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2 Living in Bromley

Context

2.1.1 The National Planning Policy Framework (NPPF) specifies that the purpose of the planning system is to contribute to the achievement of sustainable development. The planning system plays an important social role by supporting strong, vibrant and healthy communities by providing the supply of housing required to meet the needs of present and future generations; and by creating a high quality built environment, with accessible local services that reflect the community’s needs and support its health, social and cultural well-being. Additional economic and environmental roles are mutually dependent on the latter.

2.1.2 Nationally, there is a presumption in favour of sustainable development and local planning authorities should seek opportunities to meet development needs of their area and meet objectively assessed needs (including identifying key sites critical to the delivery of the housing strategy over the plan period) with sufficient flexibility to adapt to rapid change. Alongside this is the need to take account of the different roles and character of different areas, promote the vitality of urban areas, protecting the Green Belt and encourage the effective use of land by reusing land that has been previously developed.

2.1.3 The London Plan (2016) has a specific important role in the supply of housing. It includes a minimum borough annual average housing target at Table 3.1 (London Plan Policy 3.3). The annual monitoring target for Bromley Borough is 641 dwellings per annum. The Mayor for London has indicated that the current London Plan will be reviewed and replaced by 2019 and the housing target also reviewed. Bromley Council’s Local Development Scheme shows that the Bromley Town Centre Area Action Plan (2010) is to be reviewed following the adoption of the Local Plan. There are therefore two Plan reviews that are due to take place in the shorter term which could impact upon the Housing Supply in the Borough. For the purposes of the plan , the base date for residential development policy is the same as The London Plan (2016), that is April 2015 (2015/2016).

2.1 Housing

Policy 1 Housing Supply The Council will make provision for a minimum average of 641 additional homes per annum over the ten year plan period and where possible over the fifteen year plan period which will be achieved by: The development of allocated sites and sites with planning permission; Town centre renewal involving the provision of housing; The development of housing within Renewal Areas; The development or redevelopment of windfall sites; The conversion of suitable properties; Mixed use developments including housing in suitable locations; The provision of suitable non self-contained units; Vacant properties being brought back into use; Resisting the loss of existing housing except where accommodation is unsuitable and incapable of being adapted for continued residential use or where the proposal meets an identified need for community facilities; and The development of housing in Broad Locations (additional large sites within Bromley Town Centre, Orpington Town Centre and other areas where there is existing large scale retail and sites due to public sector restructuring and other land disposal). The following sites are allocated to include residential development as outlined in Appendix 10.2 of the Plan: Bromley Civic Centre Land adjacent to Bromley North Station The Hill Car Park and adjacent lands Gas holder site, Homesdale Road Land adjacent to Bickley Station Bromley Valley Gym and adjacent land, Chipperfield Road and adjoining land Orchard Lodge, William Booth Road Bassetts Campus, Broadwater Gardens Former Depot, Bruce Grove, Orpington West of Bromley High Street and land at Bromley South 18-44 Homefield Rise, Orpington Small Halls, York Rise, Crofton Road Banbury House, Bushell Way, Chislehurst Allocated sites will be subject to all relevant policies within the Local Plan and in addition subject to site specific requirements where necessary.

Supporting Text and Housing Implementation Strategy

2.1.1 Section 6 of the National Planning Policy Framework sets out national policy on the delivery of homes. Paragraph 47 sets out what local planning authorities should do to boost significantly the supply of housing. This includes housing needs assessments and identifying a supply of housing sites.

2.1.2 To assist in maintaining a five year supply of land for housing the Framework requires local planning authorities to look further into the future and to identify a supply of specific developable sites or broad locations for growth, for years 6-10 and where possible for years 11-15. London Plan Policy 3.3 provides a regional context for increasing housing supply and sets out London-wide and borough minimum targets for housing provision from 2015/16 – 2024/25. These are informed by the findings of the GLA’s 2013 London Strategic Housing Land Availability Assessment (SHLAA) and the 2013 Strategic Housing Market Assessment (SHMA) and other analysis. Paragraph 3.14A of the London Plan states that, consistent with the NPPF the approach takes account of London’s locally distinct circumstances of pressing housing need and limited land availability and aims to deliver sustainable development.

2.1.3 Paragraph 3.17 of the London Plan states that on the supply side, the London SHLAA is designed to address the NPPF requirement to identify supply to meet future housing need as well as being ‘consistent with the policies set out in this Framework’ (para 47 NPPF) not least its central dictum that resultant development must be sustainable. The SHLAA methodology is designed to do this authoritatively in the distinct circumstances of London, including the limited stock of land here and the uniquely pressurised land market and dependence on recycling brownfield land currently in existing uses. The methodology has been developed and refined over time through partnership working with boroughs and others involved in London housing as well as to reflect the principles of government guidance on preparation of SHLAAs nationally.

2.1.4 The Borough has a housing provision figure of 641 units per annum (6413 for the 10 years 2015/16 - 2014/25) as set out in Table 3.1 of the London Plan to assist in meeting requirements across London. The 2013 SHLAA specifies provision of approximately 289 units per annum on large sites (>0.25 ha) and 352 units on small sites (<0.25 ha). The figure for housing provision will be rolled forward over a 15 year period in line with advice set out in the London Plan and the GLA’s Housing Supplementary Planning Guidance. Policy 3.3 of the London Plan specifies that boroughs should enable development capacity to be brought forward to meet targets whilst having regard to other policies in the Plan
(i.e. development on brownfield land, intensification, town centre renewal, opportunity areas, mixed use, renewal of existing residential areas).

2.1.5 The trajectory in Appendix 10.1 of the Local Plan sets out the anticipated sources of housing supply over the Plan period. (This trajectory is also available as a separate Supporting Document online or on request). Specific sites that will help contribute to housing supply within the Borough over the next 15 years include those in the Bromley Town Centre Area Action Plan (2010) and the Bromley Town Centre Opportunity Area, the five year supply of deliverable land for housing which is regularly updated and site allocations. Other housing units will also be provided on large and small windfall sites. The housing trajectory in Appendix 10.1 shows a total of 10,645 deliverable and developable dwellings over the Plan period, an annual average of over 700 dwellings.

2.1.6 The trajectory in Appendix 10.1 (and Table 1) shows that the Council has identified a 10,645 housing supply over the 15 year plan period, compared with a minimum housing supply based on 641 dwellings per annum, of 9,615. This trajectory is therefore consistent with the London Plan Policy 3.3, including its clauses Da and E. It does so first by seeking to supplement the London Plan minimum housing target of 641 per annum with extra housing capacity to close the gap between identified housing need and supply, a total of 1,030 dwellings over the plan period. It also does so by drawing upon the brownfield housing capacity of the sources set out in Policy 3.3 (E), such as an Opportunity Area and town centres.

2.1.7 Paragraph 48 of the NPPF states that local planning authorities may make an allowance for windfall sites in the five year supply if they have compelling evidence that such sites have consistently become available in the local area and will continue to provide a reliable source of supply. Any allowance should be realistic having regard to the Strategic Housing Land Availability Assessment, historic windfall delivery rates and expected future trends, and should not include residential gardens. The Planning Practice Guidance (PPG) specifies in paragraph 3-24 that local planning authorities have the ability to identify broad locations in years 6-15 which could include a windfall allowance based on a geographical area (using the same criteria as set out in paragraph 48 of the NPPF).

2.1.8 The London-wide SHLAA 2013 made an assessment of the contribution that small sites (<0.25ha) have made to housing delivery within each London borough between 2004/05 and 2011/12. The figure was derived by taking an average of small site completions (new build, conversions and changes of use) 2004/05 – 2011/12 and removing 90% of new build completions built on garden land. The annual average figure for the Borough during this time period was 352 units. Over the ten year London Plan period (2015/16 – 24/25) the small site windfall figure could contribute 3520 units.

2.1.9 The London Plan (para 3.19A) observes that in compiling five year supply estimates boroughs should demonstrate that they have maximised the number of identified sites. However, given London’s reliance on recycled land currently in other uses and the London SHLAA’s evidence, it must be recognised that in addressing this national objective, capacity which elsewhere in the country would be termed “windfall” must here form part of the five year supply.

2.1.10 Paragraph 1.1.28 of the GLA’s Housing SPG (2016) states that the SHLAA provides the compelling evidence necessary to justify a windfall allowance for small sites based on historic trends, in line with paragraph 48 of the NPPF and reflecting distinct circumstances in London. It also states that trends show housing has been consistently delivered on small sites in the past and that this can be expected to provide a reliable source of future supply.

2.1.11 Paragraph 1.1.29 states that average annual trends (2004/05 – 2011/12) provide a consistent and appropriately long-term basis on which to estimate future supply, not least because they cover a full market cycle and take account of the impact of the recession. Trends also reflect particular local circumstances, for example, environmental/heritage designations and urban form. These specific points, together with the overall robustness of the SHLAA’s capacity estimates for small sites, were tested through an Examination in Public and were accepted in the Planning Inspector’s Report on the 2015 London Plan. However, boroughs are encouraged to re-examine the potential capacity from small sites and explore policy approaches which may lead to the delivery of more homes on small sites where consistent with the Plan.

