For advice on how to make further written submissions or... please contact Governance & Democracy by emailing

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For advice on how to make further written submissions or... please contact Governance & Democracy by emailing
For advice on how to make further written submissions or to register to speak on this item,
please contact Governance & Democracy by emailing [email protected] or
telephoning 020 7926 2170. Information is also available on the Lambeth website
www.lambeth.gov.uk/democracy
Site address
Former Annie McCall Hospital and 37 to 39 Jeffrey’s Road,
London, SW4 6QU
Ward
Stockwell
Proposal
Redevelopment of the former Annie McCall hospital site
including extension at roof level and conversion of the existing
building to create 13 residential units; conversion of 37-39
Jeffrey's Road to create 8 residential units; erection of a new 4
storey corner block to create 8 affordable housing units and
erection of a part single, part two storey building to the rear of
the site accommodating 350m2 of B1 space and a 2 storey
dwelling with associated hard and soft landscaping cycle and
refuse storage (Town Planning and Listed building Consent)
Application type(s)
Major Planning Application and Listed Building Consent
Application ref(s)
12/04581/FUL and 12/04582/LB
Validation date
7/12/2012
Case officer details
Name: Kevin Tohill
Tel: 020 7926 5021
Email: [email protected]
Applicant
Henley Homes
Agent
Mr Mark Pender: PPM Planning Limited
Considerations/constraints
Grade II Listed Building
Recommendation(s)
Grant planning permission subject to conditions and the signing
of a s106 for developer contributions
Report Review
Department(s) or Organisation(s)
Date consulted
Governance & Democracy (legal)
13.02/2013
Date response Comments
received
summarised in
para
14.02.2013
Yes
For advice on how to make further written submissions or to register to speak on this item,
please contact Governance & Democracy by emailing [email protected] or
telephoning 020 7926 2170. Information is also available on the Lambeth website
www.lambeth.gov.uk/democracy
Consultation
Department(s) or Organisation(s)
Internal
Crime Prevention
Housing
Housing & Investment
Implementation s106
Parks and Open Space
Conservation and Design
Highways & Transport
Trees
Noise & Pollution
Planning Policy
Streetcare
Policy, Equalities & Performance
Consulted?
(y/n)
Date response Comments
received
summarised in
report? (y/n)
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
13.01.2013
12.02.2013
N/A
Ongoing
07.01.2013
07.12.2012
04.01.2013
12.02.2013
N/A
12.02.2013
N/A
N/A
Yes
Yes
N/A
Yes
Yes
Yes
Yes
Yes
N/A
Yes
N/A
N/A
N/A
N/A
N/A
N/A
N/A
06.01.2013
N/A
N/A
N/A
N/A
N/A
17.12.2012
N/A
N/A
See
consultation
responses for
details
N/A
N/A
N/A
Yes
N/A
N/A
N/A
N/A
N/A
Yes
N/A
N/A
Yes
External
Fentiman Road, Richborne Terrace & Yes
Dorset Road Residents Association
Lansdowne Residents Association
Yes
Mursell Estate Group
Yes
Stockwell Park Residents Association
Yes
Council for British Archaeology
Yes
The Victorian Society
Yes
The Georgian Group
Yes
London Ecology Unit
Yes
Thames Water
Yes
Transport for London
Yes
Environment Agency
Yes
English Heritage
Yes
English Heritage (Archaeology)
Yes
Households
Yes
Background Documents
Case File (this can be accessed via the Planning Advice Desk, Telephone 020 7926 1180)
For advice on how to make further written submissions or to register to speak on this item,
please contact Governance & Democracy by emailing [email protected] or
telephoning 020 7926 2170. Information is also available on the Lambeth website
www.lambeth.gov.uk/democracy
1
Summary of Main Issues
1.1
The main issues involved in this application are:
•
The impact of the proposed building on the heritage interest of the Grade II
listed building;
•
The impact of the development upon the character and appearance of the
townscape;
•
The impact of the proposal upon surrounding residential amenity in terms of
visual intrusion, overbearing impact, a sense of enclosure, loss of light, privacy,
noise and disturbance;
•
The acceptability of a residential use in this location;
•
The quality of the residential accommodation proposed;
•
The quantum and type of affordable housing provided;
•
The impact of the development upon the highway network, conditions of
highway safety and levels of parking provision;
•
The ability of the proposal to reduce its energy demands through the use of
renewable energy technologies and increased energy efficiency;
•
Whether the development would suitably minimise opportunities for crime;
•
Whether adequate refuse storage facilities would be provided for the
development; and
•
Whether the development is inclusive of a sufficient package of s.106 mitigation
to address otherwise unacceptable impacts upon the locality and upon local
infrastructure.
2
Site Description
2.1
The application site is located on the corner of Jeffery’s Road and McCall Close on the
site of the former Annie Mc Call hospital. The site includes a number of buildings which
made up the Annie McCall maternity hospital and 37 - 39 Jeffery’s Road and
surrounding gardens. The site is surrounded largely by residential properties to the
north and west, sheltered housing to the southwest, industrial buildings to the south,
and residential semi-detached and terraced properties to the east.
2.2
In the 1860's houses were built along Jeffery's Road, four of which became the Annie
McCall Maternity Hospital. These were two pairs of semi-detached houses, No. 37-39
and No. 41-43 Jeffery’s Road. The hospital was extended along what is now McCall
Close, with the demolition of two houses on the corner and the building of a specialist
maternity wing on that corner and to the rear of the site, creating the main hospital
building. The building was further extended in 1938 to create an outpatients ward on
McCall Close.
2.3
The area experienced bombing during the Second World War, and the site experienced
significant damage. The corner building was rendered uninhabitable and demolished in
the 1950’s leaving the corner of the site vacant land to this day.
2.4
The area has the remnants of a Victorian street layout, which have been widely
disrupted by bomb damage and post-war development. The south side of Jeffrey's
Road, on either side of the site, retains the original layout of 4-storey villas set close
together or terraced. The site is a significant gap in this pattern, where No. 41-43 was
removed following war damage.
2.5
Facing this, No. 45 Jeffrey's Rd was replaced by a four storey block of flats built in the
1960's in an unsympathetic style. The post-war development significantly altered the
urban character of the street, some larger building types have been introduced, notably
the industrial estate to the south, also the church and flats to the north.
2.6
The buildings in the area are mostly brick with render details - sometimes with a base
marked by render. The Victorian houses have a rendered base half-sunk into the
ground, the Annie McCall wing has a fully rendered ground floor.
2.7
Brick colour varies, there are a variety of yellow bricks, mostly London Stock brick, but
reds and browns as well, most importantly the red brick of the McCall wing. Roofs to
the older buildings are mostly natural slate, newer buildings having concrete tiles of
various sorts.
2.8
The main Annie McCall building which was recently listed in 2011 for its historic and
Architectural value, has two clearly distinct aspects. The front to McCall Close is a
formal Edwardian Baroque design, matched by a single-storey extension of 1938. By
contrast, the rear of the building is a white-rendered protomodernist-design. All the
main rooms of the original hospital are on this south-facing side, with only service
rooms behind the Baroque facade to the north.
2.9
The Maternity Hospital vacated the Annie McCall wing about 25 years ago. Artists have
used the empty rooms and have been able to maintain basic weatherproofing to the
majority of the building. The fabric of the building is suffering from long neglect and is in
need of renovation. The roof has collapsed in one part, and several rooms are too
unsafe to enter.
2.10
The building has three tall storeys, with large, ward rooms lit by large windows. As well
as a pitched roof over the entrance facade, there is an extensive flat roof designed to
be used as a fourth floor; an open-air recreation area. Tall chimneys divide this space
into sections.
2.11
To the south of the building, a large garden has been established since the 1950's by
aggregating pieces of land behind other properties on Jeffrey's Road. This garden has
been used and maintained creatively in recent years, but there has been little control of
the trees which are beginning to dominate the space, and threatening the adjacent
buildings.
3
Relevant Planning History
3.1
The main Annie McCall building which was listed in 2011 for its historic and
Architectural value.
3.2
In July 2012 the applicant entered into a Planning Performance Agreement (PPA) with
the council with a view to working with officers of the council in order to bring forward an
acceptable redevelopment scheme for the site. This is a public document which set out
an agreement between the developer and the council on how the pre-application
process would be managed. The PPA has culminated in the submission of this current
planning application for the local planning authority’s full consideration.
3.3
Whilst entering into a PPA by no way means that a subsequent application will be
rubber stamped, PPAs are increasingly being used by Lambeth on schemes of this
nature to proactively and positively engage with developers to secure developments
that improve the economic, social and environmental conditions of the area; in
accordance with the expectations conferred upon LPAs by the NPPF. It is advised that
in this instance the applicant has responded positively and openly to all advice given. It
must therefore be borne in mind that whilst this officer recommendation of approval is
being presented having regard to the merits of the scheme currently before the LPA for
consideration, those ‘merits’ have been largely and positively influenced by the
extensive pre-application negotiations and discussions that preceded the application
submission.
4
Proposal
4.1
Planning permission is sought for the redevelopment of the former Annie McCall
hospital site. Town Planning and Listed Building Consent are sought.
4.2
The proposal falls into four parts:
Block A: 37-39 Jeffrey’s Road - Conversion of the two existing four-storey, semidetached houses into 8 one bedroom flats; 7 for private sale and 1 shared ownership.
Block B: Former Annie McCall Hospital – Roof top extension to and conversion of the
listed building into 13 residential units including 7 x one-bed units and 6 x two bedroom
units for private sale.
