Kidbrooke Village Centre Kidbrooke Estate Report (Planning Decisions)

8/9/2019 Kidbrooke Village Centre Kidbrooke Estate Report (Planning Decisions)

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Category 1B

1. Development (other than development which only comprises the provision of houses, flats, orhouses and flats) which comprises or includes the erection of a building or buildings— (c)outside Central London and with a total floorspace of more than 15,000 square metres .

Category 1C

1. Development which comprises or includes the erection of a building of one or more of thefollowing descriptions— (c) the building is more than 30 metres high and is outside the City ofLondon.

2 On 6 July 2011 the Mayor considered planning report PDU/ 2245a/01, and subsequentlyadvised Greenwich Council that the application did not comply with the London Plan, for thereasons set out in paragraph 92 of the above-mentioned report; but that the possible remediesset out in paragraph 94 of that report could address these deficiencies.

3 A copy of the above-mentioned report is attached. The essentials of the case with regardto the proposal, the site, case history, strategic planning issues and relevant policies and guidanceare as set out therein, unless otherwise stated in this report. On 12 January 2012 GreenwichCouncil decided that it was minded to grant planning permission and on 25 J anuary 2012 itadvised the Mayor of this decision. Under the provisions of Article 5 of the Town & CountryPlanning (Mayor of London) Order 2008 the Mayor may allow the draft decision to proceedunchanged, direct Greenwich Council under Article 6 to refuse the application or issue a directionto Greenwich Council under Article 7 that he is to act as the Local Planning Authority for thepurposes of determining the application and any connected application. The Mayor has until 7February 2012 to notify the Council of his decision and to issue any direction.

4 The environmental information for the purposes of the Town and Country Planning(Environmental Impact Assessment) (England and Wales) Regulations 1999 has been taken intoaccount in the consideration of this case. The decision on this case, and the reasons will be madeavailable on the GLA’s website www.london.gov.uk.

Update

5 At the consultation stage Greenwich Council was advised that the application did notcomply with the London Plan, for the reasons set out in paragraph 92 of the above-mentionedreport; but that the possible remedies set out in paragraph 94 of that report could address thesedeficiencies:

Principle of development: Evidence to support the reduction in community uses is

required.

Affordable housing: Further discussion with the GLA regarding the need for a viabilityappraisal. This will inform other housing and density related matters.

Urban design and access: The design team need to reconsider a number of matters asset out in this report, including the arrangements of plot F and G, building scale to plot Fand G, the number and location of front doors, various elevation treatments around plot Dand a breakdown of space standards. The applicant should also provide additionalvisualisations of the hotel service area and the pedestrian link bridge to the north. Lifetimehomes and 10% wheelchair units should be conditioned by Greenwich Council.

Climate change mitigation: provision of renewable energy, cooling strategy andsummary of overall carbon dioxide savings beyond 2010 building regulations.



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Transport: Whilst the initial assessment suggests that the implementation of this phase ofthe development is unlikely to impact on the capacity of the local bus network, additionalinformation is however required, as further detailed above in paragraph 72-87 of thisreport, in order to fully determine the impact on the highway network and to agree asuitable package of mitigation measures going forward. In addition, given the currentpolicies on ‘smoothing traffic flow’, further justification is required, for the installation ofany new signals on the TLRN to be considered acceptable

Summary of amendments

6 A summary of changes is set out below:

Table 1 summary of land use changes

Outline permission Proposed Amended

Residential539 units (38.1%

affordable)960 units (38%

affordable)983 units (37%

affordable)

Retail 3,100 sq.m 4,899 sq.m. 3,075 sq.m.

Leisure 2,782 sq.m. 0 0Supermarket 2,785 sq.m. 2,746 sq.m. 2,810 sq.m.

Office 5,450 sq.m. 0 0

Hotel 5,911 sq.m. 4,430 sq.m. 4,430 sq.m.

Community 4,884 sq.m. 3,279 sq.m. 5,495 sq.m

GP surgery 3,205 sq.m. 01,997 sq.m. Included in

community space

Rail station entrance - - 217 sq.m.

7 Amended housing mix is set out in table 2 below:

Table 2 bedroom size mix

Studi 1-bed 2-bed 3-bed -bed Total

Social rent 0 39 49 43 2 133

Intermediat 0 58 52 5 0 16

Market discoun 0 3 29 7 0 70

Market 6 160 301 89 2 616 Total 380 379 196 5 983

8 The following sections set out the extent to which the Mayor’s comments have beenaddressed.

Principle of development

9 At the consultation stage the Mayor noted that there was limited commentary or justification for the reduction of other land uses approved in the outline masterplan for this phase,

including office, leisure and the significant reduction in community space. It was accepted that theland area to the north of the site was a key constraint as it was no longer included within the redline for this phase which suggests the loss of the office and leisure could be accepted and could be



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delivered at a later date under a separate application. As noted at the consultation stage, however,the location of community space has always been focused to the south of the railway, directlyaccessible and central to the current scheme and therefore the reduction needed to bereconsidered by the design team. Since then, the community space has increased and includesprovision for the creche, GP surgery and other space to be determined with Greenwich Council. The overall provision is proposed at 5,495 sq.m. and responds to the Mayor’s comments. Theapproach is broadly acceptable.

Affordable housing

10 The section 106 agreement for the outline planning permission requires the delivery of aminimum 38.1% of housing provision as affordable housing across the development, with scopefor variation on individual phases (the stage 1 report previously reported the incorrect masterplantarget of 43% - which relates to the target set out in the Kidbrooke SPD).

11 The proposed housing mix is set out in table 2 above and differentiates betweenintermediate products.

12 The Council reports that:

“The proposed amount of affordable housing is slightly low when compared with the 38.1%required in terms of the Masterplan. Of the residential units granted detailed approval so far withinthe Masterplan, 46% of these are affordable units and this would be 42% if the proposedapplication for Phase 3 is approved. Therefore, although the proposed level of affordable for thisphase is lower than the outl ine requirement, the overall quantum of affordable housing approvedso far is above the 38.1% required in the outline planning permission and would remain above thispercentage if Phase 3 is approved.”

13 As previously reported the viability was tested at the outline masterplan stage and the sitewide target agreed as per the section 106 agreement. The phases to date exceed the masterplan

target overall and therefore the approach is supported and consistent with the London Plan.

Urban design

14 The Mayor raised a number of fairly minor design comments at the consultation stageregarding active uses of blocks at ground floor and arrangements around the pedestrian bridgelanding from the north. The design team has provided further information regarding the layoutsand has introduced changes including the relocation of the supermarket storage under Block Awhich improves the interaction with the street. The overall approach is broadly supported andconsistent with the London Plan.

Climate change

15 As previously reported, a heating network will connect all residential and non-residentialbuildings within the development fed from a single energy centre beneath Plot C. It is proposedthat this network will connect into the wider Kidbrooke Village District Heat Network at a laterdate. The applicant confirms that the overall carbon savings will be 24% beyond 2010 buildingregulations after all elements of the hierarchy. The approach is broadly supported.

