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PLANNING COMMITTEE AGENDA 14 May 2015

PART 7: Planning Applications for Decision Item 7.2

1 APPLICATION DETAILS

Ref: 14/05299/P Location: Roman House, 13-27 Grant Road, Croydon, CR9 6BU Ward: Addiscombe Description: Demolition of existing buildings; erection of buildings ranging from 2 to

4 storeys in height comprising 28 two bedroom, 23 one bedroom and 15 three bedroom flats and 6 four bedroom houses; formation of access road and provision of associated car parking, open space, landscaping and infrastructure works.

Drawing Nos: 1510_0005 Rev B, 1510_0020 Rev A, 1510_0021 Rev A, 1510_0100 Rev T, 1510_0101 Rev S, 1510_0102 Rev R, 1510_0103 Rev S, 1510_0105 Rev K, 1510_0200 Rev H, 1510_0201 Rev H, 1510_0202 Rev H, 1510_0203 Rev H and 1510_0158

Applicant: Bellway Homes (South East) Agent: Miss Thomson, Savills Case Officer: Greg Blaquière

1.1 This application is being reported to committee because the development is a Large Major development, the Ward Councillor (Cllr Sean Fitzsimons) has made representations in accordance with the Committee Consideration Criteria and Chair of Planning Committee (Cllr Paul Scott) has requested Planning Committee consideration.

2 BACKGROUND

2.1 This scheme was presented to Planning Committee during the pre-application process on 8 October 2014 and 4 December 2014. The following comments were raised by the committee during those presentations:-

8 October 2014 • Amenity provision at ground level and interaction with vehicular traffic • Question over 50% parking provision for an area with good public transport links -

opportunities to increased green space and communal play space instead of car parking

• Stressing the issue of the non-acceptability of a reduced level of affordable housing (26.5%) bearing in mind that the minimum provision is now 30% affordable housing

• Whether the proposed relatively low density of housing in a high density area needs to be reviewed for viability in order to provide scope for more units, maximise potential and enhance design

• Whether balance between family and other housing was correct • Whether the old station wall was to be retained as a heritage asset or whether it

has a negative effect and reduces permeability of the site and links to open green space. Barriers to removal as ownership not known and need to explore ownership with BR Holdings or alternatively a CPO by the Council

• Retention of old station wall - it should be noted that whilst the ownership of the wall is in question, there was a suggestion that the previous developer of the site adjacent to the wall was Bellway Homes (the current developer of Roman House)

• Consideration of Public Art as the proposals properly reference the old Station and East India Estate

• Relationship between the block of flats and the blank wall to properties fronting Grant Road (with an understanding around constraints)

• Use of roof space for amenities or renewable energy • The type of provision for private amenity space (balcony space and family

gardens) • Considerations of privacy for glass balconies and potential for creativity and

public art December 2014 • Low percentage of affordable housing (21%) • Affordable housing mix - family homes required • Lack of awareness of public consultation - even by local ward Members • Retention of solid wall • Maintenance of the wall - concern about finding out who owns the wall • Parking - getting the right balance between hard and soft landscaping • Moderate PTAL rate but has good connections to transport links; parking

provision to be considered • Lack of reasonable green spaces for playing • Look and design has progressed well • Creation of private amenity spaces • Play facility - high quality, useable space for children

3 SUMMARY OF KEY REASONS FOR RECOMMENDATION

3.1 The principle of residential development is acceptable.

3.2 The development would provide a high quality design. The form and massing is appropriate for the context.

3.3 The development would not result in significant harm towards the residential amenities of adjoining occupiers.

3.4 The development would provide satisfactory living environment for future occupiers. Each unit would accord with London Plan & National Space Standards for minimum floor space. Child’s play space would be located within the development.

3.5 The development would provide an acceptable level of on-site parking. Future residents would be restricted from obtaining parking permits for surrounding roads.

3.6 The development would provide a policy compliant amount of affordable housing.

4 RECOMMENDATION

4.1 That the Committee resolve to GRANT planning permission subject to:

A. The prior completion of a legal agreement to secure the following planning obligations:

a) Affordable housing b) Parking permit restrictions for future residents c) Any other planning obligations considered necessary by the Director of

Planning

4.2 That the Director of Planning is delegated authority to negotiate the legal agreement indicated above.

4.3 That the Director of Planning is delegated authority to issue the planning permission and impose conditions and informatives to secure the following matters:

Conditions

1) Details to be submitted, approved and retained; finished floor levels, boundary walls and fences, cycle storage for the houses; electric vehicle charging points; privacy screens

2) Garden and communal areas; parking arrangements; turning space; visibility splays provided as specified and retained.

3) Landscaping scheme including play space to be submitted 4) Materials to be submitted 5) Public art to be provided 6) Block C 2nd floor north facing windows to be obscure glazed 7) Contaminated land 8) Construction Logistics Plan 9) Lifetime homes compliance 10) 35% CO2 reduction above Building Regs Part L 2013 11) Development to commence within 3 years 12) Any other planning condition(s) considered necessary by the Director of

Planning Informatives

1) S106 agreement 2) Community Infrastructure Levy 3) Party wall 4) Code of conduct for construction sites 5) Site notice removal 6) Thames Water 7) Any other informative(s) considered necessary by the Director of Planning

4.4 That, if by 14 August 2015 the legal agreement has not been completed, the Director of Planning is delegated authority to refuse planning permission.