Block C: Former 41-43 Jeffrey’s Road - Erection of a new four-storey affordable
housing block on the currently vacant corner site. This would provide 8 units including:
1 x one-bed, 3 x two-bed and 4 x three bedroom units which would all be affordable
social rent.
Block D: Garden - A new part one, part two storey building for studio workspaces
(350sqm of B1 floor space) with a 1 x one-bedroom lodge.
4.3
The development would provide 30% affordable housing (by unit) on a 89/11 split
between Affordable Rent and Intermediate products. The dwelling size and tenure mix
would be as follows:
Market
1 bed units
2 bed units
3 bed units
TOTALS
15
6
21
Affordable
Rented Units
1
3
4
8
Intermediate
Units
1
1
TOTALS
17
9
4
30
4.4
The proposal includes 350sqm of studio accommodation (falling within use class B1) to
the rear of the site within the garden to allow the artists currently occupying the building
space within the site to carry on their work at a significantly reduced rate of rent. The
proposed studios would be split between 4 x 60 sqm studios, which can be further
segregated into 15sqm spaces as per the users requirements. This block would also
include a 20sqm office space located at ground floor level, between the 2 two-storey
studio spaces. There would also be a further 75sqm, single-storey exhibition space to
the north end of the studios.
4.5
The studio space would be located to the rear of the whole site, within the existing
garden space and would have independent access to Jeffery’s Road via an existing
lane running between Barrington Court and 33-35 Jeffery’s Road. The studios would
also benefit from approximately 400sqm of surrounding external amenity space within
the garden.
4.6
In terms of amenity space provision for the residential element, the majority of the
ground floor units would have access to private garden space, block C would include
balconies for all units, three of the units within the roof top extension on the existing
Annie McCall Hospital would include roof terraces and all units would have access to a
rear communal garden which would be approximately 445sqm.
4.7
In design terms the proposal would retain the external appearance of the existing
buildings, reinstating the features which have been lost and completely renovating the
buildings using traditional materials and features.
4.8
The proposal would include a roof extension on the listed Annie McCall building located
between the existing chimney stacks which maintains the form of the existing building.
On the south side it is set back from the roof edge and reflects the rational glazing
below. On the north side, it repeats the existing pitched roof over the stair to make a
mansard type of roof. The second extension is to the rear of 37-39 above the existing
back additions. Both extensions would be finished in materials to match the existing.
4.9
The new corner block (block C) would continue the existing building line of the
properties on Jeffery’s Road. The massing matches that of the pairs of houses along
Jeffrey's Road. The height matches the parapet of the McCall wing, which in turn is set
approximately at eaves level with the houses on Jeffrey's Road.
4.10
Refuse and recycling storage would be provided at ground floor level at various
assessable locations surrounding the different blocks. Cycle stores would also be
located in several locations, appropriate to the blocks which they are associated with.
5
Consultations and Responses
5.1
202 letters of consultation were sent out to neighbouring property addresses.
5.2
Four site notices were displayed on the 14th December 2012 and a press notice was
published on 19th December 2012 in the Weekender.
Internal Consultation Responses
5.3
Highways and Transportation - Supports the scheme subject to conditions of s.106
obligations. Welcomes the electric charging points, level of cycle parking provision and
overall layout of the scheme and landscaping.
5.4
Planning Policy - Raises no objection. Supports the mix of units, quantum of affordable
housing, and the re-provision of the B1 use within the rear gardens of the site.
5.5
Conservation and Design - Supports the development, subject to conditions.
5.6
Crime Prevention Design Advisor – Supports the scheme. Has met with the applicants
throughout the design process and the various issues raised at that time have been
addressed.
5.7
Housing - Supportive of the scheme, including the additional housing, the mix of units,
provision of family sized affordable housing units, layout, large scale of the units and
standard of accommodation proposed.
5.8
Arboricultural Officer - Raises no objection, subject to conditions relating to landscaping
and the removal of trees.
5.9
Parks and Open Space – Supports the scheme, subject to conditions requiring them to
check the site for protected species before commencement of development and to
them providing compensatory new landscaping and ecological features.
External Consultation Responses
5.10
Environment Agency - No objection has been raised.
5.11
English Heritage – Have not formally responded to the planning application
consultation, but have been involved with the development throughout the preapplication process. It is understood by Lambeth officers that the concerns that EH
officers raised at pre-application stage have been addressed.
5.12
Council for British Archaeology – No objection
5.13
London and Middlesex Archaelogical Society - Raise no objection to the conversion of
37-39 Jeffery’s Road, the Former Annie McCall Hospital building and no objection to
the proposed studios and lodge in the rear garden but have raised objection to rooftop
extension and internal layout and the impact these elements could have on the listed
building. Concern is also raised to the corner block ‘C’ building as this could have an
impact on the setting of the listed building.
5.14
Neighbour Consultation
No. of Letters sent
No. of Objections
No. in support
Comments
202
63
37
1
Comments:
Officer’s Response:
OBJECTIONS
Loss of community use/building
The proposal includes artist’s studios to the rear of the
site within the garden, specifically for the existing groups
currently using the site.
Overlooking
of
neighbouring Officers consider that due to the distances between the
residential
properties
and proposal and neighbouring properties and the design of
associated loss of privacy
the development to avoid loss of privacy there should be
no significant impacts on neighbouring amenity. Further
details are set out in section 8 of this report.
Loss of security to neighbouring The site will be used mostly for residential dwellings
properties
therefore increasing the natural surveillance of the site
and surrounding area. Furthermore the development will
be conditioned to submit a crime prevention strategy to
be approved by the Council to ensure the development
and surrounding buildings are safe and secure.
The artist group should
maintained at the property
be The proposal includes artist’s studios to the rear of the
site within the garden, specifically for the existing groups
currently using the site. The artists can use the proposed
studios and not have to move from the site.
The loss of the eco garden and
associated flora and wildlife
Retention of greenspaces is vital
given all other development coming
forward in the area.
The Councils Parks and Open Space officer has
assessed the submitted Habitat assessments and
knowing the site commented on the development, stating
that the site isn’t a current Local Wildlife Site (Site of
Importance for Nature Conservation or SINC) for
Lambeth and hasn’t been identified as such in any
previous ecological surveys. As such there would be no
automatic presumption against development or loss of
the site through the existing Core Strategy or Local Plan
policies. The site isn’t a public accessible greenspace
and as the amount of available open space wasn’t
identified in the Lambeth Open Spaces Strategy (OSS)
as it’s less than the 0.2 ha threshold. As such there is no
objections raised to the development of the site, and the
proposals may result in the open areas being improved
or better managed as a consequence.
The area does not need houses as
much as it needs community
engagement facilities such as the
existing studios. There are already a
large number of empty homes in the
area.
Too much non-family housing
The Councils 2012 Housing Needs Survey sets out the
shortage for housing in the borough and the proposed
development has been developed to address the needs
of the borough. The housing Needs Survey shows an
acute shortage in larger family sized housing.
The residents in Stockwell Studios
were promised a long lease in return
for renovating and looking after the
building, which they have done.
This is not a planning matter, renovations have been
undertaken to make the building safe for occupation, the
listed building itself is in a state of disrepair and in
desperate need for full renovation.
See above.
The council is more concerned with This is not a planning matter and no alternative scheme
capital receipt than other matters
has been brought forward to planning.
By failing to consider Stockwell
Studios not for profit scheme to
deliver affordable housing and an art
scheme, Lambeth Council is failing
to be a ‘Co-operative Council’
The residential development would Lambeth officers consider this scheme well designed.
be soulless.
Harm to the listed building
The roof extension undermine the
original roof terrace designed for
patients to take air. The conversion
obscures the original layout.
The development has been progressed through careful
consideration for the heritage asset through work with
the Council’s conservation officers, English Heritage, the
developer’s heritage advisor and architects to preserve
and enhance the character and appearance of the listed
building while bringing the building back into full use from
its current dilapidated state.
The building is not at risk as it is not The building is in a dilapidated state and has only been
included on English Heritage’s ‘at renovated to the point of making it safe for occupation.
risk’ register.
The original character and appearance of the heritage
asset is being loss through the lack of needed works to
the fabric of the listed building.
Conversion of 37/39 Jeffreys Road
conflicts with core strategy policy S2
as Jeffreys Road is identified as a
street under conversion stress.
Jeffreys Road is identified within the development plan
as a street under conversion stress. Within such streets
Policy S2 generally affords protection to family sized
housing from conversion so as "to ensure mixed and
balanced communities with a choice of family sized
housing". In this instance however the conversion of 3739 Jeffreys Road to provide 8 x 1 bed units needs to be
considered in the context of the comprehensive
redevelopment of the application site; inclusive of the
planning benefits that would be derived. In particular the
conversion of 37-39 Jeffreys Road contributes to the
overall housing offer inclusive of a choice of units and a
large number of affordable family housing units. Such
would contribute considerably to Lambeth's Housing
needs and demand. In the circumstances officers are
satisfied that the conversion of 37-39 Jeffreys Road as
part of the comprehensive redevelopment of the
application site would not unduly prejudice the
retention/provision of a mixed and balance community so
as to conflict unacceptably with Core Strategy Policy S2.
Increased parking stress in the area.
The development will be car free.
Shortfall in replacement employment
floorspace – 1,125sqm to 350 sqm.
The applicant has failed to provide
marketing evidence to demonstrate
that the existing B1 use/building is
surplus.