Transport for London’s comments

16 At the consultation stage, TfL was satisfied that the proposed level of car parking was

below the maximum agreed as part of the consented masterplan. The applicant’s intention toimplement a controlled parking zone (CPZ) was also supported, and TfL advised that this,alongside a car parking management plan and the provision of electric vehicle charging points



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(EVCP) should be secured by condition. TfL additionally raised concerns over the traffic modellingand potential highway impact, alongside the proposals to install new signals on the Transport forLondon Road Network and the pedestrian crossing arrangements. TfL was supportive however, ofthe proposal to improve the existing bus layover space at Henley Cross, and requested furtherdiscussions on the form they may take. A site specific travel plan and construction logistics planwere also requested to be secured for this phase of development by condition.

17 Discussions have taken place with the applicant since the consultation stage, and as aresult TfL is satisfied that the issues initially raised have now been satisfactorily addressed. Assuch, TfL supports Greenwich Council’s requirement for details of i) a demolition/ constructionmethod statement, ii) a construction logistics plan, iii) a delivery and servicing plan, iv) car andcycle parking arrangements and v) the provision of EVCP in accordance with London Planstandards, all to be secured by conditions that require them to be submitted and approved by thelocal planning authority prior to commencement/ first occupation on site.

18 Given TfL’s initial concerns over the highway impact of this phase of development, TfL alsosupports the section 106 obligation that requires detailed traffic modelling, mitigation and siteaccess arrangements, to have been submitted and approved by TfL prior to the occupation of anyretail floorspace associated with block A, and the commencement of any above ground worksassociated with the rest of the Phase 3 development proposals. TfL also supports of the additional£120,000 which has been secured, payable to TfL, towards the implementation of environmentalimprovements at Henley Cross.

Equalities

19 The 2010 Equality Act places a duty on public bodies, including the GLA, in the exercise oftheir functions, to have due regard to the need to advance equality of opportunity betweenpersons who share a relevant protected characteristic and persons who do not share it. Thisrequirement includes removing or minimising disadvantages suffered by persons who share arelevant protected characteristic that are connected to that characteristic and taking steps to meet

the needs of persons who share a relevant protected characteristic that are different from theneeds of persons who do not share it. The Act defines protected characteristics and includes ageand disability. The GLA in the discharge of its planning function must engage this duty, in so faras it is applicable to a particular case.

20 In this instance the proposal relates to the wider estate renewal of the Ferrier Estate(PDU/2245/01 and PDU/ 2245/02). The GLA has considered the matter in the context of the Actand note that as part of the masterplan approval there is no net loss of affordable housing and thatat present the phase by phase delivery is meeting the masterplan delivery target.

Response to consultation

21 The application has been the subject of extensive public consultation comprising a pressnotice, site notice and 2,148 letters sent to individual occupiers in the vicinity of the development.A second consultation was carried out after the application was revised. The Council sets outdetailed comments from all responses received in its committee report. The main comments aresummarised below:

Metropolitan Police – secure by design Advisor

No objection – Secure By Design certification should be conditioned

Thames Water

No objection – subject to conditions



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Environment Agency


Design Council

Although the proposed masterplan provides a much better level of connection, there are a numberof areas which could be strengthened. Firstly, the existing pedestrian ramp, connecting the villagecentre with the neighbourhood to the north is a particularly unpleasant crossing. The landing,which is within the application site, is uninviting and does not promote accessibility or encourage ahigh level of use and natural surveillance. The proposal does not make good use of the topographyto grade the approach to the elevated railway crossing, diminishing the need for such a long ramp.

Furthermore the location of the existing ramp does not offer the most convenient or legible route;if the ramp is to be reprovided, it is suggested that its location is re-considered. The local authorityis urged to facilitate the delivery of improvements to connections outside the application siteboundary, including those related to the highways and the masterplan sites that are not withinBerkeley Group’s control. Secondly, it is felt that the village centre businesses might benefit frombeing on a more convenient through route, with a second link to Kidbrooke Park Road at the

southern end of the site. Finally, it is felt that the decision to locate the supermarket on thenorthern side of the square is likely to concentrate activity along the axis from the station, at theexpense of the southern side of the public space, which is liable to become lifeless as a result.

English Heritage (archaeology)


Natural England


Southern Gas Network

Attention is drawn to the presence of a Low / Medium / Intermediate / Pressure gas main in theproximity of the site. No mechanical excavations are to take place above or within 0.5m of the lowpressure and medium pressure system and 3m of the intermediate pressure system. Where requiredthe position of mains should be confirmed using hand dug trial holes. Safe digging practices, inaccordance with HSE guidance must be used to verify and establish the actual position of mains,pipes, services and other apparatus on site before any mechanical plant is used.

Sport England

No objection

Lewisham Council

No objection

Greenwich Conservation Group -Object to:

Height increase to15 storeys Impacts on local views Lack of bus station drop off outside station Lack of family housing



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Principle of a hotel

Blackheath Society -Object to:

Exclusion of land to the north Quantum of development Lack of station pick up drop off

Principle of hotel provision Height of buildings

Affordable housing delivery

Family housing delivery

Lack of consistency with the SPD

Blackheath Park Conservation Group -Object to:

Transport impact Impacts on pedestrians

Absence of detailed design of the community facilities Lack of consistency with the SPD

South Greenwich Forum

Object to lack of family provision

Express disappointment that the hub cannot be extended north of the railway line andthat access to and from the existing residential areas to the north seems to be so limited.

Henley Cross Medical Practice

Object to absence of a specific reference to a GP Doctor’s Surgery.

Local Residents

22 Six responses were received from local residents which raised the following objections andcomments:

The increase in the maximum height of the development from 9 to 15 storeys andincreasing the number of residential units to 983 represent a major departure from theagreed masterplan. These substantial changes vastly increase the height and density ofthe development and will have a detrimental social impact. This is a clear case of seeking

to overdevelop the site and repeat the errors enshrined in the previous development. These changes represent a major departure from the agreed masterplan.

The majority of the proposed properties would be 1 and 2 bedroom flats, which areunsuitable as family homes. This development is unsuitable for social housing, and ismore akin to a cynically open commercial enterprise to maximise profits.

The increase in the height and density of the site will have a damaging visual impact onthe neighbourhood and be to the detriment of the appearance and quality of theenvironment.

Presently there is good interchange at Kidbrooke between South Eastern Rail and busservices. The development plans show bus stops on a spine road a short (covered) walkfrom the station. This is less than best practice and arguably less convenient for older or



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disabled passengers than now. There is also a north side "pull-in" which may be for "kissn ride" or for bus use.

TfL will no doubt be concerned to see that bus routes serve the new more variedcommunity and their travel plans. Mention was made of the new hotel next to thestation and its availability for visitors to the O2 but for which destination there is atpresent no direct bus.

The development of the station area should take into consideration the current technicalfeasibility study being conducted by the council in relation to extension of the DLR viaKidbrooke

GLA officer comments

23 The matters set out above do not raise any new strategic or local planning issues that havenot been considered by the Council or the GLA. The Council considers each point in detail in theOfficer report. Where appropriate suitable mitigation measures have been secured through

appropriate conditions/section 106 legal agreement.

Article 7: Direction that the Mayor is to be the local planning authority

24 Under Article 7 of the Order the Mayor could take over this application provided the policytests set out in that Article are met. In this instance the Council has resolved to grant permissionwith conditions and a planning obligation, which satisfactorily addresses the matters raised at stageI, therefore there is no sound planning reason for the Mayor to take over this application.

