Planning Statement

In respect of

Land at Rookwood Avenue

New Malden

KT3 4PT

On behalf of

Goldcrest Land

RPS CgMs Ref: KG/2046

October 2017
QUALITY MANAGEMENT

Prepared by: Kevin Goodwin

Authorised by: Kevin Goodwin

Date: October 2017

Project Number/Document KG/2046

Reference:

COPYRIGHT © RPS CgMs

The material presented in this report is confidential. This report has been prepared for the exclusive use of Goldcrest Land Plc and
shall not be distributed or made available to any other company or person without the knowledge and written consent of RPS CgMs.

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CONTENTS

1 INTRODUCTION ..................................................................................................................................... 1
2 SITE AND SURROUNDING AREA ........................................................................................................ 2
3 PLANNING HISTORY ............................................................................................................................. 3
4 PROPOSED DEVELOPMENT ................................................................................................................ 4
5 PLANNING POLICY CONSIDERATIONS ............................................................................................. 6
6 CONCLUSIONS .................................................................................................................................... 22

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1 INTRODUCTION

1.1 Goldcrest Land (the Applicant) is proposing the partial development of the land at the northern
end of Rookwood Avenue.

1.2 Full planning permission is sought for the following (the Development):

“Erection of three detached houses with parking, formation of new vehicular access from
Rookwood Avenue, provision of footpath link between Rookwood Avenue and Blagdon
Road, enhancement of biodiversity value of the western and northern parts of the site
together with minor amendment to the site boundary with 36 Rookwood Avenue so as to
enlarge their garden.”

1.3 The application is accompanied by the following supporting documents:

- Design and Access Statement;

- Bat Survey

- Phase 1 Environmental and Geotechnical Site Investigation Report;

- Ecology Report;

- Flood Risk Assessment and SUDs (including Drainage)

- Landscape Strategy;

- Reptile Survey;

- Transport Statement ;

- Arboricultural Report;

- Water Vole Survey;

- Utilities Assessment;

- Sunlight and Daylight Statement;

and

- Statement of Community Involvement

1.4 This Statement analyses the planning history of the site, the physical context of the development
and demonstrates that the proposal would comply with the relevant planning policies of the local
development framework.

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2 SITE AND SURROUNDING AREA

2.1 The following section provides an overview of the site together with its immediate and wider
context.

The site

2.2 The site is a triangular area of land that is located at the north end of the cul de sac of Rookwood
Avenue. Historically it formed part of playing fields but in recent years has been left to become
overgrown and has been dumped with aggregate materials by the previous land owners. To the
west is a footpath that links Blagdon Road with the Shannon Commercial Centre, along the
Beverly Brook.

2.3 Beyond the brook are the rear of the houses in Onslow Road and their gardens. To the south are
two storey, some with roof accommodation, houses that line both sides of Rookwood Avenue.

2.4 At its southern end Rookwood Avenue joins with Burlington Road that links to the A3 to the east
with New Malden to the west.

Surrounding Area

2.5 To the east is the large B+Q retail store, with residential against the store at Shannon’s Corner.
To the north is the Shannon’s Corner Commercial Centre. Beyond this is Beverley Park and the
Blagdons Sports Ground

2.6 The site is located approximately 1.1km from New Malden Railway Station. There are buses that
serve the site on Burlington Road.

Environmental constraints

2.7 The site is located partially within a Site of Nature Conservation Interest (SINC), mainly for its
relationship with the Beverly Brook. It is also designated as Open Space in the Site and Policies
Plan.

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3 PLANNING HISTORY

3.1 The site has been subject of a number of planning applications.

3.2 The site was sold at auction by the London Borough of Kingston in July 2013. The then owners
submitted a planning application in September 2013 (LBM Ref. 13/P3152) for vehicle storage
associated with a nearby car sales business and another planning application (LBM Ref.
13/P3652) on 31 October 2013 for six four-bed houses; the latter considered being invalid.

3.3 The then owner subsequently cleared some of the trees and deposited aggregate material on the
site for use as a car park.

3.4 Pre-application discussions were held between the new site owner (the applicant) and the
th th
Council on two occasions on 7 April and 24 June 2017. In addition two public consultation
nd nd
events have been held with the local community on 2 March and 22 June 2017.

3.5 Amendments were made to the proposal following these consultations.

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4 PROPOSED DEVELOPMENT

4.1 As noted in Section 1 of this Statement, the proposal is for the following development:

“Erection of three detached houses with parking, formation of new vehicular access from
Rookwood Avenue, provision of footpath link between Rookwood Avenue and Blagdon
Road, enhancement of biodiversity value of the western and northern parts of the site
together with minor amendment to the site boundary with 36 Rookwood Avenue so as to
enlarge their garden.”

