Planning Statement

Home , Canons Park, Canons Park tube station

Planning Statement

CBRE

March 2020

CANONS PARK STATION CAR PARK, HARROW, HA2 9SJ

Catalyst Housing Limited and Transport for London Planning Statement

March 2020

CONTENTS

1.0 Executive Summary ...... 2

2.0 Introduction ...... 5

3.0 Site and Surroundings ...... 7

4.0 Planning History ...... 11

5.0 Proposals ...... 13

6.0 Pre-application Advice and Consultation ...... 19

7.0 Planning Policy Overview ...... 29

8.0 Planning Assessment ...... 32

9.0 Planning Obligations and CIL ...... 46

10.0 Summary and Conclusion ...... 48

APPENDICES ......

Appendix A: Relevant Planning Policies ...... 50

CBRE | CANONS PARK STATION CAR PARK, HARROW, HA2 9SJ

1.0 Executive Summary

SITE

The site is within the London Borough of Harrow (hereafter referred to as ‘LBH’). It is located directly to the north of Canons Park London Underground Station, on Donnefield Avenue, and is currently used as a commuter car park serving Canons Park Underground Station. The proposals comprise the redevelopment of the existing commuter car park to deliver 118 affordable residential units along with a proportion of retained commuter car parking, TfL Cycle Hub (for public use), landscaping improvements and associated public realm.

AFFORDABLE HOUSING

The proposals make a significant contribution to Harrow’s affordable housing need, providing 118 units in an accessible and sustainable location, with a high-quality design that has been developed through extensive engagement with LBH, the Council’s Design Review Panel, key stakeholders and the local community.

All units are compliant with nationally described space standards and provide private amenity space.

HERITAGE

There are no listed buildings or assets on site. The site is adjacent to Canons Park, a Grade II Listed Park and Garden and designated Metropolitan Open Land, as well as the Canons

2 Park Estate Conservation Area, which is located to the north of the site and also covers the

northern portion of the site. The design embraces and complements the heritage setting of Page

the site, enlivening Donnefield Avenue and activating the entrance to Canons Park. RY

TOWNSCAPE EXECUTIVE SUMMA The site and its surroundings are visible from both the Canons Park Conservation Area and the listed park and garden. The high-quality architectural design is sympathetic to its historic setting, while also providing passive surveillance to the improved public realm, new community amenity space and pocket park, providing a positive contribution to the area.

ARCHITECTURE AND DESIGN

The design has evolved through extensive consultation with planning officers, the Council’s Design Review Panel and the Mayor’s Design Advocates (MDA’s), key stakeholders and community engagement. The proposals provide high-quality housing, cycle-parking and car parking, as well as considerable public realm improvements. The design is sympathetic and complementary to the historic context and adjacent Canons Park.

The form of three separate buildings, with a horizontal emphasis and largely brick appearance, is responsive to, and celebrates the, historic character of the area.

RESIDENTIAL AMENITY

The community amenity space and pocket park will be implemented and maintained for the enjoyment of residents and locals, as detailed in the Landscape and Public Realm Strategy (prepared by Townshend Landscape Architects).

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1.0 Executive Summary

These spaces will activate and enliven the public realm and approach to Canons Park, further enhanced by the play-on-the-way elements of the streetscape on Donnefield Avenue.

TRANSPORT

The proposals accord with the Mayor’s Healthy Streets Approach and the transport policies in the Draft London Plan (December 2019) in promoting a modal shift from private car use to more sustainable modes of transport, including walking and cycling.

In addition to some re-provided public car parking spaces, the proposal includes a TfL Cycle Hub for public use.

The residential development will be car-free, with the exception of blue badge parking, which will be provided at a policy compliant level of 3% active and 7% passive, based on the number of proposed residential units. The residential development will also benefit from a policy compliant level of cycle-parking.

A car club space will also be provided on-site for the benefit of residents along with the provision of electric car charging points.

The car park and the new TfL cycle hub will benefit from passive surveillance from the new residential units and will deliver safe, well-lit, well maintained assets for the station commuters to use.

3 WIDER SCHEME BENEFITS Page

Sustainability The proposals are in line with the modal shift emphasised in planning policy, away from private car use and towards more sustainable methods of transport, through the reduction

in car parking and the provision of the TfL cycle hub. EXECUTIVE SUMMARY

Public realm and connectivity to the park The proposals will activate the underutilised Donnefield Avenue and will provide an enhanced connection to the listed park.

Connectivity to station The site is in a well-connected area, sitting adjacent to the Canons Park Underground station, which is served by the Jubilee Line. The proposals will create a new community in the station area, providing high-quality residential units for future occupiers as well as a safe and inclusive environment for locals and commuters. The car parking and TfL cycle hub will deliver safe, well-lit and well-maintained spaces for commuters to use.

