planning report D&P/2436f/01 5 February 2018 Dukes Meadows, Dan Mason Drive, in the Borough of planning application no. P/2017/4957

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

The proposal Partial redevelopment of the Dukes Meadows playing fields for enhanced sports and recreational facilities and public realm River frontage improvements.

The applicant The applicant is London Borough of Hounslow and the architect is Space and Place.

Strategic issues summary

Metropolitan Open land: The entire site lies within MOL. The proposal is not inappropriate development on MOL as comprises the provision of appropriate facilities for outdoor sport and recreation. Further, the majority of development takes place within previously developed land and preserves the openness of the MOL, thus meeting the NPPF exception test. The proposal therefore accords with London Plan Policy 7.17, draft London Plan Policy G3, and the NPPF, and GLA officers conclude that there will be no harm caused to the MOL. The proposed rugby groundsman’s dwelling is not considered to be inappropriate development provided it is used exclusively for that purpose. (paragraphs 18 to 29).

Sports facilities and community use: A detailed community use agreement for affordable and accessible usage of the sports facilities should be secured by the Council (paragraphs 30 to 32). Urban design, climate change and transport concerns must also be addressed.

Recommendation That Hounslow Council be advised that whilst the principle of development is acceptable, the application does not comply with the London Plan and draft London Plan, for the reasons set out in paragraph 46 of this report; but that the possible remedies set out in that paragraph could address these deficiencies. The application does not need to be referred back to the Mayor if the Council resolves to refuse permission, but it must be referred back if the Council resolves to grant permission.

page 1 Context

1 On 6 December 2017 the Mayor of London received documents from Hounslow Council notifying him of a planning application of potential strategic importance to develop the above site for the above uses. The referral documents were received complete on 27 December 2017. Under the provisions of The Town & Country Planning (Mayor of London) Order 2008 the Mayor must 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.

2 The application is referable under Category 3D of the Schedule to the Order 2008: “Development – (a) on land allocated as Green Belt or Metropolitan Open Land in the development plan, in proposals for such a plan, or in proposals for the alteration or replacement of such a plan; and (b) which would involve the construction of a building with a floor space of more than 1,000 square metres or a material change in the use of such building.”

3 Once Hounslow 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 or allow the Council to determine it itself, unless otherwise advised. In this instance if the Council resolves to refuse permission it need not refer the application back to the Mayor.

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

5 Dukes Meadows is located within Metropolitan Open Land, south of Chiswick and comprises approximately 75 hectares of public open space and playing fields in the ownership of and administered by Hounslow Council. The site is landscaped and distinguished by its Thames side setting, and falls within Flood Zones 1 and 2. Dukes Meadows riverside stretches from the fringes of Chiswick village and Edensor Gardens to the north and and The Great Chertsey Road to the west.

The application site: Source: applicant’s design and access statement

6 To the east of Dukes Meadows is Chiswick Bridge, and the western and northern site boundary comprise the Great Chertsey Road (A3216) which connects to the A4 at the Hogarth roundabout. The site is bisected north and south by Barnes Bridge and the elevated railway line which runs to Waterloo Station in the east. The northern section is mainly occupied by Kings House Sports Ground and Chiswick Cricket Club ground, and contains the paddling pool and play areas. The other main users of this part of the site are Riverside Tennis Club and Emmanuel Boathouse. The southern part is allocated for leisure use in the Hounslow Local Plan 2015. The allocation is for

page 2 ‘enhancement of sporting facilities with appropriate protection of the openness of the MOL. Open air recreational and relevant buildings to create a hub for sporting activity’. This section is more formal sporting use which is open to the public. There are rugby, football and a hockey pitch, used by different clubs and available for public hire. There are two rowing clubs – Tideway Scullers and Thames Tradesmen, and the Dukes Meadows Golf and Tennis Centre.

