Report to the Council of the London Borough of Sutton

Report to the Council of the London Borough of Sutton

by David Smith BA(Hons) DMS MRTPI

an Inspector appointed by the Secretary of State

Date 30 January 2018

Planning and Compulsory Purchase Act 2004

(as amended)

Section 20

Report on the Examination of the

Sutton Local Plan 2016-2031

The Plan was submitted for examination on 12 April 2017

The examination hearings were held between 12 September and 28 September 2017

File Ref: PINS/P5870/429/8

Page 735 Agenda Item 8b

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Abbreviations used in this report

AA Appropriate Assessment AQAP Air Quality Action Plan

ATBP Areas of Tall Building Potential HMO Houses in Multiple Occupation

HRA LCH

Habitats Regulations Assessment London Cancer Hub

LDS Local Development Scheme

MM MOL

Main Modification Metropolitan Open Land

NPPF National Planning Policy Framework PPG Planning Practice Guidance

PPTS Planning Policy for Traveller Sites SCI Statement of Community Involvement SDP

SHELAA

Sutton Site Development Policies Development Plan Document

Strategic Housing and Economic Land Availability Assessment SHMA

SIL SLP SPG

TfL TCEDA

Strategic Housing Market Assessment

Strategic Industrial Location Sutton Local Plan 2016-2031 Supplementary Planning Guidance

Transport for London Town Centre and Economic Development Assessment

WMS Written Ministerial Statement

Page 736Agenda Item 8b

Sutton Local Plan, Inspector’s Report January 2018

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Non-Technical Summary

This report concludes that the Sutton Local Plan 2016-2031 provides an appropriate basis for the planning of the Borough, provided that a number of

main modifications are made to it. The Council has specifically requested me to recommend any main modifications necessary to enable the Plan to be adopted.

All the main modifications were proposed by the Council and were subject to public consultation over a six-week period. Their inclusion in the plan is

recommended after considering all the representations made in response to the consultation on them.

The main modifications can be summarised as follows:

Setting an affordable housing target of 35% for individual proposals and adjusting the policy threshold so that it is consistent with national policy;

Removing the reference to an alternative residential allocation at the London Cancer Hub;

Including a specific target of 25% for family housing in Sutton town centre;

Allocating a site at Beddington Lane which is currently Metropolitan Open Land to provide a potential industrial floorspace of 17,600 sq m;

Taking the proposed gypsy and traveller site at Woodcote out of the Green Belt;

Adjusting the site area of the school site at Rosehill and removing it from

Metropolitan Open Land; Altering the site allocations for some sites to ensure that details are

suitable; and Changing detailed policies so that they are justified, consistent with

national policy and effective.



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Introduction

1. This report contains my assessment of the Sutton Local Plan 2016-2031 (SLP)

in terms of section 20(5) of the Planning & Compulsory Purchase Act 2004 (as amended). It considers first whether the Plan’s preparation has complied with the duty to co-operate. It then considers whether the Plan is sound and

whether it is compliant with the legal requirements. The National Planning Policy Framework (NPPF) (paragraph 182) makes it clear that in order to be

sound, a Local Plan should be positively prepared, justified, effective and consistent with national policy.

2. The starting point for the examination is the assumption that the Council has submitted what it considers to be a sound plan. The Draft Sutton Local Plan 2016-2031 is the basis for my examination. This is the same document as

that published for consultation in January 2017 under Regulation 19 of the Town and Country Planning (Local Planning)(England) Regulations 2012 (as

amended).

Main Modifications

3. In accordance with section 20(7C) of the 2004 Act the Council requested that I

should recommend any main modifications necessary to rectify matters that make the Plan unsound and thus incapable of being adopted. This report

explains why the recommended main modifications are necessary. All of them relate to matters discussed at the hearings or raised during the examination process. They are referenced in bold in the report and set out in full in the

Appendix.

4. Following the examination hearings, the Council prepared a schedule of

proposed main modifications and carried out sustainability appraisal of them. The schedule was subject to public consultation between 24 November 2017 and 12 January 2018. I have taken account of the consultation responses in

coming to my conclusions in this report and have made some amendments to the detailed wording of the main modifications in the interests of clarity and

accuracy. None of these changes significantly alters the content of the modifications published for consultation or undermines the participatory processes and sustainability appraisal that has been undertaken.

Policies Map

5. The Council must maintain an adopted policies map which illustrates

geographically the application of the policies in the adopted development plan. When submitting the SLP for examination, the Council provided a document showing changes to the policies map (L.1.B) and an appendix with maps

(L.1.C) showing the alterations that would result from the proposals in the plan as well as confirming existing designations. An updated appendix was

produced in November 2017 to reflect the proposed main modifications.

6. The policies map is not defined in statute as a development plan document and so I do not have the power to recommend main modifications to it.

However, some of the main modifications recommended in the report require corresponding changes to be made to the policies map. Therefore, in order to

comply with the legislation and give effect to the plan’s policies, the Council will need to update the policies map on adoption so that it includes all of them.



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Consultation

7. The Council indicated that points made about inaccurate reporting of concerns from those in Lenham Road, the failure to acknowledge representations and to keep residents updated will be taken on board in future. Navigating the

volume of documentation connected with a local plan examination is daunting but this is not a problem unique to Sutton. Indeed, the level of engagement

carried out by the Council was well above the bare minimum. Moreover, the specific consultation arrangements set out in Table 3.2 of the Statement of Community Involvement (SCI) (L.2.E) have been undertaken. In accordance

with Regulation 18 it is also apparent that the plan has been altered in some places to take account of representations made. The SCI has therefore been

complied with as required by section 19(3) of the 2004 Act.

Assessment of Duty to Co-operate

8. Section 20(5)(c) of the 2004 Act requires that I consider whether the Council

complied with any duty imposed on it by section 33A in respect of the Plan’s preparation.

9. The Council is part of a number of pan-London fora and also sub-regional

structures such as the South London Partnership. The measures taken to co-operate on strategic matters with prescribed bodies and other local authorities

have been detailed (L.2.B). On issues where potential conflict has been identified the Council has taken some steps to address them so that the dialogue has not been superficial but has led to changes to the plan.

10. A summary of engagement with Reigate and Banstead Borough Council is contained in the statement of common ground (ED23). That Council maintains

that further progress should have been made in assessing the transport implications arising from the London Cancer Hub (LCH). However, that is primarily a question of soundness and there is no duty to agree. Indeed, the

cross-boundary impacts have been the subject of discussion. On this matter and overall I am satisfied that where necessary the Council has engaged

constructively, actively and on an on-going basis in the preparation of the plan and that the duty to co-operate has therefore been met.

Assessment of Soundness

Background

11. The SLP will replace the Sutton Core Planning Strategy of 2009 and the Sutton Site Development Policies Development Plan Document 2012 (SDP).

Paragraph 1.6 of the SLP states that all the policies in those adopted plans will be superseded so that Regulation 8(5) is met. There is also a duty under

section 24(1) of the 2004 Act for the SLP to be in general conformity with The London Plan. A draft London Plan was published for consultation in December 2017 with final publication expected in 2019. However, it is too early to give

significant weight to any of the policies within the new version.

Main Issues

12. Taking account of all the representations, the written evidence and the discussions that took place at the examination hearings, I have identified 12



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main issues upon which the soundness of the plan depends. Under these

headings my report deals with the main matters of soundness rather than responding to every point raised by representors.

Issue 1 - Are the spatial vision and objectives for Sutton sound having

regard to achieving sustainable development and the trends and challenges in the Borough?

13. Based on 30 headline trends the SLP identifies 5 key challenges relating to the

need for more homes; translating educational achievement into local jobs;

managing town centre change; meeting transport and infrastructure needs and delivering growth whilst enhancing the environment. These are addressed

in the vision in a positive and sustainable manner whilst taking into account the specific Sutton context. In turn, the 22 objectives support the delivery of

the vision and are concerned with people, business, centres, linkages and environment and are referred to in the SLP in relation to individual policies. However, they fail to mention the role of the Borough in meeting housing

needs in this part of London and securing necessary improvements to the road network. This omission should be rectified so that the objectives are

comprehensive and therefore justified (MM1 & MM2).

14. Together the vision and objectives reflect the economic, social and environmental dimensions of sustainable development set out in the NPPF.

Therefore the SLP has the achievement of sustainable development at its heart and the vision and objectives are accordingly sound. They have also been

carried through into the plan to ensure deliverability.

Issue 2 - Is the overall spatial development strategy for sustainable growth sound having regard to the needs and demands of the Borough;

the relationship with national policy and Government objectives; the provisions of The London Plan and the evidence base? Has the Local Plan

been positively prepared? 15. Following consideration of issues and options and the preparation of the

Sustainability Appraisal (L.1.D) the SLP incorporates a multi-centred spatial strategy but with the majority of housing and commercial growth directed to

Sutton town centre. Given that access to services and public transport is greatest here this is fully in line with the NPPF which provides that significant development should be focused in locations which are or can be made

sustainable (paragraph 17). The London Plan supports this approach too. Growth is also encouraged by intensifying areas around the town centres and

within the District Centres – especially at Hackbridge and Wallington.

16. The Sutton Town Centre Masterplan Capacity Analysis (L.8.B) and the Strategic Housing and Economic Land Availability Assessment (SHELAA)

(L.10.B) indicate that there is capacity to deliver the multi-centred strategy. In so doing the character of the suburban heartlands would be protected.

Furthermore, Policy 1 makes positive provision for infrastructure needs and the SLP is supported by an Infrastructure Plan (L.12.A). The Sustainability Appraisal also concludes that a medium growth scenario is the most

sustainable one as the higher growth option would be less beneficial in terms of increased air pollution, traffic congestion, flood risk and pressure on the

open environment and biodiversity.



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17. Overall, therefore, the SLP incorporates a balanced and justified approach to

development in the Borough. Moreover, the SLP has been positively prepared in that it seeks to meet the needs for development and infrastructure as opposed to preventing or severely restricting growth.

18. The scale of obligations and policy burdens should not threaten the ability to develop sites viably according to paragraph 173 of the NPPF. However, the

Planning Practice Guidance (PPG) on Viability confirms that not every site is required to be tested (ID 10-006-20140306). In support of the SLP the Council has produced a Viability Report (L.2.H(i)). This takes into account the

policy areas of affordable housing and carbon and energy that are likely to have a high impact on viability as well as Community Infrastructure Levy and

section 106 costs.

19. The Report is based on 40% affordable housing provision in line with the

recommendation of the Strategic Housing Market Assessment (SHMA) (L.10.C). It also uses upper quartile BCIS build costs which is realistic based on examples of recent residential schemes (ED36A). In particular some of the

developments selected included the wheelchair accessibility requirements in Policy 9. In any event, these policy provisions as well as space standards and

water efficiency are not new as they are part of The London Plan and therefore already ‘factored in’. On the basis of the evidence a mid-point figure of £1,500 per dwelling for carbon and energy is reasonable for testing purposes

and, in practice, new dwellings for social rent are not being constructed. Whilst particular values may be challenged there is insufficient evidence that

policy requirements will impair delivery provided that individual policies contain flexibility where necessary. Therefore the various policy provisions in the SLP do not undermine its overall deliverability.

20. The London Cancer Hub is a key strategic project but is covered by a separate policy. In setting out growth expectations this should be made clear (MM6).

Criterion a) of Policy 1 largely repeats paragraph 14 and should be removed as the PPG on Locals Plans indicates that policies should not reiterate the NPPF (ID 12-010-20140306). MM3 nevertheless confirms that sustainable

development will be pursued and is recommended.

Issue 3 - Are the policies for housing growth and for affordable housing

justified, deliverable and consistent with national policy? Will they be effective? Is the housing target and the distribution and location of new housing justified, will there be a 5 year supply of deliverable housing sites

and is the overall target for affordable housing and tenure type justified?

Housing target

21. The NPPF provides that to boost significantly the supply of housing, local

planning authorities should ensure that their local plans meet the full, objectively assessed needs for market and affordable housing in the housing

market area as far as is consistent with its policies. However, Policy 3.3 of The London Plan provides that Boroughs should seek to achieve and exceed the relevant minimum annual average housing target in Table 3.1.

22. For Sutton the annual monitoring target to 2025 is 363. Based on the SHELAA, capacity has been identified for 6,405 homes over the plan period or



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an average of 427 per annum. This level of provision is referred to in Policy 1

as the housing target. It represents an uplift of almost 18% above The London Plan target which reflects the shortfall of identified capacity compared to need across London as a whole. The SLP also incorporates an increase

above the recent annual average delivery of 357 net homes between 2009 and 2016. In this way Sutton would play some part in closing the gap between

identified housing need and supply in line with London Plan Policy 3.3.

23. The SHMA indicates that the housing need for Sutton is for 1,098 additional homes per annum. Whilst the shortfall between provision and this figure is a

substantial one The London Plan does not expect Boroughs to identify and meet their own objectively assessed needs. In Sutton there are constraints in

increasing supply such as Green Belt, Metropolitan Open Land (MOL), protected industrial locations and heritage areas which limit the ability to

accommodate new development. Furthermore, Policy 3.3 provides that the housing benchmarks should be augmented where possible [my emphasis] with extra capacity. Given the importance the Government attaches to Green Belts

this should not be taken as requiring the potential release of such land even allowing for the large difference between supply and need.

24. There is some criticism that sites have been discounted for weak reasons. However, the examples given are small in size and often have a related planning history which militates against development. No evidence has been

provided to indicate that large scale opportunities for new housing in suitable locations have been missed. Rather the Council has done all that can

reasonably be expected to identify sites including an assessment of over 1,600 of them through the SHELAA.

25. The SHMA estimates that 751 homes per annum are required to meet the

forecast levels of employment growth although the assumptions made about household size may have inflated this figure. The London Cancer Hub, for

example, is expected to generate 6,500 jobs. Nevertheless in a densely populated and dynamic area such as London the need for an exact ‘match’ between new homes and new jobs is less critical than it might be elsewhere.

Indeed, the consequence might be to create more opportunities for existing residents thereby reducing out-commuting.

26. In line with the PPG the Council has considered increasing the total housing figures in order to help deliver the required number of affordable homes. Over the plan period this amounts to 15,270 according to the SHMA. However, the

housing requirement is based on that in The London Plan. Furthermore, increasing housing supply to meet all affordable housing need would equate to

about 5 times the identified capacity. This is unrealistic given the constraints and likely sustainability impacts on the Borough.

27. Neither the implications for labour supply nor affordable housing therefore

warrant increasing the housing target. In the specific London context, where for planning purposes the capital is a single housing market, the figure in

Policy 1 of 6,405 new homes over the plan period is justified as the housing requirement for Sutton. However, the policy implies that the Council itself will be providing this level of housing rather than enabling its delivery and MM4 is

therefore required for effectiveness. Other changes are also necessary to Policy 1 in the interests of clarity (MM5, MM7, MM8 & MM9).



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28. The policy anticipates that 55% of new housing will be in Sutton town centre

with another 25% at Hackbridge and Wallington and the remaining 20% in other district centres and the suburban heartlands. This is consistent with the multi-centred strategy and is supported by the capacity work that has been

undertaken. As such the broad distribution and location of new housing outlined in the SLP is justified.

Housing supply

29. The NPPF expects that there should be a supply of specific deliverable sites sufficient to provide five years worth of housing against local requirements

with an additional buffer. There is no record of persistent under delivery of housing in the past and so, having regard to paragraph 47, the Council is

justified in applying an additional 5% buffer to ensure choice and competition. On this basis 2,242 units are required to achieve a five year housing land

supply between 2017 and 2022.

30. The signs are that the supply position is healthy. The Council advises that 639 net dwellings were completed in 2016/2017 and so there has been no shortfall

since the start of the plan period. The number of dwellings either under construction or with planning permission or prior approval is 2,423. Coupled

with other homes expected to come forward before 2022 the supply of deliverable sites exceeds the five year supply requirement by 462 or 21%. This provides a degree of tolerance should any site not progress as expected.

No major impediments or viability issues have been highlighted in respect of any individual site. Overall it can be said with some confidence that the

policies in the SLP should ensure the delivery of a five year housing land supply with flexibility to respond to changing circumstances.