5 PROPOSAL AND LOCATION DETAILS

Proposal

5.1 The proposal can be summarised as follows:

• Demolition of existing buildings on site

• Erection of 3 four storey blocks (Blocks A, B & D), 2 three storey blocks (Blocks C & E) and 6 two storey terraced houses buildings comprising a total of 72 units;

• 23 x one bedroom flats

• 28 x two bedroom flats

• 15 x three bedroom flats

• 6 x four bedroom houses

• Approximately 160% affordable housing provided on net increase of floor space (Vacant Building Credit applied); 11 apartments (Block E).

• Vehicular access from Grant Road

• 22 car parking spaces (including 7 available for wheelchair users)

• Associated landscaping and play space

Site and Surroundings

5.2 The site is located on the north western side of Grant Road. It is occupied by a three storey office building, three warehouses, garages, yard and car park. It has recently been made vacant (December 2014). It is irregular in shape and relatively level.

5.3 The surrounding area is residential in character. To the north and west of the site is the East India Way Estate which consists of modern two and three storey terraced houses and three storey blocks of flats. The estate was erected on former railway land. There is a substantial brick wall (5m in height), formerly part of the railway boundary separating the site from East India Way (adjacent to the north-western boundary of the application site). This wall is outside of the application site.

5.4 To the east the site adjoins two storey terraced dwellings on Grant Road. To the south of the site is a three storey block of flats leading towards the junction with Lower Addiscombe Road. Opposite the site is a series of three storey blocks of flats and the entrance to Fisher Close (which consists of two 8 storey blocks of flats). Further east along Grant Road (No.’s 14-86 - evens only) is a Local Area of Special Character.

5.5 The East India Estate Conservation Area covers land further south, starting on the southern side of Lower Addiscombe Road and includes Clyde Road, Canning Road, Elgin Road, Havelock Road, Outram Road and Ashburton Road.

5.6 The site is located within an Area of High Density.

Planning History

5.7 The following planning decisions are relevant to the application:

86/1250/P Erection of 4 dwellings, workshop and storage building, four storey extension to offices, extension to workshop and single garage, alterations to offices, formation of access road and ancillary parking.

Outline permission granted.

87/0390/P Erection of 4 three storey houses, 3 with integral garages and 1 with

parking space. Permission granted. 87/0391/P Erection of 3 two storey workshop buildings and two storey security

office. Permission granted. 87/1639/P Alterations and erection of a four storey extension to office building,

formation of access road and ancillary car parking. Permission granted and implemented. 89/2602/P Single storey building for use as staff canteen. Permission granted and implemented. 97/2531/E Use of land associated with main building for the hire, storage, service

and repair of plant, equipment and vehicles. Lawful Development Certificate granted for existing use. 07/1925/P Demolition of existing buildings; erection of 4 buildings comprising 1 x 3

bedroom bungalow; 16 x two bedroom flats and 5 x three bedroom houses; formation of vehicular access and provision of 26 parking spaces. Permission granted subject to S106. S106 remained incomplete.

14/2080/DT Environmental Impact Assessment screening opinion request submitted

for development of site for residential purposes (70 units) Environmental Impact Assessment not required. Enforcement complaints 97/0668/C In September 1997 a complaint was received by the Council’s Planning

Enforcement Team from an adjoining occupier relating to the use of the site for industrial purposes.

Lawful Development Certificate granted (97/2531/E) 97/0856/C In December 1997 a complaint was received by the Council’s Planning

Enforcement Team from an adjoining occupier regarding noise from the site.

Lawful Development Certificate granted (97/2531/E) 98/0448/C In June 1998 a complaint was received by the Council’s Planning

Enforcement team from an adjoining occupier to the site regarding the use and operating hours of the site.

Investigations concluded no breach (97/2531/E)

98/0860/C In November 1998 a complaint was received by the Council’s Planning Enforcement Team from an adjoining occupier to the site regarding excessive use and noise from the site.

01/0910/C In September 2001 a complaint was received by the Council’s Planning

Enforcement team from an adjoining occupier relating to noise and disturbance from this site and that sound insulation had not been provided in accordance with Planning Permission.

Investigations concluded the issue had been resolved.