7 North and west of Dukes Meadows comprises inter war and post war housing development along Great Chertsey Road and Staveley Gardens respectively before returning to earlier Victorian development along Burlington Lane heading towards Chiswick village centre, the Hogarth Roundabout and Great West Road. To the south lies Mortlake village with many fine 18th century listed houses on the riverside and High Street and by the redundant Mortlake Brewery site fronting the Thames. The application site itself does not include any heritage assets or listed buildings, however the approaches to the park comprises Barnes and Chiswick bridges, both of which are Grade II listed buildings. The two Conservation Areas of Barnes Green and Mortlake (both of which are within the London Borough of Richmond-upon-Thames) are on the opposite side of the River.

8 The site is bound by the A316 Great Chertsey Road (part of Transport for London Road Network), Dan Mason Drive, the River Thames, and allotment gardens. Barnes Bridge National Rail Station is approximately 500 metres from the site and three bus routes stop at the station. There are also stops on Great Chertsey Road served by one route. However, due to the frequency of services and the relative distance of the bus stops, the site records a very poor public transport accessibility level (PTAL) of 1b, on a scale of 1-6, where 1 is lowest and 6 is highest.

Details of the proposal

9 The proposed partial redevelopment of the Dukes Meadows playing fields comprises two elements; the improvements to sports facilities on Dukes Meadows land close to the railway; and public realm improvements to the River frontage along Dan Mason Drive and around ‘The Promenade’ on the opposite side of the railway.

10 Details of the planning application include: • demolition of various structures within the curtilage of the rugby clubhouse together with the demolition of the existing rowing clubhouse and the demolition of the redundant public toilets on The Promenade; • retention and accessibility improvements to the existing bandstand; • erection of a new single storey football pavilion on the playing fields comprising team changing rooms and social /coaching spaces; • extension to the existing rugby club comprising additional team changing rooms for both rugby and hockey together with an attendant first floor (1-bedroom flat) rugby groundsman's dwelling; • erection of a replacement two storey rowing clubhouse comprising new boat storage, changing and social spaces together with a ground floor cafe; • new replacement public toilets on The Promenade; • associated external works comprising reconfigured natural grass pitches for football and rugby, floodlit and fenced artificial grass pitches for football and floodlit, partially enclosed, rugby artificial grass pitch, and • ancillary car parking and access improvements, wider public realm works within Dukes Meadows along Dan Mason Drive, The Promenade, Riverside Drive & Promenade Approach Road; highways and access improvements, cycle and car parking, signage, lighting, hard and soft landscape works.

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Proposed Site Plan: Source – applicant’s design and access statement.

11 The change in floor areas across the site are as follows:

Case history

12 The relevant planning history of the site dates to 1992, and comprises of a number of applications on different plots of the site. • The Rugby Club – application references P/2011/1498 & P/2013/4414 - approved for the extension to the existing clubhouse for additional facilities, including extra changing rooms and a function room. • – planning permission for a single storey detached boathouse was granted under reference P/2009/2577. • Emanuel Boathouse – planning permission was granted for the first-floor extension of the existing boathouse. • King’s House School – the School’s appeal for the construction of floodlit 3G artificial grass pitch with fencing and two floodlit artificial grass tennis courts was allowed on 17 July 2014. 13 A planning application for Dukes Meadows Golf Course and Tennis Club (located at the bottom end of the site), was refused on 2 November 2017 (LPA Ref: P/2017/1223). The application proposed a tennis hall to replace existing air dome and was refused by Hounslow Council on the following grounds:

page 4 • Very special circumstances had not been demonstrated to allow permission and the S.106 obligations had not been delivered, and • That enforcement action be taken for the removal of the existing air dome at Dukes Meadows Tennis Centre, Dan Mason Drive, W4. 14 This application was referred to the Mayor and at stage 1 consultation, the Mayor considered the application and the proposal did not comply with the London Plan, with fundamental concerns raised in relation to the principle of land use and inappropriate development in MOL. (GLA ref: D&P/2436e/01, dated 28 September 2017). Strategic planning issues and relevant policies and guidance

15 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 2015 Hounslow Local Plan and the 2016 London Plan.

