Planning Statement · 1.2 The proposed building will provide 45 self-contained one-bedroom dwelling...

Planning Statement

Prepared by Boyer on behalf of Pocket Living | May 2016

47 Gainsford Road, Walthamstow, E17

Report Control

Project: Gainsford Road

Client: Pocket Living

Reference: 15.776

File Origin: E:\15.776\4 Boyer Planning\4.02 Reports

Primary Author J Daniels

Checked By: G Leggett

Issue Date Status Checked By

V0 13.05.2016 Draft J Daniels

V1 16.05.2016 Final G Leggett/N Williams

TABLE OF CONTENTS

1. INTRODUCTION 3

2. POCKET & THE MAYOR’S HOUSING COVENANT 4

Pocket 4

Mayor of London’s Housing Covenant 4

3. THE SITE & SURROUNDING CONTEXT 6

The Site 6

Surrounding Context 6

4. SITE HISTORY INC. PLANNING HISTORY 7

Site History 7

Planning History 7

5. PRE-APPLICATION DISCUSSIONS 8

Pre-Application Discussions with LBWF 8

6. THE PROPOSED DEVELOPMENT 9

7. THE DEVELOPMENT PLAN 10

National Planning Policy Framework (2012) 10

The London Plan (2015) 11

LBWF Core Strategy (2012) 15

LBWF Development Management Policies (2013) 17

8. PLANNING ASSESSMENT 19

Principle of Development 19

Housing Policies 23

Daylight, Sunlight & Overshadowing 29

Design 30

Technical Assessment 30

9. SUMMARY & CONCLUSIONS 33

Planning Statement | 47 Gainsford Road

APPENDIX

Appendix One – COUNCIL’S CABINET REPORT

Appendix Two – EXISTING BLDG. FLOORPLAN

Appendix Three – ASBESTOS SURVEY


3

1. INTRODUCTION

1.1 This Planning Statement is submitted in support of a planning application made on behalf of

Pocket Living for the demolition of the existing buildings (B1a Use Class) at 47 Gainsford

Road, Walthamstow, E17 6QB followed by the erection of a new part two, part three, part

four storey residential building (C3 Use Class).

1.2 The proposed building will provide 45 self-contained one-bedroom dwelling flats (100%

intermediate affordable housing tenure). The proposals also include the provision of private

and communal amenity spaces for the building’s residents, secure cycle and refuse storage

facilities, site landscaping and improvements to the public realm.

1.3 This statement includes more information about the Pocket model of affordable housing,

explains the proposals in detail and provides an assessment of the proposals against the

relevant planning policies contained within the London Borough of Waltham Forest (LBWF)

Development Plan. Other material considerations that are relevant to the proposals are also

examined.


2. POCKET & THE MAYOR’S HOUSING COVENANT

Pocket

2.1 Pocket is an award-winning developer that provides a unique type of intermediate affordable

housing to Londoners on low to medium incomes. Pocket homes are specifically targeted at

helping those working Londoners who fall between the social housing and private housing

markets. Pocket provides these people with an opportunity to buy their own home at an

affordable price, own their own home outright, and eventually move up the housing ladder.

2.2 Pocket homes are purchased on a 100% equity basis with no public subsidy. Sale prices are

set at least 20% beneath open market levels.

2.3 Through the lease conditions, provisions and clauses within the S106 Agreement, Pocket

ensures that its homes remain affordable in perpetuity. This distinguishes Pocket homes

from shared-ownership homes, whose buyers can, over time, acquire additional equity

(termed ‘staircasing’) until they own 100% equity and can sell the property freely on the open

market. Pocket homes are not available to buy-to-let investors.

2.4 Pocket homes are affordable because of the way they are designed. They are smart,

compact dwellings of 38m2, aimed at single-occupancy living. The compact size enables

them to be built to a high specification with low maintenance costs and low service charges.

Pocket developments are sustainable, Lifetime Homes compliant and include high quality

communal amenity areas.

2.5 Pocket’s first completed development was in the London Borough of Camden and won a

Camden Building Quality Award, was highly commended in the Evening Standard New

Homes Awards and was shortlisted for the National Housing Design Awards in 2009. It also

received a Building for Live Silver Standard Award.

2.6 A Pocket scheme in Westminster won the RIBA 2013 London Regional Award, the RICS

London 2013 Residential Award and was Best Development in the Affordable Homes Sector

at the Evening Standard Homes and Property Awards 2012.

Mayor of London’s Housing Covenant

2.7 In September 2012 the GLA published the Mayor’s Housing Covenant (homes for working

Londoners).

2.8 The Mayor acknowledges that for many Londoners on modest incomes, London’s current

housing market is not working. Hard-working Londoners that occupy key positions in

London’s social infrastructure are often priced out of the private housing market and

overlooked as a priority for scarce affordable rented accommodation. This forces these

Londoners to look outside the borough they work in and contribute to, increasing their

commuting times and removing them from their local communities.


5

2.9 The premise of the housing covenant is that those who work hard for London’s economy

should benefit from its success. To do this the Mayor recognises that the mid-market offer for

these people must be addressed through the provision of more flexible housing products.

The alternative is that London risks losing a significant proportion of its skilled workforce, to

the detriment of London’s economy and social fabric.

2.10 The Mayor’s Housing Covenant will make available up to £100 million to stimulate the supply

of intermediate housing. This will help an initial 10,000 Londoners and establish a ten-year

revolving fund so that this investment can continue to help future generations onto the

housing ladder.

2.11 The Mayor of London has put Pocket at the forefront of delivering the housing he seeks

through his Housing Covenant, awarding Pocket a £21.7 million loan in 2013 (subsequently

increased to £26.4m) to develop more affordable homes across London over the next ten

years.

2.12 Using this money, Pocket has agreed to recycle any profits back in to the delivery of

affordable homes over the next 10 years. Pocket is aiming to deliver 4,000 new homes in

London over this period. Provision of new Pocket homes in Waltham Forest would contribute

to meeting that target.

2.13 Pocket is supported by the Mayor of London and has achieved planning permission

previously in other boroughs such as Camden, Hackney, Lewisham, Westminster,

Hammersmith and Fulham, Hounslow, Lambeth, Ealing, Wandsworth and Kingston.

2.14 Due to Pocket’s obligations to the GLA, Pocket will always build out schemes that are

granted planning permission and deliver the new affordable homes they say they will. Pocket

has completed 9 schemes so far delivering over 200 affordable homes which are all fully

sold and occupied. They currently have several other sites across London in the construction

or planning stages.


3. THE SITE & SURROUNDING CONTEXT

The Site

3.1 The site, which is square shaped, is located on the northern side of Gainsford Road,

between the junctions with Erskine Road to the east and Palmerston Road to the west. It

currently contains a rectangular brick-built, two-storey building with a pitched and hipped

roof, plus a single storey extension attached on the eastern side. The remainder of the site is

currently laid out as hardstanding for car parking. The site currently has two vehicle entry

points from Gainsford Road. To the front of the site, there is an on-street tree.

3.2 The current configuration of the site creates a large break in the otherwise continuous

frontage of the northern side of Gainsford Road, which features two-storey C.21st terraced

properties with pitched roofs. To the east of the site is a pair of semi-detached, former

residential houses whose ground floors have been converted to a shop front and under croft,

providing access to the rear of the properties. The properties are in use as a car repair

garage with forecourt. Beyond this, on the corner of Gainsford Road and Erskine Road, at

the prominent corner site is a three-storey building built in stock brick with ornate detailing,

particularly the curved window lintels.

3.3 The southern side of Gainsford Road opposite the site features an almost un-broken C.20th

terrace of two-storey brick houses with pitched roofs. The entrance to Limewood Close to the

south of Gainsford Road breaks up this frontage. Both street-facing elevations to Gainsford

Road are continuous and fairly uniform however the use of ground-floor bay windows and

different coloured painted brick provides some variety.

Surrounding Context

3.4 The surrounding streets including Erskine Road and Palmerston Road are characterised by

terraced and semi-detached houses, all two storeys. North of the site on the southern side of

Coleridge Road are the rear gardens of the terraced properties. Coleridge Road also

features examples of more modern flatted buildings, three storeys in height. These provide

some variety to the housing types found in the surrounding streets.

3.5 Local amenities are good. There is a convenience store, nursery, church and a small local

parade of shops located within a short walk of the site. In addition the site is located 10

minutes’ walk north of Walthamstow Town Centre. The site has a PTAL rating of 4 and is

located only a short walk of Walthamstow Central (TFL/Overground), Walthamstow Queens

Road (Overground), St James Street (Overground) and Blackhorse Road (TFL/Overground).

Lee Valley Park is also located close-by to the west of the site.


7

4. SITE HISTORY INC. PLANNING HISTORY

Site History

4.1 In 1902 the vacant land currently comprising the site and the adjacent terrace of residential

properties to the west was developed for a school building named the Gainsford Road Board

School, before being re-named the William Morris Technical School. The building was of a

substantial size occupying most of the northern side of Gainsford Road, and was up to 4

storeys tall.

4.2 The current post-war building on the site replaced the technical school which was

demolished (date unknown). The site is Council-owned with the current building most

recently being used by the Council as offices, although it is understood that the building has

now been vacant for at least 12 months.

4.3 The Council has confirmed that the building is surplus to its operational requirements and

has decided (by Cabinet resolution) to sell a long lease of the site to Pocket. The report is

appended to this statement.

4.4 The Cabinet report notes that Pocket’s development model provides a uniform mix of 1-bed

flats which would be sold to inhabitants of the borough whose incomes are below the GLA

affordable housing threshold. The report also notes that the flats would be sold at 80% of the

open market value of an equivalent property in the same location and that the Pocket

product enhances the range of affordable housing tenures in the borough.

Planning History

4.5 The planning history of the site is brief. According to a review of the Council’s online planning

register records, two previous applications exist.

4.6 In 1967 an application for alterations to the front elevation of the William Morris technical

school was approved. In 1989 an application for the demolition of single storey buildings,

erection of a temporary pre-fabricated building and use of an annexe as offices for social

services was approved.

4.7 Neither application is relevant to the current proposals.


5. PRE-APPLICATION DISCUSSIONS

5.1 Pocket has carried out pre-application consultation on the proposed development in two

ways; both through engaging the LBWF pre-application advice service, and by consulting

directly with residents. For details of Pocket’s consultation with local residents, please refer

to the accompanying Statement of Community Involvement.

Pre-Application Discussions with LBWF

5.2 A request for a pre-application meeting with officers was submitted in February 2016. Pocket

met with Council planning, design, housing and transport officers in March 2016 to discuss

redevelopment of the site for a residential scheme of 51 Pocket flats. The proposals for the

site were introduced and discussed.

5.3 Officers provided a written response in April 2016 which confirmed that the Council

welcomes redevelopment of the site however it would need to be demonstrated that the site

is not a viable location for continued employment use. Other comments provided in the

written response were:

5.4 Officers requested more information and justification to be provided through any planning

application regarding the proposed uniform mix of units and the residential quality of the

units proposed, including the layouts which are uniformly single-aspect.

5.5 Officers also requested more information to be submitted explaining how the Pocket model

works and qualifies as intermediate affordable housing, including qualifying criteria for

purchasers and the way in which the units would remain affordable in perpetuity.

5.6 Officers commented on the proposed design, noting that the proposed building was taller

than the existing buildings along Gainsford Road. Overall, officers commented that the

proposal was considered to be too tall to the rear of the site. Officers felt that the rear of

building behind Coleridge Road should be no more than two-storeys, stepping up to three

storeys across the main part of the rear of the building.

5.7 Officers also commented that the proposal for a part three-storey, part four storey elevation

to Gainsford Road was taller than the adjacent buildings. A more lightweight treatment or

alternative use of materials for the tallest portion of the elevation was suggested.

5.8 Officers commented that wheelchair units should be provided and further information on the

renewable technologies to be utilised.


9

6. THE PROPOSED DEVELOPMENT

6.1 Planning permission is sought for the demolition of all existing buildings on the site followed

by the erection of a part two, part three, and part four storey building to provide 45 residential

flats.

6.2 The proposed building is T-shaped. The footprint of the building will establish a new street-

facing elevation to Gainsford Road, completing the street scene where presently there is a

large gap. The existing building is located at the rear of the site, which offers the combination

of minimal street frontage and ill-defined spaces allocated for parking. These features detract

from the quality of the urban realm in this location.

6.3 The building will extend back in to the site away from the Gainsford Road elevation, reducing

in height to three and then two storeys as it recedes. On the eastern and western sides of

the site, either side of the new building, there will be communal and private amenity spaces

including allotments and an orchard. The residential units at ground floor level will face either

on to Gainsford Road or on to the amenity spaces within the site either side of the rear ‘leg’

of the building. The units across the upper floors repeat this orientation.

6.4 The entrance to the building is positioned within the centre of the elevation to Gainsford

Road, adjacent to the resident’s bin store. From the entrance, residents can access the

building’s central core whereby the resident’s bike stores, communal amenity space and the

upper floors of the building can be reached.

6.5 The building will be constructed in brick. Each flat will feature large floor to ceiling windows to

both the main living area and the bedroom of each flat. Juliet balconies will be provided to

the main living room windows of each flat.

6.6 The scheme will be car free. There will be restriction placed on residents applying for or

obtaining car parking permits to park within the CPZ in which the site is situated. The

development will feature one wheelchair adaptable unit with a dedicated on-street parking

space positioned to the front of the scheme on Gainsford Road.

7. THE DEVELOPMENT PLAN

7.1 Section 38(6) of the Planning & Compulsory Purchase Act (2004) states that the

determination of a planning application must be made in accordance with the development

plan unless material considerations indicate otherwise.

7.2 The Development Plan in this case comprises the London Plan (March 2015), the Council’s

adopted Core Strategy (2012) and the Development Management Policies document (2013).

7.3 Also relevant to the determination of the application is the Council’s Site Specific Allocations

document (preferred options stage, 2013). The Council have also adopted supplementary

planning documents which are relevant to the proposals such as the Urban Design SPD and

the Inclusive Design SPD.

7.4 The National Planning Policy Framework (2012) contains national planning policy and sets

out the Government’s intentions for the planning system and how these are expected to be

applied. The Government’s National Planning Practice Guidance is also relevant to the

determination of the application.

7.5 The planning policy relevant to the consideration of the application therefore comprises three

levels of policy – national, regional, and local.

National Planning Policy Framework (2012)

7.6 The NPPF advises that the primary objective of development management is to foster the

delivery of sustainable development and not to hinder or prevent development. The NPPF

encourages engagement in pre-application discussions, consultation and generally front-

loading the planning application process. It also sets out that in determining planning

applications, local planning authorities should apply the presumption in favour of sustainable

development. The National Planning Policy Framework is very clear that development must

not be prevented simply because it will cause change.

7.7 The presumption in favour of sustainable development, which should be seen as a golden

thread running through both plan making and decision-taking, involves seeking positive

improvements in the quality of the built environment, including replacing poor design with

better design, improving the conditions in which people live, and widening the choice of high

quality homes.

7.8 The NPPF, under its Core Planning Principles, places weight on the effective use of land by

reusing land that has been previously developed. It states that planning should promote

mixed use developments and encourage multiple benefits from the use of land in urban

areas. Patterns of growth should be actively managed to make the fullest possible use of

public transport, walking and cycling, and significant development should be focussed in

locations which are sustainable.


11

7.9 Paragraph 22 provides that “planning policies should avoid the long term protection of sites

allocated for employment use where there is no reasonable prospect of a site being used for

that purpose. Land allocations should be regularly reviewed. Where there is no reasonable

prospect of a site being used for the allocated employment use, applications for alternative

uses of land or buildings should be treated on their merits having regard to market signals

and the relative need for different land uses to support sustainable local communities.”

7.10 Paragraphs 49 and 50 of the NPPF state that housing applications should be considered in

the context of the presumption in favour of sustainable development. To deliver a wide

choice of high quality homes, widen opportunities for home ownership and create

sustainable, inclusive and mixed communities, local planning authorities should plan for a

mix of housing based on current and future demographic trends, market trends and the

needs of different groups in the community

7.11 The National Planning Policy Framework Annex 2: Glossary defines Affordable Housing in

the following terms:

“Affordable housing: Social rented, affordable rented and intermediate housing,

provided to eligible households whose needs are not met by the market. Eligibility is

determined with regard to local incomes and local house prices. Affordable housing

should include provisions to remain at an affordable price for future eligible

households or for the subsidy to be recycled for alternative affordable housing

provision.”

7.12 Intermediate housing is defined as the following:

“....Intermediate housing is homes for sale and rent provided at a cost above social

rent, but below market levels subject to the criteria in the Affordable Housing

definition above. These can include shared equity (shared ownership and equity

loans), other low cost homes for sale and intermediate rent, but not affordable rented

housing.”

7.13 Pocket homes qualify as affordable housing under this definition (as opposed to so-called

‘low-cost’ market housing) because they will satisfy key criteria:

Restricted eligibility – all buyers must meet the relevant eligibility criteria which will be

agreed in conjunction with the Council’s housing department. Eligibility is likely to be

restricted by a maximum income level and to those living and working within the borough

Provisions to remain at an affordable price – the lease of Pocket homes will include

conditions that ensure that owners follow the same eligibility rules when selling (or

renting) their home. These restrictions are also enshrined within the s106 agreement.

Cost below open-market levels – pricing is agreed with boroughs before units are

released onto the market. Pocket homes are sold at a discount of at least 20% to open-

market value

The London Plan (2015)


7.14 The London Plan is the overall strategic plan for London, setting out an integrated economic,

environmental, transport and social framework for the development of London over the next

20–25 years. The Mayor has confirmed that the Plan is consistent with the policies contained

within the NPPF, in particular the presumption in favour of sustainable development.

7.15 The London Plan sets out policies to ensure there is an adequate supply of housing for the

city’s projected population growth. According to the Plan (table 1.1), the population of the

London Borough of Waltham Forest is forecast to increase by 17.3% from 2011 to 2036.

7.16 The Mayor’s stated Strategic Policies aim to ensure that “London is a city that meets the

challenges of economic and population growth in ways that ensure a sustainable, good and

improving quality of life and sufficient high quality homes and neighbourhoods for all

Londoners and help tackle the huge issue of deprivation and inequality among Londoners,

including inequality in health outcomes.”

7.17 The principle of establishing a residential use of the site is supported by the London Plan’s

policy objectives which state that the most efficient use of land should be achieved. At

paragraph 1.48, it is stated that London must plan for a growing population in a way that

does not worsen quality of life for London as a whole which means that “we will have to

ensure we make the best use of land that is currently vacant or under-used, particularly in

east London where the greatest potential exists.”

7.18 Policies within the London Plan are consistent with the thrust of the policies contained within

the NPPF as they recognise the need to encourage the effective use of land by reusing land

that has been previously developed (brownfield land). Paragraph 2.4 provides that “the most

efficient use will have to be made of London’s limited reserves of land, identifying places with

the potential for development on a strategic scale, and ensuring policies are in place to

enable this to happen.”

7.19 Policy 3.1 seeks to ensure equal life chances for all. The Mayor is committed to ensuring

equal life chances for all Londoners. Meeting the needs and expanding opportunities for all

Londoners – and where appropriate, addressing the barriers to meeting the needs of

particular groups and communities – is key to tackling the huge issue of inequality across

London.

7.20 Policy 3.3 Increasing Housing Supply states that the Mayor will seek to ensure the housing

need is met, particularly though the provision consistent with at least an annual average of

42,000 net additional homes across London. Table 3.1 sets out the borough housing targets.

Boroughs should seek to exceed the relevant minimum annual average housing targets.

Waltham Forest’s minimum target is 8,620 new homes over a 10 year period till 2025 which

equates to 862 new homes annually.


13

7.21 Policy 3.3 provides that boroughs should to identify and seek to enable additional

development capacity to be brought forward to supplement these targets including the

potential to realise brownfield housing capacity through intensification and (redevelopment

of) surplus commercial capacity and surplus public land, particularly that with good transport

accessibility.

7.22 Policy 3.4 seeks to ensure that the development potential of sites is maximised in order that

housing potential is optimised. Table 3.2 provides guidance on the range of housing

densities with regard to location and is a tool for increasing density in situations where

transport proposals will change the public transport accessibility ranking.

7.23 Policy 3.5 concerns the quality and design of housing developments and states that these

should be of the highest quality internally, externally and in relation to their context and to the

wider environment, taking account of strategic policies in the Plan to protect and enhance

London’s residential environment and attractiveness as a place to live. Policy 3.5 refers to

the minimum space standards at table 3.3 but states: “Development proposals which

compromise the delivery of elements of this policy may be permitted if they are demonstrably

of exemplary design and contribute to achievement of other objectives of this Plan”.

