Case for Regeneration: Planning Report

savills.co.uk

Case for Regeneration: Planning Report

Elm Grove Estate, Sutton

Appendix C4 Sutton Council

March 2021

Page 229 Agenda Item 5



Sutton Council March 2021

Contents Executive Summary 1

1. Introduction 3

2. Site Context and Surroundings 4

3. Planning Policy Context 6

4. Outline of Options 17

5. Planning Assessment of Options 19

6. Other Planning Considerations 37

7. Summary and Conclusions 40

Appendix 1: Extract from LBS’s adopted Local Plan – STC45 Allocation

30Agenda Item 5



Sutton Council March 2021 1

Executive Summary

This Planning Report has been prepared on behalf of Sutton Council to inform the potential redevelopment of Elm

Grove Estate, Elm Grove, Sutton, SM1 4EX located within Sutton Town Centre in the administrative area of London

Borough of Sutton (‘LBS’).

Elm Grove Estate currently comprises a total of 73 residential units with associated car parking, private amenity

space and public realm. It is an allocated town centre, brownfield site within the adopted 2018 Sutton Local Plan.

The Site is identified for the potential delivery of 47 net additional dwellings within heights of 2-6 storeys. In addition,

the allocation identifies potential for limited non-residential floorspace, in the form of Town Centre uses, at ground

floor (281 square metres).

The potential improvement and redevelopment options have been subject to extensive consultation with existing

residents to include an initial series of workshops and site visits between June 2017 and March 2018; the

establishment of a Residents’ Steering Group in October 2019; and more recently a series of virtual workshops

between November 2020 and February 2021. Through this process, Sutton Council has given consideration to three

potential interventions which include (1) refurbishment of the existing housing stock; (2) three different approaches

to partial redevelopment to include new-build elements; and, (3) full redevelopment to include full demolition of all

existing buildings and replacement with new, better quality homes in the form of three new building blocks across the

site. The resident consultation identified a lack of interest in potential retail uses on-site, and whilst the Site forms an

integral part of the Town Centre is does not provide a frontage onto the High Street, being classified in planning

policy terms as part of the “Secondary Shopping Frontage” and is therefore considered to provide a better opportunity

for optimisation through residential redevelopment. Retail uses do not therefore form part of the latest iteration of the

options.

This Planning Report considers the three interventions in the context of the adopted development plan and other

material planning considerations and concludes that the most viable option in planning terms is expected to be the

full redevelopment of Elm Grove Estate. This conclusion can be summarised as follows:

1. There is a critical need for new housing in Sutton Town Centre and Sutton more generally. National, London

Plan and local policy advocates making effective use of under-utilised ‘brownfield’ land in areas that are well-

connected to transport infrastructure and especially where such opportunities significantly assist in meeting

identified housing needs. Elm Grove Estate has a Public Transport Accessibility Level (PTAL) of 6a

(‘excellent’ with 6b being the best) and therefore offers this unique opportunity.

2. The Site is an allocated site within the adopted 2018 Sutton Local Plan, identified as STC45 with capacity

for additional residential and limited retail uses. As such the principle of redevelopment has already been

established. The potential uplift in residential dwellings could be achieved and significantly exceeded most

effectively through the full redevelopment option.

3. The full redevelopment option could provide a significant level of on-site affordable housing beyond the

existing provision on-site and local plan policy compliance levels which would positively contribute towards

the important need for a range of affordable tenure types within the Town Centre and borough as a whole.





4. Full redevelopment would lend itself to a comprehensive place-making approach, to include high quality

outdoor spaces in the form of public, communal and private amenity provision, areas of play and public realm

improvements. Such an approach should ensure proper integration and wider connectivity with the

surrounding residential built form to the east and retail and associated commercial activity, along the High

Street to the west.

5. The existing accommodation is not compliant with nationally described space standards. Full redevelopment

will deliver high quality, well sized and fully compliant residential units, which are more accessible and

appropriate to the end users.

6. On the above basis and as set out within this report, the full regeneration option allows for the greatest

planning benefits, economic and social value contributions to the local area and its community when

compared to the other two interventions.

Page 232Agenda Item 5




1. Introduction

Savills Planning have been instructed by London Borough of Sutton (‘LBS’) to undertake a planning

assessment of the two main intervention options (partial and full redevelopment) to re-provide existing

housing accommodation and provide new homes at Elm Grove Estate (“the Site”). A Site Location Plan is

enclosed at Appendix 1 of the overarching Options Appraisal document. This report should be read in

conjunction with the Design Feasibility Document (March 2021) which assesses from a design perspective

these options and illustrates the approaches for each as produced by Levitt Bernstein Architects.

This report is intended to feed into a broader strategic review of the LBS’s existing housing stock at the Site

and the wider Case for Regeneration. It is understood that the Council is exploring the possibility of

regenerating seven housing estates that are within, or are situated in close proximity to Sutton Town Centre.

The programme intends to make significant improvements to the quality and supply of new homes within

the borough, whilst ensuring that the intended increase in quality and quantity of the borough’s housing

stock is supported by new infrastructure. Elm Grove Estate forms part of this wider housing renewal

programme, as potentially an early opportunity for new homes delivery.

The structure of this document is as follows:

1. Introduction (This Section);

2. Site and Surroundings;

3. Planning Policy Context;

4. Outline of Options;

5. Planning Assessment of Options;

6. Other Planning Considerations; and

7. Summary and Conclusions.





2. Site Context and Surroundings

Elm Grove Estate is a 0.5 hectare site bounded to the north by Marshall’s Road, to the east by Throwley

Way, to the south by Benhill Avenue and the west by Elm Grove, with the High Street beyond. The Site is

located in the north eastern portion of Sutton Town Centre. It is understood that the site contains 73

residential dwellings (Class C3): of which 56 units are social rented, 14 units are leasehold, and 3 units are

in freehold ownership. The majority of the units, in the form of flats, are accommodated in eight, three storey

blocks fronting Throwley Way, with bookend blocks fronting Marshall’s Road to the north and Benhill

Avenue to the south. There are a further six, two storey blocks to the rear of these main blocks which

accommodate the remaining dwellings in the form of houses and bungalows. The unit mix is understood to

be 45 x one-bedroom flats, 12 x two-bedroom flats, and 14 x three-bedroom houses and 2 x three-bedroom

bungalows.

The Site is allocated in the adopted 2018 Sutton Local Plan, which forms the main document in the Council’s

Development Framework. “Elm Grove Estate”, referred to as site allocation STC45, is allocated for the

delivery of 47 net additional dwellings and 281 square metres of non-residential, Town Centre use

floorspace.

The Site also forms part of the Northern Gateway regeneration area, which comprises areas that are

considered could benefit from housing renewal and regeneration. In LBS’s Sutton Town Centre Masterplan

(2016), Elm Grove is identified as a ‘key project’ for neighbourhood improvements. Other housing estates

across the town centre are also identified for redevelopment where Local Plan (LP) Policy 3 identifies that

the Council may consider taking forward an Area Action Plan (AAP) for these other estates in setting

development parameters and allowing full resident consultation. This AAP route does not, however, apply

to the Elm Grove Estate which could therefore be considered as an early regeneration opportunity

supported by close consultation and engagement with the Council’s planning officers, Members, existing

residents and key local stakeholders to include the wider community.

Adjacent to Marshall’s Road to the north is the Matalan site, which is allocated in 2018 Sutton Local Plan

(STC 25) for mixed-use development up to 10 storeys. At present no application has come forward for this

site to our knowledge. Beyond STC 25, to the north the height transitions to a prevalent 2-3 storey

residential character, with additional height seen fronting High Street. To the east the area is predominantly

residential with both Rosebery Gardens and Benhill Estate sitting beyond Throwley Way (just outside the

designated town centre boundary) and ranging between 2 and 5 storeys in height. Both of these estates

have been identified for potential estate renewal. The area to the west of the site is characterised by 3-4

storey commercial premises, comprising properties fronting the High Street and beyond this is the Asda

Sutton Superstore, which sits at 5 storeys.

There are no statutory or locally listed /scheduled assets on the site. The closest scheduled monument is

the ‘Milestone in Sutton High Street’ which is located approximately 50 metres to the south west of the site

boundary.





The Site is also subject to the following designations in the Sutton Local Plan:

Area of Potential Intensification

Archaeological Priority Area

Area of Taller Building Potential

Decentralised Energy Opportunity Areas

Secondary Shopping Frontage

Sutton Central Setting

Sutton Town Centre Boundary

Proposed Tramlink Extension

The Site is located within Flood Zone 1, where the risk of flooding is lowest.

There are no trees subject to Tree Preservation Orders (TPOs) within or adjacent to the Site.





3. Planning Policy Context

The purpose of this section is to provide a high level overview of the policy backdrop at national, regional

and local levels, against which the options for Elm Grove Estate must be considered.

National Policy and Guidance

At a national level, the principal policy document is the National Planning Policy Framework (NPPF 2019)

and the associated up-to-date guidance provided within Planning Practice Guidance (PPG), both of which

are published by MHCLG.

National Planning Policy Framework (NPPF)

The “golden thread” of the NPPF in terms of both plan-making and decision-taking is a presumption in

favour of sustainable development (paragraph 11). Sustainable development is defined as having three

dimensions: economic, social and environmental. Focussing on the social role, sustainable development

should help to support “strong, vibrant and healthy communities, by ensuring that a sufficient number and

range of homes can be provided to meet the needs of present and future generations; and by fostering a

well-designed and safe built environment, with accessible services and open spaces that reflect current

and future needs and support communities’ health, social and cultural well-being” (paragraph 8) (author’s

emphasis underlined).

In order to support the Government’s objective of significantly boosting the supply of homes, the NPPF

(paragraph 59) requires local authorities to ensure “that a sufficient amount and variety of land can come

forward where it is needed, [and] that the needs of groups with specific housing requirements are addressed

and that land with permission is developed without unnecessary delay.”

The NPPF, continuing in relation to the supply of homes, goes on to state at paragraph 60 that “To

determine the minimum number of homes needed, strategic policies should be informed by a local housing

need assessment, conducted using the standard method in national planning guidance – unless

exceptional circumstances justify an alternative approach which also reflects current and future

demographic trends and market signals. In addition to the local housing need figure, any needs that cannot

be met within neighbouring areas should also be taken into account in establishing the amount of housing

to be planned for.” NPPF, paragraph 61 requires that the size, type and tenure of housing needed for

different groups in the community should be assessed and reflected in planning policies.

Section 12 of the NPPF (paragraphs 124 to 132), “Achieving well-designed spaces”, emphasises the

importance of good design as a “key aspect of sustainable development” and acknowledges its ability to

contribute positively to making places better for people. This is closely linked to Section 8 (paragraphs 91

to 101), ‘Promoting healthy and safe communities’, which requires planning policies and decisions to aim

to achieve places which promote opportunities for interaction between different groups within the

community, safe and accessible environments where crime and disorder and the fear of crime, do not

undermine quality of life or community cohesion, and safe and accessible developments containing high

quality public space.





Paragraph 117 states that planning policies and decisions should “promote an effective use of land in

meeting the needs for homes and other uses, while safeguarding and improving the environment”.

Paragraph 117 also encourages the development of strategic policies by local planning authorities which

makes as much use as possible of previously developed or “brownfield land”, provided it is not of high

environmental value.