2.1.12 Delivery of housing on small sites is significant in the Borough as demonstrated in the 2013 SHLAA. The inclusion of an allowance for small site completions over the Plan period takes into account advice set out in the NPPF, the PPG and the London Plan.

2.1.13 The housing trajectory illustrates the expected rate of housing delivery for a 15 year period. This will be monitored in a manner that is consistent with London Plan Policy 3.3 and supplemented by Bromley's Authority Monitoring Report, so as to maintain a five year supply of housing land to meet the housing targets. This may include providing sites brought forward from later in the plan period. The review of the Bromley Town Centre Area Action Plan (2010) is due to commence after Local Plan adoption, and the London Plan targets are due to be revised as part of a new London Plan by 2019.

2.1.14 The Council's Housing Implementation Strategy will ensure that the delivery of housing is regularly monitored. It will include the identification of new sites, liaison with developers with regard to their intentions, progress on sites, identifying risks of delay and non-delivery and sites which can be brought forward. It will also include and respond to the review of the London Plan and Bromley Town Centre Area Action Plan.

Table 1 - Summary of housing supply October 2016

2.1.15 (*completions for 15/16 have been included in the above table subject to verification with the GLA)

2.1.16 A SHMA for the South-East London sub region was finalised in June 2014 and estimates an annual housing requirement across the sub region of 7188 units and a net annual need for 5000 affordable units. The net additional dwelling requirement for Bromley per annum was estimated at approximately 1320 units. Across the sub-region annual capacity targets identified within the 2013 SHLAA reach 7893 units. GLA household projections in 2014 estimate an annual short term variant of 1840 households per annum for the Borough and a long term variant of 1530 households per annum.

2.1.17 The 2014 SHMA highlights that the highest level of need across tenures within the Borough up to 2031 is for one bedroom units (53%) followed by 2 bedroom (21%) and 3 bedroom (20%) units. Larger development proposals (i.e. of 5+ units) should provide for a mix of units sizes and considered on a case by case basis.

2.1.18 Paragraph 3.19 of the London Plan states that boroughs should use their housing supply targets as a minima augmented with additional housing capacity to reduce the gap between local and strategic housing need and supply. Examples of relevant locations that can help to achieve this include; town centres, opportunity and intensification areas and other large sites.

2.1.19 The allocations (including sites within Bromley Town Centre Area Action Plan) and broad locations referred to above are examples of such sites that will assist the Borough in meeting and exceeding its housing supply target over the Plan period. The key sites and broad locations identified above have the potential to deliver over 3800 units over the Plan period. The sites include; those identified following a call for sites in 2014, other known sites (for example Bromley Civic Centre and land adjacent to Bromley North Station) where an increase in density could be appropriate and sites identified in connection with the Bromley Town Centre Housing Zone (March 2016).

2.1.20 The broad locations include Bromley and Orpington Town Centres, mixed use development of single storey large format retail and other town centre sites, the reorganisation and disposal of land by the Council, and other public sector and partner agencies.

2.1.21 The housing supply policy aims to minimise the net loss of housing through changes of use or redevelopment. Proposals for changes of use or redevelopment will only be permitted in the circumstances outlined in the policy.

2.1.22 Risk Assessment for Housing Land Delivery

• The GLA and LBB will both monitor Bromley housing completions. The GLA takes the wider monitoring role across London as a whole. Completions against target may vary across London and local under or over achievements (if any) may be balanced by other achievements elsewhere in London.
• LBB will seek to bring forward other policy compliant large sites if the small sites rate is too low, for example in the Opportunity Area and other Town Centres and suitable Broad Locations in cooperation with landowners and developers. In practice, large site windfalls in policy compliant locations do come forward and reduce the risk of overall under-achievement.
• The post NPPF Five Year Housing Supply statements apply the NPPF criteria to 'deliverability' and this more recent housing land supply data should by definition minimise the risk of non-achievement.
• The early review of the London Plan, with its linked evidence base, should provide an early update of the housing land delivery in the Borough.

2.1.23 In any event, the PPG (3-027) advises that for years 11-15, Local Plans can pass the test of soundness even where the local planning authority have not been able to identify sites or broad locations for growth in years 11-15.

Policy 2 Provision of Affordable Housing In order to meet the needs of the Borough, the Council will: seek affordable housing on all housing developments capable of providing 11 residential units or more or where the residential floorspace is more than 1000sqm, irrespective of the number of dwellings. On all sites at, or above, this threshold negotiations will take place to determine the number of affordable dwellings to be provided. In negotiating the amount of affordable housing on each site, the Council will seek 35% provision with 60% social-rented/affordable rented housing and 40% intermediate provision, unless it can be demonstrated that a lower level should be sought or that the 60:40 split would not create mixed and balanced communities. The affordability of different elements of the scheme should not immediately be apparent from the siting, design and layout. The affordable housing should be made available for transfer or occupation before a certain proportion (to be determined through negotiations between the Council and developer) of the market housing is occupied. Where an applicant proposes a level below the 35%, or the tenure mix is not policy compliant, the Council will require evidence within a Financial Viability Appraisal that will be independently assessed. seek to maximise the use of housing grants and other funding to increase the level of affordable housing above the figure secured in a). support the delivery of affordable housing through other sources of supply, such as estate regeneration, bringing vacant units back into use and other forms of housing which demonstrate they can help meet need. Payments in lieu Where it has been determined that a site meets the size threshold and is suitable for affordable housing, payment in-lieu of affordable housing on site or provision in another location will be acceptable only in exceptional circumstances and where it can be demonstrated that: it would be impractical to transfer the affordable housing to a registered provider (RP); or on-site provision of affordable units would reduce the viability of the development to such a degree that it would not proceed; or on-site provision of affordable units would not create mixed and balanced communities and there would be benefit in providing such units at another location. The Council's Planning Obligations Supplementary Planning Document will provide detail to assist in the interpretation and implementation of this policy

Supporting Text

2.1.24 The National Planning Policy Framework (NPPF) specifies that to deliver a wide choice of high quality homes, widen opportunities for home ownership and create sustainable, inclusive and mixed communities, local planning authorities should identify the size, type, tenure and range of housing that is required in particular locations, reflecting local demand. Where affordable housing is needed policies should be for meeting this need on site, unless off-site provision or a financial contribution of broadly equivalent value can be robustly justified (i.e. to improve or make more effective use of the existing housing stock) and the agreed approach contributes towards mixed and balanced communities.

2.1.25 Planning Practice Guidance (PPG) states that where local planning authorities are requiring affordable housing obligations they should be flexible in their requirements, planning obligations will take into account specific site circumstances. Paragraph 7 sets out that on individual schemes applicants should submit evidence on scheme viability where obligations are under consideration. Wherever possible applicants should provide viability evidence through an open book approach to improve the review of evidence submitted and for transparency.

2.1.26 There are specific circumstances where contributions for affordable housing should not be sought from small scale and self-build development. Paragraph 31 of the PPG states that these circumstances are:

• Contributions should not be sought from developments of 10 units or less and which have a maximum combined gross floorspace of no more than 1000 square metres;
• Affordable housing and tariff-style contributions should not be sought from any development consisting only of the construction of a residential annex or extension to an existing home.

2.1.27 The London Plan defines affordable housing as including social-rented, affordable rented and intermediate housing. Local plans should take account of; current and future housing requirements, targets and the priority for affordable housing across London, promoting mixed and balanced communities, the capacity available to accommodate development and the viability of future developments. There is the need to encourage rather than restrain residential development, determine the size and type of units needed in particular locations and take into account the specific circumstances of sites.

2.1.28 In relation to individual sites the London Plan highlights that the following should be considered;

• the viability of the development,
• availability of public subsidy,
• implications of phased development and making provisions, if necessary, to reappraise viability prior to implementation,
• integration of affordable units within developments as a whole and
• application of Mayor’s space standards to schemes where large units prevent the affordable housing policy being triggered.
  

2.1.29 The South-East London sub region commissioned a Strategic Housing Market Assessment (SHMA) that was carried out in 2014. The study demonstrates a high level of need across the sub-region and highlights a number of key challenges and issues, including a total housing requirement of 7188 units per annum across the sub region and an estimate of net annual affordable housing need of 5,000 units per annum in South East London. In Bromley there is a net annual need for affordable housing of about 1400 units per annum.

2.1.30 With regard to unit size targets for affordable dwellings the SHMA set out a baseline scenario and a scenario which addressed under-occupation and overcrowding. Sites that trigger the affordable housing policy should provide a mix of unit sizes in light of the information set out in the SHMA which shows a need for 1-3 bedroom units (with 1 and 2 bedroom units having a higher need). Currently, the highest level of need is for two bedroom units as reflected on the Council’s Housing Register. Future updates in this respect will be set out in Committee reports or updates to the Council’s Affordable Housing Supplementary Planning Document (SPD). Individual sites will be considered on a case by case basis in consultation with the Council’s Housing Division.