7.24 Policy 3.8 concerns housing choice and provides that Londoners should have a genuine

choice of homes that they can afford and which meet their requirements for different sizes

and types of dwellings in the highest quality environments. It seeks to ensure that new

developments offer a range of housing choices, in terms of the mix of housing sizes and

types, taking account of the housing requirements of different groups, that all new housing is

built to ‘Lifetime Homes’ standards and that ten per cent of new housing is designed to be

wheelchair accessible or easily adaptable for residents who are wheelchair users.

7.25 Policy 3.9 concerns mixed and balanced communities. It states that communities mixed and

balanced by tenure and household income should be promoted across London through

incremental small scale as well as larger scale developments which foster social diversity,

redress social exclusion and strengthen communities’ sense of responsibility for, and identity

with, their neighbourhoods. They must be supported by effective and attractive design,

adequate infrastructure and an enhanced environment.

7.26 Policy 3.10 defines affordable housing. Intermediate affordable housing is defined as “homes

available for sale or rent at a cost above social rent, but below market levels. These can

include shared equity (shared ownership and equity loans), other low cost homes for sale

and intermediate rent, but not affordable rent.”

7.27 It is relevant to note that in the Mayor’s 12th Annual Monitoring Report, published March

2016, the Mayor has, in line with the Government’s approach to shared ownership,

increased the affordable housing salary threshold and removed salary restrictions by

property type and size. Therefore, from April 2016, a single £90,000 household income will

apply to all intermediate housing, regardless of size.


7.28 Paragraph 3.62 states that “increased provision of intermediate housing is one of the ways in

which the supply of affordable housing can be expanded.”

7.29 Policy 3.11 sets affordable housing targets. It states that provision of affordable housing

provision should be maximised and that an average of at least 17,000 affordable homes are

provided each year over the term of the Plan. In order to give impetus to a strong and

diverse intermediate housing sector 40% of the affordable housing provision should be for

intermediate rent or sale.

7.30 At Paragraph 3.65 it is stated that this 40% target has been informed by the role that

intermediate housing can play in helping Londoners get a first step on the housing ladder,

reducing the call on social/affordable rented housing, freeing up social/affordable rented

homes, providing wider housing choices and securing a more balanced social mix on mono-

tenure estates. Account has also been taken of the way intermediate housing development

can extend the effectiveness of scarce public resources by increasing overall housing output

through partnership working with the private sector.

7.31 Policy 3.12 concerns the negotiation of affordable housing. It is stated that the maximum

reasonable amount of affordable housing should be sought when negotiating on individual

private residential and mixed use schemes.

7.32 The London Plan recognises that in recent decades London’s economy has been

increasingly service-based, and this is likely to continue. It is stated that ensuring there is

enough office space of the right kind in the right places is a key task for the London planning

system.

7.33 Policy 4.2 concerns offices. Although it is stated that boroughs should support the

management and mixed use development and redevelopment of office provision to improve

London’s competitiveness and to address the wider objectives of the Plan, the policy

recognises that there are local differences to implementing this policy. For example, the

distinct needs of the central London office market are different to the diverse office markets

elsewhere in the capital. It is stated that new office development should be focussed on

viable locations with good public transport accessibility.

7.34 It is stated that stock should be increased where there is authoritative, strategic and local

evidence of sustained demand for office-based activities. Renewal and modernisation should

be encouraged in viable locations to improve its quality and flexibility however supporting

managed conversion of surplus capacity to more viable, complementary uses is also

encouraged.

7.35 In terms of LDF preparation, policy 4.2 states that LPAs should work with sub-regional

partners to develop co-ordinated, phased strategies to manage long term, structural changes

in the office market, focusing new capacity where there is strategic as well as local evidence

of demand, encouraging renewal and modernisation in viable locations and supporting

changes of surplus office space to other uses.


15

7.36 Paragraph 4.13 provides that “Local plans and strategies should support the conversion of

surplus offices to other uses and promote mixed use development in the light of integrated

strategic and local studies of office demand. Informed by the independent London Office

Review Panel a ‘plan, monitor and manage’ approach will be used to reconcile office

demand and supply across the development cycles likely to be encountered over the years

to 2036. This may well provide scope for changes from surplus office to other uses;

especially housing, providing overall capacity is sustained to meet London’s long-term office

needs. The scope for re-use of otherwise surplus large office space for smaller units suitable

for SMEs should also be considered”.

7.37 It is therefore clear that whilst the London Plan encourages office provision in order to

enhance and sustain London’s economy and businesses, decisions and LDF preparation

must respond to local circumstances, market signals and evidence of demand, to ensure that

offices are available in viable locations. Where they are not, LPAs should support the release

of surplus office space to other more viable and productive uses.

LBWF Core Strategy (2012)

7.38 Policy CS2 concerns improving housing quality and choice. In relation to housing growth, the

policy provides that the Council will facilitate sustainable housing growth by prioritising

development on previously developed land, particularly unused or underused land, focussing

the delivery of new homes in the borough’s growth areas and other key sites to meet or

exceed the housing target over the plan period, making effective and efficient use of land by

seeking to optimise housing densities and supporting initiatives to bring 1035 empty

properties back into use over the plan period.

7.39 In relation to affordable housing, policy CS2 provides that the Council will maximise the

number of quality affordable homes within the borough by aiming to provide at least 5,700

affordable homes over the plan period (50% of the total number of homes). A balance of

tenures should be provided. The level of affordable housing will be assessed on a site by site

basis.

7.40 Policy CS2 refers to creating mixed and balanced communities by seeking a range of home

sizes and tenures in new development. It is stated that the Council will prioritise the need for

larger homes of 3 bedrooms or more. High quality design will be required and new homes

should be accessible to all members of the community. At paragraph 5.12 it is stated that

“Given the urban nature of large parts of the Borough it is essential to make the most

effective and efficient use of land in order to maximise housing supply. As a general rule, the

Council will seek to optimise housing densities across the Borough”. This will include

affordable housing. Paragraph 5.18 provides that “given the significant level of need and the

difficulties local residents have in accessing the housing market, the Council seeks to

prioritise the delivery of affordable housing”.


7.41 Paragraph 5.19 reveals that “the Council wants to encourage a more economically balanced

community and will therefore seek a greater social mix in the Borough. Waltham Forest has

experienced the trend of more people on higher and medium incomes moving out of the

Borough than are moving in. This is largely due to the fact that they are unable to find

suitable housing options to meet their needs”.

7.42 Relevant to the Gainsford Road site is paragraph 5.47 which states that “sites outside the

Council's Key Growth Areas will be identified in the Site Specific Allocations DPD. This

document will allocate and safeguard sites for housing, mixed use and other uses.”

7.43 Policy CS4 concerns minimising and adapting to climate change. The Council will tackle

climate change locally and promote resource efficiency and high environmental development

standards during design, construction, and occupation of new developments.

7.44 Policy CS5 concerns enhancing green infrastructure and biodiversity. Amongst protecting

existing green spaces, the Council will ensure the adequate provision of allotments and other

spaces to grow food and plants.

7.45 Policy CS6 relates to promoting sustainable waste management and recycling. The Council

will require new development provides accessible, adequate and well-designed storage

facilities for residual waste and recycling.

7.46 Policy CS7 concerns developing sustainable transport. The Council will facilitate growth and

regeneration in a sustainable manner and promote sustainable travel. Car-free

developments will be promoted.

7.47 Policy CS8 concerns making efficient use of employment land. The Council will facilitate

sustainable economic growth by safeguarding and enhancing an appropriate range of sites

and premises. At paragraph 11.2 the Council recognises that the need to cater for population

growth, whilst also protecting the Borough's green assets, means that existing employment

land will need to be used more efficiently in the future.

7.48 Policy text at part E concerns non-designated employment land. It is stated that the Council

will take a pragmatic approach to non-designated employment land and premises that can

clearly be demonstrated to be surplus to requirements and no longer fit for purpose, so that it

can be released for more productive uses. Priority will be given to mixed use developments,

especially those that incorporate social infrastructure.

7.49 At paragraph 11.8 it is stated that in accordance with national planning policy, standalone

offices are included in the definition of a town centre use and should be directed towards

existing centres and areas well served by public transport. It is acknowledged that, as the

major town centre in the Borough, it is expected that Walthamstow town centre will

accommodate much of the Council’s predicted office growth.


17

7.50 At paragraph 11.25, in relation to non-designated employment land, the Council recognises

the requirement of national planning policy which advocates a flexible approach to

employment land provision in recognition of the legacy of industrial decline and the need to

provide land for new homes, social infrastructure etc.

7.51 It is stated, at paragraph 11.27 that a careful balance needs to be struck between protecting

and releasing land to more productive uses. Policy points A – C set out the Council’s

approach to its most valuable employment land. At paragraph 11.28 it is stated that outside

these areas (non-designated employment land) there may be greater scope for the release

of existing employment land. The Council requires the developer to demonstrate the site is

no longer suitable for employment use.

7.52 Policy CS15 concerns well designed buildings, places and spaces. It is stated that the

Council’s objective is to create positive, responsive and inclusive environments including

buildings and spaces of high quality that contribute to the distinctiveness of neighbourhoods.

LBWF Development Management Policies (2013)

7.53 Policy DM1 provides that the Council will take a positive approach to considering

development proposals that reflects the presumption in favour of sustainable development

within the NPPF. The Council will work pro-actively with applicants to find solutions.

7.54 Policy DM3 concerns affordable housing provision. It is stated that in accordance with policy

CS2 the Council aims to provide 50% of new housing to be affordable. The Council’s policy

text requires a tenure split in favour of social/affordable rented units.

7.55 Policy DM5 concerns housing mix. It is stated that the Council will seek all housing

developments to provide a range of dwelling sizes and tenures particularly focussing on the

provision of larger family sized homes. It is stated that the Council will generally not support

development proposals containing only smaller homes (one and two bed).

7.56 Policy DM7 relates to external amenity and internal space standards. The Council will aim to

ensure that all new residential development, is of the highest quality both internally and

externally by seeking that proposals meet the Council’s minimum internal space standards

and the external amenity space standards. The policy states that the Council does not

support studio flats or 1 bed, 1 person homes.

7.57 Policy DM10 concerns resource efficiency and high environmental standards. The Council

will require developments to achieve the Council’s stepped targets towards zero carbon by

2016 for residential development.

7.58 Policy DM11 concerns decentralised and renewable energy. It is stated that the Council will

seek to reduce carbon emissions by requiring development to examine the feasibility of

connecting to existing or future decentralised energy networks. Developments which seek to

reduce carbon emissions through on-site renewable energy should ensure that the proposed

system is appropriate and does not cause adverse effects.


7.59 Policy DM13 requires the co-ordination of land use and transport. The Council will ensure

that development is properly integrated with the transport network and is supported by

appropriate walking, cycling and public transport links. Where development is not within easy

reach of public transport stops, applications will be required to promote sustainable travel

measures and contribute to reducing car use.

7.60 Policy DM16 concerns car parking. The Council encourages car-free development in highly

accessible locations and supports limiting on-site car parking spaces designed for disabled

people.

7.61 Policy DM20, which is linked to policy CS8 as previously referred to, concerns non-

designated employment areas. Part A of the policy text states that in accordance with policy

CS8, the Council will support applications for more productive uses in non-designated

employment land where it can be demonstrated that there are clear barriers to the sites

future employment use, there is no reasonable prospect of the site being re-used for

employment purposes, the proposed use would not be better located in a town or district

centre, mitigation for the loss of employment land is provided, and in all other respects the

proposed use is well designed and suitable to its surroundings.

7.62 Part B provides that where land last used for employment is released for other uses,

preference will be given to schemes that incorporate social infrastructure.

7.63 Policy DM24 concerns development on contaminated land.

7.64 Policy DM29 concerns design principles, standards and local distinctiveness. The Council

will expect a high standard of urban and architectural design for all new development.

7.65 Policy DM30 concerns inclusive design and the built environment.

7.66 Policy DM32 relates to managing the impact of development on occupiers and neighbours.

7.67 Policy DM33 concerns improving community safety.

7.68 Policy DM34 concerns water supply and waste water infrastructure.

7.69 Policy DM35 concerns biodiversity and geodiversity.


19

8. PLANNING ASSESSMENT

Principle of Development

8.1 The current housing crisis including the lack of genuinely affordable homes for first-time

buyers, particularly within London is well publicised. This site contains a vacant building with

only remote prospects of ever being brought back in to office use and is previously-

developed (brownfield) land. It is located within a residential area with good public transport

accessibility. This is an unproductive and unsustainable use of the land.

8.2 It is considered that a more productive use of the land that would address other key

objectives within the Council’s Development Plan and the London Plan, such as provision of

affordable housing, is more appropriate and sustainable. Redevelopment of the site for new

homes would accord with the Government’s intentions for the planning system in general,

the presumption in favour of sustainable development contained within the NPPF and

relevant policies within the London Plan.

Loss of non-designated employment land

8.3 The loss of the vacant office building must be considered. The site is non-designated

employment land; therefore policies CS8 and DM20 apply.

8.4 Policy CS8 concerns making efficient use of employment land. It is acknowledged within the

supporting text that non-designated employment land is less valuable. Policy CS8 provides

that the Council will take a pragmatic approach to the redevelopment of non-designated

employment land that is surplus to requirement or not fit for purpose, so that it can be

released for more productive uses.

8.5 It is acknowledged that this approach has borough-wide advantages by catering for

population growth, whilst also protecting the borough’s green assets. Supporting text

acknowledges that the Council recognises the requirement of national planning policy which

advocates a flexible approach to employment land provision.

8.6 Policy DM20 provides that the Council will support applications for more productive uses

where it can be demonstrated that the land is no longer viable or suitable for employment

uses. Part A of the policy text provides a list of circumstances that could be used to

demonstrate this, but there is no requirement to satisfy each and every circumstance. It will

be demonstrated through this application that the redevelopment of this site would be

acceptable in planning policy terms.

8.7 The site and the existing buildings are owned by the Council. In 2015 the Council’s Cabinet

resolved to sell a long lease of the site to Pocket, so that the site could be redeveloped for

100% affordable housing. Disposal is conditional on planning permission being granted. The

Cabinet report is appended to this statement.

8.8 There are barriers to the site’s re-use for employment purposes.


8.9 These include the site’s location within a predominantly residential area, which is 10 minutes’

walk from the nearest transport hubs and Walthamstow Town Centre. It is commonly

accepted that for providers of office accommodation, location and accessibility are

paramount to ensuring that the office space is viable and will attracts tenants. Demand tends

to be focused in town centre locations, where office premises are physically visible, more

accessible as they are close to transport links, and are clustered alongside other occupiers

to benefit from the retail provision and other services, also located in the town centre.

8.10 The site features none of these characteristics. The site would not be attractive to an office

tenant when more desirable opportunities exist elsewhere. Our analysis of the local office

market, presented within a separate report indicates that Walthamstow Town Centre, despite

its transport links, has extremely limited demand for office accommodation. It therefore

follows that office accommodation outside of the town centre, is likely to be even less in

demand.

8.11 The main building, although it was previously used by the Council as offices, was originally

built as a school circa 1930. It is not purpose-built offices. This is apparent in the building’s

layout, which is divided into a series of smaller rooms accessed by a large area of circulation

space with two separate cores. Existing floorplans are appended to this statement. It is not

considered that the configuration and design of the building, which is restricted by its historic

construction for a different purpose, would be attractive to a modern office tenant who is

likely to prefer a large open-plan office, minimal circulation space, and lots of natural light.

8.12 The building has been vacant for at least 12 months. Due to its age and historic use the

building is severely dated. The floors are carpeted or lino. The stairs are of wooden

construction. It is considered that the building’s natural lifespan has come to an end.

Internally, the building is substantially dilapidated and requires major repairs. There are

internal leaks due to the poor condition of the roof and water ingress has caused substantial

damage including collapsing roof tiles and damage to walls and carpets. It is assumed that

the electrics have also been damaged by the water ingress and it is unclear if the heating is

functioning. In addition the building has a rodent infestation. Generally the building is in a

condition unfit for occupation.

8.13 The building is also riddled with asbestos which presents a dangerous risk to human health.

The first floor of the building is currently sealed off and inaccessible due to safety concerns.

In 2014 the Council instructed an asbestos survey to be carried out. The report notes

disturbed areas of asbestos which require urgent repair, and due to the building’s age,

assumes that the building contains further asbestos which will require regular inspection to

ensure safety in the long term. The survey report is appended to this statement and

concludes that “Urgent remedial action is required to make safe asbestos identified on this

site.”


21

8.14 The building’s age and condition logically means that for the building to be repaired to a

standard whereby it could attract an office tenant a significant amount of investment is likely

to be required. In addition to this required investment the site has fundamental inherent

limitations as an employment premises due to its age and configuration and its location on a

residential road outside of the town centre.

8.15 In reality, total redevelopment of the site is likely to be required for on-going employment

use. Due to the site’s constraints and limitations, the site is not likely to be considered as a

location where demand for office accommodation would be sufficient to justify the cost and

risk involved in redeveloping the site for employment purposes. Relevant to this is paragraph

22 of the NPPF which provides that

“planning policies should avoid the long term protection of sites allocated for employment

use where there is no reasonable prospect of a site being used for that purpose. Land

allocations should be regularly reviewed. Where there is no reasonable prospect of a site

being used for the allocated employment use, applications for alternative uses of land or

buildings should be treated on their merits having regard to market signals and the relative

need for different land uses to support sustainable local communities.”

8.16 Policy DM20 expects that sites have been reasonably marketed in order to demonstrate that

there is no reasonable prospect of the site being re-let or re-sold for employment purposes.

Many of the factors discussed above are relevant to the assessment of whether there is any

reasonable prospect that the building would be re-let or re-sold (re-developed) for

employment purposes.

8.17 In this case, the Applicant is unable to demonstrate that the site has been marketed for

employment purposes due to the fact that the site is owned by the Council. We understand

that the Council, acting as the vendor, have not marketed the site for employment purposes

prior to agreeing its sale to Pocket as a residential development site. As noted within the

Cabinet report the site is surplus to the Council’s operational requirements. Therefore the

redevelopment of the site would not displace any current employment taking place at the

site.

8.18 Despite lack of marketing, paragraph 51 of the NPPF is relevant in this case. It states that

LPA’s should “normally approve planning applications for change to residential use and any

associated development from commercial buildings (currently in the B use classes) where

there is an identified need for additional housing in that area, provided that there are not

strong economic reasons why such development would be inappropriate.” It has been

demonstrated above that due to the building’s condition and the site’s location, there are not

strong economic reasons indicating that permission should be withheld.


8.19 It is noted within the Cabinet report that the Council has resolved to forego the option of

selling the site on the open market, which would be likely to generate a higher capital receipt

for the Council in order to sell the site unilaterally to Pocket so that it may be redeveloped for

a scheme of 100% affordable housing. Disposal of the site will reduce the Council’s

operational liabilities and enable savings to be achieved. These savings, along with the

significant capital receipt will enable frontline Council services to be protected and is a

material consideration that should be taken into account.

8.20 Part B of policy DM20 provides that where land last used for employment purposes is

released for other uses, preference will be given to schemes that incorporate social

infrastructure. Part B of policy DM20 does not require the Applicant to demonstrate that

provision of social infrastructure has been investigated or is unlikely to be viable. It simply

states that preference will be given to schemes that do incorporate social infrastructure. This

does not mean that other development proposals, not incorporating social infrastructure, will

be unacceptable or considered adversely in comparison.

Principle of residential development

8.21 The acceptability of residential development on the site must also be considered.

8.22 Consistent with the London Plan which forecasts significant population growth across

London, the Council’s Core Strategy (paragraph 5.3) recognises that a growing population in

the borough, along with smaller household size, are fuelling significant demand for new

homes to buy and rent. Although the Key Growth Areas have significant capacity for new

homes, sites outside of these are still expected to provide 50% of the borough’s housing

growth.

8.23 There is limited land to accommodate significant population growth. The Core Strategy

(paragraph 5.12) recognises that “given the urban nature of large parts of the Borough it is

essential to make the most effective and efficient use of land in order to maximise housing

supply”. Sites such as Gainsford Road, if developed, will contribute towards meeting the

Council’s targets whilst also reducing housing pressure on more valuable employment land.

8.24 The Core Strategy recognises that Waltham Forest has a high level of need for affordable

housing (paragraphs 5.15 – 5.19). Affordability is a major challenge. Huge demand exists for

social housing, but given the very high price of entry level private housing, mobility is

restricted. Given the significant level of need, the Council prioritises affordable housing

provision with a 50% affordable housing target on new major developments.

8.25 It is recognised within the Core Strategy (paragraph 5.23) that the borough has experienced

a trend of young people on higher and medium incomes moving out of the borough; due to

the fact they cannot access housing to meet their needs. This phenomenon is common to all

London boroughs and is the reason that Pocket started selling intermediate affordable

homes at prices discounted to the local market. Pocket wants to provide those who

contribute to the borough with the opportunity to purchase their own home, gain access to

the housing ladder, and stay within their local communities.