16 The following are relevant material considerations: • The National Planning Policy Framework and National Planning Practice Guidance, and • Draft London Plan (2017). • Hounslow Playing Pitch Strategy (2016 – 2020).

17 The relevant issues and corresponding policies are as follows: • Sports facilities London Plan; • Metropolitan Open Land London Plan; • Community use London Plan; • Urban design London Plan; • Access London Plan; Accessible London: achieving an inclusive environment; • Sustainable development London Plan; Sustainable Design and Construction SPG; Mayor’ Climate Change Adaptation Strategy; Mayor’s Climate Change and Energy Strategy; Mayor’s Water Strategy; • Transport London Plan; the Draft Mayor’s Transport Strategy;

Metropolitan Open Land (MOL)

18 London Plan Policy 7.17 affords Metropolitan Open Land (MOL) the strongest possible protection, whilst Policy G3 of the draft London Plan states that MOL should be protected from inappropriate development and proposals that harm MOL should be refused. Both policies state that national Green Belt policies, set out within the NPPF, apply to MOL and therefore MOL is offered the same protection as Green Belt.

19 Chapter 9 of the NPPF is entitled ‘protecting Green Belt land’ and applies equally to MOL. Paragraph 79 states that the fundamental characteristic of the Green Belt is its openness and its permanence and a key purpose of the Green Belt is to prevent encroachment that would reduce green space, as per paragraph 80.

20 Paragraph 87 of the NPPF states that inappropriate development is, by definition, harmful to MOL and should not be approved except in ‘very special circumstances’. According to paragraph 88 of the NPPF, when determining applications, LPAs should ensure that substantial weight is given to any harm to the Green Belt; ‘very special circumstances’ will not exist unless the potential harm to MOL by reason of inappropriateness, or any other harm, is clearly outweighed by other considerations.

page 5 21 The construction of new buildings should be regarded as inappropriate development, as set out in paragraph 89, with the following limited exceptions:

• Provision of appropriate facilities for outdoor sport, outdoor recreation and for cemeteries;

• The extension or alteration of a building provided that it does not result in disproportionate additions over and above the size of the original building;

• The replacement of a building, provided the new building is the same use and not materially larger than the one it replaces;

• Limiting infilling in villages, and limited affordable housing for local community needs;

• Limited infilling or the partial or complete redevelopment of previously development sites (Brownfield land), whether redundant or in continuing use (excluding temporary buildings), which would not have a greater impact on the openness of the Green Belt and the purpose of including land within it than the existing development.

22 Paragraph 90 of the NPPF lists a limited number of development types which are not regarded as inappropriate development, provided they preserve the openness of the Green Belt, these are: mineral extraction; engineering operations; local transport infrastructure; reuse of buildings; and development brought forward under a Community Right to Build Order.

Thames Tradesmen’s Rowing Club (TTRC) Boathouse and Rugby and Hockey Club

23 The applicant proposes to demolish and reconstruct the existing boathouse within the footprint of the existing building. In addition, the applicant proposes a 431 sq.m. extension to the existing rugby and hockey club house.

24 The redevelopment of both the boathouse and rugby and hockey club would take place within previously developed areas of the site. The boathouse would be constructed within the footprint of the existing building, and results in a slight reduction in the building’s footprint; however it would be 3.3 metres higher than the existing building. The extension of the rugby and hockey club encroaches onto land currently used for informal storage and outbuildings associated with the rugby club, which is to be demolished. Both elements of the development result in the enhancement of existing outdoor sport and recreation facilities, and would not adversely impact on the openness of MOL. The extent of the proposed development area thus constitutes ‘limited infilling’ as defined by paragraph 89 of the NPPF, and is acceptable in the context of London Plan Policy 7.17 and Policy G3 of the draft London Plan.