The proposals have been developed to ensure the protection of a designated Site of Importance for Nature Conservation (‘SINC’) which is located directly to the east of the site. Mitigation measures including consideration of the boundary treatment and complementary planting have been incorporated into the landscaping and public realm strategy to ensure the long-term integrity of the SINC.

IN SUMMARY

Overall, the proposals represent an exciting opportunity to redevelop this brownfield site and provide a significant contribution to Harrow’s affordable housing need, as well as securing key public realm improvements. This will be achieved through the high-quality

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1.0 Executive Summary

architectural design of the buildings and landscaped areas and the efficient and optimised use of the site to provide a high standard of residential accommodation and amenity, as well as public car and cycle parking.

The proposed development is consistent with the National, Regional and Local Planning Policy within the Development Plan relevant for this site. In accordance with the NPPF, the presumption in favour of sustainable development should be applied in full when considering this proposal.

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EXECUTIVE SUMMARY

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2.0 Introduction

This Planning Statement has been prepared by CBRE Ltd (‘CBRE’) on behalf of the applicants, Catalyst Housing Limited and Transport for London (‘the applicants’), in relation to an application for full planning permission made to the London Borough of Harrow (‘LB Harrow’ or ‘LBH’) in respect of the Canons Park Station Car Park, 229 Donnefield Avenue, Harrow, HA8 6RL, hereafter referred to as ‘the Site’.

The Site is 0.64ha and currently comprises a 162 space public car park owned by Transport for London (‘TfL’) and operated by NCP. The car park provides car parking for the adjacent Canons Park Underground Station. The Site benefits from a site allocation which identifies the Site as being appropriate for residential redevelopment alongside the retention of a proportion of commuter car parking.

The Site (along with two further sites in Harrow which are subject to separate planning applications) has been identified by TfL as a key opportunity to deliver housing in an accessible, sustainable brownfield location. Survey work undertaken by TfL identified that the sites would be suitable for a reduction in car parking. As part of the wider TfL portfolio, and as agreed with the Mayor, this Site has been identified as an opportunity to deliver high quality affordable housing and it will therefore deliver 100% affordable housing on site, providing a mix of London Affordable Rent and Shared Ownership properties in a mix of one, two and three bed properties.

This application seeks full planning permission for the following works: “Redevelopment of existing public car park to provide new residential accommodation (Use Class C3) and flexible ground floor space and a public car

5 park along with associated works”. Page

This document sets out the characteristics of the site and surrounding area; describes the consultation with stakeholders; and assesses the proposals in terms of relevant planning

policy, as set out in the National Planning Policy Framework (NPPF) (2019) and the INTRODUCTION Development Plan which, in this instance, comprises the London Plan (2016), Harrow Core Strategy (2012), Harrow Development Management Policies Local Plan (2013) and the Harrow Site Allocations Local Plan (2013). The planning policy assessment also refers to the policies in the Intend to Publish London Plan (2019), due to its advanced stage.

An Environmental Impact Assessment Screening Request was submitted to LBH in October 2019. It was confirmed by LBH that the proposed development on the site was not EIA development and therefore did not require an Environmental Statement.

This Planning Statement should be read in conjunction with the following set of supporting documents. The list of documents reflects the extensive pre-application engagement with Officers and was agreed as part of the Planning Performance Agreement (‘PPA’). The following documents are included:

 Completed Planning Application Form and Certificate B (CBRE, March 2020)  Planning Statement (CBRE, March 2020)  Community Infrastructure Levy (CIL) Additional Information Form (CBRE, March 2020)  Site Location Plan, Existing and Proposed Plans, Sections and Elevations (Karakusevic Carson Architects, March 2020)

 Design and Access Statement (Karakusevic Carson Architects, March 2020)  Landscape and Public Realm Strategy (Townshend Landscape Architects, March 2020)  Landscape plans (Townshend Landscape Architects, March 2020)

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2.0 Introduction

 Transport Assessment (including servicing and waste) (WSP, March 2020)  Framework Travel Plan (WSP, March 2020)  Noise and Vibration Assessment (ACCON, March 2020)  Statement of Community Involvement (Lowick, March 2020)  Historic Environment Assessment (Museum of London Archaeology, March 2020)  Heritage Statement (Museum of London Archaeology, March 2020)  Sustainability Statement (CBRE Environmental, March 2020)  Air Quality Assessment (ACCON, March 2020)  Daylight and Sunlight Assessment (impact on neighbouring properties report) (GIA, March 2020)