The current building is much larger than the proposed
studio space however the existing building is
substantially underused with entire floors being occupied
by a very small number of people. The proposed artists
studios would provide modern accommodation which
officers consider appropriate in size to the level of
occupancy within the building at its current levels.
Block C will obscured public views The Councils conservation officers, English Heritage and
of the listed building
heritage experts do not consider that this would be the
case. The existing building is currently surrounded by
hoardings and badly neglected to the point that you
would not notice the listed building. This development
would reinstate the appearance of the listed building and
substantially improve the whole site to enhance the
appearance of the listed building.
Block C is unsympathetic to the
surroundings. There is no pitched
roof or bay window and the
inclusions of balconies would detract
from the appearance of the street
scene.
The development of Block C has been subject to
significant discussions with expects and officers and the
modern appearance of the block is considered to reflect
the appearance of surrounding buildings and the listed
building, avoiding a modern poor copy of the features
along Jeffery’s Road.
Too high density
The density is appropriate for a location with good
transport links as this has.
SUPPORTING COMMENTS
The site is well
redevelopment
in
need
of Noted
Developing part of the gardens for Noted
the current artists is a community
benefit.
It addresses the issues of squatters Noted
at the site.
Provides new well designed homes
Agreed
Supports enterprise and business.
Agreed
Ensures artists can stay at the site Agreed
and continue their community work
Provides much needed affordable Agreed
housing
Restoration of the listed building
Agreed
Contributing to regeneration and Agreed
investment in the area.
Ecological
features
reintroduced.
5.15
could
be The rear garden will largely be retained, as a whole
garden.
Councillor Imogen Walker has expressed concern about the planning application and
has specifically requested that this planning application be brought before the Planning
Applications Committee.
6
Planning Policy Considerations
National Guidance
6.1
Section 38(6) of the Planning and Compulsory Purchase Act 2004 requires planning
decisions to be made in accordance with the development plan unless material
considerations indicate otherwise. The development plan in Lambeth is the London
Plan (‘consolidated with Alterations since 2004’ published in February 2008), the
Lambeth Core Strategy (adopted 19 January 2011) and the remaining saved policies in
the ‘Lambeth Unitary Development Plan (UDP) 2007: Policies saved beyond 5 August
2010 and not superseded by the LDF Core Strategy January 2011’. Material
considerations include national planning policy statements and planning policy
guidance.
6.2
On 27th March 2012, the Government published the National Planning Policy
Framework. This document had the immediate effect of replacing various documents
including, amongst other documents, PPS1, PPS3, PPS4, PPS5, PPS12, PPG13,
PPG17 and Circular 05/2005: Planning Obligations.
6.3
The National Planning Policy Framework sets out the Government’s planning policies
for England and how these are expected to be applied. It reinforces the Development
Plan led system and does not change the statutory status of the development plan as
the starting point for decision making. The NPPF sets out that the National Planning
Policy Framework must be taken into account in the preparation of local and
neighbourhood plans, and is a material consideration in planning decisions. Moreover,
it sets out that in assessing and determining development proposals, local planning
authorities should apply the presumption in favour of sustainable development.
The London Plan 2011
6.4
The London Plan was published in July 2011 and replaces the previous versions which
were adopted in February 2004 and updated in February 2008. The London Plan is the
Mayor’s development strategy for Greater London and provides strategic planning
guidance for development and use of land and buildings within the London region.
6.5
The London Plan is the overall strategic plan for London, and it sets out a fully
integrated economic, environmental, transport and social framework for the
development of the capital over the next 20-25 years. It forms part of the development
plan for Greater London. All Borough plan policies are required to be in general
conformity with the London Plan policies
6.6
The key policies of the plan considered relevant in this case are:
•
•
•
•
•
•
•
•
•
Policy 1.1 - Delivering the strategic vision and objectives for London
Policy 2.9 - Inner London
Policy 3.3 - Increasing housing supply
Policy 3.4 - Optimising housing potential
Policy 3.5 - Quality and design of housing developments
Policy 3.8 - Housing choice
Policy 3.10 - Definition of affordable housing
Policy 3.11 - Affordable housing targets
Policy 3.12 - Negotiating affordable housing on individual private and mixed
use schemes
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
Policy 3.13 - Affordable housing thresholds
Policy 4.1 - Developing London’s economy
Policy 5.1 - Climate change mitigation
Policy 5.2 - Minimising carbon dioxide emissions
Policy 5.3 - Sustainable design and construction
Policy 5.6 - Decentralised energy in development proposals
Policy 5.7 - Renewable energy
Policy 5.8 - Innovative energy technologies
Policy 5.9 - Overheating and cooling
Policy 5.10 - Urban Greening
Policy 5.11 - Green roofs and development site environs
Policy 5.13 - Sustainable drainage
Policy 5.14 - Water quality and wastewater infrastructure
Policy 5.15 - Water use and supplies
Policy 5.16 - Waste self-sufficiency
Policy 5.18 - Construction, excavation and demolition waste
Policy 6.3 - Assessing effects of development on transport capacity
Policy 6.5 - Funding crossrail and other statically important transport infrastructure
Policy 6.7 - Better streets and surface transport
Policy 6.9 - Cycling
Policy 6.10 - Walking
Policy 6.13 - Parking
Policy 7.1 - Building London’s neighbourhoods and communities
Policy 7.2 - An inclusive environment
Policy 7.3 - Designing out crime
Policy 7.4 - Local character
Policy 7.5 - Public realm
Policy 7.6 - Architecture
Policy 7.14 - Improving air quality
Policy 7.15 - Reducing noise and enhancing soundscapes
Policy 7.18 - Protecting local open space and addressing local deficiency
Policy 8.2 - Planning obligations
Policy 8.3 - Community Infrastructure Levy
Lambeth LDF Core Strategy (2011)
6.7
The following policies are considered to be of relevance to the assessment of this
application:
•
•
•
•
•
•
•
•
•
•
Policy S1 - Delivering the Vision and Objectives
Policy S2 - Housing
Policy S3 - Economic Development
Policy S4 - Transport
Policy S5 – Open space
Policy S6 – Flood Risk
Policy S7 - Sustainable Design and Construction
Policy S8 - Sustainable Waste Management
Policy S9 - Quality of the Built Environment
Policy S10 - Planning Obligations
London Borough of Lambeth Unitary Development Plan (2007): ‘Policies saved beyond
5 August 2010 and not superseded by the LDF Core Strategy January 2011’
6.8
The following policies are considered to be of relevance to the assessment of this
application:
•
•
•
•
•
•
•
•
•
•
•
•
•
Policy 7 - Protection of Residential Amenity
Policy 9 - Transport Impact
Policy 14 - Parking and Traffic Restraint
Policy 16 - Affordable Housing
Policy 17 – Flat Conversions
Policy 23 – Protection and Location of other Employment Uses
Policy 30 – Arts and Culture
Policy 31 - Streets, Character and Layout
Policy 32 - Community Safety/Designing Out Crime
Policy 33 - Building Scale and Design
Policy 35 - Sustainable Design and Construction
Policy 39 - Streetscape, Landscape and Public Realm Design
Policy
45
Listed
Buildings
Local Guidance
6.9
The council has adopted the following Supplementary Planning Documents, which are
relevant:
•
SPD: Housing Development and House Conversions
•
SPD: Safer Built Environments
•
SPD: Sustainable Design and Construction
•
SPD: S106 Planning Obligations
6.10
The Council’s ‘Waste & Recycling Storage and Collection Requirements: Guidance for
Architects and Developers’ (2006) is also relevant.
Regional Guidance
6.11
The following regional guidance is relevant to the application proposal:
•
•
•
•
•
•
•
•
•
Housing Supplementary Planning Guidance (2012)
SPG: Planning for Equality and Diversity in London (2007);
SPG: Sustainable Design and Construction (2006);
London Housing Design Guide Interim Addition (August 2010);
London Housing Strategy (2010) and Revised Consultation Document (2011);
Delivering London's Energy Future: the Mayor's climate change mitigation and
energy strategy (2011);
SPG: Accessible London: Achieving an Inclusive Environment (April 2004);
BPG: Wheelchair Accessible Housing (September 2007); and
Play and Informal Recreation SPG (2012)
7
Land Use
7.1
Housing
7.1.1
Core Strategy Policy S2 (housing) seeks the provision of at least 7,700 net additional
dwellings across the borough between 2010/2011 and 2017/17 in line with the London
Plan. The London Plan sets an annual monitoring target for Lambeth of 1,195 new
homes. In addition, the London Plan seeks to maximise affordable housing provision
and ensure an average of at least 13,200 more affordable homes per year in London
over the term of the Plan.
7.1.2
The development would deliver 30 residential units, 9 of which would be affordable the level of affordable housing provision and the tenure mix is discussed in more detail
below. It is therefore the case that the development would contribute significantly
towards addressing Lambeth’s (and London’s) housing needs and demand. This is
without doubt a substantial planning/public benefit that weighs heavily in favour of the
development.
7.1.3
Jeffreys Road is identified within the development plan as a street under conversion
stress. Within such streets Policy S2 generally affords protection to family sized
housing from conversion so as "to ensure mixed and balanced communities with a
choice of family sized housing". In this instance however the conversion of 37-39
Jeffreys Road to provide 8 x 1 bed units needs to be considered in the context of the
comprehensive redevelopment of the application site; inclusive of the planning benefits
that would be derived. In particular the conversion of 37-39 Jeffreys Road contributes
to the overall housing offer inclusive of a choice of units and a large number of
affordable family housing units. Such would contribute considerably to Lambeth's
Housing needs and demand. In the circumstances officers are satisfied that the
conversion of 37-39 Jeffreys Road as part of the comprehensive redevelopment of the
application site would not unduly prejudice the retention/provision of a mixed and
balance community so as to conflict unacceptably with Core Strategy Policy S2.