2.1.31 Following the Affordable Housing Viability Assessment Update (2016), a target of 35% affordable housing was set for sites which met the affordable housing threshold. The target relates to the percentage of habitable rooms on site although the Council will consider the overall contribution in terms of floor space and unit numbers to ensure that a proportionate percentage of overall development is affordable housing. The tenure mix of 60% affordable rented/social rented and 40% intermediate housing is in accordance with London Plan Policy 3.11 and the Mayor’s Housing SPG. Where public subsidy towards affordable housing is used, this should result in an increase in the provision of affordable housing on site reflecting the Mayor's Affordable Housing and Viability SPG.

2.1.32 Paragraphs 21-22 of the PPG set out the process for determining the vacant building credit where there is an overall increase in floorspace on site. It applies in instances where vacant buildings are being brought back into use or demolished as part of the scheme. It advises that a credit should be applied equivalent to the gross floorspace of the building on site and deducted from the overall affordable housing calculation. It applies where affordable units are being provided on site or where a financial contribution is being provided. The PPG cites an example; where a building with a gross floorspace of 8,000 square metres is demolished as part of development proposing 10,000 square metres any affordable contribution should be a fifth of what would normally be sought.

2.1.33 Reference is made to starter homes in the PPG. We are currently awaiting further government guidance on the results of the technical consultation regarding the details of the application of the starter homes policy.

2.1.34 The Council believes that some of its priority needs can only be met by social-rented/affordable rented housing. Shared ownership, low-cost market, and sub-market rented housing have a role principally in relation to intermediate housing. Such options may also assist some households unable to access market housing but which the Council has a duty to assist through its strategic enabling role.

2.1.35 Affordable housing comprises both social-rented/affordable rented housing and intermediate housing:

• Social-rented housing is defined as housing provided by a landlord where access is on the basis of housing need, and rents are no higher than target rents set by the Government for housing association and local authority rents.
• Affordable rented housing is rented housing let by registered providers of social housing to households who are eligible for social rented housing. Affordable rent is not subject to the national rent regime but is subject to other rent controls that require a rent of no more than 80 per cent of the local market rent where this does not exceed Local Housing Allowance levels unless by exception.
• Intermediate housing is sub-market housing available to people on moderate incomes who cannot afford to buy or rent housing generally available on the open market. Intermediate housing may take the form of shared ownership, low cost home ownership or sub market rented housing. These sources of intermediate housing can play an important role in providing mixed communities, ensure that those on moderate incomes in Bromley (including key workers) have access to decent homes and can be controlled to ensure that it is available in the long term. The London Plan defines affordability for intermediate housing as those households earning £18,100 - £66,000 (two+ bedroom units extends this to £80,000).
  

2.1.36 The latest Council intermediate housing income threshold (June 2015) review agreed upper limit thresholds as follows:

• 1 bedroom units £38,800
• 2 bedroom units £50,500
• 3 bedroom units £62,500
• GLA upper limit applies to 4 bedroom units+
  

2.1.37 Intermediate housing income thresholds will be updated every three years.

2.1.38 These thresholds apply in accordance with Policy 3.10 Definition of Affordable Housing paragraph 3.62 of the London Plan.

2.1.39 The affordable housing policy will usually be applied to the number of habitable rooms. The Council will advise applicants of the mix of units on individual sites that will be required to meet local needs.

2.1.40 In negotiating the level of affordable housing the Council will seek the provision of 35% of habitable rooms on a site unless material considerations indicate otherwise. In these negotiations the principal considerations will be:

• Proximity to local services and facilities and access to public transport.
• Whether there will be particular costs associated with the development of the site: this will usually be reflected in the residual land value and should not affect a site’s suitability. The onus will be on applicants to submit a financial viability appraisal to demonstrate that abnormal development costs, in addition to the affordable housing contribution, would impact unduly on scheme viability.
• Whether the provision of affordable housing would prejudice the realisation of other planning objectives.
• The need to achieve a successful housing development, both in terms of unit size/tenure mix and management.

2.1.41 The Government aims to promote mixed and balanced communities so off-site provision or payments in lieu will rarely be acceptable. On sites capable of providing 11 residential units or more or where the residential floorspace is more than 1000sqm. off-site provision or a payment in lieu may be acceptable in exceptional circumstances if applicants are able to demonstrate (and the evidence submitted is verified by the Council or independent consultants) that on-site provision would be practically difficult. If off-site provision is offered, the onus will initially be on the developer to find and provide an alternative site. Where the other site falls below the 11 unit/1000sqm floorspace threshold, the 35% requirement will be applied to the total capacity of both sites. The Council will monitor the most effective use of 'payments in lieu' so as to meet housing needs. This may include the provision of accommodation outside Use Class C3 to meet the housing needs of homeless people.

2.1.42 The means of controlling future occupancy of affordable housing will be the subject of negotiations between the relevant parties. The preferred approach for controlling the occupancy of social/affordable rented housing is for the ownership of this housing to be transferred to a Registered Provider (RP) nominated or agreed by the Council. In the case of intermediate housing, arrangements will depend on the type and tenure of housing proposed. In all cases, the arrangements for securing occupancy will be confirmed either through a legal agreement or condition attached to the planning permission, whichever is more appropriate in the circumstances.

2.1.43 If the above restrictions are lifted any subsidy should be recycled for alternative affordable housing provision.

2.1.44 Government and the Mayor are introducing new initiatives to address housing need and the Council will take into account these and new housing products which can demonstrate they can address housing need. The Council's Housing Strategy will set out the Council's corporate approach to address housing need, and the wide range of initiatives which contribute to this objective. The Council will consider positively new forms of provision such as Build to Rent and discounted market rent where the rent levels can be shown to be affordable to local residents and help increase choice and address need. Further advice on the detailed implementation of the policy may be provided in a Supplementary Planning Document.

2.1.45 All other relevant policies and the Mayor’s Housing SPG will apply to affordable housing developments, including those relating to housing design and layout.

Policy 3 Backland and Garden Land Development New residential development will only be considered acceptable on backland or garden land if all of the following criteria are met: There is no unacceptable impact upon the character, appearance and context of an area in relation to the scale, design and density of the proposed development; There is no unacceptable loss of landscaping, natural habitats, or play space or amenity space; There is no unacceptable impact on the residential amenity of future or existing occupiers through loss of privacy, sunlight, daylight and disturbance from additional traffic; A high standard of separation and landscaping is provided.

Supporting Text

2.1.46 In the past the role of small sites in providing additional housing within the Borough has been significant. It is important to also consider the value of backland and garden land in helping to define local character. There is a risk that inappropriate development of these small sites over time could adversely impact upon local character, especially as the availability of sites diminishes.

2.1.47 The definition of previously developed land in the National Planning Policy Framework (NPPF) excludes land in built up areas such as private residential gardens. The Framework also specifies that windfall sites are normally previously developed sites.Core planning principles include; seeking high quality design and a good standard of amenity for all existing and future occupants of land and buildings, taking account of the different roles and character of different areas and encouraging the effective use of land by reusing land that has been previously developed. It also advises local planning authorities to consider the case for setting out policies to resist inappropriate development of residential gardens, for example, where development would cause harm to the local area (paragraph 53).

2.1.48 The supporting paragraphs to London Plan Policy 3.5 recognise the important role that gardens play. They acknowledge that pressure for new housing development means that gardens can be threatened by inappropriate development and their loss can cause significant local concern. Paragraph 3.34 also specifies that back gardens are a cherished part of the London townscape contributing to communities’ sense of place and quality of life. The London Plan supports the presumption against development on back gardens where locally justified by a sound local evidence base. The GLA Housing SPG specifies that boroughs are advised to consider proposals in light of local circumstances, taking into account the value gardens have in addressing a range of strategic policy objectives. It advises that there is a need to strike an appropriate balance between strategic policy objectives and other London Plan policies, in particular the objective to provide a wide choice of homes Londoners can afford.

2.1.49 Many residential areas within the Borough are characterised by spacious rear gardens and well separated buildings. Proposals which undermine the character or appearance (also including form and layout of existing areas) of the Borough or which would be likely to result in detriment to existing or future residential amenities will be resisted. A higher level of protection for Conservation Areas and Areas of Special Residential Character (ASRCs) is set out in Policy 41 Conservation Areas, Policy 42 Development Adjacent to a Conservation Area and Policy 44 Areas of Special Residential Character.

2.1.50 The following aspects will also be taken into account when assessing proposals; the contribution the site makes to enhancing the character and appearance of the area (including the contribution made by trees and other vegetation on the site), their role as amenity or play space, their contribution to mitigating climate change and reducing flood risk and their ecological value in terms of providing habitats for wildlife.

