Development Control CommitteeDate of Meeting: 17:02:2016

A Register No: 15/10074/FUL

Address: FORMER GOVERNMENT OFFICES (KING GEORGE'S GATE), HOOK RISE SOUTH, SURBITON

(c) Crown Copyright. All right reserved. Royal Borough of Kingston 2007. Licence number 100019285.

Recommendation: It is recommended that the Committee considers the application, seeks clarification where it is required and considers the issues raised by objectors prior to the formal determination of this application at a future meeting of the Committee.

Ward: Tolworth and Hook RiseDescription of Proposal: Outline application (means of access only)

for 705 residential dwellings (Use Class C3) with associated other ground floor uses including class A1 (Convenience Retail Store)/ A3 (Cafe)/ D1 (Doctors Surgery)/ D2 (Day Nursery/ B1 (Office) floorspace with associated car parking and a bus interchange.

Plan Type: Full ApplicationExpiry Date: 29/06/2015

Summary of Application

The application site is located to the south-west of the Tolworth roundabout adjoining the A3 trunk road and Kingston Road (A240).The site is known as the Former Government Offices site and is currently vacant. The application seeks outline approval with all matters reserved apart from means of access and consists of the following elements: 705 homes Doctors Surgery (Use Class D1) Children’s Day Nursery (Use Class D1) 262sqm Convenience Store (Use Class A1) Retail unit for either a shop of a café (Use Class A1/A3) Bus interchange adjacent to Tolworth Railway Station 356 car parking spaces

The key issues in the case are

The impact on the character and appearance of the area The provision of affordable housing The effect on the highway network The amount of car parking The cumulative impact of the development on the Tolworth area

Applicant's Plan Nos:

00-001 P3 Proposed Site Plan Received 08/06/2015

00-100 Red line boundary Received 30/03/2015

10-001 Existing topographical survey Received 30/03/2015

60-101 Outline - building envelopes P6 Received 23/12/2015

60-103 Outline Maximum Building Heights P6

Received 23/12/2015

60-107 Outline - Vehicular Access P6 Received 23/12/2015

60-110 Outline Building Heights Sections SH1P5

Received 23/12/2015

60-112 Building heights Sections SH3 P5

Received 23/12/2015

Affordable Housing Statement Received 16/03/2015

Air Quality Assessment Received 16/03/2015

Arboriculture Assessment Received 16/03/2015

Archaeology Assessment Received 16/03/2015

BREEAM and Code for Sustainable Home Pre-assessment report

Received 16/03/2015

Consultation Statement Received 16/03/2015

Design & Access Statement Received 16/03/2015

Design Statement Received 12/06/2015

Ecology Assessment Received 16/03/2015

Energy Statement Received 16/03/2015

External Lighting Assessment Received 16/03/2015

Flood Risk Assessment Received 16/03/2015

Health Impact Assessment Received 23/03/2015

Landscaping Report Received 16/03/2015

MEP Services Report Received 16/03/2015

Noise Survey Received 16/03/2015

Planning Statement Received 16/03/2015

Revised Townscape & Visual Impact Assessment part 1

Received 08/06/2015

Revised Townscape & Visual Impact Assessment part 2

Received 08/06/2015

Transport Assessment (inc Travel Plans)

Received 16/03/2015

Utility Services Report Received 16/03/2015

BASIC INFORMATION

National Planning Policy Framework (NPPF) 2012

Development Plan: London Plan March 2015LDF Core Strategy Adopted April 2012

Policies

Regional

The London Plan 2015Policy 2.6 Outer London: Vision and StrategyPolicy 2.7 Outer London: EconomyPolicy 2.8 Outer London: TransportPolicy 3.3 Increasing housing supplyPolicy 3.4 Optimising housing supplyPolicy 3.5 Quality and design of housing developmentsPolicy 3.8 Housing ChoicePolicy 3.9 Mixed and balanced CommunitiesPolicy 3.10 Definition of Affordable HousingPolicy 3.11 Affordable Housing TargetsPolicy 3.12 Negotiation affordable housing on individual private residential and mixed use schemesPolicy 3.13 Affordable housing thresholdsPolicy 4.3 Mixed Use Developments and OfficesPolicy 5.1 Climate ChangePolicy 5.2 Minimising carbon dioxide emissionsPolicy 5.3 Sustainable design and constructionPolicy 5.6 Decentralised energy in development proposalsPolicy 5.7 Renewable EnergyPolicy 5.11 Green roofs and development site environmentPolicy 5.12 Flood Risk ManagementPolicy 5.13 Sustainable DrainagePolicy 5.17 Waste CapacityPolicy 5.18 Construction, excavation and demolitionPolicy 6.2 Providing public transport capacityPolicy 6.3 Assessing effects on development on transportPolicy 6.4 Enhancing London’s transport capacity

Policy 6.7 Better streets and surface transportPolicy 6.9 CyclingPolicy 6.10 WalkingPolicy 6.11 Smoothing traffic flow and tackling congestionPolicy 6.12 Road Network CapacityPolicy 6.13 ParkingPolicy 7.2 An inclusive environmentPolicy 7.4 Local CharacterPolicy 7.6 ArchitecturePo9licy 7.7 Location and Design of Tall and Large BuildingsPolicy 8.2 Planning ObligationsPolicy 8.3 Community Infrastructure Levy

Supplementary Planning GuidanceHousingProviding for Children and Young People’s Play and Informal Recreation

Local

Local Development Framework – Core Strategy (Adopted April 2012)Policy CS01 Climate Change MitigationPolicy CS02 Climate Change AdaptationPolicy CS03 The Natural and Green EnvironmentPolicy CS05 Reducing the Need to TravelPolicy CS06 Sustainable TravelPolicy CS07 Managing Vehicle UsePolicy CS08 Character, Heritage and DesignPolicy CS9 Waste Reduction and ManagementPolicy CS10 Housing DeliveryPolicy CS11 Economy and EmploymentPolicy CS16 Community FacilitiesPolicy T1 Tolworth Key Area of ChangePolicy DM01 Sustainable Design and Construction StandardsPolicy DM02 Low Carbon DevelopmentPolicy DM03 Designing for Climate Change

Policy DM04 Water Management and Flood RiskPolicy DM08 Sustainable Transport for New DevelopmentPolicy DM09 Managing Vehicle Use for New DevelopmentPolicy DM10 Design Requirement for New Developments (including House Extensions)Policy DM11 Design ApproachPolicy DM12 Development in Conservation Areas of Affecting Heritage Assets Policy DM13 Housing Quality and MixPolicy DM15 Affordable HousingPolicy DM17 Protecting Existing Employment Land and PremisesPolicy DM19 Protecting Existing Retail UsesPolicy DM20 New Retail DevelopmentPolicy DM24 Protection and Provision of Community FacilitiesPolicy IMP3 Securing Infrastructure

Supplementary Planning DocumentsPlanning Obligations Strategy September 2011Residential Design SPD July 2013Affordable Housing SPD May 2013Sustainable Transport SPD May 2013

Other DocumentsTolworth Regeneration Strategy March 2010

Previous Relevant History

98/2039/OUT Demolition of Toby Jug PH and Govt Offices,erection of bldg for Class D2 Leisure+A3 food+drink.Uses multi-plex cinema,FEC; restaurants,refurb of ext of Bowl,new access,three storey car park-600 spaces,231 surface spaces and landscaping

Application Withdrawn 02/03/2000

06/10260/OUT Redevelopment to provide foodstore (8265sq m), A1/A2/A3/A4/D1Community units (2105sq m) and 662 residential flats.

Withdrawn 19/02/2007

08/10206/EIA Request for EIA Screening and REQUIRED 17/10/2008

Scoping Opinion for an outline application -comprehensive mixed use redevelopment for residential, retail and community uses

09/10030/OUT Mixed use development comprising 562 dwellings & retail store (13,662 sq m) with 889 basement parking spaces, D1/D2/A3 Community/Leisure/Restaurant Use (2,581 sq m); remodelling of Tolworth roundabout with vehicular turning lanes, signals & associated highway works including new pedestrian/cycle routes and parking; sustainable energy systems and landscaping (hybrid app)

Withdrawn 22/04/2009

11/10241/EIA Request for EIA Screening Opinion for an application for redevelopment

NOT REQUIRED 04/11/2011

12/10141/FUL Hybrid application for a mixed use development including (Class C1) Hotel; (Class A1) Retail Store; (Class A3) Restaurant & Cafe; 231 parking spaces, bus layover & driver facilities; A3 pedestrian link; landscaping, ancillary works; 199 sqm (Class D1); Change of Use of ground floor units to Class A1/A3/D1; 269 Residential Units (Class C3); 199sqm D1 Floorspace.