7.2
Employment
7.2.1
With regard to the site’s change of use, the majority of the site has been used for many
years as commercial artists’ studios with a smaller part for residential. The 2011
Lambeth Core Strategy de-designated the site as outside of a Key Industrial Business
Area (KIBA) where uses should be for industry, business and other similar uses
associated with industrial areas. Core Strategy and saved Lambeth UDP policies for
employment sites outside of KIBAs therefore apply.
7.2.2
Policy S3(b) states that the council will maintain a stock of sites and premises outside
KIBAs in commercial use across the borough, subject to the suitability of the site and
location and should be read alongside saved Lambeth UDP Policies 23 and 30.
7.2.3
UDP Policy 30 (Arts and Culture) sets out that the provision of additional
accommodation for the creative industries is promoted and existing accommodation is
protected by Policy 23. In addition, Policy 30 requires that premises for creative
industries are protected for that use (except where these have been introduced as
temporary uses pending redevelopment). In this latter regard, the proposed B1 space
is intended to re-house the existing artist groups on site and such would be prioritised
by way of the s106 agreement; albeit that should for any reason the artist groups not
take occupation then the space would default to a general B1 use.
7.2.4
In terms of Policy 23 (Protection and Location of other Employment Uses) protects
employment uses outside of KIBAs unless certain exception criteria are met. The
development would include a net reduction in employment space at the site, but the
existing building is currently under-utilised in terms of employment occupation
densities. Exception criterion (iii) sets out that exceptionally, where a scheme has
substantial other planning benefits and where development of part of the site is
compensated by for example increasing the amount of employment on the remainder
and/or providing modern small business units. In this instance the existing artist groups
are to be re-housed on site so the redevelopment would not result in any loss of
employment. If for any reason the artists do not take residence of the B1 space, a
conventional B1 use of the space could generate in the region of 29 jobs (using the
HCA Employment Densities Guide). Either way, these are planning benefits of the
scheme which, when considered in conjunction with the other benefits of the
development (the provision of new housing, the provision of affordable housing, the
regeneration benefits for the locality, the sensitive restoration of listed building and the
bringing back of a currently under utilised listed building into a sustainable long term
use) are substantial such as to satisfy exception criteria (iii).
7.2.5
The site is an entirely suitable location for continued employment use. The existing
artist groups have operated from the site for 25 years without undue conflict with
neighbouring residential properties. Moreover, B1 uses are, by definition, uses which
can operate in close proximity to residential properties without causing harm to
amenity.
7.3
Residential Accommodation - Size Mix, Tenure and Quality
7.3.1
Policy S2 sets out that with a residential major development, at least 50 per cent of
housing should be affordable where public subsidy is available, or 40 per cent without
public subsidy, subject to housing priorities and, where relevant, to independently
validated evidence of viability. Furthermore, there is an expectation that the mix of
affordable housing should be 70 per cent social rented and 30 per cent intermediate.
7.3.2
London Plan Policies 3.9 to 3.12 assert the need for mixed and balanced communities
and in this context seek to maximise affordable housing provision. In order to give
impetus to a strong and diverse intermediate housing sector, the London Plan advises
that 60% of the affordable housing provision should be for social rent and 40% for
intermediate rent or sale and that priority should be accorded to provision of affordable
family housing.
7.3.3
Whilst the current development plan does not make specific reference to Affordable
Rent products, the Mayor’s Housing SPG clearly sets out that the new Affordable Rent
product is intended to address the same housing needs as Social Rented housing.
Affordable Housing Offer and Dwelling Mix
7.3.4
The development would provide 30% affordable housing (by unit) on a 89/11 split
between Affordable Rent and Intermediate products. It has been assumed that no
grant will be available for the development. The dwelling size and tenure mix would be
as follows:
Market
7.3.5
Affordable
Intermediate TOTALS
Rented Units
Units
1 bed units
15
1
1
17
2 bed units
6
3
9
3 bed units
4
4
TOTALS
21
8
1
30
The affordable rented housing is provided in Block C, as this facilitates the preferred
management arrangements of the Register Providers. 50% (by unit) of the Affordable
Rent accommodation would be provided as family sized units (3+ bed); in excess of
the draft revised London Housing Strategy, which sets out that 36 per cent of the new
Affordable Rented homes will be family-sized. The need for Affordable Rent products
to be skewed towards family sized units is also echoed in the council’s own Housing
Needs Survey. By contrast, the market housing provision would be skewed towards 1
and 2 units; also in conjunction with the recommendations of Lambeth’s Housing
Needs Survey.
7.3.6
Given the overall numbers of affordable housing units proposed, provision has been
mainly constricted to Affordable Rented units. Whilst not a 60/40 or 70/30 split as
generally required by the Development Plan policies, such is considered acceptable as
the greater proportion of family sized affordable rented units than would otherwise be
secured better addresses the Borough’s priority housing need. A Core Strategy policy
compliant 40% affordable housing provision and 70/30 split could potentially be
provided, but such would provide a lower number of affordable family homes. It should
be noted that if measured by habitable room, the development would be providing 40%
affordable housing.
7.3.7
The upper limit of the rent levels of the affordable rent units will be set within the s.106
agreement to appropriately ensure that they are affordable to prospect tenants, having
regard to rent values that housing benefit caps would permit.
7.3.8
For the reasons set out above, the residential mix is considered acceptable.
Quality of the Resident Units
7.3.9
All of the new dwellings have been designed to meet the Mayor’s London Housing
Design Guide and the Council’s SPD (Housing Development and House
Conversions) in terms of size and layout. In addition, all of the new build units would
be designed and constructed to the Lifetime Homes Standards whilst the flats to be
provided within the converted listed buildings will meet the criteria as far as is
practicable. In addition, all units have been designed to maximise views and aspect
which results in no units being single aspect and the vast majority being duel aspect.
7.3.10
In terms of daylighting, all rooms/units would achieve the BRE recommended
guidelines for Average Daylight Factors (ADF).
Amenity & Play Space
7.3.11
7.3.12
7.3.13
The scheme proposes amenity space throughout the site as follows:
Private balconies/terraces/ground level 324 sqm
gardens
Shared gardens
445 sqm
Total
769 sqm
This provision is considerably over the minimum 350 sqm amenity space requirement
(either as communal or as private space) which the council’s SPD (Housing
Development and House Conversions) would dictate a residential development of this
quantum should provide. It is considered to be a generous provision.
Using the methodology within the Mayor’s Play and Informal Recreation SPG, the
anticipated child yield of the development would be 13.6. The guidance sets a
benchmark requirement of 10sqm of useable child playspace to be provided per child,
with a presumption that under 5 child playspace is to be provided on site and that
provision for over 4s may be provided via off-site contributions if there are suitable
facilities in the locality. In this context the development would be expected to make
provision for 136 sqm of playspace, with at least 40 sqm of under 5s provision on site.
It should be noted that Lambeth’s SPD is explicit in that the delivery requirements for
children’s play space provision should be considered as part and parcel of the overall
amenity space provision for the site, and not over and above.
7.3.14
The scheme includes a sizable rear garden area which would be suitable for the
location of the children’s play area while retaining sufficient additional space to
accommodate the required communal amenity space for the residential units. The
development has well in excess of this area allocated to External Amenity Space
including Children’s Park Space, this is therefore considered acceptable subject to
condition.
7.3.15
In addition to the on-site amenity and play space provision, the development would be
inclusive of s.106 financial contributions of i) £40,678.70 and ii) £10,649.50 towards
improvements to off-site i) parks and open spaces and ii) childrens’ playspace
provision respectively. Such monies would be directed, via the council’s s.106 protocol,
towards facilities within the vicinity of the site so as to mitigate the otherwise
unacceptable impacts of the development.
7.3.16
The above provisions are considered appropriate to cater for the amenity space and
play space needs that would likely arise from the development.
7.4
Land Use Conclusions
7.4.1
In summary the proposed mixed use development accords with the Council’s planning
policies, and the NPPF’s presumption in favour of sustainable development (para 14)
which recognises that housing development is a significant contributor to economic
growth. As a result the proposal is acceptable in principle in terms of land use through
its provision of housing and employment.
8
Impact on Neighbouring Amenity
8.1
Policy 7 of the Adopted Unitary Development Plan deals with the protection of
residential amenity. It states that the right of people to the quiet enjoyment of their
homes will be respected. It also states that in mixed use areas, the scale, design,
layout, hours of use, intensity, concentration, and location of non-residential uses will
be controlled in relation to residential uses in order to protect residential amenity.
8.2
Saved UDP Policy 9 relates to impacts during the construction period.
8.3
Adopted UDP Policy 36 (c) sets out criteria which new development should not
unacceptably affect. These protected criteria are as follows: privacy; outlook and
associated unacceptable sense of enclosure; and, sun/daylight. The above mentioned
daylight and sunlight assessment confirms that there would be a minimal impact on
neighbouring properties.
8.4
In the first instance the development would not be introducing any uses that would
undue conflict with neighbouring residential uses of the site. This is an existing
residential area and the artist groups have been operating on the site for some 25
years. Indeed, B1 use by definition is acceptable in residential areas.