6 CONSULTATION RESPONSE

6.1 The views of the Planning Service are expressed in the MATERIAL PLANNING CONSIDERATIONS section below.

7 LOCAL REPRESENTATION

7.1 The application has been publicised by way of one or more site notices displayed in the vicinity of the application site. The application has also been publicised in the local press. The number of representations received from neighbours, local groups etc in response to notification and publicity of the application were as follows:

No of individual responses: 9 Objecting: 7 Supporting: 0

7.2 The following Councillors and MP made representations:

• Councillor Sean Fitzsimons [objecting] • Gavin Barwell MP [objecting]

7.3 The following issues were raised in representations that are material to the

determination of the application, and they are addressed in substance in the next section of this report:

Objections

• Buildings are too tall • Poor design • Insufficient affordable housing provision • Design of scheme to ensure minimal affordable housing provided and excessive

parking • Insufficient parking • Loss of privacy to adjoining occupiers on Grant Road and East India Way • Increased noise and disturbance from population density • Increased noise and disturbance from party walls • Inappropriate density & mix; lack of 3 bedroom units, excessive 1 bedroom units • Impact on local infrastructure • Existing use does not cause noise and disturbance issues • Location of plant room potential for noise • Traffic generation • Dangerous external areas with proximity to vehicle access route • Security concerns

• Need for communal cycle storage • Play area insufficient • Noise from construction • Potential damage to foundations from tree planting Supporting comments

• Residential development welcomed • Site has good transport links • Need to retain wall to limit antisocial behaviour and protect privacy

7.4 The following issues were raised in representations, but they are not material to the determination of the application:

• Name of access road to have link to local history (OFFICER COMMENT: Street name/addresses are not part of the planning considerations. In the event of a grant of permission, the request can be forwarded to the relevant department)

• Why the previous application was considered unacceptable (OFFICER COMMENT: Previous application was withdrawn to enable the applicant to continue pre application discussions)

7.5 The following procedural issues were raised in representations, and are addressed

below:

• Lack of consultation with Ward Councillors at pre application stage (OFFICER COMMENT: As part of the pre application process, the applicant undertook consultation including Planning Committee presentations and an exhibition for local residents to attend. It is understood that an administrative error occurred with the invites to the Ward Councillors to the exhibition).

• Financial contributions should be sought for park improvements (OFFICER COMMENT: The development is CIL liable, of which the payment received covers open space as part of the Borough wide Infrastructure Delivery Plan).

8 MATERIAL PLANNING CONSIDERATIONS

8.1 The main planning issues raised by the application that the committee must consider are:

1. The principle of proposed land use 2. Siting, scale and design 3. Housing types 4. Affordable housing 5. Residential amenity 6. Effects on adjoining occupiers 7. Landscaping and amenity space 8. Access and parking 9. Environment and sustainability The principle of proposed land use

8.2 The National Planning Policy Framework (NPPF) states that the purpose of the planning system is to contribute to sustainable development. London Plan 2011

(Consolidated with alterations since 2013) Policy 2.15 supports housing growth through intensification and selective expansion in appropriate locations. Policy 3.3 recognises the pressing need for more homes in London and Policy 3.8 states that Londoners should have a genuine choice of homes.

8.3 Croydon Local Plan 1 Strategic Policy SP1.1 states when considering development proposals, the Council will adopt a positive approach that reflects a presumption in favour of sustainable development. SP1.3 and SP1.4 encourage growth in homes, jobs and services in sustainable places. Policy SP2.1 states the Council will apply a presumption in favour of development of new homes provided applications meet the requirements of policy. Policy SP2.2 seeks to deliver a minimum of 13,300 homes between 2011 and 2021 in line with the London Plan target for new homes. Between 2021 and 2031 it will seek to deliver a further 6,900 homes. Therefore overall, the Council will seek to deliver 20,200 homes over the plan period (2011-2031).

8.4 CLP1 Policy SP3.2 states that the Council will adopt a ‘4-Tier’ approach to the retention and redevelopment of land and premises relating to industrial/employment activity as set out in Table 4.3. Table 4.3 classifies the site as a Tier 4 site thereby permitting alternative B1, B2, B8 uses, employment generating sui generis uses, or D1 (community or education facilities) use (given the PTAL rating). The policy also permits limited residential development if it can be demonstrated that there is no demand for the existing premises or for a scheme comprised solely of the permitted uses (B1, B2, B8, employment generating sui generis uses or D1) and that any proposed residential use does not harm the wider location’s business function.

8.5 Croydon Plan 2006 (Saved Policies 2013) Policy EM5 relates to the retention of industrial and warehousing uses outside designated locations. The policy states that the development for other uses of sites or premises in, or last used for, employment uses will not be permitted unless; (i) the existing use materially harms residential amenity; or (ii) it has been demonstrated that that there is no demand for an appropriate alternative employment use; and (iii) the proposal is for housing or a community use; and (iv) the proposed use would not prejudice the continued use of adjacent employment sites.

8.6 The site is occupied by office and industrial uses. The applicant has submitted details indicating that the site is surplus to requirements and has been vacant since December 2014.

8.7 In consideration of the loss of office use, the General Permitted Development Order 2015 Class O permits the proposed change of use from offices to residential without the need for planning permission (up to May 2016). This is a material consideration based around the objective of Central Government to increase the total housing stock. Any refusal of a planning application not taking account of this permitted development right is unlikely to be supported on appeal. It should also be noted that whilst the Council has proposed an Article 4 Direction restricting the use of such permitted development rights, it only covers the Croydon Opportunity Area and does not extend to this part of the borough.