31. The housing trajectory indicates that the on-going availability of a five year supply in phases 2 and 3 of the plan period is less certain. The NPPF refers to

identifying a supply of deliverable sites in years 6-10 and, where possible, for years 11-15 and also to a housing implementation strategy describing how a five year supply of housing land will be maintained. Table 1 of the SLP

confirms that housing supply is expected to be strongest in the early years of the plan. However, any sites that ‘slip’ would contribute in later years without

affecting the ability to meet the annual requirement in the earlier ones.

32. Moreover, when a windfall allowance of 75 is included over the last 10 years of

the plan period the position improves. This figure is based on past trends for delivery of sites of below 5 units and its inclusion is therefore reasonable and

justified. There are also longer-term plans to investigate the feasibility of redevelopment in and around Sutton town centre. Discussions have commenced in relation to the Benhill residential estate. Whilst these

opportunities are not identified in the SLP the numerical shortfall is, in any case, very slight and does not warrant further steps being taken. The

existence of a five year supply is also a critical matter that would be monitored by the Council in any event. Indeed, across the 15 year plan period as a whole the evidence is that the overall requirement for dwellings would be met.



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Affordable housing

33. Policy 8 of the SLP sets a Borough-wide target that 50% of new housing from all sources should be affordable. This carries forward the current development plan and has regard to the Mayor of London’s Supplementary Planning

Guidance (SPG) on Affordable Housing and Viability as well as the SHMA and the Viability Report. It is not an individual site target but rather criterion c)

indicates that the maximum reasonable amount of affordable housing will be sought by negotiation in respect of private and mixed-use schemes.

34. Affordable housing delivery from 2009-2016 equated to 40% of overall

completions. This proportion has been skewed in recent years because office to residential conversions were not subject to affordable housing policy. There

are also new initiatives such as Sutton Living which has been set up by the Council to acquire sites and deliver housing.

35. However, Policy 3.11D of The London Plan indicates that Boroughs should provide a robust basis for implementing targets through the development management process. On individual sites 50% is described as “the starting

point” but has not been achieved in most cases. In 4 recent examples the amount of affordable housing ranged from 15% to 24%. Furthermore, the

SHMA recommends a 40% target for sites and the Viability Report accepts that this might not be possible for larger flatted typologies. The reliance is therefore placed on site-by-site assessment.

36. Even if that process is firm and fair, the 50% target for individual proposals is not realistic. Whilst recognising the need for flexibility the policy does not

provide the high degree of predictability for making decisions on planning applications that is one of the core planning principles of the NPPF. Consequently a target for judging the acceptability of schemes is required in

order for the policy to be effective and without one the policy is unsound. Based on the viability evidence, the recent ‘track record’ and the Mayor’s SPG

a minimum figure of 35% is justified and the SLP should be modified accordingly. At the same time, to reflect the picture in Sutton the Borough-wide target should be replaced with a more general aim of maximising

affordable housing.

37. The policy expects that 75% of units should be for social/affordable rent and

25% intermediate. This varies from the London-wide strategic target of 60% and 40% respectively. However, The London Plan refers to local targets and so this divergence is not ruled out as a matter of principle. Moreover, the

division in types of tenure is based on the findings of the SHMA supported by the housing register which shows that there are over 1,400 households

awaiting rented accommodation.

38. The evidence (ED36B) shows the difference between social and affordable rent levels and hence their attractiveness to developers. Although the Viability

Report is based on the provision of affordable rent within developments this does not necessarily mean that the policy reference to social rent should be

removed. Indeed, both rental types are bracketed together in Policy 3.11 of The London Plan and the SPG and so Policy 8 is consistent in that respect. Overall the provisions regarding tenure are justified.



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39. On all sites below the threshold of 11 or more gross units the SLP seeks a

financial contribution to the Affordable Housing Fund. This provision conflicts with the Written Ministerial Statement (WMS) of 28 November 2014 and the PPG on Planning Obligations.

40. The need for affordable housing is large and between 2010 and 2016 there were 888 completions on sites with less than 11 units which was equivalent to

35% of total supply. If the scale of development is similar in future then a significant proportion would make no contribution towards affordable housing provision. The Viability Report also indicates that smaller sites tend to be more

viable due to lower upfront costs and shorter development periods and also that the threshold distorts land values. However, the delivery of affordable

housing in Sutton is not mainly reliant on contributions from smaller sites.

41. The WMS refers to the disproportionate burden of developer contributions on

small-scale developers. The Council anticipates that a sliding scale of payments would be set out in a forthcoming Supplementary Planning Document using a similar formula to the London Borough of Richmond.

However, this means that there is no detail about the impact that the policy would have and so the implications are unclear. Indeed, this part of Policy 8 is

inconsistent with national policy. Policy 3.13B of The London Plan encourages a lower threshold than 10 but criterion b) ii) has not been justified by local circumstances in Sutton and should therefore be deleted.

42. The detailed policy provisions criterion are not clear about how it is to be determined whether a site is capable of delivering 11 units or more and

criterion d) contains insufficient detail about when off-site provision in lieu will be accepted. These are therefore not effective. Main modifications to Policy 8 and the supporting text are recommended to cover all of the above (MM36,

MM37, MM38, MM39, MM40, MM41 & MM42).

Conclusion on Issue 3

43. Subject to the main modifications identified, the housing requirement is justified and there is a sufficient supply of housing over the plan period. The SLP provides for a 5 year supply of housing sites and the amended target for

affordable housing and the type of tenure is also justified.

Issue 4 - Are the policies relating to Sutton’s strategic projects of the

London Cancer Hub, Sutton town centre, Tramlink and major transport proposals and Wandle Valley Renewal justified and will they deliver the relevant strategic objectives?

London Cancer Hub

44. The concept of the LCH has evolved since the adoption of the SDP in 2012.

Policy 2 confirms the intention to deliver a mixed use development in

accordance with Site Allocation LCH1 comprising health, medical research and development and a secondary school together with supporting uses. This

would build on the presence of the Institute of Cancer Research and the Royal Marsden NHS Trust to provide complementary cancer-related research and development floorspace and would also allow for the expansion of both



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institutions. A hospital could also be developed in conjunction with the Epsom

and St Helier University Hospitals NHS Trust.

45. The evidence base including the development framework, delivery strategy and marketing reports (L.7.A-D) confirm that the options selected for the site

are justified, that there is reasonable certainty that the aspirations for the LCH can be realised and that development is deliverable with robust partnership

arrangements in place. Whilst the amount of floorspace to be provided is not fixed an approximate figure should be given in the policy to provide some certainty that around 280,000 sq m of development is envisaged (MM10).

46. The policy indicates that the Council may also permit residential development on 5.9 ha of the site if not required for allocated uses. Whilst the NPPF refers

to flexibility this would be a wholly different use of land to that within the allocation. Moreover, given that the LCH is likely to develop over a period of

20 years or so the prospect of new housing on the site would dilute the unique opportunity to develop a high quality life sciences destination in close proximity to well-renowned institutions. This land is not included in the

housing supply and a subsequent review would be a more suitable time to assess progress. Consequently the reference to an alternative residential

allocation should be omitted as it is not justified and MM11 and MM14 are therefore recommended.

47. A high level Transport Report (L.7.E) has been undertaken to consider the

transport impacts arising from the LCH. This study identifies the potential need for improvements at a number of junctions including those along the

A217 outside the Borough. Whilst the amount and type of development at LCH are not settled the study did not discount existing flows to the site and made no allowance for future modal shift. To that extent it painted the

“darkest picture” and is therefore robust. The SLP identifies four development ‘waves’ and possible transport improvements associated with them and the

likely need for interventions is highlighted in the policy. Whilst certainty about phasing and the sources of funding may be desirable this is a long-term project where this is not possible at this stage.

48. The policy should nevertheless contain a framework by which any significant transport impacts can, if necessary, be limited in accordance with paragraph

32 of the NPPF. Irrespective of whether improvements will be required in Sutton or outside the Borough in Surrey that is what criterion c) does. However, to be effective it should be made clear that a full transport

assessment and travel plans will be required to accompany any planning applications and reference to joint working with neighbouring authorities

should be included in the text (MM12, MM15 & MM16).

49. The Transport Report sets challenging targets for modal shift. The Issues and Options Report (L.7.G) by Transport for London (TfL) identifies three different

packages including an extension of the tram to Belmont, rail improvements and bus service diversion and enhancement. Whilst further feasibility work

will be required low and medium cost beneficial options exist. Some of these measures are listed against the development ‘waves’. Given this is a complex scheme it is not possible to be more precise but the policy allows for

sustainable transport provision to be made in conjunction with the phased development of LCH. Wave 0 nevertheless omits reference to a local bus



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service enhancement to serve the new school and this should be included for

effectiveness (MM17).

50. If the Belmont Allotment is required for development then criterion d) does not give sufficient detail about provision elsewhere in terms of quality and

quantity. This should be rectified to be justified (MM13).

Sutton Town Centre

51. Policy 3 relates to Sutton town centre and carries forward the amount and

spatial distribution of development identified in Policy 1. The evidence base

establishes that the level of development proposed is realistic and the Masterplan (L.8.A) shows how this can be achieved. Given its locational

advantages the ambitions for growth in the town centre are justified. This comprises at least 3,400 new homes and 31,000 sq m of retail and food and

beverage floorspace. This figure of 17,000 sq m of offices is too low to be justified as it fails to reflect the pre-eminence of Sutton as a location for offices compared to other centres and the capacity identified. MM21 refers to

23,000 sq m and is recommended to reflect this.

52. The level of retail floorspace is supported by evidence in the Town Centre and

Economic Development Assessment (TCEDA) (L.11.A) which takes account of other centres outside the Borough. In any event the NPPF encourages policies to retain and enhance existing markets as part of ensuring the vitality of town

centres. Delivery will be achieved by sites already developed or under construction or allocated for retail or mixed uses.

53. For offices the level of provision is slightly less than that identified in the TCEDA and, as modified, includes all the provision for the Borough. A cautious approach to site allocation is justified on the basis of recent experience.

Almost 16,000 sq m of new office floorspace has already been completed or is under construction. The main allocation that has not commenced is at Sutton

Station (STC14) but there is interest in taking this forward to provide over 8,000 sq m of floorspace. Overall, as modified, the SLP allows for an adequate and realistic amount of office development in Sutton town centre.

54. The policy also encourages the necessary accompanying infrastructure to serve the town centre and its residents. The Council has worked with other

providers to take account of future population changes and the SLP allocates the Robin Hood Lane site (STC30) for a new health centres and also two sites for primary schools at the Secombe Theatre (STC10) and Sutton West Centre

(STC4). Other social and cultural facilities could be accommodated at the redeveloped Civic Centre (STC9) and some leisure and recreation facilities and

public spaces are easily accessible. Whilst it would be desirable to have a greater range of such provision commercial operations cannot be controlled and those living in Sutton would not be bereft in this respect. Infrastructure

would therefore be adequate.

55. In terms of transportation the Sutton Town Centre Transport Options Appraisal

Study (L.16.D (iii)) contains a “hybrid” solution. This comprises a mix of junction improvements at Throwley Way/Carshalton Road, a net increase in bus services and Tramlink. Works at the road intersection will be required

irrespective of Tramlink and so should be specifically referred to in this way in



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the interests of effectiveness. However, a traffic management scheme at

Burnell Road/Lewis Road is not critical at this stage and should be deleted from the policy although retained as a long-term possibility (MM24). A detailed town centre parking study will be undertaken to ensure its adequacy.

56. A new road link between Brighton Road and Grove Road has been contemplated since 2005. This will provide relief from congestion at the

southern end of the town and pave the way for a possible Tramlink extension to Belmont. In creating a new alignment some demolition would be required including the handsome, locally listed Masonic Hall which is within the Sutton

High Street Crossroads Conservation Area. In so doing, there would be some damage to the integrity of the townscape. Neither the length of time this

project has been on the cards nor the reference in the Conservation Area Appraisal (L.14.J) is decisive. Indeed, the NPPF provides that great weight

should be given to the conservation of a heritage asset when considering the impact on its significance.

57. However, as well as the public benefits in terms of transport, the scheme

would enable a section of Brighton Road within the conservation area to become a public transport, cycle and pedestrian corridor. At the same time

there would be scope for public realm improvements in front of the station that would also benefit nearby locally listed buildings and the designated asset as a whole. Any detailed proposal would be assessed having regard to

paragraph 134 of the NPPF but at this juncture the negative heritage impacts of the new road do not rule it out. As such, and notwithstanding that Sutton is

within a Heritage Action Zone, this aspect of the SLP is sound.

58. Policy 3b) refers to the provision of a range of dwellings including 3-bed market housing. In response to the SHMA and subject to some caveats, Policy

9 seeks a minimum of 50% of dwellings to be of this size. This expectation for family dwellings for the Borough as a whole would also be applied to the town

centre. However, the existing development plan target of 25% of family units is not being achieved in the town centre with a range of only between 4 and 12% in recent permissions. Looking forward there is likely to be a

preponderance of flatted accommodation although with careful design family housing is possible. Nevertheless the 50% target is unrealistic and leaving

this to be settled on a case-by-case basis would not be effective plan-making.

59. To remedy this, a specific target for family housing in the town centre should be included in the SLP. Based on the information presented during the

examination an expectation of 25% would be both aspirational and realistic and MM19 and MM43 are therefore recommended to confirm this. Keeping

the existing proportion elsewhere in the Borough is justified and would not preclude a higher amount of family housing being provided on Council-led estate renewals such as Beech Tree Place (STC11) and Elm Grove (STC45).

60. Other changes are required to Policy 3 to ensure the detailed wording is effective and that heritage assets and the Action Zone are taken fully into

account in line with national policy (MM18, MM20, MM22, MM23, MM25 & MM26).



15

Tramlink 61. The extension of Tramlink to Sutton is a key component of its transport

strategy to serve future growth in the Borough and to offer more travel choice. The preferred route has been protected in previous development plans. It is

identified by TfL (L.16.F) as a medium term proposal and mentioned in the Mayor’s draft transport strategy. Various feasibility studies have been undertaken already. The next step is to work up the route alignment to a

sufficiently detailed standard to support a Transport and Works Act Order application by 2020. Whilst there are engineering challenges nothing has been

identified that is insuperable.

62. There is a considerable funding gap of around £180/190 million at 2014 prices.

A study is in hand to look in depth at all possible options and there are 18 areas of further investigation. Whilst the scale of the shortfall is considerable TfL considers that there is a realistic prospect of a full funding package being

identified. However, even if this optimism is misplaced, the plan period runs to 2031 and including Tramlink in the SLP will be effective in demonstrating

that there are not major planning impediments. Furthermore, this is a critical part of the future infrastructure of the Borough and having regard to paragraph 41 of the NPPF the support provided by Policy 4 is justified.

63. The possible extension to Belmont is much further ‘down the line’ and can only follow the first phase. It is unfunded and there are some major difficulties

regarding the route. However, the development of the LCH is not reliant on its completion. The policy approach of safeguarding land is aspirational but if this is not undertaken now then there is the prospect that the project would be

stymied in the future. Consequently Policy 4 is justified and sound in this respect subject to modifications that are necessary for clarity and

effectiveness (MM27 & MM28).

Wandle Valley Renewal

64. The Wandle Valley is identified as a Regional Co-ordination Corridor, a Potential Strategic Outer London Development Centre and as a Regional Park

in The London Plan. Policy 5 brings together various initiatives and projects and lists them comprehensively. They comprise a mix of new development and environmental and infrastructure improvements.

65. Any designation of the area as a metropolitan park is outside the scope of the SLP and new and improved recreational facilities are shown on the associated

key diagram. The river corridor is narrow in places and sensitive to change but criterion g) expects development to respect its setting. Historic river structures are covered by Policy 30 on heritage. Provisions are in place to

improve foot and cycle paths but to be effective connectivity proposals should be made more explicit and the commitment to supporting a replacement

pedestrian bridge included (MM30 & MM31).

66. Environmental enhancement of the Beddington Industrial Estate is in hand including the upgrading of Beddington Lane. There is no clear evidence that a

separate target for the amount and tenure of affordable housing in Hackbridge is required. Agreement has been reached between the Council and developers



16

for energy to be provided to the Felnex Trading Estate (S1) by the Sutton

Decentralised Energy Network. There are local concerns about bus services, capacity at Hackbridge station and cycle routes but the Council is not the provider of all of these. The policy seeks to achieve better transport. Whether

a controlled parking zone is required is a separate matter.

