Site Location Map

Application Summary

Location Land Bounded By Barrhill Road, Blairderry Road And Ardwell Road London

Ward Streatham Hill

Proposal Application

Redevelopment of the site involving demolition of the existing buildings and the construction of a building of 3 - 6 storeys in height (plus basement) to provide 69 residential units and 272m² of commercial floorspace (Use Class A1, A2, B1 and/or D1), underground parking for 20 spaces with access onto Blairderry Road, associated landscaping and servicing.

Applicant Mr Matthew Arnold The Oakwood Group

Date valid 20 May 2011

Case Officer Mr David Smith

Application Reference

11/01568/FUL

Recommendation(s) A) Advise the Planning Inspectorate that the Local Planning Authority would have refused planning permission for the reasons set out herein; thereafter those reasons would form the basis for the Local Planning Authority’s Statement of Case for the impending Public Inquiry. B) That officers are granted delegated powers to negotiate further with the applicant and respond to any submissions as officers deem appropriate, both in the lead up to and during the Public Inquiry.

Constraints

Advert Publication Date

10th June 2011

Site Notice posted on

10th June 2011

Officer Report 11/01568/FUL INTRODUCTION Officers are reporting this application to PAC because of the Committee’s resolution to refuse a similar application in April 2009. It should be noted that an appeal has been lodged against the Council’s failure to determine the current application within the statutory 13 week period. If the Committee are minded to resist the granting of planning permission at the forthcoming Public Inquiry the reasons for this will form the basis of the council’s case. 1. SUMMARY OF ISSUES 1.1 The main issues pertaining to this application are as follows:

• The principle of redevelopment of the site for a residential led mixed use scheme;

• Whether the development would provide an appropriate mix (sizes and tenures) and quality of residential accommodation for future occupants of the development;

• The impact of the development upon the character, appearance and setting of the surrounding townscape, including the adjacent conservation area and listed building;

• The impact of the development upon the amenity of surrounding occupiers;

• The impacts of the development upon the function and safety of the surrounding highway network;

• Whether the development has paid sufficient regard to sustainable design and construction and to reducing carbon emissions;

• Whether the development would incorporate sufficient measures to reduce the opportunity for crime; and

• The impact of the development upon local infrastructure. 2. SITE DESCRIPTION 2.1 The site fronts and sits to the east of Blairderry Road, with sections fronting the

returns on Barrhill Road to the north and Ardwell Road to the south. 2.2 The northern section of the site is occupied by 1 Barrhill Road, a single storey

warehouse (B8 Use class) unit which fronts the highway. The south of the site is occupied by a single storey building containing warehouses and offices (B1 and B8 Use Classes) which front the highway. The central section of the site contains a hard surfaced area used as parking, with access onto Ardwell Road close to its junction with Blairderry Road.

2.3 Both buildings on the site are set back from Blairderry Road by approximately 3-

7m behind a concrete wall which fronts the road. The concrete wall is separated by a further low slung single storey building which fronts Blairderry Road.

2.4 Surrounding area 2.5 Immediately to the north-east of the site sits 1-15 Barrhill Rd, a four storey block of

12 residential units fronting Barrhill Road. To the south-east is a building containing a MOT testing premises (Use Class Sui Generis) that fronts Ardwell Road. To the east of the site is a service alley for the shops and flats that front Streatham Hill.

2.6 Streatham Hill, the A23 (Streatham High Road as it becomes known to the south)

runs from north to south, and lies to the east of the site. The road comprises mainly commercial and purpose built residential blocks of a variety of sizes and heights. The A23 is the main arterial road connecting London to the South Coast. To the east sits the Leigham Court Estate Conservation Area that consists of terraces leading off the High Road, forming a grid pattern of three storey residential properties.

2.7 The site lies immediately to the east of the Streatham High Road and Streatham

Hill linear Conservation Area. 2.8 Immediately to the north of the site across Barrhill Road sits a former theatre now

being used as a Bingo Venue. This is a Grade II listed building within the Streatham High Road and Streatham Hill Conservation area. The building is a substantial structure of five to six storeys in height that occupies the full depth of the plot and backs onto Blairderry Road.

2.9 To the west of the site is predominately two-storey detached and semi-detached

suburban development. Blairderry Road forms the western boundary of the site, behind which runs Killieser Avenue which sits in the Telford Park Conservation Area.

2.10 To the south of the site across Ardwell Road lies the Megabowl; four storeys where

it fronts Streatham Hill with return elevations similar in scale and a flytower at the rear (approximately 25m in height) set back from Ardwell Road and Blairderry Road. This site has an extant planning permission for a Major mixed use redevelopment containing flats and retail, in a series of new buildings ranging from 2-8 storeys in height (see planning history).

2.11 The site has a PTAL rating of 6a. Streatham Hill overland railway station lies

approximately 200m to the south, while the Streatham High Road has a range of bus services to central London and other regional centres.

2.12 The site lies within the Streatham Major Town Centre area. 3. PLANNING HISTORY 3.1 There are various records of planning permission having been granted for erection

of warehouses and use for industrial purposes dating back to the 1950’s. 3.2 A planning application for “redevelopment of the site involving demolition of the

existing buildings and the construction of a building of 3 - 5 storeys in height (plus basement) to provide 71 residential units and 831m² of office floorspace (Class B1

use), underground parking for 18 spaces with access onto Blairderry Road, associated landscaping and servicing” was refused under delegated authority in September 2008 (ref 08/02787/FUL). The reasons for refusal were as follows:

1 The proposed development, by virtue of its height, bulk, scale and massing, would appear over dominant and overbearing from the existing neighbouring residential properties, in particular properties to the west on Blairderry Road, which would result in an un-neighbourly and unacceptable sense of enclosure to the detriment of the residential amenities of these occupiers. As such the proposal is contrary to Policy 33 of the Unitary Development Plan (2007). 2 The proposal would result in an unacceptable loss of daylight to habitable rooms in properties on Blairderry Road and 1-15 Barrhill Road, to the detriment of the residential amenity for these occupiers. As such the proposal is contrary to the provisions of Policy 33 of the Unitary Development Plan (2007). 3 The proposed development, by virtue of poor standard of design, would fail to relate satisfactorily to the adjacent townscape and contribute positively to its surrounding area, and would appear as an incongruous and inappropriate addition to the streetscene thereby causing detriment to the visual amenity of the locality, contrary to the provisions of Policy 33 of the Unitary Development Plan (2007). 4 Insufficient setbacks of the upper floors and balconies of the development would lead to an unacceptable loss of amenity to residents on Blairderry Road by way of overlooking, to the detriment of the residential amenities of these properties. As such, the proposal is contrary to Policy 33 of the Unitary Development Plan (2007). 5 Insufficient information has been submitted to enable the Authority to asses the impact of the scheme on parking stress on nearby residential streets. It is considered that the scheme would be likely to have an unacceptable impact on parking stress and as such, the proposal is contrary to Policies 9 and 14 of the Unitary Development Plan (2007). 6 Insufficient information has been submitted to enable the Authority to asses the impact of the servicing demands of the scheme on the local highway network. It is likely that the demands for servicing would have an adverse impact on the safety and operation of the highway and as such, the proposal is contrary to Policies 9 and 14 of the Unitary Development Plan (2007).

3.3 A revised planning application for “Redevelopment of the site involving demolition

of the existing buildings and the construction of a building of 3 - 5 storeys in height (plus basement) to provide 71 residential units and 890m² of office floorspace (Class B1 use), underground parking for 18 spaces with access onto Blairderry Road, associated landscaping and servicing” was refused by planning committee in April 2009 (ref 08/04609/FUL). The reasons for refusal were as follows:

1 The proposed development, by virtue of its height, bulk, scale and massing, would appear over dominant and overbearing from the existing neighbouring residential properties, in particular properties to the west on Blairderry Road, which

would result in an unacceptable sense of enclosure to the detriment of the residential amenities of these occupiers. As such the proposal is an overdevelopment of the site and is contrary to Policy 33 of the Unitary Development Plan (2007). 2 The proposed development proposes inadequate s106 measures to both encourage future residents of the development to use public transport and other methods of transport other than motor car and reduce the likelihood of car ownership, and would likely give rise to an unacceptable increase in on-street parking stress in the vicinity of the site where no parking controls exist. As such, the proposal is contrary to Policies 9 and 14 of the Unitary Development Plan (2007). 3 The proposed development would result in the loss of existing and potential employment generating floorspace to the detriment of employment provision within the Borough. As such, the proposal is contrary to Policy 23 of the Lambeth Unitary Development Plan (2007) 4 The proposed development would fail to provide an adequate mix of housing units, in particular three and four bed units, for which there is a demonstrable need in the borough. As such, the proposal is contrary to Policy 15 of the Lambeth Unitary Development Plan (2007).

3.4 In terms of surrounding land, the adjacent site to the northeast, 1-15 Barrhill Road,

has recently been developed for housing, and provides 12 residential units in a four storey building (00/01363/FUL).

3.5 The site containing the Megabowl, Caesars Nightclub and other buildings has an

extant planning permission and conservation area consent (May 2010; ref:10/00507/FUL) for “Demolition of the existing buildings (except for Megabowl façade and section of side return elevation) and redevelopment to provide a mixed use scheme in a building ranging in height from 2 to 8 storeys (plus lower ground floor and basement) containing 3,786m² retail space (Class A1 (retail), Class A2 (professional services) and Class A3 (restaurant/café) including servicing and storage) 187 m² community floor space (Class D1), 840 m² assembly/leisure use (Class D2), together with 243 flats (13 x Studios, 75 x 1 bed, 121 x 2 bed, 31 x 3 bed and 3 x 4 bed) located around a ground floor internal courtyard. Other works include underground parking for 91 spaces with access onto Blairderry Road, retail service yard accessed from Sternhold Avenue”.

4. SCHEME DETAILS 4.1 The scheme proposes the redevelopment of the site, involving the demolition of all

the buildings on the site and the construction of a building ranging from three to six storeys in height to provide 69 residential units, commercial floorspace, basement car parking with access onto Blairderry Road and associated landscaping.

4.2 The 69 new residential units proposed would comprise 33 x 1 bed, 23 x 2 bed, 11

x 3 bed and 2 x 4 bed units. The affordable housing provision would be 30% (by unit) with a 29/71 split between social rented and intermediate units. Based on the

site area (including half the width of the public highways) the development would have a density of 225 habitable rooms per hectare (hrh).

4.3 It is proposed to provide 20 car-parking spaces (including 6 disabled spaces), and

cycle parking spaces in the basement area below the accommodation. Ramped access is proposed from the parking area onto Blairderry Road.

4.4 272sqm (GIA) of commercial space (Use Class A1, A2, B1 and/or D1) is proposed

on the ground floor of the Ardwell Road elevation in two separate units. 4.5 The building would be L shaped, following the contour created by Ardwell,

Blairderry and Barrhill Roads, and part three, four, five and six storeys in height. The massing would form a largely continuous three-storey frontage along Blairderry Road. Upper floors would be stepped back in turn from the main frontage on Blairderry Road. The tallest element would step up to six storeys in height along Ardwell Road.