 Internal Daylight and Sunlight Assessment (GIA, March 2020)  Solar Glare Assessment (GIA, March 2020)  Sustainable Drainage (SuDS) Design Strategy (Price & Myers, March 2020)  Ecological Impact Assessment (Middlemarch, March 2020)  Pedestrian Level Microclimate Assessment (RWDI, March 2020)  Arboricultural Impact Assessment (Middlemarch, March 2020)

 Construction Environmental Management Plan (ULS, March 2020) Page

 Ground Investigation Report (GEA, March 2020)  Townscape and Visual Appraisal (LV, March 2020) INTRODUCTION Planning policy and guidance at all levels recommends early engagement and consultation with key stakeholders in the planning process as well as with the local community. Together with a series of consultation meetings with key stakeholders from the community, the applicant has been in detailed discussion with the Local Planning Authority (‘LPA’) under the abovementioned PPA to enable collaborative engagement. The proposals have been positively shaped through this engagement and this Statement provides a summary of this engagement.

The next section of this statement, Section 3, provides a description of the site and surrounds, and Section 4 sets out a summary of the relevant planning history. Section 5 describes the proposals and Section 6 provides a summary of the pre-application consultation that has informed the development of the scheme. Section 7 provides the planning policy context; Section 8 comprises an assessment of the proposals against the relevant planning policies and other material considerations; Section 9 sets out anticipated Section 106 Heads of Terms and CIL Contributions and Section 10 sets out the conclusion.

Overall, the proposed scheme accords with the adopted policy at the local, regional and national level providing high quality affordable homes on an allocated site within the LB Harrow, a Borough which has a significant need for affordable homes in order to meet and address the current shortfall. The proposals present a highly sustainable development in a brownfield, accessible location.

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3.0 Site and Surroundings

THE SITE

The Site is located directly to the north of Canons Park Station on Donnefield Avenue, within the London Borough of Harrow (hereafter referred to as ‘LBH’). The Site is currently used as a commuter car park serving Canons Park Underground Station. The Site covers an area of 0.64 hectares and comprises 162 existing car parking spaces.

The Site is linear and broadly rectangular, tapering to the south. Access to the Site is from Donnefield Avenue for both vehicles and pedestrians. To the north of the Site lies Canons Park which is a Grade II Listed Park and Garden. Donnefield Avenue borders the Site to the east. Donnefield Avenue is a residential road comprising mainly two and three storey buildings as well as the entrance Canons Park Activity Centre, directly opposite the Site.

To the south of the Site, immediately adjacent to the boundary, is an ambulance centre and beyond this is Canons Park station. A steep railway embankment which is a designated Site of Interest for Nature and Conservation (‘SINC’) borders the Site to the west, with the Jubilee Line running directly behind.

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S SITE AND SURROUNDING

Figure 1: Site Location Plan (Karakusevic Carson Architects)

The Site has a public transport accessibility level (‘PTAL’) of 3 (where the most accessible level is 6b) and is considered to have a good level of access to public transport. The Site can be accessed by both pedestrians and vehicles from Donnefield Avenue, to the east. The Jubilee line can be accessed via the adjacent Canons Park station (Zone 5) providing access into central London. Several bus routes are available along Whitchurch Lane including routes 79 1, 1862 and 3403.

1 Route runs from Alperton Sainsbury’s to Edgware Station 2 Route runs from Northwick Park Hospital Social Club to Brent Cross Shopping Centre 3 Route runs from Edgware Bus Station to Harrow Bus Station

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3.0 Site and Surroundings

The character of the surrounding area is predominantly low-rise residential buildings ranging between two-four storeys. Canons Park Close flats, at three storeys, are located opposite the site on Donnefield Avenue. Whitchurch Lane to the west is predominantly residential, with some ground floor retail units, and to the east is Canons Park Activity Centre and recreational space, Canons Park.

The Site is located within the Edgware and Burnt Oak Core Strategy Sub Area, which is identified as having capacity to make a significant contribution to housing growth, as well as comprising a number of important employment, leisure and heritage assets.

The Site has also been allocated for housing in the Harrow Council Site Allocations Local Plan (2013). Within the allocation it was recognised as suitable for a partial residential development with the retention of an appropriate amount of station car parking to meet demand for commuter parking. The allocation states that applications should be supported by evidence demonstrating the car parking demand to justify any reduction. This is provided within the Transport Assessment prepared by WSP.

The Site is located in close proximity to Canons Park, a Grade II Listed Park and Garden and designated Metropolitan Open Land.

Adjacent to the railway embankment at the Site’s western boundary there is a further area of green space which is designated as a Site of Importance for Nature Conservation (‘SINC’) this area is inaccessible and is located outside the red line boundary. The proposals do not include any works or interventions to this SINC.

