Site address Mudie House, Miller House, Lucraft House, Lafone House, Freeman House, Angus House, Cotton House, Crossman House, Currie House And Lycett House, London, SW2

Ward Thornton

Proposal Refurbishment of existing residential buildings of 363 dwellings (Mudie House, Miller House, Lucraft House, Lycett House, Lafone House, Freeman House, Angus House, Cotton House, Crossman House and Currie House). Proposals include new replacement windows and doors, new balconies, 16 new lift towers, new landscaping, new refuse and new parking.

Application type

Full Planning Permission

Application ref(s) 14/01056/FUL

Validation date 12.02.2014

Case officer details Name: Ross Whear Tel: 020 7926 1137 Email: rwhear@lambeth.gov.uk

Applicant Ms Tracy Harrison-Smith, Durkan Limited

Agent Mr Jonathan Rees, HTA Design LLP

Considerations/constraints Major Development Opportunity TPO (ref: 456(2007)) Smoke Control Area

Approved plans Design and Access Statement Rev. A (HTA) dated 12 February 2014, Planning Statement (Wildstone Planning), Arboricultural Survey Report – Section C (Waterman) dated February 2014, Arboricultural Survey Report – Section E (Waterman) dated February 2014, Transport Statement – Section C (Royal Haskoning DHV) dated February 2014, Transport Statement – Section E (Royal Haskoning DHV) dated February 2014, Daylight and Sunlight Report – Section C (Malcolm Hollis) dated 11 February 2014, DPR600AL(0)001, DUR500AL(0)502, DUR600AL(0)602, DUR600AL(0)1001B, 1002A, 1003A, 1004A, 1005A, DUR500AL9400A, DUR600AL9401A, Mudie House – DUR500AL(0)010, 011, 013, 014, 015, 020B, 021D, 023C, 024B, 025C, 026B, Miller House - DUR500AI(0)110, 111, 112, 113, 114, 120C, 121D, 122C, 123C, 124D, Lycett House - DUR500AL(0)210, 211, 212, 213, 214, 216, 217, 220C, 221C, 22C, 223C, 224B, 225B, 226D, 227D, 228D, Lucraft House - DUR500AI(0)310, 311, 312, 313, 314, 320B, 321B, 322B, 323B, 324B, Lafone House - DUR500AL(0)410, 411, 412, 413, 414, 415,

416, 417, 420C, 421D, 422C, 423C, 424B, 425B, 426D, 427C, 428C, Freeman House - DUR500AL(0)510, 511, 512, 513, 514, 520C, 521C, 522C, 523C, 524D, Angus House – DUR600AL(0)610, 611, 612, 613, 614, 615, 616, 617, 618, 620C, 621B, 622B, 623C, 624B, 625B, 626D, 627C, 628D, 629B, 630B, Cotton House – DUR600AL(0)710, 711, 712, 713, 714, 715, 716, 717, 718, 720C, 721D, 722D, 723E, 724C, 725C, 726D, 727D, 728C, 730B, Crossman House - DUR600AL(0)810, 811, 812, 813, 814, 815, 816, 817, 818, 820B, 821B, 822B, 823B, 824B, 825B, 826C, 827C, 828C, Currie House - DUR600AL(0)910, 911, 912, 913, 914, 920B, 921B, 922B, 923B, 924C,

Recommendation(s) Grant conditional planning permission

Consultation

Department(s) or Organisation(s) Consulted? (y/n)

Date response received

Comments summarised in report? (y/n)

Internal

Arboricultural Officer Y

Building Control Y

Conservation and Design Y 23/04/14 See Section 5

Design Out Crime Officer Y 20/03/14 & 07/04/14

See Section 5

Housing Y

Parks and Open Spaces Y 22/03/14 See Section 5

Streetcare Y

Transport/Highways Y 19/03/14 & 04/04/14

See Section 5

External

Clapham Park Residents and Tenants Association

Y

Clapham Park West Tenants and Residents Association

Y

Climate Consulting Y 18/03/14 See Section 5

Environment Agency Y 25/03/14 & 11/04/14

See Section 5

LFCD Authority Y

Streatham Society Y

Telford Park Residents Tenants Association

Y

Telferscot Radbourne Community Group Y

TFL Road Network Development Y 24/03/14, 03/04/14

See Section 5

Households Y 20/03/14, 24/03/14, 25/03/14, 30/03/14, 31/03/14 & 09/04/14

See Section 5

Background documents Case File (this can be accessed via the Planning Advice Desk, Telephone 020 7926 1180)

1 Summary of Main Issues

1.1 The main issues involved in the assessment of this application are as follows: § The design and appearance of the proposed external alterations (windows,

doors, balconies and lift towers); § Improvements to the hard and soft landscaping (boundary treatments, trees and

play space); § Retention of adequate car parking and provision of cycle parking; § Whether adequate refuse/recycling storage facilities are provided; and § How the proposals link into the wider Clapham Park regeneration scheme

approved under application reference 06/03680/OUT.

2 Site Description

2.1 The proposal sites are located to the south eastern part of the Clapham Park masterplan area, split either side of Atkins Road. Section C, to the north of Atkins Road comprises of Mudie House, Miller House, Lucraft House, Lycett House, Lafone House and Freeman House containing a total of 164 residential units. Section E, to the south of Atkins Road comprises of Angus House, Cotton House, Currie House and Crossman House with a total of 199 units. In total the blocks contain 363 residential units, split between private leaseholders and tenants of Metropolitan Clapham Park.

2.2 Figure 1 overleaf, shows the proposal sites. The Clapham Park Masterplan boundary is also indicated by the dashed line.

2.3

The existing blocks are 1930s built London County Council (LCC) residential flats constructed in the common neo-Georgian, red brick style. Both sets of blocks comprise of four storey perimeter blocks set within an ‘M’ shape with a central, external facing landscaped courtyard and two larger internal facing courtyards with parking, play space and refuse provision. The sites sit within a predominantly residential area made up of a mix of housing and flatted developments, although to the east of the site, Brixton Hill/New Park Road Local Centre runs northwards along New Park Road from the junction of Atkins Road.

