The Former Grounds of Hayes Football Club

Home , Barra Hall Park, Lake Farm Country Park, Yeading

planning report PDU/2581/02 30 November 2010 The former grounds of Hayes Football Club

in the London Borough of Hillingdon planning application no.4327/APP/2009/2737

Strategic planning application stage II referral (new powers) Town & Country Planning Act 1990 (as amended); Greater London Authority Acts 1999 and 2007; Town & Country Planning (Mayor of London) Order 2008

The proposal Redevelopment of site to provide 183 residential dwellings, comprising houses and flats, with associated amenity space, landscaping, new access road and car parking. The applicant The applicant is Barratt (Southern Counties), and the architects are Acanthus LW

Strategic issues Replacement playing facilities (a multi-games area and synthetic turf pitch) to mitigate the loss of a playing field/community facilities would be secured at alternative sites by legal agreement; the issues of housing, urban design, transport and energy have also been resolved.

The Council’s decision In this instance Hillingdon Council has agreed a dual recommendation resolving to grant permission, but requesting officers to refer the application back to the planning committee for determination if any of the heads of terms of the Section 106 have not been agreed and the legal agreement has not been finalised within six months of the date of the committee resolution, or any other period deemed appropriate by the Head of Planning & Enforcement. Recommendation That Hillingdon Council be advised that the Mayor is content for it to determine the case itself, subject to any action that the Secretary of State may take, and does not therefore wish to direct refusal or direct that he is to be the local planning authority.

Context

1 On 26 January 2010, the Mayor of London received documents from Hillingdon Council notifying him of a planning application of potential strategic importance to develop the above site for the above uses. This was referred to the Mayor under Category 1A of the Schedule to the Order 2008: “Development which comprises or includes the provision of more than 150 houses, flats, or houses and flats.”

page 1 2 On 3 March 2010, the Mayor considered planning report PDU/2581/01, and subsequently advised Hillingdon Council that the application did not comply with the London Plan, for the reasons set out in paragraph 105 of the above-mentioned report; but that the possible remedies set out in paragraph 107 of the report could address these deficiencies.

3 A copy of the above-mentioned report is attached. The essentials of the case with regard to the proposal, the site, case history, strategic planning issues and relevant policies and guidance are as set out therein, unless otherwise stated in this report. Since then, the application has been revised in response to the Mayor’s concerns (see below).

4 On 7 September 2010, Hillingdon Council agreed a dual recommendation resolving to grant permission but requesting officers to refer the application back to the planning committee for determination if any of the heads of terms of the Section 106 agreement had not been agreed and the agreement had not been finalised within six months of the date of the committee resolution, or any other period deemed appropriate by the Head of Planning & Enforcement. On 19 November 2010 the Council advised the Mayor of this decision.

5 Under the provisions of Article 5 of the Town & Country Planning (Mayor of London) Order 2008 the Mayor may allow the draft decision to proceed unchanged, direct Hillingdon Council under Article 6 to refuse the application or issue a direction to Hillingdon Council under Article 7 that he is to act as the Local Planning Authority for the purposes of determining the application and any connected application. The Mayor has until 2 December 2010 to notify the Council of his decision and to issue any direction.

6 The environmental information for the purposes of the Town and Country Planning (Environmental Impact Assessment) (England and Wales) Regulations 1999 has been taken into account in the consideration of this case.

7 The decision on this case, and the reasons will be made available on the GLA’s website www.london.gov.uk.

Update

8 At the consultation stage Hillingdon Council was advised that the application did not comply with the London Plan, for the reasons set out in paragraph 105 of the above-mentioned report; but that the possible remedies set out in paragraph 107 of that report could address these deficiencies: Loss of a playing field

9 The redevelopment proposal is associated with the relocation of Hayes & Yeading Football Club from the application site to The Warren Ground in Yeading, and the subsequent vacancy of the former premises.

10 Whilst the proposal would result in the loss of a local playing field (contrary to the London Plan policies 3D.8 and 3D.11, policy 7.18 of the draft replacement London Plan and UDP policy R4), the applicant has pointed out that the privately owned grounds are not and have never been openly accessible to the general public or local community other than for hiring of the existing football pitch, or ancillary facilities such as the clubhouse and private function room by local sporting and non-sporting clubs or individuals. As such, it is argued, the site makes no contribution to publicly accessible open space or the present needs of the local community and should not, therefore, be assessed against the relevant policies.

11 The applicant, Hayes & Yeading FC has, nonetheless, pledged to compensate for the loss of the former Hayes football ground by entering into a legal agreement with Hillingdon Council to

page 2 link the first occupation of the new residential units to the delivery of alternative facilities at The Warren ground in Yeading, where the football club proposes to move.

12 In this regard, the club agrees with the Council officers’ recommendation to carry out and complete, prior to occupation of the development, the construction of a new all-weather synthetic pitch, including lighting and two five-a-side synthetic playing pitches (in accordance with a previous planning permission 26131/APP/2008/2054) at the Yeading Football Club, Beaconsfield Road (also known as The Warren). The club has confirmed in writing that the all-weather pitch would be available to the general public for recreational use all year round.

13 The submitted draft legal agreement provides that the all-weather synthetic pitch shall be constructed and laid out to Football Association standards, including perimeter fencing and lighting. The club is required to notify the Council in writing on completion of these works. The Council would, in turn, inspect the works within one month and provide written confirmation of its satisfaction or requirement for further works to be carried out to meet the necessary standard.

14 The legal agreement would also secure a financial contribution by the club to cover the cost of capacity enhancement to local recreational and sports facilities within the vicinity of the application site.

15 These proposals would mitigate the loss of the former Hayes Football grounds and resolve one of the Mayor and Sport England’s principal concerns about the application. Housing issues

16 The original quantum and mix of housing units has been altered since the initial consideration of this case by the Mayor. The most significant change is a reduction in the overall residential provision from 185 to 183, comprising 123 units for open market sale; and 60 for social renting and intermediate tenure.

17 At consultation stage, the applicant club was requested to provide full details of the split between social rented and any intermediate accommodation within the affordable housing provision; identify any registered social landlord involved; provide an explanation as to whether the affordable housing offer includes a public subsidy and if not, the reasons for a lack of subsidy; and evidence of any written agreement between Barratt Southern Counties and the Council on the level of affordable housing proposed.

18 In response, the applicant has indicated that the affordable housing contribution would be split on a ratio of 60:40 social rented to intermediate accommodation. That split falls short of the Hillingdon UDP requirement of 70:30 in favour of social rented housing, which was ostensibly based on the London Plan. In view of an acknowledged high level of social housing in the locality, however, the Council is satisfied with the 60:40 split, which is precisely in line with the ratio recommended in the Mayor’s draft replacement London Plan. There is still no indication that a registered social landlord has been nominated to manage the proposed affordable housing.

19 On the availability of public subsidy, the club has indicated that an application for grant funding can no longer be made without a viable planning permission. In the prevailing financial climate, the general cutback in resources could make it unlikely that the scheme would attract a social housing grant.