23

8.26 At paragraph 4.2 of the Development Management Policies document, it is stated that

“according to the Strategic Housing Needs Assessment (2011) the total affordable housing

requirement in the borough is over 80% of the total planned dwelling delivery in Waltham

Forest. The Council will therefore seek to maximise affordable housing provision in the

borough.”

8.27 In light of this demand, the Council’s decision to sell unilaterally to Pocket recognises that

redevelopment of the site for a residential scheme providing 100% affordable housing is of

substantial benefit to the Council. This is particularly relevant recognising that the Council’s

policy aspiration (policy DM3) seeks to achieve 50% affordable housing from major sites,

which the proposal would significantly exceed. At paragraph 49 the NPPF states that

“housing applications should be considered in the context of the presumption in favour of

sustainable development.” Provision of 100% affordable housing on this site is a significant

material consideration in assessing the acceptability of the proposals.

8.28 Policy CS2 provides that the Council will facilitate sustainable housing growth by maximising

the number of quality homes in the borough by prioritising development on previously

developed land, particularly unused or underused land; making effective and efficient use of

land by seeking to optimise housing densities; and supporting initiatives to bring empty

properties back into use over the plan period. The proposals for this site would accord with

all these policy objectives.

8.29 It is also relevant to note that the Council’s Site Specific Allocations document (preferred

options stage) identifies the site as being suitable for redevelopment for housing. Although

the document is an emerging policy and not yet adopted, the Council may give it substantial

weight in the decision making process in this case, since the NPPF (Annex 1:

Implementation) states that “from the day of publication, decision-takers may also give

weight to relevant policies in emerging plans according to: the degree of consistency of the

relevant policies in the emerging plan to the policies in this Framework (the closer the

policies in the emerging plan to the policies in the Framework, the greater the weight that

may be given).”

8.30 As discussed above, redevelopment of the site for new homes is consistent with other

policies within the Framework, and with paragraph 49, which states that housing applications

should be considered in the context of the presumption in favour of sustainable

development.

8.31 Also relevant to the Council’s consideration of this application is the Government’s decision

to make permanent permitted development rights for the change of use from office to

residential use. This recent decision, superseding the publication of the NPPF, highlights the

Government’s continued intention to further promote flexibility within the planning system, so

that previously developed land and buildings can be put to sustainable use, taking account of

market signals, and contributing towards the provision of new homes.

Housing Policies


Affordable Housing

8.32 Policy DM3 provides that in accordance with policy CS2, the Council aims to provide 50% of

new housing as affordable. The proposal will provide 100% affordable housing, significantly

exceeding the Council’s policy target and complying with the Council’s aspirations to provide

as many affordable homes as possible.

8.33 All of the proposed new homes would be intermediate affordable tenure, which must be

considered against the requirement of policy DM3 which seeks a tenure split of 60%

social/affordable rented units and 40% intermediate units.

8.34 Pocket housing is provided following a unique model that enables sites to deliver 100%

affordable housing, without public subsidy, by providing all housing as intermediate housing.

Inclusion of affordable housing of other tenures would compromise delivery of the model and

dramatically reduce the ability of sites to bring forward the level of affordable housing

provided.

8.35 Due to lease conditions and restrictions within the s106 Agreement, Pocket intermediate

homes will remain affordable in perpetuity for future buyers. This distinguishes them from

other forms of intermediate affordable housing, such as shared-equity, where over time

owners can acquire remaining equity and finally sell the property on the open market. Once

this occurs, an affordable unit is lost from the borough’s supply. Pocket intermediate homes

will always remain affordable, discounted in the future to values on the open market at that

time. A draft S106 Agreement that includes the affordability restrictions is included with the

application.

8.36 Recognising the Council’s pent-up demand for affordable homes (at least 80% of the total

planned delivery of homes across the Plan period) and the policy requirement of 50%

provision of affordable homes per major development site, the proposals are consistent with

the Council’s strategic policy objectives which seek to maximise affordable housing supply

and policy 3.12 within the London Plan which requires that the maximum reasonable amount

of affordable housing should be sought when negotiating on private residential schemes.

Mix of Dwellings

8.37 Policy DM5 provides that the Council will seek all housing developments to provide a range

of dwelling sizes and tenures particularly larger family sized homes (three bed plus). It is

stated that the Council will generally not support proposals containing only smaller homes

(one and two bed).

8.38 The proposal does not comply with policy DM5 which is a dwelling mix policy that is common

in intent to development plans across all the London boroughs. It is acknowledged that

Pocket developments require an exception to be made to these policies.


25

8.39 We consider that an exception to adopted policy DM5 is warranted on the grounds that other

material considerations – namely the provision of a large number of affordable high-quality

dwellings on a site that would otherwise deliver a significantly lower number of dwellings,

with a very small contribution to affordable housing – outweigh the need to ensure that the

site delivers a mix of dwellings of all sizes.

8.40 It must be recognised by officers that the reason Pocket homes are affordable is because

Pocket provide a certain quantum of dwellings on a small site. The uniform mix of one-

bedroom dwellings is a key element in ensuring that Pocket developments are viable and

affordable for the end user. The proposals are consistent with London Plan policies 3.3

(increasing housing supply) and 3.4 (optimising housing potential). Viability is also a

consideration in this respect. Provision of larger homes within Pocket developments

compromises the model by reducing the overall number of units impacting on the viability of

the scheme as a whole.

8.41 It must be recognised that the demographics of the population are changing; between 2006

and 2031 household growth is projected to increase from 21.5m to 27.8m of which 65% (i.e.

4.1m) will be one-person household growth (source: ONS). The vast majority of buyers of

Pocket homes are singles and couples (without children) looking to get away from renting,

with 80% of the purchasers to date being single persons.

8.42 Pocket targets buying small sites in highly accessible areas which are also the areas that

single persons and couples are looking to locate to (sites within commutable distance to

work). By designing smaller one-bed homes in these accessible urban locations Pocket is

meeting this demand from singles and couples. Proof of the need for Pocket’s one bed

homes is demonstrated by the fact that over 13,000 people have registered their interest in

buying a Pocket home.

Wheelchair Dwellings

8.43 It is recognised that policy 3.8 within the London Plan concerning housing choice provides

that 10% of new housing should be designed as wheelchair accessible or easily adaptable

for wheelchair users. Within the proposed scheme this would equate to provision of 5

wheelchair units, however in the case of this particular development, this is not considered

practical or proportionate to the evidenced level of demand.

8.44 This is due to the fact that demand for wheelchair accessible units amongst buyers of

traditional intermediate affordable housing is exceptionally low. In LBWF, there are currently

1999 households registered with the Mayor of London’s First Steps Scheme with a maximum

of 2 occupants whose earnings match the qualifying criteria for a Pocket flat. Of this number

of applicants, only 17 have a wheelchair user within their household. This represents less

than 1% of the total.


8.45 As an unintended consequence of the uniform mix of units proposed, and the fact that

eligibility to purchase is also further restricted by qualifying criteria, the demand is considered

to be even lower in reality. There is also the possibility that these 17 registered households

could be interested in purchasing a larger flat with more bedrooms, or a shared equity

product. However, in recognition of policy 3.8, the scheme includes one wheelchair

adaptable unit. It is proposed that through a clause within the S106 Agreement to be agreed

with the Council this unit would be marketed to wheelchair purchasers for an agreed period

of time, and if no purchaser comes forward, the unit would be sold to other eligible

purchasers.

8.46 Anecdotal evidence from housing departments within other boroughs where Pocket has a

presence is that demand for one-bedroom intermediate-affordable wheelchair accessible

homes is exceptionally low. Pocket has endeavoured to find an eligible person who is

registered disabled in several boroughs and have yet to find one. Other boroughs where

Pocket has a presence have accepted this reality and no longer require wheelchair provision

from Pocket developments, or require a single unit which if no buyer is found can be sold to

a non-disabled person – as proposed here.

8.47 It is therefore apparent that to provide 10% of the total number of dwellings as wheelchair

units would be unnecessary in this particular case. Provision of one unit, in the manner

proposed, would be proportionate. All dwellings will be compliant with the relevant building

regulations Part M standard, in accordance with the Mayor’s Housing SPG.

8.48 The proposal does not include a lift. There is no requirement within the Council’s own

Development Plan however within the Mayor’s Housing SPG (2016) it is expressed that

LPAs should seek to ensure that dwellings accessed above or below the entrance storey in

buildings of four storeys or less have step-free access, however, the guidance recognises

that in certain specific cases, “the provision of a lift where necessary to achieve this aim,

may cause practical difficulties, make developments unviable and/or have significant

implications for the affordability of service charges for intended residents.”

8.49 In particular, the guidance states that this may require ‘bespoke’ assessments of site-specific

circumstances and specifically, in relation to developments of four stories or less, the

requirements of Policy 3.8Bc should be applied flexibly to ensure that residential or

mixed use development is deliverable. The guidance recognises that this may bear

particularly on the following types of schemes:

Flats above shops or garages, stacked maisonettes and low rise blocks of flats where the

potential for deck access to lifts is restricted;

small-scale infill developments, where the depth and width of a plot and height

restrictions may inhibit the overall floorplate and massing of a building and the number of

units which can be provided on a particular site/grouped around the same core (eg. gap

sites adjacent to existing residential dwellings or in a conservation area);

new units as a result of upward extensions to existing residential homes and flats.


27

8.50 The site in question bears a number of the above characteristics. It is also relevant to note

that the Council’s pre-application advice focussed on how the units would be delivered as

affordable, and the height and massing of the scheme, which the Applicant has responded to

positively, albeit at the loss of several affordable units.

8.51 The cost of provision and maintenance of a lift in the scheme would be passed to the

residents in the long term through increased service charges, which is contrary to the

objective of the scheme which aims to provide 100% intermediate affordable housing to

residents of Waltham Forest on low to middle incomes. As allowed for by the Mayor’s

guidance and for these reasons, flexible application of the guidance on this issue is

appropriate, in this case.

Internal Space Standards

8.52 Policy DM7 provides that new residential dwellings are expected to meet the Council’s

internal space standards as expressed within tables 8.1 and 8.2 (page 56 of the

Development Management policies document). It is recognised within policy DM7 that the

tables omit studio flats and 1 bed 1 person flats. It is stated that the Council does not support

provision of these types of dwellings.

8.53 As noted within the Schedule of Areas within the architect’s Design & Access Statement the

majority of units within the scheme are 1 bedroom units of 38m2. Due to the design of the

building’s stepped façade, there is the opportunity to provide a number of larger 1 bedroom

units within the scheme measuring 44m2. The wheelchair adaptable unit measures 52m

2.

8.54 Whilst the Council’s approach within policy DM7 is not consistent with policy 3.5 (and table

3.3) of the London Plan, which supports 1 bed 1 person dwellings of 37m2 (GIA) such as

those proposed, we require the Council to make an exception to policy DM7, in this case.

We consider that the Council can make an allowance due to the fact that London Plan policy

3.5 states that, in reference to the minimum space standards (which LBWF have adopted

from the London Plan): ‘Development proposals which compromise the delivery of elements

of this policy may be permitted if they are demonstrably of exemplary design and contribute

to achievement of other objectives of this Plan’.

8.55 As alluded to previously, the Pocket model, including the small nature of the dwellings is

endorsed by the Mayor of London in full recognition of Policy 3.5 of the London Plan. It must

also be recognised that 80% of Pocket homes are occupied by single people rather than

being one-bed, two-person flats.

8.56 Pocket homes are designed extremely well, as demonstrated in the accompanying Design

and Access Statement and the numerous awards they have won. Consequently, whilst they

are below the Council’s expectation as expressed in policy DM7, it cannot be said that they

do not provide a suitable standard of accommodation.


8.57 Pocket homes are also designed on a standard layout which ensures consistency of quality

and so that they can be built at a price that ensures they are affordable to purchasers. The

proposals for Gainsford Road, due to the uniform mix of 1-bedroom units, enable the

redevelopment capacity of the site to be optimised and therefore a significant number of new

homes, all as intermediate affordable housing, can be delivered.

8.58 Provision of a scheme of 100% affordable housing, without public subsidy is a significant

material consideration in recognition of policies CS2 and DM3 which state that the Council

will maximise the number of new affordable homes. The Council’s policy requirement is 50%.

We believe Pocket can be granted an exception to policy DM5 for this reason, and because

the homes will remain affordable in perpetuity. Due to the s106 agreement they are not

available to buy-to-let owners or those who already own a residential property and they can

never be sold on the open market.

8.59 This type of development is specific to the Applicant (Pocket) and distinguishes Pocket from

other developers. For these reasons the Council can distinguish between Pocket and any

other proposals for a development with a uniform mix of 1-bed dwellings that the Council

may find unacceptable. The Council would not be setting a precedent.

External Amenity Space

8.60 The proposed scheme provides areas of both communal and private external amenity space.

8.61 The ground floor units facing Gainsford Road and the ground floor east-facing units within

the rear of the scheme are provided with private amenity areas. The private amenity spaces

to the units facing Gainsford Road provides each of these units with a meaningful garden

area, and these are sufficiently set back from the street edge to feel sufficiently private. They

are also protected by defensible planting at the street edge.

8.62 To the west of the rear of the scheme, the ground floor units facing the communal garden

area also benefit from defensible planting and small patio areas. The communal amenity

space features landscaped gardens, new trees and raised planting beds (allotments).

8.63 In total the scheme provides 471m2 of communal amenity space. Eight units receive private

amenity space totalling 152m2. The total amenity space is therefore 623m

2. Table 8.3 (policy

DM7) provides that in flatted developments a minimum of 10m2 external amenity space

should be provided per bedroom. This can be consolidated within communal spaces. As the

scheme provides 45 bedrooms, even if the private spaces are ignored as part of the

assessment, the scheme delivers an over-provision in communal amenity space providing

471m2 and is in accordance with policy.

Outlook & Visual Privacy

8.64 By virtue of the scheme design and taking into account the site surroundings, each of the

proposed dwellings will have an appropriate level of outlook and visual privacy. The majority

of the proposed dwellings will face Gainsford Road also bringing increased natural

surveillance to this part of the street, or into the communal amenity space area.


29

8.65 Potential overlooking to neighbouring residential properties and gardens is also mitigated by

the design and the surrounding condition. The scheme will not introduce any harmful levels

of overlooking to surrounding properties. There are no habitable rooms (or windows) within

the rear elevation of the building facing the gardens on Coleridge Road. It is relevant to note

that the existing building features windows facing north (towards Coleridge Road gardens)

and in comparison, the proposed scheme results in a reduced level of overlooking in this

direction.

8.66 Habitable rooms facing either east or west within the rear of the scheme would not cause

harmful overlooking either, since the facades of the proposed building are set back from the

site boundaries by an appropriate distance. It is not considered that the proposals would give

rise to any harmful impacts in this respect. The proposals accord with policy DM32.

Daylight, Sunlight & Overshadowing

8.67 A daylight, sunlight and overshadowing assessment of the surrounding buildings is

submitted with this planning application. The report tests all relevant surrounding windows

and gardens against the BRE regulations.

8.68 In summary the proposed building will have a low impact on the light receivable by

neighbouring property windows and is fully in accordance with the BRE regulations in this

respect.

8.69 In terms of overshadowing to surrounding garden areas, there is only one garden where a

minor transgression of the BRE regulations would result. The impact upon all other

surrounding gardens will be acceptable and in accordance with the BRE regulations.

8.70 The garden to suffer a minor transgression is identified as garden 13 of 45A Gainsford Road,

located to the west of the proposed scheme. To pass the BRE regulation, the garden would

need to receive at least two hours of sunlight on 21 March to at least 50% of its area. Under

the proposed condition, it would not. However, this garden receives less than the

recommended amount under the existing condition. This is due to its north-facing orientation,

the urban location of the site and the impact of the existing building. In this instance it would

be impractical to avoid this minor transgression of the BRE regulations and the proposal is

considered to be acceptable in this respect.

8.71 In addition to testing the surrounding properties, the proposed dwellings have also been

tested to demonstrate that they would receive an appropriate level of daylight and sunlight.

8.72 In this case and using an established methodology of testing the worst-case scenario, the

proposed flat G12 has been tested as due to its positioning and orientation within the

development, it is considered that this dwelling would receive the least daylight and sunlight

of all the proposed dwellings. The results of the testing show that this dwelling would achieve

daylight and sunlight in excess of the minimum requirement set within the BRE regulations.

8.73 It is therefore the case that all of the proposed dwellings within the scheme will achieve an

appropriate amount of daylight and sunlight.


Design

8.74 The plan of the building is laid out in an efficient T-shape. This establishes a new street

frontage to Gainsford Road and follows the shape of the current building on the site. Facing

Gainsford Road the elevation is part 3, part 4 storeys.

8.75 In response to officer’s comments raise during pre-application discussions, the Applicants

have reduced the height of the proposed building considerably from a uniform height of 4

storeys across the site to a stepped height of part 2, part 3 and part 4 storeys. At the rear,

the building would be lower, but slightly wider than the existing end elevation of the current

building.

8.76 This has resulted in the loss of 6 residential dwellings however it is now considered that the

proposed height of the rear elevation at 2 storeys, facing Coleridge Road gardens, would

ensure that the scheme does not have an overbearing or dominant effect upon these

gardens and the outlook from the rear elevations of these properties will be protected to a

sufficient degree.

8.77 The part 4 storey elevation to Gainsford Road is retained, in order to identify the entrance of

the scheme. This 4 storey element, which is stepped, deliberately announces the building as

a marker, in order to intentionally differentiate the building from the other development on

Gainsford Road. This elevation slopes downwards east to west, following the natural

gradient of the street. Although the adjacent residential buildings to the west are two-storeys,

the bulk and mass of their pitched roofs gives the impression of an additional storey.

8.78 It is relevant to note that other flatted buildings of a more modern appearance within the

vicinity of the site, such as that to the northwest across Coleridge Road are at least 3 storeys

in height. The proposal is an evolution of this incremental increase in height, which is

appropriate as developable land becomes more finite and building at greater densities is

encouraged within planning policy.

8.79 The accompanying Design & Access Statement by Gort Scott architects provides much

more detail on the evolution of the proposals and the design rationale behind the proposed

scheme.

Technical Assessment

Transport

8.80 The proposal provides 45 new dwellings in an area of good public transport accessibility.

8.81 Pocket only develops sites in areas with good public transport links close to local amenities,

since their research has shown that for their buyers who are typically single people and

couples, location is valued first. The proposal provides a policy compliant number of cycle

parking spaces in secure locations within the scheme.


31

8.82 The site is located with a Council-controlled CPZ, hence the scheme can be car-free. It is

proposed that through the lease conditions, and the s106 Agreement, future occupiers will

be restricted from obtaining a permit for on-street parking by the Council. The only exception

to this will be if a wheelchair user comes forward to purchase the wheelchair accessible unit.

If this should happen, it has been identified that a wheelchair parking space would be

marked out, on-street, in front of the development for the blue badge user.

8.83 This proposal can be accommodated without reducing on-street parking capacity, since

under the present condition, the site features two separate vehicular entrances with dropped

kerbs which restrict the width of the parking along the northern side of Gainsford Road.

Under the proposed condition, these would be removed.

8.84 The trip generation assessment demonstrates that due to the site’s existing condition as

offices with 30 vehicle parking spaces, the proposal will result in a reduction in the number of

two-way vehicle trips. There would be a small increase in the number of two-way trips during

both the AM and PM peaks for all modes of transport, except vehicle trips. In summary, the

proposal will be car-free and will promote sustainable modes of travel.

Sustainability & Energy

8.85 In accordance with the Council’s policies DM10 and DM11 and those within the London

Plan, the proposal incorporates sustainable practices and measures to reduce energy

demand. The scheme would, through the provision of highly efficient building fabric, building

services systems and adoption of feasible renewable technologies, achieve an overall

reduction in regulated C02 emissions of more than 35%, exceeding Part L of the Building

Regulations.

Drainage

8.86 In accordance with policy DM34 the proposal reduces flood risk by increasing site

permeability both reducing and slowing surface water run-off. The proposal also protects the

existing water and sewage infrastructure and reduces flood risk.

8.87 It is demonstrated within the sustainable drainage report that accompanies this planning

application that any surface water flows removed from the foul system are likely to offset the

flows generated by the new development, particularly when the foul flows generated by the

existing buildings are also removed.

8.88 The proposal would therefore be in accordance with LBWF policy which requires

development proposals to demonstrate that, where they would generate additional demand,

sufficient capacity already exists or that extra capacity will be provided to ensure that

proposals would not overload Thames Water infrastructure.


Contamination

8.89 Since the proposal would introduce a more vulnerable land use (residential) to the site, a

desktop site contamination report is submitted with the planning application in order to

assess the level of risk that the site may be contaminated by pollutants or other hazardous

material and to assess the risk to receptors.