Proposed use

4.2 The development would provide for the provision of three detached family houses on the eastern
side of the site. It would also formalise the present informal cut-through from the northern end of
Rookwood Avenue to the footpath that follows the Beverly Brook from Blagdon Road.

4.3 Importantly the majority of the site is to be enhanced in respect of its biodiversity and ecological
value to provide a varied habitat. This will be appropriately managed either by a Trust to
safeguard its future as undeveloped land which local residents will be encouraged to join or by
gifting the land to the Council with a £25,000 S106 payment towards its maintenance.

4.4 The site has an area of 0.2136 hectares. The density of the proposal would amount to 70 hr/ha
that reflects the need to retain the majority of the site for existing and proposed pedestrian
access and biodiversity.

Orientation, massing, height and design

4.5 The proposed houses would be located on the eastern side of the site and accessed from the
northern end of Rookwood Avenue on foot and by car. They are two storeys with
accommodation within a pitched roof.

4.6 The houses would have rear gardens and parking would be provided between the houses. They
will be of contemporary design with materials to match the existing materials pallet in Rookwood
Avenue.

4.7 They will be located parallel with the existing houses and therefore some distance from the
nearest residential units to the west and to the east.

External and private amenity space

4.8 Each house would have private amenity space to the rear of in excess of 50m².

Access, parking and servicing

4.9 The houses would be accessed from the end of Rookwood Avenue and have tandem parking for
two cars each. Parking will be future proofed with electric charging points. Secure provision
would be made for cycle parking in the rear gardens of the houses.

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4.10 The houses have integrated refuse stores.

Adjoining Land

4.11 In addition to the above it is proposed to regularise the current boundary with 36 Rookwood
Avenue so as to provide them with a small addition to their domestic curtilage.

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5 PLANNING POLICY CONSIDERATIONS

5.1 In accordance with Section 38 (6) of the Planning and Compulsory Purchase Act 2004, planning
applications should be determined in accordance with the development plan unless other
material considerations indicate otherwise.

5.2 The statutory development plan for the London Borough of Merton comprises:

 The London Plan (2015) (with Minor Alterations March 2016) (MALP)

 Core Planning Strategy 2011 (CPS)

 Site and Policies Plan and Policies Maps (SPP)

5.3 Other materially relevant policy documents are:

 The National Planning Policy Framework (NPPF)

 The National Planning Practice Guidance (NPPG)

5.4 The following supplementary planning documents are also material planning considerations when
determining planning applications in Merton:

 Design Supplementary Planning Guidance 2004 (Design SPG)

 Sustainable Transport Supplementary Planning Guidance (Sustainable Transport SPG)

Principle of development – Open Space and Residential

5.5 Full details of relevant policies relating to open space at national, strategic and local level are set
out in the accompanying Open Space Assessment submitted with this application.

5.6 DM O1 deals with ‘Open space’ and states:

a) The council will continue to protect Metropolitan Open Land (MOL) and designated open
spaces from inappropriate development in accordance with the London Plan and
government guidance.

b) In accordance with the NPPF, existing designated open space should not be built on unless:
i. an assessment has been undertaken which has clearly shown the open space,
buildings or land to be surplus to requirements; or,

ii. the loss resulting from the proposed develop the loss resulting from the proposed
development would be replaced by equivalent or better provision in terms of quantity and
quality in a suitable location; or,

iii. the development is for alternative sports and recreational provision, the needs for
which clearly outweigh the loss.

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 c) Development proposals within designated open spaces, which have met the conditions set
in part b) above, will be required to meet all the following criteria:
i. the proposals are of a high quality design and do not harm the character, appearance
or function of the open space;

ii. the proposals retain and/or improve public access between existing public areas and
open spaces through the creation of new and more direct footpath and cycle path links;
and,

iii. the character and function of leisure walks and green chains are preserved or
enhanced.

d) The council supports the creation of new open spaces as part of major development
proposals where suitable and viable.

e) Development in proximity to and likely to be conspicuous from MOL or designated open

space will only be acceptable if the visual amenities of the MOL or designated open space
will not be harmed by reason of siting, materials or design (our underlining).

Assessment

5.7 The application site is designated as ‘open space’ on the Policies Map and therefore the
proposed built development falls to be considered against the criteria within this policy. Under
clause b) of the policy proposals only need to meet one the criteria.

5.8 Whilst the site is designated as open space its history and the abuse of the area do not mean
that it functions well as such. The Council has categorised it through its size as a ‘pocket park’.
These are defined in the London Plan as “Small areas of open space that provide natural
surfaces and shaded areas for informal play and passive recreation that sometimes have seating
and play equipment”. Its main function is as a cut-through for local residents to and from
Rookwood Avenue onto the wider footpath network. Otherwise it is overgrown and has been
subject to anti-social behaviour. It does not provide for informal play or passive recreation. The
site has now been hoarded with the support of local residents to prevent further fly-tipping and
illegal occupation.