20 The club proposes an affordable housing contribution of 60 units, comprising 35 for social renting and 25 for shared ownership. This represents an affordable housing proportion of 33% by unit, rather than the 35% indicated in the planning committee report.

21 The applicant submitted a financial viability appraisal in support of the application, which was subjected to independent assessment on behalf of the Council. The assessment concluded that

page 3 the development would not be viable if any more than 35% of the residential units were allocated as affordable housing. Council officers consider that given the absence of a social housing subsidy and the prevailing economic conditions, this contribution represented an acceptable balance between affordable housing provision and the obligation to contribute towards other community facilities.

22 Last but not least, the stage 1 report pointed to a shortfall in the GLA minimum space standards of approximately 13 of the proposed residential units. The applicant’s response is that the Hilingdon Design and Accessibility Statement (HDAS) had imposed alternative residential space standards, which the application scheme evidently reflected. The applicant has since amended the scheme to narrow the differences in standard, bearing in mind that the HDAS had been adopted when the scheme was in preparation, whilst the draft replacement London Plan was in the earliest stage of public consultation. In the circumstances, this compromise is both reasonable and acceptable.

23 These details address the outstanding housing issues and are considered satisfactory from a strategic planning perspective. Urban design

24 The stage 1 report highlighted a need for boundary treatment of the existing and new planting proposed as part of the development; and to secure appropriate management of the communal and public open spaces, in order to integrate them into the scheme and to avoid neglect and lack of ownership.

25 The applicant has responded by providing a plan showing specific details for each boundary and specifications for planting trees and shrubs across the site. The species of ornamental trees are also indicated on the plan; however, specific details of the shrub planting are reserved for consideration and approval at a later date. The club is prepared to accept a planning condition to secure this detail and the appropriate planning conditions were included in the draft approval notice agreed by the planning.

26 The club also agreed to secure management of the proposed communal and public areas as part of the legal agreement. Schedule 7 of the legal agreement makes appropriate provision for that to take place.

Energy

27 The applicant produced a revised energy strategy in response to the issues raised in the stage 1 report. The revised strategy was reviewed by GLA energy officers who noted that the only issue remaining to be addressed was the measures to be used for passively cooling the dwellings and thus avoid overheating. Concern remained that the applicant had not clarified whether there would be a need for active cooling of the dwellings and, if so, how it would be provided. This was an issue originally raised in paragraph 92 of the stage 1 report 28 In response, the applicant clarified two south-facing top and mid floor flat types were judged to be the most likely units on the scheme to register any overheating risk. These have been entered into the SAP modelling and tested under Appendix P. Overheating risk was shown to be slight for these unit types where there was the ability to open windows.

29 The applicant has confirmed that all units would be subject to the Appendix P test as part of the Building Regulations Part L submission to Building Control during the construction of the development. Part F compliance would also ensure there is adequate controlled ventilation. It is

page 4 concluded that there will be no need for active cooling of dwellings. As such, the applicant has confirmed active cooling would not be specified.

30 It was also proposed that solar thermal panels would be applied only to the houses, thus avoiding the complications of installing solar thermal panels to serve the flats. The applicant has also investigated the potential for photovoltaics and proposes the installation of PV on the roofs of the blocks of flats. In response, the GLA energy advisor has commented that the combined effect of that approach would increase the carbon dioxide emissions reduction achieved through renewable energy to 17%, which is welcomed.

31 Based on the above, there are no remaining issues to address in relation to the London Plan energy policies. Transport for London’s comments

32 At stage 1, TfL raised several issues including car parking and provision of electric vehicle charging points, bus stop accessibility, cycle parking, trip distribution and highway impacts.

33 Although a reduction in car parking spaces has not been achieved, it has been agreed that the higher ratio of car parking will be allocated strictly to larger family units of 3 or more bedrooms and the car parking is within London Plan standards. 20% of car parking spaces across the site will have electric vehicle charging points (EVCPs). 4 spaces will be unallocated and have ‘fast-charging’ points. There will be passive provision of EVCPs across the remaining spaces. This meets requirements set out in the draft replacement London Plan.

34 TfL has secured a sum of £22,000 towards bus stop upgrades adjacent to the site ensuring conformity with London Plan policy 3C.20 Improving conditions for buses and consultation draft replacement London Plan policy 6.7 Buses, bus transits, trams.

35 The developer has agreed to provide visitor cycle parking and a construction logistics plan (CLP), delivery and servicing plan (DSP) and exemption for future residents from eligibility for on- street parking permits have all been secured by condition.

36 The developer has provided clarification regarding the trip distribution and TfL is satisfied with this. Furthermore, Hillingdon Council has secured improvements to the Church Road and Botwell Lane Roundabout. This ensures general conformity with London Plan policy 3C.17 Tackling congestion and reducing traffic and draft replacement London Plan policy 6.11 Smoothing traffic flow and talking congestion.

37 Overall the issues raised at consultation stage have been satisfactorily addressed through the submission of additional information, planning conditions and obligations. Therefore, this application is considered to be in general conformity with the London Plan and acceptable in transport terms. The proposed legal agreement

38 The Council’s resolution to grant permission was subject to the completion of a legal agreement to secure the following:

 The provision of three upgraded playing pitches at the Yeading Footbal Club, Beaconsfield Road.  Affordable housing as described previously in this report.  £ 184,000 to cover the cost of capacity enhancements to local recreational and sports facilities in the vicinity of the site.

page 5  £1,067,412 to cover the cost of capacity enhancements to local education facilities  £96,140 to cover the cost of capacity enhancements to local healthcare facilities.  £22,000 for bus stop upgrades.  A 10-year green travel plan (including a £20, 000 sustainable travel plan bond).  £ 50,000 to cover the cost of capacity enhancements to local community facilities.  £10,205 to cover the cost of capacity enhancements to local libraries.  A contribution to cover the cost of landscaping works to the area of land between the north-western end of the site and Bell House Field (or to undertake the works at no cost to the Council).  On-site provision of construction training or a contribution of £1,271,675 construction training and a training coordinator post for a period of one year.  £50,000 towards air quality monitoring.  A project management and monitoring fee of 5% of the total cash contributions. Response to consultation

39 The application was advertised in the local press, by site notices and a total of 374 letters to local owners/occupiers. The following local organisations were consulted separately:

 Hayes Village Conservation Panel  Hayes Chamber of Commerce  Hayes Garden Village Residents’ Association  Hayes & Harlington Local History Society  Hayes Town Partnership  Lake View Estate Residents’ Association  Townfield Residents Association  Home Farm Residents’ Association

40 In response to the initial consultation, 10 letters were received expressing the following concerns:

 The siting of the entrance to the site was hazardous and would cause vehicle collisions.  Increased traffic congestion and on-street parking.  Area densely populated and not suited to further development.  The development would worsen air quality.  Potential increase in crime/antisocial behaviour.  Unnecessary and unacceptable pathways through Bellhouse Field.  The appearance of the scheme would be out of character with adjoining heritage/ conservation area.  Consultation not carried out properly.