8 The northern section of the Site is located within Canons Park Estate Conservation Area, coloured red on the diagram below. Page

SITE AND SURROUNDING

The site sits within three of the RAF Northolt Safeguarding Zones:  RAF Northolt Blue Safeguarding Zones, whereby consultation is required for building, structure or works exceeding 91.4m in height above ground level;

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3.0 Site and Surroundings

 RAF Northolt Black Dotted Line (Plan B), whereby consultation is required for all applications involving a refuse tip, a reservoir, a sewage disposal works, a nature reserve or a bird sanctuary; and

 RAF Northolt Black Line, whereby consultation is required for developments that involve flying activities including gliding, micro-light aircraft and hang-gliding sites.

The site is located within Flood Zone 1 (low probability zone which is defined as having a less that 0.1% probability each year). The site is considered to be a low risk of groundwater and surface water within the London Borough of Harrow Surface Water Management Plan.

In summary, the site is subject to the following planning designations:  Canons Park Estate Conservation Area;  Adjacent to a Site of Importance for Nature Conservation;  Edgware and Burnt Oak Core Strategy;  RAF Northolt Safeguarding Zone; and  Harrow Council Site Allocation (H17).

SURROUNDING AREA

The character of the surrounding area is predominately residential. To the west of the station lies a row of two to three storey buildings comprising a mix of uses, including retail

and restaurant units on the ground floor and residential above. To the north, east and south

is Canons Park and the Canons Park Activity Centre. Page

S To the south of Whitchurch Lane is a large industrial estate, off Honeypot Lane. This area comprises a mixture of low rise, light industrial units and warehouses. Further to the south lies a residential development delivered by St Edward (Berkeley Group), Stanmore Place, comprising of just under 800 units. The development provides a range of flats and houses, SITE AND SURROUNDING with buildings ranging up to 6 storeys which was completed in 2007.

The surrounding area is generally comprised of two to three storey residential dwellings with a number of four and six storey apartment buildings located approximately 400m to the south of the site, on Howard Road.

Canons Park has been designated as Metropolitan Open Land (‘MOL’) and is located within the Canons Park Estate Conservation Area and recognised as a historic park and garden site (Grade II). In addition, an area to the south of Whitchurch Lane has been designated as open space.

The Canons Park Estate Conservation Area is subject to an Article 4 direction requiring planning permission for all the residential properties within the Conservation Area for a range of householder alterations including to extensions and rooflines.

As mentioned, a small part of the site and a significant amount of the surrounding area is in the Canons Park Estate Conservation Area. This is recognised as a high quality area for its landscaping, openness and high-quality architecture owing to much of the wider area passing from medieval origins to the early 20th century as one estate. The area was designated in 1990, however was recognised as an area of local character prior to this. Within Canons Park itself there are a number of Listed Buildings and structures, including:

 The Church of St Lawrence, located at point 1 below (Grade I listed);

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3.0 Site and Surroundings

 Wall enclosing the George V Memorial Garden, located at point 2 below (Grade II listed);

 Wall enclosing the garden to the north west of George V Memorial Garden, located at point 3 below (Grade II listed);

 Garden Temple, supporting walls and raised paved area, located at point 3 below (Grade II listed);

 Main building, formerly Canons House, North London Collegiate School, located at point 4 below (Grade II listed);

 Screen walls, terraces, retaining walls, balustrades, garden steps and rotunda to former Canons House, North London Collegiate School, located at point 4 below (Grade II listed).

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S SITE AND SURROUNDING

Figure 3 Heritage Assets (Historic England)

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4.0 Planning History

This section provides an overview of the Site’s planning history. This information has been obtained from records available from London Borough Harrow’s online planning applications register.

THE SITE

There is a limited planning history for the Site. The majority of applications have related to the Station Building, which is located outside the red line boundary of the Site. These applications have been included below for reference.

 Application reference: EAST/660/01/CLE Certificate of lawful existing use: use for mini-cab operation & administration office. Approved 19 September 2001.

 Application reference: P/1175/04/DAD Internally illuminated ATM signs. Approved 24 June 2004.

 Application reference: P/1180/04/DFU Installation of automatic teller machine. Approved 24 June 2004.

SURROUNDING SITES

Within the surrounding area there are a limited number of recent applications. The majority

11 of applications within close proximity relate to home owner applications, including upwards extensions and amendments to single dwellings. Page

The below applications relate to the most recent and relevant larger developments, deemed relevant for the purposes of this statement.