4.6 Four separate residential entrance lobbies are proposed, along with individual

entrances to two ‘houses’. The two commercial units would have their own entrances on Ardwell Road. Refuse stores would be provided adjacent to the entrance lobbies.

4.7 The footprint of the building dictates a courtyard area to the east that is proposed

to be landscaped as a communal amenity space with a children’s play area. Other amenity spaces for occupiers would be provided both through the use of private gardens, balconies and roof terraces. A total of 995sqm of communal and private amenity space is proposed.

5. CONSULTATION RESPONSES

5.1 The application was advertised by way of site notices and a press advert. In

addition, letters of notification were sent to 757 neighbouring property addresses in the vicinity of the site.

5.2 Letters of notification were sent out to the following statutory bodies and external

consultees, the responses of which to the consultation are summarised as follows:

Transport for London: Subject to conditions, TfL consider that the proposal as it stands would not result in an unacceptable impact to the Transport for London Road Network (TLRN). English Heritage: No response at time of writing English Heritage Archaeology:

No archaeological fieldwork need be undertaken prior to determination of this planning application but the archaeological position should be reserved by attaching a condition to any consent granted. Environment Agency: The Environment Agency has made the decision not to provide detailed site-specific advice or comments with regard to this proposal; although they encourage good practice for the assessment and remediation of contaminated sites. 20th Century Society: No response at time of writing. LFCD Authority: No response at time of writing. Network Rail: No response at time of writing. Thames Water: No objection, subject to the applicant entering into all the necessary [non-planning] agreements with respect to the water/sewerage infrastructure.

5.3 Letters of notification were sent out to the following amenity groups, the responses

of which are as follows:

Streatham Society – No response at time of writing

Streatham Conservation Association – No response at time of writing

Telford Court Residents Tenants Association – No response at time of writing

Telford Park Residents Association – ”A similar scheme (application no 08/02787/FUL) was refused on 19th September 2008. The reasons given for refusal, which we supported, equally apply to the current scheme. The scheme is out of character and would dominate the domestic scale of the neighbourhood. We object to the loss of employment space. The warehouse/industrial building on the site still has a useful life. It is occupied and provides employment. There is a shortage of this sort of space in the borough and if it did become vacant it would be quickly let up again. The new commercial space being offered is not a like for like replacement. The council in their wisdom have already consented to the adjoining Megabowl scheme with 250 flats. The idea that both these schemes could be built at the

same time is clearly unreasonable. The affect on residents of Blairderry Road and other surrounding streets if this were to happen would be appalling”.

5.4 Neighbour Responses

No. Letters sent No. of Objections

No. in support

No. of comments

757 16 1 2

5.5 Response to Neighbours’ Comments

Comments/Objection Response

Landuse

Net reduction in employment is regrettable

The reduction in employment floorspace/land proposed is considered unacceptable in the context of current development plan policy and forms one of the recommended reasons for refusal

There is too much commercial space. There will be little demand for A1/A2 uses in this side street and there is no parking for B1.

The application site lies within a town centre location. Setting aside the issue regarding the loss of employment land, A1, A2, B1 and D1 uses are entirely appropriate within town centre locations. Furthermore, if the development were considered acceptable in all other respects, the site has a PTAL rating of 6 whereby it is extremely well served by public transport and a designated parking space(s) for the B1 unit(s) need not be provided.

Possibly a D1 use is acceptable, but it should be restricted so as not to include a place of worship as this creates additional parking issues. A possible clinic or nursery might work.

Were the development considered acceptable in all other respects, the nature of a potential D1 use could be controlled by way of planning condition.

Limited number of social rented units.

The proposed tenure mix of the scheme conflicts with current planning policy and forms one of the recommended reasons for refusal

The area is already congested and can not cope with more cars and people.

The application site lies within a location extremely well served by public transport and where planning policies seek to optimise the development potential of sites so as to encourage a more sustainable pattern of development. Were the development considered acceptable in all other respects, the impacts of the development upon congestion, increasing vehicular trips and increasing people in the area could reasonably be mitigated through s106 obligations and planning conditions.

Design

This is an overdevelopment of the site, especially when considered in conjunction with the recently consented

The application site lies within a location extremely well served by public transport and where planning policies seek to optimise the development potential of sites so as to encourage a more sustainable

Megabowl development. pattern of development. The development would have a density of 225 habitable rooms per hectare (hrh) – this falls within the London Plan suggested density range of between 200-700hrh for this location (urban, with a PTAL between 4 and 6).

The building is too bulky, too high and too close to the Blairderry Road Boundary The quality of design is poor – far below that which should be expected in modern residential development in London The design has no relation to the character of Telford Park estate or the materials used in the Streatham High Road Conservation Area. This is an inappropriate building style for the area and does not match the houses on Blairderry road or the flats on Streatham Hill which face it. The development will not be complimentary to the Megabowl development, which is of a much higher standard The balconies should be removed on the Blairderry Road elevation and swapped to the Barrhill road specification

The site straddles a town centre and as such the surrounding townscape has a variety of massing, scales and uses. This townscape contrast represents a challenge in design terms. The six storey element along Ardwell Road is considered to be acceptable considering the scale of many of the nearby buildings and in light of the approved Megabowl development which would stand opposite the site at six to eight storeys along the majority of Ardwell Road. The massing, with the taller elements situated to the east and south of the site, stepping down in scale to three storeys towards Blairderry Road, and with the upper two storeys considerably set back, is considered to be appropriate and sensitive response to the varied scale and massing of the townscape context. This site is within the core area of the Streatham Hill Town Centre which comprises a variety of building types and scales. Although larger than the residential properties across Blairderry Road, the schemes’ massing is considered to be an appropriate and logical response to its setting. In terms of detailed design, London Stock brick is considered to be an appropriate and durable material that respects much of the surrounding built form. Whilst the aluminium and cladding proposed would be of a more contemporary appearance, it is not objected to, as it is not out of place with some of the more modern additions and approvals within the nearby townscape. The relatively simple and uniform rhythm of windows and cladding proposed throughout the lower floors would serve to break up the articulation of these facades and prevent them from appearing overly bland or monolithic. This would be helped on Blairderry Road by the variation in the building line and the set back of the central section of this façade. On the upper floors, the use of different

materials would ensure that these set back elements would be read as separate forms and serve to mitigate any sense of overbearing. It is also considered that relatively minor design alterations could add interest and greater articulation to the facades. String courses, lintels or banding for example could very easily be integrated into the scheme. Further measures to improve the detailed architectural design could be explored by way of suitably worded planning conditions so as to improve the overall design quality of the scheme. Officers are also satisfied that the development would not prove unacceptably harmful to any heritage assets within the vicinity of the site – including conservation areas and listed buildings.

It is a visual improvement over the previously refused scheme and the existing site. The development will regenerate the area.

Noted.

The development requires the loss of a well established tree which should be preserved.

The tree is not afforded any protection either by way of a tree preservation order or by virtue of falling within a Conservation Area. In the circumstances the applicant could remove that at any time. Notwithstanding, the council could ensure an overall uplift in the ecological value of the site through landscaping specifications which would act to offset any harm as may result from the loss of the tree.

Where there is a lack of amenity space this will increase crime.

There is no evidence to substantiate this concern.

Neighbouring Amenity

Loss of privacy to neighbouring properties (Barrhill Road)

Officers are satisfied that the development, subject to conditions, need not prove unacceptably harmful to the privacy of neighbouring properties.

Loss of sunlight and overshadowing to neighbouring properties (Barrhill Road and Blairderry Road)

The submitted daylight and sunlight assessment verifies that the surrounding properties of the development would not experience loss of daylight or sunlight in excess of BRE guidelines. Officers have no reason to challenge the accuracy of the assessments.

Highways and Transport

Further pressure on street parking will create difficulties The area is already congested and the development would make this worse Blairderry road is already a rat

A range of mitigation measures to limit car ownership are suggested that would address the concerns. Subject to conditions and s106 mitigations, it is considered that the development would not conflict with highways and transport related policies of the Development Plan.

run and a dangerous stretch of road. 20 car parking spaces for the development is inadequate The access ramp from Blairderry Road is too narrow and turning out into oncoming traffic would be hazardous Access ought to be from Ardwell Road or Barrhill Road where accesses already exist There should be increased visitor parking On street parking bays for the development will be required

Other Matters

Lambeth does not have sufficient school places

The council could secure a s106 contribution towards mitigating the development’s impact upon primary and secondary schools.

The development will ruin the amenity of the area and bring down the community as this type of building is simply not wanted here.

The development has the potential to contribute towards the council’s housing needs and demands within Streatham. There is no evidence to suggest that were the development considered policy compliant in all other respects, it would materially harm the amenity of the area.

Noise and dust during construction

There would inevitably be a degree of disturbance in the short term to local residents during the construction period. However, a construction management plan could be required by condition so as to minimise such harmful impacts as far as is practicable. It follows that this objection need not weigh heavily against granting planning permission.

Local residents should be given four weeks to make representations on planning applications.

Three weeks notification of planning applications is considered sufficient time to enable meaningful representations to be made. The three week period is set out in national legislation. Notwithstanding, it is the case with Lambeth that officers will accept and report any representations received right up until the determination of the application, provided it is practicable for them to do so.

5.5.1 A petition of support, inclusive of 27 signatures, has been submitted by the

applicant. The petition sets out that the site is currently an eyesore and the development will strongly aid regeneration of the area.

5.6 The following Internal consultations were sought and their response is summarised

as follows:

Transport:

Transport Planning have reservations with respect to the extent of overspill parking associated with the residential component of the scheme, and the subsequent impact on parking stress on the surrounding highway network. Based on an assessment against ward car ownership by household size and tenure, there could be up to 32 additional cars requiring on-street parking, over and above the 20 cars that will be accommodated in the basement car park. Transport Planning would only be supportive of the scheme if a range of mitigation measures to limit car ownership were agreed to and implemented, including a comprehensive Travel Plan, conditions, and s106 contributions to improve local transport infrastructure. The s106 package should be inclusive of the following:

1. Given the scale of the scheme and the expected multi-modal trip generation,

comprehensive highways improvements are required along Blairderry Road, Ardwell Road Barrhill Road and Streatham High Road. Works should include (although not be limited too) upgrading footways, carriageways, removing/reinstating crossovers, upgraded kerb and channelling to the sum of £110,000.

2. A Travel Plan needs to be secured for the site and submitted in draft for comment as early as possible and will be required as part of the s106 agreement.

3. A £6,500 contribution towards creation of two car club bays along with funding of car club memberships should also be secured as part of the Travel Plan.

4. Costs associated with the consultation and the implementation of a CPZ within the Streatham Hill Ward pending the outcome of a parking survey following occupation. NOTE: Creation of a CPZ is subject to a separate statutory and consultation process and costs should be secured for consultation on a CPZ regardless of whether the CPZ proceeds.