2.1.51 "Tandem" development, consisting of one house immediately behind another and sharing the same access, is generally unsatisfactory because of the difficulties of accessing the house at the back and the lack of privacy suffered by the house in front.

2.1.52 See also Policy 115 Reducing Flood Risk and Policy 116 Sustainable Urban Drainage Systems and Bromley’s Valued Environments chapter.

Policy 4 Housing Design All new housing developments will need to achieve a high standard of design and layout whilst enhancing the quality of local places. Housing schemes will also need to respect local character, spatial standards, physical context and density. The Council will expect all of the following requirements to be demonstrated: The site layout, buildings and space around buildings are designed to a high quality, recognising as well as complimenting the qualities of the surrounding areas; Minimum space standards for dwellings as set out in Policy 3.5 and Table 3.3 of the London Plan and the London Plan Housing Supplementary Planning Guidance (as updated); The provision of sufficient external, private amenity space that is accessible and practical; The provision of appropriate play space in accordance with the Mayor’s Play and Informal Recreation SPG; Off-street parking that is well integrated within the overall design of the development; Density that has regard to the London Plan density matrix whilst respecting local character, including heritage; Layout that is designed to give priority to pedestrians and cyclists over the movement and parking of vehicles; Safety and security measures are included in the design and layout of buildings and public areas; Ninety percent of new housing meets Building Regulation requirement M4 (2) ‘accessible and adaptable dwellings; and Ten percent of new housing meets Building Regulation requirement M4 (3) ‘wheelchair user dwellings’ i.e. is designed to be wheelchair accessible, or easily adaptable for residents who are wheelchair users.

Supporting Text

2.1.53 New housing development should make a positive contribution to the area in which it is located. Policies 3.5 and 7.4 of the London Plan emphasise the importance of new developments taking account of physical context, local character and a design approach that has an understanding of place. The Council will ensure that new development meets the nationally described space standards (2015) which have been adopted by the London Plan (Policy 3.5 as updated).

2.1.54 Within the Borough there are many diverse and attractive housing areas. In the context of Government policy it is the Council's view that their individual characteristics and quality should be adequately protected. Scope for further housing development often occurs on "infill" sites, the redevelopment of older, low-density property and through the redevelopment of large non-residential sites. The Council’s primary objective is to ensure a high standard of residential environment. Redevelopment should be of a design that is sympathetic to and complements the surrounding residential area but not necessarily a reproduction of the established form and pattern of development. In line with the advice in the National Planning Policy Framework (NPPF) (paras. 57) it is important to plan positively for the achievement of high quality and inclusive design for all development. The Council will reject poor designs that do not accord with this advice. The onus will be on applicants to demonstrate how they have taken account of the need for good layout and design.

2.1.55 The design of housing developments should be of a high quality internally, externally and should relate to their context and the wider environment. The Mayor’s Housing Supplementary Planning Guidance (SPG) sets out the minimum level of quality and design that new homes should meet. The extent to which proposed developments depart from these should be taken into account in planning decisions. Consideration should be given to the standards alongside the achievement of other objectives in the London Plan. The standards apply to new build, conversions and changes of use but not to specialist housing, however the Council will still expect a satisfactory standard of accommodation to be provided in applications relating to specialist housing (student, sheltered and HMO accommodation) see also Policy 9 Conversions and Policy 11 Specialist and Older peoples Accommodation. The Council encourages applicants to include information within design and access statements on how the above standards have been complied with.

2.1.56 Good urban design including space around and between buildings and their landscaping contributes to the quality of the built environment. In major development proposals a design statement should be submitted to the Council to include information of the key design principles, density, mix and distribution of uses as well as provide sufficient illustrations to demonstrate the relationship of the development to its wider surroundings.

2.1.57 The design of all new housing developments should include appropriate measures to maximise security and prevent crime. In determining planning applications the Council will refer to ‘Secured By Design’ principles, Government guidance on ‘Safer Places’ and any other supplementary planning guidance. “Secured by Design” is a UK Police Flagship initiative supporting the principles of designing out crime through the use of effective crime prevention and security standards set out in various guides and publications. Detailed information is available at www.securedbydesign.com.

2.1.58 The Council is required to incorporate minimum space standards (based on Gross Internal Floor Areas) in line with those set out in Table 3.3 of the London Plan and the Mayor's Housing SPG (as updated). By meeting space standards it is possible for all new homes to be fit for purpose, with the potential to be occupied over time by households of all tenures. The standards are minimum and should be exceeded where possible (subject to para. 2.3.25 of the Mayor's Housing SPG that specifies exceptions to this).

2.1.59 Regard will be given to the London Plan Density Matrix whilst respecting local character. The Matrix is intended to be used as a guide and there may be convincing environmental or local character arguments for an alternative density. This may result in some developments coming forward at densities lower than that set out in the London Plan Density Matrix and some coming forward at higher densities. The London Plan encourages high density development in appropriate locations such as larger town centres and places that benefit or will benefit from major new public transport improvements. In addition, the London Plan Housing SPG at Para 1.3.1 states that proper account must be taken of the range of factors which have to be addressed to “optimise” rather than simply maximise housing potential. It states that of particular importance are ensuring good design and taking into account public transport capacity, local context and character.

2.1.60 The provision of practical, accessible and usable private amenity space within new housing developments is important. Minimum standards are set out for London but it is important to address the existing character of amenity space within an area and show how new developments can relate to it. Private amenity space should be accessible and have level access from the home. Houses and ground floor flats should have access to private gardens and dwellings on upper floors should have access to private amenity space.

2.1.61 Policy 3.8 Housing Choice of the London Plan specifies that Boroughs should ensure that ninety percent of new housing meets Building Regulation requirement M4 (2) ‘accessible and adaptable dwellings’ and ten percent of new housing meets Building Regulation requirement M4(3) ‘wheelchair user dwellings’ i.e. is designed to be wheelchair accessible [M4(3)(2b)] for dwellings where the end user is 'known', or easily adaptable [M4(3)(2a)] for wheelchair units which are for sale or part rent/part buy.

2.1.62 The Mayor's Housing SPG contains further information regarding these standards. “Adaptable wheelchair housing” standards are also set out in the “Wheelchair Housing Design Guide” (Thorpe and Habinteg Housing Association). “Wheelchair accessible housing” will be required to comply with the “South East London Housing Partnership Wheelchair Homes Design Guidelines”.

2.1.63 Of importance is the need to produce environments which support health and wellbeing, including through the provision of new housing. This link between health and the environments we inhabit is recognised in the Bromley Health and Wellbeing Board's Strategy 2012 - 2015 and the Bromley Joint Strategic Needs Assessment (JSNA)

Policy 5 Parking of Commercial Vehicles Where planning permission is required for the parking of a commercial vehicle within the curtilage of a residential property, the Council will only grant permission where: such parking would be unobtrusive,compatible with the residential surroundings and not cause harm to highway safety; and the noise and disturbance created by such parking will not harm the residential amenities of occupiers of adjacent properties.

Supporting Text

2.1.64 The provision of permanent or long-term parking for a commercial vehicle associated with a residential property will often require planning permission. Such parking can often result in loss of amenity for adjoining residents through disturbance by vehicle movements and the visual impact of parked vehicles. The applicant would be expected to show that there was a genuine need for the parking facility, for example that it serves commercial activities legitimately pursued on or based at the property. Any such permission would be likely to include conditions that ensure the impact of the parking was minimised.

Policy 6 Residential Extensions Where planning permission is required for the parking of a commercial vehicle within the curtilage of a residential property, the Council will only grant permission where: the scale, form and materials of construction should respect or complement those of the host dwelling and be compatible with development in the surrounding area; space or gaps between buildings should be respected or maintained where these contribute to the character of the area; dormer windows should be of a size and design appropriate to the roofscape and sited away from prominent roof pitches, unless dormers are a feature of the area.

Supporting Text

2.1.65 The Council will expect the design of residential extensions to respect or compliment the style and materials of the main building. Where possible, the extension should incorporate a pitched roof and include a sympathetic roof design and materials. In particular, flat-roofed side extensions of two or more storeys to dwellings of traditional roof design will normally be resisted unless the extension is well set back from the building line and is unobtrusive.

Policy 7 Accommodation for Family Members An extension to provide space for additional family members will be expected to meet the following criteria: the extension cannot be severed from the main dwelling-house, and is in-keeping with the design and scale of the existing dwelling-house, and access to the extension is provided and maintained through the original dwelling house.

Supporting Text

2.1.66 Residential extensions can provide additional accommodation which enables a household to accommodate disabled persons, or extended family members such as adult children returning from university or elderly relatives.

2.1.67 Problems can arise where this type of development constitutes a self-contained unit which could potentially be severed from the main dwelling. This can sometimes result in the creation of substandard accommodation with inadequate privacy, access provision, parking and amenity space which the policy aims to prevent.

