proposal would see the living room in each unit being used as a bedroom, with the new occupiers sharing the kitchen and bathroom.

2.3 The submitted Planning Statement advises that Elderberry Grove was decommissioned in June 2016. It is understood from the Older Person’s Housing Strategy that residents were rehoused in the nearby New Cheviot Gardens extra-care development. The application site is currently occupied by property guardians to secure the buildings between uses.

2.4 The existing servicing arrangements (refuse and recycling storage and collection) would be maintained; a waste management plan to be approved by Veolia Environmental Services will be required as a condition of consent.

2.5 The existing off-street car parking provision would be retained and used for the parking of maintenance vehicles. The Planning Statement also suggests that this parking would be available to future occupiers but that vehicle ownership would be extremely limited.

Figure 1: Site Location Plan

Figure 2: Bird’s eye view of Elderberry Grove (outlined in red), facing north

Figure 3: View of 10 Elder Close and pedestrian access to Elderberry Grove

Figure 4: View of 17-24 Elderberry Grove and 4 Elder Road.

3 RELEVANT PLANNING HISTORY

3.1 There are no previous planning applications relevant to this application.

4 CONSULATIONS

4.1 Statutory Consultees

4.2 Responses were not received from Planning Policy, Waste or Transport. Officers have therefore referred to the comments received on applications 16/07137/RG3 (Denby Court) and 16/16/07136/RG3 (Westcott House). This approach is considered acceptable in this instance as the change of use proposed raises the same issues across all three sites.

4.2.1 Planning Policy: The change of use from sheltered housing to hostel would be acceptable in principle as long as the applicant can demonstrate that the existing accommodation is no longer required for its current lawful use and that the proposed accommodation will meet another identified priority need in relation to agreed strategies as set out in Policy H8 of the Local Plan. The acceptability of the proposal also needs to be assessed against the other tests set out in Policy H9 of the Local Plan.

4.2.2 Transport and Highways: No objections subject to the imposition of conditions for the appropriate amount of cycle storage consists with London Plan (2016) standards and the submission of a Delivery and Servicing Plan that should include details of parking, loading and turning area for service vehicles, including emergency vehicles.

4.2.3 Waste: No objections raised subject to the submission of a waste management plan.

4.3 Other Consultees

4.3.1 The following groups were consulted but had not responded at the time of drafting this report: Norwood Society, Norwood Forum and Turney Road Residents Association.

4.4 Adjoining owners/occupiers

4.4.1 In response to 77 letters of neighbour consultations, two responses objecting to the proposal have been received. A summary of the concerns raised is set out below:

Summary of objections Response

Noise

Homeless families will make more noise than the current tenants.

The level of noise made by families would not be anticipated to exceed that which would normally be expected within a residential setting. Any excessive noise made by families would be an anti-social behaviour issue which would be addressed through tenancy agreements and adequate management of the property by the landlord.

Neighbouring Amenity

The proposal would lower my quality of life.

No external alterations are proposed and therefore there would be no impact upon

daylight, sunlight or outlook to neighbouring properties. The proposed units would provide temporary accommodation to homeless families and would not be anticipated to result in excessive noise levels. It is therefore not considered that the proposed change of use would lower the quality of life of any neighbouring occupiers.

Other

Only existing plans are available online which do not show any proposed alterations.

The proposed plans were made publicly available on 23 February 2017. No internal or external alterations are proposed by this application and therefore is the absence of proposed plans is not considered to have prejudiced the ability of residents to make informed representations on the development.

5 POLICIES

5.1 Section 38(6) of the Planning and Compulsory Purchase Act 2004 requires planning decisions to be made in accordance with the development plan unless material considerations indicate otherwise.

5.2 The development plan in Lambeth is the London Plan (2016) and the Lambeth Local Plan (September 2015).

5.3 The National Planning Policy Framework was published in 2012. This document sets out the Government’s planning policies for England including the presumption in favour of sustainable development and, is a material consideration in the determination of all applications.