Conservation and Urban Design:

“In terms of scale and mass, the current scheme is an improvement to the previously refused scheme (08/04609/FUL). The reduction in height along Barrhill Road goes some way to address previous concerns highlighted by the committee. The increase in height along Ardwell Road is likely to be acceptable considering the scale of the approved Mega bowl development standing at 8 storeys along Ardwell Road. There is unease regarding under-proportioned windows used throughout the site and proposal’s relationship to its context. Overall, we feel that the elevational treatment is a missed opportunity to improve the visual appearance of the scheme. Instead we feel that the appearance has taken a step back, and in contrast to the Mega bowl scheme the proposal will appear as the poor relation. However, whilst the scheme cannot be viewed as high quality architecture, I do not think it is of such poor architecture as to refuse the application. Planning Policy:

The substantial loss of employment floorspace on the site is contrary to Core Strategy Policy S3 and saved UDP Policy 23; none of the exception criteria set out in UDP Policy 23 are met. There are spatial variations across the borough in demand for types and affordability of premises. Streatham is identified in the 2007 Business Premises Study as experiencing lower levels of demand for business premises, but nevertheless the study advises that, as a town centre location, Streatham still represents potential opportunities to provide business premises for those who may be priced out of other town centres in the borough. Robust justification, addressing the exception criteria set out in Policy 23 will therefore be required before loss of employment floorspace can be accepted. The proposed affordable housing provision is not in line with policy and therefore this will need to be justified.

Streetcare: No response at time of writing

Regulatory Services, Noise and Pollution: No response at time of writing

Regulatory Services, Licensing: No response at time of writing

Crime Prevention Design Advisor:

No objection in principle, subject to various conditions and s106 requirements; including committing the development to the achievement of Secured by Design Standards and the need for a robust management plan. Parks and Open Space: No response at time of writing.

Housing: At the time of writing further discussions are being had with the applicant in light of the concerns over the tenure mix (see assessment section below).

6. RELEVANT POLICIES 6.1 Section 38(6) of the Planning and Compulsory Purchase Act 2004 requires

planning decisions to be made in accordance with the development plan unless material considerations indicate otherwise.

6.2 The development plan in Lambeth is:

• The London Plan (adopted July 2011);

• Lambeth’s Local Development Framework (LDF) Core Strategy (adopted 19 January 2011); and

• The remaining saved policies in the ‘Lambeth Unitary Development Plan (UDP) 2007: Policies saved beyond 5 August 2010 and not supersede by the LDF Core Strategy January 2011’.

6.3 It should be noted that given the recent adoption of the council’s Core Strategy, the

policies contained therein and those remaining in the UDP are in general conformity with the recently adopted London Plan. For the purposes of this recommendation report therefore the assessment will concentrate upon the development’s compliance, or not, with Core Strategy and UDP Policies. Reference will only be made to London Plan Policies where there is conflict or where it is necessary and/or appropriate to do so.

6.4 Material considerations include national, regional and local planning policy

statements, planning policy guidance and Supplementary Planning Documents. 6.5 London Plan 6.5.1 The London Plan is the overall strategic plan for London, and it sets out a fully

integrated economic, environmental, transport and social framework for the development of the capital to 2031. It forms part of the development plan for Greater London. London boroughs’ local plans need to be in general conformity with the London Plan, and its policies guide decisions on planning applications by councils and the Mayor.

6.5.2 The following policies of the London Plan are relevant:

Policy 2.15 Town centres Policy 2.18 Green infrastructure: the network of open and green spaces Policy 3.3 Increasing housing supply Policy 3.4 Optimising housing potential Policy 3.5 Quality and design of housing developments Policy 3.6 Children and young people’s play and informal recreation facilities Policy 3.8 Housing choice Policy 3.9 Mixed and balanced communities Policy 3.10 Definition of affordable housing Policy 3.11 Affordable housing targets Policy 3.12 Negotiating affordable housing on individual private residential and mixed use schemes Policy 3.13 Affordable housing thresholds Policy 3.16 Protection and enhancement of social infrastructure Policy 4.1 Developing London’s economy Policy 4.2 Offices Policy 4.3 Mixed use development and offices Policy 4.7 Retail and town centre development Policy 4.12 Improving opportunities for all Policy 5.1 Climate change mitigation Policy 5.2 Minimising carbon dioxide emissions Policy 5.3 Sustainable design and construction

Policy 5.7 Renewable energy Policy 5.9 Overheating and cooling Policy 5.10 Urban greening Policy 5.11 Green roofs and development site environs Policy 5.13 Sustainable drainage Policy 5.14 Water quality and wastewater infrastructure Policy 5.15 Water use and supplies Policy 5.16 Waste self-sufficiency Policy 6.3 Assessing effects of development on transport capacity Policy 6.7 Better streets and surface transport Policy 6.13 Parking Policy 7.1 Building London’s neighbourhoods and communities Policy 7.2 An inclusive environment Policy 7.3 Designing out crime Policy 7.4 Local character Policy 7.5 Public realm Policy 7.8 Heritage assets and archaeology Policy 7.13 Safety, security and resilience to emergency Policy 7.14 Improving air quality Policy 7.15 Reducing noise and enhancing soundscapes Policy 7.19 Biodiversity and access to nature Policy 8.2 Planning obligations Policy 8.3 Community infrastructure levy

6.6 Lambeth’s Local Development Framework Core Strategy 6.6.1 The Core Strategy was adopted by the council on 19 January 2011. 6.6.2 The following Policies of the Council’s Core Strategy are relevant to the current

planning application:

Policy S1: Delivering the Vision and Objectives Policy S2: Housing Policy S3: Economic Development Policy S4: Transport Policy S5: Open Space Policy S6: Flood Risk Policy S7: Sustainable Design and Construction Policy S8: Sustainable Waste Management Policy S9: Quality of the Built Environment Policy S10: Planning Obligations

Policy PN4: Streatham 6.7 UDP Policies, saved beyond 5th August 2010 6.7.1 The following policies (whole or part thereof) of the adopted Unitary Development

Plan (2007), saved beyond 05 August 2010 and not superseded by the adoption of the Core Strategy, are relevant to this application:

Policy 4 Town Centres and Community Regeneration

Policy 7 Protection of Residential Amenity Policy 9 Transport Impact Policy 14 Parking and Traffic restraint Policy 16 Affordable Housing Policy 21 Location and Loss of Offices Policy 23 Protection and Location of other Employment Uses Policy 26 Community Facilities Policy 31 Streets, character and layout Policy 32 Community Safety/Designing Out Crime Policy 33 Building Scale and Design Policy 35 Sustainable Design and Construction Policy 38 Design in existing Residential/Mixed Use areas Policy 39 Streetscape, Landscape and Public Realm Design Policy 45 Listed Buildings Policy 47 Conservation Areas Policy 50 Open Space and Sports Facilities

6.8 National Planning Policy

6.8.1 The following Central Government Planning Policy Guidance Notes (PPGs) and

Planning Policy Statements (PPS) are relevant. Planning Policy Statement 1: Delivering Sustainable Development: Planning Policy Statement 2: Housing: Planning Policy Statement 4: Planning for Sustainable Economic Growth Planning Policy Statement 5: Planning for the Historic Environment Planning Policy Statement 9: Biodiversity and Geological Conservation Planning Policy Guidance 13: Transport: Planning Policy Statement 22: Renewable Energy Planning Policy Guidance 24: Planning and Noise

6.8.2 The Department of Communities and Local Government has issued a Draft

National Planning Policy Framework (NPPF) for consultation (ending October 2011). The NPPF is intended to replace all existing national planning policy statements, guidance and circulars (PPS, PPG). The policies it contains would apply to the preparation of local and neighbourhood plans, and to development management decisions. The NPPF reflects many aspects of the Localism Bill in relation to planning, including the new concept of neighbourhood planning. It also introduces the important new ‘presumption in favour of sustainable development’ which is intended to support economic growth and means that local planning authorities should approve development proposals that accord with statutory plans without delay, and grant permission where the plan is absent, silent, indeterminate or where relevant policies are out of date.

6.8.3 It is a consultation document and, therefore, subject to potential amendment. It is

capable of being a material consideration, although the weight to be given to it will be a matter for the decision maker in each particular case. The current Planning Policy Statements, Guidance notes and Circulars remain in place until cancelled.

6.9 Local Guidance

6.9.1 The council has adopted the following Supplementary Planning Documents, which

are relevant:

• SPD: Housing Development and House Conversions

• SPD: Safer Built Environments;

• SPD: Sustainable Design and Construction; and

• SPD: S106 Planning Obligations

6.9.2 The Council’s ‘Waste & Recycling Storage and Collection Requirements: Guidance for Architects and Developers’ is also relevant.

7. PLANNING CONSIDERATIONS 7.1 Land Use 7.1.1 The application falls within a Major Centre Primary Shopping Area, as defined on

the Local Development Framework Proposals Map. 7.1.2 The 0.27ha site is currently occupied by buildings comprising 1535m² (GIA) of

active employment uses (Use Classes B8 and B1) –they were in active use at the time of the case officer’s site visit on 31st August 2011.

7.1.3 The north building is occupied by a carpet warehouse company. 7.1.4 Whilst originally constructed for warehousing and industrial purposes, it was

observed on site (August 2011) that a large area of the south building (approximately 280sqm according to the application submissions) was provided as office space fitted out to a high standard, with only two of the original three warehouse/factory bays remaining available for storage purposes. Only one of the bays was being used for storage purposes and it was evident that the use of the south building had changed from an industrial/warehouse use to a mixed B1 and B8 use, perhaps even a B1 use with ancillary storage. It was definitely the case that the B1 use could not have been considered to have been ancillary to the other operations. Notwithstanding, the status (in planning terms) of the B1 use of the south building has not been established in the council’s planning records for the site.

7.1.5 The scheme proposes the redevelopment of the site to provide a mixed use

scheme providing 69 homes and 272m² (GIA) of commercial floorspace (Use Class A1, A2, B1 or D1).

7.1.6 The site is not within an identified Key Industrial and Business Area (KIBA). Employment Loss/Re-provision 7.1.7 The site is currently an ‘employment site’ containing a mix of office and

warehousing uses. The majority of the floorspace falls within use class B8, with a smaller B1 provision. However, these are both classed as ‘employment uses’ for

the purpose of the development plan and afforded protection under Core Strategy Policies S3 and UDP Policies 21 and 23.

7.1.8 By contrast A1, A2 (where in a shop premises as is proposed) and D1 uses, whilst

admittedly employment generating, are not ‘employment uses’ as defined within Policy 23 of the UDP.

7.1.9 It is thus the case that the proposed development would result in a net loss of at

least 1,263 sqm of B Class ‘employment’ floorspace; or potentially all of the existing 1,535 sqm if neither of the ‘commercial’ units are occupied by B1 uses. This equates to at least an 82% reduction in floorspace.