Application Withdrawn 04/02/2014

14/10350/EIA1 Request for EIA Screening Opinion for an application for redevelopment

Not Required 15/01/2015

15/10078/FUL Continued use for the on-site storage of skips, storage units, machinery, plant and equipment.

Approved 11/11/15

CONSULTATION .

Neighbour NotificationA total of 2040 residents were consulted on the proposal along with 4 site notices being placed around the site and a notice also being placed in the press. 46 letters of objection have been received raising the following concerns.

The junction with Toby Way and Kingston Road will be problematic as will the area around Charrington Bowl. The exit road should be moved to Lansdowne Close.

Insufficient car parking.

Cumulative impact of other developments around Tolworth including Tolworth Tower and Tolworth Girls School on traffic and infrastructure.

Not in keeping with the surrounding housing.

Design looks like a University Campus or an office / industrial estate.

Too many units.

No school is provided.

18 storeys is too high.

The Council should compulsory purchase the site and give it back to the people.

Development will increase in traffic on already congested roads and roundabout.

Pressure on schools and hospital beds because of increase in population.

Tolworth Tower is a blight on the landscape you should not be approving another tower.

Site should be developed for low rise housing.

Interchange at the Ace of Spades should be altered to allow people to access the A3 out of London which would reduce traffic at the Tolworth roundabout.

Tolworth does not need another convenience supermarket.

The Ecological Assessment is inaccurate and does not recognise Tolworth Court Farm as a statutory designated site and Local Nature Reserve.

History of flooded road and backed up drains in Hook Rise South.

No guarantees that housing would be truly affordable to nurses and teachers.

No provision for deliveries from internet shopping.

No plans to improve air quality.

Putting the 281 bus into a housing estate is stupidity because of the invisible Nitrous Oxide gases they emit.

Application should not be in outline.

A formal plan should be presented regarding construction management.

Too dense and over dominated by flats.

RBK needs more family homes rather than overpriced boxes.

The affordable housing percentage appears well below par.

Outlook of Hook Rise South properties is already affected by the railway embankment this development will make the outlook even worse.

Buildings should be limited to 4 or 5 storeys.

Overshadowing of properties in Hook Rise North.

Wind tunnelling affects of the tall buildings on Hook Rise North.

Tescos are still getting a food store by the back door.

The flat roofed houses proposed are totally out of keeping with the character of the surrounding properties which all have pitched roofs.

Concerned about the wheelchair accessible flats that are above ground floor level and how residents would evacuate in times of fire.

Only 20% of the units are 3 bedrooms are more which is contrary to Policy DM13.

Lack of amenity space.

Colour of brickwork is too grey it needs to be brighter.

The proposed residential development will introduce a noise sensitive use alongside the boundary with the existing aggregates facility, batching plant and bus depot. The noise assessment submitted is limited in its assessment and lacks detail.

2 letters of Support have been received raising the following points

Application is long overdue the site has been vacant for over 21 years

There is a need to build large numbers of homes to help solve the housing crisis and this scheme would regenerate a run down part of the Borough

The higher concentration of people will make better public transport viable.

Following reconsultation on the receipt of amended plans a further 46 letters of objection have been received raising the following additional issues:

10 storeys would have been preferable

Difficulty in maintaining tall buildings creates a high risk that in the medium and long term the buildings will fall into disrepair

Hook Rise Residents Association

The application represents complete overdevelopment of the site as the surrounding area is primarily suburban and 2 storey

Blocks along the A3 frontage are 6 to 9 storeys and will have a significant impact on the visual amenity of Hook Rise North residents

Appearance and design is completely contrary to the local environment especially the houses which have flat roofs

All the examples of design precedent are inner London sites whilst the Core Strategy has a vision to continue to recognise the outer suburban value and lower density built form of South of the Borough. The application is therefore contrary to Polices SB1 (f), DM10, CS8 and CS10.

The application proposes 705 units with only 356 parking spaces which will have a significant impact on parking within local residents which are already heavily used for on street car parking

No explanation of whether the existing on street car parking spaces on Landsdowne Close and Toby Way will be replaced or included within the CPZ.

Tolworth Roundabout is already at 98% capacity and it is considered that the lack of parking will cause road safety problems and lead to gridlock on the roundabout. The proposal is therefore considered contrary to CS7 (d), DM9 and DM10 (I)

Additional residential vehicles will add to the existing poor air quality

Why are the wheelchair accessible flats not at ground level

Policy DM13 requires 30% of housing to be 3 bedroom or more however in this development on 20% is provided.

As part of the application is in outline they could resubmit with higher towers in the future.

A petition has been received from the Hook Rise Residents Association containing 125 signatures and raising the following issues

The application represents a complete overdevelopment of the site and 18 storeys is totally out of keeping with the area contrary to Policies SB1(f), DM10 and CS10.

The limited parking facilities will have a significant effect on the surrounding roads both from new residents but also from the removal of existing on street spaces contrary to Policies CS7(d), DM9 and DM10.

The new development will add to the already highly polluted area.

Sunray and Egmont Residents Association

Cumulative impact of schemes in Tolworth including Sundial Court, Jupiter Court, Tolworth Tower and Premier Inn Hotel.

160 units per hectare appears grossly excessive and results in blocks that are too high and out of place in the Tolworth Area.

Architecture is brutal

Affordable Housing provision of 13.2% is too low

Effect on air quality

Capacity of Tolworth Station during commuter times

Congestion at the Towlorth roundabout

Parking level is inadequate and concern that future residents will us the roads within the Sunray Estate to park

Kingston Upon Thames Society

The Society is pleased to see a housing led scheme.

We believe that the developers have taken great efforts to understand the unique and difficult nature of the site to come up with proposals that address the noise issues from the A3 and visual impact on neighbouring properties.

We like the layout of the site that provides open spaces and discourages through traffic.

We welcome the proposals to improve public transport by extending bus routes and to provide basic services such as a surgery and convenience store.

Whilst recognising that the proposed buildings are of a different character to other houses we think that the scheme is coherent and appropriate to the area.

We are concerned with the low level of parking provision which could lead to overspill parking in neighbouring roads.

The Council should pay close attention to approved brickwork detail.

We are disappointed with the low level of affordable housing.

In line with the Localism Act 2011 the applicant also carried out their own consultation prior to the submission of the application. A Statement of Community Involvement has also been submitted as part of the application.

Neighbourhood Traffic Engineer: Object to the proposal due to insufficient car parking, location of bus interchange and location of offsite visitor car parkingClimate Change and Sustainability: No objection subject to conditionsTrees and Landscape: No objection subject to conditionsEnvironmental Health: No objections subject to conditions on acoustic insulation of dwellings, acoustic insulation, trading hours of the A3/A4 uses, restrictions on servicing, plant noise, vibration control from fixed plant, hours of construction, pilling, odour control, land remediation.

Housing: The affordable housing mix on the site is acceptable clarification is sought on affordability levels.Waste and Recycling: Comments awaitedLead Local Flood Authority: No objections subject to conditionsDesigning Out Crime: No objectionsEpsom and Ewell: No comments to make.Greater London Authority (GLA): Stage 1 response – Raise concerns with regard to the significance of this site in relation to strategic future infrastructure. Raise concerns relating to urban design and the implications of establishing a district heat network.Supplementary Response following further information – No objection subject to the requirement to secure design codes, inclusive design principles and energy strategy through condition.Transport for London (TfL): No objection subject to securing contributions towards the extension of the 281 bus and roundabout monitoring.Historic England Archaeology: No objection subject to a written scheme of investigation being submitted prior to development commencing on site.Sport England: Object as a non- Statutory Consultee on the lack of sports provision on site and the lack of contributions towards sports provision in accordance with Sport England’s Sport Facilities Calculator.Natural England: No objection The proposal is unlikely to have an effect on any statutorily protected sites or landscapes.Environment Agency: No objection subject to conditions regarding surface water mitigation measures and their maintenance.London Fire: No comments receivedUK Power Networks: No comments receivedTransco: No comments receivedThames Water: No objections subject to conditions for both surface and waste water that requires a drainage strategy to be undertaken prior to the commencement of development on site. A condition is also required in regard to impact piling.Network Rail: No objections

Site and Surroundings

1 The proposal site is located to the south-west of the Tolworth roundabout adjoining the A3 trunk road and Kingston Road (A240). The overall application site extends to 4.1 ha.