5.9 As set out in the accompanying report we have undertaken an Open Space Assessment within
which we considered the location and facilities of all the pocket parks in the Borough and then
scoped this further with the Council. Whilst there are no other pocket pocks in this part of Merton
the location of the site on the Borough boundary means that local residents have access to parks
in adjoining borough of Kingston. The two closest parks provide for a range of facilities.

5.10 Whilst development of part of the site will result in a loss of some of the site area there will be no
loss of usable area. We therefore consider that when assessed against criteria b) i) our separate
assessment has demonstrated that this part of the site is ‘surplus to requirements’.

5.11 Further whilst it is not necessary to consider the proposals under b) ii) the loss of that part of the
site resulting from the proposed development would be replaced by much enhanced biodiversity
in quantity and quality on the main part of the site that will be secured by legal agreement and
future ownership and a management structure for the long term.

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 Residential land use and Housing Mix

5.12 Paragraph 49 of the NPPF notes that Housing applications should be considered in the context of
the presumption in favour of sustainable development.

5.13 London Plan Policy 3.3 recognises the need for more homes in London to ensure that there is a
real choice of housing available for all within London. For the London Borough of Merton the
London Plan notes a minimum provision of new homes up to 2025 of 4,107 units with a target of
411 units per annum.

5.14 Policy CS 8 of the Core Strategy relates to Housing Choice. Paragraph a) of Policy CS 8 states
that the Council “require proposals for new homes including new build schemes and
redevelopment proposals to be well designed and located to create socially mixed and
sustainable neighbourhoods”. Paragraph b) states that the Council “will seek the provision of a
mix of housing types, sizes and tenures at a local level to meet the needs of all sectors of the
community. This includes the provision of family sized and smaller housing units and provision for
those unable to compete financially in the housing market sector and those with special needs.
All new housing will be built to lifetime home standards and 10% of new housing will be
wheelchair accessible or easily adaptable for residents who are wheelchair users”.

5.15 Policy CS 9 of the Core Strategy relates to housing provision. It states:

We will:

a. Support the provision of well-designed housing located to create socially mixed and
sustainable neighbourhoods, including the redevelopment of poor quality existing housing
and not support proposals that result in a net loss of residential units, or net loss of
affordable housing units.

b. Work with housing providers to facilitate the provision of a minimum of 4,800 additional
homes for the period 2011 - 2026 including the indicative ranges (rounded figures) for the
sub-areas of:
- 1450 -1800 in Morden.
- 1550 -1850 in Mitcham.
- 500 - 600 in Colliers Wood and South Wimbledon.
- 500 - 600 in Wimbledon.
- 500 - 600 in Raynes Park.

5.16 Policy DM H2 of the SPP states that “residential development proposals will be considered
favourably where they contribute to meeting the needs of different households such as families
with children, single person households and older people by providing a mix of dwelling sizes,
taking account of the borough level indicative proportions concerning housing mix”. The
indicative proportions are set out in the table below:

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 Assessment

5.17 The application proposal will assist the Council in meeting its housing targets. The use of the site
will be optimised having regard to other policy considerations and its housing potential released.
This would be in accord with Policy 3.3 of the London Plan and with the adopted development
plan.

5.18 The proposed scheme provides for three detached family 3b6p houses.

5.19 The proposal would meet identified needs for family sized houses.

Internal space standards

5.20 The internal space standards for new residential units are set out in the Mayor’s 2016 Housing
SPG and the MALP 2016.

5.21 The latest standards are specified in the table below.

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 Assessment

5.22 The proposed house would have the following areas:

6b3p Bedroom Houses

3 x 145.9 m²

5.23 All the units within the development would therefore meet and exceed the minimum space
standards of the London Plan.

5.24 All the rooms would comply with the standards of the Mayor’s Housing SPG and all the units
would be double aspect.

Design

5.25 London Plan Policy 7.4 explains how developments should relate to the existing site context.
New buildings should respect the character and existing grain of the area. They should provide a
“human scale” and optimise the potential of the site whilst not causing unacceptable levels of
harm to the amenity of the surrounding area.