Adjacent to the northern boundary of the site, located within Canons Park the adjacent PLANNING HISTORY property, Wyel Lodge, currently has a pending4 application (P/2845/19) for a single storey side extension to incorporate a café (Use Class A3), including outdoor seating, art gallery and community space (Use Class D1). This includes the introduction of a terrace with glazed balustrade at first floor level and other associated works including landscaping. This application was submitted in August 2019.

The proposals at Wyel Lodge will introduce further activity to Canons Park creating a community focus at the end of Donnefield Avenue.

As mentioned in Para 3.15 above, the character of the area has undergone recent changes through the approval of a major redevelopment application at Honeypot Lane (500m south of the Site). This application (P/2317/06), approved at appeal in November 2007, was for the comprehensive redevelopment of the site for 798 residential units, 959sqm Class A1/A2/A3/A4/A5/D1/D2 floorspace, 7,927sqm of Class B1 floorspace (including business incubator centre) with associated access, flood alleviation, landscaping, parking and highway works.

The proposal was originally refused on a range of matters that included:  Poor design quality, which resulted in a perception of over-development;  Poorly designed internal layouts which would result in a poor standard of living;

4 As confirmed by the London Borough of Harrow in February 2020, correct at the time of submission.

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4.0 Planning History

 Unacceptable overlooking impact, sense of overbearing and the loss of outlook to surrounding properties; and.

 Lack of parking provision and cycle storage. The reasons for refusal cited were site and context specific with the Inspector considering that whilst the development would be of a higher density to the surrounding area it would complement the existing character and provide a well-designed new neighbourhood.

This development changed the character of this area of Canons Park. When considering the proposals, the Inspector noted that the site gave rise to an opportunity to deliver a new urban village typology. This typology would present higher density suburban living, with a design responding to local context where appropriate but creating its own character and sense of place as an attractive place to live.

A subsequent S73 application was approved in December 2011 which sought to increase the height of five buildings in the latter phases of the development. The buildings were extended upwards to include fifth storeys and in one instance a setback sixth storey.

The development has been fully implemented and completed.

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PLANNING HISTORY

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5.0 Proposals

BACKGROUND

The applicants, Catalyst Housing Limited and Transport for London, are investing significantly in three sites across LB Harrow, seeking to deliver three 100% affordable housing developments on sustainable and accessible brownfield sites. The sites are all located adjacent to London Underground Stations which provides a key opportunity to deliver new homes and sustainable car-free developments.

The proposals for these sites have been developed collaboratively between TfL, Catalyst, the design team and key stakeholders. The proposals are seeking to deliver high quality affordable homes but will also seek to retain a proportion of public car parking, incorporate high quality new cycling facilities, and implement a high quality landscape and public realm strategy which supports the overarching Mayoral Transport Strategy (2018).

The quantum of commuter car parking which is proposed to be retained on the Site has been informed by a TfL User Survey (October 2017) and a subsequent survey carried out by WSP (June 2019) to inform the proposals.

This application relates to the Car Park at Canons Park Underground Station with two separate full planning applications also coming forward for sites at Stanmore and Rayners Lane.

PROPOSALS

The application at Canons Park is seeking full planning permission for the following 13 development: Page

“Redevelopment of existing public car park to provide new residential accommodation (Use Class C3) and flexible ground floor space and a public car park along with associated works” PROPOSALS

The following section provides greater detail on the proposed development and sets out key principles. This section should be read in conjunction with the supporting documents submitted with this application and referenced below where relevant.

Use and Quantum of Development

The proposed development comprises the redevelopment of the existing car park to provide three new buildings of seven storeys (six with a setback seventh storey), the re-provision of 60 commuter car parking spaces in a revised surface level public car park and the delivery of a TfL ‘Cycle Hub’ at ground floor accessed directly from Donnefield Avenue, and available to the public.

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5.0 Proposals

Figure 4: Proposed Layout (Karakusevic Carson Architects, Design and Access Statement)

The proposals also include works to Donnefield Avenue to improve the public realm and highway. Works to Donnefield Avenue include the provision of a raised table at the

northern end of the road which provides a revised entry sequence into Canons Park. 14

Table 1 summarises the location and floorspace of the land uses included in the proposed Page development.