2 The proposal site was previously occupied by a series of uniform two storey, largely temporary, buildings which ran perpendicular to the A3. The proposal site once included a public house (now demolished) adjacent to the Charrington Bowl and Marshall House office building (now demolished) adjacent to Tolworth railway station. The Charrington Bowl, a 1960s built bowling alley remains operational but outside the application site boundary. The proposal

site is now unoccupied and has been vacant for over a decade.

3 The areas to the west of the site are characterised by 1940s / 1950s residential development. Tolworth railway station is located on the south eastern tip of the site. Pedestrian access linking the site to the district centre and surrounding residential areas is via a network of subways and footbridge over the A3.

4 Tolworth District Centre lies immediately north of Tolworth roundabout, clearly landmarked by Tolworth Tower. The district centre comprises a mix of retail and service uses.

5 The retail hierarchy within the Borough is dominated by Kingston Town Centre. Tolworth Broadway was previously disconnected from the railway station and leisure facilities, as well as a large part of the local population. However, recently the Tolworth ‘Greenway’ has opened allowing pedestrian access between the north and south of Tolworth Roundabout.

6 The application site falls within the Tolworth Key Area of Change and a Housing Opportunity Area.

Proposal

7 The planning application proposes a residential led regeneration of the vacant brownfield site. The proposal responds to opportunities which the site offers in terms of its location adjacent to Tolworth Broadway railway station while attempting to mitigate against the noise and pollution of the A3.

8 The application consists of the following elements:

705 homes Doctors Surgery (Use Class D1) Children’s Day Nursery (Use Class D1) 262sqm Convenience Store (Use Class A1) Retail unit for either a shop of a café (Use Class A1/A3) A site management office (Use Class B1) Bus interchange adjacent to Tolworth Railway Station Energy Centre to including a combined cooling and power

system Communal amenity and play space 356 car parking spaces Enhanced pedestrian and cycle routes along Hook Rise South

and through the application site.

9 The application was originally a ‘hybrid’ application concerning two distinct elements. The first element concerns a full application, where all matters are to be considered, and second element of the application under consideration was an outline application with only

prescribed matters for consideration at this stage.

10 The Application originally proposed that the detailed element would contain Blocks A, B, C ,R ,U and V totaling 231 dwellings. The outline element therefore included E, F, G, H, I. J, K, L, M, N, P, Q, S, T.

11 The application was then amended following lengthy consultation and discussions with the Council, the Greater London Authority (GLA) and Transport for London (TfL) to ensure that the development of the site does not prejudice possible long term infrastructure proposals. It was therefore agreed that the whole application should be in outline with all matters reserved apart from means of access. This allows certainty for the developer but ensures that the Local Planning Authority still has control over the detail of how the site will be developed which will be informed by the revised Tolworth Regeneration Strategy which is currently being reviewed.

12 Access to the site will be via Hook Rise South/ Toby Way with a second access further down Hook Rise South towards the existing residential properties. Landsdowne Close from the new access road to the existing Drayton Court Car Park and link with Kingston Road will become an eastbound bus only route where the bus interchange with Tolworth Station is to be provided.

Assessment

13 The main considerations material to the determination of this application are:

Principle of Proposed Development Impact on Character of Area Impact on Neighbour’s Residential Amenity Highways and Parking Trees Legal Agreements Sustainability Other Material Considerations

Background

14 The site is identified as a ‘Key Area of Change’, specifically for housing, public realm and transport improvements. The site is also identified as a ‘Housing Opportunity Area’, a ‘Development Area’ and a ‘Gateway’ Any development on this site will need to be assessed against Policy T1 of the Core Strategy and whether it is delivering the type of development and infrastructure improvements required.

15 The vision for the area specifically related to the site is.

a. Tolworth will be a vibrant and attractive centre as the role of the District Centre is strengthened and more competitive with a diversified retail offer

b. The redeveloped government offices will have De-centralised Energy Networks significantly reducing carbon emissions. Drainage improvements and SUDs will reduce the risk of surface water flooding.

c. Tolworth will be a more attractive place to live, work and visit with high quality new development and a high quality public realm

d. Tolworth Station will have been improved and the 281 bus service will have been extended to serve the Station and area south of the A3.

e. There will be significant new housing development on the government offices, Toby Jug and Marshall House site…………….. to provide a range of new homes including.... flats and affordable housing.

16 In addition to the above Policy T1 also requires development to;

provide convenient secure cycle parking for short and long stay use at Tolworth Station

reinforce the character and identity of Tolworth to enhance its attraction as a place to live, work and enjoy through public realm improvements and promoting and managing development opportunities within the on the government offices, Toby Jug and Marshall House site.

work with developers and landowners to provide a range of new homes, in particular on the government offices, Toby Jug and Marshall House site to include family housing with gardens outside the district centre and higher density flats with amenity space within the District Centre.

Work with local health providers to expand and improve GP provision which is at capacity and in need to upgrading through the provision of a new facility (for relocating practices) e.g on the Toby Jug/ government offices site.

Investigate opportunities to provide additional meeting spaces/space for classes, youth facilities, indoor leisure and recreation facilities through providing new facilities on development sites e.g. former government offices.

17 The Tolworth Regeneration Strategy also specifically identifies the site or significant development opportunities. In addition to those items already mentioned above, the site should be designed

to have a residential led approach a mix of house type and tenures including family sized homes with

gardens to have a layout and design to address the issues of noise and air

quality resulting from the A3 and A240 to ensure flats have dual aspects

to a high quality with attractive frontages and a distinctive development on the Toby Jug site

to provide high specification fully services workspaces to ensure nil detriment on the highway network with a vehicle access into the site from Hook Rise South and/ or

Kingston Road with egress via Kingston Road with convenient accessible and inclusive pedestrian and cycle links

within the site and to the surrounding area with public and private amenity space and play space with parking levels kept to a minimum and with an on site car club with low energy low carbon buildings with feasibility of providing de-centralised energy network with the provision of space for or a financial contribution towards

the extension of the 281 bus.

18 Although the application site is located within the Tolworth Key Area of Change it is within the South of the Borough Neighbourhood and therefore Policy SB1 also applies.

19 Policy SB1 (South of the Borough Neighbourhood) states that the Council will:

a) Promote and enhance sustainable transport options by:i. seeking to address the poor levels of public transport provision in

South of the Borough by working with partners to provide new or extended local bus services working with TfL to manage congestion whilst improving road safety and crossing opportunities on the A3 and A243.

ii. improving the local network of pedestrian and cycle routes.

b) Work to protect and enhance the following positive character, design and heritage featuresi. Views across open land into and out of the Green Beltii. Large areas of established, high quality outer suburban character

c) Maintain and enhance housing options in the Neighbourhood byi. Working with developers to provide a range of new homes,

including affordable housing, on Brownfield sites in and around the Tolworth District Centre including on the former Government Offices, Toby Jug and Marshall House site.

Principle of Proposed Development

Land Use20 The proposal seeks to redevelop a vacant brownfield site for a

residential led development with complementary retail and community facilities. The sites location adjacent to Tolworth Railway Station and adjacent to Tolworth District Centre is a sustainable

location for development and accords with the National Planning Policy Framework (NPPF) to secure economic development and housing delivery wherever possible.

Principle of Residential Development and Housing Land Supply

21 The London Plan March 2015 requires the delivery of 6,434 dwellings within the plan period 2015-2025 and a rate of 643 dwellings per year which is almost double the previous rate of 375 dwellings per year.