Planning Practice Guidance (PPG)

On 6th March 2014 the Department for Communities and Local Government launched the Planning

Practice Guidance (PPG). The PPG replaces the majority of previous planning practice guidance,

consolidating it and providing it as an easily accessible online resource. The PPG sits alongside the NPPF.

The PPG encourages the high quality design and states that, “local planning authorities should give great

weight to outstanding or innovative designs which help to raise the standard of design more generally in

the area.”

The PPG also provides guidance on relevant issues such as: sustainability and renewable and low carbon

energy; design; housing need and quality; the natural environment and recreation; flood risk; transport and

travel plans; waste; viability; planning conditions; planning obligations and the Community Infrastructure

Levy (CIL).

Government White Paper: Planning for the Future (Consultation Document - August 2020)

On 6th August 2020, the Government published a White Paper for consultation which proposes reforms of

the planning system. The White Paper emphasises the overall aim of the Government to streamline and

modernise the planning process, in order to bring a new focus to design and sustainability, improve the

system of developer contributions to infrastructure, and ensure more land is available for development

where it is needed. The White Paper introduces three key pillars as follows:

Pillar One – Planning for development

Pillar Two – Planning for beautiful and sustainable places

Pillar Three – Planning for infrastructure and connected places

The White Paper seeks to actively promote rapid housing delivery via a more streamlined development

management process. The Paper places a priority on policy compliant rental tenures and wider affordable

housing tenure diversification to include the introduction of first homes sold at a discount to market price

for first time buyers.

The consultation also included proposed revisions to the standard methodology (‘SM2’) for assessing local

housing need to potentially supersede the original standard methodology (‘SM1’). However, in December

2020, the Government confirmed it does not propose to proceed on the basis of draft SM2 and instead,

introduced a reformed standard methodology which aligns more closely with the original SM1 approach

(‘SM1.1’). This revised approach reflects “…a number nationally that is consistent with the commitment to

plan for the delivery of 300,000 new homes a year, a focus on achieving a more appropriate distribution of

homes, and on targeting more homes into areas where there are affordability challenges” (Government

response to local housing need proposals, 16 December 2020). It includes a 35% uplift to be applied to the





20 authorities that contain the largest proportion of the city or urban centres population which includes

Greater London.

For LBS, SM1.1 reinforces a need for significant growth at an increased figure of 807 homes per annum

figure compared to the lower 598 units per annum under SM1 and the 427 units per annum target contained

with the adopted 2018 Sutton Local Plan.

Proposed Revisions to the NPPF – January 2021

On the 30 January 2021, the MHCLG announced a consultation on a number of proposed revisions to the

NPPF 2019, which runs to 27 March 2021. The proposed revisions of particular relevance are as follows:

Definition of Sustainable Development Objectives (Para 8b.) – the term ‘built environment’ removed

and ‘beautiful’ introduced. The concept of great places therefore applies to all locations. At paragraph

8c the terms ‘protect and enhance’ are stronger for the natural, built and historic environment. The

term ‘improving biodiversity’ is also introduced in line with the forthcoming introduction of Biodiversity

Net Gain requirements. Paragraph 179 (d) strengthens the requirement for biodiversity gain and

access to nature as an integral part of design.

Building Beautiful – The introduction of the term ‘beautiful’ means that design or architectural merit

could now be a sole reason to approve or refuse an application, with the additional weight potentially

tipping the balance where there is a fine line. In respect of local plan making, paragraph 20 outlines

that the strategic policies in local plans are required to include policy guidance on the design quality

of places and in addition area-based character assessments/ codes and masterplans. In respect of

making policy and development decisions, greater emphasis is placed on good design (paragraphs

124 and 128).

Presumption in Favour (Para 11) – the term ‘positively’ has been omitted with a focus on ‘meeting’

development needs aligned with supporting growth and infrastructure. Specific reference is also made

to mitigating climate change and adapting to its effects. Further emphasis is similarly placed on

making the best use of land in urban areas.

Climate Change – the Global Goals1 have been added to paragraph 7.

Annex 1 – Housing Delivery Test (HDT) requirements updated to reflect the passage of time. The

definition of HDT now refers to ‘homes delivered’ (rather than net additional dwellings).

Draft National Model Design Code – January 2021

Alongside the consultation regarding the proposed revisions to the NPPF, MHCLG are also consulting on

a new National Model Design Code. The National Model Design Code is intended to implement policy

changes on the basis of the Building Better, Building Beautiful Commission Report. The Code sets out the

requirements for the policies proposed in the NPPF and is to provide a basis for the production of design

1 Transforming our World: the 2030 Agenda for Sustainable Development.





codes and guides by local planning authorities.

Regional Policy and Guidance

At a regional level, LBS’s adopted development plan comprises recently adopted London Plan (March

2021).

London Plan (March 2021)

Adopted Policy GG2 ‘Making the best use of land’ seeks to ensure the creation of successful sustainable

mixed-use places that make the best use of land, by encouraging the development of brownfield land, and

the proactive exploration of the intensification of use of land to support additional homes. This is particularly

encouraged in areas that are well-connected to jobs, services, infrastructure and amenities by public

transport, walking and cycling.

The Plan no longer features a density matrix and any references to the application of density ranges has

been omitted. Instead and in support of Policy GG2 ‘making the best use of land’, Policy D3 ‘optimising site

capacity through the design-led approach’ expresses the importance of taking a design-led approach to

optimising site capacity with a shift of focus towards achieving good design which responds to local context,

such as character, scale, transport and infrastructure. In this respect higher density developments are

encouraged in locations that are well connected to jobs, services, infrastructure and amenities by public

transport, walking and cycling.

Building on this, adopted Policy GG4 ‘Delivering the homes Londoners need’ sets the strategic aim for the

plan to create a housing market that works better for all Londoners, which will include making sure that

more homes are actually delivered through, amongst other mechanisms, identifying and allocating a range

of sites to deliver housing at a local level.

Both of these policies are underpinned by adopted Policy H1 ‘Increasing housing supply’ which sets the

ten-year targets for net housing completions that each local planning authority is expected to plan for,

through delivery-focused Development Plans and optimising potential for housing delivery on suitable and

available brownfield sites.

Adopted Policy H4 ‘Delivering affordable housing’ sets the strategic target for 50 per cent of all new homes

delivered across London to be genuinely affordable and to be delivered on site in the case of major

applications.

Adopted Policy H6 ‘Affordable housing tenure’ outlines the desired split of affordable products that should

be applied to residential development. This comprises: a minimum of 30% low-cost rented homes, as either

London Affordable Rent (LAR) or Social Rent (SR); a minimum of 30 per cent intermediate products which

meet the definition of genuinely affordable housing, including London Living Rent (LLR) and London Shared

Ownership (LSO); and the remaining 40 per cent to be determined by the borough as low-cost rented

homes or intermediate products based on identified need.

Adopted Policy H8 ‘Loss of existing housing and estate redevelopment’ states that the “loss of existing

housing should be replaced by new housing at existing or higher densities with at least equivalent level of





overall floorspace”. Policy H8 also set out guidance for considering demolition and replacement of

affordable housing, as follows:

C Before considering the demolition and replacement of affordable homes, boroughs, housing

associations and their partners should always consider alternative options first. They should

balance the potential benefits of demolition and rebuilding of homes against the wider social and

environmental impacts and consider the availability of Mayoral funding and any conditions attached

to that funding.

D Demolition of affordable housing, including where it is part of an estate redevelopment programme,

should not be permitted unless it is replaced by an equivalent amount of affordable housing

floorspace. Affordable housing that is replacing social rent housing must be provided as social rent

housing where it is facilitating a right of return for existing tenants. Where affordable housing that is

replacing social rent housing is not facilitating a right of return, it may be provided as either social

rent or London Affordable Rent housing. Replacement affordable housing should be integrated into

the development to ensure mixed and inclusive communities.

E All development proposals that include the demolition and replacement of affordable housing are

required to follow the Viability Tested Route and should seek to provide an uplift in affordable

housing in addition to the replacement affordable housing floorspace. (with author’s emphasis).

Adopted Policy H10 sets out all the issues that applicants and boroughs should take into account when

considering the mix of homes on a site. Boroughs are encouraged to set out the preferred housing size mix

(for all tenures) as part of a site allocation, ensuring that the housing size mix is determined by robust local

evidence of need. This is the same for low-cost rent properties.

Better Homes for Local People: The Mayor’s Good Practice Guide to Estate Regeneration - 2018

The Mayor’s Good Practice Guide to Estate Regeneration, published in February 2018 seeks to provide a

framework for estate regeneration that makes sure that the residents are at the heart of any proposals for

regeneration on their estate. Better Homes for Local People sets out how plans that involve the demolition

of existing homes should provide an increase in affordable housing, full rights to return or remain for social

tenants and a fair deal for leaseholders and freeholders.

Within this guide, the Mayor’s Vision and Objectives for Estate Regeneration are laid out. The overarching

objectives of any estate regeneration will usually be to:

Deliver safe and better quality homes for local people;

Increase the overall supply of new and affordable homes; and

Improve the quality of the local environment through a better public realm and provision of social

infrastructure (e.g. schools, parks, or community centres).





In order to achieve these objectives, the Mayor acknowledges a range of possible physical interventions

that are available to support the delivery of estate regeneration projects, including: repairs to, and

refurbishment of, existing homes; building new homes on ‘infill’ sites; and demolition and rebuilding.

Different schemes will require different interventions, or a combination of some or all of the above,

acknowledging that there is no ‘one size fits all’ approach. When considering the option of demolishing and

rebuilding homes, a consideration of alternative options to demolition should first be considered.

The Guide also lays out a framework for full and transparent consultation and involvement, where councils

and housing associations are required to always engage openly and meaningfully with those affected by

the project from the outset. The Guide sets out how the consultation process should be undertaken,

ensuring the following:

Early consultation and involvement – giving residents the opportunity to be involved from the outset

in developing the vision, options appraisals, design, procurement, and delivery of schemes.

Consultation and engagement methods – ensure that consultation is transparent; extensive;

responsive; and meaningful. This should include direct proactive engagement of a wide group of

residents; involvement of residents in developing the detail of proposals; and promote broader

opportunities for residents to be key updated and engage.

Engaging with residents – Residents should be the primary consultees during the estate

regeneration project. This should include social tenants, resident leaseholders and freeholders,

councils and housing associations should seek to consult with private tenants or those living in

temporary accommodation on the site as well as non-resident leaseholders and freeholders. Bespoke

consultation approaches should be rolled out, tailored to residents’ needs.

Support residents to be involved – Residents should be empowered to engage in consultation by

ensuring they are meaningfully involved in as much as possible of the discussion and decisions about

issues like the design, scale and tenure of new homes.

Engaging with other stakeholders – Owners and operators of businesses that are within estates

must be engaged in the regeneration process, with proposals giving as much weight as is feasible to

the importance of minimising disruption to those businesses and retaining local employment

opportunities. Other facilities operating in estates should also be engaged in the process.

Resident Charters - Resident Charters set out councils’ or housing associations’ commitments to

residents at an early stage of the discussions over estate regeneration proposals. They can be an

effective way to engage residents. Commitments set out in a Charter should be clear, specific and

deliverable, and written in accessible and non-technical language.