Land Use GIA sqm Sqm/car parking spaces PROPOSALS

Residential (Use Class C3) 10,021 (118 Units) 4 wheelchair accessible spaces

Ancillary C3 (waste storage, 457 n/a bike storage, plant)

TfL Cycle Hub 99 71

Car park n/a 60 spaces (including 6 wheelchair accessible spaces)

Communal Amenity Space n/a 274

Total 10,586 274 sqm plus 60 car parking spaces

Table 1: Land Use Quantum and Distribution

Proposed Residential Development

The proposed development will deliver 118 residential units all of which are proposed to be affordable. The development has been designed to be tenure blind with all units achieving a high design quality. The development will deliver the following:

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5.0 Proposals

1 BED 2BED 3 BED TOTAL

London 0 11 11 22 Affordable Rent

Shared 48 44 4 96 Ownership

Total 48 55 15 118

Percentage Mix 41% 46% 13% 100%

Table 2: Residential Proposals

The development provides 185 dwellings per hectare which represents an efficient use of the Site given its sustainable, well-connected and brownfield location. The siting of the flats has been given significant consideration through design development and public consultation to ensure that the amenity of existing occupiers on surrounding sites and the amenity of the proposed occupiers is respected.

The proposed residential units have been designed to meet the Nationally Described Space Standards5 and meet the dwelling size standards set out within the London Plan. All units have private amenity space and also have access to two communal external spaces.

The development includes 10% wheelchair user dwellings, these will be to M4(3) standard

15 and will be fully adapted on delivery of the scheme. Page

The residential units have been designed to a high quality. There are no north facing single aspect units proposed and the majority of units across the scheme benefit from either dual

or triple aspects. PROPOSALS

TfL Cycle Hub

The proposals include a TfL Cycle Hub of 99sqm (GIA) this will provide 71 cycle parking spaces for commuters and the general public to use. The Hub is located within the ground floor of Building A.

Whilst the intended use of the floorspace is for the TfL Cycle Hub, this application seeks a range of flexible uses to account for any future changes to the approach and strategy. This will allow for an alternative use to be included. The flexible uses sought included, A1 (Retail), A3 (Café), D1(Non-Residential Institution) and Sui Generis.

Design

Design Brief

The proposals have been developed by Karakeusevic Carson Architects (‘KCA’) and Townshend Landscape Architects (‘TLA’) and have continually evolved through collaboration and engagement. The key principles integrated into the development, and elaborated upon further within the supporting Design and Access Statement include:

5 https://www.gov.uk/government/publications/technical-housing-standards-nationally-described- space-standard

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5.0 Proposals

 High-quality residential units – utilising the well-connected location of the Site and its historic setting to design affordable units that are of the highest architectural quality and tenure blind.

 Sustainability – incorporating best practice design, construction and operational management in terms of energy efficiency, waste and recycling, active transport and biodiversity.

 Community – ensuring an inclusive environment that is and feels accessible to all. This includes creating amenity spaces where residents and the wider community feel welcome to spend time.

 Connectivity – the creation of a high-quality and activated route to the adjacent listed park, to provide a safe, attractive and legible link and revitalise Donnefield Avenue.

Proposals

The proposed design has evolved through extensive consultation at pre-application stage with the LBH Planning Officers, the LBH Design Review Panel, Mayoral Design Advocates and the local community. The key principle behind the proposed design is for the development to deliver high-quality, sustainable residential development set within attractive, safe and inclusive amenity spaces and public realm. The scheme also seeks to deliver an attractive, legible and enhanced route from Whitchurch Lane to Canons Park creating an inviting environment for future residents of the proposed development and the

wider community. 16

The proposed development has taken contextual cues from the surrounding character Page including the Conservation Area and to deliver a sympathetic design response to the setting. The form and materials used are simple, modern and high quality which complements the wider context. PROPOSALS

The form of the development has developed in line with site specific constraints which have shaped the development proposals, including the adjacent SINC and Grade II Listed Park and Garden. The proposals are for three distinctive buildings separated by access points or through the provision of amenity space. The buildings face onto Donnefield Avenue creating a series of ‘front doors’ which will activate the street. The ‘front doors’ will each have defensible space which will include landscaping to create an attractive but defensible space for residents.

All three buildings have been designed to incorporate a welcoming entry sequence with a generous lobby space for residents.

Building A incorporates the proposed TfL Cycle Hub. This space has been designed on the corner of the building and has a glazed, welcoming and active frontage. The space is intended to be used for a TfL Cycle Hub but has been designed flexibly to accommodate alternative uses should future need arise.

The proposed materiality of the development has been informed through studies of the local context and material palette. The predominant materials are proposed to be brick and precast concrete with glazed bricks and further precast highlights at entrances. There is a range of brickwork detailing which adds articulation and texture to the elevations. This palette responds to the context of the surrounding area and picks up on the robust masonry identified at Canons Park Station itself.

Overall, the design has been driven by the principle of providing high-quality, sustainable residential units, the creation of safe and inclusive amenity spaces and an active and legible

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5.0 Proposals

route to the park, as well as cycle and car parking facilities. Full details on the design approach are included within the Design and Access Statement.