7.1.10 Core Strategy Policy S3 sets out that the council will support economic

development, Lambeth’s contribution to the central and wider London economy and a range of local business and job opportunities, by giving priority to a diverse range of economically beneficial uses in appropriate locations. The policy states that this will be achieved by (b) maintaining a stock of sites and premises (not in KIBAs) in commercial use subject to the suitability of the site and location.

7.1.11 Whilst the site has residential uses in its immediate proximity, it is nevertheless in a

town centre and has a high Public Transport Accessibility Level (PTAL) rating. Furthermore, it is common across London for residential uses to exist cheek by jowl with employment uses. The site therefore is not unsuitable for continued employment use by reason of its site or location. The loss of at least 82% (potentially 100%) of the employment floorspace of this employment site to a residential led mixed use development would be contrary to the objectives of Core Strategy Policy S3, subject to consideration against the remaining employment policies of the development plan.

7.1.12 With regard to specific policies and tests for the acceptability of any loss of

employment land/floorspace outside of KIBAs, UDP Policies 21 and 23 are applicable. However, where the ambiguity exists over the lawfulness of the B1 use of the south building, it is necessary to assess the application against UDP Policy 23, as opposed to Policy 21.

7.1.13 UDP Policy 23 protects employment uses, the definition of which includes B Class

uses. Part (b) of the policy sets out the tests for the loss of employment floorspace. The policy states that where land is or has been in employment use, loss of floor space to non-employment use will not be permitted unless particular criteria are met. These criteria include (i) whether the site is no longer suitable for employment use; or (ii) whether the site is vacant and is demonstrated to be surplus; or (iii) where a scheme has substantial other planning benefits; or (iv) the redevelopment is for a town centre use, providing there is compensation for the loss of employment; or (v) it relates to a listed building or building with significant architectural merit and reverts that to residential use.

7.1.14 In considering the criteria set out in part (b) of Policy 23, it should be taken into

account that the previously refused scheme (08/04609/FUL) proposed some 890sqm of replacement office floorspace. The officer recommendation report for that scheme concluded that, on balance, the loss of 42% of the employment

floorspace was acceptable having regard to UDP Policy 23. This recommendation was made taking into account the size of the 890sqm re-provided office space, site circumstances, information submitted regarding lack of demand for employment and office floorspace, the planning benefits (40% affordable housing and modern offices) and the potential to increase the employment numbers on the site. The planning committee however, in consideration of the previous scheme, was not convinced that the justification was enough to allow the loss of this town centre employment site and the scheme was refused as contrary to UDP Policy 23; which has been saved and remains relevant.

7.1.15 Officers do not accept that the site is no longer suitable for employment use (Policy

23 (b)(i)). The site is in active use, and therefore part (ii) of policy 23 (b) would not apply either. In any event, no evidence of any marketing carried out has been submitted.

7.1.16 Policy 23(b) (iii) advises that, exceptionally, a loss of employment floorspace can

be considered where a scheme has substantial other planning benefits and where development of part of a site is compensated by increasing the amount of employment on the remainder and / or providing modern small business units. In this context officers acknowledge that the scheme would present the following planning benefits:

• The provision of 69 residential units – amounting to 6% of the council’s annual housing target;

• The provision of 21 affordable housing units – albeit subject to the concerns raised below regarding tenure mix;

• The provision of two modern units which could be occupied for either A1, A2, B1 or D1 uses and which would be provided with rent subsided for three years – all of which are uses appropriate to the Major Centre Primary Shopping Area designation of the site; and

• The development would deliver regeneration benefits associated with the redevelopment of the site which currently lacks any significant townscape, architectural or historical interest – albeit bearing in mind the concerns raised by the council’s Conservation and Design Advisor with regards to the architectural quality of the scheme.

7.1.17 Substantial as these planning benefits may or may not be considered to be (see

assessments to follow), in any event the development does not suitably compensate the substantial net loss of employment floorspace as is required by the second part of the Policy 23(b) (iii) test. Given the planning permission sought is for an open end user of the 2 ‘commercial’ units, the council can not be assured that the redevelopment of the site would provide any compensatory ‘employment’ floorspace. As advised, A1, A2 and D1 uses are not considered ‘employment’ uses for the purposes of applying UDP Policy 23. Even if the development were to guarantee a B1 use of the ‘commercial’ units, it would still be the case that the proposed development would result in a net loss of at least 1,263 sqm of B Class ‘employment’ floorspace. This equates to an 82% reduction in floorspace. The previously refused scheme (08/04609/FUL) proposed 890sqm of replacement office floorspace; an amount which, whilst more than the 272sqm proposed here,

was considered unacceptable at that time having particular regard to UDP Policy 23.

7.1.18 Furthermore, the proposed development would not necessarily result in an

increase of jobs at the site, either compared to the existing B1 and B8 uses of the site or to a B8 use of the existing buildings. It was observed at the site visit that the office space of the southern building was quite intensely occupied. Despite requests, the applicant has provided no information regarding the levels of employment generated by the existing uses of the site (as existed in August 2011 at the time of the case officers site visit) but has rather asserted that the existing office use of the site is unlawful and therefore bears no relevance to the determination of the current planning application. Whilst ambiguity exists as to whether the B1 use is lawful at the site, the activities are nevertheless indicative of the type and nature of an employment use which has and could operate successfully in this location and in proximity to residential neighbours and is also an indication of demand for such employment space in the area.

7.1.19 The following table sets out a comparison of the likely job generation of the existing

and new development, using figures derived from the 2010 HCA Employment Density Guide:

Use (GIA) Area per Full Time Employer (GIA)

Jobs

Existing Use:

281sqm of B1 Floorspace 1,254sqm of B8 Floorspace

B1 – 12sqm B8 – 70sqm

41.3

1,535sqm of B8 Floorspace B8 – 70sqm 21.9

Proposed Uses:

272sqm of A1 and/or A2 Floorspace

A1/A2 – 16sqm 17

272sqm of B1 Floor Space B1 – 12sqm 22.7

272sqm of D1 Floor Space D1 – 36sqm – NB A very wide range of D1 uses exist so the guidance sets out that this figure must be used with caution. In this instance an end user has not been identified.

7.6

7.1.20 As seen in the table above, applying the density figures would infer that the

development would, at best, only result in an uplift of jobs at the site by one. Notwithstanding issues of whether the development would or would not provide increased levels of employment at the site, the supporting text to UDP Policy 23 states that it should not be presumed that a proposal would automatically be given approval if it will result in a greater number of jobs, and that the aim of the policy is not just to protect existing jobs, but to protect existing land and floorspace. The development does not do this.

7.1.21 In conclusion, in terms of Policy 23(b)(iii) whilst the development does present

planning benefits, it is considered that those are not sufficient to offset the harm

that would result from the substantial reduction of employment floor space. Moreover, the importance of maintaining a stock of employment sites and uses across the borough so as to maximise local employment opportunities weighs heavily against the grant of planning permission.

7.1.22 Regarding criterion (iv) of UDP Policy 23, whilst the development would be

inclusive of town centre uses, for the reasons set out above officers are of the opinion that the development does not offer adequate compensation for harm that would result from the net loss of employment floor space proposed.

7.1.23 The buildings are not listed, nor does the proposal involve the reversion of an

existing building back to residential use. Therefore criterion (v) of Policy 23 does not apply.

7.1.24 For the reasons set out above, the exemption tests set out in saved UDP Policy 23

(that would allow for the release of employment land/floorspace) are not met. 7.1.25 With regards to Policy PN4, officers acknowledge that it sets out that “the aim is to

seek to deliver significant development through the masterplan. Officers are also mindful that the Streatham Master Plan - developed for Streatham in consultation with local residents, businesses and organisations and approved by Cabinet in July 2009 – formed part of the evidence base to justify the policies set out within the Core Strategy. The Streatham Master Plan identifies the application site as falling within block SH1, which:

“Proposes a linear retail ground floor retail block facing onto the High Road with 3 storeys of residential above. In addition, 3 storeys of residential development fronting onto Blairderry Road and ground floor commercial with 3 upper floors of residential development fronting onto Ardwell Road are proposed. High Road improvements are proposed directly in front of Block SH1 to reduce the width of the road to 2 lanes in each direction and make a wider pavement with the planting of a boulevard. Traffic calming measures are proposed along Blairderry Road with restrictions for local access only.”

7.1.26 Notwithstanding, whilst it is the case that the Streatham Town Centre Masterplan

provides a framework for regeneration in the area and is a material planning consideration, it has not been adopted as supplementary planning guidance as part of the local development framework. Of particular relevance is that the Master Plan itself sets out that the plans contained therein are “indicative and provide an illustration of what the proposals could look like… The proposals detailed will need to conform to statutory planning policies and will be subject to the planning approval process including associated public consultation”. Moreover, the appropriate statutory process for allocating sites is through the development plan process, as opposed to the identification of indicative proposals through the masterplan. In this regard the forthcoming Site Allocations DPD is the appropriate mechanism for allocating uses to the site. It is advised that initial consultation on the Issues and Options version of the Site Allocations Development Plan Document (DPD) were carried out in 2009 (when the site was not included) and that further consultation on a draft DPD is anticipated early in the New Year.

7.1.27 Policy PN4 reflects the aspirations and approach for Streatham, supporting its role as a major town centre through appropriate regeneration, within the strategic framework set by the borough-wide Strategic Policies. Nowhere in policy PN4 is it suggested that the presumption against the loss of existing employment generating floorspace set out in UDP Policy 23 and Core Strategy Policy S3 should be disregarded.

7.1.28 The application submission also attempts in part to justify the net reduction of

employment floor space on the basis that the loss of a derelict purpose built office (Wentworth House) was accepted through the grant of planning permission on a neighbouring site known as the ‘Megabowl’ (ref: 10/00507/FUL). Officers however consider that there are no compelling reasons that the granting of the planning permission 10/00507/FUL should prove a precedent to justify the proposed change use. Whilst Wentworth House is in the vicinity of the application site and also within the Streatham Town Centre, there are few other similarities. Wentworth House was a vacant, purpose built office block, and information regarding vacant offices was submitted (dated February 2010) pursuant to the requirements of UDP Policy 21 which allows for the loss of vacant offices. The current application site is not a vacant office. Rather, it is an actively used employment site, and as set out above the argument that the existing accommodation on the site is surplus can not be made. Further, the Megabowl application is a major mixed-use redevelopment of a largely vacant site that would result in an increase in employment provision across the entire site, along with various other planning benefits such as community facilities and retail. Clearly, these are two entirely different sites in terms of the existing uses and the proposed developments, with different constraints and policy considerations. Officers do not accept that such an approach can be used to justify the loss of this employment site.

Housing

7.1.29 Core Strategy Policy S2 (housing) seeks the provision of at least 7,700 net

additional dwellings across the borough between 2010/2011 and 2017/17 in line with the London Plan. The London Plan sets an annual monitoring target for Lambeth of 1,195 new homes. Core Strategy Policy PN4 seeks to deliver within Streatham a net increase in the order of 900 dwellings over a fifteen year period up to 2025. In addition, Core strategy Policy S2 seeks affordable housing provision on all sites which can accommodate more than 10 homes, albeit subject to independently validated evidence of viability.