Trees, Landscaping and Ecology

8.90 The site is entirely hard landscaped and contains no existing trees, however there are trees

located off-site within close proximity of the site. An arboricultural impact assessment and

method statement is submitted with this planning application. The report finds that the

relationship between the building and retained trees is sustainable and is not likely to result

in any pressure to prune requests from future occupants. The arboricultural method

statement and tree protection plan include details of all tree protection measures required.

8.91 In summary, all trees will be retained through the proposals. The proposal will introduce new

trees and landscaping within the communal amenity space and overall, the biodiversity of the

site will be enhanced by the scheme. The proposals are in accordance with policy DM35.


33

9. SUMMARY & CONCLUSIONS

9.1 The Council’s strategic planning policies identify the provision of new homes, and particularly

affordable homes, as being a priority land use. The Pocket model of development provides

homes for Londoners who live and work in LBWF and who cannot afford homes on the open

market.

9.2 The proposed development will see a previously-developed (brownfield) site containing a

dilapidated vacant building back in to sustainable use to provide a significant number of new,

high quality homes. All of the new homes will be provided as intermediate affordable housing

tenure. The characteristics of the site mean that residential development is considered

appropriate.

9.3 Whilst the innovative development model proposed may appear unconventional in terms of

the unit mix and unit sizes (in comparison with the Council’s policy aspirations and

requirements) the development provides all 45 new homes as 100% intermediate affordable

housing, significantly exceeding the Council’s policy requirement of 50% provision. The

Pocket model, which is consistent across London in several other boroughs, is endorsed by

the Mayor of London who is supporting Pocket as a partner developer in delivering new

intermediate affordable homes through his Housing Covenant.

9.4 The proposals as submitted have been the subject of pre-application discussions with the

Council, it’s planning and housing officers, and with local residents through the Applicant’s

own public consultation exercise. As a result of these discussions, the development has

been significantly revised – albeit this has resulted in a reduction in the number of homes

provided.

9.5 The application is supported by a suite of technical documents and reports that demonstrate

that the proposal would comply with the Council’s detailed development management

planning policies, as well as the strategic objectives of the Council’s core strategy, and those

within the London Plan which all acknowledge the imperative to provide new homes.

9.6 The proposals are consistent with the Government’s primary objective for the planning

system – that development should be sustainable. The proposals have been shown to be

consistent with the Government’s definition of sustainable development (economic, social

and environmental) and therefore the presumption in favour applies.

9.7 The development would result in the significant benefit of providing 45 new affordable

residential dwellings within the borough. The proposal is consistent with the broad objectives

of the NPPF, the London Plan and the Council’s Development Plan. For these reasons,

planning permission should be granted.

24 Southwark Bridge Road, London, SE1 9HF | 0203 268 2018 [email protected] | boyerplanning.co.uk


APPENDIX ONE – COUNCIL’S CABINET REPORT


35

APPENDIX TWO – EXISTING BLDG. FLOORPLAN

Lift

R

44

S

44

44

ICTCabinet

s

ICTCabinet

s

44

44

44

44

444

4

Main Building01/01First Floor

105FStore 101F

Office

102FCirc.

103FStore

108FMale W.C.

109FFemale W.C.110F

Kitchen111F

Meeting Room

016FCirc.

112FServer Room

113FMeeting Room 114F

Office115FOffice

106FOffice

104FCirc.

Up.

Up. U

p.

N

44

Sh

R

R

M

Sh

HA

HA

HA

HA

HA

HA

B

B

B

B B

Server

47 Gainsford Road

First Floor Plan - Furniture Layout

1:100@A3

23/09/2013

T. Haines

GR-FF01

DateDescription

NOTES

Ref.

Drawing No.Scale :

Date :

Revision :Drawn :

Location Key

Project :

Drawing Title :

No .of floors :

This drawing should not be assumed to be 21/6/2012accurate - Do not scale. All dimensions tobe checked on site

A

Sample details

Property Services

LiftMain Building01/01First Floor

105FStore 101F

Office

102FCirc.

103FStore

108FMale W.C.

109FFemale W.C.110F

Kitchen111F

Meeting Room

016FCirc.

112FServer Room

113FMeeting Room 114F

Office115FOffice

106FOffice

104FCirc.

Up.

Up. U

p.

NIA = 249.08 sq. m.Circulation = 10.8 sq. m.

N

R

47 Gainsford Road

First Floor Plan - NIA & Circulation

1:100@A3

23/09/2013

T. Haines

GR-FF05

DateDescription

NOTES

Ref.

Drawing No.Scale :

Date :

Revision :Drawn :

Location Key

Project :

Drawing Title :

No .of floors :


A

Sample details

Property Services

Void

MainEntrance

Site Area:

Up.

Up.

Up.

Up.

Up.

44

44

SS

SS

44 44

S

444444

44

47 Gainsford Road

100022982654100022982654

Sh

Main Building01/01Ground Floor

Sh

025GW.C.

003GStaff Room / Meeting Room 002G

Office

001GMeeting Room

005GMale Staff W.C.

006GFemale Staff W.C.

007GKitchen

008GOffice

009GOffice 004G

Circ.

010GALift

017GMeeting Room016G

Meeting Room

015GMeeting Room

013GStore

014GOffice012G

W.C.

011GStore

024GStore

020GStore 018G

Office

010GCirc.

019GCirc.

022GW.C.

021GStairs

027GCirc.

023GOffice

026GInterview Room

S

Void

S4

4

4 4

S

N

SS

HA

HA

44

S

HA

HA

Sh

AC

AC

R

B

M

RR

M

Sh

V

47 Gainsford Road

Ground Floor Plan - Furniture Layout

1:100@A3

23/09/2013

T. Haines

GR-GF01

DateDescription

NOTES

Ref.

Drawing No.Scale :

Date :

Revision :Drawn :

Location Key

Project :

Drawing Title :

No .of floors :


A

Sample details

Property Services

Void

MainEntrance

Up.

Up.

Up.

Up.

Up.

47 Gainsford RoadMain Building01/01

025GW.C.


Office

001GMeeting Room

005GMale Staff W.C.


007GKitchen

008GOffice

009GOffice 004G

Circ.

010GALift


Meeting Room

015GMeeting Room

013GStore

014GOffice012G

W.C.

011GStore

024GStore

020GStore 018G

Office

010GCirc.

019GCirc.

022GW.C.

021GStairs

027GCirc.

023GOffice

026GInterview Room

NIA = 430.29 sq. m.Circulation = 81.04 sq. m.

N

RR

47 Gainsford Road

Ground Floor Plan - NIA & Circulation

1:100@A3

23/09/2013

T. Haines

GR-GF05

DateDescription

NOTES

Ref.

Drawing No.Scale :

Date :

Revision :Drawn :

Location Key

Project :

Drawing Title :

No .of floors :


A

Sample details

Property Services

Void

MainEntrance

Up.

Up.

Up.

Up.

Up.

Office Area - OP = 166.52 sq. m.

47 Gainsford RoadMain Building01/01

025GW.C.


Office

001GMeeting Room

005GMale Staff W.C.


007GKitchen

008GOffice

009GOffice 004G

Circ.

010GALift


Meeting Room

015GMeeting Room

013GStore

014GOffice012G

W.C.

011GStore

024GStore

020GStore 018G

Office

010GCirc.

019GCirc.

022GW.C.

021GStairs

027GCirc.

023GOffice

026GInterview Room

Office Area - Cellular = 10.91 sq. m.N

RR

47 Gainsford Road

Ground Floor Plan - NIA & Circulation

1:100@A3

23/09/2013

T. Haines

GR-GF06

DateDescription

NOTES

Ref.

Drawing No.Scale :

Date :

Revision :Drawn :

Location Key

Project :

Drawing Title :

No .of floors :


A

Sample details

Property Services

Void

MainEntrance

Up.

Up.

Up.

Up.

Up.

SS

SS

S

Sh

Main Building01/01Ground Floor

Sh

025GW.C.


Office

001GMeeting Room

005GMale Staff W.C.


007GKitchen

008GOffice

009GOffice 004G

Circ.

010GALift


Meeting Room

015GMeeting Room

013GStore

014GOffice012G

W.C.

011GStore

024GStore

020GStore 018G

Office

010GCirc.

019GCirc.

022GW.C.

021GStairs

027GCirc.

023GOffice

026GInterview Room

S

Void

S

S

N

SS

HA

HA

S

HA

HA

Sh

AC

AC

R

B

RR

Sh

V

47 Gainsford Road

Ground Floor Plan - Room Numbering

1:100@A3

23/09/2013

T. Haines

GR-GF04

DateDescription

NOTES

Ref.

Drawing No.Scale :

Date :

Revision :Drawn :

Location Key

Project :

Drawing Title :

No .of floors :


A

Sample details

Property Services


APPENDIX THREE – ASBESTOS SURVEY

MANAGEMENT ASBESTOS SURVEY REPORT CENTRAL DIVISION

47 GAINSFORD ROAD LONDON E17 6QB

DECEMBER 2013

232

AEC are UKAS accredited for surveying and hold the Type C UKAS inspection no. - 232.

Report prepared for: NPS London Ltd. 3-4 Avocet House Trinity Park Trinity Way Chingford E4 8TD

Report reference: L-37763

Issue date: January 2014

Survey completed by: Mr M. Collins Environmental Consultant

Approved by:

L-37763 2 of 11 Central Division, 47 Gainsford Road, London 14/01/2014 NPS London Ltd

CONTENTS 1.0 EXECUTIVE SUMMARY ................................................................................. 3 2.0 INTRODUCTION AND AEC’s BRIEF............................................................... 4 3.0 DESK STUDY AND GENERAL BUILDING INFORMATION ............................ 6 4.0 INACCESSIBLE AREAS AND PROJECT SPECIFIC RESTRICTIONS ........... 8 5.0 RECOMMENDATIONS ................................................................................... 9 6.0 MANAGEMENT OF ASBESTOS ................................................................... 11

APPENDICES I ITEM NUMBER LOCATION PLAN(S) Pages 1 - 3 II SHORT FORM INFORMATION Pages 1 - 29 III CERTIFICATES OF ANALYSIS Pages 1 - 3 IV SURVEY METHODOLOGIES Pages 1 - 3 V GENERAL RESTRICTIONS Pages 1 - 2


1.0 EXECUTIVE SUMMARY

A management asbestos survey of Central division, 47 Gainsford Road, London, E17 6QB, has been undertaken by AEC. This section should be read in conjunction with Section 4.0 (Inaccessible Areas) and Section 5.0 (Recommendations) as well as Appendix I (Item Number Location Plans) and Appendix II (Building Register and Results). The building register includes a material risk assessment. During the survey the following asbestos containing materials have been identified:

• Asbestos debris to various locations to the first floor area ceiling voids.

• Asbestos insulating board to the durasteel door in the boiler room.

• Presumed asbestos soffit boards to high level external areas. N.B. Urgent remedial action is required to make safe asbestos identified on this site. These measures are detailed in the recommendations section of this report. N.B. For further sample details, please refer to Appendix II Building Register and Results and Appendix III Certificate of Bulk Fibre Analysis. It should be presumed that the inaccessible areas detailed in Section 4.0 will contain asbestos and be managed accordingly until such time that the areas can be inspected and proven to be asbestos-free.


2.0 INTRODUCTION AND AEC’s BRIEF

At the request of Darryl Taylor, acting on behalf of NPS London Ltd, Airborne Environmental Consultants Limited (AEC) have carried out a management asbestos survey to all accessible areas of Central Division, 47 Gainsford Road, London, E17 6QB. AEC have been requested to provide the following services:

• To provide an experienced asbestos survey team to site to carry out a management survey, as outlined in HSG 264 Asbestos: The Survey Guide, and our quotation ref: LQ13-2451.

• To take representative samples of any materials suspected of containing asbestos and to analyse these in general accordance with HSE document HSG 248 - ‘Asbestos: The analysts’ guide for sampling, analysis and clearance procedures’.

• To prepare a detailed written report showing the location, extent and condition of all identified asbestos installations along with any remedial recommendations necessary. All recommendations shall be made considering the building is to be safely managed.

The survey was carried out by Mike Collins and Ben Williams and site works were completed on the 4

th December 2013.

This survey report must be read in conjunction with any other associated or referenced asbestos survey report(s).

SURVEY PLAN The exact areas to be surveyed and the survey types requested by the customer to be carried out in these areas are as follows:

Area/building to be surveyed Survey type Areas/Installations excluded by customer

All accessible areas of Central Division, 47 Gainsford Road, London

Management None

In addition, several localised areas were identified where the survey team could not obtain full access at the time of survey. These are detailed in Section 4.0. The methodology associated with this survey is given in Appendix IV of this report.


A GUIDE TO THE SURVEY RESULTS An item number is used throughout this report to relate a sampled, strongly presumed, or presumed asbestos installation to its location on site. When an asbestos installation is sampled it is given a unique laboratory sample number so that the bulk sample can be traceable within AEC’s UKAS accredited laboratory. In addition to the laboratory sample number the bulk sample is given an item number, which relates the identified asbestos installation to its location on site. Where a material has not been sampled, but is strongly presumed (typically to be the same as a sampled installation) or presumed (typically if not accessible) to contain asbestos, the material is also given an item number, again relating the installation to its location on site. The item number is used on the item number location plans in Appendix I and in the building register and results in Appendix II to help identify where the asbestos installations are located on site. Appendix I and Appendix II must be read in conjunction with the rest of this survey report, especially Section 4.0 Inaccessible areas and project specific restrictions and Section 5.0 Recommendations. The certificate of bulk fibre analysis in Appendix III uses a laboratory sample number to show the result of the analysis carried out on a bulk sample taken on site during the asbestos survey. To relate a laboratory sample number on the certificate of bulk fibre analysis to the building register and results in Appendix II, and thus find the location of the asbestos installation on site, simply look up the laboratory sample number in the building register to obtain its item number or vice versa, if you are reading the building register and results in Appendix II and wish to obtain further details on the analysis carried out on a bulk sample. If you have any concerns about the accuracy of the data, contact AEC in the first instance, as queries may be answered and additional costs prevented. For a full explanation of the various headings used in the building register and results table see Appendix II.

232

AEC are UKAS accredited for surveying and hold the Type C UKAS inspection no. - 232.


3.0 DESK STUDY AND GENERAL BUILDING INFORMATION

HSG 264 recommends that, whenever possible, a preliminary desk study be carried out in order to gather information pertinent to the building(s) under investigation. AEC have requested this information and a review of this has revealed the following: 3.1 Desk study

Information requested Information provided

Building(s) Type / Address Central Division, 47 Gainsford Road, London

Age(s) of construction 1930s

Building description Three-storey, brick-built office block

Usage of site Multi-use commercial office building

Site conditions Occupied with live services

Drawings / Plans

None provided, to be drawn on site

Information on any previous asbestos removal operations at the site

None provided

List any previous survey info / ref no’s

None provided

The general NON-ASBESTOS materials used in the structure are described below. Where sampled these will be referred to in the building register and results (see Appendix II). 3.2 General building information

Location

Description

Floors Concrete and timber overlain with carpet, modern linoleum

Stairs Timber

Sub floors No access gained, specialist access equipment is required

Risers / Service ducts None evident

Walls external Brick and profile sheeting


3.2 Continued

Walls internal Brick, plaster, timber, compressed organic board, ceramic tiles

Ceilings solid Compressed organic board, plaster, timber

Ceilings suspended Man-made mineral fibre (MMMF), metal pipework, electric cables

Rainwater goods Metal and plastic

Wastewater goods Plastic

Plant / Equipment Lift machinery

Doors/window frames Plastic and metal window frames, timber doors

Heating systems

Gas and oil boiler units (no make available)

Roof type Pitched and flat

Roof materials Modern mineral felt and profiled sheets to prefabricated unit , no access above 5m elsewhere

Insulation - pipes MMMF, compressed foam, sealed plastic within boiler room

Insulation - boilers None evident

Insulation - loft MMMF

Out buildings None evident

Other materials Ceramic toilet cisterns ‘Supalux’ panels throughout prefabricated unit (as sampled) Timber panels above entrance door Concrete canopy to external doors


4.0 INACCESSIBLE AREAS AND PROJECT SPECIFIC RESTRICTIONS

During the survey, the following areas were deemed to be inaccessible for the following reasons: 4.1 Agreed inaccessible areas

• Within live plant such as boiler and lift machinery.

• Within live electric equipment throughout.

• Behind sampled materials as these could potentially contain asbestos. 4.2 Access limitations

• All areas above 5m could not be accessed, specialist access equipment will be required.

• Various locations blocked by stored items at the time of the survey.

• Various ceiling voids throughout due to excessive MMMF being present, live cables and ductwork.

4.3 Unsafe conditions

• All services remained live for the duration of the survey.

• No access was gained to the ceiling void areas to offices 3, 4, 5, 6, server room, landing 2, WC1, WC2, Kitchen and the loft area above due to the risk of contamination (see sample 15 Appendix II).

4.4 Client restrictions

• All areas remained occupied for the duration of the survey. See Appendix V for management survey general restrictions and exclusions. AEC have not inspected areas of the property/structure, which are covered, unexposed or inaccessible and we are, therefore, unable to report that any such part of the property/structure is free from asbestos. Although the presence of asbestos in these area(s) is not confirmed, it should be presumed that asbestos could be present and caution should be exercised if any works are carried out there in the future. If any suspect materials are encountered in these areas it is recommended that works cease immediately until such time that the material can be sampled, analysed and confirmed to be asbestos-free.


5.0 RECOMMENDATIONS

Recommendations are based upon the HSG 264 material assessment, and also on a subjective priority risk assessment basis, using the surveyor’s knowledge of the occupation of the property during the survey, and any known future usage or planned works. Priority risk assessments are not UKAS accredited, and the algorithm in HSE document ‘HSG 227, a comprehensive guide to managing asbestos in premises’, is not included in this report. The implementation of appropriate remedial measures is a requirement under the Control of Asbestos Regulations 2012 where there is a risk of exposure to asbestos. In view of the findings of the survey, and it is known that ongoing maintenance and management of the building is planned, the following recommendations are made: 5.1 Management actions to be implemented urgently.

5.2 It is recommended that the identified asbestos debris to the ceiling void within landing

area 2 (see sample 15, Appendix II) be removed by a licensed asbestos removal contractor a soon as possible.

5.2.1 Access should be restricted to the ceiling void areas of offices 3, 4, 5, 6, server room, landing 2, WC1, WC2, kitchen and the loft until further investigation / removal work can be planned and undertaken (see Appendix II).

5.3 Management actions to be implemented as soon as possible but have no immediate risk of exposure.

5.3.1 The asbestos containing board to the ‘dura steel’ door within the boiler room should be

managed and inspected on a regular basis ideally every 12 months by a competent person.

5.3.2 It is recommended that the high-level external soffit boards presumed to be asbestos be managed as such and inspected on a regular basis until they can be investigate further.

5.3.3 It is recommended that this report and register be used to form a part of a management plan for this site. The management plan should include regular inspections of any asbestos installations contained within the premises, in order to prevent damage / exposure to asbestos.

5.3.4 It is recommended that an independent, UKAS-accredited asbestos laboratory be

employed to manage any asbestos removal, and where applicable carry out all visual inspections and air monitoring as outlined in - HSG248: Asbestos: The analysts’ guide for sampling, analysis and clearance procedures’.

5.3.5 If any major disturbance of the fabric of the building(s) is planned it is recommended that

all areas that have been subjected to a management survey be further investigated to a refurbishment and demolition survey standard before the works can proceed (see Appendix IV for definitions of survey types and their limitations).

5.3.6 It is recommended that the site review the data provided within the survey report and

undertake a priority assessment to determine the risks of exposure of staff (including maintenance staff) and visitors to the site in order to prioritise any future remedial action. This should be undertaken by a person or persons who understand the activities on the site and the likelihood of these activities disturbing any identified asbestos.


5.3.7 If any areas detailed in Section 4.0 ‘Inaccessible Areas’ are to be accessed or worked

upon it is recommended that the areas be subjected to an appropriate survey prior to works commencing. Until that time asbestos should be presumed to be present in these areas.

5.3.8 It is recommended that, if this report is being relied upon for tendering purposes for refurbishment or demolition works, a suitable contingency sum be included in any such tender to cater for the unlikely event of further asbestos-containing materials being identified within the fabric of the building, or behind identified asbestos installations.