5.26 Policy CS 14 of the Core Strategy states:

All development needs to be designed in order to respect, reinforce and enhance the local
character of the area in which it is located and to contribute to Merton's sense of place and
identity. We will achieve this by:

a. Conserving and enhancing Merton's heritage assets and wider historic environment
particularly the valued centres, suburban neighbourhoods, industrial heritage and iconic
green spaces, through conservation areas, statutory and locally listed buildings, scheduled
ancient monuments, historic parks and gardens and archaeological sites and other non-
designated heritage assets;

b. Promoting high quality sustainable design that:

1. meets urban design and climate change objectives;

2. responds to the 'distinctive areas of the borough';
3. improves Merton's overall design standard;
4. responds to heritage assets and the wider historic environment to enhance local
character and distinctiveness;
5. retains and adapts existing buildings where appropriate to reduce CO2 emissions
and secure sustainable development;
6. provides functional spaces and buildings with adequate internal amenity;
7. enhances community safety.

c. Protecting the valued and distinctive suburban character of the borough by resisting the
development of tall buildings where they will have a detrimental impact on this character.
Tall buildings may therefore only be appropriate in the town centres of Colliers Wood,
Morden and Wimbledon, where consistent with the tall buildings guidance in the justification
supporting sub-area policies, where of exceptional design and architectural quality, where
they do not cause harm to the townscape an significance of heritage assets and the wider
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 historic environment, and where they will bring benefits towards regeneration and the public
realm. Even with the identified centres, some areas are sensitive to tall buildings.

d. Encouraging well designed housing in the borough:

a) by ensuring that all residential development complies with the most appropriate
minimum space standards;
b) by requiring existing single dwellings that are converted into two or more
smaller units of accommodation to:
i. incorporate the re-provision of at least one family sized unit where
resulting in the loss of an existing family sized unit;
ii. comply with the most appropriate minimum space standards;
iii. not result in an adverse impact on the suburban characteristics of the
streetscape.

e. Requiring the development and improvement of the public realm to be accessible, inclusive
and safe, simplified in design and unified by Merton’s green character to create an
environment of real quality.

f. Using objectives, proposals and policies within national, regional and local policy, including
local guidance or evidence such as design guides, character appraisals and management
plans to shape new built form and enhance the overall design quality of the borough.

5.27 Policy DM D2 of the SPP is titled “Design considerations in all developments”. Paragraph a) lists
the design criteria for the assessment of new developments. It states:

Proposals for all development will be expected to meet all the following criteria:

1. Relate positively and appropriately to the siting, rhythm, scale, density, proportions, height,
materials and massing of surrounding buildings and existing street patterns, historic context,
urban layout and landscape features of the surrounding area;
2. Use appropriate architectural forms, language, detailing and materials which complement
and enhance the character of the wider setting;
3. Provide layouts that are safe, secure and take account of crime prevention and are
developed in accordance with Secured by Design principles;
4. Ensure appropriate provision of outdoor amenity space, whether public, private or communal
which accords with appropriate minimum standards and is compatible with the character of
surrounding areas;
5. […];
6. […];
7. […];
8. Conserve and enhance the natural environment, particularly in relation to biodiversity and
wildlife habitats and gardens;
9. Ensure trees and other landscape features are protected;
10. Ensure that landscaping forms an integral part of any new development where appropriate;
11. Ensure the highest practical standards of access and inclusion and be accessible to people
with disabilities;
12. Ensure that construction waste is minimised and promote sustainable management of
construction waste on-site by managing each type of waste as high up the waste hierarchy
as practically possible;

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 13. Ensure that the traffic and construction activity do not adversely impact or cause
inconvenience in the day to day lives of those living and working nearby, and do not harm
road safety or significantly increase traffic congestion;
14. Ensure that sustainable design to make effective use of resources and materials, minimise
water use and CO2 emissions are achieved by expecting these to be incorporated in the
initial design stages.

Assessment

5.28 The design, massing and materials of the buildings have been carefully chosen to create an
appropriate response to the townscape and material pallet of the existing housing in Rookwood
Avenue.

5.29 The proposal would optimise the development potential of the site having regard to the need to
meet the open space and biodiversity aspects on the site and without impacting on the
appearance, character and setting of the streetscene or creating overbearing effects.

5.30 All dwellings will be designed to comply with the relevant standards in Part M of the Building
Regulations.

5.31 It is considered that the proposed scheme has been located and designed appropriately to its
context. Its density and scale are in keeping with that of the area and can comfortably be
supported by the existing transport network.

Private amenity space

5.32 The London Plan’s Housing SPG at Standard 24 states “A minimum of 5sqm of private outdoor
space should be provided for 1-2 person dwellings and an extra 1sqm should be provided for
each additional occupant”. Also that “Houses and ground floor flats should preferably have
private gardens”.

5.33 The Councils Sites and Policies Plan states “For all new houses, the council will seek a minimum
garden area of 50 sqm as a single usable regular shaped amenity space”.