5.4 The current planning application has been considered against all relevant national, regional and local planning policies as well as any relevant guidance. Set out below are those policies most relevant to the application, however, consideration is made against the development plan as a whole.

5.5 The London Plan (2016)

- Policy 3.1 Ensuring Equal Life Chances for All - Policy 3.8 Housing Choice - Policy 3.14 Existing Housing - Policy 3.17 Heath and Social Care Facilities - Policy 6.9 Cycling - Policy 6.13 Parking - Policy 7.1 Lifetime Neighbourhoods - Policy 7.2 An Inclusive Environment

- Policy 7.3 Designing Out Crime - Policy 8.2 Planning Obligations

5.6 Lambeth Local Plan (2015)

- Policy D1 Delivery and monitoring - Policy D2 Presumption in favour of sustainable development - Policy D3 Infrastructure - Policy D4 Planning obligations - Policy H3 Safeguarding existing housing - Policy H5 Housing standards - Policy H8 Housing to meet specific community needs - Policy H9 Hostels and houses in multiple occupation - Policy T2 Walking - Policy T3 Cycling - Policy T6 Assessing impacts of development on transport capacity and infrastructure - Policy T7 Parking - Policy T8 Servicing - Policy EN7 Sustainable waste management - Policy Q1 Inclusive environments - Policy Q2 Amenity - Policy Q3 Community safety - Policy Q12 Refuse/recycling storage - Policy Q13 Cycle Storage

5.7 Additional Guidance

- Refuse and Recycling Storage Design Guide (2013) 6 ASSESSMENT

6.1 Land Use

6.1.1 The proposal seeks planning permission for change of use of the premises from a sheltered housing scheme for older persons (Use Class C2) to a homeless persons’ hostel providing short-term accommodation (Use Class Sui Generis). Policy H8 (b) of the Lambeth Local Plan supports the loss of housing, which meets an identified specific community need where the following is demonstrated:-

(i) the accommodation is no longer needed and the new accommodation will instead meet another identified priority need; or

(ii) the existing accommodation will be adequately re-provided to an equivalent or better standard on-site or elsewhere in the borough.

6.1.2 Supporting text to this policy defines “housing to meet specific community needs” as that including sheltered housing with care support, staffed hostels, residential-care and nursing-care homes, extra-care housing and supported housing provision for children, older persons and other client groups. This specialist housing is considered as essential accommodation for the most disadvantage and vulnerable residents within the borough. In this case, the identified client group are homeless households or persons. Policy requires their need for housing to be assessed having regard to Lambeth’s Housing Strategy and associated client group sub-strategies.

6.1.3 The acceptability of the change of use/loss of the sheltered accommodation for older

persons therefore requires one of the two criteria set out in Policy H8 (b) to be satisfied, having regard to the Council’s housing strategy. In relation to criteria (ii), it is understood that following the decommissioning of Elderberry Grove, all residents were rehoused in appropriate alternative accommodation. Specifically, the Older Person’s Housing Strategy states that residents were rehoused within the Cheviot Gardens development which provides 66 rented and 18 shared ownership properties for older people. The decommissioning of Elderberry Grove forms part of the wider aims of the Council as set out within Lambeth’s Older Person’s Housing Strategy and the site is earmarked for future development of a larger extra-care scheme.

6.1.4 On this basis the change of use/loss of the existing sheltered housing scheme for elderly people to temporary hostel accommodation for homeless people is acceptable in principle because a facility of equivalent functionality has been provided locally (i.e. Cheviot Gardens). Moreover, the site is scheduled to be redeveloped as a specialist older person’s development in due course; the proposed use of the site will provide temporary accommodation for homeless households whilst the procurement of the redevelopment of the site is being secured.

6.1.5 In relation to criteria (i) reference is made to the Lambeth Homelessness Strategy (2012 -17), which identifies the Borough’s 3 key strategic priorities as being the following:-.