Open and transparent options appraisals - Residents should be closely involved in shaping the

priorities for estate regeneration and options for achieving these priorities. To achieve this, options

appraisals should be open and transparent. They should:

a) Include the rationale, aims and objectives of the project in the context of: delivering better





homes for local people; the landlord’s strategic priorities; and neighbourhood, local, and

London-wide planning and housing policies.

b) Set out the factors that have informed the development of the proposed options, and how

these have been prioritised and balanced. These factors might include: the existing

characteristics and quality of an estate; the safety of existing buildings; the financial resources

available; any regeneration or redevelopment plans that affect the wider area; and the wishes

of residents and other stakeholders.

c) Include technical and financial appraisals that have influenced any decisions on options.

These should be available in an accessible format with non-technical summaries.

d) Assess the full range of social, economic, and environmental costs and benefits of different

options. This assessment might include:

any expected costs and savings resulting from changes in rents, service charges, energy

bills and any other impacts on household expenditure;

the cost to residents’ health of poor quality housing;

the financial cost to the landlord of maintaining existing homes to a reasonable standard

(given the number of years for which doing so would be effective);

the number of other households who might not otherwise have a home, or a home of the

right size for their needs, if the regeneration does not go ahead; and

the cost of disruption to residents’ lives for the duration of the project.

e) Clearly set out any options that have been discounted as unviable or undeliverable, with a

transparent explanation of why they are unviable or undeliverable.

f) Set out what role residents and other stakeholders have played in developing and shaping

options, and how the council or housing association and other agencies have supported them

in doing so.

The Guide also lays out the key principles for ‘Better Homes for Local People’, which are as follows:

An increase in affordable housing - it is vital that estate regeneration plans are used to increase

the amount of affordable housing, particularly homes based on social rent levels, wherever possible.

As a minimum, plans that involve the demolition of existing homes must ensure that affordable homes

demolished are replaced on a like-for-like basis.

Full right to return or remain for social tenants - Where estate regeneration plans involve the

demolition of existing homes, councils and housing associations should seek to phase projects

wherever possible, with the aim of ensuring that households can remain on the estate by moving no

more than once. Where tenants have to move temporarily off the estate, they must have a full right to

return.

A fair deal for leaseholders and freeholders - Leaseholders and freeholders affected by estate

regeneration should be treated fairly and fully compensated if their homes are to be demolished.





Local Policy and Guidance

Sutton Local Plan (2018)

LBS’s principal Development Plan Document is the 2018 Sutton Local Plan, which was adopted in February

2018.

In considering the development potential of Elm Grove Estate, we have reviewed site specific policy

designations and policies relating to housing and other relevant planning considerations within LBS’s

adopted 2018 Local Plan.

Site Specific Designations

The Site is designated as the following in the adopted 2018 Sutton Local Plan Policies Map:

I. Archaeological Priority Area

II. Area of Taller Building Potential

III. Area of Potential Intensification

IV. Central Setting

V. Decentralised Energy Opportunity Area

VI. Secondary Shopping Frontage

VII. Sutton Town Centre Boundary

VIII. Proposed Tramlink Extension

Adopted Site Allocation STC45 requires any development proposals for the Site to have regard to a series

of criteria, as set out below. It is identified to have a capacity for 47 net additional dwellings as well as

limited non-residential floorspace in the form of Town Centre uses (281 square metres). There is therefore

a presumption in favour of new housing development at the site’s location with the criteria providing a

framework for considering future development proposals.

I. Providing building heights 2 to 6 storeys along St Nicholas Way, with taller elements located on the

Throwley Way frontage

II. Providing an active frontage to Marshall’s Road in the form of retail or other town centre uses

III. Providing a mix of housing types, including family-sized units

IV. Retaining and enhancing connection between the High Street and Throwley Way

V. Protecting land for Tramlink along the Throwley Way frontage

VI. Enabling connection to any planned decentralised energy network serving the town centre

VII. The need to provide flood risk assessment and appropriate Sustainable Urban Drainage System

measures





The above site parameters set out in STC45 therefore provide a framework for future development at the

Site. The STC45 Allocation description from the adopted 2018 Local Plan is found at Appendix 1 of this

report.

Housing and other related Local Policy

Adopted Strategic Objective 1 states that efforts must be made “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.” Following on from this, Strategic Objective 2 states that homes must be “of the right

price, of the right tenure and of the right size for the borough’s current and future residents.”

Policy 1 ‘Sustainable Growth’ outlines the Council’s housing delivery targets to help meet London’s housing

needs and local housing needs, aiming to deliver at least 6,405 homes over the plan period (2016-2031).

55% of these (circa 3,400 new homes) are expected to be delivered in Sutton Town Centre and its

surrounding “Area of Potential Intensification” which includes the Estate.

Policy 3 ‘Sutton Town Centre’ sets out that the Council will 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 (or 227

new homes per year). The council will expect housing developments within the Town Centre to provide a

range of tenures and dwelling sizes.

Policy 4 ‘Tramlink and Major Transport Proposals’ outlines the plans to construct and extend the existing

Tramlink network to Sutton Town Centre. Other infrastructure improvements including enhancement of rail

service frequency to provide a more metro style service is to be explored. It is understood that the town

centre Tram Link Proposals for the time being are on hold.

With regards to housing supply, Policy 7 ‘Housing Density’ states that in order to increase the supply of

new homes, the intensification of existing residential areas provides a potential source of new homes. The

Council will expect new developments to be within the Central Setting of the former London Plan Density

Matrix (now excluded from the newly adopted London Plan 2021).

Policy 8 ‘Affordable Housing’ outlines the Council’s strategic aim to maximise affordable housing from all

sources. The Council will seek a minimum of 35% of all dwellings to be affordable on a site when negotiating

individual residential and mixed-use schemes. The expected split of affordable product is 75:25 between

social/affordable rent and intermediate.

Policy 9 ‘Housing Sizes and Standards’ seeks to ensure that new developments include a mix of dwelling

sizes which is proportionate across tenures. In Sutton Town Centre all development 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.

Strategic Objective 4 aims “to achieve the highest design and environmental standards possible and to

futureproof buildings in terms of a changing climate”. Strategic Objective 21 sets out the Council’s desire

to “cut pollution and address the causes and impacts of climate change by promoting low carbon and

environmentally sustainable developments.”





Following on from Strategic Objectives 4 and 21, Policy 31 ‘Carbon and Energy’ requires proposed major

residential developments to achieve a 35% reduction in regulated CO2 emissions on site, and offsetting

the remaining regulation emissions (to 100%) through the delivery of CO2 reduction measures elsewhere

through Section 106 contributions. Major developments will be expected to achieve at least a 20% reduction

in total CO2 emissions (regulated and unregulated) through renewables.

Policy 35 ‘Transport Proposals’ states that within Sutton Town Centre, the Council seeks 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.

These design aspirations are also reflected within the Council’s Sutton Town Centre Masterplan (2016) as

cited below.

Policy 37 ‘Parking’ makes clear that where development proposals are in town centres and other accessible

locations, limited or no parking will be favourably considered, provided that it can be demonstrated to the

Council’s satisfaction that this will not result in an increase in on-street parking which would adversely affect

traffic flow including bus movement, highway safety, residential amenity and the local environment.

Sutton Town Centre Masterplan

The Sutton Town Centre Masterplan (‘STC Masterplan’) (2016), commissioned by the Council and

produced by Allies and Morrison, outlines a new vision for the future of Sutton Town Centre. It aims to set

out the direction for investment and development in the town centre to 2031. It forms part of the evidence

base for the adopted 2018 Sutton Local Plan and can be a material consideration in the determination of

planning applications within Sutton Town Centre.

The Site sits within the Northern Gateway area and STC45 is specifically identified as “Elm Grove

Neighbourhood Improvements”:

I. The quality of this residential neighbourhood could be improved and the layout of homes could be

better integrated into the rest of the town centre.

II. A residential-led development opportunity for a mix of dwelling types and tenures.

III. Opportunity to present new active frontage to Throwley Way.

The Town Centre wide public realm framework diagram illustrates aspirations for an urban boulevard

landscape along Throwley Way, along the eastern boundary of the Site as well as east-west pedestrian

improvements through the centre of the Site to provide improved connectively with the High Street. This

aligns with the identified opportunity for the creation of an improved frontage along Throwley Way as a

result of redevelopment of the Site, with areas of green space and public realm contained internally between

residential blocks.

The STC Masterplan promotes the opportunity for higher and denser development. As a result, the Site is

shown to fall within an area where taller buildings of 7 – 10 storeys could be considered to be acceptable

subject to detailed design and assessment. This aligns with STC45 which recognises the potential for taller

elements beyond the indicative 2 to 6 storey height range, along Throwley Way.





Affordable Housing and Viability SPD (Emerging)

The Affordable Housing and Financial Viability SPD (March 2020) provides further guidance on affordable

housing and viability within the borough. The document gives details of how the Council will apply the Local

Plan’s affordable housing policy in relation to development viability when determining planning applications.

The SPD outlines, as per the Mayor’s Affordable Housing and Viability SPG (2017), that where

developments take place on publically owned land, 50% affordable housing will be required. The SPD for

Sutton goes further to identify that estate regeneration programmes which take place on publically owned

land will require at least 50% affordable housing units, and no overall loss of socially rented floorspace

(paragraph 3.4). Where these requirements cannot be met, a viability assessment will be required to explain

the economics of the development and demonstrate that the scheme provides the maximum reasonable

amount of affordable housing (paragraphs 4.1 – 4.6).





4. Outline of Options

Based on a range of considerations and the existing condition of the housing stock at Elm Grove Estate,

three intervention options have been identified for further consideration within this report. The below options

have drawn out of a careful and balanced approach taken by Levitt Bernstein, the appointed architects, to

consider the development potential under these different intervention scenarios. Levitt Bernstein’s Design

Feasibility Document (March 2021) is appended to the main Options Appraisal.

These options are:

Partial Redevelopment Option 1 – Infill Blocks

Number of Homes Demolished: 0

New Homes Provided: up to 14

Total Uplift: up to 14

Partial Redevelopment Option 2 – Houses Only


Total New Homes Provided: 17

Total Uplift: 1

Partial Redevelopment Option 3 – Flats & Maisonettes


New Homes Provided: 48

Total Uplift: 32

Full Redevelopment


New Homes Provided: 225

Total Uplift: 152

No consideration has been given to a “do nothing” approach. Aside from the Council’s own commitments

to improving the quality of life of its tenants, the Council are also legally bound to refurbish the condition of

the existing stock at the estate as a minimum. Through the extensive resident consultation on the various

options for the estate, it is understood that the residents support intervention. This means that “do nothing”

is not a justifiable choice that is open to Council and accordingly, it is not considered further within this

document.





As a starting point and in accordance with adopted London Plan Policy H8, consideration has also been

given to the refurbishment of the existing estate. The options for this have been subject to consultation with

existing residents, to include most recently at the virtual workshops in January 2021. The aim of this

approach would be to undertake works that target the current and emerging statutory requirements of the

Council as landlord in ensuring building safety, improving accessibility and energy efficiency, where

possible. This would predominantly comprise internal works, to include improved kitchens; upgraded

bathrooms; repairs to windows; improvements to existing communal core entrances to upgrade fire doors

and explore feasibility of lift integration; potential for enhanced thermal insulation; and better street lighting.

Whilst potentially less invasive than the alternative intervention options and in terms of the programme of

works, likely to be considerably shorter, residents would be required to vacate their properties in order for

the works to take place. A number of existing issues will also remain, such as all homes being undersized

and windows remain small as per the existing arrangement and therefore sunlight and daylight conditions

will not improve. It similarly does not allow for new or improved areas of open space, private amenity and/or

areas of play; nor does it offer an opportunity for enhanced public realm along Throwley Way as sought

through site specific allocation STC45 and STC Masterplan (2016). Furthermore, there will be no uplift in

residential units to provide wider benefits for the community, which is again sought through the site specific

allocation STC45 and important in supporting the Council in meeting pressing housing needs and demands

both for existing residents and the Borough as a whole.