22 Core Strategy Policy CS10 (Housing Delivery) states that the Council will take full advantage of opportunities to deliver new housing and, in particular maximise the delivery of affordable housing. New housing should be delivered in the most sustainable locations, and with the associated infrastructure necessary to support it. Tolworth is one of the preferred locations for new housing, as are areas with the greatest Public Transport Accessibility Level (PTAL) and areas in need of improvement or renewal - both of which are relevant to Tolworth. The Policy also states that the Council will seek to ensure that a broad mix of accommodation options are available to residents and that a range of local housing needs are met.

23 Policy T1 (Tolworth Key Area of Change) identifies this site as a ‘Housing Opportunity Area’. The site is therefore specifically identified as a site that is expected to contribute significantly to the delivery of housing across the Borough in accordance with London Plan targets. The provision of residential development on the site is therefore supported by the Council’s Development Plan.

24 The most recent five year housing supply was published in the 2014 Annual Monitoring Report (AMR) - It demonstrates that housing capacity is 37% above the five year housing supply requirement. However, the Borough’s increased annual housing target of 643 units per annum set in the Further Alterations to the London Plan (adopted March 2015) could reduce this capacity due to increased need to deliver more housing. The Borough’s annual housing target could increase further still, depending on whether the SHMA that is currently being prepared identifies a greater need for housing than that set out in the London Plan.

25 The 2013 London-wide SHLAA identified the site as having capacity for 300 dwellings. However, the 2014 AMR identified the capacity of the site as being 400 dwellings. Work has begun on a preparing a new Borough-wide SHLAA, but site capacities have not yet been reviewed. Nonetheless, the delivery of more units on the site than was identified is welcome as it will be important for helping the

Borough meet its increased housing need.

Principle of Community Facilities

26 The development proposes two D1 uses a Doctors Surgery and a Children’s Day Nursery.

27 Policy 3.16 (Protection and enhancement of social infrastructure) of the London Plan states that -

a) Development proposals which provide high quality social infrastructure will be supported in light of local and strategic needs assessments. Proposals which would result in a loss of social infrastructure in areas of defined need for that type of social infrastructure without realistic proposals for re-provision should be resisted. The suitability of redundant social infrastructure premises for other forms of social infrastructure for which there is a defined need in the locality should be assessed before alternative developments are considered.

b) Facilities should be accessible to all sections of the community (including disabled and older people) and be located within easy reach by walking, cycling and public transport. Wherever possible, the multiple use of premises should be encouraged.

28 Policy CS16 (Community Facilities) of the Council’s LDF Core Strategy states that the Council will support the provision of new facilities of appropriate size and scale in accessible locations, such as Kingston Town Centre, Surbiton, Tolworth and New Malden District Centres and Local Centres.

29 Furthermore, Policy DM24 (Protection and Provision of Community Facilities) of the LDF Core Strategy states that the Council will require new developments to contribute towards additional infrastructure requirements and community needs resulting from the development.

30 Whilst the facilities are located outside the District Centre they are located immediately adjacent. Furthermore Policy T1 identifies the site as a location for community facilities and specifically a health centre which is what is proposed as part of the development and would also ensure that the development mitigates against the impact on local health services as required by Policy DM24 of the Core Strategy.

31 The Council has expressed its desire during pre-application discussions as to the suitability of the site to accommodate a primary school however the applicant has stated that this is not feasible on the site but instead they are willing to make a financial

contribution towards expanding existing primary schools in the locality through the payment of Local CIL.

32 The provision of community facilities on the site is considered to accordance with the Council’s adopted Development Plan

Principle of Retail

33 The application now proposes a significantly different scale of retail than previous applications. The size of store is a convenience style store and will perform a neighbourhood function selling a basic range of food. The other unit is intended to be a cafe. Both of these facilities are considered important to service the new community that would be created by the development of this site.

34 As the proposal has a retail element is should be assessed against the criteria within the NPPF. Both the convenience store and cafe fall below 2,500 sq m and therefore the NPPF does not require a Retail Impact Assessment to be carried out.

Impact on Character of Area

35 The application proposes the comprehensive redevelopment of a brownfield site within the Tolworth area of the Borough. The application site is sits between the A3 trunk road, the A240 Kingston Road and the railway embankment serving the Waterloo – Chessington railway line. Formerly, the site was occupied by government offices as well as the former Toby Jug Public House which was located on the corner of the Tolworth Interchange and the A3 slip road and Hook Rise South.

36 Although now in outline a tall building of up to 18 storeys is likely to be required to enable the site to deliver 705 dwellings. The parameter plans shows minimum and maximum heights across the site to enable an assessment to be made as to whether the site can deliver this quantum of development proposed. It is therefore important that the ability of the site to accommodate a tall building is assessed as part of this outline application. Tall Buildings above 30 metres in height are also referable to the Mayor of London. The impact these buildings have on the character of the area needs to be assessed with regard to density, layout, design and townscape all of which are set out in detail below.

Tall Buildings

37 Policy 7.7 of the London Plan states that tall buildings should;

generally be limited to site in the opportunity areas, areas of intensification or town centres.

only be considered in areas whose character would not be adversely affected by the scale, mass and bulk of a tall or large building.

relate well to the form composition, scale and character of surrounding buildings, urban grain and public realm

individually or as a group improve the legibility of an area incorporate the highest standards of architecture and materials have good ground floor activities that provide a positive

relationship to surrounding streets. contribute to the permeability of the site and wider area incorporate publicly accessible areas on the upper floors where

appropriate make a significant contribution to local regeneration

38 Tall buildings should not; affect their surrounding adversely in terms of microclimate, wind

turbulence, overshadowing, noise, reflected glare, aviation, navigation and telecommunication interference

impact on local or strategic views.

39 The plans show an indicative location of the tall building which could be up to 18 storeys in height. It is located in the most accessible part of the site adjacent to the train station and bus interchange. The affect of a tall building in relation to residential amenity, daylight/sunlight will be dealt with in the relevant sections of the report along with possible impacts on local and strategic views.

Density

40 The Council’s Borough Character Study identifies the site as ‘Urban’ with densities of around 26 dwellings per hectare.

41 Policy 3.4 of the London Plan seeks to optimize housing density, taking into account local context, character and public transport capacity. The site is classed as ‘Urban’ in the Sustainable Residential Quality (SRQ) density matrix within the London Plan as it within a district centre and within 800m of a train station. The PTAL rating for the site is 2/3 and therefore, at the very upper limit the maximum density is 70-170 u/ha.

42 In determining whether a scheme is too dense however, the above is a guide as to what is likely to be appropriate. In order to sustain a reason for refusal in relation to density it has to be demonstrated that this would result in significant harm. The development therefore needs to be assessed against other criteria in Policy DM10 as to whether the density results in the development being out of keeping with the character of the surrounding area; would be

detrimental to the visual amenities of the surrounding area or would result in the scheme not providing sufficient living or amenity space for future residents.

Layout and Height43 The layout and heights of the proposed development are now

indicative however it does demonstrate a method of site master planning which should be assessed to ensure that 705 dwellings could be accommodated on the site.

44 The buildings have been arranged in linear form so that principal windows and outlook from the residential properties look into the site rather that over the A3 or the railway line. A central spine road would then link the western and eastern parts of the site including the two new vehicular entry points. This central spine will provide activity throughout the development and on to which the front doors from the flats will be located. More private communal areas will be provided between each of the buildings.

45 Building heights vary across the site with the lowest buildings at 2/3 storeys located adjacent to the existing properties on Hook Rise South. This then rises in the central part of the site where heights range from 4- 7 storeys. The most active and most dense part of the site is located around Tolworth Station and the square off which the community facilities and convenience store are located. Here the heights range from 4-11 storeys with a tall building, part 15 part 18 storeys, in height.

Design

46 Paragraph 56 of the NPPF states that the Government attaches great importance to the design of the built environment. Good design is a key aspect of sustainable development, is indivisible from good planning, and should contribute positively to making places better for people. However, Paragraph 60 of the NPPF goes on to add that planning policies and decisions should not attempt to impose architectural styles or particular tastes and they should not stifle innovation, originality or initiative through unsubstantiated requirements to conform to certain development forms or styles. It is, however, proper to seek to promote or reinforce local distinctiveness.