2.4 Section C is bounded to the north by a three storey Telephone Exchange and a maintenance yard area, with two storey terraced houses fronting onto Kingswood Road beyond. To the east the site fronts onto New Park Road, with a number of commercial uses and residential units above. To the west, on the opposite side of Forster Road are similar LCC blocks, MacArthur House, Pearce House and Tilson Gardens. In between these blocks is Thorold House, which has planning permission (subject to S106 Agreement) for its demolition and the erection of a new five storey residential block for 21 residential units) (ref. 13/05029/FUL). To the south, on the opposite side of Atkins Road lies the blocks forming Section E.

2.5 Section E is bounded to the east by New Park Road, beyond which are the completed residential blocks known as Precinct M2 and M3, rising up to seven storeys in height. The site also surrounds the Locally Listed New Park Road Baptist Church, which fronts onto New Park Road. To the south lies the four storey Cameford Court, two storey residential houses and associated garages. To the west the site is bounded by further residential blocks rising up to three storeys, running perpendicular to the proposal site.

2.6 In terms of access, Section C has two vehicular access points, one from Forster Road and the other from New Park Road. Pedestrian access points are also located on these streets, with additional pedestrian access from Atkins Road. Section E has a single vehicular access point from New Park Road to the east, with three pedestrian access points from Atkins Road in the north. There is no access to the site from the south or

west. The site has a PTAL of 6a indicating a high level of access to public transport; buses in particular provide the main provision in this area, with Brixton, Clapham South and Streatham Hill rail stations within walking distance.

2.7 The site is not within a conservation area and there are no statutory listed buildings in the immediate vicinity. The trees on the site form part of an estate-wide TPO (ref: 456(2007)).

Figure 1

3 Planning History 3.1 Although this is a separate full planning application, the proposal site forms part of the

wider Clapham Park masterplan for which outline planning permission (ref: 06/03680/OUT) was granted on 11 September 2008. The outline scheme comprises of:

A residential-led mixed use regeneration of approximately 36 hectares of land comprising the demolition of buildings (including up to 1,037 residential units (Class C3)), the refurbishment of retained housing stock (including up to 960 residential units (Class C3)) and the construction of new residential buildings (including up to 2,422 residential units (Class C3), an elderly extra care facility (including up to 51 units comprising up to 5,488m2 (Class C2 and a community hub (sui generis uses)) and ancillary community and commercial buildings for the following purposes: uses falling within Classes A1, A2, A3, A4 & A5 (including retail, financial and professional services, cafés and a public house) (up to 2,289 m2), B1 (Workspaces and Offices) (up to 2,500m2) and D1/D2 (Community facilities including a library, crèches, nurseries, a new primary school, a community hall, gym, youth centre, health centre, elderly support facility and a sports hall) (up to 8,039 m2); sui generis uses (including a maintenance yard); car, motorcycle and bicycle parking; general servicing for the new facilities; the provision of a Local Park, pocket parks and other areas of public open space, play facilities, hard and soft landscaping and public realm improvements; a bus pick-up and set-down area and bus driver facility; energy networks and centres and renewable energy technologies; and specified accesses and highways improvements (including the remodelling of the gyratory junction on the A205 South Circular road, new accesses on to the local road network and new estate roads).

3.2 The original masterplan identified blocks C and E for partial demolition and significant

new build development (nine new blocks with associated play space and new estate roads) resulting in a net increase of 42 residential units. Figure 2 below shows the indicative layout as approved under the outline planning permission.

Figure 2: Sections C and E as envisaged under the outline permission.

3.3 Following a review of the scheme it was considered that the demolition of the existing

blocks and provision of new build development was no longer viable or implementable. The existing blocks are considered to be structurally sound and in generally good condition and would therefore benefit from refurbishment, bringing the units up to Decent Homes Standard. As a result, the proposals now seek to undertake a refurbishment of the existing blocks and improvements to the existing parking and landscaping. This amended scheme falls outside the parameters of the outline consent and is therefore subject to a new full planning application.

3.4 There is no recent planning history in respect of the blocks themselves. Although the

play area to the east of Lucraft House is subject to the following application:

§ 03/00358/FUL - Refurbishment works to existing children’s play area and associated landscaping. Approved 23/06/2003

3.5 The applicant has entered into a PPA, and has been working with officers to deliver the

project and reach an acceptable development outcome. The applicant has also provided information showing public consultation with existing residents prior to the application being submitted. The applicant has responded positively to all requests for information, and the detailed pre application discussions and negotiations have lead to the application which is recommended for approval here.

4 Proposal 4.1 The proposals involve a number of external improvements and alterations to the

existing blocks. All of the units within the blocks will have new replacement windows and doors installed. General repairs are also proposed to the walkway deck access, existing roofing and dormer windows where required. The remaining alterations are specific to each block and set out below:

Section C

Mudie House – The two existing entrance cores will be upgraded with a new secure entry system, new lighting around the core, new signage and improvements to the existing canopy or the installation of a new canopy where not already in place. A new brick lift tower attached to one of the existing cores is proposed to serve 17 of the 29 dwellings with level access from the external communal areas to entry foyer along with secure access, new lighting, projecting canopy and signage. Up to 16 new black steel balconies will be added on the Forster Road elevation to provide private amenity space for each residential unit. Miller House – The two existing entrance cores will be upgraded as per Mudie House, above. No new lift towers are proposed. Up to 16 new black steel balconies will be added on the Forster Road elevation to provide private amenity space for each residential unit.

Lycett House – All three of the existing cores will be upgraded as per Mudie House. A new brick lift tower attached to one of the cores is proposed to serve 17 of the 38 dwellings with level access from the external communal areas to entry foyer along with secure access, new lighting, projecting canopy and signage. Up to 27 new black steel balconies will be added to the blocks external facing facades onto Forster Road (6), Atkins Road (7) and those facing Lafone House (14) to provide private amenity space for each residential unit.

Lafone House – This block mirrors exactly the proposals for Lycett House.

Lucraft House - The existing entrance core will be upgraded as per Mudie House, above. No new lift towers are proposed. Up to 11 new black steel balconies will be added on the southern elevation to provide private amenity space for each residential unit. Freeman House - The two existing entrance cores will be upgraded as per Miller House, above. No new lift towers are proposed. Up to 14 new black steel balconies will be added on the New Park Road elevation to provide private amenity space for each residential unit.