Policy 8 Side Space When considering applications for new residential development, including extensions, the Council will normally require the following: for a proposal of two or more storeys in height, a minimum 1 metre space from the side boundary of the site should be retained for the full height and length of the building; or where higher standards of separation already exist within residential areas, proposals will be expected to provide a more generous side space.

Supporting Text

2.1.68 The Council considers that the retention of space around residential buildings at first floor and above is essential to ensure adequate separation and to safeguard the privacy and amenity of adjoining residents. It is important to prevent a cramped appearance and unrelated terracing from occurring. It is also necessary to protect the high spatial standards and levels of visual amenity which characterise many of the Borough’s residential areas.

Policy 9 Residential Conversions A proposal for the conversion of a single dwelling into two or more self-contained residential units or non-self-contained accommodation will be permitted provided that: the amenities of occupiers of neighbouring dwellings will not be harmed by loss of privacy, daylight or sunlight or by noise and disturbance and; the resulting accommodation will provide a high quality living environment for the intended occupiers and; on and off street parking resulting from the development will not cause unsafe or inconvenient highway conditions and; the character and appearance of the area is not adversely affected and; there will not be a detrimental impact on housing choice in the locality and where accommodation at ground floor level is proposed, preference is given for family housing units with direct access to a garden, and safe and secure access is provided to each dwelling.

Supporting Text

2.1.69 This policy seeks to ensure that the Borough's older properties are efficiently used, in order to maximise, within environmental constraints, the contribution conversions make to housing supply. Such accommodation increases the choice and supply in the housing market for smaller households and provides an alternative to purpose-built flats, especially for first-time buyers and for rent by private landlords.

2.1.70 Existing housing stock comprising of small and medium size family dwellings continues to play an important role in meeting housing need. Where houses are too large for single occupation; conversion may extend their life by encouraging improvement and repair. There is the added advantage of retaining the established residential character of an area which can often be lost through redevelopment.

2.1.71 The Council will normally expect conversion work to improve the quality of the existing housing and to respect the residential amenities of adjoining properties. Any accommodation resulting from a conversion must be of a high standard and comply with The London Plan (2016) as updated and GLA’s Housing Supplementary Planning Guidance (March 2016) and proposals should address areas such as minimum space standards, car parking and outdoor spaces.

2.1.72 Conversions can often have adverse external effects, including parking in front garden areas, and can result in increased on-street parking and traffic. On-street parking can be a particular problem in areas where local shopping facilities or commuter car parking already causes congestion. The Council will resist conversions where they may result in a traffic hazard and be detrimental to the amenities of the residential area by reason of noise, visual impact or other inconvenience.

2.1.73 Non-self-contained units should be retained and improved where appropriate. Applications for non-self-contained accommodation will be supported if they provide a high standard living environment as defined in this and other policies in the plan. Proposals for non-self-contained should also ensure that the relevant Environmental Health standards are met.

Policy 10 Conversion of Non-Residential Buildings to Residential The Council will permit the conversion of [genuinely redundant] non-residential buildings to residential use, subject to compliance with Policy 83 Non-Designated Employment Land, Policy 97 Change in Use of Upper Floors and Policy 99 Residential Accommodation achieving good quality living accommodation, residential amenity and compliance with relevant building regulations. Proposals should ensure that on street and/or off street parking resulting from the development will not cause unsafe or inconvenient highways conditions.

Supporting Text

2.1.74 The National Planning Policy Framework (NPPF) and the London Plan seek to realise town centre housing potential. Modernisation/redevelopment above shops or the conversion of surplus commercial space in the right location can help bring underused and vacant non-residential units into active residential use.

2.1.75 Where planning permission is required for such a conversion the applicant must be able to demonstrate that the premises are genuinely redundant. Proposals are not likely to be acceptable where there continues to be a demand for such uses – for example, where the loss of such premises would result in the loss of employment or prevent the creation of new business or employment opportunities.

2.1.76 The design of housing developments should be of a high quality internally, externally and should relate to their context and the wider environment.

2.1.77 The London Plan (2016), and the GLA’s Housing Supplementary Planning Guidance (March 2016) set out relevant polices and standards in relation to the quality and design of housing developments. The Council encourages applicants to include information within design and access statements on how housing standards within the London Plan (and guidance) and Local Plan have been complied with.

2.1.78 Proposals should not result in an unacceptable increase in the demand for on street car parking or result in unsafe or inconvenient highways conditions. Sufficient information should be submitted to the Council to demonstrate this. Reference should also be made to Local Plan Policy 30 Parking.

Specialist & Older Peoples Accommodation

2.1.79 Bromley has an ageing population; the largest in London with approximately 57,200 people aged 65+ years in Bromley in 2015 according to POPPI Projections (Projecting Older People Population Information System, including a significant cohort now in their mid to late 60’s.

2.1.80 The National Planning Policy Framework (NPPF) encourages planning authorities to “plan for a mix of housing based on current and future demographic trends” and to consider a range of specialist housing, including for older people, in local housing market assessments.

2.1.81 The London Plan advises that Local Plan preparation should take account of the changing age structure of London’s population and, in particular, the varied needs of older Londoners (Policy 3.8). The Mayoral Housing SPG (March 2016) advises that certain types of specialist housing may need to be encouraged by planning policies, specifically, sheltered accommodation, extra care accommodation, and residential and nursing care.

Policy 11 Specialist & Older Peoples Accommodation The Council supports the provision of specialist housing across all tenures, where they are conveniently located for a range of local shops, services and public transport, appropriate to the mobility of the residents, and they provide appropriate parking and suitably landscaped amenity space. Proposals involving the loss of sites currently providing specialist accommodation will be resisted unless: it can be demonstrated that there is no demand for the existing accommodation and no demand for sites from alternative providers, or there is equal or greater replacement provision of improved specialist accommodation in an alternative appropriate location. Where opportunities arise to maximise the use of sites currently providing specialist accommodation, proposals for extensions or redevelopments to providing additional accommodation will be looked on favourably, subject to appropriate scheme design.

Supporting Text

2.1.82 The Council wishes to encourage the provision of a high quality living environment for those living in Specialist accommodation, which includes supported housing to meet different accommodation needs of people with learning disabilities, mental health problems, as well as specialist housing for older people.

2.1.83 Models of accommodation designed for older people continue to evolve. Over the last decade there has been reduced reliance on residential care homes and a shift towards enabling people to retain their independence, remaining living in the community with appropriate support or in Extra Care Housing (ECH) which provides improved opportunities for people who are no longer able to live in their own home, even with support, including older physically frail people, and thereby reducing the demand for residential care. However, there remains a potential growth in demand for both nursing and residential care for “Elderly Mentally Infirm” (EMI) people.

2.1.84 Nationally, over 75% of all older households own their home outright, with only 13% of "all older person" households live in social rented homes. Conversely around 70% of the specialist housing stock is social rented with 30% in private tenures (private rented or owner-occupation). There is therefore an issue of tenure choice for older person households. The Mayor's Housing Supplementary Planning Guidance reflects the tenure imbalance across London, and encourages the provision of a range of housing options which reflect the diversity of tenure amongst older households.

2.1.85 Bromley has a significant number of elderly people living alone in their own homes. As detailed in the Older Persons Accommodation Evidence Base (2016), in 2015 over 13,500 people over 75 years lived alone and this is predicted to rise by 37% (over 5,000 people) to almost 19,000 by 2030. Living alone has implications for the physical and mental health of residents for example through risk of falls or social isolation. Good quality safe warm and affordable housing can help maintain the physical and mental health of older people, help them stay independent for longer and assist in preventing delayed discharges from hospital.

2.1.86 A study by Shelter (2012) indicates that 68% of older homeowners live in a home that has at least two spare bedrooms and that over a third of older people are interested in the idea of retirement housing, either now or in the future, suggesting a latent demand for private elderly specialist accommodation. (Shelter and the Joseph Rowntree Foundation, April 2012).

2.1.87 The Older Persons Accommodation Paper (2016 update) illustrates the scale of the challenge presented by an ageing population will need to be addressed over the plan period and the implications of elderly residents in unsuitable accommodation for support services and the National Health Service.

2.1.88 Whilst Bromley has the highest number of specialist elderly units (Older persons accommodation, excluding care beds) in London, it also has the largest number of elderly residents and a significant pre retirement age group.

2.1.89 The London Plan 2016 acknowledges that existing sites and premises providing an element of care are a finite resource and may be threatened by higher value uses, indicating that where shortfalls of specialist housing needs have been identified, the possibility of other providers of specialist or supported needs accommodation using these existing sites should be explored (para 3.83). Such exploration should be demonstrated by evidence of appropriate and robust marketing for specialist or supported needs accommodation, for a minimum of six months.

2.1.90 There is currently ambiguity in the Use Class classification for the range of specialist accommodation for the elderly. Care Homes fall within Use Class C2. Extra Care type housing developments are generally classed as residential dwellings (Use Class C3) and therefore subject to other residential policies, including affordable housing policies.