8.8 In consideration of the loss of warehouse/industrial use planning permission was granted in 2008 (ref: 07/01925/P) for residential development on part of the site occupied by the warehouse/industrial use on the basis of noise and disturbance caused by the existing use. This was in accordance with Croydon Plan 2006 Policy EM5 which permits the loss of industrial/warehousing uses where residential amenity

is harmed by an existing use. This policy has been saved following the adoption of CLP1.

8.9 The planning history provides details of enforcement complaints received from adjoining occupiers relating to noise and disturbance for the period of 1997-2001. At the time, the Planning Service was unable to take action as the use was lawful. However, these complaints demonstrated that the lawful commercial use of the site has caused significant disturbance to the adjoining occupiers.

8.10 In recent years, there has been no record of complaints concerning noise and disturbance from the site. However, there has been a change in operation of the site. A plant hire company previously operated from the site with its maintenance division closing in 2000, before fully ceasing in 2005. The complaints previously recorded relate to the movement of heavy plant into, out of and around the site including deliveries late at night and early in the morning, and weekend working.

8.11 Since 2005, the warehouses have been used for storage of files associated with the office use of the site resulting in a significant reduction in noise and activity within part of the site. However, the existence of previous complaints regarding the use the suggest that if the site were returned to industrial use, in accordance with its lawful planning use, or a similar commercial use (also lawful) was implemented on this site that it is likely to result in noise and disturbance to the adjoining residential occupiers.

8.12 In light of the aforementioned policies, the planning history, the lawful planning use of the site, the objective of central government to increase the total housing stock and the Permitted Development rights for office space, the principle of a comprehensive redevelopment of the site for residential purposes is supported.

Siting, Scale and Design

8.13 The NPPF attaches great importance to the design of the built environment. Paragraph 17 gives 17 core planning principles. One of these principles is ‘always seek to secure high quality design and a good standard of amenity for all existing and future occupants of land and buildings’. Paragraph 56 states that ‘The Government attaches great importance to the design of the built environment. Good design is a key aspect of sustainable development, is indivisible from good planning, and should contribute positively to making places better for people’. Paragraph 58 identifies 6 points that decisions should aim to ensure in all development. These include, adding to the overall quality of the area, establishing a strong sense of place, responding to local character and being visually attractive. Paragraph 61 highlights the importance of the visual appearance and architecture but also addresses the importance of connections between people and places and the natural, built and historic environment. Paragraph 63 places weight on outstanding or innovative design. Paragraph 69 seeks to promote safe and accessible developments, containing clear and legible pedestrian routes, and high quality public space, which encourage the active and continual use of public areas.

8.14 London Plan 2011 (with 2013 Alterations) policies 7.1, 7.4, 7.5 and 7.6 states that development should make a positive contribution to the local character, public realm and streetscape. It should incorporate the highest quality materials and design appropriate to its context.

8.15 Croydon Local Plan: Strategic Policy SP1.1 states that the Council will require all new development to contribute to enhancing a sense of place and improving the character of the area. SP4.1 and SP4.2 require development to be of a high quality which respects and enhances local character and the Council requires development to protect local designated views and setting of landmarks. Policies SP4.7, SP4.8 and SP4.9 encourage improvements to the public realm.

8.16 Policies UD2 and UD3 of the Croydon Plan 2006 (Saved Policies 2013) require consideration to be given to the relationship of the development to adjoining properties, and its impact on the streetscene in general. Policy UD14 requires landscaping to be considered as an intrinsic part of the overall development.

8.17 The proposed development would result in the demolition of all existing buildings on site, none of which are of any architectural or historic interest. The proposal consists of several individual elements providing a mix of residential units that respond to the mixed residential character of the area, which is defined by blocks of flats ranging between 3 and 8 storeys, and rows of terraced two storey houses.

8.18 Blocks A, B and C would be located towards the rear of the site. Blocks A & B would have the same footprint, with Block C having a slight variation. The proposed layout provides spacing in between each block to create amenity space for future residents. Blocks A and B would be four storeys in height each containing 14 units. Block C would be part-three and part-two storeys and contain 10 units. The top floor of each block would be recessed to reduce the bulk and massing of the buildings adjacent to East India Way. The blocks would be parallel to the 3-5m high wall which runs along the rear boundary with East India Way. This wall is outside of the applicant’s ownership and does not form part of the proposal. The third and fourth storey of Blocks A and B, and the second and third storey of Block C would be above the height of the wall. The scale and massing of these blocks along East India Way is considered acceptable.

8.19 The scheme excludes any works to the wall as part of the proposed development. The wall is outside of the applicant’s ownership and the scheme has been designed to respond to the retention. Whilst the wall is not subject to any designated protection, it is understood to have a degree of heritage value relating to the former railway use of the site. Representations received highlight the value of the wall in terms of preventing antisocial behaviour. This is also supported by Crime Prevention officers.

8.20 East India Way consists of a mix of modern two storey houses and three storey flatted developments. The character of the street is also partly defined by the wall outside the rear of the site. Whilst substantial parts of the proposed development would be visible above the wall, given the varied building form on East India Way, the existing buildings on site, it is considered that the siting, layout and design the proposal responds positively to the site characteristics and constraints.