The refurbishment of the Site is therefore not considered to represent an option that will make effective use

of ‘brownfield’ land at a prime Town Centre location as required by the NPPF and the adopted, new London

Plan. It would not achieve the priorities of existing residents as set out in the draft Community Charter let

alone facilitate opportunities for much wider benefits for both existing and future residents and the wider

community It has therefore been discounted from further consideration and it is understood that residents

support this position at the recent consultation workshops. As a result of the above therefore, the

refurbishment option has been discounted and the next section therefore focuses on the main intervention

options under consideration that being: partial and full redevelopment.





5. Planning Assessment of Options

The following section of this report will consider the associated risks and benefits of each intervention

option. This planning assessment takes into consideration Planning Policy, Place Making Factors,

Economic Consideration, and Public Consultation.

Partial Redevelopment

It is important to note that as part of the partial redevelopment options, consideration has been given to the

potential for upward extensions and increased unit sizes to meet the London Plan and nationally described

space standards. However, neither are feasible and therefore have not been carried forward into the latest

iterations of the partial redevelopment options.

Upward Extensions

New permitted development rights were granted in August 2020 to enable additional storeys to be added

to existing residential dwellings and purpose built flatted blocks without the need for full planning permission

(instead Prior Approval only) provided the proposals and existing built form satisfy the criterion set out under

Classes AA-AD of the Town and Country Planning (General Permitted Development) (England)

(Amendment) (No. 2) Order 2020. Extending the existing residential blocks at Elm Grove Estate upwards

provides a means of achieving an uplift in unit numbers through optimisation at selected blocks which

positively responds to the enhanced height parameters established for the Site through both LP allocation

STC45 ( 6 storeys with taller elements) and the STC Masterplan (2016) (7-10 storeys). Levitt Bernstein

therefore undertook a design feasibility study to understood the options available.

The design feasibility study identified that the existing built structures (including foundations) would only

have capacity to carry up to a single additional storey. In order to provide this, the existing roof structure

would need to be removed and any new elements would need to be lightweight in construction to minimise

the additional load. However, in extending the existing floorplates, the new units would be undersized and

the ability to provide private amenity space would be limited, with the potential for bolt-on balconies but

subject to further load testing by a structure engineer. It is noted that there is already an insufficient provision

of external amenity space on the site and this approach would only emphasis that further. In terms of uplift,

this would be limited and not achieve the unit capacities identified in STC 45.

The study therefore concluded that whilst an additional storey may be possible on some of the blocks, it

would not bring the units up to current standards, and the cost and disruption of this approach would

outweigh the benefits of a limited number of new dwellings. It has therefore been discounted from any

further consideration.

Unit Sizes

Levitt Bernstein’s design capacity work also considered the potential options for increasing the size of the

existing units which do not meet current standards. However, the ability to achieve this within the existing

shell would be challenging. For the existing blocks with only a single apartment per floor, it would not be

possible to increase the units within the existing building envelope. For those blocks with two apartments





per floor, it would require the relocation of the core and stair. Whilst this could result in considerably larger

units it would reduce the number of dwellings overall. It is also expected that the works involved in

relocating the core would be significant and costly. Such an option, would also need to be accompanied by

additional development at the Site to ensure, in accordance with adopted London Plan Policy H8, that there

is no loss of existing housing accommodation. However, this additional built form is unlikely to achieve the

net gain of 47 additional units as set out under STC45 and, therefore, it is not considered to optimise the

potential of the Site with the complexities, disruption and costs outweighing the benefits. It has therefore

been discounted from any further consideration.

Partial Redevelopment Option 1 – Infill Blocks

Layout, Height and Massing

This partial redevelopment option seeks to retain the existing estate which would be subject to

refurbishment as set out in Section 4 of this report. Three new residential blocks would then be strategically

located along Elm Grove, with the two southern-most blocks replacing two of the existing truncated roads

which feed into internal parking areas serving the Site and the third smaller northern-most block, sitting

immediately south of the northern ‘cul-de-sac’ within an existing area of green space. The three blocks

would be north-south orientated and sit at three storeys, reflecting the larger scale blocks along the eastern

boundary but dispersed in terms of massing, resulting in the partial-containment of the existing properties

at three junctures along the western boundary.

The layout of the existing estate lacks good urban design principles and the addition of the three new blocks

along the western boundary has the potential to exacerbate this in simply replicating the existing

relationship between the Site and its built form, fragmenting the existing estate into three largely in-ward

looking areas. This is without the added benefits of improved public realm and place-making which could

come forward as part of a more comprehensive development approach.

In terms of height, the additional blocks retain the status quo at a maximum of three storeys and therefore

positively respond to the existing context and sit below the height parameters established within site

specific allocation STC45 and significantly below new height parameters for the site identified within the

STC Masterplan (2016). However, these blocks do not provide the same level of definition gained from the

continuity of similar heights to the east and west and with the backdrop of site specific policy and guidance

(as cited above), in turn, significantly fails to optimise the site’s capacity, contrary to NPPF guidelines,

adopted London Plan and local plan policy seeking to maximise housing opportunity at central and

accessible locations.

Density

This option could result in an additional 14 residential units which falls significantly short of the additional

47 unit net capacity identified within site specific allocation STC45. National, regional and local policy the

optimisation of previously developed (brownfield) land in seeking to support the delivery of much needed

new housing. Policy 7 of the adopted 2018 Local Plan states that the Council will expect development at

such Town Centre locations to be based on the “Central” setting of the former London Plan Density Matrix.

The recently adopted London Plan (March 2021) removes the former Density Matrix along with any

references to the application of density ranges. Instead and in support making the best use of land, Policy





D3 expresses the importance of taking a design-led approach to optimising site capacity with a shift of

focus towards achieving good design which responds to local context, such as character, scale, transport

and infrastructure for example, highly accessible town centre locations.

This option would result in a density of 174 units per hectare. For context only, as a Site within a ‘Central

Setting’, and with a PTAL of 6a the target density range is understood to be 215-405 u/ha (assuming 2.7-

3.0 hr/unit). This partial redevelopment option would therefore fail to achieve the densities set out within

the former London Plan Density Matrix and this is demonstrated most clearly through the under-delivery of

unit numbers when compared to the indicative additional capacity identified within site specific allocation

STC45.

As a highly accessible, Town Centre site subject to a wider STC Masterplan (2016) which recognises the

role of high densities in significantly adding activity and vibrancy to the town, this option would not achieve

a level of optimisation that actively supports these aspirations at a national, regional and local policy level.

In turn, and as set out above it similarly does not provide an opportunity for achieving good design and

place-making and therefore is not considered to comply with the requirement of adopted London Plan Policy

D3.

Housing Mix and Tenure Strategy

In addition to the existing one-bed and two-bed flats, three-bed houses and three-bed bungalows (which

are to be retained as part of this partial redevelopment option), the following could be accommodated

through the uplift of 14 units.

The adopted 2018 Sutton Local Plan indicates that the greatest affordable housing need within the borough

is for one-bed (39%) and two-bed (35%) units. Further to this, adopted LP Policy 9 requires new residential

development within Sutton Town Centre to deliver a unit mix comprising at least 25% three-bed plus

dwellings “unless it can be demonstrated that this would be unviable or the particular site circumstances

are not suitable for family housing.”

The proposed mix of the new homes would not achieve the 25% three-bed policy requirement but would

provide an appropriate provision of one and two bed units, including a proportion of 2B4P units (circa 36%).

This has the potential to more closely align with the affordable housing needs identified within the adopted

2018 Local Plan (as explained above) as well as more up to date housing needs (Sutton’s Housing

Register). Regard has also been given to other Sutton Town Centre schemes (as approved or subject to

S106 agreement) where three-bed provision is generally less than 10% in matching more closely the

housing demands at this central location. This approach aligns with adopted London Plan Policy H10 which

outlines a range of factors which should feed into the proposed mix, including the nature and location of

Unit Type No. of Units % of Units

1B 2P Flat 8 57.14%

2B 4P Flat 5 35.71%

3B 5P Flat 1 7.14%

3B 5P Maisonette 0

Total 14 100%





the site, going on to state that a higher proportion of one and two bed units are generally more appropriate

in locations that are closer to a town centre or station with higher public transport access and connectivity.

It is therefore considered that the proposed housing mix is entirely appropriate as part of an apartment-led

Town Centre scheme.

In turn and giving consideration to resident feedback, this option only accommodates flatted provision, with

all except one unit being one-beds and two-beds. It does not therefore allow for the variety of units types

and sizes, to include maisonettes and houses, that have been identified within the Residents Priorities set

out in the draft Community Charter and which a more comprehensive approach to redevelopment has the

real ability to delivery.

In terms of affordability, LP Policy 8 seeks to achieve 35% of the total number of units as affordable homes,

subject to viability and other factors. The expected split of affordable product is 75:25 between

social/affordable rent and intermediate. Initial viability considerations towards the partial regeneration of the

estate indicate that this option will not be able to deliver the desired level and tenure mix of affordable

housing given the limited uplift in unit numbers balanced alongside the costs of refurbishment of the

remainder of the estate.

Residential Amenity

This option whilst comprising an extent of refurbishment to the existing properties does not address some

of the key issues such as undersized units and small windows which limit the quality of the internal space

in terms of daylight and sunlight. The 14 additional units would be built to meet the London Plan and

nationally described space standards and be designed to achieve good internal living conditions. However,

the presence of additional massing on the western boundary has the potential to intensify the existing

poorer quality daylight and sunlight conditions of the remainder of the estate and at three storeys in height

could appear particularly overbearing for those houses and bungalows within the centre and northern parts

of the Site. This is likely to give rise to potential overlooking and privacy issues, with careful consideration

required towards separation distances and the orientation and internal configuration of the new units in

order to safeguard existing residential amenity.

It is recognised that there is a lack of sufficient and good quality external amenity space on the Site as

existing. This partial redevelopment option would accommodate private outdoor amenity space to serve

the additional 14 units, either in the form of balconies at upper floors, or front or rear gardens at ground

floor and this would be designed to meet the requirements set out in the Mayor of London’s Housing

Supplementary Planning Guidance (SPG) (2016) in accordance with LP Policy 9. It also provides an

opportunity for the formalisation of communal (or ‘semi-private’) courtyard areas to the west of the two new

southern-most blocks which could facilitate space for incidental play areas which starts to address the

Residents Priorities as set out in the draft Community Charter. However, this is not considered to be of a

scale that would benefit the existing estate as a whole nor does it provide new private amenity space, such

as balconies, for the existing homes. There is also a risk, given the consolidated nature of the Site, that the

new amenity spaces may be subject to overshadowing from the surrounding built form which will diminish

the internal quality of these courtyard areas. Without a comprehensive approach in considering layout and

orientation of these amenity spaces through full redevelopment, there remain limitations in working within

the existing block layout constraints of the remaining part of the estate under this option.





The construction of the new residential blocks whilst not requiring any demolition or temporary re-location

of existing residents will result in some disruption in terms of noise, dust, vibration and general building

activity for a set period of time. Careful consideration will therefore need to be given to how this is managed

and parking, access and areas of amenity space retained and useable so as to ensure existing residents

are not adversely affected by the development.