2.1.91 The Mayor's Housing SPG 2016 highlights the “front door” test as the most robust way of distinguishing between C2 and C3 uses. Whilst the SPG notes that, where justified by identified need, some extra care schemes, functionally are effectively C2 units it advises local authorities to consider needs and viability concerns, and highlights the risk of proposals incorrectly categorised (perhaps to avoid S106 contributions). The London Plan 2016 “supports boroughs in seeking application of the principles of its affordable housing policies to the range of developments – including those falling within Use Class C2”(para 3.51).

2.1.92 The London Plan (2016) Annex 5 indicates a specialist housing for older people “annualised strategic benchmark” for Bromley of 140 private sale units per annum and 65 intermediate sale units. There is a zero benchmark for affordable rented units.

2.1.93 Irrespective of Use Class, Bromley’s Affordable Housing SPD 2008 (para 6.27) indicates that proposals for sheltered housing and extra care homes are subject to the affordable housing policy. Local Plan Policy 2 Provision of Affordable Housing will ensure that intermediate models, which developers are still devising, come forward to meet the need, subject to viability. Given the zero benchmark for affordable rented units this provision will be sought as “intermediate” provision.

2.1.94 The Mayor's Housing SPG 2016 acknowledges the extra development costs associated with new specialist older persons housing and suggests these may require “bespoke”viability assessments for which independent validation will be sought at the developers cost.

2.2 Travellers

Travellers

Background

2.2.1 Gypsies and Travellers have traditionally stopped in Bromley whilst working in, and travelling through, the Borough and over the last half century much of the Gypsy and Traveller population has become settled in housing with St Mary Cray having one of the largest settled housed Gypsy populations in the UK. For those who retain a nomadic lifestyle the Council has two dedicated permanent sites at Star Lane, St Paul’s Cray and Old Maidstone Road. There are a number of Irish Travellers who have lived within the Borough for significant periods of time and become part of the local community.

2.2.2 There is also a community of Travelling Show-people in Layhams Road, in the south west of the Borough. Show-people are a community of self-employed business people who travel the country, often with their families, holding fairs. In general, they do not share the same culture or traditions as Gypsies and Travellers.

Policy 12 Traveller’s Accommodation The Council will ensure the continued provision of sites for Travellers (including Gypsies and Travellers and Travelling Showpeople) at the sites allocated as traveller sites only, illustrated in the location map "Location of Sites, allocated as Traveller Sites only, inset within the Green Belt", and detailed in Appendix 10.3. The Council will monitor and seek to address the accommodation needs of Travellers, including pitches for Gypsies and Travellers, and plots for Travelling Show-people, in partnership with representative groups and the wider sub region. The Council will seek to meet the identified need for provision by first considering the potential within allocated Traveller sites. Proposals for new development within allocated traveller sites will need to be sensitively located and landscaped to minimise adverse impacts on the visual amenity of the site and adjoining land. Proposals for new Traveller Sites to address an identified need for provision will be acceptable provided that: the site lies outside any areas of constraint, complying with Green Belt and other open space policies, and the site is well-related to schools, medical facilities, shops and public transport, and there are no adverse effects on the residential amenity of neighbouring properties and the local environment, and there are no adverse impacts on the health and wellbeing of travellers related to local environmental quality (such as noise and air quality). Sites in areas at high risk of flooding, including functional floodplains, will generally be resisted given the particular vulnerability of caravans. With regard to the need for transit pitches the Council will work with the sub-region to secure their provision in an appropriate location within the sub-region. Traveller Sites will be safeguarded for the purposes of Traveller Sites only. Proposals that would result in the loss of all or part of a Traveller site will be refused unless the local planning authority is satisfied that there is no longer a need for the provision. Given the allocation of the sites as insets within the Green Belt for Traveller Sites only, only uses appropriate in the Green Belt will be permitted should the site no longer be needed for traveller purposes.

Supporting Text

2.2.3 The Government’s Planning Policy for Traveller Sites (PPTS) 2015, defines 'Gypsies and Travellers' and 'Travelling Show-people' under the single umbrella of 'Travellers.' It requires local planning authorities to produce a robust evidence base to establish traveller accommodation needs, in order to inform the preparation of local plans and planning decisions, and to annually update a supply of specific deliverable sites sufficient to provide five years worth of sites, and broad locations for growth for years 6-10, and where possible years 11-15.

2.2.4 The Bromley “Traveller Accommodation Assessment” is prepared and updated in accordance with planning guidance and the statutory duty to assess the accommodation needs of Travellers under section 8 of the Housing Act 1985. This is available to view and download in the Supporting Documents folder in the online consultation portal.

2.2.5 The PPTS highlights the Government aim to promote more private traveller site provision and advises that, whilst reiterating that the Green Belt should be protected from inappropriate development, the PPTS does allow, in exceptional circumstances, for the limited alteration to the defined Green Belt boundary to accommodate a site inset within the Green Belt to meet a specific, identified need as “a traveller site only”. The PPTS advises that this can only be undertaken through the plan-making process.

2.2.6 The Borough is covered to a large extent by planning and landscape constraints, notably open space designations, including Green Belt and Metropolitan Open Land, along with a range of other protective designations. These designations and other strategic needs of the plan, including the housing requirement, represent very significant challenges to identifying suitable locations for Traveller Sites.

2.2.7 All existing sites occupied by Travellers lie within the Green Belt and are therefore by definition “inappropriate”.

2.2.8 The “Travellers Site Assessment Background Paper” (2016), also available on-line, sets out the methodology used to assess sites. The methodology involves a three-tier site selection using key criteria reflecting the Planning Policy for Traveller Sites (PPTS) which requires local authorities to ensure that traveller sites are sustainable economically, socially and environmentally.

2.2.9 The Local Plan addresses the accommodation needs of travellers, in line with the 'Planning Policy for Traveller Sites' (PPTS), through the allocation of sites with current or historic permissions as Traveller sites. The need set out in the “Traveller Accommodation Assessment” (2016) which, together with the site assessment process (confirming the lack of appropriate sites), demonstrate the justification for “exceptional circumstances” to make limited alterations to produce “insets within the Green Belt” for removal and use “as a Traveller Site only" at the following currently occupied sites which benefit from current or historic permissions:

Two Gypsy and Traveller Council Sites

• Star Lane: 22 pitches
• Old Maidstone Road: 14 pitches

Nine Gypsy and Traveller Private Sites

• 148 Croydon Road : 5 pitches
• Meadow View, Saltbox Hill : 3 pitches
• Archies Stables, Cudham Lane North: 1 pitch
• Hockenden Lane (2 sites)
  • Rosedale: single pitch
  • Southview, Trunks Alley: 2 pitches
• Layhams Road (4 sites, of which 3 are adjacent to each other)
  • Mead Green, Layhams Road : 2 pitches
  • St Joseph's Place, Layhams Road : 2 pitches
  • Millie's View, Layhams Road: 2 pitches
  • Keston Mobile Park, Layhams Road: 4 pitches

Two Travelling Showpeople Private Sites

• Keston Travelling Showmen's Ground, Layhams Road: 29 plots
• Land at the junction with Sheepbarn Lane, Layhams Road: 2 plots
  

2.2.10 Individual map extracts are set out in Appendix 10.3.

Location of sites, allocated as Traveller Sites only, inset within the Green Belt

Future Need

2.2.11 In addition to establishing the appropriate level of pitch provision the guidance also requires Local Plans to enable effective enforcement of planning policy. Addressing needs in accordance with the guidance will assist the Council in resisting future inappropriate development in the Green Belt.

2.2.12 The PPTS advises that local planning authorities should limit new traveller site development in open countryside that is away from existing settlements or outside areas allocated in the development plan. As with other forms of housing access to major roads or public transport services, will affect residents’ ability to seek or retain employment, to attend school, further education or training and to access health services and shopping facilities

2.2.13 On the basis of the evidence base and site assessments, future need can be addressed from within the allocated Traveller sites, subject to planning permission. Any proposals for new sites will, having first considered the capacity within allocated Traveller sites, be assessed against the criteria within the policy, regarding open space, the availability of services and facilities, the impact on neighbouring properties and the local environment (including natural, built and historic features) and the health and wellbeing of the travellers.

2.2.14 Whilst there are existing sites located in areas at low or medium risk of flooding (zones 1 or 2) appropriate mitigation should be undertaken to mitigate the risks associated with possible flood events on any new caravans. New sites and pitches will be resisted in areas at high risk of flooding (Flood Zone 3, which includes the functional flood plain).

2.2.15 The London Plan (2016) advises that requirements should be identified and addressed in line with national policy, in co-ordination with neighbouring boroughs and districts. In response to the London Plan and the 'Duty to Cooperate' (Section 110 of the Localism Act 2011) the Council will continue to engage with neighbouring authorities, within and beyond London, particularly in respect of the need for transit pitches, noting that other boroughs in the London South sub region, and indeed across London, have a lower provision of pitches and plots than Bromley.