(i) To prevent homelessness by supporting all households in their home or to help find alternative accommodation.

(ii) To develop tenancy sustainment and support services in the private rented

sector to ensure affordable supply and choice of accommodation.

(iii) To manage the impact of welfare reforms and develop policies to mitigate risks of increased homelessness and temporary accommodation.

6.1.6 Lambeth Local Plan Policy H9 (a) states that the council will support proposals for new hostels and houses in multiple occupation (HMOs) where it is demonstrated inter alia that the accommodation:

would meet an identified local need;

will be suitable for the intended occupiers in terms of the standard of facilities;

will be accessible to public transport, shops, services, community facilities and social networks appropriate to the needs of the intended occupiers;

will not have an unacceptable impact on parking conditions and traffic congestion in the area

6.1.7 Supporting text to Policy H9 clarifies the status of hostels (sui generis use – meaning the use does not fall within specific use classes that are set out in the Town and Country Planning (Use Classes) Order 1987 (as amended)). It states that for purposes of the policy, a hostel includes a “building providing temporary non-self-contained residential accommodation with an element of supervision, but with no significant degree of care. “ This distinguishes the current use of the site as sheltered housing for older persons (Use Class C2) from the proposed short term hostel use to

provide accommodation for homeless households (Use Class Sui Generis) and, therefore establishes a need for planning permission for the proposed change of use.

6.1.8 The need for specific housing for those that are homeless in the borough has been identified through the Lambeth Housing Strategy as a vulnerable group that need to be provided effective support to meet their housing needs. The proposed change of use accords with the objectives of Lambeth Local Plan Policy H9 having regard to the Council’s Housing Strategy and the Council’s Homelessness Strategy (2012-2017). The latter seeks, inter alia to prevent homelessness by supporting all households in their home or to help find alternative accommodation. The proposal also meets criteria (i) of Policy H8(b) of the Local Plan because the accommodation is no longer needed as it is considered not fit for purpose and the new accommodation will instead meet another identified priority need.

6.2 Design and Conservation

6.2.1 There are no design or conservation impacts for consideration as part of this proposal. It is noted that the application site is within the immediate vicinity of a number of heritage assets. However, as no internal or external alterations are proposed, it is not considered that the development would result in any impacts upon those assets.

6.3 Standard of residential accommodation

6.3.1 The proposed use would constitute a hostel for which there are no minimum space standards set within planning policy for housing. Minimum standards for hostels and HMOs are set at a national level within the Housing Act 2004, which falls within the remit of environmental health. At a local level, Lambeth has adopted additional HMO standards which supplement those set nationally and are implemented through HMO Licencing.

6.3.2 Lambeth Environmental Health have produced a document (“Summary of standards for flats & houses in multiple occupation”) which sets out the requisite standards for hostels and HMOs. This states that for each person with cooking facilities in a separate room, the minimum room size of the kitchen for exclusive or shared use is 6.5sqm for 1 person; 10.25sqm for 2 persons; 15sqm for 3 persons; 19.5sqm for 4 persons and 24sqm for 5 persons, respectively. For bathroom/shower facilities, 1 bathroom/shower is required for 1-5 persons.

6.3.3 It is not proposed to reconfigure the internal layout of the existing buildings and this could result in the kitchens failing to meet the minimum space standard for hostels and HMOs. However, these standards are not a material planning consideration and failure to comply with these standards should not prejudice the granting of planning permission. The proposed use would constitute a hostel for which there are no minimum space standards set within planning policy for housing.

6.3.4 Notwithstanding this, the proposal would provide a large number of bed spaces to meet a specific identified housing need and future residents would not be expected to occupy the units for a period exceeding six months. Therefore, there are no planning objections to the standard of accommodation.