Legal considerations

25 Under the arrangements set out in Article 5 of the Town and Country Planning (Mayor ofLondon) Order 2008 the Mayor has the power under Article 6 to direct the local planning authorityto refuse permission for a planning application referred to him under Article 4 of the Order. Healso has the power to issue a direction under Article 7 that he is to act as the local planningauthority for the purpose of determining the application and any connected application. TheMayor may also leave the decision to the local authority. In directing refusal the Mayor must haveregard to the matters set out in Article 6(2) of the Order, including the principal purposes of theGreater London Authority, the effect on health and sustainable development, national policies andinternational obligations, regional planning guidance, and the use of the River Thames. The Mayormay direct refusal if he considers that to grant permission would be contrary to good strategicplanning in Greater London. If he decides to direct refusal, the Mayor must set out his reasons,and the local planning authority must issue these with the refusal notice. If the Mayor decides todirect that he is to be the local planning authority, he must have regard to the matters set out inArticle 7(3) and set out his reasons in the direction. The Mayor must also have regard to theguidance set out in GOL circular 1/2008 when deciding whether or not to issue a direction underArticles 6 or 7.

Financial considerations

26 Should the Mayor direct refusal, he would be the principal party at any subsequent appealhearing or public inquiry. Government guidance in Circular 03/2009 (‘Costs Awards in Appealsand Other Planning Proceedings’) emphasises that parties usually pay their own expenses arisingfrom an appeal.

27 Following an inquiry caused by a direction to refuse, costs may be awarded against theMayor if he has either directed refusal unreasonably; handled a referral from a planning authority



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unreasonably; or behaved unreasonably during the appeal. A major factor in deciding whether theMayor has acted unreasonably will be the extent to which he has taken account of establishedplanning policy.

28 Should the Mayor take over the application he would be responsible for holding arepresentation hearing and negotiating any planning obligation. He would also be responsible fordetermining any reserved matters applications (unless he directs the council to do so) anddetermining any approval of details (unless the council agrees to do so).

Conclusion

29 The application is broadly consistent with the main themes of the masterplan. The mattersraised by the Mayor at the consultation stage have been satisfactorily addressed. The proposal isconsistent with the London Plan





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Category 1A

1. Development which comprises or includes the provision of more than 150 houses, flats, orhouses and flats .

Category 1B

1. Development (other than development which only comprises the provision of houses, flats, orhouses and flats) which comprises or includes the erection of a building or buildings— (c)outside Central London and with a total floorspace of more than 15,000 square metres .

Category 1C

1. Development which comprises or includes the erection of a building of one or more of thefollowing descriptions— (c) the building is more than 30 metres high and is outside the City ofLondon

3 Once Greenwich Council has resolved to determine the application, it is required to refer itback to the Mayor for his decision as to whether to direct refusal; take it over for his owndetermination; or allow the Council to determine it itself.

4 The environmental information for the purposes of the Town and Country Planning(Environmental Impact Assessment) (England and Wales) Regulations 1999 has been taken intoaccount in the consideration of this case.

5 The Mayor of London’s statement on this case will be made available on the GLA websitewww.london.gov.uk.

Site description

6 The application site falls within the outline masterplan approved in June 2009, for estaterenewal of up to 4,000 units and a range of other non-residential uses (GLA reference PDU/2245). The masterplan covers an area of approximately 109 hectares and includes, for the majority part,the existing Ferrier housing estate. The estate is a mix of residential units and large areas of openspace comprising 1,900 social rented units. It is located between Kidbrooke to the north, Elthamto the east and Blackheath and Lee Green to the west. The World Heritage Site of MaritimeGreenwich is located beyond Blackheath Park to the northwest.

7 The outline masterplan was approved on a phased basis and Kidbrooke railway station

(services to London Bridge, Charing Cross and Victoria) is central to this particular phase and islocated at the northern end of the wider SPD area. This phase comprises the proposed villagecentre (previously referred to as ‘the Hub’). The village centre will be bounded by the railway lineto the north, Kidbrooke Park Road to the west, the Holy Family Catholic Primary School to the eastand residential and open space to the south.

8 The site is located adjacent to the A2213 Kidbrooke Park Road, and is also within closeproximity to the A20 Eltham Road and the A2 Rochester Relief Road, all of which form part of the Transport for London Road Network (TLRN).The site is additionally bounded to the north by Tudway Road, which is a borough road. The site is directly served by two bus routes, the B16 andthe 178, with the nearest bus stops currently located on either Tudway Road, or Kidbrooke Park

Road. The Kidbrooke mainline railway station, which operates a services between London andKent, and is to be improved as part of the masterplan proposals, is located at the northern end of





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Total 380 379 196 5 960



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Figure 1 outline masterplan



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Figure 2 approved block layout phase 3



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Figure 3 proposed layout (excluding land north of the railway)

Case history

13 The Mayor previously considered the masterplan application for the whole estate(PDU/2245) in January 2009 and again at the determination stage in June 2009. The Mayorindicated his broad support for the estate renewal. The GLA also provided pre-application adviceon the Village Centre phase which was issued on 10 September 2010. The key strategic issuesraised at that time related to housing and affordable housing, urban design and design quality;climate change and transport.

14 In terms of phases that have come forward since the Mayor last considered the masterplan,

Phase 1 is currently under construction for 449 units. On 19 March 2010, reserved mattersapproval was given for Phase 2a, for the erection of 115 residential affordable units (09/2270/R)and construction commenced in November 2010. On 24 March 2010, reserved matters approvalwas given for Phase 2, for the erection of 595 residential units, including 170 extra care units and90 sq.m. of community floorspace (09/2269/R).

Strategic planning issues and relevant policies and guidance

15 The relevant issues and corresponding policies are as follows:

Housing London Plan; PPS3; Housing SPG; Providing for Children and

Young People’s Play and Informal Recreation SPG, HousingStrategy; Interim Housing SPG; Housing SPG EiP draf t



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Affordable housing London Plan; PPS3; Housing SPG, Housing Strategy; InterimHousing SPG; Housing SPG EiP draft

Density London Plan; PPS3; Housing SPG; Interim Housing SPG; HousingSPG EiP draft

Urban design London Plan; PPS1

Mix of uses London Plan Regeneration London Plan; the Mayor’s Economic Development Strategy

Transport London Plan; the Mayor’s Transport Strategy; PPG13

Parking London Plan; the Mayor’s Transport Strategy; PPG13

Retail/ town centre uses London Plan; PPG13, PPS4

Green Belt/ MOL London Plan; PPG2

Playing fields London Plan; PPG17, draft PPS Planning for a Natural andHealthy Environment

Access London Plan; PPS1; Accessible London: achieving an inclusiveenvironment SPG; Planning and Access for Disabled People: a

good practice guide (ODPM) Equal opportunities London Plan; Planning for Equality and Diversity in Meeting the

spatial needs of London’s diverse communit ies SPG; Diversity andEquality in Planning: A good practice guide (ODPM)

Tall buildings/views London Plan; RPG3A, Revised View Management Framework SPG

Sustainable development London Plan; PPS1, PPS1 supplement; PPS3; PPG13; PPS22;draft PPS Planning for a Low Carbon Future in a ChangingClimate; the Mayor’s Energy Strategy; Mayor’ s draft ClimateChange Mitigation and Adaptation Strategies; Mayor’s draftWater Strategy; Sustainable Design and Construction SPG

16 For the purposes of Section 38(6) of the Planning and Compulsory Purchase Act 2004, thedevelopment plan in force for the area is the Greenwich Unitary Development Plan 2006 (as saved15 July 2009) and the London Plan (Consolidated with Alterations since 2004).