N.B. 1. It is a requirement of the Control of Asbestos Regulations 2012 to use licensed asbestos

removal contractors for all significant work with asbestos sprayed coatings, asbestos insulation/lagging, asbestos insulating board (AIB) and any form of asbestos installed in an insulation capacity. This work requires a 14-day notification period to HSE or Local Authority (depending on type of premises) prior to commencement of works. Further to this, it as a requirement of the Control of Asbestos Regulations 2012 that work involving either the deterioration of non-licensed products, or work on ‘degraded’ (i.e. those in a poor condition) non-licensed products be classed as notifiable non-licensed work (NNLW) and the work be notified to HSE. Licensed asbestos removal contractors are not legally required for work with lower risk asbestos products such as asbestos cement, bitumen products, vinyl flooring products, textured coatings etc, or for NNLW work. However, in ALL instances of work with asbestos the requirements of the Control of Asbestos Regulations 2012 will apply and appropriate assessments, plans of work, controls, PPE/RPE and training will be required. For this reason AEC normally recommend that a licensed asbestos removal contractor be used for ALL asbestos related works as they should have the appropriate training, competence and equipment to undertake these works to an acceptable standard.

2. It is a requirement of Regulation 4 of the Control of Asbestos Regulations 2012 that all

remedial actions be carried out. Following this, the implementation of an asbestos management plan should be carried out, including periodic re-inspection of all identified ACMs on a 6 to 12 monthly basis.

3. In cases of emergency where the uncontrolled release of asbestos is suspected, AEC can

offer an independent analytical consultancy service for items such as initial advice, sampling, air monitoring and subsequent management of licensed contractors for any make-safe/removal work that may be found to be necessary (AEC hold a list of nationwide licensed contractors).

AEC Contact details are as follows: Airborne Environmental Consultants 23 Wheel Forge Way Ashburton Point Trafford Park Manchester M17 1EH Telephone: 0161 872 7111 Fax: 0161 872 7112


6.0 MANAGEMENT OF ASBESTOS

Regulation 4 of The Control of Asbestos Regulations 2012 places an explicit duty on persons responsible for buildings (dutyholders) to assess whether asbestos is present and, if so, implement a management plan to safely manage the material. Regulation 4 applies to all non-domestic premises, but includes ‘common areas’ of domestic buildings, such as stairwells, walkways, risers, lift shafts and machinery, tank rooms etc. The asbestos survey of the premises and implementation of the asbestos register goes a long way to compliance with the regulations, including risk assessment of existing asbestos materials, which is covered in the recommendations section (Section 5.0) of this report. However, the management plan shall require a priority risk assessment of asbestos materials to be carried out by the duty holder, and while recommendations in this report are based on the survey team’s subjective priority assessment, using the material assessment, and the location of the materials, the surveyor is not necessarily aware of the future use, occupation, and / or maintenance of each installation. There is, however, a duty under the regulations to carry out ongoing asbestos management works in the future, and the management plan should ensure that the identified asbestos installations remain safe. Airborne Environmental Consultants Ltd. can provide the following further services to ensure compliance with both the recommendations made in this report, and any future duties to be imposed by the Control of Asbestos Regulations 2012:

• Regular inspections on the condition of asbestos materials in the premises. This is to ensure that the material remains in a safe condition and is labelled. Also assists in the review of the management plan.

• Future management of asbestos. This can include the preparation of priority risk assessments for the management plan, risk assessments for works within the premises, to the preparation of specifications for their removal as required.

• Project management of all asbestos removal / treatment works, including competitive tendering of removal works.

• Independent analytical services such as air sampling following the removal of asbestos, ensuring compliance with existing legislation.

• Liaison with enforcing authorities, such as the Health and Safety Executive or local authority. AEC have the capability to maintain and to update your asbestos register. This would firstly ensure that asbestos records and procedures are being managed and updated by competent and experienced persons, and also minimise pressure on your management personnel, who would be able to overview the asbestos issue, rather than become involved in the extensive risk assessment and record keeping exercise. AEC can also host and update your asbestos information on our secure web based asbestos management service called ‘asure’.

APPENDIX I

ITEM NUMBER LOCATION PLANS

Please note: AEC have applied an area reference to the drawings provided. In the absence of clear room identifiers etc. this is often the only way to relate a sample or

asbestos installation to a specific part of a building.

Areas / rooms containing asbestos shall be indicated with the warning symbol and

item numbers shall indicate the location of the item on the plans.

��

��

��

��

��

�� !�"�#�$"!%��&�#��'

��

��

��

��

�

��

��

� �

��

��

��

��

�

��

��

��

� �!

"#"$

"

%�&��

�"

$'��

��%��

��

��

()

��

�*��'

�

��+

�*+

,��

� -��"

$��

��

.��

��

'�

"��

�"'"

��

�$,

�$�

$�

/��*-�$

��

��

��

�0

��

1

��

��

�� !��!��

��"

�##$��

��

��%

#&'(�)��&

*$�&#�

��#��

��+��

��,��

(�$-�#��

��

6

#��"� ��!��!�� 4$�5�!�$��

2��"�$"�(�"7 "(!$�"�5$!��!��

� $�&$"��$�!��"&��4�"!�

��(!$�"��5$!�$"�!��2��!%��

&�!�$��!��(�"!�$"$"��

3�!��$��

-)

-�

)�

-.

-*

-8

-�

-;

-/

))

)-

)�

.-

)8

):

��$&��

)

�/

�*

�8

8-

�;

�-

);

)/

:/

)*

��$&��

�

��$&��

�

��$&��

8

�.

�:

�-

��$&��

:

�)

��

��

�8

�.

�:

).

:;

�;

�/

�*

;

8/

�*

8:

.

)�

�

)

��

��

��

��

��

�� !�"�#�$"!%��&�#��'

��

��

��

��

�

��

��

� �

��

��

��

��

�

��

��

��

� �!

"#"$

"

%�&��

�"

$'��

��%��

��

(��

)*

��

"�$�

�'

�

��+

�,+

-��

� .��"

$��

��

/��

��

'�

"��

�"'"

��

�$-

�$�

$�

0��,.�$

��

��

��

�1

��

2

��

��

�� !��!��

��"

�##$��

��

��%

#&'(�)��&

*$�&#�

��#��

��+��

��,��

(�$-�#��

��

4

#��"� ��!��!�� 5$�6�!�$��

2��"�$"�(�"7 "(!$�"�6$!��!��

� $�&$"��$�!��"&��5�"!�

��(!$�"��6$!�$"�!��2��!%��

&�!�$��!��(�"!�$"$"��

3�!��$��

8)

88

8�

8�

8:

4

8.

;$!(��"

�

�

)

��

��

��

��

��

�� !�"�#�$"!%��&�#��'

��

� ��

�� !"!#!$�%��!#&��

��$��'��()��)�#�*��!&��

*��*

��*�+*,��-��!#��.��&�!��!&!��

�#,�#�#�/��+-�#��0��1

��

��

�� !��!��

��"

�##$��

��

��%

#&'(�)��&

*$�&#�

��#��

��+��

��,��

(�$-�#��

��

4

#��"� ��!��!�� 5$�6�!�$��

2��"�$"�(�"7 "(!$�"�6$!��!��

� $�&$"��$�!��"&��5�"!�

��(!$�"��6$!�$"�!��2��!%��

&�!�$��!��(�"!�$"$"��

3�!��$��

�$"�

��(!�$($!��

�"&��

��"'�

��3

8*

8:

8/

�2

��$��

��3

;)

;8

;. ;�

;�

;*

;;

�$�!�3�!��

��3

4

APPENDIX II

SHORT FORM INFORMATION

Location Central Division - Ground floor - Meeting room - Boarding panel to wall to the middle of the room adjacent to heater unit

Item No: 1 Laboratory sample no: SCO/13/9884A / 001

Accessibility: Easily accessible

Installation: Boarding (2)

Approx extent (m2 unless stated) 2

Asbestos Type: NAD

Condition: N/A Surface Treatment: N/A

Risk Assessment (H/M/L/VL)

None Recommendation: None

Location Central Division - Ground floor - Meeting room - Boarding panel to the far corner of the room entrance door side

Item No: 2 Laboratory sample no: SP as SCO/13/9884A / 001




Asbestos Type: NAD




Location Central Division - Ground floor - Meeting room - Boarding panel to the wall adjacent to fire escape door





Asbestos Type: NAD




Location Central Division - Ground floor - Corridor 1 - Boarding to walls (protruding panels) to plasterboard





Asbestos Type: NAD




Location Central Division - Ground floor - Photocopier room - Boarding to wall (protruding panels) to plasterboard





Asbestos Type: NAD




Location Central Division - Ground floor - WC 1 - Boarding to wall (protruding panel) to plasterboard





Asbestos Type: NAD




Location Central Division - Ground floor - WC 1 - Blue linoleum to floor



Installation: Linoleum (1)


Asbestos Type: NAD









Asbestos Type: NAD




Location Central Division - Ground floor - WC 2 - Boarding to wall (protruding panel) to plasterboard





Asbestos Type: NAD




Location Central Division - Ground floor - Kitchen - Boarding to wall (protruding panel) to plasterboard





Asbestos Type: NAD

Condition: N/A Surface Treatment: Sealed (1)


None Recommendation: Satisfactory condition, inspect periodically

Location Central Division - Ground floor - Kitchen - Beige linoleum to floor





Asbestos Type: NAD




Location Central Division - Ground floor - Office 2 - Boarding to wall (protruding panels) to plasterboard





Asbestos Type: NAD




Location Central Division - Ground floor - Staff room - Boarding to wall (protruding panels) to plasterboard





Asbestos Type: NAD




Location Central Division - Ground floor - Office 1 - Boarding to wall (protruding panel) to plasterboard





Asbestos Type: NAD




Location Central Division - Ground floor - Corridor 2 - Boarding to wall (protruding panel) to plasterboard





Asbestos Type: NAD




Location

Central Division - Ground floor - Corridor 3 - Boarding to corners of walls (protruding panel) to plasterboard to end if corridor area adjoining to corridor 2





Asbestos Type: NAD




Location Central Division - Ground floor - Corridor 3 - Textured coating to walls



Installation: Textured coating (1)


Asbestos Type: NAD









Asbestos Type: NAD




Location Central Division - Ground floor - Office 7 - Textured coating to walls

Item No: 19 Laboratory sample no: SP L-37763 / 008




Asbestos Type: NAD




Location Central Division - Ground floor - Office 7 - Boarding to ceiling above suspended ceiling tiles


Accessibility: Normally accessible



Asbestos Type: NAD









Asbestos Type: NAD









Asbestos Type: NAD









Asbestos Type: NAD









Asbestos Type: NAD




Location Central Division - Ground floor - Corridor 4 - Textured coating to walls





Asbestos Type: NAD




Location Central Division - Ground floor - Corridor 4 - Boarding to ceiling





Asbestos Type: NAD




Location Central Division - Ground floor - Office 8 - Boarding to ceiling





Asbestos Type: NAD









Asbestos Type: NAD




Location Central Division - Ground floor - Office 8 - Blue linoleum to floor





Asbestos Type: NAD




Location Central Division - Ground floor - Corridor 5 - Boarding to ceiling above suspended tiles and stairs





Asbestos Type: NAD




Location Central Division - Ground floor - WC 4 - Boarding to ceiling above suspended tiles and stairs





Asbestos Type: NAD









Asbestos Type: NAD




Location Central Division - Ground floor - Office 9 - Boarding to ceiling above suspended tiles





Asbestos Type: NAD




Location Central Division - Ground floor - Reception - Boarding to ceiling above suspended tiles





Asbestos Type: NAD




Location Central Division - Ground floor - Interview room - Boarding to ceiling above suspended tiles

No Photo Available





Asbestos Type: NAD




Location Central Division - Ground floor - WC 5 - Boarding to ceiling above suspended tiles

No Photo Available





Asbestos Type: NAD









Asbestos Type: NAD









Asbestos Type: NAD









Asbestos Type: NAD





No Photo Available





Asbestos Type: NAD




Location Central Division - First floor - Office 1 - Textured coating to walls





Asbestos Type: NAD




Location Central Division - First floor - Office 2 - Boarding to ceiling





Asbestos Type: NAD




Location Central Division - First floor - Store 2 - Boarding to ceiling

No Photo Available





Asbestos Type: NAD




Location Central Division - First floor - Lobby - Boarding to ceiling

No Photo Available





Asbestos Type: NAD




Location Central Division - First floor - Landing 2 - Debris to top of ceiling tiles



Installation: Debris (3)


Asbestos Type: Chrysotile / Crocidolite / Amosite (3)

Condition: High Damage (3) Surface Treatment: Unsealed (3)


High (12) Recommendation: Remove

Location Central Division - First floor - Kitchen - Bitumen pad to sink unit



Installation: Sink pad(s) (1)

Approx extent (m2 unless stated) 2 No

Asbestos Type: NAD




Location Central Division - Basement - Gas and electrics room - Bitumen wrap to cable



Installation: Textile (2)

Approx extent (m2 unless stated) 1m-lin

Asbestos Type: NAD




Location Central Division - Basement - Gas and electrics room - Debris to left and rear walls





Asbestos Type: NAD




Location Central Division - Basement - Gas and electrics room - Debris to right hand wall





Asbestos Type: NAD




Location Central Division - Basement - Gas and electrics room - Debris to ceiling





Asbestos Type: NAD




Location Central Division - Basement - Boiler room - Boarding to door





Asbestos Type: Amosite / Chrysotile (2)

Condition: Low Damage (1) Surface Treatment: Sealed (1)


Medium (8) Recommendation: Satisfactory condition, inspect periodically

Location Central Division - Basement - Boiler room - Debris to left hand and entrance wall





Asbestos Type: NAD




Location Central Division - Basement - Boiler room - Debris to rear wall





Asbestos Type: NAD




Location Central Division - Basement - Boiler room - Debris to right hand wall





Asbestos Type: NAD




Location Central Division - Basement - Boiler room - Debris to ceiling





Asbestos Type: NAD




Location Central Division - Basement - Boiler room - Gasket to pipework



Installation: Gasket(s) (2)

Approx extent (m2 unless stated) <10 No

Asbestos Type: NAD




Location Central Division - Basement - Boiler room - Debris to pipework





Asbestos Type: NAD




Location Central Division - External - Boarding to high level soffits

Item No: 58 Laboratory sample no: Not sampled

Accessibility: Highly inaccessible


Approx extent (m2 unless stated) 150m-lin

Asbestos Type: Presumed Crocidolite (3)



Medium (7) Recommendation: Presume ACM’s present until area has been surveyed

Location Central Division - External - Cement panels to high level prefabricated building



Installation: Cement (1)


Asbestos Type: NAD




Location Central Division - External - Panels to prefabricated building



Installation: Cement (1)


Asbestos Type: NAD




Location Central Division - Basement - Gas and electric store - No access gained to live electrics


Accessibility: No access gained

Installation: Unknown (3)

Approx extent (m2 unless stated) Unknown

Asbestos Type: P: Crocidolite(3)



Medium (8) Recommendation: Presume ACM’s are present until area has been surveyed

Location Central Division - Basement - Boiler room - No access gained to live boiler equipment





Asbestos Type: Presumed: Crocidolite(3)




Location Central Division - First floor - Kitchen - No access gained to ceiling void due to possible contamination from landing 2








High (12) Recommendation: Presume ACM’s are present until area has been surveyed

Location Central Division - Throughout - No access gained above 5m and to prefabricated building roof due to access and health and safety issues





Asbestos Type: Presumed: Crocidolite (3)




Location Central Division - First floor - Loft room - No access gained to tank room due to possible contamination from landing 2






Condition: High Damage (3) Surface Treatment: High Damage (3)


High (12) Recommendation: High (12)

Location Central Division - First floor - Office 3 & 4 - No access gained to ceiling void due to possible contamination from landing 2









Location Central Division - First floor - Office 6 - No access gained to ceiling void due to possible contamination from landing 2









Location Central Division - First floor - Office 5 - No access gained to ceiling void due to possible contamination from landing 2









Location Central Division - First floor - WC 2 - No access gained to ceiling void due to possible contamination from landing 2









Location Central Division - First floor - WC 1 - No access gained to ceiling void due to possible contamination from landing 2









Location Central Division - Ground floor - Store 4 - No access into safe






Condition: Low Damage (1) Surface Treatment: Low Damage (1)



Location Central Division - Live wall mounted heater units throughout - No access gained into live wall mounted heater units throughout









Location Central Division - Lift and lift shaft - No access gained into live lift machinery and lift shaft









Location Central Division - Basement - Lift motor room - No access gained due to no keys available

No Photo Available









Location Central Division - First floor - Server room - No access gained to ceiling void due to possible contamination from landing 2









Guidance on the building register and results

In the register, there is a risk assessment column, and a simple material risk assessment algorithm, in accordance with HSG 264, completes this risk assessment (see table in Appendix II). This material assessment is a general guide to the risk posed by the asbestos-containing materials, using the product type, damage, surface treatment, and asbestos type to give a risk ‘score’ (for explanations, see below). However, the recommendations in Section 5.0 of this report are not solely a product of this assessment. The survey team, using their experience, observations and current / future usage of the premises gleaned from the customer, give recommendations based on the usage of the area, future activities, and potential for damage.

The register table has a blank ‘Remedial Actions & Date’ column, designed for future usage. This column should be used when any removal works, remedial actions, labelling or inspections etc are carried out. It is recommended that regular inspections are undertaken to manage asbestos installations as part of a management plan, and that this information be recorded in the column on the register. HSG 264 states that ‘the person carrying out inspections and assessing the condition of asbestos must be competent and possess enough knowledge about asbestos to make decisions on its continual management’. Should your company or organisation not have a competent person, or the human resources to implement regular inspections, AEC can offer an asbestos project management services to visit premises, and update your asbestos register.

Explanation of building register and results table:

Item number and sample numbers

This report uses ‘item numbers’ to denote materials that have been sampled, strongly presumed, or presumed to contain asbestos. These should be not be confused with ‘sample numbers’, which are unique reference numbers given to each sample taken during the survey to ensure that they are traceable through the survey and laboratory analysis process.

The diagrams, tables and photographs (Appendices I, II and IV) all use the item numbers to define any materials that have been assessed (tables also include the sample number for ease of reference).

Sample numbers

The certificates of analysis (Appendix III) use the sample number as a reference guide. Where a material has been sampled, a unique identification number is allocated to every bulk sample obtained for bulk sample analysis. The unique laboratory sample number ensures traceability within AEC’s UKAS accredited laboratory system.

Strongly presumed or presumed

Where a material has not been sampled, but is visually similar to a previously sampled material then it shall be cross referenced to the previous sample and noted: ‘strongly presumed (SP) as previous sample’ and allocated an item number. Where a material has not been sampled, perhaps due to its inaccessibility and cannot be referenced to a previous sample taken for analysis, but is either strongly presumed based upon the surveyor’s expert knowledge, or presumed (if there is insufficient evidence to suggest the installation is not asbestos) to contain asbestos, then this material shall be noted as ‘strongly presumed’ (SP) or ‘presumed’ (P) and have “Not Sampled” displayed in the laboratory sample number field on the register.

As documented in HSG 264, all inaccessible areas shall be deemed to contain asbestos until can be proven otherwise. Within the limitations of HSG 264, a ‘worst case scenario’ will be given, which is that the area will contain crocidolite. Presumed products known to have never contained crocidolite, e.g. textured coatings, will be presumed to contain their known asbestos type e.g. chrysotile. Presumptions of asbestos type shall also consider the known construction dates of the building, so properties constructed before 1971 will typically be presumed to contain crocidolite. Properties constructed between 1971 and 1985 asbestos grunerite (amosite), and post 1985 building chrysotile only. However, typically, inaccessible areas are likely to contain similar ACMs to those identified within the building.

Building register / material assessment Location A description of the exact location of the asbestos installation on site and its location within a certain area. Product or installation Type of material e.g. boarding, floor tiles, insulation etc. Extent Visual estimate of area (m²), volume (m³), or length (linear metres), of installation. Asbestos types Type of asbestos identified in the material. Samples are analysed in AEC’s UKAS accredited laboratory, and certificates of analysis are located in Appendix III of this report. Condition Condition of the installation, from as new, to badly damaged. Surface treatment This section states whether the material is exposed, painted, or encapsulated. Risk assessment This is gained by adding the ‘scores’ of the previous sections, using the risk algorithm (see table overleaf). Recommendations These are achieved using the risk assessment algorithm, but also known future usage of the premises e.g. if major works are planned. Recommendations are detailed in Section 5.0 of this report. Remedial action & date Column to be used as part of the asbestos management plan. This column should be completed after every inspection, removal, encapsulation, labelling etc.