8.21 Block D would front Grant Road and be sited to the south of the vehicular access into the site. It would be a four storey building and be sited further forward of the building line of the adjacent block and comprise 17 units. Block D would include access to ground floor units from Grant Road which would assist in the provision of an active frontage. It would replace the existing office block fronting Grant Road. The height increase to four storeys from the existing three storey building (and adjacent three storey flats) is considered acceptable. Grant Road consists of a varied building height

and form, including two storey houses and flatted developments (up to 8 storeys in Fisher Close, access opposite the site).

8.22 Block E would be located on the northern side of the vehicular access and adjoin the existing two storey dwelling to the east (33 Grant Road), as is the case for the existing gatehouse building. It would contain 11 units. It would be a three storey building and extend around to the rear of 33-39 with units (and access) facing into the site. It is considered that the relationship with the adjoining single aspect buildings fronting Grant Road is acceptable. It is acknowledged that developing this section of the site is a potentially challenging aspect. The option proposed is considered to achieve an appropriate solution given the constraints.

8.23 The northern end of the site would comprise 6 two storey four bedroom houses, each with private amenity space to the rear. 16 car parking spaces would be located outside these houses, with another 6 to the rear of Block D. Landscaped amenity areas would be between Blocks A, B & C, and also in front of Block C.

8.24 The site layout consists of a vehicular access and servicing route within the site. Whilst the landscaping details would be secured by condition (including the child play space) it is considered that the scheme would provide an appropriate balance between hard and soft surfaces. The full landscaping scheme would be expected to include complimentary planting features, ensuring the spaces are suitable for future residents’ needs. Whilst vehicles would not be travelling at speed, the landscaping scheme must also ensure clear separation between vehicles and play areas. The indicative planting shown that this would be intention.

8.25 The architectural approach and elevational treatment would consist of two main elements of development; the larger blocks of flats and the smaller scale houses. The lowered height of Blocks C & E would provide a transition between the two elements. The palette of materials includes light and medium tone bricks. There would also be a mix of glazed features, grey roof tiles, and balustrading. Samples of materials would be subject to condition to ensure high quality. Public art would be secured by condition. The proposed materials are considered to be acceptable in keeping with the character of the area.

8.26 The development overall is considered to positively respond to the character of the area and constraints of the site. The proposal would result in a residential development located in an area predominantly characterised by residential uses. The size, siting and design of each element is considered appropriate for the context. The development would accord with CLP SP4, Croydon Plan 2006 (Saved Policies 2013) UD2, UD3, UD8, H2 and London Plan Policies 7.4 and 7.6.

Housing Mix

8.27 Chapter 6 of the NPPF states that local planning authorities should deliver a wide choice of sustainable homes. They should plan for a mix of size, type and tenure of accommodation to meet the specific needs to the area.

8.28 The London Plan policy 3.8 states that new developments should offer a range of housing choices, in terms of mix of housing sizes and types. SP2.5 of CLP1 states that the Council will seek to ensure that a choice of homes in available in the borough that will address the borough’s need for homes of different sizes, setting a strategic

target of 60% of all new homes outside the Croydon Opportunity Area to provide three or more bedrooms.

8.29 The development would provide 72 units with a mix of 1 bed (32%), 2 bed (39%), 3 bed (21%) and 4 bed (8%) units. Family accommodation (3 bed+) therefore would be 29% of the total units provided. This is considered an acceptable mix for the development in the context of the site, other flatted schemes in the locality and policy requirements, including CLP Policy SP2.2 which seeks to deliver a minimum of 13,300 homes between 2011 and 2021 in line with the London Plan target for new homes.

Affordable Housing

8.30 Chapter 6 of the NPPF relates to affordable housing. It indicates that where local planning authorities have indicated that affordable housing is required they should:

“Set policies for meeting this need on site, unless off-site provision or a financial contribution of broadly equivalent value can be robustly justified”

8.31 London Plan Policies 3.8 to 3.13 relate to affordable housing. Policy 3.11 states:

‘The Mayor will, and boroughs and other relevant agencies and partners should, 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, 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’.

8.32 London Plan policies 3.12 and 3.13 to indicate that the maximum reasonable amount

of affordable housing should be sought on schemes, taking into account viability and other issues.

8.33 Policies SP2.3 and SP2.4 of CLP1 set out the number of units that should be secured for affordable housing unless developers can demonstrate that it makes their schemes unviable. Since 1 April 2015, a minimum of 50% affordable housing is required on all sites outside the Croydon Opportunity Area.

8.34 The building has been vacant since December 2014 and therefore qualifies for the Government’s recently introduced Vacant Building Credit. Planning Practice Guidance states:

“National policy provides an incentive for brownfield development on sites containing vacant buildings. Where a vacant building is brought back into any lawful use, or is demolished to be replaced by a new building, the developer should be offered a financial credit equivalent to the existing gross floorspace of relevant vacant buildings when the local planning authority calculates any affordable housing contribution which will be sought. Affordable housing contributions may be required for any increase in floorspace”.

8.35 In essence, this means that the Council’s affordable housing requirement can only be applied to the net increase of floorspace on the site.

8.36 The proposed development would result in a net floor space increase of 620m². Consequently, with the 50% minimum affordable housing policy applied, 310m² would be required for affordable accommodation.