47 London Plan Policy 3.5 (Quality and design of housing developments) states that

a) Housing developments should be of the highest quality internally, externally and in relation to their context and to the wider environment, taking account of strategic policies to protect and enhance London’s residential environment and attractiveness as a place to live.

b) The design of all new housing developments should enhance the quality of local places, taking into account physical context; local

character; density; tenure and land use mix; and relationships with, and provision of, public, communal and open spaces, taking particular account of the needs of children and older people.

48 Policy DM10 states that new development proposals will be required to incorporate principles or good design and those elements that are identified as contributing to the character and local distinctiveness of a street or areas which should be respected, maintained or enhanced.

49 Policy DM11 states that the Council should take a more flexible approach to new development where the existing development lacks any identifiable or cohesive character and / or is located in a lower quality environment; in these circumstances it will seek a high quality development that creates its own distinctive character.

50 The application is in outline with design reserved for consideration at reserved matter stage. If approved detailed conditions and clauses within the S106 agreement would be required to ensure the development adheres to an agreed Masterplan including full landscape design along with detailed design codes to ensure that the Council can ensure a high quality cohesive development.

51 The scheme has undergone a Design Review by an independent panel of experts to provide a professional critique of the scheme. It is important to note however that whilst the critique is important the views of the panel have to be balanced out by other planning issues and therefore there may be areas where the Council does not agree with the approach suggested.

52 The review was carried out by Design South East when the application was still a hybrid application and they have not commented on the application now that it is all in outline. The Review Panel considered “The overall layout is logical and the use – primarily residential – is appropriate. We support the idea of a central spine and a hierarchy of spaces, which provide the masterplan structure for the buildings of broadly appropriate, varying heights and form. The tallest building seemed to the Panel to be in the right place, where it will act as a counterpoint to Tolworth Tower.” The panel went on to say that the masterplan could be improved by increasing density adjacent to the railway line, by considering a comprehensive development solution that could incorporate the Charrington Bowl site in future and to improve the pedestrian linkages from the station into the development.

Impact on Townscape and Protected Assets

53 The Core Strategy identifies Tolworth and this site as a ‘Key Area of Change’ which incorporates the existing ‘Strategic Landmark’ of Tolworth Tower and that this site and others around the A3 roundabout should act as a ‘Gateway’. Any change however needs to take account of the existing character of the area and the impact that new development would have on this character and townscape along with

its affect on the protected assets which are the areas of Green Belt to the south.

54 A Visual Impact Assessment (VIA) has been included with the application however the detail contained within this assessment is no longer for consideration as part of the outline application. The VIA does however give an indication of where scale and height is visible from and whether building at this scale would be detrimental on local and strategic views.

Housing Quality and Mix

Housing Mix

55 Policy 3.8 (Housing Choice) of the London Plan states that taking account of housing requirements identified at regional, sub-regional and local levels, boroughs should work with the Mayor and local communities to identify the range of needs likely to arise within their areas and in terms of the mix of housing sizes and types, taking account of the housing requirements of different groups and the changing roles of different sectors, including the private rented sector, in meeting these ensure that new developments offer a range of housing choices,

56 Policy DM13 requires all new major development to be delivered to a high quality and the most appropriate type including housing mix; adequate internal space standards; lifetime home and appropriate amenity space standards.

57 As the application is in outline there is no breakdown of the 705 units into units sizes. A condition would be required on any approval to stipulate the percentage of 3 bedroom or more units which would then need to be complied with through the submission of any reserved matters application.

Living Standards

58 Policy 3.5 of the London Plan sets out internal space standards for individual units. All units proposed on the development accord with these space standards and are all designed to Lifetime Homes standards. 10% of the units are also wheelchair adaptable.

59 Residential Design Policy 13 of the SPD requires all units to be provided with 10 sq m of private amenity space either in the form of a garden or a balcony. SPD Policy Guidance 19 requires also new development to provide defensible space.

60 As this application is in outline no floor plans have been provided and therefore living standards would be assessed as part of a reserved matters application.

Children’s Playspace

61 Policy 3.6 (Children and young people’s play and informal recreation facilities) of the London Plan states that development proposals that include housing should make provision for play and informal recreation, based on the expected child population generated by the scheme and an assessment of future needs. The Mayor’s Supplementary Planning Guidance Providing for Children and Young People’s Play and Informal Recreation sets out guidance to assist in this process.

62 The Mayor’s SPD sets a benchmark of 10sqm of useable child play space to be provided per child, with under-5 child play space provided on-site. An assessment of the required provision would need to take place as part of a reserved matters application when the tenure and unit type are known.

Affordable Housing

63 Policy 3.12 (Negotiating affordable housing on individual private residential and mixed use schemes) of the London Plan states that the maximum reasonable amount of affordable housing should be sought when negotiating on individual private residential and mixed use schemes, having regard to:a) current and future requirements for affordable housing at local

and regional levelsb) the need to encourage rather than restrain residential

developmentc) the need to promote mixed and balanced communitiesd) the size and type of affordable housing needed in particular

locationse) the specific circumstances of individual sites.

64 Policy DM15 of the Core Strategy requires new development to provide 50% of the units as affordable and that this provision should also be on site.

65 The scheme does not propose 50% of the units to be affordable and therefore in accordance with Police DM15 a financial viability assessment has been submitted with the application which has been independently assessed on behalf of the Council by a Financial Viability Assessor and Cost Consultant. The review has confirmed that the scheme can support 13.19% affordable units which equates to 93 units of a range of sizes and tenures to be provided on site. They recommend however that as the development will be phased over 5-7 years the scheme should also be subject to review mechanisms during the construction of the different phases.

66 An affordable housing statement was submitted with the original application which identified the location, type and tenure of the units which also formed part of the detailed planning application. As the scheme is now all in outline measures will be required within the Section 106 to ensure that the appropriate types of affordable housing are secured on the site within a reasonable timeframe.

Impact on Neighbours’ Residential Amenity

67 Policy DM10 states that new development should have regard to the amenities of occupants and neighbour in terms of privacy, outlook, sunlight / daylight, avoidance of visual intrusion and noise and disturbance.

68 Separation distances for new development are set out in the Council’s SPD Residential Design Guide. Policy Guidance 16, 17 and 18 all deal with amenity requirements.

69 As the scheme is now in outline the majority of the detailed assessment would be considered as part of the reserved matters application when location of windows and habitable windows within the development are known. The indicative layout does however demonstrate that these separation distances could be achieved within the development and in relation to surrounding residential properties most notably 87 Hook Rise South, Drayton Court and Dean Court.

70 The indicative location of the tallest building would be at least 40m from the side elevation of Drayton Court and also located to the south.

71 The applicant has submitted a Daylight / Sunlight Report in accordance with the BRE Guidelines to assess the impact of the development on surrounding properties. The following properties have been assessed: 87 Hook Rise South, 2-66 Hook Rise North, Bell Court, Dean Court and Drayton Court. All properties meet the 25 degree test. In some case further testing in relation to the Vertical Sky Component (VSC) has also been undertaken. These have also demonstrated that the indicative heights proposed would not affect the VSC of surrounding properties in relation to the BRE guidelines.

72 In terms of overshadowing the report sets the suns path for the Spring Equinox (March 21st). This demonstrates that properties on Hook Rise North will experience overshadowing until 10am in the morning and Drayton and Dean Court will experience overshadowing from 3pm.

Highways & Parking

73 There are two highway authorities responsible for commenting on this application. Transport for London (TfL) are the Highway Authority for the A3, Kingston Road and the Tolworth roundabout and RBK Highways are responsible for all other roads within the vicinity of the application site.

74 The application site is currently served by two existing vehicular accesses, one via Lansdowne Close and another via Hook Rise South. The main residential areas in Tolworth are to the northwest of the site (north of the A3) and to the northeast of the site (east of Kingston Road).

75 As well as providing access to the application site, Lansdowne Close also provides access to Drayton Court Car Park (Dean Court has no allocated parking). Access to Lansdowne Close is gained via a left turn from the A240 Kingston Road northbound traffic stream. This also provides access to Toby Way via a short link road that runs parallel to Kingston Road adjacent to Dean Court.