17 The following are also relevant material considerations:

The Mayor’s draft replacement London Plan (October 2009) which underwentExamination in Public in 2010 and upon which the Panel has now reported is a relevantmaterial consideration of significant weight.

The draft Core Strategy and Development Management Policies Development PlanDocument (consultation closed 5 February 2011).

The Kidbrooke Development Area Supplementary Planning Document.

Principle of development

Policy background

18 The London Plan focuses on Kidbrooke at paragraph 5.123, which states, “The KidbrookeArea centres on Kidbrooke rail station and will include the Ferrier housing estates together withadjoining recreation facilities. A masterplan for the redevelopment of the area is being prepared,

with the aim of creating a sustainable mixed-use neighbourhood incorporating at least 2,400addit ional new homes. The development should focus on integrating the station, which will have



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improved links to north Greenwich, with the surrounding area and improving links within the areaacross existing roads and rail lines.”

19 The Mayor’s draft replacement London Plan makes similar reference in Table A1.1Opportunity Areas, but with the housing target set at a minimum of 4,400.

20 At local level, Greenwich Council has published the Kidbrooke Development AreaSupplementary Planning Document (June 2008) which sets key development aspirations andsupplements the Council’s UDP Policy H4. The key objectives within the SPD seek to achieve thefollowing:

Create a mixed neighbourhood and community.

Provide approximately 4,400 units including the replacement of 1,900 affordable homes.

Create quality open space.

Provide a local shopping centre.

Improve transport interchange and public transport.

A minimum of 43% affordable housing across the SPD area.

A minimum of 50% affordable housing on the Greenfield sites allocated for new housing.

A 70/30 split between social rent and intermediate housing.

21 As set out in the previous report to the Mayor (PDU/2245/ 01 & PDU/2245/ 02) the

principle of estate regeneration is supported in broad terms. At that time, the quantum and mix ofuses as set out in the approved masterplan was broadly consistent with the aspirations of the SPDguidance and the designation as a set out in the London Plan.

22 The applicant is in the process of delivering on phases 1, 2 and 2a providing 1,159 units,170 extra care units and 90 sq.m. community space.

23 This application is detailed submission for phase 3 formally the Hub, now KidbrookeVillage Centre. As set out in table 1, the quantum of development has changed as have the mix ofuses. There is a significant increase in residential quantum for this particular phase in comparisonto the outline detailed approved for this phase. Specifically the residential quantum has increased

by 421 units and there is an increase in commercial floorspace overall. The application alsoproposes a reduction in community space including the provision of GP facilities and no longerincludes office or leisure space due mainly to the exclusion of land to the north, which wasintended as the location for these particular uses.

24 The applicant states the driver for the increase in residential provision is for three mainreasons:

Other Phases (e.g. Phase 2) of the Kidbrooke redevelopment have been designed toprovide less flats and more low-rise houses, to respect the character of thesurrounding area. This has slightly reduced the number of units coming forward to

date.



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The site area of the Village Centre is slightly larger than previously envisaged at theoutline stage to the south. There is a reduction in area due to the exclusion of landto the north.

The proposals seek to ensure that the number of residential dwellings surroundingthe train station and Kidbrooke Park are maximised.

25 There is however limited commentary or justification for the reduction of other land usesapproved in the outline for this phase, including office, leisure and the significant reduction incommunity space. The land area to the north is a key constraint which suggests the loss of theoffice and leisure can be accepted as these may come forward at a later date; however the locationof community space has always been focused to the south of the railway, directly accessible andcentral to the current scheme. The reduction in community space has not therefore been clearly justified. The planning statement suggests that there are ongoing discussions with Greenwich PCTin terms of providing GP surgery and healthcare facilities; however the broad approach tocommunity space needs to be reconsidered.

Commercial development:

26 As previously reported (PDU/2245/01) the application falls outside the Town Centreboundary of Woolwich, Eltham and Greenwich. Whilst this is the case, a local centre for Kidbrooke,has been identified within Greenwich Council’s UDP, Policy H4, and within Greenwich Council’sUDP Proposals Map (Policy STC2 (iii)) and the Kidbrooke Development Area SPD. Table 5D.1 ofthe London Plan also identifies an indicative employment capacity for Kidbrooke of 400 new jobs,in the period up to 2026, subject to adequate transport capacity improvements. This is alsoreflected in the emerging Plan in Table A1.1 Opportunity Areas.

27 The PPS4 tests were considered at the outline stage (then under PPS6). At that time it wasconcluded that whilst the proposed scale and mix of uses exceeded some of the parameters withinthe SPD, the mix and scale would meet locally arising need, generated from the estate renewal andintensification of the masterplan area in an identified local centre within the plan was thereforesupported. The further increase in commercial space is for an additional 1,799 sq.m. Theapplicant has provided further impact analysis in the retail and hotel assessment submitted as partof the application. This considers the sequential test again and the impact on Eltham Town Centre,Blackheath District Centre, Lee Green District Centre, other local parades and out of centrefacilities. The sequential test is satisfied in this instance, and the evidence suggests that thequantum proposed would meet the needs of the immediate emerging population withoutsignificant adverse impacts on existing centres.

28 The London Plan states that neighbourhood and more local centres typically serve a

localised catchment, often most accessible by walking and cycling and include local parades andssmall clusters of shops mostly for convenience goods and other services, They may include a smallsupermarket (less than 2,000 sq.m.) sub-post office, pharmacy, launderette and other useful localservices. The quantum of retail proposed in this instance would not undermine the localdesignation. The London Plan identifies that larger district centres typically contain between10,000 and 50,000 sq.m of retail. In this context the approach remains proportionate to theemerging population and masterplan objectives and consistent with the requirements of PPS4.

Affordable housing

29 The Kidbrooke regeneration is an estate renewal application of which this phase is an

integral part. Policy 3A.15 of the London Plan resists the loss of housing, including affordablehousing, without its planned replacement at existing or higher density. Paragraph 3.75 of theLondon Plan gives further advice on the Mayor’s approach to estate renewal. This approach is



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carried through to the draft replacement plan in policy 3.13 (B) and paragraph 3.75. More detailedguidance is set out in Section 20 of the Housing SPG and policy 3.15 of the draft London Plan. This clarifies that there should be no net loss of affordable housing, which can be calculated on ahabitable room basis and should exclude right to buy properties. Replacement affordable housingcan be of a different tenure mix where this achieves a better mix of provision. Private housing that

forms part of estate renewal schemes need not provide the normal level of additional affordableprovision as required by policy 3A.10, where this is necessary to cross subsidise redevelopment. This would need to be justified through a financial appraisal.

30 The section 106 agreement for the outline planning permission requires the delivery of aminimum 43% of housing provision as affordable housing across the development, with variationon individual phases. The minimum provision for this particular phase was secured at 38.1%.