Assessment

5.34 The development would also provide for individual gardens for each of the proposed houses.
These are at least 50m² in size, ranging from 60.4m² to 90m².

Residential amenity

5.35 Paragraphs (v) to (vii) of Policy DM D2 of the SPP relate to residential amenity. They state that
new developments will be expected to:

− Ensure provision of appropriate levels of sunlight and daylight, quality of living

conditions, amenity space and privacy, to both proposed and adjoining buildings and
gardens
− Protect new and existing development from visual intrusion, noise, vibrations or
pollution so that the living conditions of existing and future occupiers are not unduly
diminished;

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 − Ensure provision of appropriate energy efficient external lighting that provides safe and
secure environments while not causing light pollution that adversely affects
neighbouring occupiers or biodiversity.

5.36 Policy DM EP2 of the SPP relates to noise. It states:

Development which would have a significant effect on existing or future occupiers or the
local amenity due to noise or vibration will not be permitted unless the potential noise
problems can be overcome by suitable mitigation measures.
Development proposals will be expected to meet the following criteria:

i. Noise-generating developments should be appropriately located so as to minimise its

impacts on noise sensitive land uses; and
ii. Noise-sensitive developments should be located away from noise priority locations
and noise generating land uses; and
iii. Where relevant, the council will require the submission of a Noise Impact
Assessment; and
iv. That where applicable suitable mitigation measures will be sought by planning
obligation or condition.

5.37 The BRE Report ‘Site Layout Planning for Daylight and Sunlight: A Guide to Good Practice’ is the
established national guidance to prevent and/or minimise the impact of a new development on
the availability of daylight and sunlight for the existing occupiers of the surrounding properties
and the new occupiers of the development. It has been developed in conjunction with daylight
and sunlight recommendations in BS 8206: Part 2: ‘Lighting for Buildings - Code of Practice for
Daylighting’.

Assessment

5.38 The proposed houses are sited parallel with the existing housing on the east side of Rookwood
Avenue. Therefore they will not result in any overlooking of adjoining properties or gardens.
They are also located at some distance from the rear of the houses in Onslow Road so as not to
result in overlooking to the west.

5.39 They would not create any overbearing, overlooking or enclosing effect on the adjoining
occupiers nor would not have impacts on the availability of sunlight and daylight to existing
dwellings.

Land Contamination

5.40 Policy DM EP4 of the SPP states that to minimise pollutants developments “should be designed
to mitigate against its impact on air, land, noise, and water both during the construction process
and lifetime of the completed development” and “individually or cumulatively, should not result in
an adverse impact against human or natural environment”.

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 Assessment

5.41 The Phase 1 Environmental and Geotechnical Site Investigation Report submitted in support of
the application reaches the following conclusions:

− The outline CSM has identified a number of potential pollutant linkages that could be
active upon redevelopment of the site. However, given the historical and current on site
uses, the potential for these pollutant linkages to be active upon completion of the
redevelopment is considered to be low.

− It is recommended that limited environmental testing is carried out as part of the

geotechnical investigation to confirm the presence or otherwise of these potential
pollutant linkages.

Transport and Parking

5.42 Policy CS 20 of the Core Strategy relates to parking, servicing and delivery and states:

We will seek to implement effective traffic management by:

a. Working with Transport for London and other partners to progress a range of transport
improvements in key town centres, in particular, to enhance the environment and bring
about significant improvements for all road users;
b. Prioritising for people with restricted mobility and protecting vulnerable road users;
c. Supporting development that includes car club bays and electric vehicle charging points;
d. Requiring developers to demonstrate that their development will not adversely affect
pedestrian and cycle movements, safety, the convenience of local residents or the quality of
bus movement and/or facilities; on-street parking and traffic management;
e. Providing car parking in accordance with the council’s current parking standards;
f. Considering new or expanding existing Controlled Parking Zones (CPZ) where it is deemed
to reduce trip generation, promote road safety and protect existing residential amenity;
g. Supporting permit-free developments in areas within CPZ’s benefiting from good access to
public transport (PTAL 4 - 6), with good access to facilities and services and/or in a town
centre location. Permit free agreements may apply to proposals with or without off-street
parking;
h. Incorporating Merton’s road hierarchy and Merton’s Vehicle Crossover Information Pack
when locating and designing access arrangements to developments;
i. Requiring developers to incorporate adequate facilities for servicing to ensure loading and
unloading activities do not have an adverse impact on the public highway or create areas
which are unsafe at night or hours of low usage in accordance with standards set by the
Freight Transport Association;
j. Requiring developments to incorporate safe access to and from the public highway as well
as on-site parking and manoeuvring for emergency vehicles, refuse storage and collection,
and for service and delivery vehicles;
k. Implementing measures to discourage/reduce pavement parking in industrial areas of the
borough, particularly at Willow Lane, South Wimbledon/Morden Road and Weir Road /
Durnsford Road;
l. Including measures for visitor drop-off and pick-up areas, taxis, bus/coach parking, off street
parking, set-down and pick-up facilities and Community Transport (e.g. Dial-a-ride) in
development where appropriate;
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 m. Seeking planning obligations to mitigate the impact of development proposals and provide
improvements to the highway network/public realm;
n. Promoting measures to reduce the impact of goods vehicles on residential areas and town
centres.