Section E

Angus House – All six of the existing entrance cores will be upgraded with a new secure entry system, new lighting around the core, new signage and improvements to the existing canopy or the installation of a new canopy where not already in place. New brick lift towers will be attached to two of the existing cores in order to serve 34 of the 66 dwellings with level access from the external communal areas to entry foyer along with secure access, new lighting, projecting canopy and signage. Up to 52 new black steel balconies will be added on the three main external facing elevations to provide private amenity space for each residential unit.

Cotton House – All six of the existing entrance cores will be upgraded with a new secure entry system, new lighting around the core, new signage and improvements to the existing canopy or the installation of a new canopy where not already in place. A new brick lift tower will be attached to one of the existing cores in order to serve 17 of the 67 dwellings with level access from the external communal areas to entry foyer along with secure access, new lighting, projecting canopy and signage. Up to 51 new black steel balconies will be added on the three main external facing elevations to provide private amenity space for each residential unit.

Crossman House – Crossman House is made up of three blocks, each with a single entrance core. All of the entrance cores will be upgraded as per the other blocks, but no lift towers installed. In terms of balcony provision, 35 new black steel balconies are provided.

Currie House - The two existing entrance cores will be upgraded as per the other blocks, but no lift towers installed. Up to 16 new black steel balconies will be added on the western facade to provide private amenity space for each residential unit.

4.2 The proposals include improvements to and additional hard and soft landscaping in the

form of new boundary treatments to create defensible space for ground floor units; new hedge and shrub planting to reinforce the blocks main external frontages; securing the internal soft landscaped area between the blocks for resident access only; reconfiguration of the existing car park layout but retaining all existing car parking provision with one additional space in Section E and six additional spaces in Section C to reflect the potential future development of the adjoining maintenance yard (known as the Mears Site); new cycle parking in the form of Sheffield stands provided across both sites; retain and enhance the existing pedestrian entrances with new lighting, and a site-wide wayfinding and signage strategy implemented. The proposals also include improvements to the existing play areas in both Sections C and E in accordance with the S106 Agreement (as varied) for the wider Clapham Park Estate.

4.3 In terms of refuse and recycling, the proposals include the removal of 18 existing refuse stores in Section C and 17 in Section E with new consolidated refuse enclosures away from the blocks. Section C will provide seven enclosures with capacity for 33, 1280L bins. Section E will provide eight enclosures for 42, 1280L bins.

4.4 Although not subject to planning permission, the tenanted properties within the blocks

are also to be refurbished internally, including kitchen and bathroom upgrades, electrical and heating system upgrades and internal dry lining to improve thermal performance of the building fabric. All works are to be undertaken with the existing residents in situ.

5 Consultations and Responses

5.1 A total of 782 site residents and neighbouring addresses were consulted on 5th March

2014. Following a number of minor alterations to the external balcony positions, the residents of Miller House and Mudie House were consulted for a further 14 days on 24th April 2014.

5.2 A site notice was displayed on 13th March 2014 and a press notice was published on 21st March 2014.

5.3

Internal consultation The following internal consultee responses have been received and summarised below: Conservation and Design – No objection. Some reservation regarding positioning of a small number of balconies, but recognises the wider benefits of providing each unit with private amenity space. Would not recommend the use of timber sleepers for planting or timber materials for the refuse stores. Reference should be made to the Council’s Refuse and Recycling Guidance. The following conditions are recommended:

1. Brick used in elevations must match existing brick; 2. Notwithstanding approved drawings a section, cross section and elevation of

windows of each window type should be submitted; 3. Details of new signage should be submitted; 4. Notwithstanding approved drawings details of soft and hard landscaping should

be submitted; 5. Details of refuse storage; 6. Details of new boundary treatment other than proposed railings to defensible

space as shown in drawing DUR 600 AL (0) 1004 Rev A; 7. Rain water pipes; 8. Details of external lighting (fixtures and location).

Transport – No objection, subject to conditions requiring details of final car parking layout, adequate cycle parking provision (in accordance with London Plan standards) to be provided and to ensure that turning areas are kept clear of obstruction at all times and retained for the life of the development. Parks and Open Spaces – No objection, subject to appropriate soft landscaping condition. Designing Out Crime Officer – No objection. Subject to the proposals meeting Secured by Design Principles and that the external lighting scheme conforms to BS5849:2013 and a lux plan (prepared by an ILP registered lighting designer) is secured by condition for approval and to be maintained thereafter.

External consultation The following external consultee responses have been received and summarised below: Environment Agency – No objection. Transport for London (TfL) – No objection, subject to conditions relating to electric vehicle charging point provision, Construction Logistics Plan, Delivery and Servicing Plan, Residential Travel Plan and adequate provision of cycle parking. Climate Consulting – Further detail on the proposals including proposed u-values of replacement windows, doors, and upgraded external walls (including proposed thickness of insulation) as well as further detail on the proposed heating and electrical installation upgrades (i.e. what is the existing situation, and what specific upgrades are proposed. Proposals should be considered in accordance with the Mayor’s energy efficiency hierarchy. A BREEAM for Domestic Refurbishments Pre-Assessment is also recommended. Details to be secured by condition.

5.4 Seven letters of objection for four separate addresses have been received following the consultation process. Officers and the applicant have actively engaged with residents’ to try and resolve their concerns. No letters of support have been received. The objections and the Council’s response are summarised below.

Objection: Council’s Response:

(Lafone House) Concern at the proposed location of new gate to restrict access to open space between Lafone House and Lycett House. Request that the gate does not make noise when closed and will not result in people congregating in this area. Repairs to existing pathway and broken drain cover also requested.

This is an existing footpath onto the open space from Atkins Road with the only proposed change being the new railings and garden gate. The gate forms part of a new physical boundary to the open space, which is intended to give residents a sense of ownership and privacy over this space. This will be supported by additional buffer planting in front of residents’ windows. The applicant confirms that the gate will be lightweight and will create minimal noise when closing. Applicant also confirms that elements of the pavement which are damaged or present trip hazards will be repaired.