31 The current housing offer for this phase is set out in table 2 and represents 38% (split as45/55, social/ intermediate). The quantum, tenure split and bedroom size mix remains the subjectof further discussions. The need for a viability appraisal may not be required in this instance giventhe phase is broadly consistent with the outline permission in terms of minimumdelivery. Thephase is however larger and the breakdown of delivery of affordable housing on current phasesunder construction needs to be confirmed. Furthermore it is also important that the implicationsof the new affordable housing model, as outlined in the HCAs affordable housing programmeframework, as well as changes to funding and definitions of affordable housing, are recognised inthe approach. It may be appropriate to consider the use of a review mechanism within the section106 agreement to ensure the policy regarding the maximum reasonable amount is deliverable. GLAofficers therefore require further discussion on the matter of affordable housing quantum with theCouncil and the applicant to ensure that the policy requirement regarding the maximum reasonableamount has been satisfied.

Tenure split

32 As above, the availability of HCA funding and changes to the definitions of affordablehousing will be a determining factor regarding the type of affordable housing products that will besecured. The planning policy position is, however, currently unchanged. London Plan Policy 3A.9states that affordable housing targets should be based on an assessment of regional and localhousing need and a realistic assessment of supply, and should take account of the London Planstrategic target that within the affordable element 70% of housing should be social and 30%intermediate provision, and of the promotion of mixed and balanced communities. Policy 3.12 ofthe draft replacement London Plan states that within the 13,200 affordable homes per year target,the Mayor will, and boroughs and other partners should, seek to ensure that 60% is social housingand 40% is intermediate. The current offer set out in table 2 provides a tenure spite set at 45/ 55

(social/ intermediate). This tenure split needs to be considered in the context of the othersurrounding phases. The applicant should provide details of how the proposed split fits in thiswider context. The applicant will therefore need to confirm current affordable housing delivery onthe emerging phases 1, 2 and 2a.

33 The masterplan objective seeks to redress the balance of tenure to an even split (50/ 50social/ intermediate). The Mayor accepted this approach given the circumstance of the estate aswholly social rented in tenure, with a significant lack other tenants including private marketaccommodation. Further discussion will be necessary in line with the above considerationregarding affordable housing quantum.



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Mix of units

34 London Plan Policy 3A.5 encourages a full range of housing choice. This is supported bythe London Plan Housing Supplementary Planning Guidance, which seeks to secure familyaccommodation within residential schemes, particularly within the social rented sector, and sets

strategic guidance for councils in assessing their local needs. Policy 3.12 of the draft replacementLondon Plan states that within affordable housing provision, priority should be accorded to familyhousing. Recent guidance is also set out in the draft revised interim Housing SupplementaryHousing Guidance (October 2009) and draft replacement London Plan policy 3.8, which seeks towiden housing choice.

35 A mix is provided as set out in the above table 2 but may be subject to change. There isclearly a higher proportion of 1 and 2 bedroom units and the applicant will need to justify theapproach and demonstrate that this does not undermine the overall masterplan objectives in termsof delivering affordable family size accommodation. As with the other housing matters, this issubject to the emerging phases and its context of the approved masterplan. Whilst the VillageCentre is the most appropriate opportunity to deliver high density, it can also support familyaccommodation, given the proximity to local town centre facilities.

Density

36 London Plan Policy 3A.3 outlines the need for development proposals to achieve thehighest possible intensity of use compatible with the local context, the design principles withinPolicy 4B.1 and public transport capacity. Table 3A.2 of the London Plan provides guidelines ondensity in support of policies 3A.3 and 4B.1. As mentioned above, Policy 3.4 of the draftreplacement plan moves away from maximising site capacity to optimising development potentialwith a stronger focus on local context in particular (Table 3.2).

37 Based on the character and location of the site the London Plan suggests a density ofbetween 200-450 habitable rooms per hectare. The applicant states that this part of the site wasapproved with a density of 350 units per hectare, higher than the London Plan guidance given themix of uses a focus on non-family accommodation and its location as part of the station hubdevelopment and close to the wider park and open space areas to the west. It is not clear wherethis is set out and how the proposed density for the current application fits within theseparameters given the site area has changed and the phase is significantly different. The densitycalculation should be explicitly set out as a formula and explained in accordance with the guidancein the London Plan and the Mayor’s Housing SPG. The design suggests the density is significantand therefore it is important that the Mayor’s objective to optimise rather than maximise fits withinthe masterplan aspirations.

Urban design and access

38 Good design is central to all objectives of the London Plan and is specifically promoted bythe policies contained within Chapter 4B which address both general design principles and specificdesign issues. London Plan Policy 4B.1 sets out a series of overarching design principles fordevelopment in London. Other design polices in this chapter and elsewhere in the London Planinclude specific design requirements relating to maximising the potential of sites, the quality ofnew housing provision, tall and large-scale buildings, built heritage, views, and the Blue RibbonNetwork. The draft replacement London Plan reinforces these principles, with new developmentrequired to have regard to its context, and reinforce or enhance the character, legibility and

permeability of the neighbourhood (policy 7.1).



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39 The design of the Village Centre primarily consists of four building typologies:

Residential towers (‘pocket towers’) – Higher density buildings (8 to 15 storeys) in areasof prominence;

Linear buildings – Medium density buildings (4 to 9 storeys) that help to define plotboundaries;

Town Houses – Low density buildings (2 to 3 storeys) that provide screening and varietyto the development;

Other Buildings – Standalone buildings of distinct use and design including the station,the hotel and the park pavilion building.

Figure 4 scheme overview

Layouts and residential quality

40 The Mayor has published his draft Housing Design Guide and aspects of this, notably theminimum space standards for dwellings, are also reflected in the draft replacement London Plan.Policy 3.5 of the draft replacement London Plan introduces a new policy on the quality and designof housing developments. Part A of the draft policy states that housing developments should beof the highest quality internally, externally and in relation to the wider environment. Part C of thedraft policy states that new dwellings should meet the dwelling space standards set out in Table3.3, have adequately sized rooms and convenient and efficient room layouts. Part E of the draftpolicy states that the Mayor will provide guidance on implementation of this policy including onhousing design for all tenures. The reasoned justification provides further guidance andexplanation. In particular paragraph 3.31 states that other aspects of housing design are also

important to improving the attractiveness of new homes as well as being central to the Mayor’swider objectives to improve the quality of life of Londoner’s environment.



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Figure 5: plot layouts

41 The layout is split over a series of plots A, B, C, D, E, F, G, the station building and pavilionbuilding onto the park. Figure 5 sets out the key plots layouts Commercial and non residential

uses are focused to the north of the site in plot A, B, C and D, closest to the station

42 In general terms the layouts of the flats are well considered. Cores are located centrally oron the north elevation of blocks. Defensible space within the courtyards needs to be designed indetail. A breakdown of balcony sizes should also be provided as many appear fairly small andunusable. There is no single aspect north facing only units which is welcomed. There are somesingle aspect units, but these either benefit from east, west or southerly outlook. The schemeprovides a range of no more that 3-7 units per core (in most cases between 4 and 5) which shouldbe commended as it allows the level of multi aspect accommodation to be fairly high and createsintimate private cores improving residential quality. The provision of front doors onto the streetshould be maximised to enhance pedestrian movement and natural activity with the street. Whilst

the applicant commits to the Mayor’s Housing Design Guide standards, a full breakdown of thespace standards should be provided across all tenures. Further detailed comments on each plot isset out below:



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Plot A

43 The ground floor is well considered, commercial layouts are acceptable and the residentialentrance points are evenly spaced. The number of units per core is between 4 and 5 and is broadlysupported.

