London Plan Policy 3.4 (Optimising Housing Potential) seeks to optimise housing output from development by applying the sustainable residential quality density matrix at Table 3.2 of the Plan.
Paragraph 3.28 of the reasoned justification to Policy 3.4 is clear that the density matrix is only the start of planning for housing development and that it should not be applied mechanistically. Further guidance on how the matrix should be applied to proposals is set out in the Mayor’s Housing SPG (March 2016) and this indicates that whilst the maximum of the ranges set out in the density matrix should not be taken as a given, reasons for exceeding them should be clearly demonstrated.
CS Policy 22 (Housing density) makes clear that higher residential density in the borough will be promoted in sustainable locations that offer distinct opportunities for neighbourhood and community cohesion such as the main Town Centres (Dalston and Hackney Central), alongside major transport infrastructure, on renewed estates, as part of the 2012 Olympic legacy site and around the City Fringe. It goes on to state that all proposals for development should take account of the density matrix and PTAL scores, as set out in the London Plan.
The policy also makes clear that if an area has a PTAL under 5 (which this site does), development will only be permitted at higher densities where there are firm proposals to improve public transport in the locality, increasing the PTAL rating and allowing for high levels of sustainable movement. Finally, the policy states that in areas with controlled parking zones or high PTAL scores car-free residential development will be encouraged.
The justifying text (7.61) to CS Policy 22 states that much of Hackney is ‘Urban’.
Whilst Bethune Road exhibits a number of suburban characteristics (located more than 800m from a District centre and containing predominantly semi-detached two-storey housing), overall the existing location might be considered to have an ‘urban’ character. The southern part of the site has a PTAL of 2 and the middle and northern part of the site has a PTAL of 3. As such, the indicative density range is 200 to 450 habitable rooms per hectare (hr/ha) and 55 to 170 units per hectare (u/ha) (depending on average size of homes).
It should be noted that the potential housing scheme alone has an average of 3.1 habitable rooms per unit, suggesting a range of 55-145 u/ha, whereas the overall potential scheme (existing and proposed homes) has an average of 2.9 habitable rooms per unit, suggesting a range of 70-170 u/ha.
Both the July 2014 BPA feasibility study, and the May 2014 Savills, report consider residential density on the basis of the potential scheme alone, with three individual potential development areas amounting to approx.0.54 hectare. This method of calculation results in the potential scheme having a density of 509 hr/ha and 161 u/ha.
Given the integral nature of the site, with all three residential buildings being joined by ground floor car parking structures with communal amenity play space above, and having access to communal open space along the western boundary, it is considered that it would be more appropriate to consider density across the overall potential scheme, based upon the overall site of approximately 1.21 hectares. Taking account of existing and potential housing within the overall site, the resulting density would be 688 hr/ha or 235 u/ha.
Further, if one was to consider only the impact on the calculated density of the remainder of Lincoln Court including the existing residential blocks, then the resulting density of the existing increases to 856 hr/ha or 288 u/ha.
Whichever method of calculation is followed, the density of any potential scheme would be significantly greater than the maximum London Plan indicative density in terms of habitable rooms. Whilst this in itself does not make the potential scheme unacceptable, it does highlight the importance of paying particular attention to substantive factors such as open space and play space provision, scale and massing, residential amenity, infrastructure provision public transport and parking (with CS Policy 22 making clear that higher density development will only be permitted in areas with a PTAL less than 5 where there are firm proposals to improve public transport in the locality. There are no such proposals here).