case for regeneration: planning report
TRANSCRIPT
savills.co.uk
Case for Regeneration: Planning Report
Elm Grove Estate, Sutton
Appendix C4 Sutton Council
March 2021
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Case for Regeneration: Planning Report
Elm Grove Estate, Sutton
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
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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.
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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.
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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.
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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.
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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.
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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.
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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
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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.
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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
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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).
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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
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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.
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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
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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.”
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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.
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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).
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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
Number of Homes Demolished: 16
Total New Homes Provided: 17
Total Uplift: 1
Partial Redevelopment Option 3 – Flats & Maisonettes
Number of Homes Demolished: 16
New Homes Provided: 48
Total Uplift: 32
Full Redevelopment
Number of Homes Demolished: 73
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.
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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.
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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
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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
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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%
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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.
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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
Layout, Height and Massing
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
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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.
Housing Mix and Tenure Strategy
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.
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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
Unit Type No. of Units % of Units
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%
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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.
Car Parking, Access and Movement
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.
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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
Layout, Height and Massing
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.
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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.
Housing Mix and Tenure Strategy
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.
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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.
Unit Type No. of Units % of Units
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 -
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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.
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Car Parking, Access and Movement
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
Layout, Height and Massing
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.
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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
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redevelopment of the Site provides an opportunity for density optimisation.
Housing Mix and Tenure Strategy
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
Unit Type No. of Units % of Units
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 -
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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
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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
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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.
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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.
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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.
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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.
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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.
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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.
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Appendix 1: Extract from LBS’s adopted Local Plan – STC45 Allocation
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savills.co.uk
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