Plot B (hotel block)

44 The layout to the north is essentially the back of the building which interacts poorly withthe street. This was raised at pre-application stage. It is difficult to resolve given the building has360 degree frontage with the street. The design team should therefore provide rendered imagesof how this elevation will appear in the street.

Plot C (including the station building)

45 Ground floor layout is well considered and provides active frontage along all elevations. The residential arrangement is over 6 units per core and is acceptable. The balconies to the tower

should be increased in size.

Plot D (supermarket)

46 Kidbrooke Park Road elevation has some unfortunate uses at ground floor, including thesupermarket storage area and two fairly large car park vents which result in a poor elevation,lacking active frontage. The residential entrance on the eastern elevation of plot D is also poorlylocated between the car park and the service yard entrance. The retail frontage to the north ispositive.

Plot E

47 The arrangements for the pedestrian bridge heading north are unclear. It forms animportant link to the north and the introduction of its presence in the centre visually (i.e visible onthe east/ west – north/ south access routes, is supported). The space around it and associationwith the creche needs some further consideration. Upgrade of landscaping and lighting could helpto improve the area to make it a more inviting and surveyed area of the site. A groundsman storeand temporary refuse store is also shown to the east. Visualisations should be provided to showhow the store will fit within the existing constraints of the bridge. The ground floor layout to themain residential block is supported; however the design team should consider introducing morefront doors with direct access onto the street on the east and northeast elevations. It isunfortunate that steps up to the town houses on the western elevation cannot be designed out.

Defensible space within the courtyard should be designed in detail. The link between the twocourtyard podium levels should be considered.

Plot F

48 The level change results in the building having a blank podium elevation facing west ontothe open space designed using ‘hit and miss brick’. This is unfortunate and is not successful interms of integrating the open space into the building or providing direct access onto the openspace and up to Kidbrooke Park Road. The podium should be removed to provide level access. The number of direct residential entrance points should then be increased at ground floor to thewest elevation to provide a street frontage. Alternatively the design team should considerintroducing town houses along this elevation. The corner unit on the northeast corner should alsobenefit from a front door onto the street.

Plot G



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49 The western elevation appears unresolved. There appears to be no active uses for themajority of the block on the western side. This needs further consideration as it creates an harshrelationship with the street, that is unfortunate given the rest of the masterplan seeks to embracethe street/ block relationship. It is unclear why town houses have not been introduced as with therest of the block typology with other plots. Given the length of this particular block, the height

seems fairly oppressive, particularly as this part of the masterplan seeks to integrate with the lowermore suburban elements to the east.

Figure 6 single aspect (white) and multi aspect (green) units

Building height

50 As set out above, the height of the buildings ranges between the town house scale (2-3storey) up to the 15 storey ‘pocket towers’. The natural graduation of scale is not apparent in themasterplan as would be expected given the scale to the east and south will be lower. Theimplications in terms of the wider long distant views are acceptable, however, it is not clear howthe blocks, particularly F and G, will sit within the local context. The design team should thereforeprovide further townscape analysis in the form of visualisations to ensure the scale is compatiblewith the graduation outside the redline of this phase. In addition, the impact of the tower andblocks above the supermarket need to be tested in terms of shadowing across the pubic square.

Architecture



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51 London Plan policy 4B.1 and 4B.2 underpin the Mayor’s aspiration to create world classarchitecture that inspires, excites and delights. The proposal will be high quality in terms of theappearance and materiality.

52 The design is well considered in broad terms with high quality architecture as shown in the

images presented. This is consistent with the parameters of the outline permission.

Children’s play space

53 Policy 3D .13 of the London Plan sets out that “the Mayor will and the boroughs shouldensure developments that include housing make provision for play and informal recreation, basedon the expected child population generated by the scheme and an assessment of future needs.”Using the methodology within the Mayor’s supplementary planning guidance ‘Providing forChildren and Young People’s Play and Informal Recreation’ it is anticipated that there will beapproximately 312 children within the development. The guidance sets a benchmark of 10 sq.m.of useable child playspace to be provided per child, with under-5 child playspace provided on-site.As such the development should make provision for 3,120 sq.m. of playspace.

54 The outline masterplan comprehensively deals with the issue of open space and play spacethrough the introduction of a range of uses and formal facilities such as courts.

Local Areas of Play – every 100 metres.

Local Equipped Areas for Play – every 400 metres.

Neighbourhood Equipped Areas for Play – Every 1000 metres.

Multi Use Games Areas – Every 1000 metres.

New MOL open space – 45,000 sq.m.

New allotment space.

55 There is however very limited commentary on how the Village Centre phase will specificallydeal with the emerging population for play opportunities. It is also unclear how the masterplanintended to phase in these facilities as the scheme develops over time. This needs to bereconsidered by the applicant to ensure that there will be interim access for children duringconstruction as well as the facilities at the end state of the estate renewal.

Access and inclusive design

56 London Plan policy 4B.5 and the corresponding draft replacement London Plan policy 7.2seek to ensure that proposals achieve the highest standards of accessibility and inclusion (not justthe minimum), and this and all developments should seek to better minimum access requirements.Design and access statements should explain the design thinking behind the application anddemonstrate how the principles of inclusive design, including the specific access needs of disabledand older people, have been integrated into the proposed development and how inclusion will bemaintained and managed. The development should aim to meet the highest standards of

accessibility and inclusion.

Commercial buildings



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57 The broad arrangements for access into the commercial buildings is through step freeenvironment. This is supported. The station similarly creates grade level entrance which removesthe convoluted approach to the station at present.

Residential Units

58 Policy 3A.5 of the London Plan and policy 3.8 of the draft replacement London Plan require that 100% of new homes meet the Lifetime home standards and that 10% of new housingis designed to be wheelchair accessible or easily adaptable for residents who are wheelchair users.

59 The applicant confirms a commitment to Lifetime Home Standards and 10% wheelchairunits. Flat layouts are provided to determine that the standards will be met. This should beconditioned by Greenwich Council.

60 There needs to be flexibility for allocation of parking spaces as residential units are adaptedin the future and for Blue Badge users who may reside in the Lifetime Home apartments. Thearrangements for the future review of demand and supply of bays for disabled people should be

reflected in the parking management and travel plans. This can also be conditioned by GreenwichCouncil.

61 Extending the Lifetime Home concept to the neighbourhood level can help to ensure thatthe public realm, amenity spaces, the parking areas, the routes to and from the site and links toadjacent public transport and local services and facilities are all designed to be accessible, safe andconvenient for everyone, particularly disabled and older people. This concept can also help tomeet the specific needs of older people. The pedestrian links to the adjacent roads are level orgently ramped. The lighting design is particularly important to create safe, well and evenly lightroutes through and into the site, in particular the existing route north over the bridge. This shouldbe conditioned by the Greenwich Council

Climate change mitigation

62 The London Plan climate change policies as set out in chapter 4A collectively requiredevelopments to make the fullest contribution to tackling climate change by minimising carbondioxide emissions, adopting sustainable design and construction measures, prioritisingdecentralised energy supply, and incorporating renewable energy technologies with a target of20% carbon reductions from on-site renewable energy. The policies set out ways in whichdevelopers must address mitigation of, and adaptation to, the effects of climate change. Thecorresponding policies within the draft replacement London Plan are set out in chapter 5.