5.43 Policy DM T1 of the SPP states that “development must provide cycle parking in accordance with
the standards set out in the London Plan”. The Mayor of London Housing SPG 2016 states that
all developments should provide dedicated storage space for cycles at the following level:

- 1 cycle parking space per studio and one bedroom dwellings;

- 2 cycle parking spaces for all other dwellings;
- 1 short stay cycle parking space should be provided per 40 residential units.

5.44 Policy DM T2 of the SPP relates to the transport impacts of developments. It states:

a. Planning permission will be granted for development proposals provided they do not
adversely impact on the road or public transport networks, safety or congestion particularly
on strategically important routes.
b. Development proposals will need to demonstrate their impact on the transport network
through the provision a Transport Assessment and associated Travel Plan in accordance
with Transport for London referral thresholds.
c. Smaller developments that fall below Transport for London referral thresholds, which may
impact on transport conditions, will be expected to demonstrate potential impacts through a
Transport Statement.

5.2 Policy DM T3 of the SPP relates to car parking and servicing standards. It states:

a. Development should only provide the level of car parking required to serve the site taking
into account its accessibility by public transport (PTAL) and local circumstances in
accordance with London Plan standards unless a clear need can be demonstrated.
b. Planning permission for residential permit free development will be approved where the
council is satisfied that this will not have an adverse effect on the level of on-street parking,
road safety or local amenity. Permit free development will be expected to:
1. Prohibit through legal agreement and Title Deeds occupants from obtaining a
parking permit.
2. Benefit from good access to public transport (generally PTAL 4 or above).
3. Be within an existing Controlled Parking Zone.
4. Ensure that the public transport infrastructure has enough capacity to serve
increased demand arising from the development.
c. That for mixed use development parking spaces should be allocated to each specific use.
d. Disabled and electric vehicle parking spaces should be provided in accordance with the
London Plan standards. Where appropriate, provision should also be made for Car Clubs,
Car Sharing schemes (including free floating style car sharing schemes where cars can be
picked up and left within specified zones), motorcycles, taxi and coach parking where
identified by a Transport Assessment or in support of a Travel Plan.
e. That car parking in retail and leisure development is allocated towards short stay parking,
takes into account local charging structures, achieves a nationally recognised safety mark
standard and is not reserved for any development.

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 f. Planning permission for the conversion of existing parking places for other uses will be
supported where it is demonstrated to be surplus to requirement, the site is well served by
public transport and supported by a range of alternative travel choices and will not adversely
impact on road safety, on-street parking and local amenity.
g. New development or modification to existing development should make proper provision for
loading and servicing in accordance with Freight Transport Association (FTA) guidance,
except when a development would impact on a listed building or designated conservation
area then facilities will be considered on a case by case basis.
h. That car parking at ambulance, fire and policing facilities will be assessed on individual
merits.

Assessment

5.45 The application is supported by a Transport Statement that analyses the stress levels of the local
transport network and assess the potential impacts of the proposal on mobility.

5.46 The Statement demonstrates that the development would not have a severe impact on the local
highway network, including on-street parking. The report concludes that “Overall, the proposed
development will generate around 32 person movements including 17 vehicle movements
between 0700 and 1900. It is considered that the proposals will not produce a material impact on
the surrounding highway and public transport network and the development cannot therefore be
considered as severe in the context of NPPF paragraph 32 and the proposals should not be
refused on transport grounds.

Flooding and drainage

5.47 Paragraph B of the London Plan Policy 5.12 states that “development proposals must comply
with the flood risk assessment and management requirements set out in the NPPF and the
associated technical Guidance on flood risk1 over the lifetime of the development and have
regard to measures proposed in Thames Estuary 2100 (TE2100 – see paragraph 5.55) and
Catchment Flood Management Plans”.

5.48 Policy CS 16 of the Core Strategy relates to flood risk management. It states:

We will:

a. Work with the Environment Agency, landowners and developers, based on the findings of
the most recent Strategic Flood Risk Assessment and other plans, to manage and reduce
flood risk from all sources of flooding;
b. Apply the sequential and exception tests to avoid inappropriate development in relation to
flood risk;
c. Implement sustainable drainage systems (SUDs) across the borough and work towards
effective management of surface water flooding;
d. Fully engage in flood risk emergency planning including the pre, during and post phases of
flooding event;
e. Propose ensure the implementation of measures to mitigate flood risk across the borough
that are effective, viable, attractive and enhance the public realm and ensure that any
residual risk can be safely managed.