41 A further 8 responses were received following re-consultation on the revised scheme and the following concerns were expressed:

 Over population from high density.  Inadequate local infrastructure and social facilities to serve the development.

page 6  Loss of existing sports pitch.  Loss of light to residents due to proximity of the development to Chartwell House.  Increased traffic congestion/ on-street parking.  Need to relocate existing market.  Inadequate parking space; need for separate entry and exit points.  Development should include shopping facilities.  Too many housing estates in the area.

 Hayes FC was part of the heritage of the area and the development would result in the loss of a venue for social activity.

42 Sport England initially raised objection to the loss of a football playing field at the former Hayes FC grounds but withdrew that objection following the undertaking by the club to provide adequate replacement facilities at ‘The Warren’ in Yeading, and make a financial contribution towards local recreational and sports facilities in the vicinity of the application site. Article 7: Direction that the Mayor is to be the local planning authority

43 Under Article 7 of the Order the Mayor could take over this application provided the policy tests set out in that Article are met. In this instance the Council has resolved to grant permission with conditions and a planning obligation, which satisfactorily addresses the matters raised at stage I, therefore there is no sound planning reason for the Mayor to take over this application. Legal considerations

44 Under the arrangements set out in Article 5 of the Town and Country Planning (Mayor of London) Order 2008 the Mayor has the power under Article 6 to direct the local planning authority to refuse permission for a planning application referred to him under Article 4 of the Order. He also has the power to issue a direction under Article 7 that he is to act as the local planning authority for the purpose of determining the application and any connected application. The Mayor may also leave the decision to the local authority. In directing refusal the Mayor must have regard to the matters set out in Article 6(2) of the Order, including the principal purposes of the Greater London Authority, the effect on health and sustainable development, national policies and international obligations, regional planning guidance, and the use of the River Thames. The Mayor may direct refusal if he considers that to grant permission would be contrary to good strategic planning in Greater London. If he decides to direct refusal, the Mayor must set out his reasons, and the local planning authority must issue these with the refusal notice. If the Mayor decides to direct that he is to be the local planning authority, he must have regard to the matters set out in Article 7(3) and set out his reasons in the direction. The Mayor must also have regard to the guidance set out in GOL circular 1/2008 when deciding whether or not to issue a direction under Articles 6 or 7. Financial considerations

45 Should the Mayor direct refusal, he would be the principal party at any subsequent appeal hearing or public inquiry. Government guidance in Circular 03/2009 (‘Costs Awards in Appeals and Other Planning Proceedings’) emphasises that parties usually pay their own expenses arising from an appeal.

46 Following an inquiry caused by a direction to refuse, costs may be awarded against the Mayor if he has either directed refusal unreasonably; handled a referral from a planning authority unreasonably; or behaved unreasonably during the appeal. A major factor in deciding whether the

page 7 Mayor has acted unreasonably will be the extent to which he has taken account of established planning policy.

47 Should the Mayor take over the application he would be responsible for holding a representation hearing and negotiating any planning obligation. He would also be responsible for determining any reserved matters applications (unless he directs the council to do so) and determining any approval of details (unless the council agrees to do so). Conclusion

48 The issues raised in response to the initial consultation of the Mayor have been addressed as explained in the preceding paragraphs of this report. The proposed development is therefore, compliant with the relevant policies of the London Plan.

for further information, contact Planning Decisions Unit: Colin Wilson, Senior Manager – Planning Decisions 020 7983 4783 email [email protected] Justin Carr, Strategic Planning Manager (Development Decisions) 020 7983 4895 email [email protected] David Blankson-Hemans, Senior Strategic Planner, (Case officer) 020 7983 4268 email [email protected]

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planning report PDU/2581/01 3 March 2010 The former grounds of Hayes Football Club

in the London Borough of Hillingdon planning application no.4327/APP/2009/2737

Strategic planning application stage 1 referral (new powers) Town & Country Planning Act 1990 (as amended); Greater London Authority Acts 1999 and 2007; Town & Country Planning (Mayor of London) Order 2008

The proposal Redevelopment of site to provide 185 residential dwellings, comprising houses and flats, with associated amenity space, landscaping, new access road and car parking.

The applicant The applicant is Barratt (Southern Counties), and the architects are Acanthus LW.

Strategic issues The principal issues to consider are the loss of a playing field/community facility; the types, density, mix of unit sizes and quality of housing; the proportion and tenure of affordable housing; the provision of children’s play space, urban design & architectural quality, inclusive access provisions, climate change mitigation and adaptation (including energy provisions); transport & parking issues.

Recommendation That Hillingdon Council be advised that whilst the application is generally acceptable in strategic planning terms, it does not fully comply with the London Plan, for the reasons set out in paragraph 105 of this report; but that the possible remedies set out in paragraph 107 of this report could address these deficiencies.

Context

1 On 26 January 2010, the Mayor of London received documents from Hillingdon Council notifying him of a planning application of potential strategic importance to develop the above site for the above uses. Under the provisions of The Town & Country Planning (Mayor of London) Order 2008 the Mayor has until 8 March 2010 to provide the Council with a statement setting out whether he considers that the application complies with the London Plan, and his reasons for taking that view. The Mayor may also provide other comments. This report sets out information for the Mayor’s use in deciding what decision to make.

page 9 2 The application is referable under Category 1A of the Schedule to the Order 2008: “Development which comprises or includes the provision of more than 150 houses, flats, or houses and flats.”

3 Once Hillingdon Council has resolved to determine the application, it is required to refer it back to the Mayor for his decision as to whether to direct refusal; take it over for his own determination; or allow the Council to determine it itself.

4 The environmental information for the purposes of the Town and Country Planning (Environmental Impact Assessment) (England and Wales) Regulations 1999 has been taken into account in the consideration of this case.

5 The Mayor of London’s statement on this case will be made available on the GLA website www.london.gov.uk. Site description

6 A 3.35-hectare site located in exclusively residential surroundings and presently comprising a football pitch, with spectator terraces on three of its four sides; ancillary buildings including a grandstand, with changing facilities on the south side; a clubhouse (the Les Ferdinand Suite) with function room, which is available for hire by community groups and the general public; and an open car park accessed from Church Road, which forms the eastern boundary of the site. The playing grounds are otherwise enclosed by a perimeter wall, and are presently used for football training purposes and managed by Hayes & Yeading Football Club.

7 In its wider context, the site is bounded by residential properties to the west and south, and by Bell House Field to the north. It is located approximately 4.5 km southeast of Uxbridge Town Centre, and 1.5km northwest of Hayes Town Centre.

8 The site is approximately 0.6km from the A4020 Uxbridge Road, which forms part of TfL’s Strategic Road Network (SRN), and approximately 1.6km from the A312 The Parkway (Hayes Bypass), which is part of the Transport for London Road Network (TLRN).