7.1.30 The development would deliver some 69 residential units, 21 of which would be

provided as affordable housing on a 29/71 split between social rented and intermediate units – the level of affordable housing provision and the tenure mix is discussed in more detail below. It is therefore the case that the development would contribute towards addressing Lambeth’s housing needs and demand.

7.1.31 The site falls within a Major Town Centre. It is accepted that residential uses are

appropriate for town centre locations. It is thus not contended that were the development to justify an exemption from the planning policy presumption for the protection of the employment floor space, then in principle a mixed use

development inclusive of residential uses would be appropriate for the site. The scheme however presents insufficient justification for such an exemption.

7.1.32 The Council’s housing development pipeline for 2010/11 shows that 1,289 new

dwellings were completed in Lambeth, with a total of 1,602 new homes when other forms of residential supply are added. The housing development pipeline is also healthy with over 5 years housing supply identified. It follows that the council need not in this instance override its employment protection policies in order to achieve its housing targets.

A1, A2 and or D1 Use

7.1.33 Officers do not contend that A and D Class uses would be inappropriate within

Major Town Centre locations; especially where the active frontages would promote urban vitality and/or regeneration in accordance with UDP Policy 19 and Core Strategy S3 (d). Notwithstanding, this in itself does not sufficiently justify an exemption to the employment use protection set out in UDP Policy 23 and within Core Strategy Policy S3 (b). Landuse Conclusions

7.1.34 The development is unacceptable in that it would result in the substantial loss of

employment floor space without presenting sufficiently substantial planning benefits and/or adequate compensatory provision of employment floor space. In the circumstances the development fails against UDP Policy 23 and Core Strategy Policy S3 and should be resisted.

7.1.35 Nowhere in policy PN4 is it suggested that the presumption against the loss of

existing employment generating floorspace set out in UDP Policy 23 and Core Strategy Policy S3 should be disregarded.

7.2 Residential Accommodation - Dwelling Mix and Tenure 7.2.1 Policy S2 sets out that developments should provide a mix of housing sizes and

types to meet the needs of different sections of the community, including through applying Lifetime Homes standards and providing wheelchair accessible housing.

7.2.2 Policy S2 sets out that with a scheme of this nature, at least 50 per cent of housing should be affordable where public subsidy is available, or 40 per cent without public subsidy, subject to housing priorities and, where relevant, to independently validated evidence of viability, or where there is a clearly demonstrable benefit in a different mix in the case of housing estate regeneration. Furthermore, there is an expectation that the mix of affordable housing should be 70 per cent social rented and 30 per cent intermediate.

7.2.3 London Plan Policy 3.11 requires borough council’s to seek to maximise affordable

housing provision and ensure an average of at least 13,200 more affordable homes per year in London over the term of this Plan. In order to give impetus to a strong and diverse intermediate housing sector, the Policy sets out that 60% of the

affordable housing provision should be for social rent and 40% for intermediate rent or sale. Priority should be accorded to provision of affordable family housing.

7.2.4 Policy 16 of the UDP sets out that a range of units sizes of affordable housing should be provided, having regard to local circumstances, site characteristics and the aims of the borough’s annual housing strategy.

7.2.5 London Plan Policies 3.8 and 3.9 encourages a full range of housing choice. Also relevant is the London Housing Strategy, which sets a target for 42% of social rented homes to have three or more bedrooms. Mix and Tenure

7.2.6 The development would provide 69 residential units in total. 30% of the dwellings would be affordable, with a 29/71 split between social rented and intermediate units. The mix of the residential units would be as follows:

Owner Occupied

Social Rented Intermediate Unit Total

1 bedroom units

27 1 5 33 (48%)

2 bedroom units

15 2 6 23 (33%)

3 bedroom units

6 1 4 11 (16%)

4 (+) bedroom units

2 2 (3%)

TOTAL 48 (70%) 6 15 69

Percentage of Affordable Housing

29% 71%

7.2.7 The affordable housing would be located predominantly within block A of the

scheme, although 2 x three storey ‘dwellings’ are proposed along the Blairderry Road frontage. The private housing would be provided around the cores of blocks B, C and D.

7.2.8 The 30/70 social rented/intermediate split represents a departure from the normally

expected 70/30. The applicant has concentrated the affordable units within one block for management purposes.

7.2.9 The application was accompanied by a confidential financial viability appraisal,

which was referred to BNP Paribas for independent verification. BNP Paribas have concluded that if the council are to accept the 30/70 social rented/intermediate split, the offer set out above is the maximum reasonable amount of affordable housing that is viable for the proposed scheme. BNP Paribas go on to advise however that a 50/50 tenure split would be viable with 25% Affordable Housing (8

Social Rented / 9 Shared Ownership), or a 70/30 tenure split viable with 19% Affordable Housing (9 Social Rented / 4 Shared Ownership).

7.2.10 Whilst officers acknowledge the advantage of clustering the affordable housing

units to facilitate practicable management, officers have not been presented with any compelling evidence at this time that the development could not deliver a more policy compliant tenure split. It is acknowledged that such would result in a net reduction in overall affordable units, but the split as it is currently proposed is unacceptable in that it does not appropriately reflect priority need within the borough. Officers are recommending that the scheme be refused on this basis.

7.2.11 It is accepted that at least 50% of the social rented units would have 3 or more

bedrooms in line with the London Housing Strategy target. In addition, overall 19% of the units would provide larger family sized units (3 or 4 bed units); which is an improvement over the 14% previously proposed in the 08/04609/FUL planning scheme. Notwithstanding, these matters do not outweigh the concerns highlighted over the affordable housing tenure split.

7.2.12 At the time of writing discussions between officers and the applicant are ongoing

with regards to securing a more policy compliant affordable housing tenure split within the development. Officers therefore intend to up-date Members on the night of the Committee as to where discussions in this regard have reached, with a view to potentially resolving the matter in advance of the Public Inquiry. Accessibility/Lifetime Homes

7.2.13 The applicant has confirmed that all new homes would be built to lifetime homes

standard in accordance with the policy requirements. However, the application submissions set out that only 6 (8.7%) of the 69 of the units would be built to be fully wheelchair accessible, which falls short of the London Plan 10% target. No explanation for this shortfall against London Plan standards has been provided.

7.3 Quality of Residential Accommodation 7.3.1 Policy S2 of the Core Strategy requires the provision of high standards of

residential amenity, having regard to Council space standards and including the provision of outside space for children’s play in private and communal gardens.

7.3.2 Policy S2 of the Core Strategy is supplemented by the Council’s SPD: Guidance

and Standards for Housing Development and House Conversions. Density 7.3.3 Core Strategy Policy S2 seeks levels of residential density consistent with London

Plan guidelines. The London Plan advocates a design led approach and a presumption towards the highest possible intensity of use, which must be compatible with the local context, design principles and local transport. Table 3.2 of the London Plan suggests a maximum density range of between 200-700hrh for this location (urban, with a PTAL between 4 and 6).

7.3.4 Based on the site area (including half the width of the public highways) the development would have a density of 225 habitable rooms per hectare (hrh). It is considered that the density of the scheme is acceptable subject to residential amenity being safeguarded and mitigation of the impacts of the development through s106 obligations.

Internal layout/Room sizes

7.3.5 The residential units and the rooms therein have been designed to comply with the

size standards set out within the Council’s Supplementary Planning Guidance for Housing Development. In addition, the dwellings would also accord with the minimum standards for such set out in London Plan Table 3.3.

7.3.6 On balance it is considered that the residential units would be sufficiently large and

that the internal layouts are appropriately and logically arranged so as to provide liveable residential accommodation in terms of size, circulation and functionality.

Outlook and Privacy

7.3.7 It is considered that the residential dwellings contained within the development

would be sufficiently distant from one another and from neighbouring property boundaries or developments and are orientated such as would achieve levels of outlook, privacy and aspect appropriate to this London location.

Daylight/sunlight

7.3.8 The applicant has submitted an ‘Internal Daylight Report’ which sets out the levels

of daylight and sunlight that would be expected to the proposed dwellings. The report concentrates upon a selected range of the lowest level accommodation, those presenting the worst case scenarios. Flats A1, A2, B1, C1, C3, House 1, House 2, D1 and D4 were analysed.

7.3.9 In terms of daylighting, the majority of rooms would either achieve the BRE

recommended guidelines for Average Daylight Factors (ADF) or only fall marginally short. Specific concern is however raised with regards to flat D1 (the internal facing flat on the Barrhill Road site of the development), where ADFs for the kitchen and for the living room are recorded at 0.0% and 0.6% respectively (BRE guidelines are 2% and 1.5% respectively). Future occupiers of this flat therefore would be heavily reliant upon artificial lighting for the majority of the use of those rooms.

7.3.10 In terms of sunlight, of the 7 living/kitchen/diners or living rooms which have

windows facing within 90’ due south, none achieve the recommended level of 25% total and 5% winter sunlight. Only two thirds of the windows tested would achieve within two thirds of their suggested total levels of Annual Probable Sunlight Hours.

7.3.11 Officers are mindful of the relatively dense urban environment within which the

application site sits and of the sustainable objectives of seeking to optimise the development potential of sites so well served by public transport. Within this context officers are of the opinion that the shortfalls against the non-mandatory BRE guidelines would not necessarily in themselves warrant a refusal of planning

permission. However, in this case officers do not consider the benefits of the scheme outweigh the shortfall identified and are therefore recommending that this should form a reason for refusal.

7.3.12 At the time of writing, the applicant is investigating the reorganisation of the

accommodation in block D to accommodate a more policy compliant affordable housing tenure mix. Such amendments could involve changes to the layout of the proposed units that could potentially offset the concerns regarding levels of natural lighting identified. Officers will up-date members at the Committee.

Noise Environment/Air Quality

7.3.13 No reports on the noise and air quality environments of the proposed development

have been submitted as part of the application. Notwithstanding, there are existing residential uses contained around the site (Streatham High Road, Ardwell Road, Blairderry Road and Barrhill Road) and those currently exist in close proximity of the surrounding commercial uses. In the circumstances there is no evidence to suggest that the development could not provide a suitable noise and air environment for future residents and such matters could be reserved/secured by way of planning condition if the development were considered acceptable in all other respects.

Amenity Space and Children’s Play Space Provision

7.3.14 With respect to amenity space the council’s SPD on Housing Development and

House Conversions sets out that for new flatted developments, shared amenity space of at least 50sqm per scheme should be provided. A further 10 sq m per flat should also be provided, either as a balcony, terrace or private garden or consolidated with the communal space. For a development inclusive of 69 residential units, the council’s SPD would require an amenity space provision of some 740sqm in total – at least 50sqm of which should be communal space.