Figure 5: Example proposed unit layout (two bedroom)

6.4 Neighbour Amenity

6.4.1 The proposed change of use would not give rise to any unacceptable impacts on the amenity of neighbours in terms of loss of privacy, outlook or natural lighting as no external alterations to the buildings are proposed. The requirements of Policy Q2 of the Local Plan in terms of design considerations therefore do not apply to this case. Concerns raised regarding potential noise by future tenants are noted, however, this is a matter that would be addressed through property management and appropriate tenancy agreements.

6.5 Transport

6.5.1 The NPPF seeks to promote sustainable transport and in doing so it seeks to ensure that new development, which generates significant movements is located where the need to travel would be minimized and the use of sustainable modes can be maximized. This is echoed by Policies 6.1 and 6.3 of the London Plan, which also seek to ensure that the impacts of development on transport capacity and the

transport network are fully assessed.

6.5.2 Policy T6 seeks to ensure that development does not have an unacceptable impact upon transport capacity and infrastructure. Policies T7 and T8 of the Lambeth Local Plan relate to car parking and servicing. Policies T1, T2 and T3 promote sustainable travel, walking and cycling. These policies require development not to cause unacceptable harm to either public or private transport networks or have an adverse impact on transport safety. Walking and cycling are encouraged

Accessibility

6.5.3 The site is in an accessible location, served by public transport and has a Public Transport Accessibility Level rating of 4, which equates to a ‘good’ levels of public transport accessibility.

Car Parking and Traffic

6.5.4 The site is not within a controlled parking zone and therefore parking cannot be controlled through the removal of parking permits. No comments were provided on this application but the Transport Officer did raise concerns regarding additional parking pressures as a result of the change of use of Westcott House and requested the submission of a parking stress survey report. Although the Transport Officer’s concern is noted, the proposed hostel would provide short term accommodation to homeless households who are far less likely to own a private vehicle. Experience from similar Council operated hostels within the borough supports this assertion and it is therefore not considered necessary for the applicant to undertake a parking stress survey.

Cycle Parking

6.5.5 In order to comply with the London Plan’s cycle parking standards, a minimum of two secure, covered cycle storage spaces are required on the site.

6.5.6 The submitted plans did not illustrate the area for cycle storage. However it is considered that the site could accommodate the requisite cycle storage within the communal area. The detail of the cycle storage can be secured through the imposition of an appropriate condition.

6.6 Refuse and Recycling

6.6.1 Lambeth Local Plan Policy Q12 relates to refuse and recycling storage and requires arrangements for waste storage to be integrated into the design of a development from the outset to ensure that it is attractively designed and conveniently located for users and collection.

6.6.2 The submitted plans do not identify the area for the refuse and recycling store. However, given that the residential nature of the site is not changing, it is considered the existing refuse storage area could continue to be used or have its capacity increased to meet current requirements for refuse storage and recycling. Detailed drawings illustrating the provision for refuse and recycling storage are reserved as a condition of consent together with a waste manage plan, which should be submitted and approved in writing before the change of use of the properties can take place.

6.7 Community Safety/Designing out Crime

6.7.1 London Plan 2015 Policy 7.3 states that development should amongst other things, reduce opportunities for crime and contribute to a sense of security. In particular, there should be well maintained routes, a clear indication of whether spaces being provided are private, semi-private or public with natural surveillance of publicly accessible spaces from buildings at their lower floors, design should encourage activity appropriate to the location, promote a sense of ownership of communal spaces, places and buildings should integrate security features into the design and minimise on-going management and future maintenance. Policy Q3 (Community safety) requires developments to be designed in a manner that does not engender opportunities for crime or anti-social behaviour or create a hostile environment that would produce fear of crime.

6.7.2 No external alterations to the buildings or boundary treatments are proposed and although there would not be full-time staff on the site the good behaviour of tenants could be secured through an appropriate tenancy agreement. Criminal activity associated with the change in use could be addressed through other legislation including policing. It is not considered necessary to require the development to introduce new physical protection measures to address potential anti-social behaviour.

7 CONCLUSION

7.1 Having regard to the above assessment it is considered that subject to the conditions set out below the proposed development would comply with the relevant policies of the development plan, accordingly the application is recommended for approval.