(Miller House) Objects to no lifts being installed in Miller House and the intention to block the existing bin chutes when the new refuse storage areas are provided.

The proposed works were subject to an extensive viability exercise and it was concluded that only a certain number of new lifts could be provided within the refurbishment programme. The applicant confirms that the locations of the proposed lifts were discussed during the resident consultation events and were selected based on the space available, minimising the impact on surrounding residential dwellings and the ability to serve the maximum number of units. The applicant states that removal of access to the refuse chutes is due to on-going management and

maintenance issues. The locations of the new refuse storage areas have been carefully identified within the proposals to ensure that travel distances for residents are kept to a minimum, in accordance with policy.

(Mudie House (x2)) Object to positioning of balconies onto bedrooms rather than living rooms. Insufficient consultation undertaken by Metropolitan Clapham Park with residents prior to the application being submitted.

The applicant has provided amended plans for Mudie House showing the repositioning of balconies to living rooms rather than bedrooms where possible. The residents of Mudie House and Miller House have been consulted on the amended plans for a period of 14 days as of 24th April 2014. The comments relating to Metropolitan Clapham Park’s consultation is not a planning consideration.

6 Planning Policy Considerations

6.1 National Guidance

The National Planning Policy Framework (NPPF) was published on 27 March 2012.

NPPF sets out Government planning policies for England and how these are expected to be applied in favour of sustainable development. The NPPF replaces Planning Policy Guidance and Planning Policy Statements and is a material consideration in decisions on planning applications. The most relevant sections in respect of this application are as follows:

§ Chapter 4: Promoting sustainable transport § Chapter 6: Delivering a wide choice of high quality homes § Chapter 7: Requiring good design § Chapter 8: Promoting healthy communities § Chapter 10: Meeting the challenge of climate change, flooding and coastal

change § Chapter 11: Conserving and enhancing the natural environment § Chapter 12: Conserving and enhancing the historic environment

6.2 The London Plan 2011

The London Plan was published in July 2011. It sets out the overall strategic plan for

London and 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 Lambeth.

The London Plan policies considered relevant in this case are:

§ Policy 2.9 – Inner London § Policy 2.14 – Areas for Regeneration § Policy 3.5 – Quality and Design of Housing Developments § Policy 3.6 – Children and Young People’s Play and Informal Recreation

Facilities § Policy 3.14 – Existing Housing § Policy 5.2 – Minimising Carbon Dioxide Emissions § Policy 5.3 – Sustainable Design and Construction § Policy 5.4 - Retrofitting

§ Policy 5.17 – Waste Capacity § 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 7.21 – Trees and Woodlands

6.4 6.5

Other Regional Guidance The following regional guidance is relevant to the application proposal:

§ GLA – Housing SPG – November 2012 § GLA – Draft Sustainable Design and Construction SPG – July 2013

Core Strategy (2011)

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 S4 – Transport § Policy S5 – Open Space § Policy S7 – Sustainable Design and Construction § Policy S9 – Quality of the Built Environment § Policy S10 – Planning Obligations

6.6 London Borough of Lambeth Unitary Development Plan (2007): ‘Policies saved beyond

5 August 2010 and not superseded by the LDF Core Strategy January 2011’

The following policies are considered to be of relevance to the assessment of this application:

§ Policy 9 – Transport Impact § Policy 14 – Parking and Traffic Restraint § 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 38 – Design in Existing Residential/Mixed Use Areas § Policy 39 – Streetscape, Landscape and Public Realm Design § Policy 50 – Open Space and Sports Facilities § Policy 66 – Clapham Park

6.7 Local Guidance

The following Lambeth Supplementary Planning Documents are also relevant to the proposals:

§ Guidance and Standards for Housing Development and House Conversions

SPD - July 2008

§ Safer Built Environments SPD - April 2008 § Sustainable Design and Construction SPD - July 2008 § S106 Planning Obligations SPD - updated July 2010

7 Principle of Development 7.1 The principle of refurbishing the existing blocks in Sections C and E of the Clapham Park

estate has been established both by UDP Policy 66, which supports the regeneration of the wider Clapham Park area, including improvements to open spaces, and by virtue of the original outline planning permission (ref. 06/03680/OUT) which consented the refurbishment of blocks within Sections C and E alongside new build development. The complete refurbishment of the existing blocks, rather than partial redevelopment can also be supported as it will improve the quality of the existing housing (363 dwellings) on the estate to bring it up to Decent Homes Standard.

8 External Alterations 8.1 Windows and Doors

The provision of replacement windows and doors across the site is supported by virtue of Core Strategy Policy S9 and UDP Policies 32 and 33, both in terms of improved external appearance, enhancing the existing character of the blocks and improving the security of each of the dwellings.

8.2 The existing windows will be replaced with appropriately detailed Georgian sash windows in white uPVC, similar to those used in the earlier refurbishment of surrounding blocks. The Design and Conservation Officer supports the proposals, making clear that, “these characterful windows would dramatically transform the appearance of the building reinforcing the character of the blocks.”

8.3 New private front doors and new doors to balconies (mix of French doors and single doors with sash windows) are also proposed across the development. The private front doors will be solid timber with a consistent style and colour across each block and are supported by Officers in terms of their appearance. Further detailed specifications of the proposed window and door components can be found on plans ref. DUR600AL(0)1001B and 1002A.

8.4 New Lift Towers

The proposals include the provision of new lift towers on a number of blocks to provide step free access to the walkways on the upper floors. The lift towers will provide additional accessibility to 102 of the 363 (28%) of the existing residential dwellings. Six lift towers are proposed in the following blocks:

§ Mudie House § Lycett House § Lafone House § Angus House (x2) § Cotton House

8.5 The towers will be connected to existing entrance cores in each block with a new brick

built lift shaft and new communal entrance door on the ground floor. The lifts have been located to minimise their impact on the existing dwellings, while maximising the number of units served within budgetary constraints. The application has been accompanied by a Daylight and Sunlight assessment for each block, which concludes that the proposed lift towers will not have an adverse impact on the amenity of the existing residential dwellings.