9 There are no train or London Underground stations in close proximity of the site, however, the site is served by two bus routes (H98 and 195) that run along Church Road and provide a connection to Hayes & Harlington station; which is 1.4 km away from the site. Seven further bus services are within 10 minutes’ walk of the site. Hayes and Harlington station will also benefit from Crossrail services from 2017 although being 1.4km away this falls outside the PTAL calculation area. As such, it is estimated that at present the public transport accessibility level (PTAL) of the site is 2, on a scale of 1 to 6 where 1 is low and 6 is high.

Details of the proposal

10 The redevelopment proposal is associated with the imminent relocation of Hayes & Yeading Football Club from the site to The Warren Ground in Yeading, and the subsequent vacancy of the former premises.

11 Barratt Homes proposes the demolition of existing buildings on the site and the delivery of an exclusively residential redevelopment, comprising 185 dwellings in a variety of flats (71) and houses (114) of different sizes and tenure, including 64 affordable units. The development would entail the construction of a new vehicular access from Church Road, with new cycle and pedestrian links; car and cycle parking spaces, and the provision of comprehensively landscaped public open spaces and private gardens, including two communal play areas for younger children.

page 10 Case history

12 In November 2008, Hillingdon Council referred a planning application to the Mayor for a redevelopment of the site to provide 282 residential units. The Deputy Mayor (Planning and Policy) considered the proposal under delegated authority, on 5 January 2009, and agreed with the GLA planning officer’s conclusion that the proposal did not comply with London Plan, for reasons set out in the officer report (referenced PDU/2086b/01). The Deputy Mayor agreed with the officer recommendations suggested to remedy the identified deficiencies.

13 The proposal was subsequently withdrawn, following Council officers’ concerns that the high density development did not sufficiently respect the open parkland character and appearance of the adjoining Bell House Field and Barra Hall Park, both of which are designated as Metropolitan Open Land; the historic setting of the grade II listed Barra Hall, or the adjoining Hayes Village Conservation Area as a whole.

14 Sketched proposals for a revised application, comprising 185 dwellings, were the subject of further negotiations with the Council in March and May 2009. The current application has evolved from those discussions. Strategic planning issues and relevant policies and guidance

15 The relevant issues and corresponding policies are as follows:

 Playing fields London Plan; PPG17  Housing London Plan; PPS3; Housing SPG; Providing for Children and Young People’s Play and Informal Recreation SPG, draft Housing Strategy; draft revised interim Housing SPG  Affordable housing London Plan; PPS3; Housing SPG, draft Housing Strategy; draft revised interim Housing SPG  Density London Plan; PPS3; Housing SPG; draft revised interim Housing SPG  Access London Plan; PPS1; Accessible London: achieving an inclusive environment SPG; Planning and Access for Disabled People: a good practice guide (ODPM)  Urban design London Plan; PPS1  Transport/parking London Plan; the Mayor’s Transport Strategy; draft replacement Transport Strategy; PPG13  Sustainable development London Plan; PPS1, PPS3; PPG13; PPS22; the Mayor’s Energy Strategy; Sustainable Design and Construction SPG

16 For the purposes of Section 38(6) of the Planning and Compulsory Purchase Act 2004, the development plan in force for the area is the 1998 Hillingdon Unitary Development Plan and the London Plan (Consolidated with Alterations since 2004).

17 The Revised Core Strategy (Preferred Options) 2007 and the Mayor’s Consultation Draft Replacement London Plan (October 2009) are material considerations to which appropriate weight should be accorded.

page 11 Loss of a playing field and the principle of development

18 The site has no specific designation in the Hillingdon UDP, although its policies (R4 and R5) seek to protect against the loss of recreational open space, including private playing fields, particularly if it would cause or exacerbate a local deficiency in accessible open space.

19 The UDP approach is broadly supported by policies 3D.8 and 3D.11 of the London Plan, which state the Mayor’s commitment to work with strategic partners to protect, promote and improve access to open spaces; realise the current and potential value of open spaces to communities; and protect the many benefits of open space, including those associated with health, sports, recreation, biodiversity and the environment.

20 To identify deficiencies, PPG17 requires local authorities to carry out quantitative and qualitative assessments of need and the availability of open space, as well as sports and recreation facilities. London Plan policies 3D.11and 3D.12 reiterate the national guidance, requiring borough councils to identify broad areas of public open space deficiency and the priorities for addressing them on the basis of local need and an audit of existing provision, as part of an open space strategy. Policy 3.20 of the Draft Replacement London Plan also resists the loss of sports and recreational facilities.

21 Whilst the development proposal would result in the permanent loss of a local playing field, the applicant has pointed out that the privately owned grounds are not and have never been openly accessible to the general public or local community; other than for hiring of the existing football pitch or ancillary facilities, such as the clubhouse and private function room, by local sporting and non-sporting clubs or individuals. As such, it is argued, the site makes no contribution to publicly accessible open space or the needs of the local community at present and should not, therefore, be assessed against the UDP policy R4.

22 The applicant has, nonetheless, submitted two open space and play facility reports to demonstrate a good local distribution of public open spaces within 1, 5, and 15 minutes’ walk of the site. The report shows that there is one public open space (Bell Field Park) with no play equipment within a minute’s walk; and cumulative totals of five public open spaces, including a neighbourhood area of play within 5 minutes; and eleven public open spaces of varying standards within 15 minutes’ walk of the site. In addition, the proposed development includes some 4,385 sq.m. of public amenity space for informal recreation, representing a net increase over the present provision on site.

23 Sport England has been consulted on these proposals and, after an initial objection, appears to be satisfied with Barratt Homes’ commitment to:

Make an off-site financial contribution to provide a new, or upgrade a run-down multi-use games area in close proximity of the site, to meet the needs of the additional new residents. The facility is planned for Barra Hall Park.

Make a financial contribution to offset the impact of the development on local indoor sports facilities; with the sum required calculated using Sport England’s ‘Sports Facilities Calculator’ and all three elements based on GLA child yield figures.

Enter into a legal agreement with Hayes & Yeading FC to link the first occupation of the new residential units to the delivery of a synthetic turf pitch at The Warren ground in Yeading, where the football club proposes to move.

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24 These mitigation measures are considered acceptable and, on the basis of their effective implementation, likely to address the strategic policy objections to enable the development to proceed.

The loss of community facilities

25 UDP policy (R5) further provides that Hillingdon Council will not grant planning permission for proposals that involve the loss of land or buildings used or last used as a sports stadium; for outdoor or indoor sports and leisure facilities; or as a public or community meeting hall, unless alternative facilities are available. Policies R10 and R11 provide additional positive and proactive support for development proposals specifically involving the provision of meeting halls for social and community use.

26 For its part, London Plan policy 3A.18 encourages that approach by requiring borough councils to produce DPD policies that assess the need for social infrastructure and community facilities in their areas and ensure that they are capable of being met wherever possible. Those needs include community halls and meeting rooms within easy reach by walking or public transport. The policy further seeks to increase the provision and resist the net loss of such facilities to meet existing deficiencies and an increasing population.