Material Assessment Algorithm

Variable Score Examples

Installation / Product type 1 Vinyl, ‘Bakelite’, Cement

2 Asbestos insulating board, paper,

rope

3 Pipe insulation, sprayed coating,

friable debris

Condition / damage 0 As new

1 Slight / minor damage

2 Moderate damage - breakage to

surface treatment

3 Major damage - smashed or exposed

material

Surface treatment 0 Non-friable e.g. vinyl

1 Enclosed insulation, encapsulated

AIB

2 Unsealed AIB, encapsulated

insulation

3 Unsealed insulation or sprayed

coating

Asbestos type 1 Chrysotile

2 Asbestos Grunerite (amosite) & other

amphiboles

3 Crocidolite

The scores from each of the four sections are added together to produce a Material risk assessment score:

Risk score Risk assessment

10 or more High risk

7 - 9 Medium risk

5 - 6 Low risk

4 or below Very Low risk

Method of Determination to distinguish Asbestos Insulating Board from Asbestos Cement

In the Building Register and Results (Appendix II) the terminology ‘Board’ is used to represent Asbestos Insulating Board (AIB), ‘Ceiling Tiles’ is used to represent Asbestos Insulating Board Ceiling Tiles, and ‘Cement’ is used to represent Asbestos Cement (AC). Where the Lead Surveyor during a survey on site is unsure whether a suspect asbestos containing material (ACM) is AIB or AC the terminology ‘Cement / Board’ is used and reported in the Building Register and Results (Appendix II) in the installation column. If there is any doubt about the type of asbestos material after the material has been identified that it is a mixture of asbestos and cement, and reported as ‘Cement / Board’ in the Building Register and Results (Appendix II) it is recommended to have the water absorption test of a sample calculated to determine whether the materials is asbestos cement or AIB. Asbestos cement, in a dry state will absorb less than 30% water by weight, and the method is documented in the ACoP L143. Airborne Environmental Consultants perform this service to UKAS accredited standard ISO 17025, for further details on the water absorption method please contact our Laboratory Manager.

APPENDIX III

CERTIFICATE OF BULK FIBRE ANALYSIS

Samples analysed by Scopes Asbestos Analysis Services Ltd. SCO/13/9884A

� � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � �� ! " � # " ! $ % � � � � � ! " � # " & ' ( ) � � " " $ ! $ � � � * + ' , - � � . / 0 1 2 3 2 . 4 5 4 6 7 8 . 4 9 9 4 : ; 6 7 ; 1 <= > ? @ A B C D E F G > H I J K J L K M D E F N O O P E Q Q H N Q A R > S E

T U V U W X Y Z [ \ [ W ] Z X \ ^ Y [ _ X ` Z [ \ [ W ] Z [ ^ ` ^ \ ] a b X a Z ^ a \ [ b Y X ac d e f g h i j k l m n o l p q q p r k l n p s q p t j u c n p v o u t j p t v u t wj x x y f z z i v o k t q { | { c q s q c j s } o vs j l v ~ � j �l j k p ~ j sq v v q �l s � � � q o j g � d � z e z l f � � y h p � � v c n � � � � � � � � jj h h f g h e � g i t q c ~ p k c j u s j p j � q l l f � � y h w � h f � � � � � { � � �v e h f j x x y f z z i � | � j k p v � n l w l n j w v e h f l f � p � � u � | | � �w � h f z � � � d f h � � f g i � � � � { � � � } � � f p � i � n � �w � h f z � � � d f y f � f e � f x i � � � � { � � � p � � � � v � � � d f z i { �w � h f � � j g � d � z e z i � � � � { � � � n � h � e g f x i w q u k r q l q wv � � � d f z � � � � h f y e � d � y f � f y f g � f x � f d � � � � � � f � f f g f � � � e g f x h � x f h f y � e g f h � f � y f z f g � f � � � z � f z h � z � e � y f z � � z e g � v � � � f z j z � f z h � z j g � d � z e z � e g � � � z f � f h � � x � � h y � g z � e h h f x � � � d � y e z f x d e � � h � e � y � z � � � � � g x � f g h y f z h � � x e z � f y z e � g z h � e g e g � � � � z f x � g ~ v q ¡ z ~ v � { � � �k � z � � � d f z � � � f � f f g w q u k r q l q w h � f z e h f � x x y f z z � g x � � h � � d z � � � d f d � � � h e � g e z � z � e � f g � � h � f � d e f g h � h h � f h e � f � � x f d e � f y � � v � � � f z j z � f z h � z j g � d � z e zv f y � e � f z u e � e h f x � y f g � h y f z � � g z e � d f � � y h � f � � � � y � � � � y � � � � f h f g � f � � h � f z � � � d e g � � � h � e y x � � y h e f z � o g x f y h � f z f � e y � � � z h � g � f z v � � � f z j z � f z h � z j g � d � z e zv f y � e � f z u e � e h f x � � g g � h � f � f d x y f z � � g z e � d f � � y h � f e g h f y � y f h � h e � g � � h � f y f z � d h z z � � � g �v c n } q vv j s } u q p � � c u k q p tv j s } u q p � � v � � � d f u � � � h e � g � e � y f t � � f w f h f � h f x� � m n j l w k p � t n s q q t k p � l n n s � j u u v p j w k v{ { m n j l w k p � t n c n l l k w n l � p j w k v� � m n j l w k p � k p t n k u q t � p j w k v� � u k p n t n t n k u q t � p j w k v� � u k p n k p ¢ k t c ~ q p p j w k v� � m n j l w k p � k p n � � k c q p j w k v| | m n j l w k p � k p n � � k c q p j w k v� � t q � t o l q w c n j t k p � t n c n l l k w n l � � j u u v p j w k v� � } j k p t � l n s j m n r q c q k u k p � p j w k v� � � � t q � t o l q w c n j t k p � t n c n l l k w n l � � j u u v p j w k v� � � � m n j l w k p � t n c n l l k w n l � l n n � p j w k v¢ q � i p j w k v £ p � j z � f z h � z w f h f � h f x e g v � � � d fp � h f i j d d z � � � d f z � e d d � f y f h � e g f x � � y � � e g e � � � � � z e � � � g h � z �p � h f i t � e z c f y h e � e � � h f � � y k x f g h e � e � � h e � g � � j z � f z h � z � e � y f z z � � d d g � h � f y f � y � x � � f x f � � f � h e g � � d d � e h � � � h h � f � y e h h f g � � � y � � � d � � h � f u � � � y � h � y � �j � h � � y e z f x z e � g � h � y � ij g � d � z f x � � i c � v j s s n p } y e g h g � � f i ¤ ¥ ¦ § ¨ ¦ © ª « ¬ ¬ ®¥ ¯ § ° ± ± ² ª ³ ´ µ ¶ ² · ª ¸ ¯ ¹ ¯ ¤ ¨ ª ± º ª « ®

v t j p w j l w} l q s k o sq s q l � q p c �

» ¼ ½ ¾ ¿ À Á Â Ã Ä Å ¿ Æ Ç ½ Ã Å È Ä Ã À É Ê ½ Ä É Æ Ë Ã Å Ì È Í Î À À Ï Ð Ì É Ã Ï È Å Î Ä À Ñ Ï È Ä È ¿ Æ Ë Ä Ï Î À É ½ Ì Æ Ñ Ï Ï ¿ Ò Á Á Ó Ô Ó Õ ÁÖ × Ø Ù Ú Ó » Û Ü Ý » Þ Ý Ü ß à Ä Ò Ù Ú Ó » Û Ü Ý » Þ Ý á Û â ã ä Ù Ú Ý Ý Û ß Û Ü ß Ó Ô » å æ â ç è Ø Ù é ê ë ì í î í é ï ð ï ñ ò ó é ï ô ô ï õ ö ñ ò ö ì ÷ø ù ú û ü ý þ ÿ � � � ù � � � � � � � � ÿ � � � � � � � � ü ù � �

� � � � W X Y Z [ \ [ W ] Z X \ ^ Y [ _ X ` Z [ \ [ W ] Z [ ^ ` ^ \ ] a b X a Z ^ a \ [ b Y X ac d e f g h i j k l m n o l p q q p r k l n p s q p t j u c n p v o u t j p t v u t wj x x y f z z i v o k t q { | { c q s q c j s } o vs j l v ~ � j �l j k p ~ j sq v v q �l s � � � q o j g � d � z e z l f � � y h p � � v c n � � � � � � � � jj h h f g h e � g i t q c ~ p k c j u s j p j � q l l f � � y h w � h f � � � � � { � � �v e h f j x x y f z z i � | � j k p v � n l w l n j w v e h f l f � p � � u � | | � �w � h f z � � � d f h � � f g i � � � � { � � � } � � f p � i { n � �w � h f z � � � d f y f � f e � f x i � � � � { � � � p � � � � v � � � d f z i { �w � h f � � j g � d � z e z i � � � � { � � � n � h � e g f x i w q u k r q l q wv � � � d f z � � � � h f y e � d � y f � f y f g � f x � f d � � � � � � f � f f g f � � � e g f x h � x f h f y � e g f h � f � y f z f g � f � � � z � f z h � z � e � y f z � � z e g � v � � � f z j z � f z h � z j g � d � z e z � e g � � � z f � f h � � x � � h y � g z � e h h f x � � � d � y e z f x d e � � h � e � y � z � � � � � g x � f g h y f z h � � x e z � f y z e � g z h � e g e g � � � � z f x � g ~ v q ¡ z ~ v � { � � �k � z � � � d f z � � � f � f f g w q u k r q l q w h � f z e h f � x x y f z z � g x � � h � � d z � � � d f d � � � h e � g e z � z � e � f g � � h � f � d e f g h � h h � f h e � f � � x f d e � f y � � v � � � f z j z � f z h � z j g � d � z e zv f y � e � f z u e � e h f x � y f g � h y f z � � g z e � d f � � y h � f � � � � y � � � � y � � � � f h f g � f � � h � f z � � � d e g � � � h � e y x � � y h e f z � o g x f y h � f z f � e y � � � z h � g � f z v � � � f z j z � f z h � z j g � d � z e zv f y � e � f z u e � e h f x � � g g � h � f � f d x y f z � � g z e � d f � � y h � f e g h f y � y f h � h e � g � � h � f y f z � d h z z � � � g �v c n } q vv j s } u q p � � c u k q p tv j s } u q p � � v � � � d f u � � � h e � g � e � y f t � � f w f h f � h f x� { � { m n j l w k p � t n n � � k c q � l n n � p j w k v� � � � t q � t o l q w c n j t k p � � � � � u n n l n � � k c q � p j w k v� � � � m n j l w k p � t n c q k u k p � � � � � u n n l p j w k v� � � � � � � � u n n l � c n l l k w n l { £ w q m l k v t n c q k u k p � t k u q c ~ l � v n t k u q � c l n c k w n u k t q � j s n v k t q� � � � v k p ¢ } j w p j w k v� | � | t q � t k u q � l j } t n } k } q m n k u q l p j w k v� � � � � j v � q u q c t l k c l n n s � j u u v � u q � t � l q j l � p j w k v� � � � � j v � q u q c t l k c l n n s � j u u � l k � ~ t � p j w k v{ � { � � j v � q u q c t l k c l n n s c q k u k p � p j w k v{ � { � m n j l w k p � t n w n n l j s n v k t q � c ~ l � v n t k u q{ { { { w q m l k v t n u q � t � j u u £ m n k u q l l n n s p j w k v¢ q � i p j w k v £ p � j z � f z h � z w f h f � h f x e g v � � � d fp � h f i j d d z � � � d f z � e d d � f y f h � e g f x � � y � � e g e � � � � � z e � � � g h � z �p � h f i t � e z c f y h e � e � � h f � � y k x f g h e � e � � h e � g � � j z � f z h � z � e � y f z z � � d d g � h � f y f � y � x � � f x f � � f � h e g � � d d � e h � � � h h � f � y e h h f g � � � y � � � d � � h � f u � � � y � h � y � �j � h � � y e z f x z e � g � h � y � ij g � d � z f x � � i c � v j s s n p } y e g h g � � f i ¤ ¥ ¦ § ¨ ¦ © ª « ¬ ¬ ®¥ ¯ § ° ± ± ² ª ³ ´ µ ¶ ² · ª ¸ ¯ ¹ ¯ ¤ ¨ ª ± º ª « ®


» ¼ ½ ¾ ¿ À Á Â Ã Ä Å ¿ Æ Ç ½ Ã Å È Ä Ã À É Ê ½ Ä É Æ Ë Ã Å Ì È Í Î À À Ï Ð Ì É Ã Ï È Å Î Ä À Ñ Ï È Ä È ¿ Æ Ë Ä Ï Î À É ½ Ì Æ Ñ Ï Ï ¿ Ò Á Á Ó Ô Ó Õ ÁÖ × Ø Ù Ú Ó » Û Ü Ý » Þ Ý Ü ß à Ä Ò Ù Ú Ó » Û Ü Ý » Þ Ý á Û â ã ä Ù Ú Ý Ý Û ß Û Ü ß Ó Ô » å æ â ç è Ø Ù é ê ë ì í î í é ï ð ï ñ ò ó é ï ô ô ï õ ö ñ ò ö ì ÷ø ù ú û ü ý þ ÿ � � � ù � � � � � � � � ÿ � � � � � � � � ü ù � �

� � � � W X Y Z [ \ [ W ] Z X \ ^ Y [ _ X ` Z [ \ [ W ] Z [ ^ ` ^ \ ] a b X a Z ^ a \ [ b Y X ac d e f g h i j k l m n o l p q q p r k l n p s q p t j u c n p v o u t j p t v u t wj x x y f z z i v o k t q { | { c q s q c j s } o vs j l v ~ � j �l j k p ~ j sq v v q �l s � � � q o j g � d � z e z l f � � y h p � � v c n � � � � � � � � jj h h f g h e � g i t q c ~ p k c j u s j p j � q l l f � � y h w � h f � � � � � { � � �v e h f j x x y f z z i � | � j k p v � n l w l n j w v e h f l f � p � � u � | | � �w � h f z � � � d f h � � f g i � � � � { � � � } � � f p � i � n � �w � h f z � � � d f y f � f e � f x i � � � � { � � � p � � � � v � � � d f z i { �w � h f � � j g � d � z e z i � � � � { � � � n � h � e g f x i w q u k r q l q wv � � � d f z � � � � h f y e � d � y f � f y f g � f x � f d � � � � � � f � f f g f � � � e g f x h � x f h f y � e g f h � f � y f z f g � f � � � z � f z h � z � e � y f z � � z e g � v � � � f z j z � f z h � z j g � d � z e z � e g � � � z f � f h � � x � � h y � g z � e h h f x � � � d � y e z f x d e � � h � e � y � z � � � � � g x � f g h y f z h � � x e z � f y z e � g z h � e g e g � � � � z f x � g ~ v q ¡ z ~ v � { � � �k � z � � � d f z � � � f � f f g w q u k r q l q w h � f z e h f � x x y f z z � g x � � h � � d z � � � d f d � � � h e � g e z � z � e � f g � � h � f � d e f g h � h h � f h e � f � � x f d e � f y � � v � � � f z j z � f z h � z j g � d � z e zv f y � e � f z u e � e h f x � y f g � h y f z � � g z e � d f � � y h � f � � � � y � � � � y � � � � f h f g � f � � h � f z � � � d e g � � � h � e y x � � y h e f z � o g x f y h � f z f � e y � � � z h � g � f z v � � � f z j z � f z h � z j g � d � z e zv f y � e � f z u e � e h f x � � g g � h � f � f d x y f z � � g z e � d f � � y h � f e g h f y � y f h � h e � g � � h � f y f z � d h z z � � � g �v c n } q vv j s } u q p � � c u k q p tv j s } u q p � � v � � � d f u � � � h e � g � e � y f t � � f w f h f � h f x{ � { � w q m l k v t n l q j l � j u u £ m n k u q l p j w k v{ � { � w q m l k v t n l k � ~ t � j u u £ m n k u q l p j w k v{ � { � w q m l k v t n c q k u k p � £ m n k u q l l n n s p j w k v{ � { � � j v ¢ q t £ m n k u q l l n n s p j w k v{ | { | w q m l k v t n } k } q � n l ¢ p j w k v{ � { � c q s q p t � j v c k j p j w k v{ � { � } j p q u t n } l q £ t j m c j m k p p j w k v¢ q � i p j w k v £ p � j z � f z h � z w f h f � h f x e g v � � � d fp � h f i j d d z � � � d f z � e d d � f y f h � e g f x � � y � � e g e � � � � � z e � � � g h � z �p � h f i t � e z c f y h e � e � � h f � � y k x f g h e � e � � h e � g � � j z � f z h � z � e � y f z z � � d d g � h � f y f � y � x � � f x f � � f � h e g � � d d � e h � � � h h � f � y e h h f g � � � y � � � d � � h � f u � � � y � h � y � �j � h � � y e z f x z e � g � h � y � ij g � d � z f x � � i c � v j s s n p } y e g h g � � f i ¤ ¥ ¦ § ¨ ¦ © ª « ¬ ¬ ®¥ ¯ § ° ± ± ² ª ³ ´ µ ¶ ² · ª ¸ ¯ ¹ ¯ ¤ ¨ ª ± º ª « ®


APPENDIX IV

SURVEY METHODOLOGIES

SURVEY METHODOLOGIES Management surveys

Management surveys are documented in HSG 264 Asbestos: The Survey Guide. Its purpose is to locate, as far as reasonably practicable, the presence and extent of any suspect ACMs in the building which could be damaged or disturbed during normal occupancy, including foreseeable maintenance and installation, and to assess their condition.

Management surveys will often involve minor intrusive work and some disturbance. The extent of intrusion will vary between premises and depend on what is reasonably practicable for individual properties, i.e. it will depend on factors such as the type of building, the nature of construction, accessibility etc. A management survey should include an assessment of the condition of the various ACMs and their ability to release fibres into the air if they are disturbed in some way. This ‘material assessment’ will give a good initial guide to the priority for managing ACMs as it will identify the materials that will most readily release airborne fibres if they are disturbed.

The survey will usually involve sampling and analysis to confirm the presence or absence of ACMs. However a management survey can also involve presuming the presence or absence of asbestos. A management survey can be completed using a combination of sampling ACMs and presuming ACMs or, indeed, just presuming. Any materials presumed to contain asbestos must also have their condition assessed (i.e. a material assessment).

By presuming the presence of asbestos, the need for sampling and analysis can be deferred until a later time (e.g. before any work is carried out). However this approach has implications for the management arrangements. The dutyholder bears potential additional costs of management for some non-ACMs. Any work carried out on ‘presumed’ materials would need to involve appropriate contractors and work methods in compliance with CAR 2012 irrespective of whether the material was actually an ACM or not. Alternatively, before any work starts, sampling and analysis can be undertaken to confirm or refute the presence of asbestos. The results will determine the work methods and contractors to be used. The ‘presumption’ approach has several disadvantages: it is less rigorous, it can lead to constant obstructions and delays before work can start, and it is more difficult to control. ‘Default’ presumptions may also lead to unnecessary removal of non-ACMs and their disposal as asbestos waste. Default presumptions may be suitable in some instances, e.g. ‘small’ or simple premises, as part of a client’s management arrangements.

Surveyors should always endeavour to positively identify ACMs. A sufficient number of samples should be taken to confirm the location and extent of ACMs. It is legitimate to reduce sample numbers where materials can be strongly presumed to be ACMs. However the default presumption option should be avoided where possible, as it can make managing asbestos more difficult for the dutyholder. Default presumption should only be used in circumstances where it is requested by the client and/or where access genuinely cannot be obtained.

When sampling is carried out as part of a management survey, samples from each type of suspect ACM should be collected and analysed. If the material sampled is found to contain asbestos, other similar materials used in the same way in the building can be strongly presumed to contain asbestos. Less homogeneous materials (e.g. different surfaces/coating, evidence of repair etc) will require a greater number of samples. The sample number should be sufficient to establish whether asbestos is present or not in the particular material. Sampling may take place simultaneously with the survey, or as in the case of some larger surveys, can be carried out later as a separate exercise.

All materials sampled and suspected to contain asbestos will not be removed by the survey team to look behind for further suspect materials, as removing asbestos materials may pose a risk to health and breach CAR 2012, such as licensing requirements.

All areas should be accessed and inspected as far as is reasonably practicable. Areas should include underfloor coverings, above false ceilings, and inside risers, service ducts, lift shafts etc such as accessing behind fascia and panels and other surfaces or superficial materials. The extent of intrusion will depend on the degree of disturbance that is or will be necessary for foreseeable maintenance and related activities, including the installation of new equipment/cabling. Surveyors should come prepared to access such areas (i.e. with the correct equipment etc). Management surveys are only likely to involve the use of simple tools such as screwdrivers and chisels. Any areas not accessed must be presumed to contain asbestos. The areas not accessed and presumed to contain asbestos must be clearly stated in the survey report and will have to be managed on this basis i.e. maintenance or other disturbance work should not be carried out in these areas until further checks are made. All ACMs should be identified as far as is reasonably practicable. The areas inspected should include: underfloor coverings, above false ceilings (ceiling voids), lofts, inside risers, service ducts and lift shafts, basements, cellars, underground rooms, undercrofts (this list is not exhaustive). Insulation to pipes and boilers shall be inspected on its outer surfaces and at points where the underlying pipe is visible i.e. valves, flanges etc. AEC shall not remove pipe insulation as part of a management survey and shall not remove any surface coverings such as metal cladding or panels that pipes may be behind.