67. All in all, subject to some further modifications that are necessary for clarity

(MM32, MM33 & MM34), the detailed provisions of Policy 5 are justified and it will be effective in achieving sustainable place shaping in the Wandle Valley growth corridor.

Conclusion on Issue 4

68. All the policies relating to Sutton’s strategic projects are justified provided the

identified modifications are undertaken and are likely to deliver the relevant strategic objectives.

Issue 5 - Are the policies for commercial growth and for growing employment offer justified, deliverable and consistent with national

policy? Will they be effective? Will the Local Plan ensure the future supply of land available for economic development and its sufficiency and

suitability to meet identified needs? 69. Policy 1 indicates that provision will be made to deliver at least 10 additional

hectares of land for industrial uses. This is to be accomplished by the intensification of floorspace at the Beddington Strategic Industrial Location

(SIL) and is supported by Policy 14 b).

70. In assessing need for industrial land the Council relies on a labour supply growth forecast which correlates with the housing requirement and so seeks to

keep the two in balance. The assumptions made in that methodology do not relate to variables that are likely to fluctuate in Sutton. Furthermore, it is one

of the methods referred to in paragraph 032 of the PPG on Housing and Economic Needs Assessments. However, the TCEDA supports the use of an Experian baseline jobs forecast which estimates a requirement for 21.7 ha

unconstrained by land availability.

71. No method is perfect for forecasting future trends. However, the NPPF refers

to meeting the development needs of business rather than future residents. Furthermore, in the London context there is likely to be substantial movement of workers across Borough boundaries so that relating floorspace to housing

growth is less useful. In addition, there is evidence of immediate demand for industrial floorspace and open storage/yard premises in the Sutton/Croydon

area and vacancy rates across the sub-region are low. Bearing in mind all of these factors the method adopted is not reliable for this purpose.

72. However, a report from June 2017 on London Industrial Land Demand

(R1.B.C) reviews the position across the capital as a whole to 2041. For Sutton the policy approach is to provide capacity as positive net demand for

industrial land is being experienced. Over the plan period this equates to approximately 9 ha of land. Given the scope of the report and its date it can be considered authoritative. Floorspace at Felnex and Wandle Valley Trading

Estates has already been demolished and can be taken to have been ‘factored



17

in’. Primarily because of the findings of the recent London-wide review the

target in the SLP is sufficient and justified.

73. At a plot ratio of 0.4 the requirement is therefore for 40,000 sq m of industrial floorspace to 2031. Following the Phase 1 – Baseline Study (L.11.H) and the

Beddington Regeneration Framework (L.11.I) the SLP refers to the creation of over 50,000 sq m at Beddington by the reconfiguration of over 20 sites.

However, a number can be discounted because they already exceed the 40% ratio, are within MOL or are in existing uses and so are unlikely to come forward. Two areas are safeguarded for waste uses in the South London

Waste Plan. Whilst this will be reviewed after 2021 there is no certainty that these vacant sites will be able to be developed after then and they are not

available now.

74. There are further issues with achieving additional floorspace by intensification.

Additional parking within this heavily-congested estate may well require land. Some areas are small and no mechanisms are in place for site assembly. If sites are to be re-developed then some firms may have to re-locate to achieve

this but businesses at Beddington are quite static and there are limited options as to where they could decant to. Furthermore, some existing uses rely on

extensive open areas to carry out their activities and there is no analysis of the likelihood of development on a site-by-site basis. The irregular configuration of site 23 does not lend itself to expansion. So it is not certain

that all of the identified sites would increase their capacity.

75. On the other hand, there are examples of significant increases in floor area

like the Zotefoams extension of over 4,000 sq m. Some £3 million has also been awarded to address highway and place making issues within the SIL. In addition, the Beddington Industrial Area has been designated as a Business

Improvement District. Therefore the prospects for the modernisation of Beddington are good and worthy of support. However, in the light of the

above factors and the overall track record at Beddington from 2001 it is not realistic to expect that all of the required floorspace can be met by pursuing a policy of intensification alone.

76. Indeed, taking on board the constraints, the Council’s post hearing review (ED44) suggests that some 22,000 sq m could be delivered from this source.

Even if reduced to take account of parking at site 18 this figure is increased by two other sites not previously identified in the Baseline Study. The allocation at Plumpton Way (S54) should be assessed on the basis of new floorspace and

the permission for a completed development at Oldfields Road pre-dated the plan period and so would have formed part of the supply prior to 2016. With

these adjustments total supply would be over 30,000 sq m.

77. In order to ‘bridge the gap’ it is proposed to allocate site S76 on the western side of Beddington Lane (former sludge drying beds) to provide a potential

floorspace of 17,600 sq m. This is designated as MOL. Compared to other MOL parcels considered at Issues and Options stage this site is not within the

Wandle Valley Regional Park. The construction of an energy recovery facility to the west has also significantly weakened its MOL function. If allocated and developed, isolated parcels of land fronting Beddington Lane would be created

at its northern and southern ends but these would be protected by existing designations. The selection of S76 is therefore justified.



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78. Policy 7.17 of The London Plan provides that any alteration to the boundary of

MOL should be undertaken by Boroughs through the plan-making process. As paragraph 7.56 confirms that the Green Belt policies in the NPPF apply equally to MOL, the test is whether there are exceptional circumstances to warrant

this. In this regard following extensive consideration the allocation of site S76 is the only means by which the Council can meet the business needs of the

area thereby providing jobs for residents and reducing out-commuting. There is no scope within other SILs and limited opportunity in neighbouring Boroughs. The intensification of Beddington will not deliver sufficient capacity.

The site itself adjoins the existing SIL and the land does not perform well when judged against the criteria for MOL in The London Plan. The boundaries

are clear and defensible and capable of enduring beyond the plan period as total supply would exceed that required. Overall exceptional circumstances

exist and it is recommended that Policy 14 and relevant paragraphs be modified accordingly (MM29, MM55 & MM56).

79. Therefore, with the modifications referred to, the SLP has the ability to deliver

the 10 additional hectares referred to in Policy 1. As such it will ensure a supply of land for economic development which is sufficient and suitable to

meet identified needs.

80. Policy 14 a) expects that proposals within SILs or Established Industrial Areas

should provide at least one full-time job per 60 sq m of floorspace. The aim of this provision is to ensure that employment sites are used efficiently but it is

rather an unwieldy and blunt instrument to that end. On the basis of the Council’s own evidence about average employment densities it would preclude B8 uses which are supported in these areas. It may also prevent many of the

industrial typologies specifically identified as having market potential within the Beddington SIL.

81. Moreover, implementing the policy would raise various practical difficulties such as if an end user is not known, how it might affect existing businesses wishing to expand that are below the threshold, how the policy would be

verified and whether it could be enforced. Whilst intended as a “bold measure” to make efficient use of industrial land this provision could have the

unintended consequence of inhibiting commercial development that would otherwise make a contribution to the economy. It is not justified or effective and is recommended for deletion as part of MM56.

82. The amount and distribution of town centre and local centre development is justified having regard to the TCEDA subject to the reference to office

development outside Sutton town centre being removed given the very limited demand (MM58). For effectiveness and clarity other changes are required to the wording of Policies 15 and 16 (MM57, MM59, MM60 & MM61). The

evidence also shows that the delivery of retail and food and beverage uses is already taking place and so the provision expected in the centres other than

Sutton is realistic.

83. Therefore, subject to the modifications identified, the policies for commercial growth and for growing employment meet the criteria for soundness.

Issue 6 - Are the policies for meeting housing needs justified, deliverable and consistent with national policy?



19

84. If there is no change in existing trends then there should be sufficient care home provision in the Borough for the initial part of the plan period. After 2021 the position is less clear cut but the Council believes that demand will

decrease due to the policy preference of supporting independent living at home. At the same time the population is ageing and evidence at the hearing

painted a picture of a sector that is heavily regulated and changing hugely as traditional or unsuitable homes close down in favour of new, purpose-built accommodation. There is no compelling evidence that a plethora of care

homes is preventing conventional housing from coming forward.

85. The NPPF refers to planning for the needs of different groups in the community

such as older people but Policy 11 is not positively prepared in this respect. In particular it presumes against further care homes rather than allowing for

them to meet a specific need that is not catered for elsewhere. The policy also requires all works to result in improvements in the level of care. This imposes an unwarranted restriction on necessary ancillary facilities that may not

directly affect care provision. Furthermore, it seeks to prevent concentrations of housing for the elderly and care facilities for which there is no justification.

Those later in life may also be able to access public transport and this option should not be precluded. Modifications MM46, MM47, MM48 & MM49 are recommended to address these findings and to achieve soundness.

86. The density matrix at Table 3.2 of The London Plan has been modified in its application to Sutton taking account of relevant character studies (L.14.E &

L.14.H). This is primarily because the District Centres are generally linear and fairly small so that the extent of the Urban Setting is limited to a 400m walking distance rather than 800m. This approach is justified but to be

effective Policy 7 should be amended to give clarity about the density ranges sought and where they will be applied. I recommend MM35 accordingly.

87. The WMS of March 2015 establishes that the optional technical standards should only be required through new policies if they address a clearly evidenced need and where viability has been considered. Policy 9 reflects the

provisions of The London Plan in relation to internal space standards and accessible and adaptable dwellings. To that extent these are not new policies.

In any event, similar provisions have been in effect since 2011 and are supported by the evidence provided as part of the Minor Alterations which were published in 2016. Consequently these requirements are justified.

88. Compared to neighbouring Boroughs and London as a whole the proportion of houses in multiple occupation (HMO) in Sutton is small. However, some

clusters have been identified in certain streets which have created problems regarding parking and appearance. Concern about the cumulative effects is a valid planning consideration but Policy 10 is too vague. To address this

shortcoming a modification is recommended to specify that within a 100m frontage no more than 20% of properties should be HMOs. The evidence

(ED41) suggests that this is a targeted response that should not be unduly punitive and is consistent with approaches taken elsewhere (MM45). To be justified the provisions of criterion c) should only apply when extensions would

increase the number of residents (MM44).



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89. Paragraph 53 of the NPPF and Policy 3.5 of The London Plan refer to policies

that resist the inappropriate development of rear gardens. In the Sutton context the restrictive approach in Policy 13 is justified on the basis of local character, biodiversity and amenity. However, to be specific and hence

effective there should be a reference to flooding rather than a site making a general significant contribution to climate change objectives (MM54).

90. The Council has considered the needs of those covered by the definition at section 124 of the Housing and Planning Act and not just those within the definition at Annex 1 of the Planning Policy for Traveller Sites (PPTS). Against

this background the Gypsy and Traveller Needs Assessment (L.10.E) identifies an immediate need for 9 pitches in the Borough and for a further 14 pitches

between 2020 and 2029. In response it is proposed to allocate a new site directly to the south of an existing one at The Pastures (S104).

91. The allocation is in the Green Belt and the SLP shows that it would continue to ‘wash over’ it. Green belt boundaries should only be altered in exceptional circumstances. However, the PPTS refers to making a limited alteration,

possibly by creating a site inset, in order to meet a specific identified need. That is exactly the case here. The Council is concerned about the future

implications of removing the designation but there is a distinction between sites with built development already on them and those allocating a use of land. In any case, the PPTS provides that any allocations should be as

traveller sites only and this should be confirmed by MM53 which is recommended for effectiveness.

92. More fundamentally, the SLP would result in any future application for a gypsy and traveller site amounting to inappropriate development and requiring the demonstration of very special circumstances. By not providing certainty this

would cloud the issue and addressing the current overcrowding at The Pastures could be slowed down. All in all, the SLP is not positively prepared in

this respect and neither is the approach effective in facilitating the traditional and nomadic way of life of travellers. In order to tackle this and in the light of my post hearings advice (ED42) it is proposed to remove the site from the

Green Belt.

93. As well as the current need and overcrowding issues, the Council has carried

out an extensive site search and has not been able to identify a suitable location within the urban area. Furthermore, the allocation is the preferred option for a significant proportion of gypsies and travellers and would not

disrupt existing occupiers if re-locating. Developing next to the existing site would also be beneficial in terms of improving highway and pedestrian safety

and would allow a mains gas supply to be considered. All these reasons amount to the exceptional circumstances necessary to justify altering the Green Belt boundary and the SLP should refer to them all for clarity (MM51).

As the site is Council owned there can also be confidence about delivery.

94. The PPTS indicates that for years 6-10 of the plan period a supply of specific,

developable sites or broad locations for growth should be identified and, where possible, for years 11-15. The Council has not been able to do this but rather considers the entire Borough to be a broad location for growth. Given the

constraints encountered in the urban area and the extent of the Green Belt this is a flawed stance. Furthermore, whilst the numbers of pitches required



21

may fluctuate as families move to and from Ireland there is no clear support

for a plan, monitor and manage approach to the provision of traveller sites after the first five years of the SLP.

95. It is proposed to include reference to a review of the need for any further

provision for travellers. The text commits the Council to this course of action and to the submission of a further plan for examination by the end of 2023 if it

is necessary to allocate further sites. In so doing the plan, as modified, would be effective in tackling the matter within a reasonable time span. This change is therefore recommended in order to address the unsoundness of the plan in

this respect (MM50).

96. The detailed criteria in Policy 12 regarding gypsy and traveller accommodation

are fair and reasonable. However, the reference to showing that there is an identified need should be omitted given the position in Sutton and to accord

with paragraph 10 of the PPTS (MM52).

Issue 7 - Are the policies for making centres destinations justified, deliverable and consistent with national policy? Will they be effective?

97. The SLP adequately addresses the function and role of town centres and their

capacity to accommodate new development. In view of the needs of older people, working parents and carers and the increasing numbers that will be living there the addition of community uses to the definition of town centre

uses in the NPPF is justified. To be consistent with the remainder of the SLP, Policy 17 should be adjusted to clarify that there is no express target for office

development outside Sutton town centre. Other changes are required in relation to the delivery of retail and food and drink floorspace to ensure numerical consistency and effectiveness (MM62, MM63, MM64 & MM65).

98. The NPPF refers to defining primary and secondary frontages in designated centres and to setting policies that make clear which uses will be permitted in

such locations. The 75% threshold in Policy 18 for retail (A1) uses in the primary shopping frontages of Sutton town centre is justified given the existing proportions of such uses and the centre’s important role. However,

the policy seeks to maintain 65% of retail uses in the primary frontages of the District Centres. As this figure is currently only exceeded at Carshalton it

would be overly prohibitive and lead to vacancies. Based on the evidence provided a figure of 55% is more realistic and should be inserted together with other wording alterations required for clarity (MM66, MM67 & MM68).

99. The over-concentration and clustering of certain use classes within a specific area is referred to in the PPG on Health and Wellbeing. Hot food takeaways

have had adverse cumulative impacts in terms of litter, noise, smell, traffic and, in some cases, anti-social behaviour (L.11.F). The proposed 20% limitation in criterion e) would only affect a small number of Local Centres

where the effects are most noticeable. In preventing a proliferation in the most sensitive locations the policy is suitably targeted and justified.

100. The introduction of residential uses has also, in some places, created disjointed Local Centres including at Belmont and Angel Hill (L.11.E). This has occurred through re-development as well as through the exercise of permitted

development rights. In order to maintain the vitality of all centres a restriction



22

on the introduction of residential uses is justified. However, to be effective

some flexibility is required to take account of empty premises where conventional town centres uses are no longer viable (MM69).

101. Policy 19 seeks to protect the provision of everyday goods and services in

Local Centres. Such an approach is justified given their health subject to an allowance for non-viable units. However, criterion c) is overly complicated and

for effectiveness should be deleted (MM71). Other changes are also required for clarity (MM70, MM72 & MM73).

Issue 8 - Are the policies for serving communities and for delivering one

planet targets justified, deliverable and consistent with national policy? Will they be effective?

102. The PPG advises that local planning authorities can enable a healthier

environment by supporting opportunities for communities to access a wide range of healthier food production choices. Policy 21 on health and well-being is as supportive as it reasonably can be of the retention and improvement of

such facilities and so reflects this guidance.

103. Policy 22 provides sufficient flexibility for assessing proposals involving the

loss of community facilities but changes are required to the wording for clarity and effectiveness (MM74 & MM75). Although the supporting text refers to Assets of Community Value the process for registering them is a separate one

and the SLP is sound without a policy explaining how applications will be considered. However, for completeness The New Inn in Myrtle Road should be

added to the list of public houses of value (MM76).