63 The applicant has broadly followed the energy hierarchy. Sufficient information has beenprovided to understand the proposals as a whole. The proposals are broadly acceptable; however,further information is required before the carbon savings can be verified as set out below.

Be lean

Energy efficiency standards

64 A range of passive design features and demand reduction measures are proposed to reducethe carbon emissions of the proposed development. Both air permeability and heat loss parameterswill be improved. Other features include energy efficient lighting and minimising the use ofthermal bridging. The development is estimated to achieve a reduction of 6 tonnes per annum(0.5%) in regulated carbon dioxide emissions compared to a 2010 Building Regulations compliantscheme.



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Be clean

District heating

65 A heating network will connect all residential and non-residential buildings within thedevelopment fed from a single energy centre beneath Plot C. It is proposed that this network willconnect into the wider Kidbrooke Village District Heat Network at a later date.

Combined Heat and Power

66 Combined heat and power is proposed as the lead heat source for the network providing60% of residential and non residential heat load. A reduction in carbon dioxide emissions of 368tonnes per annum (13%) will be achieved through this second part of the energy hierarchy.

Cooling

67 The proposal does not require air conditioning for residential units. There will however be

cooling requirement for the non residential uses. This is however not clearly set out in the energystrategy and therefore further information is required.

Be green

Renewable energy technologies

68 No onsite renewable energy is proposed. The applicant has identified space for a maximumof 3,764 sq.m. of photovoltaic panels which would reduce carbon emissions by 229 tonnes (9%). The applicant should reconsider making a minimum contribution or provide technical justificationto support its rejection.

Summary

69 The estimated carbon emissions of the development are 2,628 tonnes of carbon dioxide peryear after the cumulative effect of energy efficiency measures and combined heat and power hasbeen taken into account. Taking into account the comments above, the applicant should providean estimate of the overall regulated carbon dioxide emissions savings compared to a 2010compliant development.

Climate change adaptation

70 The London Plan promotes five principles in Policy 4A.9 to promote and support the mosteffective adaptation to climate change. These are to minimise overheating and contribute to heatisland effects; minimise solar gain in summer; contribute to flood risk reduction, including applyingsustainable drainage; minimising water use; and protect and enhance green infrastructure (thecorresponding draft replacement London Plan policy is policy 5.3). There are specific policiescovering overheating, living roofs and water. Further guidance on these policies is given in theMayor’s SPG Sustainable Design and Construction.

71 Policy 4A.11 and draft London Plan policy 5.11 seek major developments to incorporateliving roofs and walls where feasible. Policy 4A.14 of the London Plan and Policy 5.13 of the draftreplacement plan seek to ensure that surface water run-off is managed as close to its source as

possible and sets out a hierarchy of preferred measures to achieve this. Policy 4A.16 of the LondonPlan and policy 5.15 of the draft replacement plan seek to ensure that new development has



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proper regard to the impacts on water demand and existing capacity by minimising the use oftreated water and maximising rainwater harvesting.

72 A sustainability statement supports the application and demonstrates general compliancewith the relevant London Plan policies on sustainable design and construction and climate change

adaptation. The commercial component is designed to achieve a BREEAM ‘very good’ rating andthe residential component with Code for Sustainable Homes level four. The provision of a newopen space to the west of the site and incorporation of a significant proportion of living roofs isparticularly positive in terms of climate change adaptation. In summary the proposal would beconsistent with London Plan policies 4A.3 and 4A.9 and the associated policies. The Councilshould secure the proposed measures by condition.

Transport for London’s comments

73 The residential car parking is being proposed at a ratio below the maximum level agreed aspart of the consented masterplan, which is supported. This equates to the provision of one space

per house (or 25 spaces), and 0.54 spaces per flat (or 503 spaces), plus two car club spaces. It isnoted that a controlled parking zone is proposed to be introduced by the applicant. This issupported, and TfL recommends that this requirement is secured for the site either by condition orthrough the section 106 agreement. The controlled parking zone should restrict potentialcommuter parking on the streets close to the train station.

74 It is noted that the 24 car parking spaces currently associated with Kidbrooke station are tobe retained as part of these proposals, with an additional 171 spaces for the commercial uses, alsobeing proposed. Whilst this level of provision is accepted in principle and is consistent with theconsented Masterplan, TfL question how parking will be managed on site. The transportassessment states that “for security and management purposes, access to the car parking will beeither gated or barrier controlled”, however given the number of spaces proposed on site and theproximity to the train station, TfL recommends that a specific car park management plan for thisphase of the development, be secured for the site by condition. TfL also recommends furtherconsideration for blue badge parking provision closer to certain building plots, such as thecommunity areas/healthcare, and also the benefit from a managed drop-off area on site. Thisshould therefore be further investigated.

75 Electric vehicle charging points are being proposed in accordance with Policy 6.13’Parking’, of the draft replacement London Plan (DRLP). This is supported, and should be securedby condition.

76 Both the residential and commercial trip generation has been based on previously agreed

criteria. As a result, TfL can confirm that the trip generation exercise and modal split presentedwithin the transport assessment is sufficiently robust.

77 At present, a number of junctions are shown operating either close to, or over capacity inboth scenarios considered within the transport assessment, and while TfL has provided interimcomments on the individual junction modelling as part of its letter to the borough, until the resultsof the VISSIM model, which is being developed in parallel in conjunction with TfL, have been seen, TfL is not in a position to fully comment on the junction proposals and their acceptability.Following the submission of the VISSIM modelling however, any mitigation measures provednecessary as a result of this development will need to be agreed with TfL, and secured through asection 278 agreement with the relevant highway authority (or a financial contribution where

appropriate), in accordance with the section 106 agreement secured as part of the consentedMasterplan.



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78 TfL would reiterate its current concerns over the number of new signalised junctionsproposed on the Transport for London Road Network, in accordance with Policy 6.11 ‘Smoothingtraffic flow and tackling congestion’ of the draft replacement London Plan. Since the Masterplanwas originally approved, the change in policy direction has now resulted in a presumption againstthe installation of any new traffic signals, particularly on the Transport for London Road Network.

As a result, further work will be required to fully justify the need for providing these new signals,while also demonstrating that an alternative, non-signalised layout would not perform adequatelyin that location.

79 TfL understands that while the pedestrian crossings are shown as being straight acrossKidbrooke Park Road, they actually act as staggered crossings. TfL does however have somesafety concerns about this proposed arrangement, as further detailed in its letter, and this shouldtherefore be addressed. It is also noted that particularly for southbound traffic on Kidbrooke ParkRoad, the merge from two lanes into a single one on the exit from the junction is short, and TfLwould therefore question whether this is sufficient. Swept paths for both left and right turns willalso need to be provided to demonstrate that the junction can accommodate all anticipated traffic.

80 This phase of the development will require the existing bus services (B16 and 178) to bere-routed through the site. As such, discussions are needed over what bus priority measures andinfrastructure will be required, in order to support the diversion. As part of this, future bus stoplocations and designs will need to be agreed between TfL the Council and the applicant, and willneed to be fully funded through the contributions previously secured towards bus stopimprovements, as part of the consented masterplan section 106 agreement, and in accordance withPolicy 6.7 ‘Buses, bus transits, trams’, of the draft replacement London Plan.