8.37 Notwithstanding the above minimum, the applicants have offered to exceed the policy requirement of 310m² by providing 1000m² for affordable accommodation. This would be contained within Block E (3 x 1 bedroom; 2 x 2 bedroom; 6 x three bedroom units). With the Vacant Building Credit applied, the scheme would provide approximately 160%of the affordable housing requirement. This would be provided at a 60:40 tenure split of affordable rent and shared ownership.

Residential amenity

8.38 Chapter 6 of the NPPF relates to delivering a wide choice of high quality homes. It states that:

‘Housing applications should be considered in the context of the presumption in favour of sustainable development’ and that it is the role of local planning authorities ‘to deliver a wide choice of high quality homes, widen opportunities for home ownership and create sustainable, inclusive and mixed communities’.

8.39 London Plan Policy 3.5 states that housing developments should be of a high quality and exemplary design.

8.40 The adopted London Housing Supplementary Planning Guidance provides guidance on the design of residential units and provides a breakdown of minimum floor areas by unit type and requirements for individual room dimensions to ensure adequate amenity.

8.41 Policy SP2.6 indicates that housing should cater for residents’ changing needs over their lifetime and contribute to creating sustainable communities. Individual units will be expected to meet the standards set out in the London Housing SPG. Croydon Plan Saved Policy UD8 sets requirements for the provision of amenity space and provision of adequate amenity for new residents.

8.42 The proposal would provide 72 units. The scheme would comply with standards set out in the London Plan, the London Housing SPG and the new National Technical Housing Standard 2015 in terms of minimum floor space standards for each type of unit. 10% of units would be wheelchair accessible.

8.43 The London Housing SPG seeks to minimise the number of single-aspect units in schemes and indicates that north-facing single aspect units would not be acceptable. 21 units would be single aspect. However, none of these are north facing with each having a south-easterly aspect. The London Housing SPG encourages a maximum of 8 units being served by one residential core on a floor so as to build sustainable and safe communities. The development would accord with this aim.

8.44 The internal layout of Blocks A, B and C takes account of the proximity and height of the wall on the rear boundary into the design ensuring habitable rooms facing the wall are dual aspect. This would ensure occupiers of the ground and first floors have an acceptable outlook and light source. The main living spaces within these blocks would not face towards the wall.

8.45 The occupiers of each unit would be served by private amenity space in accordance with the London Housing SPG. The flats would have balconies and the houses would each have rear gardens. Communal space would also be provided. This is discussed in the ‘Landscaping and amenity space’ section below.

8.46 The development would provide a satisfactory living environment for future occupiers in accordance with the London Plan and London Housing SPG standards and Technical Housing Standards.

Effects on adjoining occupiers

8.47 Chapter 7 of the NPPF, requiring good design, makes clear that the impact of development on adjoining land and occupiers is a key consideration of good design.

8.48 Policies SP1.2, SP4.1 & SP4.2 of CLP1 sets out the need for developments to respond to the local character and circumstances, which includes the need for ensuring there is no detrimental impact on neighbours. Croydon Plan 2006 (Saved Policies 2013) Policies UD2 and UD3, referring to the layout, siting and scale of new developments makes clear that developments should distinguish between public and private spaces and not have an impact on the future development of other land. Additionally, policy UD8 protects the amenity of adjoining residential properties from overlooking, overshadowing and loss of light and outlook.

8.49 7-25 East India Way are two storey houses with front elevations and habitable room windows facing the 5m high brick wall adjacent to the rear boundary of the application site. The existing office building is three storeys with a substantial extension and pitched roof and is opposite 19-25 East India Way. Proposed Blocks A and B would be located adjacent to the wall for the majority of the rear boundary, approximately 14m from the front elevations of East India Way properties. The massing of the development would be broken up by the gaps between each block with also the top floors being recessed which would ensure the outlook from these properties is not unduly affected. There would be no significant harm in terms of loss of daylight and sunlight to the occupiers of these properties. The retention of the wall assists in the protection of privacy. Furthermore, the positioning of windows would ensure that there is no direct window to window relationship.

8.50 Block C would also have an acceptable impact on the amenities of adjoining occupiers. It would be lower in height at three storeys, with a recessed top floor which would ensure outlook is not unduly affected. The wall at this section lowers from 5m to 3m which exposes more of the fenestration at first floor. However, due to the relationship with 27-49 East India Way which is a three storey block of flats, it is not considered to result in a material loss of privacy. Whilst windows would face towards the existing building, there would not be direct window to window outlook to habitable rooms with the majority serving bathrooms or circulation space within Block C. The flats, served by Juliette balconies, would be opposite non habitable rooms. The windows in the elevation of 27-49 East India Way and facing the application site are secondary aspect and to a kitchen. There would be no significant harm in terms of daylight or sunlight loss for the occupiers of this building.

8.51 52-60 East India Way are two storey houses to the north of Block C. Block C would be two storeys in height at the closest point to the boundary with these properties. The first floor would not have any glazing in the side elevation. The second floor

would be setback and have obscure glazed panels. There would be no significant loss of daylight or sunlight or loss privacy towards the adjoining occupiers.