8.5
In terms of the development works, the development largely includes the conversion of
the existing Annie McCall hospital and 37-39 Jeffery’s Road, although new build
development and extension is included.
8.6
The proposed new buildings include the four storey residential building on the corner of
Jeffery’s Road and McCall Close, adjoining 37-39 Jeffery’s Road. This building is
located within a currently vacant plot which historically housed a much larger building
than was typical of the Street. The block would be located some 15m from the flank
wall of No. 45 Jeffery’s Road and some 20m from the opposite buildings across
Jeffery’s Road. At these distances it is considered that the proposal which is or
comparable size to the surrounding buildings on Jeffery’s Road would have no impact
on neighbouring properties and the distances would be sufficient to avoid any loss of
privacy.
8.7
To the rear of the site the proposed artists studios would be located within the rear
corner of the garden, bounded to the rear by the existing high walls of the industrial
park to the south of the site. Due to this location adjoining the existing industrial
buildings and at a distance of over 20m from the rear windows of Barrington Court it is
considered that there would be no unacceptable impact upon residential amenity in
terms of loss of daylight, sunlight, outlook or privacy.
8.8
The proposed extension on the roof of the former Annie McCall Hospital has been set
back significantly from the rear boundary wall to avoid any impact on neighbouring
properties in terms of over shadowing or loss of privacy. While the rear windows and
small terrace near 33-35 Jeffery’s Road would be approximately 15m from the nearest
rear windows, the set back from the boundary and the angles of the windows would
prevent overlooking. Furthermore the roof terrace for this nearest proposed unit would
intentionally serve the main bedroom and not the main living room to avoid more
regular use of the space.
8.9
The proposed rear extensions to the rear of 37-39 Jeffery’s Road would be located
within relatively close proximity to the rear of the adjacent property, No. 33-35 Jeffery’s
Road. No windows are proposed on this elevation to avoid overlooking and loss of
privacy.
8.10
The
submitted daylight, sunlight and overshadowing report identifies that all
neighbouring windows other than the lower ground floor level window set in the
projecting rear range at the back of No. 35 Jeffrey’s Road will retain levels of daylight
and sunlight in accordance with BRE guide levels. The window in question will
experience only a marginal reduction in its VSC level as a result of the development
and in any event appears to be a secondary window serving a room that also benefits
from a west facing window, which itself will be unaffected by the development.
8.11
Overall, the submitted evidence demonstrates that the level of compliance with the
BRE guide levels amongst neighbouring properties is very high for an urban
environment in Inner London, particularly taking account of the flexibility of the BRE
guidance and its basis on a suburban scale of development.
8.12
Noise, disturbance and inconvenience during the construction period can be
appropriately minimised through good practice and the recommended conditions.
8.13
In terms of its impact upon neighbouring residential amenity, the development need
not therefore fail against the relevant policies of the Development Plan; namely UDP
Policies 7, 9 and 33.
9
Design
9.1
Policy S9 of the Lambeth LDF Core Strategy states that the Council will improve and
maintain the quality of the built environment and its liveability by seeking the highest
quality of design in all new buildings, alterations and extensions and, of the public
realm.
Impact on the Grade II Listed Building
9.2
The former Annie McCall hospital is a unique building of historic and architectural
value which was Grade II listed in 2011. Its cultural significance lies in the pivotal role it
plays in women’s history and their contribution to the medical and architectural
professions.
9.3
Despite some inappropriate interventions, there are many historic features of note in
this building; these have been identified and documented extensively in the applicant’s
heritage statement and have been used to inform the development of the scheme. The
historic floorplans would remain legible, the historic fabric would be left intact and,
where appropriate, damaged or missing features of note have been proposed for
reinstatement.
9.4
At present, the building is difficult to appreciate from the public realm. The applicant
has worked closely with Council officers to design an entrance to the building which
respects the traditional design whilst making the boundary treatment less defensive.
Officers support the reinstatement of the traditional gates and the sensitive
landscaping works proposed. The retention and minimal intervention to the rear garden
space is welcomed and the landscaping proposals respect the desire to retain the
garden largely as is, with the appearance that it has not been partitioned off through
the use of low hedging and fences.
9.5
Officers have extensively discussed the proposed extensions to the listed building with
English heritage and consider them to be appropriate to context; provided details are
secured via condition. Officers consider the works likely to remain subordinate to the
host building and unlikely to affect its historical significance. Overall, it is considered to
be a sensitive scheme which will serve to bring a currently under-utilised building back
into full use.
Scale, Massing and Design
9.6
The new development on the site was developed in close consultation with the
planning department at pre-application stage. Officers raised a number of issues with
previous proposals and these concerns were considered and ultimately addressed by
the applicant in a meaningful and evolving design process. The bulk, massing and
height are appropriate for the context; serving to punctuate the corner without over
dominating the listed building. The fenestration pattern, vertical hierarchy and
boundary treatments provide a contemporary interpretation of the traditional character
of the Victorian villas at 37-39 Jeffrey’s Road. Finer detailing, such as materials, shall
be controlled by condition.
9.7
Refuse, recycling and cycle storage have been incorporated meaningfully into the
development.
9.8
37 - 39 Jeffrey’s Road are a pair of semi detached Victorian villas which would largely
remain unaltered on the front elevation. Extensions to the rear are considered
appropriate in the context of the whole site redevelopment, maintaining the building
lines of the existing back addition.
9.9
The proposed development to the rear of the site is in a discreet location along the
existing site boundary and is subordinate in height and sensitive in its design. Officers
consider the proposal appropriate in the context of the site given the use and modest
scale, located to the rear of the garden, adjoining the KIBA industrial park, subject to
details being secured via condition.
9.10
The proposed development is considered to provide a high quality and comprehensive
solution to the development of this prominent location on the corner of Jeffery’s Road
and McCall Close, enhancing views from the surrounding area to the Annie McCall
grade II listed building. The development would fit in well within the context of the site
in terms of scale and massing with regard to the adjoining buildings within the site and
wider Jeffery’s Road. Officers consider the proposal appropriate and inline with Council
policy.
Design Conclusions
9.11
Overall, conservation and design officers are supportive of the proposed development.
The layout, height and form of the building are acceptable and would not have a
negative impact on nearby heritage assets. As such, the proposal is considered to be
in accordance with London Plan and UDP policies relating to urban design.
Overall the proposal is considered to be of a high quality design and subject to
condition, would have a positive impact on the surrounding townscape, complying with
Council and London Plan policies. (London Plan: policy 7.7 and LBL Policies: [CS] S9
and [UDP] 31, 32, 33, 39, 40, 41, 45 & 47)
10
Traffic and Parking
10.1
Policy 9 of the Adopted Unitary Development Plan states that development will be
assessed for their transport impacts, including cumulative impacts on highway safety,
the environment and road network, and on all transport modes.
10.2
Policy S4 of the Lambeth LDF Core Strategy states that the Council will achieve
transport objectives by requiring development to be appropriate to the level of public
transport accessibility and capacity in the area.
10.3
The site has a PTAL score of 4, which is considered ‘good’. Increased housing density
is encouraged within areas of good public transport accessibility, as are car free
developments. The site is located within CPZ “Stockwell S”, where parking stress is
known to be high. The Transport Statement states that the developer is willing to
designate all the residential units as parking permit free, which would be secured via
S106. There are also several Car Club bays within a 400m walk of the site.
10.4
The applicant has proposed that the development would be car free and transport
offices welcome this proposal, as the site is well serviced by public transport including
the Northern and Victoria line underground stations and numerous bus stops within
walking distance.
10.5
The s.106 would ensure the delivery of a Travel Plan so as to reduce reliance on the
private car and promote more sustainable modes of transport.
10.6
34 cycle parking spaces are proposed within the site, which meets London Plan
standards. Several stores are positioned across the site to serve each of the blocks.
No cycle parking is shown for the 16 x studios in Block D. A small number of cycle
stands should also be provided for the artists studios, this would be secured by
condition.
10.7
A Construction Method Statement and Construction Management Plan would be
secured by condition as requested by the Councils Transport department.
10.8
Subject to the conditions and s.106 obligations, officers are of the opinion that the
development will not impact unacceptably upon either the function or safety of the
surrounding highway network. The development would be inclusive of a range of
mitigation measures that would mitigate as far as is practicable the impacts of the
development upon parking stress in the area. In addition, the development would be
inclusive of cycle parking and a travel plan; each reducing reliance on the private car
and/or promoting more sustainable modes of transport. It is therefore considered that
the development complies with the relevant transport policies of the Development
Plan.
11
Biodiversity and Ecology
11.1
The application submissions include assessments of the ecological impacts of the
application, in the form of a desk based exercise and field investigations, including a
field-based bat assessment. Lambeth officers have assessed the information provided
and consider that these studies are acceptable and provide sufficient detail on existing
habitats and species to inform decisions as to future use, development and
management of the site to protect any ecological value. The assessment concludes
that impacts of the development will be low in that the habitats and species found on
site are not of high ecological status and no legally protected species or sensitive
ecological receptors have been identified on the site. It is therefore reasonable to
conclude that removal of existing habitat from the site would not have a significant
ecological effect, in that this habitat exists in abundance elsewhere near to the site,
can be recreated elsewhere with minimal effort, or that habitat or equal if not better
value can be created as part of the development through appropriate mitigation
measures.
11.2
It is however recommended that a final site survey is carried out by a competent
surveyor to ensure no new habitats or species which have ecological value, or legally
protected from disturbance or destruction have become present on site. If any such
protected habitats/species are found then it may be necessary to take action to avoid
disturbance or loss of protected species/habitats.