25 The Council and applicant should note that the proposed first floor, one-bedroom flat, proposed to be used as a rugby groundsman’s dwelling would be considered inappropriate development unless used exclusively for that purpose. This must be secured through an appropriate condition in perpetuity.

Football pavilion

26 The applicant proposes the construction of a new single storey 941 sq.m. football pavilion comprising team changing rooms and coaching spaces. The applicant has submitted CGI visuals that demonstrate that the football pavilion has been sited to have minimal impact on the openness of MOL. Whilst the pavilion would be constructed on undeveloped Green Belt given that the use of the pavilion would be associated with the existing football pitches it is considered to constitute the

page 6 ‘provision of appropriate facilities for outdoor sport’ as defined by paragraph 89 of the NPPF, and is acceptable in the context of London Plan Policy 7.17 and Policy G3 of the draft London Plan.

Very special circumstances (VSC)

27 The applicant considers the proposed elements of the application are either appropriate development, or covered by the GPDO. However, the applicant has also set out the following very special circumstances, to be applied should the LPA/GLA disagree with its assessment that all the development is appropriate. In this instance, GLA officers have determined that the boathouse and the clubhouse are appropriate, therefore, no very special circumstances assessment is required to justify those elements of the development. However, for completeness, the applicants VSC assessment is summarised below:

• Sport and facilities need: meeting identified quantitative and qualitative deficiencies in the Borough’s provision of sports facilities set out in the LPA’s assessments of its existing services; • Policy support: in the NPPF, the adopted ‘Development Plan’ and elsewhere for sport and recreation in achieving sustainable communities, in particular the NPPF’s three dimensions (‘economic’, ‘social’ and ‘environmental’) to achieving sustainable development; • Site allocation: the site’s allocation as a ‘regional hub’ for sports and water-borne recreation in the Hounslow Local Plan (Site Reference 01); • Conservation of heritage assets: the replacement of utilitarian structures with more sympathetic designs and restoration of undesignated heritage assets, enhancing public access to the River frontage and restore lost vistas to the Thames; and • Sustainability benefits - a better energy efficiency in the replacement of the Boathouse by modern structure. • General Permitted Development Order (GPDO): The applicant has stated that some of the works might be covered by Permitted Development rights under the GDPO, and therefore do not require express planning permission.

Conclusion on principle of development

28 The proposals for the reprovision of appropriate facilities for outdoor sports and recreational facilities on Duke’s Meadows are supported in terms of land use, as they meet the exception test in paragraph 89 of the NPPF and thus are not inappropriate development on MOL. In addition, CGI visuals submitted by the applicant demonstrate that impact on openness of the MOL in the longer- term views is limited, and that the increase in built form is minimal, with materials blending well with the existing environment. GLA officers therefore conclude that there will be no harm caused to the MOL.

29 The proposal therefore, accords with London Plan Policy 7.17, draft London Plan Policy G3, and the NPPF. The proposed rugby groundsman’s dwelling would be considered inappropriate development unless used exclusively for that purpose. This should therefore be secured through an appropriate condition.

page 7 Sports facilities and community use

30 Policy S5 of the draft London Plan ‘Sports and recreation facilities’ and London Plan Policy 3.19 ‘Sports facilities’ set out that those proposals that increase or enhance the provision of sports and recreation facilities will be supported; whereas those that result in a net loss of sports and recreation facilities, including playing fields should be resisted.

31 The playing pitches the site can accommodate will be reduced by 3 adult football grass pitches and 1 rugby grass pitch. However, by providing 2 new artificial grass pitches, which are fully FA compliant with floodlighting, the proposal will substantially increase the overall number of games, training and sporting activities that the site will be able to accommodate, from a current site total of 72 hours across 9 pitches per week to over 208 hours capacity with 6 adult football pitches and 2 artificial grass pitches. This is not accounting for the Rugby AGP provision which will increase capacity for rugby by a minimum of 2,000 additional hours of use. In addition, all existing users of the playing field land will be adequately accommodated and the opportunities and the usage of the site by all the resident clubs and hirers will be enhanced by the new facilities.