7.3.15 London Plan Policy 3.6 sets out that boroughs should ensure developments that

include housing make provision for play and informal recreation, based on the expected child population generated by the scheme and an assessment of future needs. Policy S2 of the Core Strategy also sets out the presumption that developments should provide outside space for children’s play in private and communal gardens.

7.3.16 Using the methodology within the Mayor’s supplementary planning guidance ‘Providing for Children and Young People’s Play and Informal Recreation’ it is anticipated that there will be approximately 22 children within the development. The guidance sets a benchmark of 10sqm of useable child playspace to be provided per child, with under-5 child playspace to be provided on-site. In this context the guidance would expect that the development makes provision for 220 sqm of play space; of which at least 70 sqm should be provided on site for children under 5. It should be noted that Lambeth’s SPD is explicit in that the delivery requirements for children’s play space provision should be considered as part and parcel of the overall amenity space provision for the site, and not over and above.

7.3.17 The scheme proposes amenity space throughout the site comprising of private gardens, a communal space to the rear including a children’s play area, private balconies and roof terraces. The combined total of amenity space that would be provided is 995 sqm. This is considerably over the minimum of 740 sqm which the council’s SPD would dictate a residential development of this quantum should provide, and is considered to be a generous provision.

7.3.18 The applicant has committed to provide 70 sqm of on site play space for under 5s,

which could be secured via condition. 7.3.19 With regard to play and recreation space for over 5s, the development would be

reliant upon local facilities off site. In such circumstances the council would generally expect a financial contribution towards mitigating the impact of the development upon those spaces. At the time of writing the applicant had not agreed to this contribution.

Residential Quality Conclusions

7.3.20 Concern is raised with regards to the levels of daylight and sunlight that would be

received to the residential units of the development. This lends further weight to resisting the scheme.

7.3.21 In all other regards, the development would provide an acceptable standard of

residential accommodation subject to conditions and to a s106 contribution towards improving local play and recreational spaces for over 5s so as to enable the development to forego on-site provision of such. It is advised however that the s106 package of mitigation has not been agreed at the time of writing.

7.4 Design, Conservation Area and Listed Building Considerations 7.4.1 Officers have assessed the proposals in relation to national, strategic and local

policy guidance contained within Planning Policy Statement 1 (PPS1), Planning for the Historic Environment (PPS5), London Plan Policies, Saved UDP Policies and the Adopted Core Strategy. Government guidance promotes the creation of more sustainable residential environments and puts the application of urban design principles and practices at the heart of making better, more 'liveable' places. PPS1 states that high quality and inclusive design requires carefully planned, high-quality buildings and spaces that support the efficient use of resources.

Scale and Massing, and integration with the surrounding townscape 7.4.2 The previous application (08/04609/FUL) was refused as being contrary to the now

Saved UDP Policy 33, as the height and bulk of the proposed buildings were deemed to have been excessive and over dominant, with the result that the development would have appeared particularly overbearing from the properties on Blairderry Road.

7.4.3 The current scheme would be an L shaped building, following the contour created

by Ardwell, Blairderry and Barrhill Roads, consisting of a series of conjoined blocks ranging from three to six storeys in height with a courtyard within. Along Blairderry

Road the main front elevation would be three-storeys in height and set back from Blairderry Road by between 2 and 3m. A four-storey element above would run along the majority of the Blairderry Road frontage, but with a gap opposite of No’s 38 - 42 Blairderry Road. These fourth storey elements would be set back from the ground floor frontage by 3m (the southern element) and 7-8m (the northern element). Two fifth storey elements would be provided: the first located centrally along the Blairderry Road elevation but stepped a further 2.5m back from the lower floor (5.6m from the three storey element along Blairderry Road); and the second located to the south of the site along the Ardwell Road Elevation and stepped back 14.5m from the three storey element presenting to Blairderry Road. A further sixth storey element would sit at the south of the site, set back by a total of 15m from the Blairderry Road building frontage and 2m from the Ardwell Road building frontage.

7.4.4 The site straddles a town centre and as such the surrounding townscape has a

variety of massing, scales and uses. Large, deep plan buildings front the High Road, with considerable visual prominence; such as the Megabowl and Riva Bingo building. Blairderry Road with Killeiser Avenue behind present lower and much more modest residential buildings. This townscape contrast represents a challenge in design terms.

7.4.5 The massing described above represents amendments to the scheme refused

under application 08/04609/FUL. The principle changes to the massing are alterations to the set-back of the upper floors, the removal of a fifth floor element to the north of the site and the introduction of a sixth floor element to the south of the site.

7.4.6 The massing on Ardwell Road has increased by one storey over the previous

scheme. This is to accommodate massing lost from the scheme on the Blairderry Road frontage. This six storey element along Ardwell Road is considered to be acceptable considering the scale of many of the nearby buildings and in light of the approved Megabowl development which would stand opposite the site at six to eight storeys along the majority of Ardwell Road.

7.4.7 In terms of the principal three-storey frontage to Blairderry Road, the overall

massing is broadly similar to the previous scheme and its impact upon the townscape and buildings opposite would therefore likely be very similar. The third and fourth floors are set back a similar distance from the Blairderry Road frontage as was presented in the previous scheme, with the principle difference being the removal of a fifth-storey element on the northern most element of this frontage, and the addition of a sixth-storey element on Ardwell Road.

7.4.8 It is considered the application scheme successfully breaks up the massing on the

upper floors and provides gaps in massing so as to avoid a continuous five storey element being presented to the Blairderry Road townscape. Whilst these setbacks and amendments described above are subtle when compared to the previous refused scheme, the overall set backs are significant and would serve to significantly diminish the impact of these upper floors when viewed from the immediate streetscene. It should be taken into account that these changes have removed elements of massing away from the Blairderry Road frontage and towards Ardwell Road elevation opposite the Megabowl site where there would be

little impact in terms of juxtaposition of scale (both in terms of the existing Megabowl structure and the extant permission).

7.4.9 The entire Blairderry Road frontage would not be uniform in its building line, with

set backs serving to prevent it from being viewed as monolithic. The entire building would be set back from the footway by a distance of 2-3m, with the central section recessed, which would further serve to mitigate its impact. The significant set backs of the upper floors behind the three-storey elements would ensure that these elements would not appear overly prominent or overbearing when viewed from the streetscene. Whilst the upper floors would not be completely obscured behind the three storey element, the set backs and changes in massing from the previous scheme are considered to be sufficient to overcome the concerns previously raised.

7.4.10 The massing, with the taller elements situated to the east and south of the site,

stepping down in scale to three storeys towards Blairderry Road, and with the upper two storeys considerably set back, is considered to be appropriate and sensitive response to the varied scale and massing of the townscape context. This site is within the core area of the Streatham Hill Town Centre which comprises a variety of building types and scales. Although larger than the residential properties across Blairderry Road, the schemes’ massing is considered to be an appropriate and logical response to its setting.

7.4.11 In determining this application, Members should have regard to the planning

permission granted in 2010 for the adjacent Megabowl site (reference 10/00507/FUL), which is considerably greater in scale and massing than this proposal and which was not considered by officers or committee to be overbearing to the residential properties on Blairderry road or the townscape in general.

7.4.12 Design officers consider that in terms of scale and mass, the current scheme is an

improvement to the previously refused scheme (08/04609/FUL). Taking the above into account officers consider that the proposed massing of the development is acceptable in terms of the general townscape, and that the previous reason for refusal has been overcome.

Detailed design and materials 7.4.13 The principle elevational treatment proposed for the lower floors is London Stock

brick. Within the brick façade, balconies are proposed along with bedroom windows which would be grouped within panels of grey cladding. The recessed upper floors would be clad in aluminium, with balustrading serving roof terraces. Windows would be articulated in a relatively simple and consistent manner, following horizontal and vertical columns.

7.4.14 London Stock brick is considered to be an appropriate and durable material that

respects much of the surrounding built form. Whilst the aluminium and cladding proposed would be of a more contemporary appearance, it is not objected to as it is not out of place with some of the more modern additions and approvals within the nearby townscape.

7.4.15 The relatively simple and uniform rhythm of windows and cladding proposed throughout the lower floors would serve to break up the articulation of these facades and prevent them from appearing overly bland or monolithic. This would be helped on Blairderry Road by the variation in the building line and the set back of the central section of this façade.

7.4.16 The Council’s Urban Design officer has expressed some concern with regards to

the detailed design of the scheme. There is unease regarding under-proportioned windows and the proposal’s relationship to its context. However, on balance it is considered that the architecture is not of such poor quality so as to justify a reason for refusal; especially where relatively minor design alterations could add interest and greater articulation to the facades. String courses, lintels or banding for example could very easily be integrated into the scheme and further measures to improve the detailed architectural design could be explored by way of suitably worded planning conditions so as to improve the overall design quality of the scheme.

Impact upon Heritage Assets 7.4.17 The Streatham High Road and Streatham Hill Conservation area abuts the site to

the east, north and south. No part of the site is within the Conservation Area. To the east of the Streatham High Road sits the Leigham Court Estate Conservation Area, whilst the Telford Park Conservation Area sits behind Blairderry Road to the west.

7.4.18 The proposed structure would be seen from the Streatham Hill Conservation Area

when standing on the High Road and looking down Ardwell and Barrhill Roads. However, the massing and height of the proposed structure on these elevations would be similar to the buildings it would stand opposite, whilst the façade treatments have been kept simple to avoid there being any clash with regards to the relatively plain facades opposite. It is considered that the addition to the townscape of the proposal would not harm the setting of the Streatham Hill Conservation Area or harm views into or out of this Conservation Area.

7.4.19 The scale and form of the proposal would have no material impact on any public

views into or out of the Telford Park or Leigham Court Conservation areas. 7.4.20 The Streatham Hill Theatre (Grade II listed) is an unusually lavish example of a

theatre built in the short-lived revival of building in 1929-30. Whilst the Streatham Hill elevation is elaborate with a loggia which is a full height wing with a decorative wreath set within a classical pediment, the flank and rear elevations are more utilitarian, faced in pale brick with metal framed windows. The layout of the proposed site results in only the rear south west of the theatre sitting directly opposite the proposed building on Barrhill Road. The proposed building would be subordinate in height to the listed structure, and would not block important views onto the cinema whose flank elevations are not of special interest. The treatment of the proposed façade in this location is simple and unfussy, and is considered appropriate as it would in no way draw attention away from the setting of the listed building opposite.

7.4.21 Officers are therefore satisfied that the development would not prove unacceptably harmful to any heritage assets within the vicinity of the site.

7.5 Energy and Sustainability 7.5.1 All major development should achieve a reduction in carbon dioxide emissions in

line with London Plan targets through energy efficient design, decentralised heat, cooling and power systems, and on-site renewable energy generation.