2.3 Renewal Areas

Renewal Areas

Introduction

2.3.1 Bromley has identified five ‘renewal areas’ which include the areas most ‘deprived’ as evidenced by the 2015 English Indices of Deprivation, based on information about income, employment, health deprivation and disability, education, skills and training, barriers to housing, and crime. Indices of Deprivation explorer 2015 (Department of Communities and Local Government)

2.3.2 The London Plan identifies its ‘Areas for Regeneration’, as the 20% most deprived Lower Super Output Areas (LSOAs) in London based on the 2012 Indices of Deprivation. London Plan Policy 2.14, indicates that the Mayor will prioritise these areas for renewal and advises that boroughs should identify areas for regeneration and set out integrated spatial policies, bringing together regeneration, development and transport proposals with improvements in learning and skills, health, safety, access, employment, environment and housing, in locally based plans, strategies and policies. London Plan paragraph 2.63A states ‘the overriding objective of the Mayor’s regeneration programmes is to drive and shape growth in London’s town and economic centres and high streets.’

2.3.3 Generally Bromley, as a Borough, scores favourably in the English Indices of Deprivation. However, the pattern of scores varies within the Borough, with generally concentrations of poorer scores to the north west of the Borough in Crystal Palace, Penge and Anerley, to the north in Mottingham, and to the east in the Cray Valley, as well as centrally in Bromley Common, and in the Downham area of Ravensbourne, Plaistow & Sundridge.

2.3.4 The 2015 English Indices of Deprivation shows all Bromley’s ‘renewal areas’ including pockets of deprivation in the 20% of census super output areas scoring highest nationally. These areas experience poorer health outcomes as illustrated in the 2012 Bromley Joint Strategic Needs Assessment which describes the indicators of the wider determinants of health and health outcomes for several of the renewal areas. A focus on these renewal areas can contribute to a reduction in health inequalities, improve links to employment opportunities and improve the overall ‘well-being’ of the area.

Bromley’s Renewal Areas

2.3.5 Bromley’s renewal areas are based on the Bromley ‘Places’, identified in the Core Strategy Issues Document (2011) Regeneration Areas Map 2.5, however whilst the London Plan uses the 2012 indices The Renewal area reflect the updated indices (2015). This enables opportunities within those 'Places' to respond positively to changes, harnessing the contribution to the economic, environmental and social well-being, as well as maximising the potential to address issues which led to the London Plan designation of specific areas as Regeneration Areas.

2.3.6 The following Places, which incorporate the most deprived areas, in line with the Mayoral “Areas of Regeneration”, are identified in this plan as “Renewal Areas”:

• Crystal Palace, Penge & Anerley,
• Bromley Common,
• The Cray Valley, including two adjacent 'Places' of:
  • Cray Valley, St Paul's Cray, St Mary Cray. and
  • Orpington, Goddington & Knoll,
• Mottingham,
• Ravensbourne, Plaistow and Sundridge.
  

2.3.7 Map illustrating the five Bromley Renewal Areas - which encompass the Mayor's "Areas of Regeneration".

Note: The hatched area to the east of the Borough includes a single large electoral district falling within the 20% most deprived LSOAs. This electoral district includes a significant area of sparsely populated Green Belt which has not been included within "The Cray Valley Renewal Area".

Policy 13 Renewal Areas The Council will seek to maximise opportunities for enhancement and improvement within the Renewal Areas. Proposals should provide demonstrable economic, social and environmental benefits and address identified issues and opportunities. For example, proposals will be expected to maximise opportunities to: deliver high quality environments, which complement and enhance existing development and ’assets', including built heritage and other environmental assets, support health and wellbeing by producing healthy environments through scheme designs and expanding access to recreation, leisure and by, optimising opportunities to increase the provision or enhance the quality of open spaces and recreational facilities, create inclusive communities, engaging and involving the local community in the development of proposals and acknowledging and, where appropriate, responding to locally developed plans, encourage an appropriate mix of housing tenures, particularly within the Mayor’s defined “Areas of Regeneration”, that will promote mixed and balanced communities, make a positive contribution to the vitality of local centres having regard for their importance as providers both of local facilities and local employment, acknowledge relevant initiatives and plans in adjacent boroughs and cooperate with them to plan strategically across administrative boundaries and to maximise the benefits of proposals with cross borough impacts, improve accessibility, developing transport connectivity across transport modes. Weight will be attached to proposals which deliver improvements to address the particular issues relating to the Mayor’s “Areas for Regeneration” within the Borough.

Supporting Text

2.3.8 The National Planning Policy Framework (NPPF) advises that plans need to take local circumstances into account, so that they respond to the different opportunities for achieving sustainable development in different areas.

2.3.9 The Localism Act 2011 places a duty on local authorities to work together on planning issues. The NPPF expands on this, indicating that Local Plans should be based on co-operation with neighbouring authorities, public, voluntary and private sector organisations. It will be important to take full account of plans, developed by communities in partnership with the Council and other agencies, including town centre initiatives, and local regeneration projects. (e.g. the Mottingham Big Local Vision and Partnership Plan March 2013).

Cross Borough Working

2.3.10 Two renewal areas, have cross border planning designations. The Crystal Palace Renewal Area shares a District Centre boundary with Croydon Council, as well as boundaries with Lambeth, Southwark and Lewisham. The Cray Valley Renewal Area includes the Foots Cray Business Park which straddles the boundary between Bromley and Bexley boroughs.

2.3.11 The Mottingham Renewal Area includes the Mottingham estate which shares similar characteristics with the adjoining residential estates in Greenwich and Lewisham and the Downham area of the Ravensbourne, Plaistow and Sundridge Renewal Area forms part of the wider ‘Downham’ area which extends into the adjoining part of Lewisham. These adjacent residential areas in the neighbouring boroughs are also highlighted in the London Plan as “Areas for Regeneration.

2.3.12 The various Renewal Areas have a range of assets, physical (including heritage), social and economic, which offer potential for enhancement though a variety of different opportunities. The Bromley Local Plan recognises the characteristics of the 'Places' within the Borough, including the Renewal Areas and other guidance can be developed to expand on the range of issues , challenges, key sites and opportunities within the various Renewal Areas.

Policy 14 Development Affecting Renewal Areas The Council will require development in, or close, to Renewal Areas to demonstrate that they maximise their contribution to economic, social and environmental improvements and will, where appropriate, prepare Development Briefs or other guidance.

Supporting Text

2.3.13 Where appropriate the Council will consider preparing “Development Briefs” to provide more detailed guidance on design and planning issues and the acceptable quality and quantity of development, including the spatial distribution of uses on a particular site. It should deliver a degree of certainty to prospective developers and help to coordinate development, guide local decision-making and, ultimately, speed up the overall planning application process.

2.3.14 Sites lying close to Renewal Areas may also offer the potential for developments of a scale and type which would enable them to contribute to economic, social and environmental improvements within the Renewal Areas. In such circumstances proposals will be expected to comply with Renewal Area policies and to demonstrate that they have optimised their contribution to the economic, social and environmental well-being of the relevant Renewal Area

2.3.15 The health and wellbeing challenges in the renewal areas are set out in the Joint Strategic Needs Assessment 2012 (Bromley Clinical Commissioning Group and London Borough of Bromley).

Specific Renewal Area Policies

2.3.16 Developments within Renewal Areas which are experiencing significant transition and growth and incorporate Mayoral “Areas for Regeneration” will be expected to respond to particular opportunities as they present themselves.

Policy 15 Crystal Palace, Penge & Anerley Renewal Area Proposals within the Crystal Palace, Penge & Anerley Renewal Area will be expected to take advantage of opportunities: to maximise contributions to, and benefits from the thriving cultural and leisure economy, which has evolved in the Crystal Palace District Centre and, in the Crystal Palace Strategic Outer London Development Centre; which create benefit to the wider area by contributing to the conservation and enhancement of Crystal Palace Park through development that respects its character area and ensures a positive relationship with natural and heritage assets to support renewal in Penge Town Centre.

Supporting Text

2.3.17 The Crystal Palace, Penge & Anerley Renewal Area extends from the northwest of the Borough, where it adjoins four other boroughs: Croydon, Lambeth, Southwark, and Lewisham, and meets the Crystal Palace District Centre, downhill to Penge and Anerley. It includes areas identified by the Mayor as Areas for Regeneration, in the vicinities of Betts Park and Maple Road/ Franklin Road.

2.3.18 The London Plan defines Crystal Palace as a District Centre which is reflected in this Local Plan. The centre straddles three boroughs falling substantially within the London Borough of Croydon, whose Local Plan Strategic Policies (adopted April 2013) identifies Crystal Palace District Centre as an Enterprise Centre and seeks to promote the growth and expansion of Cultural and Creative Industries.