8 RECOMMENDATION

8.1 Resolve to grant conditional planning permission.

8.2 Agree to delegate authority to the Assistant Director of Planning and Development to:

1. Finalise the recommended conditions as set out in this report including such refinements, amendments, additions and/or deletions as the Assistant Director of Planning and Development considers reasonably necessary

Conditions and Reasons

General

1. Time period (standard three years)

The development to which this permission relates must be begun no later than three years from the date of this decision notice.

Reason: To comply with the provisions of Section 91 of the Town and Country Planning Act 1990.

2. In accordance with approved plans

The development hereby permitted shall be carried out in complete accordance with the approved plans and drawings listed in this decision notice, other than where those details are altered pursuant to the conditions of this planning permission.

Reason: For the avoidance of doubt and in the interests of proper planning.

3. Waste and recycling storage (to be submitted and provided)

Prior to the commencement of the use hereby permitted, details of waste and recycling storage and management plan for the development shall be submitted to and approved in writing by the Local Planning Authority. The waste and recycling storage shall be provided and managed in accordance with the approved details prior to the commencement of the use hereby permitted, and shall thereafter be retained solely for its designated use. The waste and recycling storage areas/facilities should comply with the Lambeth’s Refuse & Recycling Storage Design Guide (2013), unless it is demonstrated in the submissions that such provision is inappropriate for this specific development.

Reason: To ensure suitable provision for the occupiers of the development, to encourage the sustainable management of waste and to safeguard the visual amenities of the area (policies Q2 and Q12 of the London Borough of Lambeth Local Plan (2015)).

4. Delivery and Servicing Management Plan Prior to the commencement of the use hereby permitted, details of a Delivery and

Servicing Management Plan for the development shall be submitted to and approved in writing by the Local Planning Authority. The development shall thereafter be operated in accordance with the approved Delivery and Servicing Management Plan for the duration of the use. Reason: To ensure minimal nuisance or disturbance is caused to the detriment of the amenities of adjoining occupiers and of the area generally, and to avoid unnecessary hazard and obstruction to the public highway (Policies EN4, EN7, Q12 and T8 of the London Borough of Lambeth Local Plan 2015).

5 Cycling

Prior to the occupation of the development hereby permitted, details of the provision to be made for cycle parking, including plans and elevations at a scale of 1:20, shall be submitted to and approved in writing by the Local Planning Authority. The cycle parking shall thereafter be implemented in full in accordance with the approved details and shall thereafter be retained solely for its designated use. The cycle parking must be secure and covered and all spaces should be horizontal.

Reason: To ensure adequate cycle parking is available on site and to promote sustainable modes of transport and maintain the character and appearance of the conservation area. (Policies T1, T3, Q13 and Q22 of the London Borough of Lambeth

Local Plan (2015)).

Informatives(s) 1. This decision letter does not convey an approval or consent which may be required

under any enactment, by-law, order or regulation, other than Section 57 of the Town and Country Planning Act 1990.

2. You are advised that this consent is without prejudice to any rights which may be enjoyed by any tenants/occupiers of the premises.

3. Your attention is drawn to the provisions of the Building Regulations, and related legislation which must be complied with to the satisfaction of the Council's Building Control Officer.

4. Your attention is drawn to Sections 4 and 7 of the Chronically Sick and Disabled Persons Act 1970 and the Code of Practice for Access for the Disabled to Buildings (B.S. 5810:1979) regarding the provision of means of access, parking facilities and sanitary conveniences for the needs of persons visiting, using or employed at the building or premises who are disabled.

5. You are advised of the necessity to consult the Council's Streetcare team within the Public Protection Division with regard to the provision of refuse storage and collection facilities.

Background documents – Case file (this can be accessed via the planning Advice Desk, Telephone 020 7 926 1180). For advice on how to make further written submissions or to register to speak on this item, please contact Democratic Services, 020 796 2170 or email.