Car Parking, Access and Movement

The existing access off Benhill Avenue would be retained and the extent of Elm Grove largely unaffected

with the exception of the northern end, where a partial set back of the northern-most block would mean the

upper two storeys would overhang the road.

The placement of the blocks would result in the loss of 15 parking spaces and two of the associated internal

access roads which are not proposed to be replaced as part of this partial redevelopment option. Of the 46

car parking spaces currently on the site it is understood that a minimum of 42 spaces are generally

occupied. On the basis of the resident consultation undertaken to date it is understood that the Council is

committed to re-providing all existing occupied spaces to continue to meet the needs of existing residents.

A full survey will need be undertaken to confirm the extent of this need, particularly as it is recognised that

a number of the spaces are used by shop owners and commercial occupiers of the properties immediately

to the west. This will then need to be balanced against the loss of 15 spaces proposed under this partial

redevelopment option and on the assumption that it can be agreed in accordance with adopted London

Plan Policy T6 that the uplift in units will be car-free (with the exception of provision for blue badge holders).

The pedestrian through-route within the northern part of the Site which provides a connection between

Throwley Way and the High Street would be retained in accordance with the site specific allocation STC45

and could benefit from enhanced natural surveillance from the new northern most block. However, this

option does not provide an opportunity for public realm and pedestrian movement improvements along

Throwley Way as sought through site specific allocation STC45 and STC Masterplan (2016).

Partial Redevelopment Option 2 – Houses Only


This partial redevelopment option will involve the demolition of the six central two storey blocks which

comprise 14 x houses and 2 x bungalows. The three storey perimeter blocks along the northern, eastern

and southern boundaries will be retained and the existing units within them will be subject to refurbishment

as set out within Section 4 of this report. The Site will then be framed by the addition of two new linear

blocks located along the western boundary, either side of the existing through route which connects

Throwley Way and the High Street. These blocks will sit at two storeys and provide 17 houses.

The removal of the series of smaller blocks from the centre of the Site and replacement with more

concentrated massing along the Site’s edges better defines the estate itself but does not provide any added

value in terms of permeability, effectively creating a western barrier between Throwley Way and the High

Street. This fails to assist in the integration of the Site into the Town Centre as sought through the

aspirations of the STC Masterplan (2016). From an urban design perspective, the layout provides a more

consistent and equal relationship between the residential blocks, opening up the estate internally and

3 Agenda Item 5




providing a focal strip that extends the length of the Site and is free from built form.

The height of the two new blocks will continue to reflect the lower two storey height parameter already

established within the central part of the Site. This sits, again, significantly below the 2 to 6 storey indicative

height range (with taller elements) as identified within STC45 and therefore within its context will appear

as a marked “step down” from the three and four storeys that immediately surround the Site. This option

also fails to give any regard to accommodating taller elements along Throwley Way with the potential for

heights between 7 to 10 storeys, as set out within the STC Masterplan which can only be addressed through

a comprehensive redevelopment approach. It is therefore not considered to effectively optimise the

potential of the Site as identified in policy and design terms which is clearly evident through only facilitating

the creation of one additional unit when balanced against the provision of the 16 units demolished and

replaced.

Density

As noted above, this option would only result in one additional residential unit when considered against the

need to re-provide the 16 existing residential units displaced as result of the proposed demolition of the

central blocks. This does not therefore achieve any notable uplift in residential units and would be

considered to perform poorly against the requirements of adopted London Plan Policy H8 which expects

an uplift, where viable, in affordable housing where development proposals include demolition and

replacement of existing stock. It similarly does not satisfy the 47 unit net capacity identified within site

specific allocation STC45 and therefore in national, regional and local planning policy terms would not be

considered to represent the optimisation of previously developed (brownfield) land which is essential in

supporting the delivery of much needed new housing.

Whilst the recently adopted London Plan (March 2021) removes the former Density Matrix in favour of a

design-led approach (London Plan Policy D3), LP Policy 7 does refer back to it in seeking to assess the

acceptability of schemes. Therefore for context only, this option would result in a density of 148 units per

hectare. This would fall significantly short of the density range for a ‘Central Setting’ site at 215-405 u/ha

(assuming 2.7-3.0 hr/unit).

In giving consideration to the design-led approach to site optimisation, as set out under London Plan Policy

D3, this partial redevelopment option does provide opportunities for some place-making. However, this is

with a focus on improved experience and quality for residents and, as set out above, does not necessarily

make the best use of land with respect of form and layout and therefore is not considered to satisfy the

requirements of adopted London Plan Policy D3.


This partial redevelopment option would re-provide 16 units to compensate for the loss of the existing three-

bed houses and two-bed bungalows. It would also result in the delivery of one additional house, as set out

below.





In accordance with adopted London Plan Policy H8, the proposed re-provision which is considered to be

like for like in terms tenure in order to facilitate a right to return, would ensure that an equivalent (and slightly

greater) amount of replacement affordable housing floorspace is delivered (based on habitable rooms).

This is on the basis that in addition to the like for like replacement of the existing 14 x three-bed houses,

the existing 2 x two-bed bungalows would also be replaced with 2 x three-bed houses which in accordance

with London Plan and nationally described space standards will provide larger individual units, increasing

the quantum of floorspace (in terms of habitable rooms) overall.

However, adopted London Plan Policy H8 also states that “all development proposals that include the

demolition and replacement of affordable housing…should seek to provide an uplift in affordable housing

in addition to the replacement affordable housing floorspace”. This option creates one additional unit in

addition to a slight increase in replacement affordable housing floorspace which does very little to contribute

to the delivery of much needed affordable (and private sale) housing both at a national and local level.

In terms of unit type mix, the introduction of an additional 3 x three-bed family unit when compared to the

existing housing mix is welcomed in planning policy terms and positively responds to the Residents

Priorities as set out in the draft Community Charter which seeks more genuinely affordable homes for local

families but not at the volume required to meet needs.

Residential Amenity

This partial redevelopment option will provide significantly improved living conditions for a small majority of

existing residents in the form of larger and better quality homes built to modern standards as well as new

private amenity spaces in the form of front and rear gardens serving the individual properties. However, for

the majority of existing residents located within the retained perimeter blocks, the proposed refurbishment

works, as set out within Section 4 of this report, will not address some of the key issues identified by both

the Council and residents. The units will remain undersized and they will not benefit from new private

amenity space.

The removal of massing from the centre of the Site and setting back of the new blocks along the western

boundary will improve the internal quality of the estate, maximising separation distances between the


Re-provision

1B 2P Flat 0 -

2B 4P Flat 0 -

3B 5P Flat 0 -

3B 5P House 16 94%

Total 16 -

Additionality

1B 2P Flat 0 -

2B 4P Flat 0 -

3B 5P Flat 0 -

3B 5P House 1 6%

Total 1 -

TOTAL 17 100%





elements of built form and encouraging a better outlook for existing residents. It has the potential to improve

the daylight and sunlight conditions for those units located on the lower two floors of the retained perimeter

blocks.

The opening up of the centre of the Site also provides an opportunity to address the current lack of sufficient

and good quality external space. The creation of a green thread of communal courtyards which will run

along the eastern blocks and be interspersed with areas for play and landscaping will positively contribute

to ‘urban greening’ as set out under London Plan Policy G5. When compared to partial redevelopment

option 1 this layout allows for more meaningful external amenity provision which would benefit the existing

estate as a whole and provide an element of play space on-site for existing residents. However, the more

onerous standards for private amenity space associated with three-bed dwellings when compared to other

unit types does mean that the on-site provision for gardens requires a substantial land take which

diminishes the extent of the ‘green’ space within the central strip that is accessible to all residents and could

be considered to appear disproportionate.

Given this partial redevelopment option will involve both demolition and construction, existing residents are

likely to experience significant disruption, with regards to noise, dust, vibration and general disturbance as

a result of the associated activities. Existing residents within the houses and bungalows to be demolished

will need to be decanted and the strategy for this will require careful consideration as to whether this can

be dealt with on-site or require housing to be made available off-site in light of the phasing of development.


The existing access off Benhill Avenue and extent of Elm Grove, as existing would be retained. However,

the placement of the two blocks along the western boundary would result in the loss of the three internalised

car parking areas as well as the truncated roads that provide access to these. An extent of this displaced

parking could be accommodated through the infilling of the existing linear strip of parking bays that runs

parallel to Elm Grove and will be further defined by the two new residential blocks along this western

boundary. Overall, there will be a loss of 21 car parking spaces as a result of this option.

It is recognised that a minimum of 42 of the existing 46 car parking spaces on the Site are generally

occupied and the Council is committed to re-providing all existing occupied spaces to continue to meet the

needs of existing residents. A full survey will need be undertaken to confirm the extent of this need,

particularly as it is recognised that a number of the spaces are used by shop owners and commercial

occupiers of the properties immediately to the west. However, this option only allows for a total of 25 car

parking spaces to be re-provided and therefore is unlikely to be considered favourably by existing residents.

The impact of an additional unit on the Site is likely to be negligible in parking and highways terms. In

accordance with London Plan Policy T6, as a Town Centre Location with an ‘excellent’ PTAL rating, the

starting point for new development should be car-free and the additional unit does not give rise to minimum

disabled parking requirements as set out under London Plan Policy T6.1.





The alignment of the new residential blocks along the western boundary of the Site in combination with the

linear placement of parking bays, allows for the creation of a new north-south pedestrian link which joins

the existing east-west route at the meeting point of the new blocks and could form a focal area of public

space. In addition, this option provides an opportunity for improvements to the public realm along this route

as well as at the access point off Throwley Way which starts to contribute towards the urban boulevard

aspirations for Throwley Way as set out under site specific allocation STC45 and the STC Masterplan

(2016). However, the scope for improvements is limited and this option fails to facilitate the integration of

the Site into the Town Centre as sought by the STC Masterplan (2016). The pedestrian through-route within

the northern part of the Site will be retained as existing but there is no added value in terms of permeability,

meaning it lacks the ability to provide wider benefits for surrounding residents which could be gained

through a comprehensive redevelopment approach.

Partial Redevelopment Option 3 – Flats & Maisonettes


Similar to partial redevelopment option 2, this option will also involve the demolition of the six central two

storey blocks which comprise 14 x houses and 2 x bungalows. The three storey perimeter blocks along the

northern, eastern and southern boundaries will be retained and the existing units within them will be subject

to refurbishment as set out within Section 4 of this report. Two new L-shaped blocks are proposed along

the western boundary, orientated north to south before then each extending eastwards at the existing

through-route which connects Throwley Way and the High Street, effectively dividing the Site into two parts.

These blocks will sit at four storeys and provide 48 residential units.

From an urban design perspective, the layout, as per partial redevelopment option 2, concentrates massing

along the Site’s physical edges whether this be Throwley Way to the east, Elm Grove to the west, or the

walkway through the northern part of the Site. As a result the estate is effectively internalised with built form

containing and clearing defining the ‘private’ areas that serve residents from those forming public spaces

as part of the Site’s immediate surroundings.