8.6 The towers are built in brick to match the existing block (Ibstock West Hoathly Multi stock - examples can be seen on earlier refurbished blocks within the estate) with full floor height narrow aluminium steel coated windows in grey to give further definition to the block. The communal entrance doors are also in grey steel coated aluminium, with new cantilevered canopy.

8.7 The principle of providing the new lift towers on the above blocks is considered

acceptable and further helps to improve accessibility within the estate. The Council’s Design and Conservation Officer states that, “the proposed lift cores have been installed on previously refurbished blocks and have been successful in their materiality and detailing. The proposed siting and appearance of lift cores are considered acceptable.”

8.8 New Balconies

The main alteration to the existing blocks is the provision of new cantilevered balconies to allow each unit to have access to an area of private amenity space. The siting of the balconies has been considered in terms of their impact on the heritage of the building, the presence of existing balconies and where possible to provide balconies direct from living rooms. The balconies are constructed in steel, painted black (examples can be seen on earlier refurbished blocks within the estate) and come in two types. Type ‘B1’ is approximately 2.7m in width and provides a space of approximately 3.5m2 of additional space. Type ‘B2’ is approximately 1.8m in width and provides a space of approximately 2.16m2 of additional space. The principle of providing balconies of this type and style is considered acceptable by Officers, subject to satisfactory placement on the blocks. The balcony provision for each block is considered in more detail below.

8.9 Section C

Mudie House – 16 balconies will be added on the Forster Road elevation in addition to the six existing concrete balconies. Ten of the proposed balconies are type ‘B1’ with the remaining six type ‘B2’. Following a number of objections from residents in Mudie House, the applicant has amended the previous plans to move one set of balconies across so that they are accessed from a living room rather than a bedroom. As a result, this and the adjoining balconies have been reduced in size. The final layout still results in two units having their balcony accessed from the bedroom, but is considered acceptable given the internal layout of the block and the fact that any further changes would result in an unacceptable external appearance. The symmetry and rhythm of this block has been largely retained with vertical alignment of the new balconies and appropriate spacing between. The only exception is a lone balcony on the third floor and is a result of the internal layout being different at this level. As such, it is considered that the proposals are acceptable in this instance.

8.10 Miller House –16 balconies will be added on the Forster Road elevation in addition to the existing first floor concrete balcony centred on this façade. Twelve of the proposed balconies are type ‘B1’ with the remaining four type ‘B2’. As with Mudie House, four of the proposed balconies will be accessed from bedrooms rather than living rooms, although in one case the dwelling will benefit from a living room balcony too. The internal layout of the blocks makes it difficult to provide balcony access from living rooms in all cases without having significant impacts on the external appearance. The symmetry and rhythm of this block has been well retained with vertical alignment of the new balconies working with the existing balconies and façade treatments and providing appropriate spacing between them. As such, it is considered that the proposals are acceptable in this instance.

8.11 Lycett House –27 new balconies will be added to the block’s external facing facades

onto Forster Road (6 all type ‘B1’), Atkins Road (7 (6 type ‘B1, 1 type ‘B2’)) and those facing Lafone House (14 (11 type ‘B1, 3 type ‘B2’)). Three of the proposed balconies will be accessed from bedrooms rather than living rooms, all of which are located on Forster

Road. The reason for this has already been explained above, however the Forster Road elevation has the added issue of being much smaller and therefore even more difficult to rearrange balconies with only a limited number of windows. The symmetry and rhythm of this block on all facades has been generally retained with vertical alignment of the new balconies working with the existing balconies and façade treatments and providing appropriate spacing between them. There is one exception on the façade facing Lafone House, but this will be mirrored across the courtyard and therefore appropriate. As such, it is considered that the proposals are acceptable in this instance.

8.12 Lafone House – This block mirrors the proposals for Lycett House. Although in this case only one balcony is accessed from a bedroom on third floor unit fronting onto Atkins Road. It is considered that the proposals are acceptable in this instance, by virtue of the external impact on the symmetry and spacing of balconies.

8.13 Lucraft House – Eleven new black steel balconies will be added on the southern

elevation in three vertically aligned sets. The balconies are made up of eight type ‘B1’ and three type ‘B2’ in order to match the existing balcony on the first floor. All of the balconies are accessed directly from living rooms and are therefore considered acceptable.

8.14 Freeman House - 14 balconies will be added on the New Park Road elevation in

addition to the existing first floor Juliet Balconies. All of the proposed balconies are type ‘B2’. In order to maintain symmetry across the façade, all of the balconies with the exception of two on the third floor are accessed from bedrooms. This is the case with the existing balconies too. As such, it is considered that the proposals are acceptable in this instance.

8.15 Section E

Angus House – 52 balconies are proposed. 22 (17, type ‘B1’ and 5, type ‘B2’) are proposed on the western façade, broadly in vertical alignment taking into account existing balconies and external features. There is one exception on the third floor, which is as a result of the upper floor having a different internal layout. There is one balcony on this façade with access from a bedroom. However, in order to maintain the rhythm and symmetry of the block, this is considered acceptable. The eastern façade mirrors the western façade in terms of balcony numbers, types and locations. The northern façade includes provision of eight (6, type ‘B1’ and 2, type ‘B2’) balconies, none of which are accessed from bedrooms. The proposals seek to retain the character of this key façade with strong vertical alignment and symmetry. The proposed locations are therefore considered acceptable.

8.16 Cotton House – 51 balconies are proposed. 22 (17, type ‘B1’ and 5, type ‘B2’) are

proposed on the eastern façade, broadly in vertical alignment taking into account existing balconies and external features. There is one exception on the third floor, which is as a result of the upper floor having a different internal layout. None of the balconies are accessed from bedrooms. 21 (13, type ‘B1’ and 8, type ‘B2’) balconies are proposed on the western façade, broadly in vertical alignment taking into account existing balconies and external features. There are 16 balconies on this façade with access from a bedroom. However, in order to maintain the rhythm and symmetry of the block, this is considered acceptable. The northern façade includes provision of eight (6, type ‘B1’ and 2, type ‘B2’) balconies, none of which are accessed from bedrooms. The proposals seek to retain the character of this key façade with strong vertical alignment and symmetry. The proposed locations are therefore considered acceptable.