32 In satisfying Policy S5 of the draft London Plan and Policy 3.19 of the London Plan, the applicant has demonstrated that there would not be a loss of sports facilities, and the improvements to sports and recreation use is strongly supported. However, active engagement with relevant sports national governing bodies such as the FA, RFU and Sport England; and local sports communities, is highly recommended. A detailed community use agreement for affordable and accessible usage of the sports facilities must be secured by the Council. It is noted that the initial assessment of the proposal by Sport England is supportive. Urban design

33 There are no strategic design concerns. The Council should secure key details of materials to be used to ensure the best possible build quality is delivered in the context of the MOL. In accordance with Policy D11 of the draft London Plan, the Council has agreed to secure an Informative requiring the submission of a fire statement, produced by a third party suitable qualified assessor. Inclusive design

34 Policy D3 ‘Inclusive design’ of the draft London Plan and Policy 7.2 of the London Plan seek to ensure that proposals achieve the highest standards of accessible and inclusive design (not just the minimum). The new clubhouses, the improved sports facilities and the new toilets, will offer a fully inclusive access and sports programme to all users. Sixteen controlled disabled parking spaces are located close to the main building entrances (currently there is none). The approach to inclusive design is supported and must be secured through condition. Climate change Energy

35 An on-site reduction of 11 tonnes of CO2 per year in regulated emissions compared to a 2013 Building Regulations compliant development is expected for the proposed non-domestic buildings, equivalent to an overall saving of 2%. The carbon dioxide savings fall short of the targets within Policy 5.2 of the London Plan and Policy S12 of the draft London Plan. The applicant should consider the scope for additional measures aimed at achieving further carbon reductions. In addition, all other comments regarding overheating, cooling demand, photovoltaic panels and BRUKL files should be addressed before compliance with energy policies of the draft London Plan

page 8 and London Plan can be verified. Full details of the issues have been provided directly to the applicant and Council.

Flood risk and drainage

36 The Environment Agency’s indicative flood map shows the site lies within Flood Zone 1 with an ingress of Flood Zone 2 on the north-eastern boundary. The site is generally at low risk of flooding and benefits from the Thames flood defence. The proposals comply with Policy SI12 ‘Flood risk management’ of the draft London Plan. There will be an increase in surface water runoff as a result of the development, and this will be managed through a suitable surface water network and discharge to the watercourse will be controlled through a flow control device. Whilst draining to the tidal Thames is supported, surface water should be managed through green sustainable drainage measures rather than grey features and the applicant should consider combining surface water drainage with rainwater harvesting. A planning condition to secure this must be applied to any planning permission to ensure compliance with Policy SI13 ‘Sustainable drainage’ of the draft London Plan.

Transport

37 The applicant should clarify the trip generation for the existing scenario and undertake a modal share assessment to allow a robust assessment of the likely impact from the proposal, in line with Policy T4 of the draft London Plan and Policy 6.3 of the London Plan.

38 It is proposed to provide 238 car parking spaces (an uplift of 104 spaces) to accommodate what is projected to be the maximum requirement at the weekend peak based on the existing demand. Whilst there are no London Plan standards for this type of use, the applicant should justify the high level of provision. Parking for coaches and mini buses should also be clarified together with drop off/pick up arrangements at each part of the facility. The number and location of electric vehicle charging points should be confirmed and demonstrated as making adequate provision in the light of policies and targets in the draft Mayor’s Transport Strategy, Policy T6 of the draft London Plan and Policy 6.13 of the London Plan. An improved car parking management plan is also required which should include measures to prevent parking elsewhere than in designated spaces.