104. Policy 31 conforms to Policy 5.2 of The London Plan in expecting major residential developments to achieve ‘zero carbon’ standards. This is by a 35%

reduction in regulated CO2 emissions with, if necessary, a contribution of £60 per tonne to the carbon off-set fund. Given this, the Mayor has stated that it

is not necessary for Boroughs to carry out a further viability assessment. In any event the additional build costs arising from this provision have been included in the Viability Report. The policy is therefore justified subject to

changes to reduce the emphasis on combined heat and power and to promote district heating networks throughout the Borough in order to more closely

reflect the support in the NPPF for a low carbon future (MM98 & MM99).

105. In Policy 32 on flood risk and sustainable drainage some qualification is required to explain how run-off rates will be assessed on previously developed

sites and other changes are needed for effectiveness (MM100, MM101, MM102, MM103, MM104, MM105 & MM106). Policy 34 should include

provisions to the effect that adequate water supply and sewerage infrastructure capacity should exist or be provided. This is to ensure that the environment is protected and that developments can function properly

(MM107, MM108 & MM109). Other changes to the wording of this policy are required for effectiveness (MM111 & MM112).

106. Sutton is within an area of severe water stress. There is therefore a clear local need and there is no evidence that viability would be affected by the inclusion of the optional Building Regulation requirement for water consumption of 110



23

litres/person/day. Due also to the similar provision in Policy 5.15 of The

London Plan, Policy 33 is justified in this respect.

107. The SLP includes policies on carbon and energy and climate change adaptation as referred to above. Furthermore, Policy 32 ensures that run-off rates from

new development are as close as practicable to greenfield ones. Together with policies regarding Wandle Valley renewal, back garden development,

biodiversity and character and design, climate change issues are adequately addressed in line with section 19(1A) of the 2004 Act.

108. Policy 34 expects all development proposals to be air quality neutral in line

with Policy 7.14 of The London Plan. The entire Borough is within an Air Quality Management Area and an Action Plan (AQAP) was produced in 2013.

Wallington and Worcester Park currently exceed the annual and hourly mean statutory limits for nitrogen dioxide although the general trend is for levels to

fall. As part of the AQAP a series of measures have been taken.

109. The policy does not refer to the objectives of the AQAP as referred to in paragraph 124 of the NPPF. Neither does it highlight planning obligations as a

means of providing offsetting measures in support of an air quality action plan in line with the PPG on Air Quality. These omissions should be rectified to

ensure consistency with national policy. To be effective further detail of the expectations for an air quality assessment are also required and the wording adjusted so that it is clear that Policy 34 relates to all of Sutton (MM110).

110. Realistically the SLP cannot ensure compliance with the statutory limits on its own. For example, traffic affecting air pollution in Wallington and Worcester

Park is likely to be partly attributable to trips originating outside the Borough. However, other policies in the SLP set NOx limits on boilers, promote sustainable modes of transport and restrain parking provision and these are

likely to further reduce levels in support of the AQAP. Furthermore, much development will be on previously-developed land and therefore may not lead

to an increase in emission levels. Coupled with the specific requirements in Policy 34 the impact from new development is likely to be neutral.

111. Therefore, as modified, Policy 34 would complement the AQAP and assist in its

implementation. Having regard to cumulative impacts, the SLP would not delay or jeopardise compliance with the statutory limits. As such it is justified

and consistent with national policy in relation to air quality considerations.

Issue 9 - Are the policies for maintaining green spaces and for raising design standards justified, deliverable and consistent with national policy?

Will they be effective? Are there exceptional circumstances that warrant altering Green Belt and Metropolitan Open Land boundaries?

112. Policy 25 seeks to retain existing levels of open space in the Borough and to

enhance it where possible. However, it does not acknowledge the possibility

that any loss could be replaced by provision of an equivalent or better quality and quantity in the local area. To be consistent with paragraph 74 of the NPPF

the policy should be adjusted accordingly (MM81). The PPG recognises the importance of adequate space for food growing opportunities and some strengthening is required to reflect national guidance without making provision

an imperative (MM82). Some bolstering of Policy 26 is required to protect



24

biodiversity value in line with national policy and to reflect the adjacent

Banstead Downs SSSI (MM83). The reference to openness in Policy 27 should be removed so that it is compatible with national Green Belt policy (MM84).

113. Policy 24 envisages the amendment of the Green Belt boundary to remove

areas that have now been developed as housing estates. Given that they make no contribution to the 5 purposes of the Green Belt this is justified and

the alteration would also lead to the creation of recognisable, defensible and permanent boundaries. Similarly the MOL is to be adjusted to reflect changed circumstances at Mayflower Park and to align with an access road. At Grove

Park the land in question is no longer school playing field and has been incorporated into the park and the change will ensure the MOL designation is

coherent. As required by paragraph 83 of the NPPF there are therefore exceptional circumstances that warrant these boundary alterations.

114. The policy and the supporting text also needs to be altered to reflect the findings made about the allocation of land limited to a gypsy and traveller site at Carshalton Road in the Green Belt. Similarly in relation to the removal from

MOL of the site at Beddington Lane and also at Rosehill Recreation Ground for reasons to be explained shortly (MM77, MM78 & MM79).

115. The approach to decision-taking in Policy 24 is not consistent with national policy regarding the Green Belt in relation to the definition of inappropriate development, the treatment of very special circumstances and the effect on

openness. This should be remedied to achieve soundness (MM80). There is no support in the NPPF for specific provision to be made for accommodation

for the elderly in the Green Belt and no evidence that this is the only location in Sutton where this can be accomplished.

116. The Tall Buildings Study (L.14.G) was produced in 2008. Given that the

townscape within the town centres has, by and large, not materially changed since then it can be regarded as forming a robust evidence base. Arising from

its findings are Areas of Tall Building Potential (ATBP) around the District Centres and which are unchanged from the adopted development plan. In Sutton town centre bespoke ATBPs have been devised from the Masterplan.

There is a close correlation between actual building heights of developments completed or under construction and the policy provisions within the ATBPs.

This suggests an effective policy. Whilst there is some disquiet about the scale of development in Hackbridge, the ATBPs have been properly defined.

117. The Taller Building Categories in the Glossary define mid-rise, tall and very tall

buildings. These labels are clear in terms of what is intended and also give definite storey heights. Moreover, it is evident that they have not acted as a

‘cap’ on housing delivery as there are examples of building in excess of 11 storeys within Sutton town centre. Criterion p) of Policy 28 is therefore sound. However, for completeness a further criterion should be added to ensure that

the setting and visual amenity of the Green Belt, MOL, public open space and urban green space is taken into account and other changes are also required

so that the policy is effective (MM85, MM86, MM87 & MM88).

118. Modifications are required to Policy 30 on heritage so that it fully reflects Government policy on conserving and enhancing the historic environment.

This includes views in and out of conservation areas and protecting



25

archaeological remains as well as ensuring that the wording is effective

(MM89, MM90, MM91, MM92, MM93, MM94, MM95, MM96 & MM97).

119. In terms of the public realm Policy 28 contains specific criteria regarding direct, accessible and easily recognisable routes; minimising crime and anti-

social behaviour; creating functional public spaces and the integration of new development into its surroundings. Coupled with the provisions of Policy 9

about accessible dwellings and existing policies in The London Plan, the SLP makes adequate provision for inclusive design and accessible environments in accordance with the NPPF.

Issue 10 - Are the policies for improving the sustainable transport network justified, deliverable and consistent with national policy? Will

they be effective?

120. In general terms the policies of the SLP are balanced in favour of sustainable transport modes as indicated by paragraph 29 of the NPPF. Outside of Sutton town centre the evidence (L.16.C & L.16.G) is that there is sufficient highway

capacity to cope with the extra trips to be generated taking account of mitigation measures. However, to be justified, the list of proposals in Sutton

town centre should be adjusted to reflect those that are critical regardless of Tramlink and those that are not (MM113). Furthermore, in Policy 36 the distinction between the requirements for Transport Assessments or

Statements for major or smaller developments and the support for reducing freight deliveries should be clearly set out (MM114 & MM115).

121. Policy 37 on parking refers to the restraint-based, maximum parking standards and to proposals for car-free development in certain circumstances. However, the standards for dwelling houses in Table 11.4 also refer to

requiring the maximum provision to be made in full in areas with PTAL levels of between 0 and 1 and on a case-by-case basis in PTAL area 2. Furthermore,

where there is a demand and a lower provision would give rise to on-street parking problems, the maximum standard can be exceeded.

122. Sutton has relatively high levels of car ownership which contributes to parking

stress, especially in areas of older housing where there is no off-street provision at some properties (ED36C). The broad approach of the SLP reflects

the Minor Alterations to The London Plan which allow for higher levels of provision in outer Boroughs where residents are dependent on the car. The very varied picture across Sutton means that a ‘one size fits all’ policy

response would not be effective and given this lack of uniformity considering some proposals individually is warranted. Therefore, notwithstanding the

WMS of March 2015, Policy 37 is justified due to the acceptance of minimum standards in the London context. This is subject to a change required for effectiveness (MM116).

Issue 11 - Are the site allocations justified and deliverable within the plan period having regard to any constraints and consistent with national

policy? Is there sufficient detail on form, scale, access and quantum? 123. Policy 41 confirms that planning permission will be granted for development in

accordance with the land uses set out in the individual site allocations. This is both positive and effective. It also contains an “override” clause to permit, in



26

exceptional circumstances, social and community infrastructure that has not

previously been identified. Given the importance of uses of this kind this justifiably allows for flexibility. Similar provisions apply to office development which is also warranted given that the proposed allocations are circumspect in

their response to possible demand. However, clarification of how this will operate in practice is required to ensure that the policy is effective (MM118).

124. As well as specific uses the individual allocations set out an indicative capacity and phasing and a delivery mechanism as well as background information and other matters to have regard to. In this way the detail on form, scale, access

and quantum is generally sufficient. Detailed matters will be resolved as necessary through the development management process and matters such as

affordable housing are covered by Borough-wide policies.

Sutton town centre allocations

125. The expectation at the Kwikfit Site (STC7) for a building of 2 to 4 storeys stepped down towards Lenham Road should ensure a development that fits into its context and safeguards residential living conditions. However, to be

accurate, the site plan should omit the rear service road from within the site boundary (MM121). In order to protect the significance of heritage assets the

importance of views of Trinity Church should be specified at the Civic Centre Site (STC9) (MM122 & MM123). The scale of development proposed at Morrisons Local and Car Park (STC2) is apt for its setting and there is no

compelling evidence that the site should be retained for leisure as opposed to residential and retail uses.

126. The allocation for the Matalan Block (STC25) specifies a range of between 2 and 10 stories for new development. However, it should be made plain that this will step down towards the housing along Lewis Road to the east. To be

justified the design of any scheme should also take account of the presence and operation of the timber yard to the north (MM125 & MM126).

127. Pre-application discussions regarding Land to the Rear of Times Square (STC39) suggest that there may be potential for buildings taller than 8 storeys and for an increase in the stated housing capacity. However, the supporting

text on how to read the site allocations confirms that the number of units given is a guide. The height of buildings specified is derived from the Sutton

Town Centre Masterplan. Its strategy is to concentrate very tall buildings in the elevated area of the town close to the station and to avoid Throwley Way becoming excessively ‘canyon-like’. These principles hold good and there is no

justification for amending the allocation detail as this contains sufficient flexibility should an exemplar design be forthcoming.

Other allocations

128. Although Hackbridge has had a considerable amount of new development the overall proportions given in the SLP within the District Centre and surrounding

Area of Potential Intensification have not been exceeded. There is therefore no reason to preclude further housing on Land Adjoining Hackbridge Station

(S2) especially given its location and previous allocation. However, to be consistent with the supporting text and other allocations outside the town centre, the indicative capacity should reflect the middle band of The London

Plan density matrix and not a higher figure (MM130). The storey height is



27

based on the Tall Buildings Study and there is insufficient evidence to suggest

that its findings should not be followed. From past experience retaining a percentage of the existing employment uses is not feasible.

129. Any development of Hackbridge Station and Car Park (S5) would not come

forward until Phase 3 of the SLP. However, as part of any development the existing on-site station parking would be re-provided so that laying out an

open public square is not realistic. That said, the provision of town centre uses at ground floor and other works would make a greater contribution to the public realm than the site does at present. The broad scale of development

anticipated (4-6 storeys) is consistent with that permitted in the near vicinity.

130. There is no indication that St Helier Hospital (S55) is likely to become

available for residential development during the plan period so allocating it for health uses is justified and sound as a safeguarding measure.

131. The All Weather Pitch and Part of Tennis Centre at Rosehill (S98) is allocated as a secondary school to be built in the first phase of the SLP. The site boundary should be altered to more closely reflect the land required including

that for parking (MM133 & MM134). It is intended that the land remains as MOL. However, in any planning application the proposed school would be

inappropriate development and to be permitted would require very special circumstances to exist. This would not be effective or positive plan-making.

132. The Council is concerned that the wider area would become vulnerable to

development pressure in the event that the land was removed from its existing designation. However, if the extent of the site is tightly drawn as

recommended, there is no reason to suppose that this would be the case and the allocation is specifically for a school. To justify the removal of the site from the MOL there is the critical need for further education provision, the lack

of alternatives and the suitability of the site in terms of location and the chance to share adjoining facilities and open space. In addition, parts of the

site are already developed and the land was identified as a poorly functioning part of the MOL in the Review (L.13.A). Consequently exceptional circumstances to alter the boundary exist in this case.

133. The site allocation includes floodlit tennis courts and a disused all weather pitch. However, there is reference to providing on-site sports facilities and the

provisions of Policy 25, as modified, would apply to future proposals. In this way the SLP ensures that the expectations in paragraph 74 of the NPPF regarding replacement provision will be adhered to.

134. Within the site allocations schedule at Chapter 4 a number of other changes are also required for accuracy and to ensure that the SLP is coherent and

complete in reflecting the modifications previously recommended (MM119, MM120, MM124, MM127, MM128, MM129, MM131, MM132 & MM135). However, there is no need for development at S76 to have regard to the

Waste Plan and monitoring reports relating to it.

Conclusion on issues 5-11

135. Subject to the recommended main modifications referred to above the development management policies of the SLP are justified, consistent with national policy and effective.



28

Issue 12 - Does the Local Plan have clear and effective mechanisms for

implementation, delivery and monitoring?

136. Receipts obtained via the Community Infrastructure Levy will be spent at local

level according to Policy 38 and paragraph P38.3. The Regulation 123 List is due to be revised and this is the mechanism for deciding the exact distribution

of funds. As such, the SLP is sound in this respect. The policy also confirms that obligations will be sought to ensure that new development meets on and off-site requirements directly associated with it. This provides certainty about

implementation and a list of specific infrastructure projects is in Table 2. Therefore in line with the PPG on Local Plans the SLP makes clear for the first

5 years what infrastructure is required, who is going to fund and provide it and how it relates to the anticipated rate and phasing of development.

137. Table 3 of the SLP sets out a comprehensive schedule of measurable indicators

for each policy and, where relevant, targets derived from it or The London

Plan. This is given effect by Policy 39 and so the mechanisms for monitoring are clear and effective.

138. Policy 40 is intended to “add teeth” to the Council’s planning enforcement

function. However, setting out how it will use its powers in this regard is

outside the expectations for plan-making in paragraph 154 of the NPPF and these provisions are statutory in any event. There is no real evidence that

omitting the policy would fetter the Council’s actions in any way and to be consistent with national policy it should be deleted (MM117).

General conformity with The London Plan

139. The Greater London Authority objects to certain aspects of the SLP, as modified, including the allocation of land in Beddington Lane because of its designation as MOL, the omission of the 50% overall Borough-wide target for

affordable housing and the removal of the Rosehill school site from the MOL. However, the need for the recommended modifications including the

exceptional circumstances to justify the loss of MOL has been explained in the report. The London Plan does not wholly preclude these changes and many of the policies of the SLP fully reflect the spatial development strategy. Indeed,

when looked at as a whole, I am satisfied that, as modified, there would be general conformity with The London Plan.

140. There is no need for the Council to give a specific commitment to an early review of the SLP. No doubt it will consider this after the final publication of the new London Plan and the amended Regulations of 2017 will require this to

be completed every 5 years in any event.