76 Along the north western boundary of the site is Hook Rise South, a single carriageway two-way service road that runs immediately south of the A3 and provides access to housing, an industrial park and King George’s Field. It is accessed via the A3 southbound slip road by way of a left turn only link. Hook Rise South connects with Kingston Road via Toby Way, which is a 7m wide two-way carriageway.

77 The A240 Kingston Road is a dual carriageway route that links to the A3 and the Tolworth Broadway. The A3 is a three lane, major carriageway that provides access from Central London down to the south coast.

78 To the south east of the application site is Tolworth Station that provides a link between Chessington and Central London. Kingston Road is also a TfL designated London bus route.

79 Existing bus stops are located on Kingston Road adjacent to the site. These are served by bus numbers 406, 418 and K2 providing a typical frequency of 1 bus every 6 minutes. Additional services are available on the other side of the A3, namely route numbers 265, 281 and K1. The various bus routes provide access between Tolworth and Kingston, Twickenham, Surbiton, Epsom, Putney and New Malden.

80 A bus interchange is proposed, which would be served via the new site access and adjacent to Tolworth Rail Station. Re-routing of bus service 281 would extend the existing service which currently terminates in front of the Tolworth Tower. This route extension would

effectively terminate and commence the service at Tolworth Railway Station creating a transport interchange.

81 Layover facilities are also to be provided within the site adjacent to the railway station. Such facilities would include toilets and drivers rest rooms.

82 Paragraph 32 of the NPPF states that all developments that generate significant amounts of movement should be supported by a Transport Statement or Transport Assessment. Decisions should take account of whether:

a) the opportunities for sustainable transport modes have been taken up depending on the nature and location of the site, to reduce the need for major transport infrastructure;

b) safe and suitable access to the site can be achieved for all people; andc) improvements can be undertaken within the transport network that cost

effectively limit the significant impacts of the development. Development should only be prevented or refused on transport grounds where the residual cumulative impacts of development are severe.

83 Paragraph 34 of the NPPF goes on to add that planning decisions should ensure developments that generate significant movement are located where the need to travel will be minimised and the use of sustainable transport modes can be maximised. However this needs to take account of policies set out elsewhere in this Framework.

84 Furthermore, Paragraph 35 of the NPPF states that developments should be located and designed where practical to:

a) accommodate the efficient delivery of goods and supplies;b) give priority to pedestrian and cycle movements, and have access to high

quality public transport facilities;c) create safe and secure layouts which minimise conflicts between traffic and

cyclists or pedestrians, avoiding street clutter and where appropriate establishing home zones;

d) incorporate facilities for charging plug-in and other ultra-low emission vehicles; and

e) consider the needs of people with disabilities by all modes of transport.

85 Policy 6.3 (Assessing effects of development on transport capacity) of the London Plan states that:

a) Development proposals should ensure that impacts on transport capacity and the transport network, at both a corridor and local level, are fully assessed. Development should not adversely affect safety on the transport network.

b) Where existing transport capacity is insufficient to allow for the travel generated by proposed developments, and no firm plans exist for an increase in capacity to cater for this, boroughs should ensure that development proposals are phased until it is known these requirements can be met, otherwise they may be refused. The cumulative impacts of development on transport requirements must be taken into account.

c) Transport assessments will be required in accordance with TfL’s Transport Assessment Best Practice Guidance for major planning

applications. Workplace and/or residential travel plans should be provided for planning applications exceeding the thresholds in, and produced in accordance with, the relevant TfL guidance. Construction logistics plans and delivery and servicing plans should be secured in line with the London Freight Plan and should be co-ordinated with travel plans.

86 Policy 6.12 (Road network capacity) of the London Plan states that in assessing proposals for increasing road capacity, including new roads, the following criteria should be taken into account:

a) the contribution to London’s sustainable development and regeneration including improved connectivity

b) the extent of any additional traffic and any effects it may have on the locality, and the extent to which congestion is reduced

c) how net benefit to London’s environment can be providedd) how conditions for pedestrians, cyclists, public transport users, freight

and local residents can be improvede) how safety for all is improved.

87 Policy 6.12 then goes on to add that proposals should show, overall, a net benefit across these criteria when taken as a whole. All proposals must show how any dis-benefits will be mitigated.

88 Policy CS5 (Reducing the Need to Travel) of the Council’s LDF Core Strategy states that to reduce the need to travel, particularly by car the Council will locate major trip generating development in accessible locations well served by public transport including Surbiton, New Malden, Tolworth and Kingston Town Centres. Sites that have poor levels of accessibility by sustainable modes will not usually be considered suitable for development that could generate high numbers of trips.

89 Policy CS6 (Sustainable Travel) states that to support and encourage the use of public transport, cycling and walking the Council will:

a) provide infrastructure, including cycle lanes and crossing facilities, to overcome specific barriers to the safety and convenience of cycling and walking trips, such as the A3, busy roads/ junctions, rail lines and the Hogsmill River.

b) work with and lobby partners to improve existing train services including increased capacities, frequencies and late night services, improved station facilities and fairer pricing.

c) work with and lobby Transport for London to improve the Borough's network of local bus services particularly in areas of low public transport accessibility such as the south of the Borough.

d) improve integration between transport modes particularly to provide improved accessibility to train stations.

90 Policy CS 7 (Managing Vehicle Use) of the LDF Core Strategy states that to manage car use to ensure sustainability, road safety and reduce congestion the Council will:

a) support and promote the use of car share and car club schemes including expanding the network of on-street car club bays.

b) support the use of low emission vehicles including the provision of electric vehicle charging points.

c) implement traffic management measures to ensure highway safety, improve residential amenity and smooth traffic flow.

d) manage on and off-street parking provision to promote sustainability and residential amenity, whilst maintaining the economic vitality of the town centres.

91 Policy DM8 (Sustainable Transport for New Development) states that to support and promote the use of sustainable modes of travel to development sites the Council will:

a) require all significant new development, including schools, workplaces and residential developments to develop and implement a robust and effective Travel Plan.

b) prioritise the access needs of pedestrians and cyclists in the design of new developments and protect and enhance pedestrian and cycle access routes to, and where possible, through development sites, including the protection or enhancement of the strategic cycling and walking networks, as shown on the Proposals Map.

c) require new development to provide facilities on-site for cyclists as appropriate, including showers, lockers and secure, convenient cycle parking, in accordance with minimum standards.

d) require development to make a financial contribution towards sustainable transport improvements and initiatives in line with the Planning Obligations SPD/CIL.

92 Lastly, Policy DM9 (Managing Vehicle Use for New Development) of the LDF Core Strategy states that to ensure that new development does not contribute to congestion or compromise highway safety the Council will:

a) require all major developments to submit a Transport Assessment based on TfL’s Best Practice Guidance.

b) require new development to comply with car parking standards and implement parking management schemes.

c) require new development to provide car club and electric vehicle infrastructure where appropriate in accordance with minimum standards.

Traffic Generation

93 Extensive modelling with regards to the impact of the proposed development on the local highway network has been carried out by both the applicant and TfL. The trip generation models have been agreed by TfL which sees a 10% modal shift away from the car to reflect the extension of the bus services and the sites proximity to Tolworth Station.

94 RBK Highways do not accept that there would be a 10% modal shift

as the 281 bus service already exists and also that reduced levels of car parking provision do not result in reduced car ownership.

Highway Impact95 The application has been accompanied by a Transport Assessment.

TfL have reviewed the assessment and raise no objection to the highway impact of the development in particular on the roundabout and junction with the A3, they do however request a financial contribution to monitor the impacts of the development once constructed. They also require further modelling using VISSIM model to be undertaken at detailed design stage.

Buses

96 TfL consider that the proposed extension of the 281 route into the site is acceptable in principle given the quantum of development, existing routing and the need to provide a connection to the town centre.

97 RBK Highways raise concern about the impact of the location of the Bus Interchange on Lansdown Close and the impact on existing residents in Dean and Drayton Court.