In seeking to optimise the Site’s potential, the height of the two new blocks at four storeys responds slightly

more positively to the indicative height parameters set out under specific allocation STC45 albeit still

representing under-utilisation in terms of housing potential. Within the wider context, this option provides

a potential transition between the higher 4 and 5 storey heights at the north western end of the High Street

and the lower three to two storey heights to the east. However, as these blocks are proposed to consistently

sit at four storeys across the extent of the Site, consideration does need to be given to how, in their relatively

central position, they will relate to the three storey buildings immediately to the east and west, as well as

each other, to ensure massing is staggered where appropriate and does not appear overbearing. Whilst

this option goes further in seeking to make effective use of the land, it does not maximise the opportunity

for taller elements at appropriate locations of the estate and, in particular, along Throwley Way with the

potential for heights of 7 to 10 storeys (as cited within the STC Masterplan). This would provide a means

of ensuring the scale and bulk of development is more effectively dispersed across the Site which, in turn,

is likely to be achieved most comprehensively through full redevelopment.





Density

This option would result in an additional 32 residential units which of the three partial redevelopment options

gets the closest in seeking to achieve the 47 unit net capacity identified within STC45 albeit still below

requirements. In line with national, regional and local policy, it is demonstrating how previously developed

(brownfield) land could be optimised to support the delivery of much needed new housing. This option

would result in a density of 210 units per hectare. In accordance with LP Policy 7 and in the context of the

former London Plan Density Matrix, this still falls below the minimum density of 215 units per ha (assuming

2.7-3.0 hr/unit) established by the range appropriate for the Site.

NPPF paragraph 123 states that “where there is an existing or anticipated shortage of land for meeting

identified housing needs, it is especially important that planning policies and decisions avoid homes being

built at low densities, and ensure that developments make optimal use of the potential of each site”.

(author’s emphasis). Part (b) continues and explains that in achieving this it “…should include the use of

minimum density standards for city and town centres and other locations that are well served by public

transport. These standards should seek a significant uplift in the average density of residential development

within these areas…” (again, author’s emphasis).

There is a clear shortage of ‘deliverable’ land to meet identified housing needs both within a local and

regional context as is evidenced through the adopted 2018 Local Plan and recently adopted London Plan

(March 2021). The Site is located within a designated Town Centre and is highly accessible with a PTAL

rating of 6a. It is also subject to the STC Masterplan (2016) which recognises the role of higher densities

in adding activity to the town. In accordance with the NPPF, building at low densities, as would be the case

under this option, should be avoided. The Site represents an opportunity for achieving a significant uplift in

the average density of residential development and this is supported at a local level by indicative design

parameters and higher residential capacity (site specific allocation STC45). This option would not, however,

enable this potential to be achieved.


This partial redevelopment option would re-provide 16 units to compensate for the loss of the existing three-

bed houses and two-bed bungalows. It would also result in the delivery of 32 additional residential units, as

set out below.





In accordance with adopted London Plan Policy H8, the proposed re-provision would ensure an equivalent

amount of affordable housing floorspace is delivered on-site to compensate for the loss as a result of

demolition. In turn, when considered in terms of ‘floorspace’ (which is based on habitable rooms), it is

anticipated that this option could result in an increase in affordable housing floorspace under London Plan

Policy H8. This is on the basis that the existing 2 x two-bed bungalows would be replaced with 2 x three-

bed units introducing an additional habitable room to each unit when compared to the existing which will

increase the quantum of floorspace (in terms of habitable rooms) overall.

Adopted London Plan Policy H8 also expects “all development proposals that include the demolition and

replacement of affordable housing...should seek to provide an uplift in affordable housing in addition to the

replacement affordable housing floorspace”. It understood that the Council seek to deliver 50% affordable

housing as part of the total additional units (over and above the re-provision component). This provision

therefore exceeds the adopted 2018 Local Plan requirements of 35% (based on units). It would equate to

an uplift of 16 affordable housing units (of a mix of affordable tenure) across the estate, therefore. However,

the viability testing of this will be critical to determine whether this level and mix can be supported given the

extent of the total number of new homes created through this partial redevelopment option, the

refurbishment costs of existing homes within the remaining part of the estate and when also set against

other potential S106 obligations and contributions.

In terms of unit mix, the additionality would not achieve the 25% three-bed requirement but would provide

high proportions of one and two bed units, including a proportion of 2B4P units (circa 34%). This has the

potential to more closely align with the affordable housing needs identified within the adopted 2018 Local

Plan (at 39% 1 beds and 35% 2 beds) as well as more up to date housing needs (Sutton’s Housing

Register). Regard has been given to other Sutton Town Centre schemes (as approved or subject to S106)

where three-bed provision is generally less than 10%. This approach aligns with London Plan Policy H10

which outlines a range of factors which should feed into the proposed mix, including the nature and location

of the site, going on to state that a higher proportion of one and two bed units are generally more appropriate

in locations that are closer to a town centre or station with higher public transport access and connectivity.

It is therefore considered that a 4% three-bed provision represents a proportionate amount at this town

centre location.


Re-provision

1B 2P Flat 0 -

2B 4P Flat 0 -

3B 5P Flat 1 -

3B 5P Maisonette 15 -

Total 16 -

Additionality

1B 2P Flat 20 63%

2B 4P Flat 11 34%

3B 5P Flat 1 3%

3B 5P Maisonette 0

Total 32 100%

TOTAL 48 -





When considered against the other two partial redevelopment options, this option provides the greatest

variety of unit types and sizes comprising one-bed, two-bed and three-bed flats as well as three-bed

maisonettes which provide alternative family accommodation when compared to houses. This mix when

compared to partial redevelopment option 2, contributes to a slightly greater optimisation of the Site’s

potential. It also more positively responds to the Residents Priorities set out in the draft Community Charter.

Residential Amenity

As per partial redevelopment option 2, this option could provide significantly improved living conditions for

a small majority of existing residents as well as a number of new residents currently on the Council’s

Housing Register. This in the form of larger and better quality homes built to modern standards and which

are directly served by private amenity space designed to London Plan standards and in the form of a front

or rear garden for the maisonettes and flats at ground floor or balconies for those on the upper floors.

However, for the majority of existing residents located within the retained perimeter blocks, the proposed

refurbishment works, as set out within Section 4 of this report, will not address some of the key issues

identified by both the Council and residents. The units will remain undersized and they will not benefit from

new private amenity space.

The removal of massing from the centre of the Site and setting back of the new blocks along the western

boundary could improve the internal quality of the estate, maximising separation distances between the

elements of built form where possible and encouraging a better outlook for existing residents. This option,

similar to partial redevelopment option 2, has the potential to improve the daylight and sunlight conditions

for those existing units located on the lower two floors of the retained perimeter blocks. However, careful

consideration will need to be given to the orientation of units within the southern and eastern ends of the

new blocks as well as the proximity of these to the adjacent retained blocks to ensure there are no adverse

impacts in terms of overlooking/loss of privacy and daylight/sunlight; particularly given the additional fourth

storey. The placement and treatment of private amenity space serving units at ground floor along the public

route through the Site will also require further refinement to ensure there is sufficient defensible space

between these public and private areas in the interest of safeguarding residential amenity.

The proposed housing mix reduces the need for expansive gardens when compared to the housing-only

mix of partial redevelopment option 2 with a greater provision of private amenity space instead

accommodated in the form of balconies. As a result, the central area of the Site will be able to fulfil a greater

estate-wide function in terms of communal amenity and play space whilst also positively contributing to

‘urban greening’ as set out under London Plan Policy G5. However, as a result of the proposed housing

mix, this option generates a larger new resident population which increases on-site requirements, to include

children’s playspace. This will need to be tested in accordance with the GLA’s play space calculation to

determine demand at the detailed design stages.

Given this partial redevelopment option will involve both demolition and construction, existing residents are

likely to experience significant disruption, with regards to noise, dust, vibration and general disturbance as

a result of the associated activities. Existing residents within the houses and bungalows to be demolished

will need to be decanted and the strategy for this will require careful consideration as to whether this can

be dealt with on-site or require housing to be made available off-site in light of the phasing of development.






As per partial redevelopment option 2, the existing access off Benhill Avenue and extent of Elm Grove, as

existing would be retained and overall, there will be a loss of 21 car parking spaces as a result of this option.

It is understood that the Council is committed to re-providing all existing occupied spaces to continue to

meet the needs of existing residents and that a full survey will need be undertaken to confirm the extent of

this need. However, similar to partial redevelopment option 2, this option only allows for a total of 25 car

parking spaces to be re-provided (54% of the existing provision) and therefore is unlikely to be considered

favourably by existing residents.

In addition, this option will result in 32 additional residential units which could put further pressure on the

demand for on-site parking. However, as a Town Centre Location with an ‘excellent’ PTAL rating, the

starting point for new development should be car-free in accordance with London Plan Policy T6. This is

with the exception of disabled parking provision where a minimum 3% requirement is expected under

London Plan Policy T6.1 with an ability to demonstrate that a further 7% could be provided to serve future

needs if required. Regard has been given to comparable Sutton Town Centre schemes with a PTAL of 5

or 6 (as approved or subject to S106) and it is evident that the Council is endorsing the car-free approach

with the exception of disabled parking where a provision of up to a maximum of 10% is being pursued

subject to the capacity within the immediate surrounding. Therefore, consideration would need to be given

to how disabled parking requirements could be addressed as part of this option.

Similar to partial redevelopment option 2, the reconfiguration of the Site’s layout provides opportunities for

public realm improvements. The alignment of the new blocks along the western boundary in combination

with the linear placement of parking bays creates a new north-south pedestrian link which joins the existing

east-west route through the Site at the meeting point of the new blocks and could form a focal area of public

space. Whilst the pedestrian through-route within the northern part of the Site will be retained, it will remain

as existing and potentially become more confined as a result of the placement of the two L-shaped blocks

on its northern and southern edges. This limits the permeability of the Site and prevents any opportunities

for enhanced east-west connections as sought by site specific allocation STC45 and the STC Masterplan

(2016). It therefore lacks the ability to positively contribute towards the creation of an urban boulevard along

Throwley Way and deliver wider neighbourhood improvements which a comprehensive redevelopment

approach would provide an opportunity for.

Full Redevelopment


The comprehensive redevelopment of the Site will involve the complete demolition of the existing estate to

provide three new residential blocks. The massing will be concentrated along the eastern boundary of the

Site to maintain a strong and regular frontage onto Throwley Way, as per the existing estate. Built form will

then extend westwards, into the Site, effectively creating three separate parcels each centred around ‘semi-

private’ courtyards and accessed via openings in the blocks at the southern wester corners. The

reconfiguration of the Site in this way positively responds to the urban grain beyond Throwley Way so that

development is broken down into self-contained plots, separated via distinctive east to west movement

corridors.





The establishment of a 10 storey element at the north eastern corner of the Site, fronting the junction of

Marshall’s Road and Throwley Way which then steps down to nine, eight and six storeys as the blocks

recede south, accords with the aspirations of the STC Masterplan (2016) and the potential 7 to 10 storey

height range that the Site is noted to fall within. It also addresses the indicative design parameters and

principles set out under site specific allocation STC45 which encourages taller elements (above 6 storeys)

along this frontage before stepping down to the west. The three blocks do this respectively, lowering in

height to six, five, four and finally three storeys as the blocks met Elm Grove. This gradual transition in

height reduces the scale of development so that within the Site the built form respects and relates well to

the existing three and four storey context to the south and west whilst also adhering to the indicative 2 to 6

storey height range set out under site specific allocation STC45.