AEC shall not normally access high-level roofs other than from safe working platforms or edge protected flat roof areas. AEC cannot therefore accept responsibility for asbestos products located on high roofs, which are not easily visible from safe access points. AEC shall not normally access parts of loft voids that are not immediately visible/accessible from safe walkways and will inspect periodically beneath loft insulation.

HSG 264 allows surveyors to presume or strongly presume that visually similar materials are likely to contain or not contain asbestos. In these instances there is the possibility that visually similar rogue items of asbestos containing material may not be identified.

During the survey, the survey team will use their judgement to determine whether it is possible to sample materials without causing damage to the structural integrity of the building. Examples of this may be that sampling of the roofing felt may result in a leak in the roof, or breaking an external under-window panel may result in weather penetration. In such instances either no sample will be taken, and a presumption made, or a much smaller than normal sample will be taken. For small samples the accuracy of the analysis will be reduced. In occupied buildings where samples are required, the survey team will use discretion as to the location and size of samples taken. HSG 264 advises that a sample size of approximately 3 to 5 cm² be taken throughout the entire depth of the suspect installation.

The survey was carried out in accordance with the HSE document HSG 264 Asbestos: The Survey Guide, and AEC’s UKAS accreditation as a Type ‘C’ inspection body (number 232). All sample analysis is carried out in AEC’s UKAS accredited laboratory (testing laboratory 2054).

The survey was carried out by an experienced survey team, who inspect all safely accessible parts of the building, and look for any installation that potentially could contain asbestos. Any suspect materials were sampled and subsequently analysed in accordance with HSG 248 - ‘Asbestos: The analysts’ guide for sampling, analysis and clearance procedures’’. This method identifies the asbestos types.

Samples are taken using low-disturbance techniques, whereby a small amount of material will be taken, after firstly wetting the sample location with a polyvinyl acetate (PVA) solution spray. This minimises the release of asbestos fibres during the process. Air monitoring carried out during sampling work of this type has shown airborne fibre concentrations to stay below the clearance indicator level of 0.01 fibres per millilitre of air.

Sampled materials are immediately placed in sealable, airtight sample bags and appropriately labelled. Sample points will be suitably filled / sealed using PVA spray, ‘Polyfilla’ or adhesive tape.

Where this is likely to cause distress to occupants or major damage to furnishings or fixtures a reduced sample size shall be taken. Textured coatings are non-homogenous materials, i.e. they do not have an even distribution of asbestos throughout and often only have asbestos present in trace levels. AEC shall endeavour to take representative samples of textured coatings but cannot accept responsibility for localised inconsistencies in terms of sampling or analysis for this material.

In buildings where large amounts of items are stored, AEC cannot accept responsibility for any asbestos containing materials hidden/covered by the stored items. The survey shall not include any items contained on the surface of or within the ground beneath or adjacent to the survey area, or items stored inside containers, drawers, cupboards, under false flooring etc within the building/site, unless specifically requested by the customer.

AEC cannot accept responsibility for the identification of any sealed void within structures such as bricked up basement rooms, risers etc. or where there is no evidence to support its presence such as clearly marked drawings.

Management surveys should cover routine and simple maintenance work. However it has to be recognised that where ‘more extensive’ maintenance or repair work is involved, there may not be sufficient information in the management survey and a localised refurbishment survey will be needed. A refurbishment survey will be required for all work which disturbs the fabric of the building in areas where the management survey has not been intrusive. The decision on the need for a refurbishment survey should be made by the dutyholder.

Survey restrictions and caveats

The value and usefulness of the survey can be seriously undermined where either the client or the surveyor imposes restrictions on the survey scope or on the techniques/method used by the surveyor. Information on the location of all ACMs, as far as reasonably practicable, is crucial to the risk assessment and development of the management plan. Any restrictions placed on the survey scope will reduce the extent to which ACMs are located and identified, incur delays and consequently make managing asbestos more complex, expensive and potentially less effective.

In management surveys, surveyors and customers should be properly prepared for accessing all reasonably practicable areas in all parts of the building. Potentially difficult to enter areas (including locked rooms etc) should be identified in the planning stage with the dutyholder and arrangements made for access (e.g. MEWPs for work at height, rooms unlocked, doors/corridors unblocked etc). In situations where there is no entry on the day of the survey, a revisit should be made when access will be possible. Where there are health and safety risks associated with some activities (e.g. height, confined spaces), these should be adequately assessed and arrangements made to control them (see paragraphs 83-91 of HSG 264). Any area not accessed (and where no other information exists) must be presumed to contain asbestos and be managed on that basis.

If any restrictions have to be imposed on the scope or extent of the survey, these items must be agreed by both parties and clearly documented. They should be agreed before work starts (e.g. at the preliminary site meeting and walk-through inspection or during discussion) and are likely to form part of the contract. If during the survey, the surveyor is unable to access any location or area for any reason, the dutyholder must be informed as soon as possible and arrangements made for later access. If access is not possible, then the survey report should clearly identify these areas not accessed. Limitations should be kept to an absolute minimum by ensuring that staff are adequately trained, insured and have the appropriate equipment and tools.

The surveyors do not disturb any suspected asbestos installation in any other way than to take a representative sample. This measure shall minimise the risk of asbestos fibre release, but shall prevent access above/behind a suspected asbestos installation. It is possible, therefore, that further asbestos materials could be present behind an existing asbestos installation.

All relevant sample point data is recorded and shown in the final report e.g. accessibility, condition, extent of material, etc. The pertinent data required to carry out a material risk assessment is recorded and the risk rating for each asbestos installation is given in Appendix II.

The material risk assessment is an assessment of the ability of the identified asbestos installations to release fibres into the air. It is not an assessment of the likelihood of damage to the materials identified. The likelihood of damage or disturbance would be determined by carrying out a priority assessment. In order to achieve this, a thorough understanding of the activities on the site is required and therefore this is a responsibility placed on the duty holder as defined in the Control of Asbestos Regulations 2012.

APPENDIX V

GENERAL RESTRICTIONS

GENERAL RESTRICTIONS AEC have instructed all survey teams that health and safety considerations are paramount during our work. If the survey team find an area where access or sampling will present a risk to themselves or others, they have been given authority to cease works until such time that the risk can be controlled to acceptable levels. This may include accessing confined spaces, work at heights, work near active equipment or processes etc. If such a situation arises, AEC shall inform the customer and explore the possible solutions to the problem. In such instances, AEC will expect the customer to sign to show that the restriction has been agreed.

Areas above fixed office equipment, furniture, process equipment etc. will not be accessed where there is a risk to the survey team. These areas will be subject to a visual assessment only.

Surveying of fixed items of plant, heaters, services or process equipment shall be restricted to easily accessible external elements only. AEC survey teams are not competent to open/dismantle/reassemble such items and will not compromise any fixed guards etc. In such instances presumptions shall be made on the basis of the surveyors observations and experience.

No access was gained to the rear of heater units in properties, where connected. ACMs are typically found behind heater units.

Moving plant shall be excluded from the survey unless specifically requested by the customer. In such cases the safety aspects discussed above shall apply.

Lift shafts shall only be accessed when accompanied by a competent lift engineer who shall be provided by the customer. In the absence of such a lift engineer, the survey team shall demark the lift shaft as presumed to contain asbestos.

Modern man-made mineral fibre (MMMF) insulation to pipework and boiler plant will not typically be removed during management surveys, as this will affect the integrity of the insulation. The survey team, shall always look for evidence of previous removal works and contamination, but will not detect residual contamination beneath new insulation unless this is removed in its entirety.

All materials sampled and suspected to contain asbestos will not be removed by the survey team to look behind for further suspect materials, as removing asbestos materials may pose a risk to health and breach CAR 12, such as licensing requirements.

Samples have not been taken where the act of sampling would endanger the surveyor or affect the integrity of the material concerned e.g. fuse boxes, gaskets, fire doors, rope seals etc.

Samples have not been taken where prohibited by the customer, tenant or their representative, or sampling would cause excessive damage to décor such as tiles, paintwork, carpets or wallpaper.

Material referred to as asbestos insulating board and asbestos cement have been defined by visual appearance of the material in situ.

HSG 264 allows surveyors to presume or strongly presume that visually similar materials are likely to contain or not contain asbestos. In these instances there is the possibility that visually similar rogue items of asbestos containing material may not be identified.

During the survey, the survey team will use their judgement to determine whether it is possible to sample materials without causing damage to the structural integrity of the building. Examples of this may be that sampling of the roofing felt may result in a leak in the roof, or breaking an external under-window panel may result in weather penetration. In such instances either no sample will be taken, and a presumption made, or a much smaller than normal sample will be taken. For small samples the accuracy of the analysis will be reduced.

In occupied buildings where samples are required, the survey team will use discretion as to the location and size of samples taken. HSG 264 advises that a sample size of approximately 3 to 5 cm² be taken throughout the entire depth of the suspect installation. Where this is likely to cause distress to occupants, damage to furnishings or fixtures, or cause excessive fibre release a reduced sample size shall be taken. Samples are only taken sympathetically to the décor of the property. This usually results in small sample sizes. The small sample sizes could lead to discrepancies with certain installations, such as textured coatings, or adhesive to the underside of floor tiles, where a larger sample of the material is usually required to confirm the presence of asbestos.

Textured coatings are non-homogenous materials, i.e. they do not have an even distribution of asbestos throughout and often only have asbestos present in trace levels. AEC shall endeavour to take representative samples of textured coatings but cannot accept responsibility for localised inconsistencies in terms of sampling or analysis for this material. Where decorative textured coatings appear to have been applied at construction, a single positive asbestos sample among several shall be enough to consider all the materials as asbestos-containing.

In buildings where large amounts of items are stored, AEC cannot accept responsibility for any asbestos containing materials hidden/covered by the stored items.

The survey shall not include any items contained on the surface of or within the ground beneath or adjacent to the survey area, or items stored inside containers, drawers, cupboards, under false flooring etc. within the building/site.

AEC cannot accept responsibility for the identification of any sealed void within structures such as bricked up basement rooms, risers etc. where there is no evidence to support its presence such as clearly marked drawings etc.

Please note the information, in part or as a whole contained within this report and all associated liabilities, is not transferable to any third party in any instance.

Management surveys are designed to be carried out in occupied buildings where service connections are live. Access during such surveys is therefore restricted to areas that can be easily reached and do not require destructive access. Consequently sealed voids such as partition wall cavities, voids above plaster-boarded ceilings, sealed boxwork/risers etc. will not be accessed.

It should be noted that the findings of the survey are discussed across the report in its entirety. Readers should note the contents in all sections of the report and should not rely purely on the information given in individual sections of the report.

� �� ! "� �� #$�! � �� !

� ��

%& '()%* '%++ '%(, '-

. ��/0 12 ��30 14 �$50 16 ��#�00 1 7 898:; <=> ?@A BC ?@9 D ?9E= 8F 8:GH 8BIJ ?KL MMNO PQPRS

T UV W First

Flo

or:

Landin

g 2

X YZ [V \] ^] _` aYVbV Wc]Vb Y\def �5 g�

T UV W Base

ment:

Boile

r R

oom

h U[iV Wc] ^i ^[j

" �� k �l� $1l �m�� n� ��o�l� o�$� m� l�00 1

T UV W Exte

rnal

p qrstu vwx qyu wyz {|{z }q~~ux }�

� ��

� ��

� ru v Base

ment:

Gas

& E

lect

ric

Sto

re

�u |{{z {�x su �}�

� ��

� ��

� ru v Base

ment:

Boile

r R

oom

�u |{� quz {s{��u ��{vx�

� ��

� ��

� ru v First

Flo

or:

Kitch

en

� {uzu vw|qut��

� ��

� ��

� ru v Thro

ughout

� q|{¡ �rvtx q�s{~ r� su �rx {t sqq~

��

��

� ru v First

Flo

or:

Loft

Room

¢ rv£ sqq��

� ��

� ��

� ru v First

Flo

or:

Offic

es

3 &

4� {uzu vw|qut��

� ��

� ��

� ru v First

Flo

or:

Offic

e 6


� ��

� ��

� ru v First

Flo

or:

Offic

e 5


� ��

� ��

¤� ¥�� ¦ �� ¥�� §

¨ {�q��{vt �xu qvr}© rªrstu }£ }}{}}�{vx« ��rs¬ ®¯ °±² °³®¯ µ¶ ·¹ ·¶ º»¼ ³³°³³½°¶ ¾ �¿§�� §�

À ·º¶ ·

ÁÂ °Ã °Ä

� ��

� ru v Thro

ughout

�u |{Årzz �q�vx {ty {rx {s�vux }�

� ��

� ��

� ru v Lift

and lift

shaft

��

��

� ru v Lift

moto

r ro

om

��

��

� ru v First

Flo

or:

Serv

er

Room


� ��

� ��

ÆÇ ÈÉÈÊËÈÊÉÇ ÊÌÈÍÎÏÐ ÈÈÍÊÑÑÈÉ

ÉÈÒÓ ÉÔËÌÈÕÈÒ

Ö × Ø Ù × Ú Û × Ü Ý Þ Ý ß Ù à Ù Þ Ú á â Û ã Ù ä å â Ù × æ Ù Þ Ú â Ý ç è é ê é × é Û Þë ì í î ï ð ï ñ ð ò ï ó ô ì ñ ë ì í î õ ñ ö ÷ õ ð ï ø ù ú ñ ï û

Ö × Ø Ù × Ú Û × Ü Ý Þ Ý ß Ù à Ù Þ Ú á â Û ã Ù ä å â Ù × æ Ù Þ Ú â Ý ç è é ê é × é Û Þü ý þ ÿ ý � � ý � � ý � ü ý ý ÿ ý ý � ÿ � � � � ÿ � � ÿ � ÿ � ÿ � � � � � � ý� � � � � � � � � � � � � � � � � � ÿ � ÿ � � � � � � ý� ì ó � ï � ð ó õ � ð ï û � ó ì í õ ô � ï ô ð ì ô ó ï ú ù ô ð ï ó � �� ì ó � õ � � ì � õ ð ï û ð ì � �

��

� ï � ù ï � ÷ õ ð ï û � �� ð ï í ÷ ï ô � ó ù î ð ù ì ñ ì � � ì ó � ð ï í ! ñ � ù ó ì ñ í ï ñ ð õ �" ì ñ ù ð ì ó ù ñ ú ÷ õ ð ïò � õ ñ ñ ï û ÷ õ ð ïë ì í î � ï ð ï û ø ù ú ñ ï û õ ôë ì í î � ï ð ï

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

F I F C : 5 ; 7 9 N 6 B F I B E 9 K I 6 B 2 6 7 8 9 : - ;< ; 7 = 43 ; I E 9 B 6 7 L 5 6 : 5 6 7 F I F B B 9 : 9 ; I 2 6 7 8 9 : - ;< ; 7 = 8 F J M 6 7 6 T C 9 7 6 B U E C A 5 F E G ; 7 . ; :< ; 7 = E U < ; 7 = 9 I K $ : . 6 9 K 5 : F I B3 ; I G 9 I 6 B 1 @ F A 6 E 4/ I E C 7 6 : 5 6 @ 6 7 E ; I > E ? F C : 5 ; 7 9 E 6 B : ;9 E E C 6 F I B A F I A 6 H : 5 6 2 6 7 8 9 : - ; < ; 7 =F 7 6 A ; 8 @ 6 : 6 I : 4/ E : F M H 9 E 5 A H 6 F 7 H 9 8 9 : F : 9 ; I E U 7 6 K F 7 B 9 I K : 5 6E A ; @ 6 U : 9 8 6 G 7 F 8 6 F I B @ 7 ; A 6 B C 7 6 G ; 7M 7 6 F A 5 ; G @ 6 7 8 9 : A ; I B 9 : 9 ; I E 4/ I E C 7 6 : 5 6 A ; I : 7 F A : ; 7 @ 7 ; D 9 B 6 E E C 9 : F M H 6F I B E C G G 9 A 9 6 I : 7 9 E = F E E 6 E E 8 6 I : E F I B8 6 : 5 ; B E : F : 6 8 6 I : E G ; 7 F H H : 5 6 5 F N F 7 B EH 9 = 6 H J : ; 9 I R C 7 6 ; 7 5 F 7 8 : 5 6 5 6 F H : 5 ; GE : F G G ; 7 ; : 5 6 7 @ 6 7 E ; I E U : ; 9 I A H C B 6 : 5 6F B B 9 : 9 ; I F H @ 6 7 8 9 : E ; C : H 9 I 6 B F M ; D 6 4. F E : 5 6 A ; I : 7 F A : ; 7 7 6 A 6 9 D 6 B F @ @ 7 ; @ 7 9 F : 69 I B C A : 9 ; I : 7 F 9 I 9 I K U 9 I G ; 7 8 F : 9 ; I F I B9 I E : 7 C A : 9 ; I ; I : 5 6 7 6 T C 9 7 6 8 6 I : E ; G : 5 9 E2 6 7 8 9 : - ; < ; 7 = 9 I A H C B 9 I K : 5 66 8 6 7 K 6 I A J @ 7 ; A 6 B C 7 6 G ; 7 B 9 E A ; D 6 7 9 I KB F 8 F K 6 B ; 7 B 9 E : C 7 M 6 B $ 3 0 E 43 5 6 A = : 5 6 A ; I : 7 F A : ; 7 5 F E @ 7 ; D 9 B 6 BF E M 6 E : ; E F L F 7 6 I 6 E E : 7 F 9 I 9 I K G ; 7 : 5 6 9 7E : F G G 4/ I E C 7 6 : 5 6 3 ; I : 7 F A : ; 7 5 F E E 9 K I 6 B : 5 6$ A A 6 @ : F I A 6 F I B 3 H 6 F 7 F I A 6 A ; I B 9 : 9 ; I E9 8 @ H 9 A 9 : 9 I : 5 6 2 6 7 8 9 : - ; < ; 7 = 4/ I E C 7 6 : 5 6 A ; I : 7 F A : ; 7 9 E 9 E E C 6 B L 9 : 5 F3 ; I : 7 F A : ; 7 E 2 F E E F I B 5 F E E 9 K I 6 B : 5 62 F E E U 3 ; I : 7 F A : ; 7 E $ C : 5 ; 7 9 E F : 9 ; I : ;< ; 7 = U & B 6 I : 9 G 9 A F : 9 ; I F I B + 9 7 6 , 6 K 9 E : 6 7 40 ; I 9 : ; 7 : 5 6 L ; 7 = E 9 I @ 7 ; K 7 6 E E 4/ I E C 7 6 a formal �hand back� and A F I A 6 H H F : 9 ; I @ 7 ; A 6 B C 7 6 : ; 6 I E C 7 6 : 5 F :E : F G G F I B ; : 5 6 7 E U M C 9 H B 9 I K U @ H F I : F I B6 T C 9 @ 8 6 I : F 7 6 E F G 6 M 6 G ; 7 6 7 6 V

; A A C @ F I A J ; 7 A ; 8 8 6 I A 6 8 6 I : ; GI ; 7 8 F H L ; 7 = 4< 5 ; 9 E F C : 5 ; 7 9 N 6 B : ; 9 E E C 6 : 5 9 E @ 6 7 8 9 : O+ ; 7 : 5 6 @ C 7 @ ; E 6 ; G : 5 9 E 2 6 7 8 9 : - ; < ; 7 = U: 5 6 A ; 8 @ 6 : 6 I : @ 6 7 E ; I 9 E P& E B 6 6 8 6 B : ; M 6 : 5 6 2 7 6 8 9 E 6 E 0 F I F K 6 7; 7 @ 6 7 E ; I > E ? F A : 9 I K ; I : 5 6 9 7 M 6 5 F H G Q0 C E : 5 F D 6 E C G G 9 A 9 6 I : 6 S @ 6 7 9 6 I A 6 ; 7= I ; L H 6 B K 6 ; 7 5 F D 6 C I B 6 7 : F = 6 I : 7 F 9 I 9 I K9 I : 5 6 C E 6 ; G 2 6 7 8 9 : - ; < ; 7 = 1 J E : 6 8 E 4< 5 F : : ; B ; 9 G J ; C B 9 E A ; D 6 7 U B F 8 F K 6 B; 7 B 9 E : C 7 M 6 B F E M 6 E : ; E A ; I : F 9 I 9 I K8 F : 6 7 9 F H E O& I : 5 6 6 D 6 I : ; G B F 8 F K 6 B U B 9 E : C 7 M 6 B ; 7@ 7 6 E C 8 6 B $ 3 0 E : 5 6 $ E M 6 E : ; E