11.3
The landscaping proposals for the development would be inclusive of ecological
enhancements as part of any soft landscaping, ensuring that tree and shrub plantings
have a fair proportion of native species or those which have ecological benefit. Final
landscaping plans and schedules for the development would be submitted for approval
by the Council pursuant to the recommended condition.
11.4
The site currently provides no public open space and the surrounding landscaped
areas of the building are of low quality. However, there are opportunities to enhance
local areas of accessible open space, if public space cannot be offered within the
development site. Nearby public open spaces such as Larkhall Park, have
management plans or master plans which identify features and assets that can be
improved or developed to serve a wider community of users. A s106 contribution of
£40,678.70 would be secured specifically for investment in such sites to provide
residents of the development with improved public open space for the site and
surrounding residents.
11.5
Subject to the recommended conditions officers are accepting that the redevelopment
of the site need not prove unacceptably harmful to any bio-diversity features of
acknowledged value and that opportunities could be secured to improve the biodiversity value of the site and of the surrounding open spaces. It follows that the
development need not fail against UDP Policy 39 and Core Strategy Policy S5 in these
regards.
12
Other Matters
12.1
Crime Prevention
12.2
Policy 32 of the Adopted Unitary Development Plan states that development should
enhance community safety and will not be permitted where opportunities for crime are
created or where it results in an increased risk of public disorder.
12.3
The Council’s Crime Prevention Officers comments were incorporated into the design
of the scheme, however to ensure the entrances and access points are fully secure, a
condition is proposed should permission be granted to ensure compliance with the
Secured by Design standards.
12.4
Sustainability and Renewable Energy
12.5
Lambeth Core Strategy Policy S7 requires all major developments to achieve a
reduction in carbon dioxide emissions in line with the London Plan targets through
energy efficient design, decentralised heat, cooling and power systems, and on site
renewable energy generation.
12.6
The London Plan requires developments to make the fullest contribution to tackling
climate change by minimising carbon dioxide emissions, adopting sustainable design
and construction measures and prioritising decentralised energy, including
renewables. Policy 5.2 sets out a minimum target reduction for carbon dioxide
emissions in buildings of 25% over the Target Emission Rates outlined in the national
Building Regulations. The London Plan sets out that development proposals should
contribute to this by minimising carbon dioxide emissions in accordance with the “be
lean, be clean, be green” hierarchy:
•
•
•
Be Lean: The reduction of energy demand and CO² emissions from using less
energy, in particular by adopting sustainable and passive design and
construction measures;
Be Clean: Proposals for the reduction of energy demand and CO² emissions
through supplying energy efficiently;
Be Green: Renewable energy technologies to be incorporated.
12.7
Policy 5.7 of the London Plan seeks to increase the proportion of energy generated
from renewable sources. There is a presumption that all major development proposals
will seek to reduce carbon dioxide emissions by at least 20 per cent through the use of
on-site renewable energy generation wherever feasible.
12.8
Be Lean: Energy efficiency measures will be applied to the development. The
development will exceed the minimum requirements of Part L1A, L2A and L1B for
building envelope and services performance. Measures proposed include improvement
to the building fabric air permeability and the use of heat recovery systems, including
flue gas heat recovery and waste water heat recovery. The proposed new elements of
the development will also reduce the effects of thermal bridging through the use of
Accredited Construction Details and benefit from the use of mechanical ventilation heat
recovery. The proposed energy conservation measures will reduce the regulated
carbon dioxide emissions in comparison to the 2010 Building Regulations compliant
case by 4.75 per cent.
12.9
Be Clean: The opportunity for the proposed development to link into an existing or
planned decentralised energy network has been explored using the London Heat Map
tool. At present there are no existing or proposed energy networks located within a
feasible connection distance of the Jeffrey’s Road development site. In the absence of
an existing energy network within a reasonable distance of the proposed development
site, the report assesses the feasibility of incorporating a CHP communal heating
system within the new build elements of the development. The incorporation of a
communal system has been assessed and is deemed unfeasible given the constraints
of the site and the energy use profile of the operational development.
12.10
Be Green: A feasibility study has been undertaken to establish the most suitable
renewable technology for integration at the proposed development. Photovoltaic
panels are the recommended renewable technology, providing the most cost effective
carbon dioxide emission saving for the proposed development. A 24.8kWp, 180m²
photovoltaic system mounted horizontally on the flat roof areas of Blocks B and C,
combined with the Be Lean: energy conservation measures will provide a 25.84 per
cent reduction in the CO2 emissions over the base case Building Regulations
compliant development thereby meeting the requirements of London Plan Policy 5.2
for a 25% and the minimum energy requirements of Code level 4 of the Code for
Sustainable Homes.
12.11
The combined Be Lean and Be Green measures will also achieve the mandatory
energy efficiency rating of >65 required to achieve a BREEAM Refurbishment Very
Good rating for the conversion of the Grade II listed hospital building to residential
apartments.
12.12
The specified photovoltaic system will provide a reduction in carbon dioxide emissions
of 22.14%, over the lean case development and would therefore allow the
development to meet the renewable energy requirements of London Plan Policy 5.7
Renewable Energy for a 20% reduction in carbon dioxide emissions. This energy
assessment concludes that all viable reductions in total carbon dioxide emissions from
the development have been achieved within the framework of the energy hierarchy to
satisfy the policy requirements of the London Plan and Lambeth’s Core Strategy Policy
S7.
Archaeology
12.13
English Heritage (Archaeology) have been consulted and recommended that no
archaeology requirements are needed in this instance.
Refuse and Recycling Considerations
12.14
Policy S8 of the Core Strategy sets out that the Council will contribute to the
sustainable management of waste in Lambeth. The proposed refuse storage
arrangements/facilities have been calculated in accordance with Lambeth’s document
‘Waste & Recycling Storage and Collection Requirements - Guidance for Architects &
Developers’. The recommended condition would ensure suitable provision and
management in accordance with Core Strategy Policy S8.
S106 Heads of Terms & Mayoral CIL
12.15
The development would deliver the following s.106 obligations:
•
•
•
•
•
•
•
•
•
•
•
•
•
•
Affordable Housing – To be secured
Workspace to be prioritised for the existing artist groups at below market rents,
although with a cascade clause so that if the artists do not take residence then
the space may be used for general B1 uses.
Education Contribution - £58,582.78
Health Contribution - £24,234.00
Libraries Contribution - £4,585.72
Sport & Leisure Contribution - £17,102.69
Parks & Open Spaces Contribution - £40,678.70
Children & Young People Play Space Contribution - £10,649.50
Travel Plan Submission and Monitoring Contribution of £1,000.00
Local Labour in Construction Contribution - £10,500.00
A permit capping agreement to prevent residents being eligible for on-street
residents parking permit
Compliance with existing section 106 sustainability measures and also a
Commitment to achieve Code for Sustainable Homes Level 4.
Local Labour in Construction Commitments: Promotion of opportunities for local
residents.
S106 monitoring and programme costs contribution - £8,899.15
12.16
The above package is considered reasonable to mitigate the otherwise unacceptable
impacts of the development upon local infrastructure. The package has been
negotiated having regard to the expectations set out in policy (Core Strategy Policy
S10 and the Council’s adopted SPD: S106 Obligations), to the details of the scheme
and to the substantial planning/public benefits that the scheme would deliver. Each of
the obligations above has also been negotiated having regard to the statutory tests set
out in the Community Infrastructure Levy Regulations 2010; namely they are
considered: (i) necessary to make the development acceptable in planning terms; (ii)
directly related to the development; and (iii) fairly and reasonably related in scale and
kind to the development.
12.17
It is advised that the scheme will also be liable to a Mayoral CIL payment towards
Crossrail implementation. This will amount to approximately £76,287.67 and is in
addition to the s.106 package set out above.
13
Conclusion
13.1
The re-development of the Listed Annie McCall Hospital site provides the following
planning benefits:
•
•
•
•
•
•
13.2
The provision of 30 new dwellings;
The provision of 9 affordable dwellings, 4 of which would be family sized
dwellings to target Lambeth’s priority housing needs;
The sympathetic refurbishment of a listed building and the securing of a long
term use for that building;
Regeneration benefits for the locality; and
The promotion of Opportunities for local people to work in the construction of
the development; and
The re-provision of workspace for the existing artist groups of the site which are
well regarded by the local community.
These are, without doubt, substantial public benefits.
13.3
The development scheme is subject to a Planning Performance Agreement. In this
instance the applicant has responded positively and openly to all advice given. It must
therefore be borne in mind that the ‘merits’ of the scheme have been largely and
positively influenced by the extensive negotiations and discussions that preceded the
application submission.
13.4
The development would provide a high quality residential environment for all future
occupiers. All of the new dwellings have been designed to meet the Mayor’s London
Housing Design Guide and the Council’s SPD (Housing Development and House
Conversions) in terms of size and layout. In addition, all of the new units would be
designed and constructed to the Lifetime Homes Standards as far as is practicable,
whilst 15 (10%) of the units would be wheelchair accessible in accordance with the
relevant London Plan target. In addition, the development is inclusive of generous onsite amenity and play space provision.
13.5
All necessary reductions in total carbon dioxide emissions from the development would
be achieved within the framework of the Mayor’s energy hierarchy to satisfy the
Development Plan policy requirements. In addition, the development has been
designed in conjunction with advice offered by the council’s Crime Prevention Design
Advisor so as to minimise the opportunity for crime as far as is practicable.