Public Sector Equality Duty

141. In undertaking the examination I have had due regard to the equality impacts of the SLP in accordance with the Public Sector Equality Duty, contained in section 149 of the Equality Act 2010. This, amongst other matters, sets out

the need to advance equality of opportunity and foster good relations between people who share a protected characteristic and people who do not share it.

142. There are policies in the SLP that concern accommodation for the elderly, gypsies and travellers and accessible environments that should directly benefit



29

those with protected characteristics. In this way the disadvantages that they

suffer would be minimised and their needs met in so far as they are different to those without a relevant protected characteristic. There is also no compelling evidence that the SLP as a whole would bear disproportionately or

negatively on them or others in this category.

Assessment of Legal Compliance

143. My examination of the compliance of the Plan with the legal requirements is

summarised in the table below. I conclude that the Plan meets them all.

LEGAL REQUIREMENTS

Local Development Scheme (LDS)

The SLP has been prepared in accordance with the Council’s LDS 2014-17.

Statement of Community Involvement (SCI) and

relevant regulations

The SCI was adopted in December 2014. Consultation on the SLP and the proposed main

modifications has complied with its requirements.

Sustainability Appraisal Sustainability appraisal has been carried out and is

adequate.

Habitats Regulations

Assessment (HRA)

The Habitats (Appropriate Assessment) Screening

Report of February 2016 concludes that the SLP would not have a potential significant effect on

European conservation sites and that an appropriate assessment is not required. Natural England has no objections.

National Policy The SLP complies with national policy except where indicated and main modifications are recommended.

2004 Act (as amended) and 2012 Regulations.

The SLP complies with the Act and the Regulations.

Overall Conclusion and Recommendation

144. The plan has a number of deficiencies in respect of soundness for the reasons set out above, which mean that I recommend non-adoption of it as submitted,

in accordance with section 20(7A) of the 2004 Act. These deficiencies have been explored in the main issues set out above.

145. The Council has requested that I recommend main modifications to make the plan sound and capable of adoption. I conclude that with the recommended main modifications set out in the Appendix the Sutton Local Plan 2016-2031

satisfies the requirements of section 20(5) of the 2004 Act and meets the criteria for soundness in the National Planning Policy Framework.

David Smith

INSPECTOR

This report is accompanied by an Appendix containing the Main Modifications.


1

Schedule of Main Modifications to the Sutton Local

Plan 2016-2013

Deletions shown as strikethrough. Additions shown as underlined

Page reference is to Draft Local Plan Submission version (Regulation 19)

Page 764

Agenda Item

8b

2

Ref

Page

Plan Ref Main Modification

MM1 14 Objective 1

Also

updated in later references

in the plan

To meet the borough’s share of London’s future housing need and make a positive contribution to meeting

housing needs across the wider area of south west London.

MM2 15 Objective

15

Also updated in later

references in the plan

To improve public transport within the borough and across south London, and secure improvements to the

road network to address the impacts of new development where necessary.

Page 765

Agenda Item

8b

3

Ref

Page


MM3 18 Policy 1a When considering development proposals the council will take a positive approach that reflects the presumption in favour of sustainable development contained in the National Planning Policy

Framework. It will always work proactively with applicants jointly to find solutions which mean that proposals can be approved wherever possible, and to secure development that improves the

economic, social and environmental conditions in the area. Planning applications that accord with the policies in this Local Plan will be approved without delay, unless material considerations indicate otherwise. Where there are no Policies relevant to the application or relevant policies are out of date

at the time of making the decision then the council will grant permission unless material considerations indicate otherwise - taking into account whether:

(1) Any adverse impacts of granting permission would significantly and demonstrably outweigh the benefits, when assessed against the policies in the National Planning Policy Framework taken as a

whole, or: (2) Specific policies in that Framework indicate that development should be restricted.

When considering development proposals the council will take a positive approach that reflects the presumption in favour of sustainable development contained in the National Planning Policy

Framework. The council will create the conditions for sustainable growth to deliver homes, jobs, thriving centres

and improved infrastructure. The council will protect and enhance the borough’s natural and historic environment. The council will harness the benefits of sustainable development for those who live

and work in the borough.

MM4 18 Policy 1b The council will make provision for enable the delivery of new homes to help meet London's housing needs and local housing needs by aiming to deliver at least 6,405 new homes over the plan period 2016-2031 (427 homes per annum), subject to any subsequent borough target approved by the Mayor of London over the plan

period.

Page 766

Agenda Item

8b

4

Ref

Page


MM5 19 Policy 1c In order to achieve this target, the council will allocate strategic sites for housing delivery, promote the redevelopment of Sutton Town Centre including with taller buildings where appropriate in the Areas of

Taller Building Potential, encourage the intensification of areas around Sutton town centre and the borough's District Centres where appropriate suitable.

MM6 19 Policy 1e To ensure a sustainable and balanced borough and to limit out-commuting over the plan period the council will make provision to deliver enable the delivery of at least 10 additional hectares of land for industrial uses,

23,000m² additional gross office floorspace, 36,000 39,000 m2 additional gross square metres retail floorspace and 10,000m² additional gross floorspace for restaurants, cafes and other appropriate food and beverage outlets, subject to Policy 18e. Figures exclude additional floorspace expected at the London

Cancer Hub (see Policy 2).

MM7 19 Policy 1f In order to achieve these targets, the council will allocate strategic sites for industry, offices, shops and

appropriate food and beverage outlets, (subject to Policy 18e) work with development partners to deliver the London Cancer Hub, encourage the re-configuration of industrial areas to make a more efficient use of land,

introduce a job density floor to ensure new industrial floorspace is used efficiently, promote the redevelopment of outdated office space to meet modern requirements, encourage, in the right circumstances, the amalgamation of shop floorplates to provide space to meet modern retail requirements and

apply a flexible approach to town centre uses relax shopping frontage policy to enable town centre uses other than shops to locate in town centres.

MM8 19 Policy 1g To ensure a liveable and inclusive borough, the council will make provision to deliver enable the delivery of a tram extension to Sutton Town Centre and the London Cancer Hub, work to improve services, links and

frequencies as well as other transport infrastructure within the borough and across the region and will make provision for enable the delivery of six new or expanded health centres, three new primary schools, two new secondary schools and over 40 hectares of public open space.

MM9 19

Policy 1h In order to achieve these targets, the council will safeguard tram routes and work with the Mayor of London on the delivery of the tram extension, work with the appropriate relevant authorities to ensure an upgrade in

public transport, allocate appropriate sites for health centres and schools and deliver the Wandle Valley Regional Park.

Page 767

Agenda Item

8b

5

Ref

Page


MM10 22 Policy 2a The council will work with its partners, the Institute of Cancer Research, the Royal Marsden NHS Foundation Trust, the Epsom and St Helier University Hospitals NHS Trust and the Greater London Authority, to deliver

about 280,000m2 additional gross mixed use floorspace at the London Cancer Hub according to Local Plan Site Allocation LCH1.

MM11 22 Policy 2b

NB: Subsequent clauses to

be renumbered

However, as this is a key development site, the council, in consultation with the partners, may also permit residential development on any appropriate part of the site which is demonstrated not to be

required for the allocated uses. The council will monitor the progress of the development of the site and review the allocation and report any amendments through its Monitoring Report.

MM12 22 Policy 2c Each ‘development wave’ will only be occupied once the appropriate necessary transport interventions have been implemented, unless equivalent means of alternative mitigation have been identified and implemented. A

full transport assessment and travel plan will be required to accompany any planning applications for the development of all or any part of the site.

MM13 22 Policy 2d Should the Belmont Allotment part of the site be required for the allocated uses, it should not be developed until suitable and appropriate allotments of at least the same number and horticultural quality are available for immediate use elsewhere on the site and with the necessary facilities to enable cultivation.

MM14 23 P2.6

NB: Subsequent

paragraphs to be renumbered

While the council considers that the prognosis for the success of the London Cancer Hub is good, it is aware that the occupation of the research and development floorspace cannot be guaranteed. Therefore, in light of the

National Planning Policy Framework's statement that "Local Plans should allocate sites to promote development and the flexible use of land" (Paragraph 157) and to avoid potential planning blight,

the council has formulated clause (b) of the policy to ensure that, if occupation of the research and development floorspace is below the anticipated rate of demand with no immediate prospect of this being reversed, residential development could substitute without delay and without the need for a

revised allocation.

Page 768

Agenda Item

8b

6

Ref

Page


MM15 25 Paragraph 2.14

Add at the end of Paragraph 2.14: A full transport assessment will need to accompany any planning application submitted for the

proposed London Cancer Hub development setting out the transport impact of the development and how it is proposed to mitigate that impact. Travel Plans for the various different users on the site

will be required to encourage the use of sustainable modes of travel. This requirement is set out in Policy 36 and the council’s Supplementary Planning Document ‘Transport Assessments and Travel Plans’ (or any successor document).

MM16 25 Paragraph 2.14 a

Insert new Paragraph (P2.14a) after existing Paragraph P2.14 Further work will be necessary to establish the location and scale of transport improvements to

support the LCH proposals as they are refined. In this regard, the council will continue joint working with adjoining authorities including Epsom and Ewell Borough Council, Reigate and Banstead

Borough Council and Surrey County Council to establish the impact of the proposals on the local road network both within and outside the borough and how that might be mitigated and funded in the context of the existing transport network and other development proposals.

MM17 25 Table of Transport

Improve-ments

(Wave 0)

Add 2nd bullet point to text in third column of table under Wave 0 as follows: ● Enhancements to local bus services to serve the proposed new secondary school.

MM18 28 Policy 3a The council will work with residents, community groups, businesses, landowners and developers and relevant

bodies to deliver a comprehensive redevelopment of approach to developments in Sutton Town Centre, having regard to the Sutton Town Centre Master plan, the Heritage Action Zone designation and other material considerations.

Page 769

Agenda Item

8b

7

Ref

Page


MM19 28 Policy 3b The council will make provision for enable the delivery of at least 3,400 new homes in the plan period 2016-2031 within Sutton Town Centre and its Area of Potential Intensification (227 new homes per year). The

council will expect housing developments to provide a range of tenures and dwelling sizes. and provide particularly 1- and 2-bed affordable housing and 2- and 3-bed market housing. All developments

should seek to provide a minimum of 25% of all dwellings on the site as having three bedrooms or more, unless it can be demonstrated that this would be unviable or the particular site circumstances are not suitable for family housing. The council will also investigate the feasibility of the redevelopment of

the following estates: Chaucer Estate, Benhill Estate, Rosebery Gardens, Collingwood Estate, and Sutton Court. These will appear on the Policies Map as ‘Potential Renewal Areas’, and, subject to feasibility and viability

studies, the council may bring these estates forward through an Area Action Plan which will ensure full resident consultation. However, the redevelopment of the estates can only take place with infrastructure improvements,

in particular inprovements improvements in transport infrastructure such as Tramlink.

MM20 28 Policy 3c The council will make provision for enable the delivery of at least 3,000m² gross convenience retail floorspace and at least 23,200m2 gross comparison retail floorspace and 5,000m2 gross food and beverage

floorspace in Sutton Town Centre. The council will expect much of the new floorspace to be delivered by reconfiguring the shopping centres, retail floorspace on the ground floor of mixed use developments and,

where appropriate subject to the site allocations, new or redeveloped floorspace providing solely retail floorspace. The council will expect a significant proportion of food and beverage floorspace to be delivered in

the area south of Hill Road and will promote the area as a restaurant and café and cultural centre. However, food and beverage floorspace may be delivered elsewhere in the centre (see also Policy 18).

MM21 29 Policy 3d The council will make provision for enable the delivery of at least 17,000 23,000 m2 gross office

floorspace within Sutton Town Centre. The council will expect much of this office floorspace to be delivered around Sutton station. In particular, the council will support single occupier office developments and

developments for start-ups and small companies. (see also Policy 16)

Page 770

Agenda Item

8b

8

Ref

Page


MM22 29 Policy 3e In particular, within and adjoining the Sutton High Street Crossroads Conservation Area, new development should conserve and, where appropriate practicable, enhance the significance of heritage assets and their

settings. New development Developments should also respond positively to other heritage assets that make a positive contribution to the Town Centre, including those identified in the Sutton Masterplan.

Proposals for taller buildings must be of the highest quality and justify their presence in the townscape through careful consideration of the existing positive features in the area. conform to the taller building zones and the taller building requirements of Policy 28

MM23 29 Policy 3f The council will support proposals to soften the effects of the gyratory. In particular, the council will encourage the creation of active frontages along St Nicholas Way and Throwley Way, the introduction of soft landscaping

and measures to create a pedestrian friendly environment along the gyratory and to reduce the barrier effect of the gyratory for pedestrians intending to visit the High Street. The council will also support the removal of the

Hill Road underpass under St Nicholas Way and introduce measures to improve other existing roads and alleyways in the town centre and seek to improve the setting of Trinity church.

MM24 29 Policy 3g The council will encourage the development of new infrastructure to serve Sutton Town Centre and to improve the environment for residents, shoppers, employees and visitors. In particular, the council will continue to work with Transport for London to deliver a Tramlink service to Sutton Town Centre (as set out in Policy 4) and

seek to transform the existing gyratory system to make the roads less traffic dominated (see Policy 35). The council will work to improve east-west pedestrian and cycle movements, provide a new traffic

management scheme at Burnell Road/Lewis Road, a new road link between Brighton Road and Grove Road and implement junction improvements (as set out in Policy 35), as required, in particular improvements to the junction of Throwley Way/Carshalton Road. The council will help to provide a new

primary school on the Secombe Centre Theatre site (Site Allocation STC10). The council will expect new developments, where feasible and appropriate practicable, to be future-proofed to enable connection to any

future district heat network.

Page 771

Agenda Item

8b

9

Ref

Page


MM25 29 Policy 3h All new development should incorporate the requirements of site allocations STC1-STC45 later in this document, where applicable, and have regard to the Sutton Town Centre Masterplan and the town centre’s distinctive

heritage. Please note the site allocations are flexible for most sites and are not prescriptive regarding floorspace for each land use. Instead, a site allocation can be mixed use or mono-use. This enables businesses

wishing to have their own office premises or large retailers to be able to locate in Sutton Town Centre without the requirement to provide other uses on site, providing that this does nor not result in an underdevelopment of the site. Nevertheless, the council will monitor floorspace development within Sutton Town Centre by use

class to ensure development is occurring in the quantity required for each land use.

MM26 30 Map Under ‘South Sutton’ insert:

● An improved setting for Trinity Church as a distinct local landmark.

Under ‘Station Gateway’ insert: ● Improvements to heritage assets, existing buildings and the setting of the Baptist church.

MM27 31 Policy 4 1stpara

The council will work with Transport for London (TfL) and other stakeholders to deliver the following strategic improvements to the transport network and where appropriate necessary safeguard land to ensure the scheme(s) can be implemented

MM28 31 Policy 4a The construction of an extension of the existing Tramlink network to Sutton Town Centre and Belmont (the London Cancer Hub, Site Allocation LCH1). The council has identified a number of alternative alignments

between the borough boundary with LB Merton and Sutton Town Centre which it will safeguard as shown on the Policies Map and in Maps 11.1 to 11.3 of the Plan. The council will work with TfL to identify an appropriate

suitable route for a further tram extension from Sutton Town Centre to Belmont as shown on the Policies Map and Map 11.4.

MM29 35 Policy 5 c The council will: work with developers to deliver new, improved industrial premises at the Felnex site in Hackbridge and

the Wandle Valley Trading Estate, Beddington Corner.

work with the Greater London Authority and landowners to deliver a more efficient use of land on the Beddington Industrial Estate.

designate Land to the West of Beddington Lane (Site Allocation S76) as an extension to the Strategic Industrial Location

Page 772

Agenda Item

8b

10

Ref

Page


MM30 35 Policy 5d The council will: seek to deliver decentralised energy to new homes, including the Felnex site in Hackbridge initially and

then beyond as part of further progress deliver a new primary school, with high sustainability standards, on the land north of BedZED, Hackbridge

(Site Allocation S2 S3). work with the Sutton Clinical Commissioning Group to deliver new health facilities on the Felnex site,

Hackbridge.

work with Network Rail to produce an improved station and forecourt at Hackbridge (Site Allocation S5). work with partners and landowners to create and improve foot and cycle paths across the area, notably

foot and cycle routes to Mitcham Junction and towards Croydon from Hackbridge, and crossing improvements at London Road, Hackbridge for access to the railway station.

support the Wandle Valley Forum to lead on securing external funding for a replacement pedestrian bridge

MM31 35 Policy 5f

4th bullet point

seek to improve the pedestrian link between Mill Green and Poulter Park in line with the Poulter Park

Development Plan.