Car Parking

98 In accordance with Policy 6.13 of the London Plan, the following maximum car parking standards should be applied to planning application

No of Bedrooms Car Parking Spaces Required

1 Less than 12 Less than 13 1 – 1.54 1.5 - 2

99 The application proposes the following breakdown of spaces 356 residential 3 Nursery (D1 use) 8 Doctor Surgery (to include 1 Doctors Space and 1 Ambulance

Space) 31 visitor spaces along Toby Way and Hook Rise South

100 The car parking provision for the residential units would equate to an average of 0.5 spaces per unit. As the unit sizes as this stage are not known a more detailed breakdown of provision is not possible. TfL do not object to the car parking levels however they do raise concern about overspill car parking on to surrounding streets. TfL therefore recommend that a survey is carried out about the suitability of a CPZ

on surrounding streets for which future residents of this development would not be able to obtain permits for.

101 The TA states that the bays along Hook Rise South will accommodate some of the visitor demand generated by the development however this parking is uncontrolled so there is no guarantee that there will be spaces available for visitors. In addition these spaces could encourage commuter car parking

102 Parking standards will also need to meet London Plan requirements including 20% of the parking spaces should also be for electric vehicles with an additional 20% passive provision for electric vehicles in the future.

103 One car club space is to be provided adjacent to the railway station and all new residents would be provided with free two year membership to the car club.

104 RBK Highway Officers object to the parking provision and consider that it should be higher than the maximum standards within the London Plan with each unit having at least 1 space. They also object to the creation of a CPZ on the development site and state that there is not community support for a CPZ surrounding the site.

Pedestrian / Cycling and Wayfinding

105 Details of pedestrian and cycle routes have been provided within the Design and Access Statement although these are now indicative they do illustrate how pedestrians and cyclist could enter into and move through the development.

106 The development proposes 1,141 cycle parking spaces which meets London Plan Policy 6.9.

Trees and Landscaping

107 Policy DM10 (Design Requirements for New Developments) of the Council’s LDF Core Strategy states that development proposals should ensure landscaping is an integral part of the overall design of all new developments and that landscaping proposals are submitted as part of planning applications.

108 The landscape masterplan submitted with the application covers the entire site and was provided in detail however this has now become indicative as the scheme is all in outline and landscaping is a reserved matter. The masterplan proposes extensive tree planting along the back edge of Hook Rise South, all the way from No. 87 up to the corner of Toby Way. The trees are proposed to be London Plane and would line the proposed cycle and pedestrian route along the edge of the site. Trees would also line the bottom of the railway embankment as well as the bus interchange and around the edge of Dean and Drayton Court.

109 Within the confines of the development site itself, the proposal would introduce significant tree planting along the central spine road where London Plane is proposed and other varieties of trees and vegetation around the proposed areas of communal amenity space and within the semi-private garden courts.

F

Sustainability

Energy Efficiency 110 Policies 5.1 & 5.2 of the London Plan seek to achieve an overall

reduction in London’s carbon dioxide emissions through a range of measures including using less energy, supplying energy efficiently and using renewable energy, improving on Building Regulations targets by 25% in the period 2010-2013.

111 Additionally, Policy CS1 (Climate Change Mitigation) of the LDF Core Strategy states that the Council will ensure that all development (including extensions, refurbishments and conversions) is designed and built to make the most efficient use of resources, reduce its lifecycle impact on the environment and contribute to climate change mitigation and adaption.

112 The submitted energy strategy demonstrates how the overall development targets meet London Plan requirements.

113 The appropriate BREEAM assessment methodologies demonstrates that Very Good rating is achieved for the commercial units.

Ecology114 The site is not subject to any statutory or non-statutory nature

conservation designation. The nearest statutorily designated sites for nature conservation are Tolworth Court Farm which is separated from the site by the railway line and Hogsmill River Park Local Nature Reserve (LNR) situated approximately 800 m to the south . The site is generally dominated by hardstanding, with a small amount of vegetation being present.

115 Policy 7.19 (Biodiversity and access to nature) of the London Plan states that development proposals should wherever possible, make a positive contribution to the protection, enhancement, creation and management of biodiversity.

116 Policy DM6 (Biodiversity) states that the Council will:a) ensure new developments protect and promote biodiversity as

part of sustainable design, through the inclusion of sustainable drainage, tree planting, soft landscaping, habitat enhancement and/or improvement, green roofs and new or improved semi-natural habitats, where appropriate

b) require an ecological assessment on major development proposals, or where a site contains or is next to significant areas of habitat or wildlife potential.

117 A Phase 1 Ecological Appraisal of the site was submitted as part of the application. This report concluded that those habitats on site are of value within the immediate vicinity of the site only but due to the location of the site and its potential to offer connectivity to other habitats along the rail embankment. The habitats, predominantly scattered scrub, semi improved grassland and introduced shrub, are common urban habitats, limited in extent and not exceptional examples of their type in the context of the local area.

118 Although no reptiles were observed during the initial ecological appraisal the site is directly adjacent to a vegetated rail embankment offering connectivity to sub-optimum habitat for common reptiles such as slow worm and common lizard. It is therefore recommended that if more than 18 months elapses between the survey being carried out and work commencing on site then a further survey should be carried out.

119 It is therefore considered that the development would not have an adverse effect on biodiversity, subject to conditions securing the above mitigation measures, and is therefore in accordance with Policy DM6 of the Council’s adopted Core Strategy.

Environmental Considerations

Flooding and Surface Water Drainage120 The application site is located within Flood Zone 1 and therefore is

considered to be of low risk for fluvial flooding. No significant risks have also been identified in relation to flooding from other non fluvial sources.

121 In accordance with the NPPF and associated Technical Guidance, the FRA qualitatively assesses all sources of flooding and sets out overarching principles that will be adopted as part of the on-going drainage strategy detailed design process.

122 The Environment Agency has no objections to the proposal and recommends a condition regarding the implementation of the mitigation measures and the ongoing maintenance. The Council’s Flood Risk Officer has also made comments on the surface water attenuation methods which would also be addressed by the imposition of this condition.

123 The development would not result in adverse affect on surface water flooding and therefore is in accordance with Policy DM4 of the Council’s LDF Core Strategy 2012.

Land Contamination124 Paragraph 120 of the NPPF states that to prevent unacceptable risks

from pollution and land instability, planning policies and decisions should ensure that new development is appropriate for its location. The effects (including cumulative effects) of pollution on health, the natural environment or general amenity, and the potential sensitivity of the area or proposed development to adverse effects from pollution, should be taken into account. Where a site is affected by contamination or land stability issues, responsibility for securing a safe development rests with the developer and/or landowner.

125 Nevertheless, Paragraph 121 goes on to add that planning policies and decisions should also ensure that:a) the site is suitable for its new use taking account of ground

conditions and land instability, including from natural hazards or former activities such as mining, pollution arising from previous uses and any proposals for mitigation including land remediation or impacts on the natural environment arising from that remediation;

b) after remediation, as a minimum, land should not be capable of being determined as contaminated land under Part IIA of the Environmental Protection Act 1990; and

c) adequate site investigation information, prepared by a competent person, is presented.

126 A Phase 1 Desk Top Assessment was submitted with the application. This concluded that in the absence of any significant historic contaminated land uses that the likelihood for significant pollution is low. As with any development there is potential during ground works for the discovery of materials which could be identified as “contaminated” and therefore a condition should be imposed should unexpected contamination be discovered during the construction process.

127 The Council’s Environmental Health Officer has reviewed the assessments submitted and has no objections subject to conditions.

Noise Impact 128 Paragraph 109 of the NPPF states that the planning system should

contribute to and enhance the natural and local environment by preventing both new and existing development from contributing to or being put at unacceptable risk from, or being adversely affected by unacceptable levels of soil, air, water or noise pollution.

129 Paragraph 123 of the NPPF goes on to add that planning policies and decisions should aim to:a) avoid noise from giving rise to significant adverse impacts on health

and quality of life as a result of new development;b) mitigate and reduce to a minimum other adverse impacts on health

and quality of life arising from noise from new development, including through the use of conditions; and

c) recognise that development will often create some noise and existing businesses wanting to develop in continuance of their business should not have unreasonable restrictions put on them because of changes in nearby land uses since they were established.