27 At present, the Les Ferdinand Suite on site is available for hire for a variety of private and community events. It has an approximate capacity for 180 people and is offered with a stage, licensed bar and kitchen and a small number of parking spaces that can be supplemented by the club car park on non-match days. Regular community users include the Hayes Chess Club, Uxbridge and District Social Cub for the Blind, Weight Watchers, a local darts club, and a local pool club.

28 The loss of this facility runs contrary to the aims of the local and strategic policies summarised above. To address this issue, the previous application sought to include a small community hall on the site, though that facility is excluded from the current proposals. The applicant has, however, submitted a survey of existing community venues in Hayes, to demonstrate a generous availability of alternatives to the Les Ferdinand facility.

29 In summary, the report demonstrates the presence of a wide variety of community meeting venues, including those contained within premises such as parish halls, church facilities, community centres, public houses, schools and colleges, health facilities, libraries, sports facilities, arts and cultural facilities, and youth club buildings.

30 There were 21 such facilities within 15 minutes’ walking distance from the Church Road site advertising their accommodation and services, 13 of which had a capacity to accommodate more than 100 people. The Hayes Sports and Social Club premises, located approximately 100 metres south of the application site has a capacity of 370 in one of its two halls, bar and lounge; whilst the Botwell Social Centre, some 7 minutes’ walk from the site, has a capacity of 300 people in its hall and bar. Indeed, The Warren site, to which Hayes & Yeading FC would be moving, offers facilities for over 250 people.

31 Most significantly, Hillingdon Council secured funding to refurbish and improve the capacity and facilities of Townfield Community Centre, which is about 5 minutes’ walking distance from the application site. That facility would be fully operational well before the Les Ferdinand Suite is demolished.

page 13 32 Given the capacity and proximity of the Townfield Community Centre to the application site, the comprehensive distribution and easy availability of similar facilities in the surrounding area, and to avoid two facilities competing against each other; it was agreed between the applicant and the Council that an on-site community hall should be excluded from the current proposals.

33 It is evident from this that the loss of the Les Ferdinand Suite is unlikely to compromise or inconvenience local residents or community groups, which currently use that facility. In this respect, the application proposals are in line with the requirements of the UDP and London Plan policies. Housing issues

34 The proposal is for a total of 185 dwellings, comprising 71 flats and 114 houses of varying sizes. A breakdown of the accommodation is provided in the following table:

Unit Market Affordable Total Habitable Unit mix type units units units rooms (%) Studio 0 1 1 1 0.5 1 bed flat 9 13 22 44 12 2 bed flats 23 25 48 144 26 2 bed houses 8 4 12 36 6.5 3 bed houses 70 15 85 340 46 4 bed houses 11 4 15 90 8 5 bed houses 0 2 2 14 1 Total 121 64 185 669 100 Tenure split (%) 65.4 34.6 - - -

35 With a site area of 3.35 hectares, the housing density is calculated at 55 units per hectare or 200 habitable rooms per hectare; which is precisely at the lower end of the indicative range 55- 145 u/ha (or 200-450 hr/ha) provided in the London Plan density matrix for an urban site with an average dwelling size of 3.61 hr/unit and a public transport accessibility level of 2. It is, therefore, just within the acceptable limit for a development in that location.

36 In terms of dwelling mix, it can be calculated from the table that 55% of the units (and approximately 66% of the habitable rooms) would be family-sized, with three or more bedrooms in each unit. Assessed against the Mayor’s Housing SPG and draft Housing Strategy, the proposed mix is acceptable from a strategic planning perspective.

37 With respect to residential quality, the majority of dwelling units meet or exceed the minimum space standards provided in table 3.3 of the Consultation Draft Replacement London Plan and the Draft London Housing Design Guide.

38 However, as shown below, 13 of the total 185 dwellings proposed i.e. nine of the two- bedroom houses (type E/EP), three of the two-bedroom houses (type WH) and a one–bedroom flat (type FOB), representing 7% of all units, fall below the minimum requirement:

page 14 Unit Space Minimum Difference Total size/type proposed standard (sq.m.) units (sq.m.) 1-bed flat 43 50 - 7 1 (FOB) 2-bed house 67.5 83 -15.5 9 (E/EP) 2-bed house 81.5 83 -1.5 3 (WH)

39 The applicant should endeavour to raise these units to the required standard to improve the overall quality of the development.

Affordable housing

40 London Plan Policy 3A.10 requires borough councils to seek the maximum reasonable amount of affordable housing when negotiating on individual private residential and mix-use schemes. In doing so, each council should have regard to its own overall target for the amount of affordable housing provision. Policy 3A.9 states that such targets should be based on an assessment of regional and local housing need and a realistic assessment of supply, and should take account of the London Plan strategic target that 35% of housing should be social and 15% intermediate provision, and of the promotion of mixed and balanced communities. In addition, Policy 3A.10 encourages councils to have regard to the need to encourage rather than restrain residential development, and to the individual circumstances of the site. Targets should be applied flexibly, taking account of individual site costs, the availability of public subsidy and other scheme requirements.

41 Policy 3A.10 is supported by paragraph 3.52, which urges borough councils to take account of economic viability when estimating the appropriate amount of affordable provision. The ‘Three Dragons’ development control toolkit is recommended for this purpose. The results of a toolkit appraisal might need to be independently verified.

42 Where borough councils have not yet set overall targets as required by policy 3A.9, they should have regard to the overall London Plan targets. It may be appropriate to consider emerging policies, but the weight that can be attached to these will depend on the extent to which they have been consulted on or tested by public examination.

43 The Council’s UDP does not specify an affordable housing target and, in any event, the Secretary of State did not save policy H.11 on affordable housing in the September 2007 review. In such instances, where borough councils have not yet set overall targets as required by policy 3A.9, they are required to have regard to the overall London Plan targets.

44 Core Policy 28 of the Council’s Affordable Housing SPD (May 2006) follows the London Plan objective to to negotiate the maximum reasonable provision of affordable housing on a site by site basis and will seek to ensure 50% affordable housing provision between 1997 and 2016, on the basis of 70% social rent housing and a minimum 30% intermediate housing (including various options for shared ownership) from all residential and mixed-use developments with an element of housing.

page 15 45 Hillingdon Council has a Local Area Agreement with the government to deliver 465 affordable housing units between 2008 and 2011, and has also agreed a target of 598 affordable homes with the Mayor over the same period.1

46 As the housing table shows, the proposal offers almost 35% affordable housing by unit (calculated at approximately 32% of the total number of habitable rooms). Although the applicant makes reference on the submitted drawings to ‘housing association’ accommodation, there is no indication of the split between social rented and intermediate provision, or indeed the identity of the housing association concerned. This information should be provided in advance of any further referral of this case back to the Mayor.