Furthermore, the development would not impact unacceptably upon the amenity of any
neighbouring residential properties or upon the function or safety of the surrounding
highway network.
13.6
The proposal is well considered in design terms and responds sensitively to the
constraints of the site including the surrounding area and listed building at the heart of
the development. It optimises the development potential, in a manner that would not
harm conditions of on-street parking or prejudice conditions of the free flow of traffic
and highway safety.
13.7
The development would also be inclusive of a range of s.106 obligations that would
reasonably mitigate the otherwise unacceptable impacts of the development upon local
infrastructure. The package of s.106 contributions has been negotiated having full
regard to the nature of the development, to the normal expectations conferred upon
developers by the council’s s.106 Supplementary Planning Document (SPD), and to
the statutory tests for s.106 obligations set out in the Community Infrastructure Levy
Regulations 2010.
13.8
In conclusion, the proposal would provide a significant contribution to the regeneration
of the site which has become run down over the years. It would provide significantly for
social housing as well as much needed market accommodation; whilst facilitating the
continued operations of the existing artist groups. The scheme is well thought out and
of a high quality design and will enhance the visual appearance of the area generally.
13.9
This is a sustainable development that would deliver substantial public benefit. The
development would be in general compliance with the Development Plan for the
Borough and there are no material considerations of sufficient weight that would dictate
that the application should nevertheless be refused. Officers are therefore
recommending approval of the scheme in accordance with the presumption in favour of
sustainable development conferred upon Local Planning Authorities by the National
Planning Policy Framework (NPPF).
14
Recommendation
14.1
Grant planning permission subject to the satisfactory completion of a Section 106
Obligation (Heads of Terms set out in this report) and the attached conditions.
15
Summary of the Reasons
15.1
In deciding to grant planning permission, the Council has had regard to the relevant
policies of the Development Plan and all other relevant material considerations. Having
weighed the merits of the proposal in the context of these issues, it is considered that
planning permission should be granted subject to the conditions listed below. In
reaching this decision the following policies listed in this recommendation report were
relevant.
16
Conditions
16.1
The development to which this permission relates must be begun not later than the
expiration of five years beginning from the date of this decision notice.
Reason: To comply with the provisions of Section 91(1)(a) of the Town and Country
Planning Act 1990 (as amended by Section 51 of the Planning and Compulsory
Purchase Act 2004.)
16.2
The development hereby permitted shall be carried out in accordance with the
approved plans listed in this notice.
Reason: For the avoidance of doubt and in the interests of proper planning.
16.3
Prior to the commencement of development (including demolition), full details of the
proposed construction methodology, in the form of a Method of Construction
Statement, shall be submitted to and approved in writing by the Local Planning
Authority. The Method of Construction Statement shall include details regarding: the
notification of neighbours with regard to specific works; advance notification of road
closures; details regarding parking, deliveries, and storage; details regarding dust
mitigation, details of measures to prevent the deposit of mud and debris on the public
highway, and other measures to mitigate the impact of construction on the amenity of
the area. The details of the approved Method of Construction Statement must be
implemented and complied with for the duration of the demolition and construction
process.
Reason: To ensure minimal nuisance or disturbance is caused to the detriment of the
amenities of adjoining occupiers and of the area generally, and avoid hazard and
obstruction to the public highway in compliance with Policies 9 and 31 of the London
Borough of Lambeth UDP: Policies saved beyond 5th August 2010.
16.4
Adequate precautions shall be taken during the construction period to prevent the
deposit of mud and similar debris on the adjacent public highways in accordance with
details to be submitted to and approved in writing by the Local Planning Authority prior
to the commencement of development.
Reason: To minimise danger and inconvenience to highway users (Policies 9 and 31
of the London Borough of Lambeth UDP: Policies saved beyond 5th August 2010)
16.5
Prior to the commencement of buildings works, details of the new blocks C and D as
shown on plan 1120-05 rev.E which should include: samples and a schedule of
materials to be used in the elevations including all walls, doors, roofs (including green
roofs on block D), windows front entrances and balconies within the development
hereby permitted shall be submitted to and approved in writing by the Local Planning
Authority before any building work commences and this condition shall apply
notwithstanding any indications as to these matters which have been given in the
application. The development shall thereafter be carried out solely in accordance with
the approved details.
Reason: To safeguard and enhance the visual amenities of the locality. (Policies 31,
33, 36, 39 and 45 of the London Borough of Lambeth UDP: Policies saved beyond 5th
August 2010)
16.6
Prior to the commencement of buildings works for the whole site, detailed drawings to
a scale of 1:20 to confirm the detailed design and materials of the:
a) Schedule and sample of materials used in all elevations;
b) Details of balconies, railings, canopies and screens;
c) Construction details of all external elements at 1:20 scale (including sections). This
should include: entrances and exits, glazing, masonry, cladding weathering and
flashings, balustrades and parapets, roof, plant and plant screening, health and safety
systems and communal garden enclosures;
d) Fenestration at 1:20, 1:5 and 1:1 where appropriate;
e) New(extended) chimneys at 1:20, to exactly match the existing in terms of materials
and detailing;
f) Boundary treatments at 1:20, including new ball finial and replacement gates;
g) Details and locations of rain water pipes;
Shall be submitted to and approved in writing by the Local Planning Authority prior to
the commencement of the development herby permitted. The development shall
thereafter be carried out solely in accordance with the approved details.
Reason: To safeguard and enhance the visual amenities of the locality. (Policies 31,
33, 36, 39 and 45 of the London Borough of Lambeth UDP: Policies saved beyond 5th
August 2010)
16.7
Prior to the commencement of buildings works, full details of the proposed internal
repair and reinstatement works including works to terrazzo and parquet flooring and
areas of fallen plaster and balustrade to follow that set out in Appendix E of the
submitted heritage statement ref: 037-SHG-st-2012-09-09-28; shall be submitted to
and approved in writing by the Local Planning Authority prior to the commencement of
the development herby permitted. The development shall thereafter be carried out
solely in accordance with the approved details.
Reason: To safeguard and enhance the listed heritage asset. (Policies 45 of the
London Borough of Lambeth UDP: Policies saved beyond 5th August 2010)
16.8
Prior to the commencement of buildings works, full details of the proposed landscaping
scheme including materials and planting to be used in the hard and soft landscaped
areas of all internal and external amenity spaces (including winter gardens) and on the
public highway, shall be submitted to and approved in writing by the Local Planning
Authority. Development shall be implemented and retained in accordance with the
approved details. Landscaped areas shall be permanently retained for the enjoyment
of occupiers of the scheme.
Reason: To ensure that the proposed landscaping areas are of a high quality and for
consistent treatment of the public realm. (Policies 33 and 39 of the London Borough of
Lambeth UDP: Policies saved beyond 5th August 2010.)
16.9
All planting, seeding and additional turfing comprised in the approved details of
landscaping shall be carried out in the first planting and seeding season following the
occupation of the development hereby permitted or the substantial completion of the
development, whichever is the sooner. Any trees, hedgerows or shrubs forming part of
the approved landscaping scheme which within a period of five years from the
occupation or substantial completion of the development die, are removed or become
seriously damaged or diseased shall be replaced in the next planting season with
others of similar size and species, unless the Local Planning Authority gives written
consent to any variation.
Reason: To ensure a satisfactory and continuing standard of amenities are provided
and maintained in connection with the development. (Policy 39 of the London Borough
of Lambeth UDP: Policies saved beyond 5th August 2010.
16.10
Prior to occupation, a crime prevention strategy shall be submitted to and approved in
writing by the Local Planning Authority in consultation with the Police. The strategy
shall demonstrate how the development meets 'Secured by Design' standards and
shall include full detailed specifications of the following: Means of enclosure, external
lighting provision, electronic access control, specifications of all external doors,
windows, glazing and cycle storage. The approved measures are to be carried out in
full and retained thereafter.
Reason: To ensure that satisfactory attention is given to security and community safety
(Policy 32 of the London Borough of Lambeth UDP: Policies saved beyond 5th August
2010.
16.11
Prior to occupation, full details of a lighting strategy, including details of the lighting of
all public and private areas, shall be submitted to and approved in writing by the Local
Planning Authority. The approved lighting shall be installed before the commencement
of the use and maintained thereafter. Development shall be implemented and retained
in accordance with the approved details.
Reason: To ensure that the local Planning Authority may be satisfied with the details of
the proposal. (Policy 32 and 33 of the London Borough of Lambeth UDP: Policies
saved beyond 5th August 2010)
16.12
The development hereby permitted shall be carried out in full accordance with
measures indicated in the Create Consulting Engineers Ltd Energy Assessment ref:
PS/RH/P12-414/01 rev.B and Sustainability Statement ref: LS/RH/P12-414/02 rev.B,
accompanying the application, unless otherwise agreed in writing by the Local
Planning Authority.
Reason: In the interests of securing a sustainable development (Policy 35 of the
Saved Unitary Development Plan (2010) and Core Strategy policy S7 refer and the
adopted Supplementary Planning Document for Sustainable Design and Construction
2007)
16.13
The development hereby approved shall achieve a Code for Sustainable Homes
minimum of Level 4 in accordance with the requirements of the relevant BREEAM
scheme (Code for Sustainable Homes) or subsequent superseding equivalent
BREEAM scheme and BREEAM ‘Very Good’ for all other buildings as set out in
Sustainability Statement ref: LS/RH/P12-414/02 rev.B, accompanying the application.
No development shall take place until a relevant BREEAM Certificate demonstrating
the proposal’s achievement has been submitted to and approved by the Council.