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5.49 Policy DM F1 of the SPP relates to flood risk management. It states:

a. To minimise the impact of flooding in the borough the council will:

1. Encourage development to locate in areas of lower risk by applying the
Sequential Test; any unacceptable development and land uses will not be
permitted.
2. Ensure that flood resilient and resistant measures are incorporated into design of
development proposals in any area susceptible to flooding to minimise and
manage the risk of flooding.
3. Ensure that developments consider all sources of flooding from fluvial,
groundwater, surface water run-off, ordinary watercourse, and sewer; and
including the risks of flooding arising from and to the development.
4. All development proposals must have regard to the Strategic Flood Risk
Assessment (SFRA) and the Local Flood Risk Management Strategy.
5. Permit appropriate development in Flood Zones 1, 2, 3a and 3b subject to
meeting the criteria in the following table:

5.50 Policy DM F2 of the SPP relates to Sustainable Urban Drainage Systems (SUDS). The relevant
paragraphs state:

The council will require all developments to reduce water consumption, the pressures on the
sewer network and the risk of flooding by:
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 1. Ensuring all new developments have to consider SUDS and demonstrate sustainable
approaches to the management of surface water in line with the emerging National SUDS
standards.
2. Seeking mitigating measures against the impact of flooding from all sources; and surface
water run-off through the inclusion of SUDS including green roofs rainwater harvesting and
other innovative technologies where appropriate.
3. Ensuring developers demonstrate the maintenance and long-term management of SUDS
through a SUDS Management Plan.
4. Requiring developers, where feasible, to incorporate soft landscaping, appropriate planting
(including trees) and permeable surfaces into all new developments including non-
residential developments. For development proposals associated with existing homes, the
council requires:
o The retention of soft landscaping and permeable surfaces in gardens and the
reduction, or at least not the increase in, the amount of impermeable surface
associated with existing homes
o new driveways or parking areas associated with non-residential developments
and those located in gardens to be made of permeable material in line with
permitted development rights
5. [...]
6. Requiring developers, when discharging water including wastewater into the public sewer,
development proposals are required to demonstrate that the local public sewerage
network has adequate capacity to serve the development and existing developments. If
the public sewer does not have adequate capacity, the developer should demonstrate
alternative sustainable approaches to the management of water.
7. Requiring any development proposals with adverse impact including potential water
pollution will be refused by the council.
8. […]
9.
10.
11. […]

Assessment

5.51 The Flood Risk Assessment submitted in support of the application demonstrates that:

 The site is located primarily in Flood Zone 1 and partially in Flood Zone 2 which corresponds
with an annual risk of flooding between 1 in 100 and 1 in 1000. Detailed hydraulic modelling
has shown that the majority of the site is located outside the 1 in 100 year plus 35% climate
change event apart from a limited area of the north of the site that would experience depths
of flooding less than 0.2m. This area is proposed as soft landscaping only; and

 Overall, it has been demonstrated that the development would be safe, without increasing
flood risk elsewhere, and that a positive reduction in flood risk would be achieved through
the use of an attenuation pond and permeable paving.

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 Landscaping/Trees

5.52 Adopted Policy DM O2 deals with ‘Nature conservation, trees, hedges and landscape features’.
In respect of trees it states:

b) A development proposal will be expected to retain, and where possible enhance, hedges,
trees and other landscape features of amenity value.

c) Development will only be permitted if it will not damage or destroy any tree which:

i. is protected by a tree preservation order;

ii. is within a conservation area; or,
iii. has significant amenity value.

d) However, development may be permitted when:

i. the removal of the tree is necessary in the interest of good arboricultural practice; or,
ii. the benefits of the development outweighs the tree’s amenity value.

e) In granting permission for a proposal that leads to the loss of a tree, hedge or landscape
feature of amenity value, replacement planting or landscape enhancement of a similar or
greater value to that which has been lost, will be secured through the use of conditions or
planning obligations.

f) Proposals for new and replacement trees, hedges and landscape features should consist
of appropriate native species to the UK.

5.53 The supporting text to the policy in respect of trees states:

Trees make an important contribution to the borough’s townscape and the quality of life for
residents. The council will use the existing planning mechanisms i.e. Tree Preservation
Orders and Conservation Area designations to protect existing trees on private land.

5.54 The text further advises that the “Council may require semi-mature replacement trees when, for
example, the original trees had an important landscape or screening function”.