8.52 The two storey houses to the north of the site would be located adjacent to the turning head outside 60 and 70 East India Way at an oblique angle from the front elevations of these properties. The two storey houses would be approximately 17m from the rear elevation of Storrington Road properties. It is not considered that there would be any significant effect on the residential amenities of occupiers of these properties in terms of daylight, sunlight or privacy.

8.53 It is considered that the impact of the development towards the occupiers of Grant Road properties would also be acceptable. Blocks D & E would be approximately 16m-20m from properties opposite on Grant Road due to the main highway providing separation. Whilst balconies would be provided on the front elevation, the distance is considered sufficient not to result in significant ability to overlook neighbouring properties. This would also be the case for Block A and the relationship to the block of flats comprising 3-11 Grant Road. Block D is set forward of this adjacent building. However, there are no side windows.

8.54 33-39 Grant Road are single aspect terraced dwellings and do not have any rear facing windows. The existing gate house building is set forward of the adjoining terrace. Block E would have a similar relationship with the adjoining terrace. The main building would be flush with the front wall of 33 Grant Road with the balconies projecting forward of a similar depth to the existing gate house. It would be the same height as the ridge line of the terrace. The projecting element above the eaves of the terrace would not have a significant impact in terms of light given the existing building. Balcony screening would be secured by condition to limit any ability to overlook adjoining land.

8.55 Whilst population density would increase, the development is not considered to result in an increase in noise and disturbance. As discussed above, the lawful planning use of the site has greater potential for noise and disturbance. The proposed party wall at Block E would result in residential units directly adjacent to the rear of 33-35 Grant Road. Appropriate sound insulation would be subject to Building Regulations. A Construction Logistics Plan condition is attached to the recommendation ensuring the build-phase is managed appropriately, minimising disturbance towards neighbouring properties.

8.56 The impact towards all adjoining occupiers has been considered. Subject to appropriate conditions, the development would not to result in significant harm towards the residential amenities of adjoining occupiers.

Landscaping and Amenity Space

8.57 Chapter 7 of the NPPF requires good design; it states that:

‘it is important to plan positively for the achievement of high quality and inclusive design for all development, including individual buildings, public and private spaces and wider area development schemes’.

8.58 London Plan Policy 7.5 indicates that public realm should use gateways, focal points and landmarks as well as high quality street furniture to create uncluttered high quality spaces, with opportunities for greening of public areas maximised.

8.59 Policies SP4.7 to SP4.10 of CLP1 relate to the integration of public realm into schemes and policy SP7.3 requires multi-functional green open spaces to be developed, with opportunities for landscaping, green walls and roofs incorporated into schemes. UDP Policy UD14 requires all landscape associated with new development to be considered as an intrinsic part of the overall design concept and should be considered in detail at the outset.

8.60 In order to avoid extensive areas dominated by vehicle routes and hardsurfacing, the development would incorporate a shared surface for pedestrians and vehicles. Full details would be secured by condition and seek to ensure safe movement and use for all users.

8.61 The development would provide communal amenity/play spaces between Blocks A and B, B and C and in front of Block C. Indicative plans have been submitted demonstrating how the spaces may be used. The areas would be designated for doorstep play (for small children e.g. under 5s). Full details of each space would be secured by condition. The amenity space of 477m² exceeds the GLA requirement of 179m² for this development, in accordance with the London Providing for Children and Young People's Play and Informal Recreation document. Furthermore, Addiscombe Railway Park is in close proximity to the site providing an area for older children.

8.62 Each residential unit would be provided with an area of private amenity space through the provision of a patio, balcony or garden area which would meet the standards set out in the London Housing SPG.

Access and Parking

8.63 Chapter 4 of the NPPF seeks to promote sustainable transport. It indicates that a modal change towards public transport should be encouraged and that the pattern of development should be managed to encourage developments to the most suitable locations.

8.64 London Plan Policy 6.13 indicates that the Mayor wishes to see an appropriate balance being struck between promoting new development and preventing excessive car parking provision that can undermine cycling, walking and public transport use. Developments in areas of good public transport accessibility should aim for significantly less than 1 space per unit. Policy 6.3 states development proposals should ensure that impacts on transport capacity and the transport network, at both a corridor and local level, are fully assessed. The cumulative impacts of development on transport requirements must be taken into account. Walking and cycling is also strongly endorsed in Policies 6.9 and 6.10 and there is a need for cycle parking to be provided in accordance with the standards set out in Table 6.3.

8.65 Policy SP8 of CLP1 sets out local requirements to promote sustainable travel and levels of parking. Croydon Plan Saved Policy UD12 demands the safety of all users to be maintained and UD13 requires car and cycle parking to be designed as an integral part of the scheme and to minimise their visual impact.

8.66 The site is located in an area with a PTAL rating of 3 indicating a moderate level of access to public transport. It is however acknowledged that the site is within walking distance to the range of services and facilities within the Metropolitan Centre.