Whilst the principle for up to 10 storeys at the Site is considered within the STC Masterplan this will need

to be fully explored with LBS Planning Officers in demonstrating that in the delivery of a ‘tall’ building, the

redevelopment achieves good design and place-making. The parcel of land directly adjacent to the Site,

beyond Marshall’s Street to the north, is allocated within the adopted 2018 Local Plan under STC25

(Matalan Block) and identified for heights of 2 to 10 storeys. The 10 storey element within this full

redevelopment option would be responding positively to this and it provides further context within which the

redevelopment of the Site should be considered. This is particularly important in seeking to optimise the

Site’s potential, which only this full development option is able to achieve in line with the indicative height

parameters. Any development at the Site needs to be forward-looking in order to address the longer-term

aspirations of local and regional policy as part of a coherent approach to regeneration within the Town

Centre, as sought by the STC Masterplan. The full redevelopment option provides a unique opportunity for

this.

Density

The full redevelopment option would result in a total of 225 residential units, which represents an uplift of

152 units when compared to the existing estate and triples the 47 unit net capacity identified within site

specific allocation STC45.

As set out previously in this report, the NPPF requires the use of minimum density standards for Town

Centre locations which are well served by public transport, such as the Site and encourages these such

standards to achieve a “a significant uplift” in density within these areas (NPPF, paragraph 123). This full

redevelopment option would equate to a density of 450 units per hectare. In accordance with national

guidance, the London Plan (March 2021) no longer identifies density standards in favour of a design-led

approach to optimisation as set out under Policy D3. However, LP Policy 7 does refer back to the former

London Plan Density Matrix as a benchmark, and therefore, for context, this full redevelopment option

would exceed the upper figure of the indicative density range for the Site, which sits at 405 u/ha.

In taking a design-led approach to optimising the Site’s capacity as required by London Plan Policy D3,

emphasis is instead placed on the local context, to include character, scale, transport and infrastructure.

The Site is located within a designated Town Centre and highly accessible with a PTAL rating of 6a. It is

subject to the STC Masterplan (2016) which recognises the role of high densities in creating activity to the

town and the Site is identified in having an important role to play within this. Therefore, in accordance with

the NPPF and London Plan policies and in the context of site specific allocation STC45, the full





redevelopment of the Site provides an opportunity for density optimisation.


This full redevelopment option will re-provide the existing 73 units at the estate and it is understood that

these will be like for like in terms of unit sizes and tenure in order to facilitate the right to return for existing

residents. This is with the exception of the 14 x three-bed houses and 2 x two-bed bungalows which are

proposed to be re-provided in the form of three-bed flats and maisonettes. It is understood that this has

been discussed with residents as part of the consultation undertaken to date and that those occupiers that

would be affected, are supportive of this transition. In addition, the comprehensive redevelopment of the

estate would provide an opportunity for an additional 152 residential units, as set out below.

In accordance with adopted London Plan Policy H8, the existing 73 units on the estate will be replaced as

part of the full redevelopment of the Site through an equivalent amount of affordable housing floorspace (in

terms of habitable rooms). In addition, there is the potential for an increase in ‘floorspace’ (in terms of

habitable rooms) when compared to the existing provision on the Site. This on the basis that the existing 2

x two-bed bungalows will be replaced with 2 x three-bed units increasing the quantum of floorspace (in

terms of habitable rooms) overall. Finally, this option will also provide 43 additional affordable units which

represents a significant uplift in compliance with part E of London Plan Policy H8.

Overall, the full redevelopment of the scheme has the potential to provide 116 affordable housing units on

the Site which equates to 52% of the total number of houses being delivered. This meets and exceeds the

adopted 2018 Local Plan requirement target of 35% (LP Policy 8) and accords with London Plan Policy H8

in terms of like for like re-provision and a potentially viable uplift of additional affordable homes. In terms of

tenure mix, this option is broadly compliant with adopted LP Policy 8 at 79% London Affordable Rent/Social

Rent and 21% intermediate products (although would fall short of the minimum 30% requirement for

intermediate products sought under London Plan H6).

It is recognised that the above will be subject to detailed viability testing with the precise affordable mix and

tenure to also be discussed in consultation with LBS’s Planning Officers as part of any pre-application


Re-provision

1B 2P Flat 45 -

2B 4P Flat 12 -

3B 5P Flat 9 -

3B 5P Maisonette 7 -

Total 73 -

Additionality

1B 2P Flat 65 43%

2B 4P Flat 85 56%

3B 5P Flat 2 1%

3B 5P Maisonette 0

Total 152 100%

TOTAL 225 -





engagement on a preferred option. However, unlike the partial redevelopment options, this full

redevelopment option offers an opportunity to provide a range of affordable housing products across a mix

of unit types and therefore significantly contribute to meeting identified housing needs and demands both

in terms of affordable and private sale.

In terms of overall unit mix, neither the scheme as a whole or the additionality in isolation would achieve

the 25% three-bed requirement. However, it would provide high proportions of additional one and two bed

units (43% and 56% respectively), including a proportion of 2B4P units which aligns with more up to date

housing needs (Sutton’s Housing Register). Regard has been given to other Sutton Town Centre schemes

(as approved or subject to S106) where three-bed provision is generally less than 10%. This approach

aligns with London Plan Policy H10 which outlines a range of factors which should feed into the proposed

mix, including the nature and location of the site, going on to state that a higher proportion of one and two

bed units are generally more appropriate in locations that are closer to a town centre or station with higher

public transport access and connectivity. It is therefore considered that an 8% three-bed provision overall

represents a proportionate amount at this town centre location with the precise mix subject to detailed

consultation with Planning Officers at LBS.

Overall and when considered in the context of the partial redevelopment options, this option provides the

greatest variety of unit types and sizes comprising one-bed, two-bed and three-bed flats as well as three-

bed maisonettes which provide alternative family accommodation and is considered a more suitable

typology in a Town Centre location. It positively responds to the Residents Priorities set out in the draft

Community Charter and is considered to represent the effective optimisation of the Site in enabling the

estate to improve its important role in continuing to meet identified local housing needs.

Residential Amenity

Unlike the partial redevelopment options, the full redevelopment of the Site provides an opportunity to

significantly improve living conditions for all existing residents and comprehensively address the Residents

Priorities (as set out in the draft Community Charter). In particular, this will involve the provision of larger

and better quality homes built to modern standards which will be directly served by private amenity space

designed to London Plan standards and comprise either a front or rear garden for the maisonettes and flats

at ground floor, or balconies for those on the upper floors.

The concentration of the development around central ‘green areas’ will improve the internal quality of the

estate and provide a better outlook for residents whilst ensuring appropriate separation distances are

maintained between the inward facing facades of the blocks. The scheme should look to maximise the

provision of dual aspect units to ensure that all new homes achieve acceptable levels of daylight and

sunlight in accordance with London Plan Policy D6. This will need to be supported by daylight and sunlight

testing as part of the detailed design work and will in turn inform the configuration of units. Within the

development this will be particularly important at the pinch-points where two ‘arms’ of the development

blocks meet and where the blocks sit immediately adjacent to one another, either side of the movement

corridors. In this respect, the arrangement of the units should ensure that there is no direct overlooking and

good levels of privacy are achieved.

The elements along Throwley Way have the potential to cause overshadowing both in relation to the lower

three and four storey elements as well as the external amenity spaces. This will need to be tested at the





detailed design stage to ensure all areas are useable in accordance with BRE guidance. Beyond the Site,

consideration will also need to be given to the potential impact of the increased massing on neighbouring

residents; in particular the 8 to 10 storey heights on the smaller scale existing residential development to

the north and east. The separation provided via Throwley Way is considered to assist in mitigating the

potential for any direct adverse effects on neighbouring residential amenity but the relationship with the

existing building adjoining the Site in the north-eastern corner is likely to require more sensitive treatment.

The comprehensive redevelopment of the Site provides an opportunity for provide all residents with external

high quality outdoor private amenity space as well as communal amenity space in the form of ‘semi-private’

courtyards and play areas. This directly responds to the Residents Priorities set out in the draft Community

Charter and contributes to ‘urban greening’ in accordance with London Plan Policy G5. It is understood that

this full redevelopment option has been designed to meet the requirements for private amenity space set

out in the Mayor of London’s Housing Supplementary Planning Guidance (SPG) (2016) and in accordance

with LP Policy 9. The placement and treatment of private amenity space serving units at ground floor along

the public routes through the Site will need to be designed to ensure there is sufficient defensible space

between these public and private areas in the interest of safeguarding residential amenity.

In terms of child’s play space, the GLA’s calculation indicates that this full redevelopment option will give

rise to a need for approximately 876 square metres of provision on-site on the basis of the proposed housing

mix. An allowance has been designed into this option and it will need to be quantified at the next stage of

the process to determine whether this can all be accommodated on-site and where not feasible whether

this may give rise to financial contributions in lieu to support improved or new provision within the vicinity

of the Site. As part of this full redevelopment option, it is understood that there may be an opportunity for

the incorporation of a part-first floor podium. Levitt Bernstein has advised that this would continue to

facilitate the delivery of 225 units as proposed under this option whilst also allowing for the more effective

use of the Site as a whole. In this way, car parking re-provision along with accessible play space serving

the family maisonettes could be provided at ground floor with access to a podium at first floor which could

provide additional communal amenity provision as well as play space. This provides a greater opportunity

to meet the needs of future residents on-site. However, the feasibility of this will be subject to detailed

design and viability considerations.

It is understood that the delivery of the full redevelopment option will be phased in three parts. Whilst this

may require some existing residents of the first phase to move off-site temporarily, the benefits of this

comprehensive redevelopment approach means the decant and recant of existing residents can otherwise

be accommodated on-site through a careful phasing strategy. In the feedback received from residents to

date, it is acknowledged that there may be some temporary disruption but that in the longer-term this is the

only option that will enable the existing issues to be resolved and Residents Priorities to be wholly satisfied.

Car Parking and Access

The existing access off Benhill Avenue and extent of Elm Grove, as existing, would be retained as part of

the full redevelopment option. However, the current configuration and quantum of car parking would be lost

through the comprehensive redevelopment of the Site. It is understood that there are two potential

approaches for re-providing car parking on-site; one would comprise the re-provision of 32 of the existing

46 spaces through the internalisation of parking courtyards within the three development parcels (resulting

in a loss of 14 spaces); the other would comprise podium development which would facilitate the on-site





provision of 55 car parking spaces (resulting in a net gain of 9 spaces). Levitt Bernstein has confirmed that

the podium approach would not impact on the number of units that could be delivered as part of this option

and in turn would provide wider benefits in allowing for a greater provision of communal amenity space and

child’s play areas to come forward where currently space is reserved for parking functions. However, it is

recognised that this will have cost implications that will need to be weighed in the balance as part of the

viability testing exercise.

It is understood that the Council is committed to re-providing all existing occupied car parking spaces as

part of any redevelopment option in order to continue to meet the needs of existing residents. It is

acknowledged that a full survey will be undertaken to confirm the extent of this need and this will in turn

determine whether the proposed re-provision of 32 spaces, which can be accommodated without the need

for a podium, is sufficient.

In terms of the new residents of the additional 152 units, as a Town Centre Location with an ‘excellent’

PTAL rating, the starting point in accordance with London Plan Policy T6 should be that the development

is car-free. This is with the exception of disabled parking provision where a minimum 3% requirement is

expected under London Plan Policy T6.1. The uplift of 9 spaces that would be provided via the podium

approach would enable for this requirement to be satisfied on-site, accommodating 4 spaces on the Site

for disabled persons whilst also demonstrating that there is capacity for an additional 5 spaces (achieving

a total of 6%) to come should forward should future needs arise. Regard has been given to comparable

Sutton Town Centre schemes with a PTAL of 5 or 6 (as approved or subject to S106) and it is considered

that this would align with the approach the Council is taking where they are endorsing car-free development

with the provision for disabled persons parking at 5-7%.