Landscaping and Public Realm

The scheme has been designed with a focus on four key character areas for the development, this includes:

 Social Street – integrating elements of TfL’s ‘Healthy Streets’ initiative to activate the Donnefield Avenue frontage, creating a playful and soft landscape boundary;

 Community Garden – a social, playful and interactive space for the residents of the development, this is located between Buildings A and B (see Figure X).

 SINC Buffer – creating a visual buffer and connection with the adjacent SINC, providing opportunity for biodiversity enhancements; and,

 Park Entrance - improvements to the entrance to create a moment of arrival, celebrating this key asset within the local community.

The four character areas define the private and semi-private areas within the development and provide a distinctive character addressing different elements of the development.

The proposals incorporate high quality play space within the proposed communal spaces, overall 274sqm of play space will be provided within the Community Garden and the Park Entrance space. In addition, there is proposed to be incidental ‘play on the way’ along

Donnefield Avenue which further activates and softens the development edge. Page The full details of the landscaping proposals are set out within the ‘Landscape and Public

Realm Strategy’ prepared by Townshend’s Landscape Architects and submitted in support of SALS

the proposals. PROPO

Transport and Parking

The Site is highly accessible being located immediately adjacent to Canons Park London Underground Station. The development is proposed to be car-free for the residential use aside from the provision of wheelchair accessible car parking.

The residential wheelchair accessible parking will be provided in line with the Draft London Plan delivering 3% (four spaces) on implementation of the scheme and a further 7% (eight spaces) identified. The 7% passive spaces will be provided for on-site should the demand arise.

The proposals also include the provision of an on-site Car Club bay which will be provided for the use of incoming residents, the location which can be secured by way of legal agreement.

The station car park is aiming to provide 60 car parking spaces, including six wheelchair accessible parking spaces and 6% will feature electric vehicle charging points.

Cycle parking will be provided on-site for the residents of the proposed development and has been designed to accommodate the standards set out within the Draft London Plan. In total 212 cycle parking spaces will be provided for residents, including 5% of spaces for non-standard cycles. A further eight short-stay spaces will be provided for visitors.

To further encourage modal shift, the proposals also include a TfL Cycle Hub. The Hub is located within the ground floor of Building A (closest to the station) and comprises space for

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5.0 Proposals

circa 71 cycle parking spaces for use by visitors and commuters. This space will be managed by TfL and further details are expected to be secured by planning condition.

Access

The site is bound to the east by Donnefield Avenue and the development is therefore accessed solely from Donnefield Avenue by both vehicles and pedestrians.

Access to the car park which is located to the rear of the proposed residential development adjacent to the railway line can be accessed between Buildings B and C (see Figure 4).

Pedestrian access to the residential units is all taken from Donnefield Avenue, all units have either an entrance lobby sequence or a ‘front door’ onto Donnefield Avenue. The community garden and park entrance space are also accessed by pedestrians and cyclists from Donnefield Avenue.

Environmental Impact Assessment

An Environmental Impact Assessment Screening Request (reference: P/4557/19) was submitted to LBH in October 2019. This assessment outlined the proposals and considered the impacts of the proposals on the Environment.

It was confirmed in a letter from LBH dated 29 October 2019 that the proposed development on the site was not EIA development and therefore did not require an Environmental Statement.

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PROPOSALS

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6.0 Pre-application Advice and Consultation

In bringing forward the Proposed Development, the applicants have consulted extensively with the LPA under a PPA to ensure that the scheme represents collaborative engagement in the best interest of residents, LB Harrow and the applicants. Further engagement has also taken place with a number of statutory bodies including TfL, Historic England, the Met Office and the Ministry of Defence.

CONSULTATION WITH LONDON BOROUGH OF HARROW

As part of the evolution of the proposals, the applicants have engaged with LB Harrow on a number of occasions, the engagement has focussed on a range of matters relating to the scheme both in terms of the design and technical evolution. The feedback received has been considered and the scheme has sought to evolve and respond, the table below provides a commentary on this engagement.

The table below provides a summary of the engagement on design and technical matters and represents the final position reached with the LB Harrow. The below table is a summary of the most pertinent matters raised during pre-application and is not intended to be exhaustive.

THEME LB HARROW COMMENT SCHEME RESPONSE

Land Use

Principle of The site at Canons Park is a The scheme will deliver a

residential designated housing site and is residential development retaining

development included within the Harrow Council a proportion of commuter Page

Site Allocation documents. parking in line with the Site Allocation. There are no objections in principle to the redevelopment of the site for The schemes are delivering much housing. needed affordable housing within the LB Harrow contributing to overall housing targets. APPLICATION ADVI CE AND CONSULTATION - PRE Affordable The LBH expressed concerns over the The schemes are delivering 100% Housing provision of Shared Ownership affordable housing, providing a properties and the extent to which mix of London Affordable Rent they are considered affordable within and Shared Ownership. Harrow. The 40% policy compliant affordable housing component is delivered in line with policy requirements with the remaining 60% providing Shared Ownership properties. Discussions have taken place with the LB Harrow and the tenure, split and mix has been agreed.