MM32 36 Policy 5h The council will encourage community representatives to collaborate to fund local projects, using the in accordance

with the Community Fund Scheme. encourage community groups work with the Wandle Valley Regional Park Trust to deliver a new

local facility at Culvers Lodge, Hackbridge.

work with the Greater London Authority to support the Beddington Business Improvement District Steering Group deliver its objectives.

work with the Hackbridge and Beddington Corner Neighbourhood Forum to produce a neighbourhood plan. work with the Beddington North Neighbourhood Forum to produce a neighbourhood plan.

Page 773

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8b

11

Ref

Page


MM33 36 Policy 5i The council will work with Transport for London (Sustrans), the Environment Agency, Thames Water, The London Wildlife Trust, the Wandle Valley Regional Park Working Group Trust, Groundwork London and The

Wandle Trust to: improve the water quality of the river, in particular lowering levels of phosphates and limiting sewage and

road run-off. expand the network of walking and cycling routes, including the Wandle Trail. enhance the river banks for biodiversity by removing hard infrastructure.

take a river-wide corridor approach to manage flooding, make adaptations to climate change and provide sustainable drainage.

mitigate or remove the effects of barriers on wildlife movement. seek to improve the visual appearance and biodiversity value of the Beddington Carrier.

achieve good ecological potential for the River Wandle by 2027.

MM34 38 Key and Map

Wandle Valley Regional Park Green Spaces Safeguarded for the Wandle Valley Regional Park

Amended boundary of ‘New or Improved Employment Areas’

Page 774

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12

Ref

Page


MM35 47 Policy 7 Local Character a The council will permit new dwellings and conversions of existing properties provided the density is

appropriate suitable to the local character and taking into account the characteristics of Conservation Areas, Areas of Special Local Character and respecting the Suburban Heartlands.

Within Sutton Town Centre ab As a guide, the council will expect new developments to be within the Central Setting of the London Plan

Density Matrix (see Table 1 below). This will be applied within the Sutton Town Centre boundary (see Appendix 1, Map 1.1 and Policies Map).

Within the Sutton Town Centre Area of Potential Intensification

bc As a guide, the council will expect new developments to be within the Urban Setting of the London Plan Density Matrix (see Table 1 below). This will be applied to an area within approximately 800 metres walking distance of Sutton Town Centre (see Appendix 1, Map 1.1 and Policies Map).

Within District Centres and the Areas of Potential Intensification

cd As a guide, the council will expect new developments to be within the Urban Setting of the London Plan Density Matrix (see Table 1 below). This will be applied to an area within approximately 400 metres walking distance of a district centre (see Appendix 1, Maps 1.2-1.8 and Policies Map).

Within the Suburban Heartlands (all other residential areas)

de Developments should maintain and seek to enhance the quality of the borough's environment ensuring all new development respects the positive features of Sutton's character, reinforcing local distinctiveness and a sense of identity. The council will apply the Suburban Setting of the London Plan Density Matrix (see

Table 1 below) to these areas.

For Areas of Potential Intensification see Appendix 1, Maps 1.1 to 1.8 and Policies Map Add Table 1 under Advice on Meeting the Policy:

Page 775

Agenda Item

8b

13

Ref

Page


Table 1: London Plan Density Matrix

Setting Public Transport Accessibility Level (PTAL)

0 to 1 2 to 3 4 to 6

Suburban

35-55 u/ha 35-65 u/ha 45-90 u/ha

40-65 u/ha 40-80 u/ha 55-115 u/ha

50-75 u/ha 50-95 u/ha 70-130 u/ha

Urban

35-65 u/ha 45-120 u/ha 45-185 u/ha

40-80 u/ha 55-145 u/ha 55-225 u/ha

50-95 u/ha 70-170 u/ha 70-260 u/ha

Central

35-80 u/ha 65-170 u/ha 140-290 u/ha

40-110 u/ha 80-210 u/ha 175-355 u/ha

50-110 u/ha 100-240 u/ha 215-405 u/ha

MM36 48 Paragraphs

8.3 – 8.4

P8.3 In the context of the borough, small sites make a significant contribution to housing supply. An

analysis of housing completions in the borough between 1 April 2010 and 31 March 2016 (see table below) shows that out of a total of 2,574 completions, 888 units were completed in schemes that

provided fewer than 11 units (the new national affordable housing threshold). This represents a substantial percentage of all completions (34.5%), which is not contributing towards affordable

housing provision. P8.4 Given the relatively high house prices in the borough; the fact that considerable need for

affordable housing has been demonstrated by the council's SHMA; and the fact that small sites contribute significantly towards housing provision in the borough, it is considered that all housing

should contribute in some way towards the provision of affordable housing in the borough to ensure maximum provision over the Local Plan period (2016-2031).

Page 776

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14

Ref

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MM37 49 Policy 8 a-c

a The council will seek to maximise affordable housing from all sources meet an overall borough-wide target that 50% of all new housing from all sources is affordable, of which 75% should be for

social/affordable rent and 25% intermediate, in accordance with the council's Strategic Housing Market Assessment (GL Hearn, May 2015).

b A contribution towards affordable housing will be expected on housing sites: (i) capable of delivering 11 units or more gross or which have a maximum combined gross floorspace of more

than 1000m². (ii) on sites below the threshold of "capable of 11 or more gross units or a maximum combined

gross floorspace of 1,000m²", a financial contribution to the Sutton ‘Affordable Housing Fund’ will be sought.

c The council will seek a minimum of 35% of all dwellings to be affordable on a site the maximum

reasonable amount of affordable housing when negotiating on individual private residential and

mixed-use schemes. The council will have regard to: (i) individual site costs.

(ii) economic viability. (iii) the availability of public subsidy. (iv) any other scheme requirements.

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15

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MM38 49 Policy 8d d The council will expect the affordable housing contributions for developments of 11 units or more gross to be made on-site but, in exceptional cases, where it can be demonstrated that it would be more beneficial to

the council's affordable housing objectives, the council may accept the provision of affordable housing off- site, or a payment in lieu.

e Where schemes are brought forward for ten or fewer dwellings, the developer will need to satisfy the council that:

(i) the proposal does not represent an underdevelopment of the site with having regard to the character

of the area, the level of public transport accessibility (PTAL rating) and the London Plan Density Matrix (see Policy 7 (Housing Density), or:

(ii) a large site is not brought forward in phases to avoid the threshold at each stage. In such circumstances, the council will apply the affordable housing target to subsequent phases based on the

capacity of all phases, including those already permitted or built.

MM39 49 Paragraph P8.5

The policy applies to all new housing developments, including changes of use for wholly residential and mixed use sites incorporating residential use, where planning permission is required. In considering whether sites

are capable of delivering 11 units or more, the council will have regard to the character of the area, the level of public transport accessibility (PTAL rating) and the London Plan Density Matrix.


In order to meet the borough-wide target, the council will seek to achieve 50% affordable housing provision on all sites capable of delivering 11 units or more gross and which have a maximum

combined gross floorspace of more than 1,000m², either in terms of the number of units on site, or the overall residential floorspace of the development and that 75% of the units should be for social or affordable rent. The council will also seek a payment of £X per unit on sites below the threshold

of being "capable of delivering 11 units or more gross units or a maximum combined gross floorspace of 1,000m²". The council recognises, however, that it may not be financially viable to

provide 50% affordable housing on all individual sites, or a contribution below the threshold of 11 units.

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In considering proposed developments, the council will take into account the economic viability of a scheme and the most effective use of public subsidy, as well as any particular costs associated with the development of the

scheme. In such cases, the council will request that the developer provides a financial appraisal of the scheme so that a fair contribution can be agreed, subject to the Mayor of London’s Affordable Housing and

Viability Supplementary Planning Guidance (2017): Homes for Londoners. The GLA Affordable Housing "Three Dragons" Toolkit can be used for this purpose. The council will nonetheless expect developers to have taken into consideration any abnormal costs in developing a site before acquiring the land. This should include

consulting the council on any particular policies or planning obligations relevant to the development of the site.

MM42 50 After

Paragraph 8.8

8.8a Further details on the council’s approach to seeking affordable housing both on- and off-site

along with how the council will apply this policy to maximise the delivery of affordable housing on larger sites that may be developed in phases can be found in the council’s Affordable Housing SPD

(or any successor document).

MM43 52 Policy 9b In terms of dwelling sizes:

(i) All developments within Sutton Town Centre should seek to provide a minimum of 25% of all dwellings on the site as having three bedrooms or more, unless it can be demonstrated that this would be unviable or the particular site circumstances are not suitable for family housing

(ii) , all All developments outside Sutton Town Centre should seek to provide a minimum of 50% of all dwellings on the site as having three bedrooms or more, unless it can be demonstrated that this would be

inappropriate unsuitable to the location or not viable.

MM44 55 Policy 10c

(first sentence)

Proposals for and extensions which result in an increase in residents to large houses in multiple occupation

(seven people or more) will be permitted, provided that the proposal:

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Agenda Item

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MM45 55 Policy 10c After Part (c) clause (vi): delete clause (vii) and add part (d):

(vii) Does not lead to a concentration of HMOs in the vicinity where the cumulative effect of the HMOs harms the character of the area (see Policy 28).

(d) Proposals for new large houses in multiple occupation (HMO, seven people or more) will be permitted, provided that the proposal does not lead to a concentration of HMOs in the vicinity where

the cumulative effect of the HMOs harms the character of the area. Concentration which harms the area will be considered as where more than 20% of properties 100 metres either side of the

proposal site are HMOs, with an HMO defined as student accommodation, houses recorded or known to be an HMO by the council or properties with a C4/Sui Generis planning permission.

MM46 57 Policy 11a (a) New care homes for older people will not be permitted unless where they meet a specific need that is not provided by other existing care homes in the borough.

MM47 57 Policy 11b NB: Subsequent

clauses to be

renumbered

(b) Redevelopments of and alterations and extensions to care homes for older people will not be permitted if the proposals do not result in an improvement in the level of care.

MM48 57 Policy 11 d Planning permissions for Housing with Care for Older People, Sheltered Housing and Retirement Housing will be

granted, provided that: (i) The site is within reasonable walking distance of shops and services. (ii) The the proposal provides accommodation of a type that is designed to meet the needs of older people.

(iii) The proposal does not lead to a concentration of older peoples' housing in the vicinity where the cumulative effect harms the character of the area or the vitality of local shops and services.

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Agenda Item

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MM49 57 Policy 11 e Planning permissions for Housing with Care for Vulnerable Groups and Residential Units for Young People in Need of Support will be granted provided that:

(i) The site is within reasonable walking distance of shops and services and has good public transport accessibility.

(ii) The proposal provides accommodation of a type that is designed to meet the needs of the client group. (iii) The proposal does not lead to a concentration of care facilities in the vicinity where the

cumulative effect harms the character of the area or the vitality of local shops and services.


The council has decided to meet the immediate need of 9 pitches only. This is because it will deal with the current overcrowding and that planning for any further into the future is difficult. As the need

figures are relatively small, any fluctuation in the current Gypsy and Traveller population could have a big effect on the need figure. For instance, if two families decided to relocate, the need figure

could reduce by 8 over the 15-year plan period. Therefore, with nine new pitches provided, the residual need could shrink to six. However, the council will undertake a further review of Gypsy and Traveller need and potential sites in the first five years of the plan period to meet any outstanding

need over the 15-year plan period. If necessary to allocate additional site(s) to meet this need, a development plan document will be submitted for examination before the end of 2023.


6 An extensive site search and consultation identified no suitable site within the urban area 7 A second “greenfield” site search showed an extension to the existing site was the most

appropriate option

MM52 60 Policy 12

Page 60, 1st sentence

Planning permission for further Gypsy and Traveller sites will only be permitted when a site meets an

identified need and satisfies the following criteria:

MM53 60 Policy 12 Last line

Safeguarded for Gypsy and Traveller sites Land Limited to Gypsy and Traveller Sites’

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Agenda Item

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MM54 62 Policy 13a-d

The council will not grant planning permission for the development of back garden land where the site, either individually or as part of a larger street block:

a Makes an important contribution to the character and appearance of the surrounding area.

b Is considered to be of local ecological value by the council. c Is likely to make a significant contribution to mitigating the impacts of climate change minimising the

risk of flooding in Flood Zones 2 and above or in a critical drainage area.

d Where the development of the site would adversely affect the amenity of future occupiers or those currently occupying adjoining or nearby properties.


The council will employ three measures to ensure employment land supply matches demand. Firstly it will make every effort to retain existing employment land. Secondly, it has undertaken a study of the Beddington Strategic

Industrial Location and found that, if existing employment sites were intensified, additional floorspace could be created. Thirdly, the council will release some land west of Beddington Lane to provide additional employment land. so that 0.4 of the site area was used as floorspace, an additional 50,269m² could

be created. However, it is unlikely that all this would be developed and so the council will also consider applications according to a job density floor. Any application providing less than one job

per 60m² will be refused. According to the Employment Density Guide (Homes and Communities Agency, 2015), this threshold would mean applications for uses B1(b), B1(c), B2 and Mixed B Class

uses would be acceptable but other land hungry-low employment uses would not.

Page 782

Agenda Item

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20

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a Within Strategic Industrial Locations and Established Industrial Areas, the council will grant planning permission for B1-b (research and development), B1-c (light industrial), B2 (industrial and manufacturing)

and B8 (storage and distribution) uses or other similar industrial uses only, provided that the proposal will provide one full-time job or equivalent per 60m² of floorspace or denser.

b The council will support proposals which intensify industrial floorspace in the Beddington Strategic Industrial Location either by the reconfiguration of sites or the amalgamation of sites.

c The council has designated Land to the West of Beddington Lane (Site Allocation S76) as an

extension to the Beddington Strategic Industrial Location. c d Outside the Strategic Industrial Locations and Established Industrial Areas, proposals resulting in the loss of

industrial / business floorspace will not be granted planning permission unless it can be demonstrated that:

(i) The retention of existing use will have an adverse effect on residential amenity and there is no reasonable prospect that this effect can be alleviated by retaining the use.

(ii) There is genuine evidence that the site has been marketed for a period of 12 months at an appropriate

rate a reasonable market rent for its location and condition

MM57 66 Policy 15 a Within Strategic Industrial Locations and Established Industrial Areas, development will be expected to

contribute to environmental and transport improvements, either through on-site works or through planning obligations, where appropriate necessary.

b The council will grant permissions for proposals containing trade counters, provided that the display and sales areas are a maximum of 15% of the total net floorspace.

c The council will grant permissions for ancillary uses which will assist the functioning of the Strategic

Industrial Locations and Established Industrial Areas, such as small shops and cafes, provided that it can be shown that the use meets only the needs of the employees within the industrial area.

d The council will support proposals from green businesses (excluding waste management, waste recovery, recycling and transfer which are covered in the South London Waste Plan), where they are appropriate suitable for the location proposed.

MM58 68 Policy 16a The council will make provision for enable the delivery of 23,000m² of new B1(a) office space over the plan period, of which approximately 70 per cent should all is likely to be in Sutton Town Centre.

Page 783

Agenda Item

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21

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MM59 68 Policy 16 b The council will support the development of office buildings providing company headquarters and small complexes of self-contained offices with an appropriate level of parking, commensurate with the parking

standards, in suitable locations.

MM60 68 Policy 16 c The council will not grant planning permission for proposals involving the loss of existing B1(a) office

accommodation unless it is shown that the office accommodation is no longer required. The need for the particular office accommodation will be assessed against:

(i) Proof of marketing for a 12-month period at an appropriate reasonable market value with a recognised agent. For proposals in Sutton Town Centre, an independent survey of office demand for the particular office type should be submitted with the application.

(ii) Proof that opportunities to reconfigure and reuse the accommodation as offices have been exhausted.

MM61 68 Policy 16 d If office space has been demonstrated no longer to be required, proposals involving the loss of ground floors

office space in town centres will be required to be replaced by an appropriate (an)other town centre use(s) (see Glossary).