39 The proposal includes improvements to pedestrian access within the site and measures to enhance the safety of the shared route under the railway and the vehicle and cycle access routes. These are welcomed. However, further detail is required of these and they should be secured by condition or legal agreement to make sure the improvements are delivered to support the increased sports use of the site and active travel. 29 cycle spaces will be provided near the clubhouses and boathouses with additional ‘casual’ provision elsewhere. However, it should be demonstrated that adequate provision is being made to encourage cycling as a mode of travel as set out in the draft Mayor’s Transport Strategy, Policy T5 of the draft London Plan and Policy 6.8 of the London Plan.

40 The impact on local public transport services cannot be established until a modal share assessment has been provided. The increased use of the site at times when public transport is less good, will in particular needs careful consideration.

41 The framework travel plan requires further improvements regarding targets and measures to achieve a shift to sustainable modes of transport by staff, users and spectators. The final plan should be appropriately secured, in line with Policy T4 of the draft London Plan and Policy 6.3 of the London Plan. A construction traffic management plan (CTMP) and construction logistics plan (CLP), should be produced in accordance with TfL guidance, and secured by condition. This is required to accord with Policy T7 of the draft London Plan and Policy 6.14 of the London Plan.

42 In summary, the proposal does not currently comply with transport policies of the London Plan and draft London Plan. It is not clear that this development as it stands will promote active

page 9 and sustainable travel and reduce car trips. Further work is required in respect of trip generation and modal share, and on the car parking management plan and the travel plan. In addition, details are needed on car parking including electric vehicle charging point provisions; cycle parking; which should then be appropriately secured; construction arrangements should also be conditioned. An s106 obligation or condition is required to ensure that the pedestrian, cycle and vehicle access improvements are delivered.

Local planning authority’s position

43 The Council’s planning officers have confirmed that they support the proposals and are recommending approval to their planning committee on 8 February 2018. Legal considerations

44 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 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. 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

45 There are no financial considerations at this stage. Conclusion

46 London Plan and draft London Plan policies on Metropolitan Open Land, sports facilities and community use, urban and inclusive design, climate change and transport are the key strategic issues relevant to this planning application. Whilst acceptable in principle, the application does not comply with the London Plan and draft London Plan; the following changes might lead to the application becoming compliant:

• Metropolitan Open land: The entire site lies within MOL. The proposal is not inappropriate development on MOL as comprises the provision of appropriate facilities for outdoor sport and recreation. Further, the majority of development takes place within previously developed land and preserves the openness of the MOL, thus meeting the NPPF exception test. The proposal therefore, accords with London Plan Policy 7.17, draft London Plan Policy G3, and the NPPF, and GLA officers conclude that there will be no harm caused to the MOL. The proposed rugby groundsman’s dwelling is not considered to be inappropriate development provided it is used exclusively for that purpose. • Sports facilities and community use: A detailed community use agreement for affordable and accessible usage of the sports facilities should be secured by the Council. • Urban and inclusive design: There are no strategic design concerns. The approach to inclusive design is supported and should be secured.

page 10 • Climate change: The carbon savings fall short of the targets within Policy 5.2 of the London Plan and Policy S12 of the draft London Plan. Additional measures to achieve further carbon reductions and details regarding overheating, cooling demand, photovoltaic panels and BRUKL files, should be submitted. A drainage strategy that accords with policies of the London Plan and draft London Plan must be secured. • Transport: A robust mode share assessment must be submitted. Given the nature of the site active travel measures must be strengthened. Further work is required regarding trip generation, car parking management plan and the travel plan, and details on cycle parking and construction arrangements must be submitted. An s106 obligation or condition is required to ensure that the pedestrian, cycle and vehicle access improvements are delivered.

For further information contact GLA Planning, Development & Projects Team: Juliemma McLoughlin, Assistant Director - Planning 020 7983 4271 email: [email protected] Sarah Considine, Senior Manager - Development & Projects 020 7983 5751 email: [email protected] Shelley Gould, Strategic Planning Manager – Development Decisions 020 7983 4803 email: [email protected] Tefera Tibebe, Case Officer 020 7983 4312 email: [email protected]

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