Unlike the partial redevelopment options, this option facilitates both the retention and improvement of the

existing through-route within the northern part of the Site as well as the creation of a new north-south

pedestrian link through the site (as explained under partial redevelopment option 3). In addition, the full

redevelopment of the estate provides an opportunity for an additional east-west connection to be created

between Throwley Way and the High Street. This will formalise an underutilised route that exists between

the High Street and Elm Grove and provide an additional direct link through the Site as sought under site

specific allocation STC45. This will be complemented by an opportunity to redefine the public realm along

Throwley Way and positively contribute to the creation of an urban boulevard as per the aspirations of the

STC Masterplan (2016). When considered in the context of the partial redevelopment options, this option

is the only one that is able to deliver these wider public benefits identified within the adopted 2018 Local

Plan and result in a renewed sense of place as part of the Northern Gateway.





6. Other Planning Considerations

This section includes consideration of other salient planning matters that are likely to influence the

development potential of the site. The key matters to be covered are as follows:

I. Housing Need

II. Socio-Economic and Social Value Factors

III. Energy and Sustainability

IV. CIL and s106 Contributions

Housing Need

The adopted 2018 Local Plan establishes a housing delivery target of 427 units per annum. The recent

publication of housing need figures based on the Government’s revised standard methodology (‘SM1.1’)

and inclusive of a 35% uplift across London Boroughs, identifies an increased requirement for LBS of 807

homes per annum.

In terms of affordable housing, the adopted 2018 Local Plan outlines that the number of affordable homes

being built is falling. It identifies that there is a net requirement of 1,018 homes per year over the plan period

based on occupants’ spending 30% of income on housing costs. This net affordable need represents 238%

of the plan’s annualised housing target. It is therefore clear that affordable housing delivery is critical and

Elm Grove offers an early development opportunity to assist in meeting this need.

The comprehensive regeneration of the estate would 1) provide better housing for the current residents but

also 2) allow the site to help deliver more housing to meet future needs for affordable (and market) housing

in line with the Council’s up to date Housing Register. The regeneration of the estate allows an increased

volume of purpose built housing stock to be built which could play a significant role in reducing deprivation

levels.

The opportunity to diversify housing mix, type and size to meet current needs means that a broader cross

section of needs of various groups within the community, including young people, elderly and vulnerable

groups can be met locally, without them needing to move away to find suitable accommodation. This option

also offers an opportunity to address the balance of tenures to create a sustainable mixed and balanced

community in accordance with adopted 2018 Local Plan (and adopted London Plan) policy requirements.

It should also be noted that full regeneration offers the greatest opportunity to give more detailed

consideration to positive health impacts of living in better quality residential accommodation through the

evolution of the regeneration proposals, taking account of the Mayor’s Social Infrastructure SPD and draft

SPD guidance “Good Quality Homes for all Londoners” (October 2020). As set out within Sections 4 and 5

of this report, neither the refurbishment nor the partial redevelopment options would be able to achieve this

and address all the existing issues identified by both the Council and residents which are need to be

resolved in order to bring the existing stock up to modern living standards.





Socio-Economic and Social Value Factors

The adopted 2018 Local Plan also identifies that the number of households in Sutton is increasing and is

continued to do so over the plan period. Partial redevelopment options 1 and 3 as well as the full

redevelopment option will ensure that the Elm Grove Estate site can contribute to accommodating this

increase in households to ensure that people are not left without any other choice but to look at housing in

other boroughs. The knock-on effect of retaining and accommodating this growth in households is the

sustained and future increase in local spend by future residents to the High Street. This potential for

increased expenditure is likely to result in increased job opportunities within those local businesses and

services within the town centre.

The regeneration proposals will also increase revenues received by the Council through council tax which

can be reinvested to improve the borough further. The Council tax receipt created from either the partial or

full redevelopment option could also be improved via the New Homes Bonus, a government scheme where

central Government matches the council tax raised from new homes for the first six years.

The construction of the full regeneration option is also likely to have a positive social value impact delivering

multiple benefits to the local community (with the largest number of benefits possible through the full

redevelopment option). There would be benefits associated with construction-related job opportunities

during construction. This could include on-site training opportunities for apprentices which could be secured

by planning legal agreement. This could also include construction related jobs for a number of construction

workers who have been previously unemployed and the number of jobseekers’ allowance claimants.

Associated NHS saving with returning to work could also be calculated to support the social value

measurement. These intervention options would also deliver multiple community benefits including

provision of a community space, public realm improvements, play space, additional local procurement

during the construction which will support local businesses ensuring that the local community will benefit

from the investment in the area. All such contributions assist in drawing together the social value benefits

generated from the regeneration of the site.

Energy and Sustainability

In accordance with adopted LP Policy 31, major residential development is expected to achieve a 35%

reduction in regulated CO2 emissions on site, and offsetting the remaining regulation emissions (to 100%)

through the delivery of CO2 reduction measures elsewhere through Section 106 Agreements. At least 20%

reduction in total CO2 emissions (regulated and unregulated) is also required through renewables.

The refurbishment and partial redevelopment options would provide limited scope for the utilisation of new

energy and sustainability measures when compared to full redevelopment which would introduce more

energy efficient development, using a fabric-first approach, consistently across the Site and for all residents.

It also offers an opportunity for the incorporation of renewable measures such as green roofs, roof gardens

and solar panels.





CIL and S106 Contributions

CIL

Sutton Council adopted their CIL Charging Schedule on 1 April 2014 and sets a flat rate of £100 per square

metres for new residential floorspace. Development at the Site will also be liable for Mayoral CIL (MCIL2).

The MCIL Charging Schedule was adopted in April 2019 and sets a flat rate for Zone 3 boroughs (for which

Sutton sits) of £25 per square metres for any new floorspace.

Based on the scale of the full redevelopment option, the requisite CIL charges are likely to be significant

and this can be reinvested into the borough and wider region with improvements to existing infrastructure

being facilitated by such a receipt.

S106 Contributions

At this stage we are unable to comment with any kind of certainty on potential S106 contributions. However,

a review of recent S106 agreements in Sutton on similar schemes have included such Heads of Terms as

highways contributions, education provision contributions, travel plans amongst other section 106

obligations which will be considered in the context of the housing and scheme benefits set against viability

also, in detailed discussions with LBS Planning Officers at the time of pre-application consultation.





7. Summary and Conclusions

This Planning Report has been prepared on behalf of Sutton Council to provide a planning assessment in

respect of the redevelopment potential of Elm Grove Estate in the London Borough of Sutton (‘LBS’). This

planning report supports the broader strategic case for regeneration being prepared for Sutton Council

which will set out the preferred course of action for the development of the estate in close and active

consultation with residents and other key stakeholders.

The report has been framed by three intervention options that have been developed by Levitt Bernstein

following extensive consultation with existing residents through a series of workshops and site visits. These

options have been assessed in the context of national, regional and local planning policy, particularly the

site specific allocation (STC45) in the Council’s adopted 2018 Local Plan and with due regard also given to

the STC Masterplan (2016). The options consider different levels of intervention from refurbishment to

partial redevelopment and full redevelopment which in accordance with adopted London Plan Policy H8

have been given full and thorough consideration in developing a case for regeneration of the existing estate.

This review included consideration towards: scope for increasing the number of homes across the Site;

access and site constraint issues; affordable housing delivery and viability; contribution to the future

housing land supply and other important considerations and benefits. The main objective, of course, to

significantly enhance the living accommodation of existing residents on the estate and enable the delivery

of wider regeneration benefits to the surrounding area and local community.

The options must be considered against a backdrop of adopted planning policy in which it is clear there is

support for boosting the supply of both good quality affordable and market housing to meet current and

future housing needs of different groups in the community. It is considered that the full redevelopment

option would significantly improve the quality of stock for all residents and for a longer period of time, whilst

also boosting the overall volume of units which is considered preferential.

The refurbishment option, whilst being the least capital intensive albeit still with significant upfront costs,

would not achieve an uplift in the number of residential dwellings on site. Following a technical review by

Levitt Bernstein, the refurbishment option would also not be able to resolve all of the issues identified by

the Council and residents as necessary to bring the units up to current standards. For example and as

detailed in Sections 4 and 5 of this report, undersized units, poor sunlight and daylight conditions as result

of small windows and a lack of sufficient private amenity would remain under this option. It is not therefore

considered to represent optimisation of the Site or its future potential.

The partial redevelopment options are separated into three sub-options, Option 1 (Infill Blocks); Option 2

(Houses only); and Option 3 (Flats & Maisonettes). Sub-option 3 represents the more feasible option in

viability and deliverability terms. It has the potential to provide up to 32 additional residential units and

achieves beyond policy compliance in terms of additional affordable housing provision of a potential range

of affordable tenure. However, this is only to the benefit of a small proportion of existing residents as well

as new residents on the Council’s Housing Register. It does not address the issues for the majority of the

existing residents or create a substantial uplift in new homes (both affordable and private sale). This option

also lacks the wider place-making benefits that could be achieved as part of a comprehensive approach.





The full redevelopment option represents optimisation of the existing estate in accordance with national,

regional and local planning policy. When compared to the partial redevelopment options it has the potential

to deliver a total of 225 residential units (i.e. an uplift of 152 units when compared to the existing estate) on

the Site which translates to 177 more units than could come forward under partial redevelopment option 3.

Subject to viability considerations, the proposals could also achieve a significant proportion of affordable

housing as part of a higher density, mixed tenure redevelopment when compared to the partial

redevelopment options in more positively achieving London Plan and local plan policy aspirations whilst

also satisfying the Residents Priorities (as set out in the draft Community Charter). The full regeneration

proposals provide for a net gain in new homes in line with the general aspirations of site specific allocation

STC45 and STC Masterplan and through a carefully designed scheme positively respond to the indicative

height parameters and wider place-making principles set out within the adopted 2018 Local Plan.

Detailed design proposals will evolve as part of the involved pre-application consultation with Planning

Officers at LBS, and other statutory consultees and key stakeholders in support of a future planning

application.

In conclusion, it is considered that the full redevelopment option presents the best opportunity for creating

design innovation which integrates well with the surrounding townscape and provides for effective place-

making to include new areas of outdoor amenity space, play space, public realm and landscaping. The

comprehensive redesign with these principles in mind, is capable of significantly enhancing the Site’s

integration and connectivity with the wider built form, alongside providing significant improvements to

energy performance of new dwellings and achieving other necessary sustainability credentials. It is clear

that the full redevelopment will deliver the most significant regeneration benefits.

This comprehensive approach would also allow for optimising economic and social value contributions to

the local community as a whole, including increased local spending and funding raised through S106, CIL

and the New Homes Bonus.

Aside from the technical work undertaken, the Council have also embarked on an extensive programme of

public consultation to understand the aspirations of the existing residents of the estate. Whilst the Council

believe feedback from the consultation process favoured the full redevelopment option, all options have

been ranked equally to avoid any misinterpretation.

In the context of national, regional and local policy it is considered that the full redevelopment option would

deliver the most significant planning and other benefits when considered against the other options and

should be taken forward for further consideration and design development.





Appendix 1: Extract from LBS’s adopted Local Plan – STC45 Allocation



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Case for Regeneration: Planning Report

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