7.5.2 The London Plan requires developments to make the fullest contribution to tackling

climate change by minimising carbon dioxide emissions, adopting sustainable design and construction measures and prioritising decentralised energy, including renewables. Policy 5.2 sets out a minimum target reduction for carbon dioxide emissions in buildings of 25% over the Target Emission Rates outlined in the national Building Regulations. The London Plan sets out that development proposals should contribute to this by minimising carbon dioxide emissions in accordance with the “be lean, be clean, be green” hierarchy:

W Be Lean: The reduction of energy demand and CO² emissions from using less

energy, in particular by adopting sustainable and passive design and construction measures;

W Be Clean: Proposals for the reduction of energy demand and CO² emissions through supplying energy efficiently;

W Be Green: Renewable energy technologies to be incorporated. 7.5.3 Policy 5.7 of the London Plan seeks to increase the proportion of energy generated

from renewable sources. There is a presumption that all major development proposals will seek to reduce carbon dioxide emissions by at least 20 per cent through the use of on-site renewable energy generation wherever feasible.

7.5.4 The application submissions set out that the proposed ‘Be Lean’ energy efficiency

measures would reduce carbon emissions to 5.1% below baseline emissions. For ‘Be Clean’ measures, a CHP plant has been discounted as unviable based on the small hot water demand created by the development. ‘Be Green’ measures would involve solar Photo-Voltaic panels located on roofs across the application site which would provide a 20.1% reduction over and above ‘Be Lean’ measures. The application submissions therefore set out that the development would achieve a minimum target reduction for carbon dioxide emissions of 25.2% over the Target Emission Rates outlined in the national Building Regulations. This exceeds the London Plan targets of 20% and 25% for renewables and overall savings respectively.

7.5.5 Lambeth’s adopted “Sustainable Design and Construction” SPD sets out the

minimum standards to be met for various types of development. The minimum standard for residential development is Code for Sustainable Homes Level 3. For non-residential elements BREEAM ‘Very Good’ is expected as a minimum.

7.5.6 It is proposed that all private homes would be designed to meet at least code level

3 of the Code for Sustainable Homes. The non-residential uses would achieve

BREEAM very good standards. Such commitments could be secured by planning condition.

7.5.7 It should be noted that the Streatham Master Plan sets out an expectation for

developments to achieve Code for Sustainable Homes Level 4 or BREEAM Excellent. Officers are mindful however that the Streatham Master Plan has not been adopted as Supplementary Planning Guidance as part of the Local Development Framework and, as such, the development’s failure to achieve the standards set out therein should not weigh heavily against granting planning permission.

7.5.8 The proposed measures would ensure that the application is policy complaint with

regards to reducing carbon emissions and sustainable design and construction. Were the development considered acceptable in all other respects, the matters could be ensured by the use of planning conditions and s.106 obligations.

7.6 Neighbouring Amenity 7.6.1 Policy 7 of the UDP sets out that the right of people to the quiet enjoyment of their

homes will be respected. Policy 33 of the UDP sets out that building scale and design should protect the residential amenity of existing and future residents by having an acceptable standard of privacy; having an acceptable impact on levels of, and impact on daylight and sunlight; not creating unacceptable overlooking; not creating an undue sense of enclosure; and where appropriate, having sufficient outdoor amenity space.

Proposed Uses

7.6.2 The development would not introduce any uses that need prove unacceptably harmful to the residential environment of the locality. The proposed range of uses are all uses that occur and are suitable within Major Shopping Centres and within Streatham. Were the development considered acceptable in all other respects, the council could reasonably impose a planning condition requiring the provision of a management/operations plan for the non-residential uses – especially given the wide spectrum of uses that fall within use class D1 – so as to ensure the protection of neighbouring residential amenity.

Daylight/Sunlight/Overshadowing 7.6.3 The application submissions are inclusive of a daylight/sunlight report. The report

concludes that all neighbouring residential properties would retain levels of daylight and sunlight in accordance with BRE recommended guidelines. Officers have no evidence or reason to dispute those conclusions.

Overlooking and sense of enclosure 7.6.4 1-15 Barrhill Road sits at an oblique angle to the development. The first floor of this

development has west facing flank windows with bedrooms behind, set back by 5m behind a roof terrace which would face the development. It is considered that the proposal has been sensitively designed to avoid any instances of unnecessary or

unacceptable overlooking into 1-15 Barrhill Road. Conditions of consent could ensure any windows facing this property are obscurely glazed and high opening.

7.6.5 The primary ground, first and second storey elevation of the development would sit

at 21m from the nearest facing windows in the residential properties across Blairderry Road. The third and fourth floors would be set back further. A mixture of bedrooms, living rooms and balconies would face the properties on Blairderry Road. Within the current proposal the upper two floors have been cut away in elements and set back from the Blairderry Road elevation. It is considered that the proposed building would ensure suitable enclosure and passive surveillance to the street, without appearing unduly overbearing to, or unacceptably reducing the privacy of, the residential properties opposite.

7.6.6 The development is designed so that the closest windows that would face the rears

of the upper floors of 112-140 Streatham Hill would have a minimum separation from one another of at least 25m. This is considered adequate to avoid any instances of unnecessary or unacceptable overlooking for these properties. The distance of 25m is considered acceptable in relation to the scale of the proposal to ensure that no sense of enclosure occurs for any of these properties.

Impacts During Construction

7.6.7 It is inevitable that there would be an element of noise, disturbance and inconvenience during the construction period. Notwithstanding, this would not prove reason to resist the development. A range of measures could minimise such impacts as far as is reasonably practicable, including the preparation and implementation of a Construction Management Plan and a construction Logistics Plan. If the development is considered acceptable in all other respects, such matters could suitably be dealt with by way of planning conditions.

Neighbouring Amenity Conclusion

7.6.8 It is considered that, subject to conditions, the development would not given rise to

conditions unacceptably prejudicial to the levels of amenity currently experienced at neighbouring residential properties so as to conflict with the relevant policies of the development plan; namely UDP Policies 7 and 33.

7.7 Secure by design 7.7.1 In this instance, the council’s Crime Prevention Design Advisor has reviewed the

scheme and raises no in principle objections to the development proposed. In addition, the application submissions commit the development to the achievement of Secured By Design Standards; which could be ensured by way of planning condition. It follows that the development need not fail against UDP Policy 32 or Core Strategy Policy S9 (f).

7.8 Archaeology 7.8.1 English Heritage has raised no objections to the application, subject to the

archaeological position being reserved by way of attaching a condition to any

consent granted. Officers accept English Heritage’s advice. In this regard the development need not fail against the objectives of Policy S9 of the Core Strategy.

7.9 Contaminated land 7.9.1 The planning application is accompanied by a geo-environmental investigation,

inclusive of a preliminary assessment of contamination issues. The report includes various recommendations related to the treatment and removal of contaminants. Were the development considered acceptable in all other respects, officers would have recommended conditions of consent to ensure suitable measures of mitigation – in accordance with the recommendations of the submitted investigation and the objectives of PPS23 (Planning and Pollution Control).

7.10 Bio-diversity/Ecology 7.10.1 The existing site has limited bio-diversity value. Subject to suitable conditions and

s.106 obligations, officers are accepting that the redevelopment of the site need not prove unacceptably harmful to any bio-diversity features of acknowledged value and that opportunities could be secured to improve the bio-diversity value of the site and of the surrounding open spaces. It follows that the development need not fail against UDP Policy 39 and Core Strategy Policy S5 in these regards.

7.11 Transport and Highways issues

Site & Accessibility 7.11.1 The site is well served by public transport with Streatham Hill Rail Station located

approximately 200m to the south of the site and several routes accessible from Streatham Hill. The site has a PTAL of 6a which is the second highest possible on the PTAL scale.

Trip Generation 7.11.2 In this instance officers accept that the trip generation associated with the

proposed development would unlikely have any significant impact on the operation or safety of the surrounding highway network.

7.11.3 Officers recognise that given the wide spectrum of uses that fall within D1 of the

use classes order, without details of an end user it is difficult to properly consider the transport impacts associated with such a use. Notwithstanding, it is the case that a condition of consent could require a management plan for the future uses of the premises to be submitted for the council’s approval – at which time the council could refuse consent for any specific activities which may prove unacceptably harmful to the highway network.

Car Parking 7.11.4 A total provision of 20 off-street car parking spaces are proposed within the

basement, 6 of which are disabled spaces. It is stated by the applicant that 13 of these spaces would be allocated to the family sized units (3 & 4 bedroom). This

level of provision is in accordance with London Plan policy. However, it is also necessary to consider how the proposed development would impact upon on-street car parking levels with existing concerns over the current parking situation and a very large consented development of 250+ flats and significant commercial floorspace on the adjacent site.

7.11.5 It is also the case that provision for electric vehicles within the scheme could be

secured by way of planning condition so as to ensure compliance with London Plan Policy requirements in this regard.

On-street car parking & parking stress

7.11.6 The site is not situated within a Controlled Parking Zone (CPZ). There are double

red line parking and waiting restrictions on Streatham Hill which prevent parking; but there are no such parking restrictions on surrounding local roads such as Blairderry Road, Barrhill Road and Ardwell Road.

7.11.7 Having regard to available census information regarding car ownership levels in

Streatham Hill and to the submitted transport assessment, officers project that this development would potentially generate 52 cars requiring parking. Of these 52 cars, only 20 could be accommodated within the basement car park.

7.11.8 Parking surveys were undertaken by the applicant in November 2010. The surveys

were completed in accordance with the council procedure for such and showed the overall parking stress within the wider area at around 70%. For information it is worth noting that the parking stress on the adjoining streets of Blairderry Road (68%), Barrhill Road (55%) and Ardwell Road (40%) are significantly lower than the wider area’s average. It is also however worthy of note that since the 2007 parking surveys undertaken for the nearby Megabowl development, average parking stress in the area has increased by 8% from 63%. This suggests that car ownership levels in the area are steadily increasing. If the projected additional 32 cars are added to the current situation, overnight occupancies of 78% and 79% are derived.

7.11.9 The council’s transport planner however advises that having regard to the recently

consented Megabowl scheme and the trend for increased car ownership levels in this area, this data can not be relied upon as an accurate reflection of future parking pressures in this area; with parking stress certain to become an issue if either one and certainly if both schemes were to be implemented without robust mitigation put in place.

7.11.10 With the Megabowl scheme this robust mitigation comprised of a financial

contribution of £30k for the proper and reasonable costs of monitoring the parking situation by means of on-street parking surveys; payment to enable CPZ consultation if the situation was deemed to have changed significantly; and the covering of the costs of implementing a CPZ should the consultation favour this approach. These latter two aspects were not costed within the s106. Further to this it was also determined that if a CPZ were to be introduced in to this area at any future date residents of the development would not be eligible for parking permits.

7.11.11 In the circumstances, Lambeth’s Transport Planner supports the scheme provided that a similar package of mitigation is secured to that which was secured at the adjacent Megabowl scheme – especially where the council has no guarantee that the Megabowl scheme will come forward. Discussions in this regard will be ongoing with the applicant in advance of the Public Inquiry.