MM62 70 Policy 17a The council will make provision to deliver approximately 6,000m2 of gross office floorspace outside of Sutton Town Centre, primarily in Wallington and Carshalton but also in other suitable locations.

permit windfall office floorspace in District Centres and other suitable locations, subject to other policies in the plan.

MM63 70 Policy 17b The council will make provision to deliver enable the delivery of approximately 7,200m² of gross convenience retail floorspace in the following locations: circa 75% in the Wallington and Hackbridge District Centres, 15% in Cheam, 5% in North Cheam and 5% in Carshalton

MM64 71 Policy 17c The council will make provision to deliver enable the delivery of approximately 2,220 5,000 m2 of gross comparison retail floorspace in the following locations: circa 75% 90% in Wallington and Hackbridge District

Centres and 25% 10% in Carshalton

MM65 71 Policy 17d The council will make provision to deliver enable the delivery of approximately 5,000m² of gross food and

beverage floorspace in the following locations 50% in the District Centres and 50% in the Local Centres.

Page 784

Agenda Item

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22

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MM66 73 Policy 18a Within Sutton Town Centre, District Centres and Local Centres, the council will grant planning permission for new development that:

(i) is appropriate suitable to the scale, role, function and the character of the centre and its catchment (ii) makes the optimum use of the site providing a town centre use or mix of town centre uses appropriate

suitable to the scale of the development and its location within the centre. (iii)provides active frontages at ground floor level and is compatible with council's requirements on shopping

frontages.

MM67 73 Policy 18c Within the Primary Shopping Frontages of District Centres, the council will expect the proportion of A1 (retail) ground floor units not to fall below 65 55% and that there should not be more than three adjoining non-A1

uses within the Primary Shopping Frontage.

MM68 73 Policy 18d Within the Secondary Shopping Frontages of Sutton Town Centre and District Centres, the council will consider

other town centres uses (for definition see glossary and box above) as appropriate suitable uses provided that the proposed development does not result in more than three adjoining non-A1 uses.

MM69 73 Policy 18f Within Shopping Frontages and Local Centres the council will not grant planning permission for conversions or change of use which result in C2/C3/C4 (residential) ground floor uses, where permission is required, unless

the unit is vacant and it has been demonstrated that it has been marketed at an reasonable market rent through a recognised agent for 12 months.

MM70 75 Policy 19b In addition to the existing local centres, the The council will not grant planning permission for the change of use from A1 uses (particularly those involving cold food sales, newsagents, chemists and post offices) to other uses unless it is demonstrated that:

(i) An A1 use providing similar goods is easily accessible to serve local residents. (ii) The shop unit has been marketed at an appropriate a reasonable market rent with a recognised agent

for 12 months. (iii) Proposals will not lead to an over-concentration of single uses.

Page 785

Agenda Item

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23

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MM71 75 Policy 19c

NB: Subsequent

clauses to be renumbered

Aside from A1 uses, the council will permit the change of use between town centre uses, provided that:

(i) Convenient local shopping facilities are maintained. (ii) Proposals will not lead to an over-concentration of single uses.

MM72 75 Policy 19d Outside town and local centres, the council will not grant planning permission for the loss of A1 shops within areas of more than 400 metres walking distance from alternative shopping facilities, unless it has been

demonstrated and that the shop has been marketed at an appropriate a reasonable market rent through a recognised agent for 12 months.

MM73 75 Policy 19e The council will encourage new convenience shops within existing communities or as part of new development provided that the proposals are of an appropriate a suitable scale to the locality.

MM74 82 Policy 22a The council will grant planning permission for the development of social and community infrastructure (as defined in the glossary) where it:

(i) is accessible by a range of transport modes, in particular by walking, cycling and public transport. (ii) provides flexible and adaptable space, where appropriate practicable. (iii) is close to or accessible to the community it is intended to serve and is of an appropriate a suitable scale

to meet that need. (iv) is designed and sited to enable the shared use of premises and playing fields for community purposes.

(v) would not have any adverse environmental effects. (vi) in the case of proposals for large developments generating significant numbers of trips, such as indoor

sports facilities, are located within or on the edge of town centres or other areas of higher public transport

accessibility.

Page 786

Agenda Item

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24

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Page


MM75 82 Policy 22b

l

The council will not grant planning permission for development that involves the loss of social and community infrastructure unless:

(i) it can be demonstrated that the facility is no longer required either in its current use or for any alternative social or community use.

(ii) suitable alternative provision is made or is available nearby. Where proposals come forward involving the loss of a social and community facility, sufficient evidence will need to be provided to satisfy the council that the requirements of this policy have been met. This would demonstrate

that for a period of 12 months there had been no interest in using the premises/land for their current use or other community purposes at a reasonable charge or and that the need for such a facility is already satisfied

within premises in easy walking distance or an alternative facility will be provided within a similar distance.

MM76 83 List of

Public Houses

Add under ‘Sutton and West Sutton on Page:

● New Inn, 16-18 Myrtle Road, Sutton SM1 4BX


However, the council is making two amendments one amendment to the Green Belt boundary. It is taking the housing estate including Damson Way (to the east), Lawson Walk (to the south) and Burns Close (to the west) out of the Green Belt as this is area is an established extension to the residential area and performs no

Green Belt function. In addition, the council is making a modest extension to the Gypsy and Traveller site which is in the Green Belt but, as with the current site, the Green Belt designation will wash over the site.

and the current Gypsy and Traveller sites and the extension will be removed from the Green Belt and become an inset in the Green Belt and re-designated as ‘Land Limited to Gypsy and Traveller Sites’.


The borough has 18 areas of MOL (some of the areas have been amalgamated since the last plan) and two areas have been extended: Mayflower Park in Worcester Park is bigger on the ground than planned by 1.4ha and Grove Park, Carshalton, has been extended by 0.7 hectares. However, two areas have been taken out

of Metropolitan Open Land: Rosehill Recreation Ground will lose 2.7ha in order for a new school to be built, and a 4.4ha site to the west of Beddington Lane has been designated as Strategic Industrial

Land.

Page 787

Agenda Item

8b

25

Ref

Page



a The council has removed one site from the Green Belt and allocated it as an extension to the existing Gypsy and Traveller Site at land south of The Pastures, Carshalton Road (Site Allocation

104). The council has removed two sites from Metropolitan Open Land for a school on Rosehill Recreation Ground (Site Allocation S98), and to extend the Beddington Strategic Industrial

Location on Land to the West of Beddington Lane (Site Allocation 76). b The council has amended the Green Belt boundary to remove the housing estate including Damson Way (to

the west), Lawson Walk (to the south) and Burns Close (to the east).

cb The council has amended MOL boundaries so that the Mayflower Park, Worcester Park boundary follows the road and line of built development, and that Grove Park, Carshalton, includes the former school playing

field. c The council is allocating an extension to the existing Gypsy and Traveller Site in the Green Belt

and a school on Rosehill Recreation Ground MOL. In both cases existing designations will wash over the site.

Page 788

Agenda Item

8b

26

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MM80 88 Policy 24d-f d The council will not grant planning permission for inappropriate development in the Green Belt or Metropolitan Open Land unless very special circumstances other material considerations clearly

outweigh harm to the Green Belt or Metropolitan Open Land and can be demonstrated constitute very special circumstances which clearly outweigh the harm to the Green Belt or Metropolitan

Open Land. The construction of new or replacement buildings and structures or the re-use of buildings and structures in the Green Belt and Metropolitan Open Land will be inappropriate unless it is for the following purposes:

(i) agriculture, horticulture or animal-related businesses. (ii) appropriate facilities for outdoor sport and recreation and cemeteries .and as long as the new or

replacement buildings or structures or the re-use of buildings and structures have a minimal effect on/preserve the openness of the Green Belt or Metropolitan Open Land.

e The council will grant planning permission for extensions to, alterations to and the replacement of an existing buildings and or structures in the Green Belt provided that the effect on the openness of the Green Belt is minimal and that the increase in the external volume of the built form is no greater than

30% above the size of the original building or structure. f The council will not grant planning permission for development within or conspicuous from the

Green Belt or Metropolitan Open Land if it has a detrimental impact on visual amenity. f The council will grant planning permission for redevelopment of previously developed sites

comprising two or more non-ancillary buildings, excluding temporary buildings, which would not

have a greater impact on the openness of the Green Belt and the purpose of including land within it than the existing development.

For Green Belt and Metropolitan Open Land maps, see Appendix 5, Maps 5.1 to 5.21 5.22, and Policies Map

Page 789

Agenda Item

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27

Ref

Page


MM81 90 Policy 25a(i)

The council will seek to retain the existing level of open space in the borough by: (i) refusing development of all open space and play space in the borough (as identified on the Policies Map)

unless (1) it can be demonstrated that such development would preserve or enhance its open character, its function as

a sport, leisure or recreational resource, and its contribution to visual amenity, or (2) the loss resulting from the proposed development would be replaced by equivalent or better

provision in terms of quantity and quality in the local area.

MM82 90 Policy 25b The council will encourage and support the provision of community-run and managed allotments and community food growing spaces in major new developments where possible and appropriate. practicable.

Page 790

Agenda Item

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28

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MM83 93 Policy 26 a The council will protect and enhance Sites of Importance for Nature Conservation, Green Corridors and biodiversity. It will ensure the restoration of Beddington Farmlands is completed to the agreed quality and

implement its Biodiversity Action Plan and agri-environment schemes. Major new development should result in no net loss in biodiversity value, as assessed against the DEFRA biodiversity offsetting

metric, the Environment Bank Biodiversity Impact Calculator or any metric which the council subsequently adopts formally. New development should incorporate opportunities to enhance biodiversity, wherever possible.

b The council will grant permission for developments that create, conserve or enhance biodiversity and improve access to nature, subject to other policies in the plan. In particular, the council will support the

creation of: 1 hectare of new woodland.

2 hectares of new chalk grassland at appropriate suitable locations. Various habitat enhancements identified through the council's Biodiversity Action Plan and the

Catchment Plans for the River Wandle and Beverley Brook.

c The council will not grant planning permission within or adjacent to a SINC where there would be a damaging impact on the nature conservation value or integrity of the site, unless:

(i) the need for and the benefits of the development clearly outweigh the harm. (ii) where there are no reasonable alternative sites that would result in less harm. (iii) where development can demonstrate no net loss for biodiversity and, where possible, net gains for

biodiversity by providing appropriate mitigation and / or compensation measures. d The council will not grant planning permission for development within a Green Corridor where there would

be a significant damaging impact to the corridor, unless the need for and benefits of the development clearly outweigh the harm and where development can demonstrate no net loss for biodiversity by providing appropriate mitigation and / or compensation measures.

e The council will grant planning permission for development provided that the development will not adversely affect the integrity and biodiversity of the Banstead Downs SSSI (adjacent to the

London Borough of Sutton). For Sites of Importance for Nature Conservation and Green Corridors, see Appendix 6, Maps 6.1 to 6.66 and

Policies Map

Page 791

Agenda Item

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29

Ref

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MM84 95 Policy 27 On agricultural land, defined as the Woodcote Green Belt: a The council will only grant permission for agricultural, horticultural and animal-related businesses only

provided that they are of a scale appropriate with size of the site and they have a minimal effect on the openness of agricultural land.

b The council will only permit development that would lead to the loss of the Best and Most Versatile

Agricultural Land provided that if:

(i) it has been demonstrated that the benefits of the development outweigh the loss of Best and Most Versatile Agricultural Land.

(ii) the loss would not result in a reduction of the viability of the remaining agricultural land.

c The council will not permit new agricultural, horticultural or animal-related business buildings unless it is satisfied that they are necessary, do not affect the character of the area and that there are no other suitable buildings on the site for the proposed use. The council will assess whether existing horticultural,

agricultural, horticultural or commercial buildings are being used for those purposes. Proposals must be accompanied by a comprehensive business diversification plan, which establishes how retaining the

buildings the proposals will assist the viability of the business. d The council will grant planning permission for residential units arising out of the replacement or

redevelopment of vacant horticultural, agricultural, horticultural or commercial buildings, where required, provided that:

(i) it can be demonstrated the building had been in active horticultural, agricultural, horticultural or commercial use for a significant 10-year period prior to its becoming vacant and there is no prospect of the building being used for horticultural, agricultural, horticultural or commercial in the future.

(ii) it can be evidenced that a replacement building for agricultural, horticultural or commercial use would not be viable

(iii) the residential unit will have a maximum plot size of 0.2ha for each detached dwelling and 0.1ha for each semi-detached dwelling.

MM85 98 Policy 28c Is of an appropriate a suitable scale, massing and height to the setting of the site and/or townscape.

Page 792

Agenda Item

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30

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Page


MM86 98 Policy 28e Makes a positive contribution to the street frontage, streetscene and / or public realm, such as using railings and low walls where appropriate practicable.

MM87 98 Policy 28

Subsequent clauses to

be renumbered

Add additional criterion:

n Maintains the setting and visual amenity of the Green Belt, Metropolitan Open Land, Public Open Space and Urban Green Space.

MM88 99 Policy 28p The Mayor of London requires boroughs to identify Areas of Taller Building Potential. In addition to being located within the zones areas the council has identified and the requirements of character and design set out above, taller buildings will be expected to:

(i) Be of exemplar design and make a positive contribution to the quality of the local and wider townscape and skyline.

(ii) Integrate visually with the townscape and streetscape, particularly in terms of an active ground floor frontage.

(iii) Include a mix of functions that are widely used by the public (such as gyms or retail outlets) in order to

ensure the successful integration into the local area, where appropriate practicable. (iii) Ensure safe, attractive and comfortable amenity/open spaces designed to support social interaction and

cohesion and engender a sense of place in predominantly residential developments. (iv) Ensure safe, attractive and comfortable amenity/open spaces designed to support social interaction and

cohesion and engender a sense of place in predominantly residential developments.

v) Protect the setting of any designated heritage assets and the overall.

(vi) Protect the amenity of neighbours and surrounding occupiers and the overall historic character that

makes an area distinctive and special.

MM89 103 Policy 30a The council will conserve and, where appropriate practicable, enhance the borough’s historic environment.

This comprises: listed buildings and structures, scheduled ancient monuments, conservation areas, historic parks and gardens, areas of special local character, locally listed buildings and undesignated archaeological

remains.

Page 793

Agenda Item

8b

31

Ref

Page


MM90 103 Policy 30b Development that has an impact upon a heritage asset will be expected to conserve and, where appropriate practicable, enhance its significance. The council will expect that new development integrates into the historic

environment and will look for opportunities from new development affecting heritage assets and their settings to enhance or better reveal their significance.

MM91 103 Policy 30g (i)

The council will (i) expect development within a Conservation Area to conserve and, where appropriate practicable, to

enhance those elements which contribute to the Conservation Area's special character or appearance. These elements may include landscaped areas, gardens, trees, hedges and boundary treatments as well as the built form. In considering development proposals, consideration will be given to matters including

height, scale, massing, materials, urban grain and layout, the public realm and views into and out of the conservation area.

MM92 104 Policy 30g (iii)

expect development outside a Conservation Area but which would affect a Conservation Area to conserve and, where appropriate practicable, enhance those elements which contribute to the Conservation Area's special

character or appearance.

MM93 104 Policy 30h

(i)

The council will:

(i) expect that development conserves and, where appropriate practicable, enhances Historic Parks and Gardens and their settings

MM94 104 Policy 30i (i)

The council will: (i) expect development within an Area of Special Local Character conserves and, where appropriate

practicable, enhances those elements which contribute to the Area of Special Local Character's particular

character or appearance.

MM95 104 Policy 30i

(ii)

expect development outside an Area of Special Local Character but which would affect an Area of Special Local

Character to conserve and, where appropriate practicable, enhance those elements which contribute to the Area of Special Local Character's particular character or appearance.