47 Similarly, whilst the accompanying planning statement mentions a viability statement as part of the application proposals, there is no further reference to it in the list of documents provided in the applicant’s covering letter; nor is it included in the batch of documents provided. If the document exists, it should be forwarded to the GLA in the event of any further referral of this case back to the Mayor.

48 The only justification provided for the applicant’s offer of affordable housing is a reference in (paragraph 5.24, page 20) the planning statement to the prevailing economic downturn and its effects on the viability of development; the narrow margins of profit achievable in the current market and the proportion of affordable housing accepted by the Council in recently approved developments, such as the former Hayes Sports Stadium (where a 34% contribution was acceptable).

49 Barratt Southern Counties has also not confirmed whether the level of affordable housing proposed includes a subsidy from the Homes and Communities Agency and if not, why an application has not been made for such a grant.

50 The applicant has stated, however, that the level of affordable housing proposed has been agreed with Council officers, following extensive negotiations on viability between the parties. If that is the case, some written evidence would be useful to support the scheme in its existing form.

51 As it stands, the level of affordable housing has not been fully justified to the GLA and, therefore, does not comply with the London Plan policy 3A.10. Children’s play space

52 Policy 3D.13 of the London Plan sets out that “the Mayor will and the boroughs should ensure developments that include housing make provision for play and informal recreation, based on the expected child population generated by the scheme and an assessment of future needs.” Using the methodology within the Mayor’s supplementary planning guidance ‘Providing for Children and Young People’s Play and Informal Recreation’ it is anticipated that there will be approximately 122 children within the development. The guidance sets a benchmark of 10 sq.m. of useable child playspace to be provided per child, with under-5 child playspace provided on-site. As such the development should make provision for 1,220 sq.m. of playspace.

53 This development would provide a range of private, semi-private and public amenity space, incorporating designated play areas for children. The provision includes 6,744 sq.m. of private and secure back gardens to the houses suitable for toddlers’ play; 2027 sq.m. of semi-private or communal amenity space; and 4,385 sq.m. of publicly accessible amenity space, with 200 sq.m. of

1 Source: The London Housing Strategy- Draft for public consultation, May 2009, Appendix 2 (pg.155)

page 16 specially designated play spaces. Thus, the amenity space provision on site amounts to 13,156 sq.m. or 39% of the gross site area.

54 For older children, Barra Hall Park is situated within 5 minutes’ walk from the site. Play provision in the park consists of two seesaws, a wooden circular activity track, toddler and junior swings, multi-activity centres and a separate ball court. The level of provision fulfils the requirements of a ‘neighbourhood area of play’ (NEAP) under the ‘Six Acre Standards’ nationally adopted by local planning authorities. Hayes Cricket Ground is also within 5 minutes’ walk from the site.

55 As indicated in paragraph 22 above, there are several other equipped play areas within 15 minutes’ walk of the site. They include Lake Farm Country Park (also classified as a NEAP), Botwell Green, which is a Super Local Area of Play (SLAP); the Hayes Pool Open Space, which includes tennis courts and a bowling green in addition to the swimming pool; and Park Road Green (which is also a SLAP).

56 It is evident from the above that there is a generous local provision of play space for children of all ages both on and off site, and that the development would be compliant with London Plan policy 3D.13 and the Mayor’s SPG on ‘Children and Young People’s Play and Informal Recreation’. Inclusive design and access

57 London Plan policy 3A.5 aims to ensure that all new housing is built to ‘Lifetime Homes’ standards and ten percent of all new housing is designed or easily adaptable to wheelchair accessible standards.

58 Policy 4B.5 also requires all future development to meet the highest standards of accessibility and inclusion. It also requires design and access statements to be submitted with development proposals, to demonstrate how the principles of inclusive design, including the specific needs of disabled people, have been integrated into the proposed development and how inclusion will be maintained and managed.

59 The applicant has confirmed that all the dwellings will be constructed to ‘Lifetime Homes’ standards and would, therefore, be adaptable to the changing needs of individuals and families over time, as well as being suitable for occasional use by a wheelchair user or person with physical impairment. In addition, 19 of the units (approximately 10%) would be designed to be easily adaptable for residents that are permanent wheelchair users. Urban design and architectural quality

60 The applicant has attempted to integrate the proposed development into the surrounding area. The site has two public edges visible from, but not abutting onto MOL, at Bell House Field to the north and Church Lane to the East. The proposed building arrangement acknowledges these two public interfaces and places new buildings along those edges to improve visual quality and overlooking. The proposed approach is supported and in the case of the Church Lane, the new buildings would mirror the existing residential buildings on the opposite side of the road, which in turn would further help to frame the existing street.

61 However, further information on the treatment of the edge boundaries is required in terms of new and the proposed retention of existing planting. The scheme should maintain a level of visual and physical connection with the road so as not to make the new development feel overly separated from the existing street, particularly along Church Lane,

page 17 62 The application proposes a new public route through the site, which allows pedestrian and cycle connection from Church Lane to Bell House Field. This new route is well overlooked and integrated into the development. The route will increase permeability across the development and is supported.

63 The design and layout of routes and spaces around the site is well considered. The majority of routes and spaces are well overlooked by buildings. The applicant has ‘in-part’ adopted some of the principles of providing a shared surface across the site. The provision of car parking is provided in a variety of locations including; clustered on-street parking, private garage spaces and driveway spaces. This approach reduces the overall level of car clutter along the main movement routes and around the main public spaces. In addition, the road arrangements, materials and the incorporation of raised pedestrian tables across the site will reduce vehicle speeds across the site and encourage a more pedestrian-friendly environment. This design approach is welcomed.

64 The proposed pedestrian connection with Bell House Field is welcomed. The arrangement of the buildings around this new entry point will ensure overlooking of this route. The success of the route will be dependent on the materials, planting and upkeep and the applicant should provide further information on these.

65 The scheme includes a mix of public, communal and private spaces across the site. The arrangement of the proposed spaces offers a clear understanding of the differences between the public and private spaces, which is welcomed. The applicant has made a significant attempt to provide quality public spaces for residents that are well overlooked and well proportioned.

66 However, further information on the management of the proposed communal and public spaces should be provided. The public spaces should include dedicated play areas for children and the applicant should provide further detail demonstrating how the proposed public spaces accommodate the play requirements for children of different ages. Transport for London’s comments

67 The transport assessment should make reference to the Consultation Draft Replacement London Plan (October 2009), which now carries some weight in determining planning applications.

Site Layout & Access

68 Vehicular access to the site will be via a new access from Church Road, which borders the east of the site. Two further accesses for pedestrians and cyclists will be provided- one from Church Road at the northern end of the site, and one from the north-western edge of the site into Bell House Field.