Within 4 months of the first occupation of any part of the development hereby
approved, an issued Final BREEAM Certificate stating the BREEAM award achieved
shall be submitted to and approved by the Local Planning Authority.
Reason: In the interests of securing a more sustainable development (Policy 35 of the
Unitary Development Plan: Policies saved beyond 5th August 2010 and not
superseded by the Local Development Framework Core Strategy January 2011,
Policies S1 and S7 of the Local Development Framework Core Strategy (January
2011) and the Council’s associated Supplementary Planning Document: ‘Sustainable
Design and Construction’ (2008)).
16.14
There shall be no amplified sound, speech or music system fixed, used, or audible
outside any of the studio premises, unless otherwise agreed in writing by the Local
Planning Authority.
Reason: To ensure that no nuisance or disturbance is caused to the detriment of the
amenities of neighbouring occupiers. (Policy 7 of the London Borough of Lambeth
UDP: Policies saved beyond 5th August 2010.)
16.15
Prior to the commencement of buildings works above grade, full details of the
soundproofing of premises and insulation of premises (including ventilation) for all
party walls and the ceiling/floors, shall be submitted to and approved in writing by the
Local Planning Authority, and thereafter be retained for the duration of the use, to
prevent fumes, smell and noise permeating into adjoining accommodation.
Reason: To ensure that no nuisance or disturbance is caused to the detriment of the
amenities of neighbouring occupiers. (Policy 7 of the London Borough of Lambeth
UDP: Policies saved beyond 5th August 2010.)
16.16
Noise from any mechanical equipment or building services plant shall not exceed the
background noise level when measured outside the window of the nearest noise
sensitive or residential premises, when measured as a L90 dB(A) 1 hour.
Reason: To ensure that no nuisance or disturbance is caused to the detriment of the
amenities of neighbouring occupiers. (Policy 7 of the London Borough of Lambeth
UDP: Policies saved beyond 5th August 2010.)
16.17
No pipes or vents (including gas mains and boiler flues) shall be constructed on the
external elevations unless they have first been submitted to the Local Planning
Authority and approved in writing. Any pipes and vents shall be installed as approved.
Reason: Such works would detract from the appearance of the building and would be
detrimental to the visual amenities of the locality (saved policies 33, 38 and 47 of the
Saved Unitary Development Plan (2010) and Core Strategy Policy S9 (2011).
16.18
Notwithstanding the approved plans, no part of the development hereby approved
shall be occupied or used until full details of the proposed cycle storage, including
details of manufacturer’s specifications, has been submitted to and approved in writing
by the Local Planning Authority. The details as are approved shall be provided prior to
first occupation of the development and shall thereafter be retained as such for the
duration of the permitted use.
Reason: To ensure that adequate provision is made for the cycle parking on the site,
in the interests of the promotion of sustainable modes of transport (Policy 14 of the
Adopted Lambeth Unitary Development Plan (2007): Policies saved beyond 5th August
2010 refer).
16.19
Notwithstanding the approved plans, no part of the development hereby approved
shall be occupied or used until full details of the refuse and recycling storage, hereby
permitted shall be submitted to and approved in writing by the Local Planning Authority
before any building work commences and this condition shall apply notwithstanding
any indications as to these matters which have been given in the application. The
development shall thereafter be carried out solely in accordance with the approved
details.
Reason: To ensure that adequate provision is made for the storage of refuse and the
provision of recycling facilities on the site, in the interests of the amenities of the area
in accordance with Policy 35 of the London Borough of Lambeth UDP: Policies saved
beyond 5th August 2010.
16.20
A Travel Plan shall be submitted to and approved in writing by the Local Planning
Authority prior to the use hereby permitted commencing. The measures approved in
the Travel Plan shall be implemented prior to the residential use hereby permitted
commencing and shall be so maintained for the duration of the use, unless the prior
written approval of the Local Planning Authority is obtained to any variation.
Reason: To ensure that the travel arrangements to the residential development are
appropriate and to limit the effects of the increase in travel movements. (Policy 9 of the
London Borough of Lambeth UDP: Policies saved beyond 5th August 2010)
16.21
All residential flats hereby permitted shall comply with the relevant Lifetime Homes
standard.
Reason: To secure appropriate access for disabled people, in accordance with Policy
33 of the London Borough of Lambeth UDP: Policies saved beyond 5th August 2010.
16.22
No development shall take place until an up to date assessment for protected habitats
and species has been submitted and approved in writing by the Local Planning
Authority.
Reason: To ensure suitable protection to local ecology (Saved UDP Policy 39 and
Core Strategy Policy S9).
16.23
No development shall take place other than in full conjunction with the measures of
tree protection set out in the Arboricultural Method Statement hereby approved.
Reason: To ensure the suitable protection of the existing trees on site in the long
term interests of local amenity (Saved UDP Policy 39 and Core Strategy Policy S9).
17
Informatives
17.1
This decision letter does not convey an approval or consent which may be required
under any enactment, by-law, order or regulation, other than Section 57 of the Town
and Country Planning Act 1990.
17.2
You are advised that this consent is without prejudice to any rights which may be
enjoyed by any tenants/occupiers of the premises.
17.3
Your attention is drawn to the provisions of the Building Regulations, and related
legislation which must be complied with to the satisfaction of the Council's Building
Control Officer.
17.4
You are advised to consult the Council's Environmental Health Division concerning
compliance with any requirements under the Housing, Food, Safety and Public Health
and Environmental Protection Acts and any by-laws or regulations made there under.
17.5
You are advised to consult the Council's Environmental Health Division with regard to
the extraction of fumes from the premises.
17.6
Your attention is drawn to Sections 4 and 7 of the Chronically Sick and Disabled
Persons Act 1970 and the Code of Practice for Access for the Disabled to Buildings
(B.S. 5810:1979) regarding the provision of means of access, parking facilities and
sanitary conveniences for the needs of persons visiting, using or employed at the
building or premises who are disabled.
17.7
You are advised of the necessity to consult the Transport and Highways team within
the Transport Division of the Directorate of Environmental Services, with regard to any
alterations affecting the public footway.
17.8
You are advised of the necessity to consult the Council's Streetcare team within the
Public Protection Division with regard to the provision of refuse storage and collection
facilities.
17.9
You are advised that this permission does not authorise the display of advertisements
at the premises and separate consent may be required from the Local Planning
Authority under the Town and Country Planning (Control of Advertisements)
Regulations 1992.
17.10
In connection with the soundproofing condition, you should consult the Council's
Building Control Section before carrying out any works.
17.11
As soon as building work starts on the development, you must contact the Street
Naming and Numbering Officer if you need to do the following:
- name a new street
- name a new or existing building
- apply new street numbers to a new or existing building
This will ensure that any changes are agreed with Lambeth Council before use, in
accordance with the London Buildings Acts (Amendment) Act 1939 and the Local
Government Act 1985. Although it is not essential, we also advise you to contact the
Street Naming and Numbering Officer before applying new names or numbers to
internal flats or units. Contact details are listed below.
Street Naming and Numbering Officer
e-mail: [email protected]
tel: 020 7926 2283
fax: 020 7926 9104
17.12
You are advised to contact Thames Water Utilities regarding mains/supply pipe
connections for the development at Network Services Waterloo District, Thames Water
Utilities Ltd, Waterworks Road, Brixton Hill, London SW2 1SB. Contact Mr D Kirk on
0645 200800 for details
17.13
It is the view of Lambeth Council that the proposed development has scope for the
provision of recycling and/or composting facilities. For advice on incorporation of such
facilities please contact:
Jason Searles/ Dean Parry
3rd Floor,
Blue Star House
234-244 Stockwell Rd
London SW9 9SP
020 7926 2624
[email protected]
17.14
You are advised of the necessity to consult the Council’s Highways team prior to the
commencement of construction on 020 7926 9000 in order to obtain necessary
approvals and licences prior to undertaking any works within the Public Highway
including Scaffolding, Temporary/Permanent Crossovers, Oversailing/Undersailing of
the Highway, Drainage/Sewer Connections, Hoarding, Excavations (including adjacent
to the highway such as basements, etc), Temporary Full/Part Road Closures,
Craneage Licences etc.
17.15
It is current Council policy for the Council's contractor to construct new vehicular
accesses and to reinstate the footway across redundant accesses. The developer is
to contact the Council's Highways team on 020 7926 9000, prior to the
commencement of construction, to arrange for any such work to be done. If the
developer wishes to undertake this work the Council will require a deposit and the
developer will need to cover all the Council's costs (including supervision of the works).
If the works are of a significant nature, a Section 278 Agreement (Highways Act 1980)
will be required and the works must be carried out to the Council's specification.
17.16
The Environment Agency strongly recommends that the applicant consults our
Pollution Prevention Guidance notes (PPGs). These are aimed at a wide range of
industries and activities that have the potential to cause pollution. They can be
downloaded from our website www.environment-agency.gov.uk .
17.17
Landscaping schedules should endeavour to include, within reason, measures to
promote biodiversity including use of native species typical of locality and ground
conditions or naturalised areas. The applicant should act on good practice to maximise
the site’s landscape, visual and horticultural quality, ease of maintenance and to
provide long-term environmental benefit. The applicant should also endeavour to
include, within reason, measures to encourage protected species to occupy the
application site, such as installation of bat and bird boxes on trees and buildings, bat
bricks within remodelled buildings, creation of stag beetle loggeries or wood piles, and
the creation of naturalised areas within communal areas.