Page 794

Agenda Item

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32

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Page


MM96 104 Policy 30k (i)

The council will: (i) in consultation with the Greater London Archaeological Advisory Service, require the necessary

level of investigation and recording for development proposals that affect, or have the potential to affect Sutton’s archaeological heritage. Remains of archaeological importance, whether

scheduled or not, should be protected in situ or, if this is not possible, excavated and removed as directed by the Greater London Archaeological Advisory Service. permit development within Archaeological Priority Areas if accompanied by an archaeological evaluation, which assesses the

archaeological implications of the development and which proposes effective mitigation measures to safeguard the area from adverse development

MM97 104 Policy 30l Where a scheme should be submitted for archaeological site-based survey and/or intervention, in addition to the method statement it will need to include analysis, publication and archive deposition

of the material and the records made, and for the public dissemination of the results to further understanding. Where mitigation includes archaeological excavation, a scheme should be submitted for the excavation, analysis, publication and archive deposition of the records made, and for the

public dissemination of the results to further understanding”

MM98 106 Policy 31b

(ii) 2nd bullet

(ii) a site wide combined heat and power (CHP) heating and/or cooling network supplied by low or

zero-carbon energy’

MM99 106 Policy 31d The council will collaborate with potential heat suppliers, energy service companies (ESCos), major developers and the community to deliver a district heating networks to serve new and existing developments in Hackbridge

and within other identified ‘DE Opportunity Areas’ over the plan period (Maps 10.1 and 10.2).

MM100 111 Policy 32a

4th bullet

Ensuring that all 'more vulnerable' and 'highly vulnerable' developments within Flood Zones 2 and 3 set finished

floor levels a minimum of 300mm above the modelled 1 in 100 annual probability flood level including climate change in accordance with the latest guidance published by the Environment Agency.

MM101 111 Policy 32a 5th bullet

Ensuring that any residual risks are safely mitigated through the use of appropriate flood resistance or resilience measures,including measures, including safe access and escape routes where required.

MM102 111 Policy 32b Proposed developments should incorporate appropriate effective sustainable drainage (SuDS) measures as part of the design and layout of the development

Page 795

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33

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Page


MM103 111 Policy 32b 2nd bullet

Insert an additional sentence at the end of the 2nd bullet point …In such cases, run-off rates must not exceed 3 times the calculated greenfield rate in accordance

with Mayor’s Sustainable Design and Construction SPG; and

MM104 111 Policy 32b

4th bullet

Delete the 4th bullet point

● ensure the limiting discharge rate is at least 5 l/s at the point of discharge from the site.

MM105 111 Policy 32c All major development proposals should be accompanied by a Drainage Assessment Form and appropriate

relevant surface water run-off calculations

MM106 113 Paragraph

32.20

P32.20 If greenfield runoff rates are not proposed, developers must demonstrate how all opportunities to

minimise final site runoff, as close to the greenfield rate as practical, have been taken, taking account of ground conditions, the permeability of all existing and proposed surfaces on the site, any existing surface

water drainage networks and the need to minimise the risk of blockage at the point of discharge from the site. Microdrainage calculations should be provided for a range of return periods up to and including the 1 in 100 year 6-hour rainfall event plus climate change.

MM107 121 After Paragraph

34.7

Insert new text after Paragraph P34.7 and before Paragraph P34.8 under Policy 34 on ‘Environmental Protection’ as follows:

Water Supply and Sewerage Infrastructure In order to ensure that adequate water supply, surface water, foul drainage and sewage treatment

capacity is in place to serve all new developments, developers and the relevant statutory will be required to demonstrate that there is adequate capacity both on and off the site to serve the development and that it would not lead to problems for existing users.

MM108 124 Policy 34b Where appropriate necessary, the Council will negotiate Section 106 agreements with developers to deliver river restoration objectives.

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MM109 124 Policy 34 New part of

policy - after (b)

with later sections re-numbered

to add one.

Water Supply and Sewerage Infrastructure b(i) Prior to the occupation of any development resulting in additional demand for on-and off-site

water supply, surface water drainage, foul drainage and sewage treatment capacity: (i) the developer, together with the relevant statutory undertaker, should demonstrate that

sufficient water supply, surface water drainage, foul drainage and sewage treatment capacity exists to serve the development; or extra capacity will be provided prior to any discharge of foul or surface water from the site being

occupied.

MM110 124 Policy 34c-d

Air Quality

Subsequent clauses to be

renumbered

c All development proposals should be at least 'air quality neutral' with respect to particulates

(PM10s) and nitrogen oxides (NOx) based on the emissions benchmarks set out in Appendix 7 of the Mayor's Sustainable Design and Construction SPG. Any proposal that would have significant adverse

impacts on air quality, lead to a breach of national air quality standards or expose the public to existing sources of air pollution will not be permitted unless appropriate mitigation measures are put in place to reduce these impacts to acceptable levels.

d All major development proposals with potentially significant adverse impacts on air quality; located within 150m of a sensitive receptor or incorporating CHP or biomass boilers should be

accompanied by an Air Quality Assessment setting out the potential impacts and proposed mitigation measures to make the development acceptable. Any CHP or biomass boilers should meet

the emissions standards in the Mayor's Sustainable Design and Construction SPG. Any individual or communal gas boilers should achieve a NOx rating of less than 40 mg/kWhr.

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(c) All major development proposals with potentially significant adverse impacts on air quality; located within 150m of a sensitive receptor or incorporating CHP or biomass boilers should be

accompanied by an Air Quality Assessment setting out:

impacts on existing receptors during the demolition/construction phase;

impacts on existing receptors once the development is occupied and operational;

impacts on future occupants of the development from exposure to the predicted levels of air

pollution; and

cumulative impacts from other committed developments in the vicinity.

(d) All development proposals should seek to contribute towards the achievement of national air quality objectives as far as possible and support the objectives of the Council’s Air Quality Action

Plan. Any proposal that would have significant adverse impacts on air quality or expose the public to existing sources of air pollution will not be permitted unless appropriate mitigation measures are put in place to reduce these impacts to acceptable levels. Where necessary, the council will

negotiate Section 106 agreements with developers to offset any unacceptable air quality impacts, including through the implementation of measures in Sutton’s Air Quality Action Plan.

(e) All development proposals should be at least 'air quality neutral' with respect to particulates (PM10s) and nitrogen oxides (NOx) based on the emissions benchmarks set out in Appendix 7 of the Mayor's Sustainable Design and Construction SPG as amended. Any proposed CHP or biomass boilers

should meet the emissions standards in the Mayor's Sustainable Design and Construction SPG. Any individual or communal gas boilers should achieve a NOx rating of less than 40 mg/kWhr.

MM111 125 Policy 34h Developments that would generate noise or vibration affecting existing noise-sensitive land-uses, such as housing, schools and hospitals, will not be permitted unless appropriate adequate mitigation measures are

proposed to reduce the adverse impacts to acceptable levels, having regard to the Mayor's Sustainable Design and Construction SPG.

MM112 125 Policy 34k Details of proposed measures should be provided through submission of an appropriate scheme prior to the start of construction on site

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MM113 128 Policy 35a Sutton

Town Centre

Sutton Town Centre Proposals to transform the existing gyratory system to make the roads less traffic dominated and more

pedestrian and cycle friendly including measures to encourage shared space, reassignment of priorities and landscape improvements.

Construction of a new road link between Grove Road and the Brighton Road / High street junction.

A new link connecting the northern end of the High Street and Marshalls Road using Burnell

Road and Lewis Road. Crown Road / High Street junction Improvements.

Critical Schemes required regardless of Tramlink: High Street / Old Gasworks junction improvements.

Throwley Way / Carshalton Road (A232) / Chalk Pit Way / Manor Park Road junction improvements – by 2021.

High Street / Old Gasworks junction improvements – by 2026.

Sutton Court Road (A232) / High Street junction improvements. Cheam Road (A232) / St Nicholas Way / Sutton Park Road junction improvements – by 2026.

Other schemes: Sutton Court Road (A232) / High Street junction improvements. Construction of a new road link between Grove Road and the Brighton Road / High street

junction. A new link connecting the northern end of the High Street and Marshalls Road using Burnell

Road and Lewis Road. Crown Road / High Street junction Improvements.

MM114 131 Policy 36b Therefore Transport Assessments and Travel Plans will be required for all major development applications, while

for smaller developments Transport Statements will be required. The thresholds as to whether a Transport Assessment, Transport Statement and/or Travel Plan will be required are set out in Appendix B of

the Transport Assessments and Travel Plans SPD or any successor document.

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MM115 131 Advice on meeting

the policy

… The council has also produced guidance on the need for and the operation of car clubs in new developments: Car Clubs Supplementary Planning Document (2007) and the guidance will be re-introduced in any successor

document. TfL has produced guidance on both Construction Logistics Plans and Delivery and Service Plans. The council welcomes initiatives that reduce the impact of freight deliveries/servicing on residents and

the local environment. It therefore supports, in principle, measures aimed at breaking down larger vehicle loads so that they can be carried by smaller, more sustainable vehicles and the provision of unattended delivery facilities in sustainable locations such as "click and collect”.

MM116 132 Policy 37a New developments will be expected to provide the appropriate amount of car parking in accordance with the council's restraint-based, maximum car parking standards

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MM117 139-140

Policy 40 and

paragraphs 401 – 40.3

POLICY 40: Enforcement Facts and Trends

P40.1 The planning process is quickly undermined if unauthorised development takes place. To address breaches of planning, legislation gives powers to local authorities to take

enforcement action where development has been carried out, either: ● without planning permission, and / or consent. ● where a condition on a planning permission has not been met.

P40.2 When considering whether to take enforcement action, the council will have regard to the

national planning policy and guidance, which sets out how the enforcement sections of the 1990 Town and Country Planning Act should be used, and the further enforcement powers in

the 1990 Planning (Hazardous Substances) Act and the Planning (Listed Buildings and Conservation Areas) Act 1990.

P40.3 The legislation makes it clear that planning objectives should provide the basis for considering if enforcement action should be taken. In applying this policy, the council will be

guided by the following considerations which are set out in further detail in national planning policy and guidance: ● whether the breach of control would unacceptably affect public amenity or the existing use of land

and buildings meriting protection in the public interest. ● the need for enforcement action to be commensurate with the breach of planning control to which

it relates, for example it is usually inappropriate to take formal enforcement action against a trivial or technical breach of control which causes no harm to amenity in the locality of the site. ● the extent to which a breach of planning control may prejudice the achievement of any important

policy objective of the Local Plan.

Strategic Objectives This is an all-encompassing policy and so all strategic objectives are relevant to this policy.

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Policy P40: Enforcement The council will use the discretionary enforcement powers provided by planning legislation when it

appears there has been a breach of planning control, or where local amenity is adversely affected by the condition of land.

The use of these powers will have regard to: ● whether it is expedient to take enforcement action. ● the Local Plan and any other material considerations.

● the need to take enforcement action within an acceptable timescale in cases where remedial action is needed to prevent serious harm to public amenity.

● where negotiations fail to achieve compliance or. ● where offences have occurred that would mean that negotiation would be inappropriate.

MM118 141 P41.2a

Insert new paragraph after P41.2: The allocations state the particular land uses the council expects to be developed on a particular site. However, in the case of social and community infrastructure and free-standing offices, it is

difficult to allocate particular sites for such uses as these are usually stand-alone uses and may occur in any number of sites. Therefore, Policy 41 allows for applications for social and community

infrastructure and free-standing offices to override the plan’s allocation where these uses are proposed and where exceptional circumstances exist.

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MM119 146 LCH1 Site ‘LCH1 London Cancer Hub’ is allocated for:

MIXED USE: HEALTH, MEDICAL RESEARCH AND DEVELOPMENT AND SECONDARY SCHOOL TOGETHER WITH ASSOCIATED ANCILLARY DEVELOPMENT INCLUDING RETAIL, COMMUNITY USES, PATIENT

HOTEL/ACCOMMODATION, OPEN SPACE AND NEW TRANSPORT INFRASTRUCTURE INCLUDING A NEW UNDERGROUND CAR PARK.

IN THE EVENT THAT ANY PART OF THE SITE (OTHER THAN THE PROPOSED OPEN SPACE) IS NOT REQUIRED FOR THE ALLOCATED USE RESIDENTIAL DEVELOPMENT WOULD BE CONSIDERED AN

APPROPRIATE ALTERNATIVE USE. ...

INDICATIVE HOUSING CAPACITY In the event that residential was proposed on part of the site, as described above, the indicative

capacities would be based on the London Plan Density Matrix Setting of Suburban 40 – 80 u/ha. Not Applicable

MM120 149 STC1 Additional

bullet

Developers, working in conjunction with the relevant statutory undertakers, will be required to demonstrate that there is adequate waste water capacity both on and off the site to serve the

development and that it would not lead to problems for existing or new users.

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MM121 160 STC7: Map

Amend site boundary to follow the back of the current Kwikfit building:

MM122 165 STC9:

Allocation

Site ‘STC9 Civic Centre Site’ is allocated for:

MIXED USE: CIVIC, COMMUNITY, RESIDENTIAL, RETAIL AND TOWN CENTRE USES

MM123 165 STC9:

Additional bullet

Protecting the views of Trinity Church spire by stepping down to 3-4 storeys at the junction of

Cheam Road and St Nicholas Way

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MM124 173 STC13: Additional

bullet



MM125 197 STC25

4th bullet

point

Providing buildings between 2 and 10 storeys in height, stepping down in height on the eastern part of the

site adjacent to Chestnut Terrace/ Lewis Road

MM126 197 STC25

Additional bullet

● Ensuring the design of the development protects future occupants from the operation of the

existing timber yard to the north of the site (see Policy 29)

MM127 215 STC35 Additional bullet

Retaining the Post Office and Telephone Exchange as they are good townscape buildings and enhance the setting of the nearby Conservation Area

MM128 217 STC36 Additional

bullet



MM129 231 S1

Additional bullet

Developers, working in conjunction with the relevant statutory undertakers, will be required to

demonstrate that there is adequate waste water capacity both on and off the site to serve the development and that it would not lead to problems for existing or new users.

MM130 233 S2 Indicative

Housing Capacity

204 174 net additional dwellings – Based on the London Plan Density Matrix Setting of Urban 55-145 u/ha

MM131 256-257

S16 Delete Site S16 ‘Wallington Delivery Office’ from the Draft Local Plan

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MM132 After page

321

Site Allocation

S76

S76: LAND WEST OF BEDDINGTON LANE Beddington Lane, Beddington Location: Beddington

Ward: Beddington North Site Area: 4.4 Hectares

Current Land Use: Metropolitan Open Land Ownership: Private PTAL: Level 1b

Fluvial Flood Risk: Zone 1

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SITE DESCRIPTION The site is located to the west of Beddington Lane adjacent to the Coomber Way roundabout. An

access road to the Energy Recovery Facility is under construction in the southern part of the site. To the east of the site lies land safeguarded for the Wandle Valley Regional Park.

POLICIES MAP DESIGNATIONS Archaeological Priority Area; Metropolitan Green Chain,; Site of Importance for Nature Conservation.

RELEVANT PLANNING HISTORY

None.

Site ‘S76 Land West of Beddington Lane’ is allocated for: Industry

Any development should pay particular regard to:

Providing high quality industrial premises falling within B1(b)(c), B2 or B8 uses class Providing high-quality environmental improvements to the Beddington Lane frontage and providing sensitive boundary treatments to minimise the impact on the adjacent Wandle Valley

Regional Park Respecting and enhancing the adjacent SINC

Site allocation S100 ‘Beddington Lane Road Improvement Scheme’ The need to provide flood risk assessment and appropriate Sustainable Urban Drainage System measures

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INDICATIVE HOUSING CAPACITY Not applicable

INDICATIVE NON-RESIDENTIAL CAPACITIES

B1(b)(c), B2 or B8: 17,600sqm (based on a plot ratio of 40%) INDICATIVE PHASING

Phase 1: April 2016 to March 2021

DELIVERY MECHANISM The council understands that the landowners intend to bring forward the site for industrial

development.

MM133 332 Site Allocation

S98

Site Area: 2.2 2.6 Hectares

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MM134 332 S98: Map

Amend site boundary for S98 ‘All Weather Pitch and part of Tennis Centre, Rose Hill, Sutton’ to include the small strip to the east of the existing site, and northern part of site.

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MM135 341 S102: Additional

text

Add the following below the dotted red line: The council, working in conjunction with Transport for London, will be carrying out further work

including traffic modelling to establish the need for and extent of highway works in the town centre. When considered with possible public transport improvements, it should enable the council to

determine which proposals need to be taken forward over the plan period to improve the environment of Sutton Town Centre and to support future growth. Detailed proposals for any of these schemes would be subject to consultation with affected local residents and businesses to

ensure any specific access or servicing requirements are taken into consideration.

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Documents

Report to the Council of the London Borough of Sutton