81 It is noted that this phase of development will take the number of units on site, to just over2,100. Given that this proposed residential quantum is similar to that was present prior to thedecant process taking place, TfL accepts that the impact on the capacity of the local bus networkwill be limited.

82 As part of the consented masterplan, it was proposed to relocate the existing bus layoverspace from Henley Cross, to south of the railway line, in order to improve interchange betweenbuses and the improved train station. It is understood however, that as a result of spaceconstraints within the village square, this is no longer feasible. As such, it is now proposed toretain the existing bus standing space in its current location, to the north of the railway line, but toupgrade the waiting environment through the provision of improved lighting and security, as wellas new driver facilities. This is supported by TfL, in accordance with Policy 6.2 ‘Providing publictransport capacity and safeguarding land for transport’ of the draft replacement London Plan, andfurther discussions are therefore needed over the exact nature of the improvements required, and

how they will be best secured, given that this was excluded from the obligations secured in theoriginal section 106 agreement.

83 It is not clear from the transport assessment what provisions are proposed to accommodatecoach and taxi demand arising from the hotel, or from the station, and clarification on this point istherefore required.

84 The transport assessment states that the development will provide a number of newpedestrian routes through the area of Metropolitan Open Land, linking up to the pedestriancrossing facilities on Kidbrooke Park Road, and while this is supported, TfL would howeverreiterate the caveats relating to the provision of new signals on Kidbrooke Park Road. Wayfinding

around the site should also be considered to ensure that new footpaths through the MetropolitanOpen Land are appropriately located. TfL would therefore welcome discussions over theappropriateness of introducing Legible London to the site, and whether additional contributions



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need to be secured in order to implement this, in accordance with Policy 6.10 ‘Walking’, of thedraft replacement London Plan.

85 1,182 cycle parking spaces are being proposed on site, with cycle parking across all landuses complying with the London Plan standards, which is supported. In addition, TfL considers

that the applicant should ensure that the main routes through the Metropolitan Open Land aresuitable for shared use by cyclists and pedestrians, and that they are of a minimum of three metresin width, with suitable tactile paving to allow for this, as should any other routes which areintended to be shared between pedestrians and cyclists.

86 While the travel plan is considered to generally be of a good quality, some furtherenhancement is required. Primarily, the plan needs to reference the anticipated number of tripsinto and out of the site, as while this information is included in the transport assessment, it is nothowever reproduced in the travel plan. Some information on phasing, funding and how the travelplan will be secured should also be provided.

87 It is noted and accepted that the construction impacts will be assessed in more detail post-consent, once a contractor has been appointed. This should be done as part of a specificconstruction logistics plan for Phase 3, which TfL would recommend is secured for the site bycondition, in accordance with Policy 6.14 ‘Freight’ of the draft replacement London Plan. This willsubsequently need to be agreed by TfL in addition to the Council, due to the requirement toremove the existing Tudway Road Bridge as part of the construction works, and its replacementwith a new highway layout.

88 In summary, while initial assessment suggests that the implementation of this phase of thedevelopment is unlikely to impact on the capacity of the local bus network, additional information,as further detailed above, is however required in order to fully determine the impact on thehighway network and to agree a suitable package of mitigation measures going forward. In

addition, given the current policies on ‘smoothing traffic flow’, further justification is required, forthe installation of any new signals on the TLRN to be considered acceptable.

Local planning authority’s position

89 The officer recommendation is currently unknown.

Legal considerations

90 Under the arrangements set out in Article 4 of the Town and Country Planning (Mayor ofLondon) Order 2008 the Mayor is required to provide the local planning authority with a statementsetting out whether he considers that the application complies with the London Plan, and hisreasons for taking that view. Unless notified otherwise by the Mayor, the Council must consult theMayor again under Article 5 of the Order if it subsequently resolves to make a draft decision on theapplication, in order that the Mayor may decide whether to allow the draft decision to proceedunchanged, or direct the Council under Article 6 of the Order to refuse the application, or issue adirection under Article 7 of the Order that he is to act as the local planning authority for thepurpose of determining the application and any connected application. There is no obligation at

this present stage for the Mayor to indicate his intentions regarding a possible direction, and nosuch decision should be inferred from the Mayor’s statement and comments.



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Financial considerations

91 There are no financial considerations at this stage.

Conclusion

92 London Plan policies on affordable housing, housing mix, density, urban design, access,climate change and transport are relevant to this application. The application complies with someof these policies but not with others, for the following reasons:

Principle of development: (non-compliant) There is no clear justification for the reductionin community floor space, or clarity for the delivery of healthcare facilities.

Affordable housing, tenure split, bedroom size mix and density (non-compliant): Furtherevidence regarding affordable housing delivery on current phases is required. Theproposed phase is larger than that envisaged by the outline, therefore the minimumdelivery of affordable housing needs reconsideration as does the detail of the density

calculation. Further discussion regarding the need for a revised financial parasail istherefore required. These discussions will inform the tenure split, bedroom size mix andoverall density.

Urban design and access (non-compliant): The report identifies some detailed designmatters that require further consideration, including the arrangements of plot F and G,number and location of front doors, various elevation treatments around plot D and abreakdown of space standards.

Climate change mitigation (non-compliant): The applicant should provide a contributiontowards renewable energy and set out the strategy for cooling. The applicant shouldsummarise the overall carbon saving beyond 2010 building regulations.

Climate change adaptation (compliant): broadly acceptable subject to conditions set out inthis report.

Transport (non-compliant): A number of technical transport concerns are set out inparagraph 73-88 in the transport section of this report.

93 On balance, the application does not comply with the London Plan.

94 The following changes might, however, remedy the above-mentioned deficiencies, andcould possibly lead to the application becoming compliant with the London Plan:

Principle of development: Evidence to support the reduction in community uses is required. Affordable housing: Further discussion with the GLA regarding the need for a viability

appraisal. This will inform other housing and density related matters.

Urban design and access: The design team need to reconsider a number of matters as setout in this report, including the arrangements of plot F and G, building scale to plot F andG, the number and location of front doors, various elevation treatments around plot D anda breakdown of space standards. The applicant should also provide additionalvisualisations of the hotel service area and the pedestrian link bridge to the north. Lifetimehomes and 10% wheelchair units should be conditioned by Greenwich Council.

Climate change mitigation: provision of renewable energy, cooling strategy and summary ofoverall carbon dioxide savings beyond 2010 building regulations.



Transport: Whilst the initial assessment suggests that the implementation of this phase ofthe development is unlikely to impact on the capacity of the local bus network, additionalinformation is however required, as further detailed above in paragraph 72-87 of thisreport, in order to fully determine the impact on the highway network and to agree asuitable package of mitigation measures going forward. In addition, given the current

policies on ‘smoothing traffic flow’, further justification is required, for the installation ofany new signals on the TLRN to be considered acceptable.

for further information, contact Planning Decisions Unit:Colin Wilson, Senior Manager – Planning Decisions020 7983 4783 email [email protected]

Justin Carr, Strategic Planning Manager (Development Decisions)020 7983 4895 email [email protected] CaseOfficer

Documents

Kidbrooke Village Centre Kidbrooke Estate Report (Planning Decisions)