Car Parking

69 A car parking provision of 231 spaces is proposed. Whilst TfL appreciates the relatively low PTAL of the site and that the number of parking spaces has been reduced since the previous application, TfL requests that the number of car parking spaces is reduced to a maximum of 1 space per unit in line with objectives to restrain car parking and avoid unnecessary car trips and achieve wider objectives relating to health, air quality and sustainability. The London Plan: consultation draft replacement (October 2009) states that parking provision should be provided at a ratio of less than one for all 1 and 2 bedroom units, TfL request that further guidance and controls are applied to allocate spaces to different unit sizes. TfL recommends that the applicant considers setting aside a number of spaces for car club use as part of the travel plan measures, this would assist in reducing the overall parking ratio and give those who did not wish or could not afford to own a car the option of using the car club.

page 18 70 Electric vehicle charging points are also necessary in line with standards set out in the London Plan: consultation draft replacement (October 2009) and the Mayor’s Electric Vehicle Delivery Plan (2009). This states that 20% of all residential spaces must be able to charge electric vehicles, with an additional 20% passive provision whereby additional spaces or points can be provided at the time of implementation or at some time in the future.

71 The proposal to have 10% parking spaces designated as disabled is welcomed by TfL. These should be designed in accordance with the Disability Discrimination Act standards.

72 TfL requests that a legal agreement is entered into to prevent future residents from obtaining local on-street parking permits, if a Controlled Parking Zone or similar is in place.

Pedestrians and cycling

Pedestrians

73 The transport assessment provides a good level of information on the pedestrian environment and identifies several deficiencies. TfL strongly recommends that the borough secure, through the s106 package, contributions towards the implementation of improvements to the pedestrian environment, including (but not restricted to) those recommendations contained within the transport assessment. Additional measures should include two-metre footway widths, appropriate lighting, tactile or colour delineation of the paths to segregate pedestrians and cyclists, or appropriate signage should be implemented in order to protect vulnerable users. These measures will ensure general conformity with London Plan policy 3C.21 Improving conditions for walking and consultation draft replacement London Plan policy 6.10 Walking.

Cycling

74 The transport assessment demonstrates that the site has a direct link to Church Road, which is designated as “routes on quieter roads recommended by cyclists”, and access to other cycle routes serving a range of destinations.

Cycle parking

75 The provision of 287 cycle parking spaces is welcomed as this meets TfL’s cycle parking standards for residential units. However, additional visitor cycle parking spaces should be provided externally, in a visible and convenient location close to the building entrances. TfL also recommends that CCTV is provided in all cycle storage areas as an additional security measure. These measures will ensure general conformity with London Plan policy 3C.21 Improving conditions for cycling and consultation draft replacement London Plan policy 6.9 Cycling.

Public transport

76 TfL considers that existing public transport capacity is sufficient to meet demand created by this development in accordance with London Plan policy 3C.2 Matching development to transport capacity and consultation draft replacement London Plan policy 6.3 Assessing transport capacity.

77 However, as there will be an increase in bus use as a result of this development, TfL requests that the applicant makes a contribution towards upgrading bus stops in the vicinity of the site to meet TfL bus stop accessibility standards. This would include the bus stop on Church Road identified in the audit in Appendix L of the transport assessment. TfL has identified a further five bus stops within a 400m radius of the site which are in need of accessibility upgrades. TfL requests a total contribution of £65,000 towards this work, in line with London Policy 3C.20 Improving

page 19 conditions for buses and consultation draft replacement London Plan policy 6.7 Buses, bus transits, trams.

Trip distribution and highway impacts

78 Trip distribution has been established based on traffic survey results undertaken in 2007, in addition to 2001 Census data. TfL accepts that the methodology for establishing the proportion of trips with the use of Census data is adequate. However, use of the traffic survey count data for assigning both vehicular and non vehicular trips is unacceptable, as the existing site had a different land use with a very different travel pattern.

79 The transport assessment states that the Botwell Lane/Church Lane mini roundabout would be operating close to capacity and that the traffic generated from the proposed development may need to be reviewed by the borough working with the developer and others in the vicinity to contribute towards improvements.

Construction and servicing

80 A construction logistics plan and a delivery and servicing plan should be provided to minimise the impact of vehicles on the road network.

81 It is satisfactory for these documents to be secured by condition to satisfy London Plan policy 3C.25 Freight strategy and consultation draft replacement London Plan policy 6.14 Freight.

Travel plan

82 The travel plan submitted is comprehensive with appropriate objectives, targets, measures, monitoring programme and management plan. Overall, the submitted travel plan is considered to be compliant with London Plan policy 3C.2 Matching development to transport capacity and the Consultation Draft Replacement London Plan policy 6.3 Assessing transport capacity.

Traffic Management Act

83 Should this application be granted planning permission, the developer and their representatives are reminded that this does not discharge the requirements under the Traffic Management Act 2004. Formal notifications and approval may be needed for both the permanent highway scheme and any temporary highway works required during the construction phase of the development.

Summary

84 In summary, TfL requires further improvements to the pedestrian environment, a bus stop contribution to be secured in the s106 agreement, the provision of visitor cycle parking, and for a construction logistics plan and a delivery and servicing plan to be secured by condition. An introduction of parking controls, a reduction in car parking space, and a commitment to supplying electric vehicle charging points are also required.

Climate change mitigation

85 The London Plan climate change policies as set out in chapter 4A collectively require developments to make the fullest contribution to tackling climate change by minimising carbon dioxide emissions, adopting sustainable design and construction measures, prioritising decentralised energy supply, and incorporating renewable energy technologies with a target of

page 20 20% carbon reductions from on-site renewable energy. The policies set out ways in which developers must address mitigation of and adaptation to the effects of climate change.

Energy

86 Policies 4A.1 to 4A.8 of the London Plan focus on how to mitigate climate change, and the carbon dioxide reduction targets that are necessary across London to achieve it.

Be Lean

Baseline emissions (policy 4A.4)

87 The applicant has calculated baseline carbon dioxide emissions on a whole-energy basis to be 450 tonnes per annum, using the results from Building Regulations approved software.

88 For clarity, the applicant should provide the modelling output sheets that provide the basis for the baseline estimate for each dwelling type.

Energy efficiency standards (policy 4A.3)

89 A range of energy efficiency measures are committed to, including heat recovery, better than building regulation Part L requirements for building envelope performance such as U-values and air tightness, energy efficient lighting. These measures would reduce the baseline carbon dioxide emissions by 10%.

Be Clean

District heating (policies 4A.5 and 4A.6)

90 Communal heating is not proposed for any parts of the development. The applicant has found no existing or planned system to which the development could be linked. The GLA energy team is also not aware of any such system.

Combined heat and power (policy 4A.6)

91 It is acknowledged that the type of development is not suitable for combined heat and power.

Cooling (policy 4A.6)

92 The applicant should clarify if there would be a need for active cooling and how this would be provided. For those spaces where cooling is not required, the applicant needs to describe the measures proposed to ensure the occupants’ comfort in the summer season and to avoid unacceptable overheating levels, particularly for any south-facing single aspect units.