0 F I F K 6 8 6 I : - 6 F 8 ; 7 W X 5 7 / 8 6 7 K 6 I A J. ; : % 9 I 6 E 5 ; C H B M 6 A ; I : F A : 6 B M J : 5 6T C 9 A = 6 E : @ 7 F A : 9 A F M H 6 8 6 F I E 4$ E M 6 E : ; E 0 F I F K 6 8 6 I : - 6 F 8 P> ( G G 9 A 6 . ; C 7 E ? Y W Y Z [ W \ ] W W W ^ ] W W ]W X 5 7 / 8 6 7 K 6 I A J . ; : % 9 I 6 PY W Y Z X _ ] \ Y Y Y, 6 G 6 7 : ; : 5 6 + 7 F 8 6 L ; 7 = G ; 7 0 F I F K 9 I K. 6 F H : 5 F I B 1 F G 6 : J F I B % ; A F H 3 ; B 6 ; G2 7 F A : 9 A 6 G ; 7 G C 7 : 5 6 7 K C 9 B F I A 6 P$ A A 9 B 6 I : ^ & I A 9 B 6 I : , 6 @ ; 7 : 9 I K F I B& I D 6 E : 9 K F : 9 ; I P G ; 7 8 2 1 Z Y ` X , 6 D Y \ QF I B3 ; I : 7 F A : ; 7 E a C 9 B F I A 6 G ; 7 0 F I F K 6 7 EF I B 1 : F G G 4

b c d e f g h d i j g k l m n c k n c o p n q e j e n f r b c d e f j g k g h n o m e j ls h d n o o g l m n k t e o n o p n q e j e n f ru v w x y z { | }~ v � z y | � � � | w � � v z � y � �� | � � v z � y � �� | � � | � � z y | �~ z � � � | w � | � z w � � z | w � � x v� | � z w � � z | w�s Company~ v � z y | � � � � � � v | � z � v u v w x y z � | � | w � � � ~ { �� v � | � � | � � | � v � z � v w v � � y w v x v � z � | � z � v � v � � z � � � � � � � v z � � | z v � | � z � v � w | � z � � � � � � �| � z � y � u v w x y z � | � | w � � | w � | w � { v � w � � � v � z | � � | � z � y � y � � � � z v w y � � � �� z � v � | � z w � � z | w w v � v y � v � � � � w | � w y � z v y � � � � z y | � z w � y � y � � � y � � | w x � z y | � � � � y � � z w � � z y | � | �z � v w v � � y w v x v � z � | � z � y � u v w x y z � | � | w � y � � � � � y � � z � v v x v w � v � � � � w | � v � � w v � | w� y � � | � v w y � � � � x � � v � | w � y � z � w � v � � � � v � z | � � | � z � y � y � � x � z v w y � � � �� z � v � | � z w � � z | w � w | � y � v � � � � y z � � � v � � � � � � � y � y v � z � � � v � � x v � z | � z � v w y � � � � | w � � �� w � � � y � v � � z | y � ¡ � w v | w � � w x z � v � v � � z � | � � z � � � | w | z � v w � v w � | � � � � � � w | � v w z � �{ | � | w � x � � z � v � � � v w z � � v � | � � � | � � | w � w v � � x v � � � � v � z | � � | � z � y � y � � � � z v w y � � �� z � v u w v x y � v � � � � � � v w | w � v w � | � y � � � � w � v � v � � � w v � � | | z � v w � | w � z � � � z � � z � z � z v � � � | � v � y � � � v� � w w y v � | � z } � � � � � x � � z y � � y v � � y z � � � � z � v � w v � � � z y | � � w � x v � � � w v � y � v � z y � y v � y � z � v w y � � � � � v � � x v � z �� x v z � | � � z � z v x v � z � � w | � y � v � � � z � v � | � z w � � z | w }{ � x v | � u w v x y � v � � � � � � v w | w � v w � | � y � � � � w � v ¢� | � z y z � v ¢ ~ z � w z � y x v £ � � z v ¤ y � y � � � y x v £ � � z v~ v � z y | � ¥ � � � v � z � � � v | � z � v u v w x y z � | � | w �� z � v � | � z w � � z | w | w � v w � | � y � � � � w � v � v � � � w v � � | | z � v w � | w � z � � � z � � z � z � z v � � � | � v � y � � � v � � w w y v � | � z }� � � z � � z � � � � v w v � � � � � � � � v w � z | | � z � v � v � � z � � � � � � � v z � � | z v � | � � | z � z � v � w | � z � � � w v � v w � v | � z � y �u v w x y z � | � | w � }{ � x v | � � | � z w � � z | w | w � v w � | � y � � � � w � v ¢� | � z y z � v ¢ ~ z � w z � y x v £ � � z v ~ z � w z � y x v £ � � z v~ v � z y | � ¦ � � v � w � � � v� z � v � | � z w � � z | w | w � v w � | � y � � � � w � v � v � � � w v � z � v � | w � � � � v w z � � v � � � � v � v v � � | x � � v z v � � � � v � � v � � �x � � v � � � � � z � v � w v � � v � z y � � � � � v � � � z y � � � | � � y z y | � }{ � x v | � � | � z w � � z | w � w v � � | � � y � � v � v w � | � § � y � � � � x v ¨ ¢� | � z y z � v ¢ � � z v ¢ � y x v ¢~ v � z y | � © � � � � v � � � z y | �� z � v u w v x y � v � � � � � � v w | w � v w � | � y � � � � w � v � v � � � w v � z � v � | w � � � � v w z � � v � � � � v � v v � � | x � � v z v � }� � v � � v � � � x � � v � � � � � z � v � w v � � v � z y � � � � � v � � � z y � � � | � � y z y | � } � � � ~ u � ª � � � � ~ { � � � � { � � « « � � }{ � x v | � u w v x y � v � � � � � � v w | w w v � � | � � y � � v � v w � | � § � y � � � � x v ¨ ¢� | � z y z � v ¢ � � z v ¢ � y x v ¢~ v � z y | � ¬ � � � z z | � | y � � | � � y � � | � v w � � x � � v � � � y � z � w � v � | w � w v � � x v � � � � �� ~ z | � � � � � | w � y � z � v � w v � }� ª v x | � v � � � � v v � � � � � v w � | � � | � z | � z � v � w v � }¥ � � | � v | w � v � � | w � | � � | � � z � v � w v � � � v w v � w � � z y � � � � v }¦ � | � | z w v x | � v v � � y � x v � z | w x � z v w y � � � }© u w | x y � v � z � � � y � � � � � � � � w � y � � � y � � § � ¨ ¢ u | z v � z y � � � � � v � z | � � � � w � v v � � � z }¬ ª v � | w z z � v y � � y � v � z y x x v � y � z v � � z | z � v u w v x y � v � � � � � � v w | w � v w � | � y � � � � w � v }® ¯ ° ± ² ³ ´ ² µ ¶ ² · ¸ ¹ ¸ º ´ » ´ ¹ µ ¼ ´ ¸ » ½ � � � y � v � | � w � ½ ¾ � ¾ ¿ © � ¥ ¬ � � � £ ¬ � � ¬ | w� ¦ � w � x v w � v � � � � | z « y � v ¾ � ¾ ¿ ¦ À ¬ ¥ ¾ ¾ ¾ £ ¿ ¾ © ¦ £ ¿ ¾ ¬ �

0 F I F K 6 7 E 8 C E : 9 I G ; 7 8 : 5 6 $ E M 6 E : ; E 0 F I F K 6 8 6 I : - 6 F 8 ; 7 W X 5 ; C 7 . ; : % 9 I 6 ; G F H H9 I A 9 B 6 I : E 9 I D ; H D 9 I K F E M 6 E : ; E M J : 5 6 T C 9 A = 6 E : @ 7 F A : 9 A F M H 6 8 6 F I E 4 . F D 9 I K 8 F B 6 : 5 69 I 9 : 9 F H @ 5 ; I 6 A F H H B 6 : F 9 H 9 I K : 5 6 I F : C 7 6 ; G : 5 6 9 I A 9 B 6 I : U 8 F I F K 6 7 E 8 C E : G ; 7 L F 7 B : 5 6A ; 8 @ H 6 : 6 B $ E M 6 E : ; E & I A 9 B 6 I : G ; 7 8 : ; : 5 6 G ; H H ; L 9 I K P� � � v � z | � � � � � � v x v � z � v � x � | w § � � � y � v � | � w � ¨ ¾ � ¾ ¿ © � ¥ ¬ � � � £ ¬ � � ¬' F 7 7 J H 4 - F J H ; 7 Á I @ E 4 A ; 4 C =� ¦ � | � w � x v w � v � � � � | z « y � v ¾ � ¾ ¿ ¦ À ¬ ¥ ¾ ¾ ¾ £ ¿ ¾ © ¦ £ ¿ ¾ ¬ �� y w v � z | w � z v � v � � | � ~ v w � y � v � � � � � w | � w y � z v� v � � z � Â ~ � � v z � � v � x � v � � z � � � � � � � v z � Ã � � � z � � x � | w v � z } � | � } � �� addition, managers must complete and forward the Council�s Accident and Incident report form � � � y � � � � v � z Ä µ µ Å ½ Æ Æ Ç ¶ ° ´ ² µ ¹ ´ µ È É ³ Ê Ç È º ¶ Ë È Ì Í Æ Î ¹ Ï ´ Ð Æ Ñ ¶ ° Ò Ä ´ ¸ É µ Ä Æ Ä ² Ò Ç ¶ ° » ² È Ä µ » � y z � y � © � | w � y � � � � � � z | z � v� v � � z � Â ~ � � v z � � v � x � � � � � w � � � v � � � ª y � � � � � � � v x v � z Ó � y z � � � � w � � v Ó � y | � � v � � z � � � � ~ � � v z �� | � � v � v w }� � � v � z | � � � � y � v � z � | � z � � z � v z � y � � ¢� y w v � z | w � z v~ v w � y � v� v � � w z x v � z | w Ó � y z« | � � z y | � | � y � � y � v � z� � z v | � y � � y � v � z� y x v | � y � � y � v � zu � | � v { |{ � x v | � � v w � | � y � � | � z w | � | � � w v x y � v �� v � z | � ª v � y � z v w w v � v w v � � v y � � � | � �{ � x v � � � z y z � v | � � v w � | � w v � | w z y � � y � � y � v � z� � � v � z | � � � � � � v x v � z � v � x | w � ¦ � | � w � x v w � v � � � � | z « y � v � | � z � � z � v z � y � � ¢{ � x v � � � z y z � v | � � v w � | � y � � y � v � z w v � | w z v � z |� � z v y � � y � v � z w v � | w z v �� y x v y � � y � v � z w v � | w z v �u � v � � v � y � v � � � � � � � � � � � � w � z v � � � | � � z | � z � v y � � y � v � z ¢

u � v � � v � w | � y � v z � v � � x v � | � � z � � � | w | z � v w � v w � | � � y � � | � � v � y � z � v y � � y � v � z ¢

Ö × Ø Ù × Ú Û × Ü Ý Þ Ý ß Ù à Ù Þ Ú á â Û ã Ù ä å â Ù × æ Ù Þ Ú â Ý ç è é ê é × é Û ÞÔ � ÿ � Õ ÿ ý Ö � � × � � � � � Ø Ù � ÿ � ÿ � � Õ � � ÿÚ ÿ ÿ � Ú ÿ ÿ �Û � Ü � � � ÿ � � ýÝ ü ý þ ÿ ý � � ý � � � � � ÿ � ÿ � � Þ � � Ö ÿ ß � ÿ ý× � ÿ ý ÿ � � � � Ø ß � � � Ø � � � ÿ � ß �à ü × × � � × � � � � ÿ Õ ß � � á � � ÿ � Ô ÿ � � � Ø � ÿ â ü × × � � × � � � � ÿ � ÿ ý × � � ý � þ � ÿ Þ ÿ � ý � �Ô ÿ � � � Ø � ÿ ã ä � � � � � � � � ÿ ÿ ý � Ø � � å � � ß ý ÿ ý � � Ø Ø � ÿ � � � Ø � ÿ æ� � � � � � ÿ � � � � � ÿ � ÿ çè é � � � × × � � Ö � þ � ÿ � � ÿ ê � ÿ � � � � � � ÿ � Ö � ÿ ý ë ìí ü ý þ ÿ ý � � ý � � � � � ÿ � ÿ � � Þ � � � � � × � � Ö ÿ � � ý � � � ÿ � Ø Ø ëî ü ý þ ÿ ý � � ý � ÿ � � ý � ÿ � � � × � � Ö ÿ � � ß × � � ÿ ï ü ý þ ÿ ý � � ý � ÿ å � � ý × ÿ Ö � � � � × � ÿ ý ÿ � � � � � � ÿ ý× � � � � ÿ ð � ÿ � ÿ � � � � � � ý è � Ø � � � ì Ö � � × � ÿ � ÿ � �× � � � � ÿ � � � Ø ß � � Ö � � � � � � ÿ � � � � × � � Ö ÿ ÿ ëñ � � � � � � � � ÿ � � ÿ

�ý × � ÿ ý ÿ � � � � � � ÿ ý× � � � � ÿ ëÝ ò ü � � ß � � � ß � � Ö � � × � ÿ � ÿ � � Ø � � ÿ ë

Version Date Author

001 September 2013 A. Ferdinand-Sergeant

ó ô õ ö ÷ ô ø ù ú û ü ý ö þ ú ÿ � � � õ � � õ õ ü � � ü � ö � � ü õ � ø ô � ô � ü ö ÷ ü û � ý � ý û ü ý ü � ö ü � � � ý � ü ý ö ú ý ô � ô ý � ü ý ö ú ý � ú � ö ô � � � � � ø ô ö ü û � ô õ ý � � þ � ý � � � ô õ õ ó ô õ ö ÷ ô ø ù ú û ü ý ö þ ú ÿ � � � õ � ÿ � õ � � � ý � � ÷ � ý ú õ � � � ý ÷ ú ÿ õ � ü û ü ô � �� ! " � ö ú ý � ô � ô � ü ø ü � ö # õ ô � ý �ó ô õ ö ÷ ô ø ù ú û ü ý ö þ ú ÿ � � � õ ô � ø ý ö ú $·

# û ü � ü � ö % ú û û ü ÿ � ü ö ú ö ÷ ü õ ú � ü ý ö õ ü � ü õ û ô � ö � � ô � õ ü % ö ÷ ü û � ý � ý � û ú ø ô ý � ü ý ö ú ý ö ú ô õ õ ü ø õ ú � ü ü ý ô � ÿ ý ü û ý ú � ú ÿ û � ÿ � õ � � � ý � ÷ ü ö ÷ ü û � ú û � � � � % ú � � ÿ � � � � ú û � � ý � ö � � � ó ô õ ö ÷ ô ø ù ú û ü ý ö þ ú ÿ � � � õ û ü ø � ý ü ý �·

þ ú ø õ � � � ö ÷ ô õ õ ý ö ô ö ÿ ö ú û � û ú � � ý � ú � ý û ü õ ô ö � � � ö ú ö ÷ ü ø ô � ô � ü ø ü � ö ú � ô ý � ü ý ö ú ý ø ô ö ü û � ô õ ý ý ú � ô û ô ý� ý û ü ô ý ú � ô � õ � û ô � ö � � ô � õ ü �· & ø õ ü ø ü � ö ü � � ü � ö � � ü ô ý � ü ý ö ú ý ø ô � ô � ü ø ü � ö û ú � ü ÿ û ü ý � � � ú ø õ � ô � � ü � � ö ÷ ' ( ) � ÿ � ô � � ü % �þ ú ø û ü ÷ ü � ý � � ü * ÿ � ü ö ú � ô � ô � � � � � ý � ü ý ö ú ý � � # û ü ø � ý ü ý � ' ( * + + , � �· - ü ô � ü � � õ ô � ü ô õ õ � þ � ý � ÷ � � ÷ ô û ü � � � ú ú � ú � � ö � ú � % ý ü ô õ ü ô � . ú û û ü ô � û ü % ô � � ÷ � � ÷ ô û üÿ � õ � � ü õ � ö ú � ü � ý ö ÿ û � ü � � õ � � ü � � ö ÷ ö ÷ ü ô � ú � ü � ÿ � ô � � ü �· & ü � ö � � � ô � û ü � ú û % ý ú � ô û ô ý � ý û ü ô ý ú � ô � õ � û ô � ö � � ô � õ ü % ö ÷ ü õ ú � ô ö � ú � % ü / ö ü � ö ô � � ú � � ö � ú � ú �� þ � ý û ü ý ü � ö � � ö ÷ ü � ÿ � õ � � � ý � ú û � ÷ � � ÷ ó ô õ ö ÷ ô ø ù ú û ü ý ö þ ú ÿ � � � õ � ý û ü ý ú � ý � � õ ü �· 0 ü � ÿ õ ô û õ � ø ú � � ö ú û ô � � � ý ü � ö � ü � ö � � � ü � þ � ý ö ú ô ý ý ü ý ý ö ÷ ü û � ý � ý ô � ö ú ÿ ý ü ö ÷ ü ý ü ô ý ý ü ý ý ø ü � ö ýö ú û � ú û � ö � ý ü û ü ø ü � ô õ ô � ö � ú � � ÷ ü û ü � ü � ü ý ý ô û � �·

) � ý ÿ û ü ö ÷ ô ö ô � � � ú û � ý � � ö ÷ ö ÷ ü ú ö ü � ö � ô õ ö ú � ý ö ÿ û � ô ý � ü ý ö ú ý ø ô ö ü û � ô õ ý � � ô õ õ û ü ø � ý ü ý � ú û � ÷ � � ÷ó ô õ ö ÷ ô ø ù ú û ü ý ö þ ú ÿ � � � õ � ý û ü ý ú � ý � � õ ü % ô û ü ÿ � ü û ö ô � ü � � � ö ÷ ö ÷ ü ô û ú � ô õ ú � ö ÷ ü þ ú ø õ � ô � � ü� ü ô ø ô � ö ÷ ü # û ú � û ô ø ø ü 1 # û ú 2 ü � ö ý � ü ô ø � � ö ÷ ü ) � � � û ú � ø ü � ö 1 0 ü � ü � ü û ô ö � ú � � û ü � ö ú û ô ö ü %� ü ü � � � ô õ õ � � ö ü û ü ý ö ü ô û ö � ü ý ÿ ô ö ü � � � õ ÿ � � � ö ÷ ü � û ô ü 3 � � ú � ý �·

) � ý ÿ û ü ö ÷ ô ö ô õ õ � ú û � ý ô � ý ÿ û � ü � ý � � ö ÷ ö ÷ ü ú ö ü � ö � ô õ ö ú � ý ö ÿ û � ô ý � ü ý ö ú ý ø ô ö ü û � ô õ ý ô û ü � ô û û � ü ú ÿ ö � � � ú ø ü ö ü � ö � ú � ö û ô � ö ú û ý �·

# û ú � � ü ô ý ý ÿ û ô � � ü ú � ö ÷ ü ü � � ü � ö � � ü ø ô � ô � ü ø ü � ö ú � � ý � ü ý ö ú ý ô � � þ � ý � � û ü ú û ö � � � ú � ö ÷ ü û ú � û ü ý ý ú � ý ÿ û � ü � ý % û � ý � ô ý ý ü ý ý ø ü � ö ý ô � � ú û � ý û ü õ ô ö � � � ö ú ô ý � ü ý ö ú ý ö ú ö ÷ ü þ ú û ú û ô ö ü ' ü ô õ ö ÷ 1( ô � ü ö � þ ú ø ø � ö ö ü ü �·

# û ú � � ü � � � ú û ø ô ö � ú � û ü õ ô ö � � � ö ú ö ÷ ü õ ú � ô ö � ú � ú � ô ý � ü ý ö ú ý ø ô ö ü û � ô õ ý ö ú ý ö ô � � ú � � ÿ � � � � ó ô õ ö ÷ ô øù ú û ü ý ö � ÿ � õ � � � ý % � � � õ ÿ � � � � ú � ö û ô � ö ú û ý ô � ô � � ú ö ÷ ü û ü û ý ú � � ÷ ú ø ô � � ý ö ÿ û � ô ý � ü ý ö ú ýø ô ö ü û � ô õ ý �·

# û ú � � ü ô û ú û � ô ö ü ö û ô � � � � � � ú û ö ÷ ú ý ü ý ö ô � � � � � ú õ � ü � � ö ÷ ø ú � � ö ú û � � � ú û ø ô � ô � � � � ô ý � ü ý ö ú ý �( � � � ü $ 4 ô ö ü $ 5 6 7 8 9 � ö ú � ü û + : 5 ;� ô û ö � � ) ý ú ø < þ ÷ � ü � ) / ü � ÿ ö � � ü

!

!

!

!

Planning Statement · 1.2 The proposed building will provide 45 self-contained one-bedroom dwelling...

Documents

Transcript of Planning Statement · 1.2 The proposed building will provide 45 self-contained one-bedroom dwelling...