8.16 Crossman House – The first and third blocks both provides 13 new balconies (4, type

‘B1’ and 9, type ‘B2’). The balconies are placed in a vertical alignment with one exception on the third floor, which is as a result of the upper floor having a different

internal layout. Each block has four balconies with access from a bedroom. However, in order to maintain the rhythm and symmetry of the block, this is considered acceptable. The second block provides 9 new balconies (all type ‘B1’), which are set either side of an existing bay window running from first to third floors. None of these balconies are accessed from bedrooms. The proposed locations are therefore considered acceptable.

8.17 Currie House – 16 balconies are proposed all on the western elevation of the block.

Eight of which are type ‘B1’ and the remaining eight type ‘B2’. The balconies are aligned vertically and provide a symmetry within the block overall and the existing balconies and features. There is one balcony on this façade (second floor) with access from a bedroom. However, in order to maintain the rhythm and symmetry of the block, this is considered acceptable.

8.18 The proposals have been subject to a Daylight and Sunlight Assessment, which

concludes that the impact of the new balconies across the site have a minor impact on the existing daylight and sunlight currently enjoyed by residents. However, it is considered that a minor impact would be acceptable given the proposals will provide new private amenity space for every dwelling in both Sections C and E.

9 Landscaping 9.1 Hard Landscaping

The proposals include a number of hard landscaping features including, new and improved play equipment within the existing play areas; improved boundary treatments to give a better sense of enclosure, particularly for the ground floor units with a clearly defined defensible space; new external gates and security measures to create residents only communal open space between the blocks; raised planters to define edges and break up the newly tarmacked and demarcated car parking; and new seating within the communal open space. These measures will be supported by new lighting and a wayfinding strategy to help support movement through and around the site. These measures are broadly supported in principle, subject to details being secured by condition.

9.2 Soft Landscaping

The proposals include the provision of new soft landscaping throughout the site. This includes new hedge planting around external facing facades of the blocks to reinforce boundary lines and provide new defensible space; new tree planting (4 in Section C and 7 in Section E); improvements to the existing grassed areas with bulb planting and new shrub planting in raised planters within the internal courtyards.

9.3 No trees are identified for removal in Section C. In terms of Section E, three trees are

scheduled for removal, these include one category B and two category C trees. The removal of the category C trees is considered acceptable. The category B ‘swamp cypress’ tree (T60) has been reassessed given the existing root protection area is already covered wholly by hard surfacing. The applicant’s aboriculturalist has suggested that the tree has a limited life span and that the proposed works to the hard surfacing are likely to cause further root damage. As such, it should be removed. The updated information has been assessed by Officers and on this occasion is satisfied that the proposed works will require removal of the tree. It should be noted that the number of trees planned for removal as part of this scheme is actually fewer than those approved for removal as part of the outline permission.

9.4 The Council’s Parks and Open Space Officer is supportive of the proposals for soft

landscaping, subject to a detailed specification, planting and maintenance programme to be secured by condition.

10 Transport and Parking 10.1 The proposals do not result in an increase in residential dwellings, as such there would

not be any significant change in trip generation or other impacts arising from the development. The proposals also seek to maintain the existing vehicular and pedestrian access points in both Sections C and E, with a reorganisation of the existing car parking layout and improvements to legibility and new lighting as part of the wider landscaping proposals.

10.2 The proposals show that all existing car parking provision will be retained with the

addition of six spaces in Section C, taking into account the potential future development of the adjoining Mears site, which is accessed from the internal courtyard. A further space will be provided as part of Section E. The Transport/Highways Officer considers that the car parking provision is acceptable in terms of quantity and layout, subject to the final parking layout being agreed by condition.

10.3 The proposed provision of 16 cycle parking spaces across the site has raised concerns

from the Transport Officer and TfL. London Plan standards require a minimum of 1 cycle space per 1 or 2 bedroom dwelling and a minimum of 2 spaces for every 3 bedroom or larger. It is accepted that internal cycle stores within the buildings are unlikely to be feasible but provision of high quality external cycle stores may be appropriate. The applicant has indicated that the proposals are a reorganisation of the existing layout, and therefore constrained in the level of cycle parking that can be delivered. It is considered that some additional work should be undertaken to assess what capacity exists, although Officers accept that the London Plan standards are unlikely to be met fully. Further details on cycle parking provision should be secured for approval by condition.

10.4 The plans include turning areas for vehicles, including refuse collection vehicles, to

turnaround within the site. These are acceptable subject to a condition ensuring that these areas are kept clear of obstruction at all times and retained for the life of the development.

11 Refuse and Recycling 11.1 London Plan Policy 5.17 and Core Strategy Policy S7 require that development makes

sufficient provision for waste management and promotes designs and layouts that secure the integration of waste management facilities without adverse impact on the street scene.

11.2 The current refuse/recycling provision in Section C is located within separate units on the ground floor of each block, with a number of freestanding blocks within the rear car parking yards. These units are also fed via refuse chutes from the upper floors. The proposals seek to rationalise the existing provision by closing the waste chutes and creating new screened refuse/recycling areas away from the blocks. The principle of this is supported as it will create a better environment for those living on the ground floor, moving refuse bins away from the dwellings. The plans show up to seven new enclosures holding between 3 and 6 1280L bins each, predominantly within the internal courtyards. The number of bins has been calculated in accordance with relevant guidance, providing 28,800L capacity for refuse, with 50% additional capacity for recycling.

11.3 In terms of Section E the existing situation is broadly similar to Section C, although there are currently no freestanding bin blocks. The proposals seek to close the existing bin chutes and provide up to seven new enclosures holding between 3 and 6 1280L bins each, predominantly within the internal courtyards. The number of bins has been

calculated in accordance with relevant guidance, providing 22,860L capacity for refuse, with 50% additional capacity for recycling.

11.4 Some concern has also been raised in relation to the bin chutes being closed and the

distance to the new bin enclosures. It is considered that the new enclosures have been placed as close as possible to the communal entrances to reduce travel distances. The closure of the chutes has been deemed necessary by the applicant due to ongoing maintenance and management issues.