130 Policy DM10 (Design Requirements for New Developments) of the Council’s LDF Core Strategy states development proposals should have regard to the amenities of occupants and neighbours, including in terms of noise and disturbance.

131 The application is accompanied by a Noise Impact Assessment which covers the noise from existing noise sources including road, rail and industrial development on future occupiers. The assessment demonstrates that the proposed development would not have a material impact on noise amenities for future occupiers

132 The assessment also concludes that the proposed commercial uses would not have an adverse effect on existing and future occupiers subject to conditions regarding trading and servicing hours.

133 In relation to the existing noise sources the report states that the noise from the road and rail (passenger services) can be mitigated through the detailed design stage including acoustic double glazing and alternative methods of ventilation.

134 To the southeast of the application site, on the opposite side of the railway line, is a concrete batching plant. It is noted that freight trains delivering to this plant regularly arrive at 06:30am and sit idly on the tracks, in an elevated position, with their engines on, waiting for the plant to open at 07:00am. This means that there could be large freight trains sat behind parts of the proposed residential development alongside the railway embankment which could result in harm upon residential amenity, which could, in future, result in unreasonable demands being placed on the plant business because of nearby land use changes. A letter of objection has also been received from the concrete batching plant and their concerns with regard to noise complaints from future occupiers.

135 Further surveys have been carried out in association with the noise consultants employed by the adjacent landowners. These assessments have covered the

Noise from the activity at Day Aggregates and London Concrete (Daytime

Noise from freight train arrival (Night Time)

Noise from activity at London Buses (Night Time)

136 These surveys have concluded that the noise can be mitigated by the methods stated above and will meet the British Standards in relation to noise within residential properties. The outside amenity areas /balconies that could back on to the noise generating uses could be adversely affected however this could be mitigated through the design of the units at reserved matters stage.

Air Quality 137 London Plan Policy 7.14 provides strategic guidance, seeking to

minimize exposure to existing poor air quality and make provision to address local problems. The site lies within the Borough-wide Air Quality Management Area (AQMA) with levels of annual mean nitrogen dioxide (NO2) which exceed recommended objectives.

138 Paragraph 124 of the NPPF goes on to add that planning decisions should ensure that any new development in Air Quality Management Areas is consistent with the local air quality action plan.

139 An Air Quality Assessment has been submitted with the application which assesses the impacts of the development during both construction and operational periods. The development would be air quality neutral for building emissions but not air quality neutral for transport emissions. The transport emissions are approximately twice the benchmark and therefore appropriate mitigation measures should be proposed at the design stage. If the mitigation measures do not result in the development being air quality neutral then the developer will be required to offset any excess emissions.

Legal Agreements

140 Policy IMP3 of the Core Strategy states that the Council will use Planning Obligations to secure financial contributions to meet on and off site requirements which are required to support and mitigate the impacts of the development in accordance with the Council’s SPD on Planning Obligations.

141 On the 1st November the Council commenced the operation of a Community Infrastructure Levy (CIL) which is means of collecting monies to provide local infrastructure to offset the impact of developments. Local CIL replaces S106 as a mechanism for collecting contributions for local infrastructure e.g education and health with the exception of affordable housing which will still be dealt with by way of a S106 agreement.

142 As this application is in outline with all matters reserved the floor area on which the CIL calculation is not known. Using the indicative floor plans however the CIL liability is approximately £2.9 million.

143 In addition the development would also be liable for Mayoral CIL at a rate of £35/m2.

144 The legal agreement will also need to secure the doctors surgery which is to be provided on site. Along with contributions required by Transport for London in relation to the extension of the 281 bus to the station including an additional service and driver facilities (£1.9 million)

and £50,000 for highway monitoring.

Other Material Considerations

Archaeology145 Paragraph 128 of the NPPF states that in determining applications,

where a site on which development is proposed includes or has the potential to include heritage assets with archaeological interest, local planning authorities should require developers to submit an appropriate desk-based assessment and, where necessary, a field evaluation.

146 The site does not lie within an Area of Archeological Significance. An Archeological Desk Based Assessment was submitted with the application this concluded that the site had low potential for remains and taking into account the extent of past ground disturbance the development is unlikely to impact on any significant archeological assets. Historic England have been consulted on the application and agree with the findings of the Desk Based Assessment. On the basis on adjacent areas of Archeological significance they do however recommend that a condition be imposed to secure a programme of archeological evaluation prior to the commencement of development on site

147 The development is unlikely to have an impact on heritage assets and therefore is in accordance with Policy DM12 of the LDF Core Strategy April 2012.

Waste148 Waste management for the residential development needs to be

addressed with a collection strategy in line with Policy Guidance 22 of the Residential Design SPD. As the application is in outline no details of the waste strategy have been included.

Education Impacts 149 Policy DM23 of the Council’s Core Strategy requires new residential

development to contribute to education provision in accordance with guidance in the Planning Obligations SPD of CIL charge.

150 The application has identified that the development would require an additional 78 primary school places and additional 75 secondary school places. At present there is a known deficiency of primary school places which could be mitigated by the expansion of Knollmead School (which is the nearest primary school to the site) to a 2 form entry school. The application will generate a CIL charge which would contribute towards this possible expansion.

Health Impacts151 Policy DM21 of the Council’s Core Strategy requires that all major

developments must submit a Health Impact Assessment (HIA) as part of their application to assess the positive and negative effects of a development. This is particularly important in Tolworth where there is already pressure on GP practices which are at a capacity and in addition to the cumulative effect of other large developments in the vicinity.

152 The HIA sets out that the proposal would l increase the overall practice list per GP from 1,371 to 1,451 however this would still result in a higher level of service than the average provision target for England.

153 The applicant is however providing a new Doctors Surgery on site and discussions with the local NHS Commissioning Board has confirmed that this facility is suitable.

154 The applicant has demonstrated there will be no impact on health provision in the locality which cannot be accommodated within the existing doctors surgeries and in addition a new surgery is proposed which would increase capacity for the whole of the Tolworth area. The development is therefore in accordance with Policy DM21 of the LDF Core Strategy April 2012.

Impact on Leisure Facilities155 Sport England has raised concern with regard to the provision of

sports and leisure facilities and have suggested financial contributions towards off site provision. As this development does not result in the loss of playing fields or sports provision Sport England are a non- statutory consultee.

156 The applicant is required to pay Local CIL through which monies can be spent is sports and leisure facilities to mitigate the impact of the development on local infrastructure.

Cumulative Impact157 Paragraph 24 of the National Planning Policy Guidance (NPPG)

states that local planning authorities should always have regard to the possible cumulative effects arising from any existing or approved development. Since this application was submitted the Tolworth Tower site on the opposite side of the roundabout how has a resolution to approve subject to the completion of a S106 agreement. This development proposes 308 residential units with a further 78 previously approved under the prior notification procedure which allows vacant office space to be converted to residential units without the need for a formal planning application. The impact of these 386 residential units in conjunction with those proposed as part of this application needs to be taken into account

158 There is also the application for the Lidl Headquarters which is undetermined however an assessment on cumulative impact should still be undertaken to assess the possible effects of the schemes on the surrounding area.

159 If both schemes were to gain permission they would result in around 1,000 new residential units being constructed. In this instance, whilst this number of units is significant they are to be constructed in and adjacent to a District Centre, in a sustainable location adjacent to mainline station into London and in an area designated as a Key Area of Change and Housing Opportunity Area within the Council’s adopted Core Strategy. Having regard to these factors it is considered that the development would be taking place in an area identified for development.

160 All the developments would result in changes to traffic on the surrounding road network especially the roundabout with the A3 which is already heavily congested. In making their comments and reaching recommendations on all 3 applications Transport for London has modelled the impact of all 3 developments on the roundabout. The cumulative impact in terms of traffic has therefore been assessed.

161 The developments are also likely to have impacts on socio –economic infrastructure such as school places and health services. The developments on both sites will be phased so it would not result in 1,000 new dwellings all at once. The applicants for this application have indicated a 5-7 year build program which would allow time for the necessary infrastructure to be provided. In addition both developments will be required to mitigate their impacts on local services through the payment of the Community Infrastructure Levy which will provide the monies for additional service provision. This application will also provide a site and building for a new doctors surgery to facilitate increased GP services in the locality.