Be Green

Renewable energy technologies (policy 4A.7)

93 The proposals include solar thermal panels for each dwelling individually. Considering the height of the buildings these is an acceptable approach. It is proposed that houses would have 4.2 sq.m. of panels each and that flats would have 2.1 sq.m. each that would reduce the carbon dioxide emissions by a further 14% over and above the reductions due to energy efficient design.

page 21 94 As such the proposals fails to reach the 20% reduction target.

95 It is acknowledged that there may not be potential for more solar thermal panels, however, there may be potential for also including photovoltaic panels on the roof.

96 In relation to photovoltaic panels the applicant should provide roof plans showing available space for photovoltaic panels, as well as pointing out why the other areas are not available for this application. The applicant should endeavour to maximise the carbon dioxide reductions through the use of renewable technologies.

Overall acceptability

97 The energy hierarchy in policy 4A.1 has broadly been followed. Sufficient information has been provided to understand the proposals as a whole and to verify carbon dioxide savings in principle. However, further information is required to make a full assessment of the application.

98 The proposals are broadly acceptable in principle, subject to the submission of further information and other significant revisions. Climate change adaptation

99 Developments are required to be adaptable to the climate they will face over their lifetime and address the five principles set out in policy 4A.9 of the London Plan. These are: to minimise overheating and contribution to heat island effects; minimise solar gain in summer; contribute to flood risk reductions, including the application of sustainable drainage principles; minimise water use; and protect and enhance green infrastructure. Specific policies cover overheating, living roofs and walls, and water conservation. Chapter 5 of the Consultation Draft Replacement London Plan also considers climate change adaptation, specifically in policies 5.9 to policy 5.15.

100 The relevant matters have been comprehensively covered in a Flood Risk & Drainage Assessment and a Sustainability & Energy Statement submitted as part of the application. Its provisions include a commitment to design and construct all dwellings to improved energy efficiency standards, above Building Regulations, and in line with the requirements of level 3 of the Code for Sustainable Homes as a minimum; and rainwater harvesting for irrigation and non-potable uses, in conjunction with the landscaped areas and permeable paved areas to reduce surface water run-off.

101 Hillingdon Council is urged to secure the proposed measures by appropriately worded planning conditions, to ensure full implementation in accordance with the submitted proposals. Local planning authority’s position

102 At the time of writing, it could not be ascertained when Council officers were likely to report this application to the local planning committee or what the officers’ recommendation was likely to be. However, the deadline for local consultation responses is 10 March 2010 and a decision is due by 13 April 2010, if the application is to be determined within the statutorily prescribed timescale. Legal considerations

103 Under the arrangements set out in Article 4 of the Town and Country Planning (Mayor of London) Order 2008 the Mayor is required to provide the local planning authority with a statement setting out whether he considers that the application complies with the London Plan, and his

page 22 reasons for taking that view. Unless notified otherwise by the Mayor, the Council must consult the Mayor again under Article 5 of the Order if it subsequently resolves to make a draft decision on the application, in order that the Mayor may decide whether to allow the draft decision to proceed unchanged, or direct the Council under Article 6 of the Order to refuse the application, or issue a direction under Article 7 of the Order that he is to act as the local planning authority for the purpose of determining the application and any connected application. There is no obligation at this present stage for the Mayor to indicate his intentions regarding a possible direction, and no such decision should be inferred from the Mayor’s statement and comments. Financial considerations

104 There are no financial considerations at this stage. Conclusion

105 London Plan policies on the loss of open space, the protection of community facilities, housing, children’s play space, urban design, inclusive access, parking/transport and climate change issues (particularly the energy provisions) are relevant to this application. The application complies with some of these policies but not with others, for the following reasons:

 Loss of open space: The proposal entails permanent loss of an open space and playing field, which London Plan policies seek to protect. The applicant has, however, provided a reasonable justification, primarily on grounds of high quality alternatives within an acceptable walking distance from the site.

 Loss of community facilities: The London Plan policy 3A.18 encourages the protection and enhancement of social infrastructure and community facilities to meet needs of London’s diverse communities. The applicant has carried out an audit of community venues to demonstrate availability of an appropriate range of such venues within an acceptable distance of the Les Ferdinand facility, which is due for demolition if permission is granted.

 Housing: Inadequate information has been provided on the tenure split, proportion, availability of a housing subsidy and management of the proposed affordable housing to enable a full assessment of the provision against the housing policies of the London Plan.

 Inclusive access: The commitment to construct all the proposed dwellings to Lifetime Homes standard and 10% to wheelchair accessible standards is welcome, and is likely to meet the requirements of policies 3A.5 and 4B.5 of the London Plan.

 Urban design: The design and architectural quality of the scheme is broadly acceptable, but a relatively small proportion of the dwellings do not meet the minimum space standards provided in the Mayor’s Draft Replacement London Plan and the London Housing Design Guide. Further clarification is required on the management of the proposed communal and public spaces, together with details to demonstrate how the public spaces would accommodate the play requirements for children of different ages.

 Transport: As Transport for London has indicated elsewhere in this report, additional works, information, restrictions and financial contributions need to be secured to ensure full compliance with the transport policies of the London Plan and the Consultation Draft Replacement London Plan.

page 23  Energy: The proposal fails to achieve the London Plan target of 20% reduction in carbon dioxide emissions from enable energy sources. Further investigations and information are required to justify and ensure robustness of the submitted energy strategy.

106 Whilst the application is broadly acceptable in strategic planning terms, on balance, it does not fully comply with the London Plan.

107 The following changes might, however, remedy the above-mentioned deficiencies, and could possibly lead to the application becoming compliant with the London Plan:

 Housing: The applicant should provide full details of the split between social rented and any intermediate accommodation within the affordable housing provision; identify any registered social landlord involved; provide an explanation as to whether the affordable housing offer includes a public subsidy and if not, the reasons for a lack of subsidy; and evidence of any written agreement between Barratt Southern Counties and the Council on the proposed level of affordable housing.

 Urban design: The applicant should endeavour to make the necessary revisions to ensure that all dwellings meet the minimum space standards provided in the Mayor’s Draft Replacement London Plan and the London Housing Design Guide, as indicated in paragraphs 38 and 39 above. Further information should be provided on the management of the proposed communal and public spaces, together with details demonstrating how the proposed public spaces would accommodate the play requirements for children of different ages

 Transport: The applicant should fully address the matters raised by Transport for London in paragraphs 67-84 of this report prior to any future referral of this application back to the Mayor.

 Energy: The applicant should also address the energy issues identified in paragraphs 87-98 of this report, including the submission of modelling output sheets on which the baseline estimate for each dwelling type is based, the cooling requirements and how they would be met; and the provision pf roof plans or other justification for the shortfall in meeting the Mayor’s renewable energy target.

for further information, contact Planning Decisions Unit: Colin Wilson, Senior Manager - Planning Decisions 020 7983 4783 email [email protected] Justin Carr, Strategic Planning Manager (Development Decisions) 020 7983 4895 email [email protected] David Blankson-Hemans, Senior Strategic Planner (Case Officer) 020 7983 4268 email [email protected]

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