11.5 The bin enclosures are shown as mid-height timber structures, details of materials and their locations are to be secured by condition. Subject to these details officers consider that the proposals are acceptable in principle.

12 Other Issues 12.1 Sustainability

The proposals constitute refurbishment works and therefore are not required to achieve a Code for Sustainable Homes accreditation. However, the proposals do seek to significantly improve the thermal performance of the existing dwellings, with new windows, doors and internal thermal insulation (tenanted properties only). This approach is consistent with the earlier refurbished blocks and is supported by Core Strategy Policy S7(d).

12.2 The proposals should be considered in accordance with the Mayor’s energy efficiency

hierarchy and seek appropriate measures to reduce carbon dioxide emissions. As such, details of u-values of replacement windows, doors, and upgraded external walls (including proposed thickness of insulation) as well as further detail on the proposed heating and electrical installation upgrades shall be secured by condition.

12.3 Planning Obligations

The S106 Agreement (as varied) for the original outline permission (ref. 06/03680/OUT) secured new local play provision within the Clapham Park Estate. In accordance with Schedule 6, Part 1, para. 6 of the Agreement, a Local Equipped Area for Play (LEAP) (detailed specification set out in Schedule 10 of the Agreement) of a minimum of 400m2 shall be provided in the areas surrounding Lycett and Lafone House (Section C) and Cotton and Angus House (Section E).

12.4 The above areas were defined based on the outline permission and intention to

demolish and introduce new build blocks in these locations. As the proposals now do not include new build elements, the intention is to improve the existing play areas in these locations. The existing play space for Section C equates to approximately 410m2, while in Section E approximately 160m2 of play space is provided with a 252m2 MUGA to be retained. As such, the proposals would meet the requirements of the Agreement in terms of floor area.

12.5 The S106 Agreement goes on to require that the Lycett/Lafone Local Play is delivered

prior to implementation on Phase 3 and the Cotton and Angus Local Play prior to implementation on Phase 4. Given the current proposals will form part of Phase 1, the intention to bring forward improvements to the play space in advance of the timescales of the S106 Agreement is supported. It is not considered that a variation of the original S106 Agreement is required in this instance as the proposed local play is provided in accordance with the Agreement.

13 Conclusion

13.1 It is considered that the proposed development and refurbishment of the existing blocks is broadly in accordance with policy. The proposals will result in a significant improvement to the quality of the existing housing, in terms of energy efficiency, provision of private amenity space and the creation of defensible space throughout the site. In addition, the improvements to the existing landscaping, including the upgraded children’s play space, creation of resident only communal open space and a reorganisation of the parking and refuse/recycling provision is supported. It is accepted that the site presents a number of site specific issues and constraints, particularly in terms of providing lift access to all blocks and the level of cycle parking. On balance however, the benefits of the scheme clearly outweigh the dis-benefits and is therefore considered to be acceptable.

14 Recommendation 14.1 Grant planning permission subject to conditions set out below. 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 were relevant:

London Plan (2011)

§ Policy 2.9 – Inner London § Policy 2.14 – Areas for Regeneration § Policy 3.5 – Quality and Design of Housing Developments § Policy 3.6 – Children and Young People’s Play and Informal Recreation

Facilities § Policy 3.14 – Existing Housing § Policy 5.2 – Minimising Carbon Dioxide Emissions § Policy 5.3 – Sustainable Design and Construction § Policy 5.4 - Retrofitting § Policy 5.17 – Waste Capacity § 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 7.21 – Trees and Woodlands

Core Strategy (2011)

§ Policy S1 – Delivering the Vision and Objectives § Policy S2 – Housing § Policy S4 – Transport § Policy S5 – Open Space § Policy S7 – Sustainable Design and Construction § Policy S9 – Quality of the Built Environment § Policy S10 – Planning Obligations

UDP (2007)

§ Policy 9 – Transport Impact § Policy 14 – Parking and Traffic Restraint § 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 38 – Design in Existing Residential/Mixed Use Areas § Policy 39 – Streetscape, Landscape and Public Realm Design § Policy 50 – Open Space and Sports Facilities § Policy 66 – Clapham Park

16 Conditions

1. The development to which this permission relates must be begun not later than the expiration of three 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.)

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. 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 and consideration given to the inhabitants of the surrounding dwellings. 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.

4. In accordance with the approved plans, the proposed brick used in elevations must match the existing brick. Reason: To ensure the new elements of the blocks match the existing block and safeguard and enhance the visual amenities of the locality in compliance with Policies 31, 32, 36 and 38 of the London Borough of Lambeth UDP: Policies saved beyond 5th August 2010.

5. Within three months of commencement of development, the following details shall be submitted to and approved by the Local Planning Authority:

- Details of new signage; - Details of refuse storage; - Details of new boundary treatment other than proposed railings to defensible

space as shown in drawing DUR600AL(0)1004 Rev.A; - Details of the improvements to the existing play areas;

- Details of rain water pipes; - Details of external lighting (fixtures and location).

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 in compliance with Policies 31, 32, 36 and 38 of the London Borough of Lambeth UDP: Policies saved beyond 5th August 2010.

6. Within three months of commencement of the development hereby permitted, 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 (conforming to BS5849:2014 and including lux levels), 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 in accordance with Policy 32 of the London Borough of Lambeth UDP: Policies saved beyond 5th August 2010.

7. Within three months of commencement of the development, full details of the proposed car and cycle parking provision (including details of manufacturer’s specifications for cycle parking) shall be submitted to and approved in writing by the Local Planning Authority. The details as are approved shall be retained as such for the duration of the permitted use.

Reason: To ensure that adequate provision is made for car and cycle parking on the site, in the interests of the promotion of sustainable modes of transport in accordance with Policy 14 of the London Borough of Lambeth UDP: Policies saved beyond 5th August 2010 and Policy 6.13 of the London Plan.

8. Prior to completion of the development, a scheme shall be submitted to and approved in

writing by the Local Planning Authority a scheme for the ‘soft landscaping’ of the application site, including the selection of species, planting plans/programmes, and schedules for management and maintenance of landscaped features, whether formal or natural in nature and purpose. These proposals should include all new plantings of trees, hedges, grass, shrubs, ground flora or climbers, and cover all areas of the development including roofs, walls and boundary features.