8.67 The parking provision would be 22 spaces (30%). The site is located within a Controlled Parking Zone. The S.106 would include a clause restricting future residents of the development from obtaining parking permits for the cars of both residents and visitors. This is considered a requirement in order to avoid increased pressure upon street parking in the locality and would be in accordance with policies seeking to reduce car use within Croydon and London. 10% of spaces are to be designated for electric vehicle charging points with a further 10% passive provision for future use along with 10% of the spaces for wheelchair users. 74 cycle spaces would be provided in accordance with London Plan policy for the flats. The houses would be served by private cycle spaces in the rear garden.

8.68 Access for vehicles and pedestrians would be from Grant Road only. Full details of the shared surface will be secured by condition, ensuring safe movement of vehicles and pedestrians. Swept path analysis has been submitted demonstrating sufficient turning space for refuse and emergency vehicles. The Transport Assessment states that the proposal would result in circa 31 two way trips during the AM peak period and circa 33 two way trips during the PM peak period, which would be a net reduction from the existing use in the peak periods by 35 movements (AM) and 22movemnets (PM) respectively. The development would not result in a material impact on the local highway network in terms of traffic or trip generation.

8.69 The development would be acceptable in highways terms in accordance with the aforementioned policies.

Environment and Sustainability

8.70 At the heart of the National Planning Policy Framework is a presumption in favour of sustainable development. It states:

‘Planning plays a key role in helping shape places to secure radical reductions in greenhouse gas emissions, minimising vulnerability and providing resilience to the impacts of climate change, and supporting the delivery of renewable and low carbon energy and associated infrastructure’.

8.71 Policies 5.1-5.15 of the London Plan relate to sustainability, seeking to achieve an overall reduction in London’s carbon dioxide emissions of 60 per cent (below 1990 levels) by 2025 and reduce carbon dioxide (CO2) levels by 40%. However, as outlined in the Sustainable, Design and Construction SPG, since 6 April 2014 the Mayor has applied a 35 per cent carbon reduction target beyond Part L 2013 of the Building Regulations - this is deemed to be broadly equivalent to the 40 per cent target beyond Part L 2010 of the Building Regulations, as specified in Policy 5.2 of the London Plan for 2013-2016.

8.72 Proposals should seek to reduce carbon dioxide emissions through the energy efficient design of the site, buildings and services. District heating and cooling and combined heat and power should be adopted. The highest standards of sustainable design and construction should be achieved in London to improve the environmental performance of new development.

8.73 Policies SP6.2 – SP6.6 of CLP1 provide a local interpretation of the above policies. They require development to minimise CO2 emissions through application of the energy hierarchy, require high density schemes to incorporate site wide communal heating and require developments to be constructed to BREEAM “Excellent”

standards and achieve Code for Sustainable Homes Level 4 (now withdrawn). Furthermore developments should minimise pollution and improve air, land, noise and water quality as well as managing waste sustainably. In order to minimise the risk of flooding, all new developments should incorporate sustainable drainage systems (SuDs).

8.74 Retained policy EP16 of the Croydon Plan 2006 (Saved Policies 2013) requires major new development to incorporate renewable energy production equipment to off-set at least 10% of predicted carbon emissions except where a) the technology would be inappropriate; b) it would have an adverse visual or amenity impact that would clearly outweigh the benefits of the technology; and c) renewable energy cannot be incorporated to achieve the full 10%.

8.75 The Sustainability Statement submitted states the scheme would achieve 35% CO2 reduction above the Part L 2013 of the Building Regulations, the majority of which provided through PV roof panels. As outlined above this a reduction that broadly equivalent to 40% and therefore in accordance with the requirement of London Plan Policy 5.2. This can be secured by way of condition.

8.76 The developer has submitted a screening opinion under the Environmental Impact Regulations. The Council has assessed the development does not constitute EIA development (see paragraph 3.7 ref: 14/2080/DT).

Other Planning Issues

8.77 The Mayor of London has introduced a London wide Community Infrastructure Levy (CIL) and Croydon has introduced a Borough CIL. The development would be liable for both charges which cover borough wide issues of education, health, open space, community facilities and some public realm works.

8.78 Chapter 11 of the NPPF seeks to conserve and enhance the natural environment. London Plan Policy 5.21 supports the remediation of contaminated sites and that the development of brownfield sites does not result in significant harm to human health or the environment and to bring contaminated land to beneficial use. CLP1 SP6.3 requires development to positively contribute to improving air, land, noise and water quality by minimising pollution. Policy EP1 of the Croydon Plan (2006 Saved Policies) state that development that may liable to cause or be affected by pollution of water, air or soil, or pollution through noise, dust, vibration, light, heat or radiation will only be permitted if the health, safety and amenity of users is not put at risk and the quality and enjoyment of the environment would not be damaged or put at risk. Policies EP2 and EP3 of the Croydon Plan (2006 Saved Policies) ensure that the land is suitable for the proposed use and that an investigation into the extent of any possible contamination required. A Phase I and Phase II assessment has been submitted of which the findings are agreed. Appropriate conditions are attached to the recommendation.

Conclusions

8.79 All other relevant policies and considerations, including equalities, have been taken into account. Planning permission should be granted for the reasons set out above. The details of the decision are set out in the RECOMMENDATION.