Assessment

5.55 The Site is the subject of a TPO on the perimeter trees. None of these trees will be adversely
affected by the proposals. The Tree Survey demonstrates that the trees on the site are in the
majority of poor quality. All of the trees are categorised as C or U grade. Notwithstanding that no
trees are proposed for removal.

5.56 Landscape Strategy that accompanies the application summarises the benefits of the proposal as
follows:

 Enhancement and extension of the existing characteristics of the site to create an

ecologically rich, biodiverse landscape;

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  Respecting the existing public footpath running through the site and incorporating the
informal path running between Rookwood Avenue and Blagdon Road;

 Creation of an attractive setting for the new homes.

Energy and sustainability

5.57 Policy 5.2 of the London Plan requires each major development proposal to submit a detailed
energy assessment. Further, as outline in the Housing SPG from 1 October 2016 the Mayor will
apply a zero carbon standard to new residential development. The Housing SPG defines ‘Zero
carbon’ homes as homes forming part of major development applications where the residential
element of the application achieves at least a 35% reduction in regulated carbon dioxide
emissions (beyond Part L 2013) on-site. The remaining regulated carbon dioxide emissions, to
100 per cent, are to be off-set through a cash in lieu contribution to the relevant borough to be
ring fenced to secure delivery of carbon dioxide savings elsewhere (in line with policy 5.2E).

5.58 Policy CS 15 of the Core Strategy relates to climate change. It states:

All minor and major development, including major refurbishment, will be required to
demonstrate the following unless developers can robustly justify why full compliance with the
policy requirements is not viable:

a. How it makes effective use of resources and materials, minimises water use and CO2
emissions;
b. How development proposals are making the fullest contribution to minimising carbon
dioxide emissions in accordance with the following energy hierarchy:
- Be lean: use less energy
- Be clean: supply energy efficiently
- Be green: use renewable energy
c. How it is sited and designed to withstand the long term impacts of climate change,
particularly the effect of rising temperatures on mechanical cooling requirements;
d. Regeneration plan in town centre are an excellent opportunity to implement District Heat
and Power networks, and all major development would be strongly encourage to be
'Multi Utility Services Company (MUSCo) ready where viable and actively contribute to
the networks where possible;
e. We will require all new development comprising the creation of new dwellings to achieve
Code for Sustainable Homes Level 4;
2
f. All non-domestic development over 500m which does not qualify for assessment under
Code for Sustainable Homes will be expected to be built to a minimum of BREEAM
(Building Research Establishment Assessment Method) Very Good standard, and meet
CO2 reduction targets in line with the requirements of the London Plan or national policy,
whichever is the greater.

Assessment

5.59 The application will be an energy efficient and sustainable scheme. The proposal will meet the
current Building Regulations in this respect. It is also proposes to develop the site using modern
methods of construction and using CLT that reduces deliveries and allows for faster construction
as well as the environmental benefits as set out in the DAS.

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 Planning obligations

5.60 We will have regard to Planning Obligations SPD in the discussion with the Council on S106
matters and this matter will be discussed further post-submission.

5.61 We are happy to cover the Council’s reasonable costs in preparing any legal agreement.

5.62 The applicant has also agreed to either gift the remaining amenity land to the Council to protect
against future development with a £25,000 contribution towards its maintenance or set up a
suitable management company to safeguard and maintain the land with the local residents and
Council.

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6 CONCLUSION

6.1 The application proposal is to develop only around a third of this triangular shaped site by the
erection of three new contemporary houses. These would be accessed from the northern end of
Rookwood Avenue. In addition the existing informal pedestrian route from Rookwood Avenue
will be formalised and connected to the existing footpath that runs parallel to Beverley Brook.
The majority of the site will be retained as undeveloped land and its biodiversity and ecological
value enhanced.

6.2 As part of the proposals it is proposed to regularise the southern boundary of the site with 36
Rookwood Avenue, something that has been agreed with the occupiers. This will result in a slight
enlargement of their garden.

6.3 The proposals have been the subject of engagement with local residents through two
consultation events and also twice with Council officers. The loss of a small part of the site for
the development of the three family houses has been assessed in the separate report on Open
Space.

6.4 Extensive surveys of the site have been undertaken looking at bats, reptiles and water voles in
order to inform the enhancement and future management of the site to achieve a varied
environment for the future. Residents will be encouraged to join a Trust to secure the appropriate
future management of the site.

6.5 The proposed houses will be suitable for families with gardens and provision for two car spaces
and cycle storage. Future proofing will be incorporated in the parking with electric charging
points.

6.6 We therefore consider that subject to conditions and appropriate S106 clauses, the proposal can
be supported and planning permission granted.

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