2.3.19 Crystal Palace Park is a Grade II* listed park designated as Metropolitan Open Land which was once home to Sir Joseph Paxton's Crystal Palace, which, in its original form, housed the Great Exhibition of 1851 in Hyde Park. The Park adjoins four other London Boroughs and there is an approved master plan to restore the Park which includes a museum, park maintenance facilities, children’s nursery, cafes, information and retail kiosks, greenhouses, a treetop walk, a horticultural and animal husbandry training college, as well as the development of 180 homes.

2.3.20 The identification of Crystal Palace as a Strategic Outer London Development Centre (SOLDC) with a greater than sub-regional importance in relation to leisure and sport, together with the Crystal Palace Masterplan, which supports renewal and regeneration, has the potential to significantly benefit the wider area. In combination with the development of enhanced transport infrastructure, such as the extension of the tram network, these strategies present opportunities to boost the local economy. See Policy 111 Crystal Palace SOLDC.

2.3.21 The implications of proposals within Crystal Palace Park are potentially beneficial to Penge Town Centre, which, along with the surrounding area has been the subject of regeneration programmes and recent improvements have contributed to the revival of Maple Road market.

Policy 16 Bromley Common Renewal Area Proposals within the Bromley Common Renewal Area will be expected to maximise opportunities to create a successful transition zone from Bromley Town Centre to the suburban and semi-rural urban fringe and produce a positive gateway to Bromley Town Centre along the Hayes Lane / Homesdale Road / A21(Bromley Common) junction, supported by appropriate green infrastructure.

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2.3.22 Bromley Common Renewal Area forms part of the A21 corridor and is part of a major radial route into London. This section of the A21 is an important transition area between Bromley Town Centre and the more rural and residential areas in the south of the Borough.

2.3.23 The area has experienced significant recent change with the development of "Trinity Village" and, further north, the changing nature of Homedale Road from commercial offices and houses to flatted development. The Renewal Area includes an area identified by the Mayor as an Area for Regeneration close to Turpington Lane.

2.3.24 The policy seeks to ensure that change is appropriately managed to ensure the opportunities for the area provide a successful transition to the town centre and a high quality residential environment whilst protecting and enhancing valued environments and ensuring that recreational opportunities are maximised to cater for the growing population within the Renewal Area.

2.3.25 The nature of education provision is changing, allied to significant pressure for educational places. The area's central location (of Bromley Common Renewal Area) within the Borough and the good public transport accessibility in the vicinity of the A21 has resulted in the location of significant educational infrastructure, including Bromley College of Further and Higher as well as both primary and secondary schools and the renewal area includes an allocation for an additional secondary school at Turpington Lane. (See Policy 29 Education Site Allocations).

Policy 17 Cray Valley Renewal Area Proposals within the Cray Valley Renewal Area will be expected to maximise opportunities: to create a successful economic “growth area” along the Cray Valley, including the Cray Business Corridor, supporting the health and wellbeing of the community, and to protect and enhance the green wildlife corridor along the River Cray, integrating with the public realm, along highways and open spaces and through commercial and industrial areas by creative design, and to support Orpington Town Centre in its role, as a Major Town Centre, serving the east of the Borough in respect of retailing and community services and developing a thriving retail, office and leisure economy.

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2.3.26 The Cray Valley Renewal Area comprises two adjacent identified “Places” within Bromley, namely “Cray Valley, St Paul’s Cray & St Mary Cray”, “Orpington, Goddington and Knoll”.

2.3.27 The Cray Valley Renewal Area includes areas identified by the Mayor as Areas for Regeneration, in the vicinities of Cotmandene Crescent, Ramsden and east of St Mary Cray High Street. It should be noted that the significant area shown on the above Renewal Areas map, along the eastern boundary of the Borough with Sevenoaks is a mapping anomaly. This large lower super output area (LSOA) incorporates a significant area of very sparsely populated Green Belt, with the population concentrated within the residential area of the Cray Valley. The renewal areas are based on distinct places within the Borough rather than electoral districts and hence, despite the “Eastern Green Belt" falling within the 20% most deprived LSOAs, the vast majority of this large electoral district is sparsely populated Green Belt. It has not therefore been included within "The Cray Valley Renewal Area".

2.3.28 The River Cray runs through open spaces, including recreation grounds, SSSI and SINC designations, as well as residential, commercial and industrial areas and two conservation areas. Development may present opportunities for the restoration of the river and providing improved ecological habitats to buffer the watercourse.

2.3.29 The Cray Business Corridor accounts for approximately half the industrial floor-space in the Borough and is defined as a Strategic Industrial Location (SIL) in the London Plan, and an area identified for strategic growth in this Plan (see Policy 81)

2.3.30 Cray Village Community Forum (CVCF), supported by the Council produced “Shaping a better future - A feasibility report on improving services and facilities in the Crays” (2011).

2.3.31 Orpington is the Borough's second largest town and is important as a centre for retailing and community facilities. Whilst it is a competitive shopping destination it is under pressure from competing facilities such as the Nugent Shopping Park and the proximity of larger centres, such as Bromley and Bluewater. Substantial investment in the town centre has seen the development of the Orpington campus of Bromley College of Further and Higher Education, an enhanced leisure and retail offer at the Walnuts Centre, including a new multi-screen cinema and a mixed use development incorporating a new health centre. These developments are reinforcing Orpington’s importance in respect of cultural, social and recreational facilities and its role as a Major Town Centre which is recognised, reinforced, and controlled through Policies 91 'Proposals for Main Town Centre Uses' and 92 'Metropolitan and Major Town Centres'.

Policy 18 Mottingham Renewal Area Proposals within the Mottingham Renewal Area will be expected to maximise opportunities to support the vitality and viability of the Mottingham Local Centre and Kimmeridge Cross Neighbourhood Centre; the enhancement of linkages with other areas of Bromley and adjoining boroughs, particularly in relation to centres of employment; and the protection and enhancement of the public realm and residential environment, particularly within the Mottingham Estate.

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2.3.32 The 1930s London County Council (LCC) Mottingham Estate, and indeed the adjoining LCC estates in Lewisham and Greenwich were part of the London wide housing programme between the two world wars, providing family housing with private gardens, but no off street parking. These estates, which still retain some of the existing social infrastructure, feature in the Mayor's ‘Areas of Regeneration’ as within the most deprived areas. It is notable that these residential estates, score well in terms of the “living environment” indices making the maintenance and enhancement of the living environment particularly important in these areas.

2.3.33 There have been a number of plans and strategies developed by the local community, most recently “The Mottingham Big Local Vision and Partnership Plan” (March 2013).

2.3.34 A predominantly residential area, the Mottingham Local Centre and the local neighbourhood centre provide shops, services and local employment.

2.3.35 The area is poorly connected to the rest of the Borough and beyond. Mottingham train station is located away from the two retail centres, in the adjacent borough of Greenwich, to the north of the A20 and over 1km to the nearest part of the Mayor’s ‘Area of Regeneration’.

Policy 19 Ravensbourne, Plaistow, Sundridge Renewal Area Proposals within the 'Ravensbourne, Plaistow and Sundridge' Renewal Area will be expected to maximise opportunities to support the vitality and viability of the Burnt Ash Lane and Plaistow Lane Neighbourhood Centres; enhance linkages with other areas of Bromley and adjoining boroughs, particularly in relation to centres of employment; and protect and enhance the public realm and residential environment, particularly within the Downham Estate.

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2.3.36 The Renewal Area is characterised by a mix of suburban development, including spacious roads of large detached houses to the south of Sundridge Park Golf course, terraced housing and converted Victorian Villas north of Bromley Town, suburban private estate development and the Downham Estate, interwar London County Council (LCC) public housing. The Downham Estate lies predominantly within the borough of Lewisham,however, a significant area covering approximately 65ha lies within Bromley and within one of the 20% most deprived Lower Super Output Areas within the English Indices of Deprivation 2015. As with the Mottingham Estate it is notable that this former LCC estate, scores well in terms of the “living environment” indices making the maintenance and enhancement of the living environment particularly important in these areas.

2.3.37 The Lewisham Core Strategy 2011 identified a number of areas as Local Regeneration Areas. These areas were identified as falling within the top 20% LSOAS nationally and include Downham. Given these areas have the greatest socio-economic needs, the Lewisham Core Strategy states that with their partners, Lewisham will seek to strengthen the quality of life and well-being by addressing deprivation and health inequalities.

2.3.38 The renewal area is served by local centres at Plaistow Lane and Burnt Ash Lane providing local shops and services. Being a predominantly residential area, these commercial centres also provide important employment opportunities, along with the Bromley Court Hotel, and local schools.

2.3.39 Sundridge Park Railway Station lies on the link line between Bromley North and Grove Park Station. Onward journeys to employment centres in London or south to Orpington and beyond require transport changes. Improving access to employment opportunities and retaining the commercial uses in the area are important.

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