Cycle Parking

7.11.12 Cycle parking is proposed at various locations throughout the site with the majority (50) in secure storage areas in the proposed basement car park, but with further cycle parking spread throughout the communal areas on the ground floor. The relevant London Plan standards are met and it is considered that the proposed provision is acceptable. Such could be secured by way of planning condition.

Car Club

7.11.13 Were the development considered acceptable in all other respects, it would be expected that the applicant should contribute £6,500 towards the creation of on-street car club bay in the vicinity of the site. Further to this, the applicant would be expected to provide free membership of a car club to residents of the development for a period of two years. Such measures would reduce reliance on the private car and contribute to sustainable travel objectives that should be included within the travel plan for the development.

Highway Alterations

7.11.14 The site is currently served by two crossovers, one from Ardwell Road and one from Barrhill Road. It is proposed that both of these would be stopped up and a new vehicle entrance would be created on Blairderry Road to serve the basement car park. This would form the only means of vehicle access on to the site.

7.11.15 The stopping up of the redundant crossovers would provide additional on-street car

parking space that would off-set any parking lost through the creation of the new access on Blairderry Road. It is advised that the applicant would have to meet all costs associated with these works including any traffic orders necessary. The final design of the new access would need to be submitted to the Council prior to implementation.

Servicing

7.11.16 The proposed basement would not be big enough to accommodate large vehicles so all servicing and deliveries would have to be carried out on-street. With the final use of the commercial unit being undecided, assessment has been made on the basis that those would be A1 food retail units. Whilst 272sqm is fairly small for this type of use, previous sites of similar size (such as Tesco Express or Sainsbury’s Local) have been shown to generate up to 5 deliveries from goods vehicles per day. The applicant refers to a proposed servicing bay to be created on Ardwell Road as part of the Megabowl development and the potential for joint use. However, the revised Megabowl application no longer proposes this, with an off-street facility proposed instead. The most appropriate means of providing a

suitable servicing facility would be the creation of a Loading Bay on Ardwell Road and this would require a Traffic Order, line marking and signage. Lambeth Transport Planners do not object to the principle of this arrangement. A Servicing and Deliveries Management Plan could also be secured by way of planning condition so as to minimise any potentially adverse impacts in this regard.

7.11.17 The applicant proposes that refuse collection would be undertaken from the

kerbside and this is also considered acceptable. Environmental Improvements

7.11.18 Given the scale of the scheme and the expected multi-modal trip generation, comprehensive highways improvements are required along Blairderry Road, Ardwell Road, Streatham Hill and Barrhill Road. Works should include (although not be limited to) upgrading footways, carriageways, removing/reinstating crossovers, upgraded kerb and channelling. The adjacent Megabowl development contributed £440,000 to these type of works and it is considered appropriate that this development should contribute £110,000 to highway improvements in the vicinity.

Travel Plan

7.11.19 A Travel Plan would be required for the residential element of the proposals and this should be prepared in accordance with TfL’s latest travel plan guidance or subsequent amendment. Such matters could be secured by way of s106 agreement.

Transport and Highways Conclusion

7.11.20 There are reservations with respect to the extent of overspill parking associated with the residential component of the scheme, and the subsequent impact that could result to parking stress on the surrounding highway network. To overcome those reservations, a range of mitigation measures to limit car use would need to be agreed to and implemented.

7.11.21 In all other respects, subject to conditions and s106 mitigations, it is considered

that the development would not conflict with highways and transport related policies of the Development Plan; namely UDP Policies 9 and 14 and Core Strategy Policy S4.

7.12 Waste 7.12.1 Refuse storage areas have been provided at ground floor adjacent to the entrance

cores of each of the blocks of the development. They appear to have been sized and located so as to accord with the requirements set out in the council’s guidance for such. Were the development considered acceptable in all other respects, a condition of consent could secure the provision as shown and also the provision of a waste management plan with respect to the non-residential uses of the site. It follows that the development need not conflict with Core Strategy Policy S8.

8. Planning Obligations 8.1 The Community Infrastructure Levy Regulations 2010 explicitly set out that

planning permission should only be granted subject to completion of a planning obligation where the obligation meets all of the following tests. A planning obligation should be: (i) necessary to make the development acceptable in planning terms; (ii) directly related to the development; and (iii) fairly and reasonably related in scale and kind to the development.

8.2 Policy S10 of the Core Strategy sets out the circumstances in which planning

obligations will be expected from developers. 8.3 With specific regard to Streatham, Policy PN4 of the Core Strategy sets out that

the various infrastructure improvements, public realm, education and other community premises and other improvements associated with the impact of development will be secured through planning obligations.

8.4 The Council’s adopted SPD on planning obligations sets out the circumstances

where monies towards community infrastructure would generally be expected and a framework for calculating amounts that would likely be sought.

8.5 Were the development considered acceptable in all other respects, having regard

to the council’s SPD and the various consultation responses received, a development of this nature would likely require the following mitigation:

• Securing of the affordable housing;

• Traffic and Highways contribution of £110,000 for highways improvements to Streatham Hill, Blairderry Road, Barrhill Road and Ardwell Road;

• The making good of the redundant vehicular accesses;

• The provision of a servicing bay on Ardwell Road;

• £6,500 to enable the provision of an on-street car club bay in the vicinity of the site;

• In addition, free membership of a car club to residents of the development for a period of two years;

• Travel Plan Submission and a monitoring fee of £1,000;

• Primary Schools Contribution of £98,715;

• Secondary Schools Contribution of £51,758;

• Libraries Contribution of £8,840;

• Indoor sports and leisure facilities contribution of £32,968;

• Local Labour in Construction Contribution of £19,790;

• Local Labour in Construction Commitments: Promotion of opportunities for local residents

• General Employment and Training Contribution of £16,934;

• Parks and Open Spaces Contribution of £81,640;

• Revenues Contribution of £10,245;

• Play Space Contribution of £13,927;

• Monies to fund pre-implementation and post occupation on-street parking surveys (£30k for the surveys), reasonable costs of CPZ consultation if the situation was deemed to have changed significantly and finally reasonable

costs for the implementation of a CPZ should the consultation favour this approach;

• Monies towards Public Art in the vicinity of the site – the council’s s106 toolkit would suggest a sum of £79k;

• The securing of a Sustainability and Energy Strategy, in line with the application submissions and to ensure reductions of carbon dioxide emissions 25% in excess of minimum building regulations requirements; and

• S106 Monitoring fee of £11,194.

8.6 At the time of writing, discussions regarding the s106 package were on-going. The applicant has not committed to the levels of mitigation set out above. The applicant has not objected in principle to the financial contributions being sought, but has asked for more detailed information to be provided on the infrastructure projects that would be funded. In the circumstances, as no s106 has been presented at this time that would suitably mitigate the otherwise unacceptable impacts of the development officers are recommending that the lack of mitigating measures should form a further reason for refusal; albeit subject to further discussions and potential agreement on the matters in advance of the Public Inquiry.

9. Conclusion

9.1 The scheme proposes the redevelopment of the site, involving the demolition of all

of the existing buildings on the site and the construction of a building ranging from three to six storeys in height to provide 69 residential units, 272 sqm of commercial floorspace space (A1, A2, B1 and/or D1), basement car parking with access onto Blairderry Road and associated landscaping.

9.2 Although the proposals would deliver 69 residential units (including an element of

affordable housing), officers do not consider that the ebenfitsof the scheme outweigh the unacceptable loss of existing and potential employment generating land/floorspace to the detriment of employment provision within the Borough. In this latter respect the proposal is contrary to Saved Unitary Development Plan Policy 23 and Core Strategy Policy S3.

9.3 Furthermore, the proposed affordable housing mix is heavily skewed towards the

provision of intermediate units. As such, the development would not appropriately seek to address Lambeth’s priority housing need and is in conflict with Policy S2 of the Core Strategy.

9.4 The development would provide several residential units which would fail against

BRE recommended guidelines for daylight and sunlight, with one unit in particular demonstrating severe failings. The units demonstrating failings against the BRE guidelines would experience less than high standards of residential amenity in conflict with Core Strategy Policy S2 (h).

9.5 In addition, at this time no s106 agreement has been finalised with regards to the

scheme. In the absence of appropriate planning obligations under s106 of the Act, the development would fail to: Provide the maximum reasonable amount of affordable housing in perpetuity; Suitably mitigate against its potential impact upon local/community infrastructure; Suitably mitigate against its likely impact upon the

function, operation and safety of the highway network; Encourage future residents of the development to use public transport and other methods of transport other than the private motor car so as to reduce the likelihood of car ownership, giving rise to a likely unacceptable increase in on-street parking stress in the vicinity of the site where no parking controls currently exist; Secure sufficient commitment towards promoting local labour opportunities within the construction of the development; Provide mitigation against the loss of the employment floorspace; and Secure a suitable Sustainability and Energy Strategy for the development. Officers are therefore recommending that the lack of mitigating measures should form a further reason for refusal; albeit subject to further discussions and potential agreement in advance of the Public Inquiry.

10. Recommendations

A. Advise the Planning Inspectorate that the Local Planning Authority would have refused planning permission for the following reasons:

1. The proposed development would result in the loss of existing and potential

employment generating land/floorspace to the detriment of employment provision within the Borough. As such, the proposal is contrary to Saved Unitary Development Plan Policy 23 and Core Strategy Policy S3.

2. The proposed affordable housing mix is heavily skewed towards the provision of

intermediate units. As such, the development would not appropriately seek to address Lambeth’s priority housing need and is in conflict with Policy S2 of the Core Strategy.

3. In the absence of appropriate planning obligations under s106 of the Act, the

development would fail to:

- Provide the maximum reasonable amount of affordable housing in perpetuity; - Suitably mitigate against its potential impact upon local/community infrastructure; - Suitably mitigate against its likely impact upon the function, operation and safety of the highway network; - Encourage future residents of the development to use public transport and other methods of transport other than the private motor car so as to reduce the likelihood of car ownership, giving rise to a likely unacceptable increase in on-street parking stress in the vicinity of the site where no parking controls currently exist; - Secure sufficient commitment towards promoting local labour opportunities within the construction of the development; - Provide mitigation against the loss of the employment floorspace; and - Secure a suitable Sustainability and Energy Strategy for the development.

The development would therefore be contrary to Unitary Development Plan Policies 4, 9, 14, 23, 26, 35, 39 and 50 and Core Strategy Policies S1, S2, S3, S4, S5, S7, S9, S10 and PN4.

4. The development would provide several residential units which would fail against BRE recommended guidelines for daylight and sunlight, with at least one unit demonstrating severe failings. The units demonstrating failings against the BRE guidelines, particularly those demonstrating severe failings, would experience less than high standards of residential amenity in conflict with Core Strategy Policy S2 (h).

B. In addition, officers are granted delegated powers to negotiate further with

the applicant and respond to any submissions as officers deem appropriate, both in the lead up to and during the Public Inquiry.

NB: This would allow officers to potentially concede certain of the grounds should they be satisfied in those regards following further discussions, submissions and agreements.