Landscaping schedules should include, within reason and not entailing excessive cost, measures to promote biodiversity including the use of native species that are typical of locality and ground conditions. The applicant should seek and act on good practice as well as advice from professionals to maximise the site’s landscape, visual and horticultural quality, ease of maintenance and to provide long-term biodiversity and environmental benefit. The development shall thereafter be carried out solely in accordance with the approved details.

Reason: To ensure a satisfactory and continuing standard of amenities are provided and maintained in connection with the development in accordance with Policy 39 of the London Borough of Lambeth UDP: Policies saved beyond 5th August 2010.

9. Prior to completion of the development, a scheme detailing hard landscaped areas (including children’s play space) 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 a satisfactory and continuing standard of amenities are provided and maintained in connection with the development in accordance with Policy 39 of the London Borough of Lambeth UDP: Policies saved beyond 5th August 2010.

10. The proposals for manoeuvring and the loading and unloading of vehicles shown on

the submitted plans shall be laid out in accordance with the approved plans hereby permitted and shall not thereafter be used for any other purpose, or obstructed in any way.

Reason: To enable vehicles to draw off, park and turn clear of the highway to minimise danger, obstruction and inconvenience to users of the adjoining highway in accordance with Policy 14 of the London Borough of Lambeth UDP: Policies saved beyond 5th August 2010.

11. Prior to completion of development, electric charging points shall be provided at this site in accordance with the standards embodied in Policy 6.13 of the London Plan. Reason: In order to accord with Policy 6.13 of the London Plan.

12. A Travel Plan shall be submitted to and approved in writing by the Local Planning Authority prior to completion of the development. The measures approved in the Travel Plan shall be implemented upon completion of the development 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)

13. Prior to completion of the development, energy efficiency details including proposed u-

values of replacement windows, doors, and upgraded external walls (including proposed thickness of insulation) as well as further detail on the proposed heating and electrical installation upgrades (i.e. what is the existing situation, and what specific upgrades are proposed) shall be submitted to the Local Planning Authority. The proposals should be considered in accordance with the Mayor’s energy efficiency hierarchy and a BREEAM for Domestic Refurbishments Pre-Assessment is recommended for this purpose.

Reason: To ensure that the development makes the fullest contribution to minimising carbon dioxide emissions in accordance with London Plan Policy 5.2 and Core Strategy Policies S7.

17 Informatives

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.

2. You are advised that this consent is without prejudice to any rights which may be enjoyed by any tenants/occupiers of the premises.

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.

4. 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.

5. 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.

6. Flood risk - We note that the site is located in Flood Zone 1 which is defined as having a ‘low probability’ of river and sea flooding by the 'flood risk and coastal change' section of within the 'flood risk and coastal change' section of the National Planning Practice Guidance (NPPG) (Table 1: flood zones of the flood zone and flood risk tables – Paragraph 065, Reference ID 7-065-20140306).

Please note that there may be other sources of flooding which affect this site – such as surface water, groundwater and sewer flooding – which are not within our direct remit, but nevertheless could be important considerations for managing flood risk for the proposed development. Under the Flood & Water Management Act 2010, the Local Planning Authority has the lead role in such flooding matters.

We also note that the development – namely, residential accommodation – is classified as ‘more vulnerable’ by the ‘flood risk and coastal change’ section of the NPPG (Table 2: flood risk vulnerability classification of the flood zone and flood risk tables –Paragraph 066, Reference ID 7-066-20140306).

7. Surface water management - We encourage any development to strive to achieve

greenfield run-off rates, in line with the Greater London Authority’s London Plan (Policy 5.13). Indeed, the Mayor of London’s relevant ‘essential standard’ requires that any development achieves a minimum of 50% attenuation of the undeveloped site’s surface water run-off at peak times, whilst the relevant ‘preferred standard’ requests that any development achieves 100% attenuation of the undeveloped site’s surface water run-off at peak times, as stated in the Greater London Authority’s Sustainable Design and Construction Supplementary Planning Guidance (SPG) (Section 2.4.4).

We also encourage any development to manage surface water run-off as close to its source as possible, in line with the given drainage hierarchy, and to utilise Sustainable Drainage Systems (SuDS) wherever practical, as required by the London Plan (Policy 5.13). Indeed, such a requirement is further supported by the ‘essential standard’ within the aforementioned Sustainable Design and Construction SPG (Section 2.4.4).

Moreover, we encourage that the incorporation of SuDS is considered during the design of the development site and any associated drainage scheme, with reference to ground and contamination investigations and hydrological and hydro-geological analysis, in line with the London Borough of Lambeth’s Strategic Flood Risk Assessment (SFRA) (Section 10.3).

We acknowledge that it can be difficult for some development proposals to achieve reductions in surface water run-off rates and to incorporate SuDS measures, owing to the type of development or constraints on site. Nevertheless, we would be pleased if every effort could be made to reduce surface water run-off as a result of any

landscaping proposals at the site, such as via the incorporation of rain gardens and so on.

We advise that the applicant visits the following resources for further information on SuDS:

§ the ‘flood risk and coastal change’ section of the NPPG (the 'use of SuDS' section of the ‘reducing the causes and impacts of flooding’ section – Paragraph 051, Reference ID 7-051-20140306);

§ CIRIA C697 document – ‘The SuDS manual’; § the ‘Interim Code of Practice for SuDS’ which provides advice on design,

adoption and maintenance issues, plus a full overview of other technical guidance on SuDS;

§ CIRIA C522 document – ‘Sustainable Drainage Systems – design manual for England and Wales’;

§ CIRIA C635 document – ‘Designing for exceedance in urban drainage: good practice’.

8. Groundwater and land contamination - We note that the site is located within a

groundwater Source Protection Zone (SPZ2).

9. The proposed bin stores must be secure, screened from view and robust. As such timber is not recommended for refuse stores and defensible space planters. Details of suitable materials for refuse stores can be found in the Council’s Refuse and Recycling Storage Design Guide (July 2013).