Adjacent TfL Development should consider the It is not possible to bring forward Owned site adjacent TfL owned site as part of the adjacent TfL site as part of

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this proposal to create a holistic this development due to lease scheme. arrangements. Within the Design and Access Statement, an indicative masterplan has been prepared which demonstrates how this site would work with a future development phase.

Heritage

Impact on The proposed buildings would be The proposals would be visible, character of visible in open views; there is a however the palette of materials neighbouring concern that the proposal would chosen, and the design approach Heritage undermine the character given the taken has been designed to Assets. height proposed and proximity to sensitively relate to the heritage assets. surrounding heritage assets. A Townscape and Visual Impact Assessment will be submitted with There is a requirement for verified the planning application for the views from the Park and Garden to purposes of assessment. This demonstrate the impact. includes a range of Verified 20

Views taken from key locations Page

surrounding the site.

Canons Park It would be intrusive on the Canons Through pre-application the facing Park Estate to have balconies and proposed approach to balconies elevation glazing high up facing onto the park has been amended, the entrance. balconies facing Canons Park are no longer projecting and APPLICATION ADVI CE AND CONSULTATION -

have been amended to Juliet PRE Windows to reduce intrusion on the Park.

Design

Height Concerns were raised over the The proposed setback was proposed height of the development amended through pre- given that it is greater than application discussions. The surrounding heights. setback is from the street frontage not from east-west. The proposed setback at seventh should be from all sides to limit This reduces the visual impact of impact of development. the setback seventh storey reducing prominence within the streetscape. During pre-application discussions it was noted that the

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6.0 Pre-application Advice and Consultation

height, scale and massing could be supported.

Site Layout The proposal encourages vehicular The proposal was amended movement along the entirety of during pre-application stage and Donnefield Avenue, the Car Park the entrance has been re-located entrance is located furthest away between Buildings B and C. from the Station and creates a car This re-location reduces the dominated scheme. length of Donnefield Avenue where cars will be present and travelling and creates an opportunity to deliver improved play and amenity space. The proposed change to vehicle access was welcomed and supported by Officers.

Setback from The proposed set back from the The proposals have been set front street edge is not sufficient at back a further 200mm from the elevation 800mm. street edge and the scheme now and adjacent provides a 1m setback which is

footpath. considerable and provides 21

sufficient defensible space for Page

units.

Gable end The scheme has two entrances and KCA developed the proposed design each of the ‘book ends’ should better gable ends further to ensure that announce these and should avoid they addressed the immediate flank gable ends. context fully. The gable adjacent to Canons Park has been APPLICATION ADVI CE AND CONSULTATION

The gable end adjacent to Canons -

articulated to respond to and PRE Park should be fully articulated and compliment the character of the not designed in a manner, so it is park without being overbearing. not read as an ordinary flank. The gable of Building A has been designed to respond to the adjacent site with recognition of the future development potential so as not to prejudice development coming forward.

Materiality The proposals need to be developed As set out within the Design and and Design to better reflect the character of the Access Statement sections 2.11 surroundings. and 2.12, consideration has been given to the surrounding context and a number of direct contextual cues have been included within the final design.

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Landscape and Public Realm

Quality of The quality of community/garden The proposed amenity and landscaping play space needs to be resolved, communal garden spaces have and spaces. especially with regard to usability. been developed through the pre- application process. The proposed re-location of the car park entrance enabled the space to be widened, creating an improved communal space. The re-location of the car park access also enabled the creation of an additional communal space adjacent to Canons Park, this provides both amenity for residents and creates an improved entrance to the existing park. Overshadowing and microclimate has been considered and supporting

statements provided which 22

demonstrate that the space is Page

suitable for its intended use. Further details of the soft and hard landscaping strategy is set out within the Landscaping and Public Realm Strategy.

Proposed The street appears rather urban and The streetscape has been APPLICATION ADVI CE AND CONSULTATION -

Street out of keeping in the existing sub- significantly improved through PRE urban area. There are concerns the re-location of the car park regarding the play space on the access and the further setback of street. the buildings. There is a palette of suggested materials and planting which is robust, maintainable and provides a softer edge to the development. Incidental ‘play-on-the-way’ is provided along Donnefield Avenue. This is proposed to be incidental and is ancillary to the main play space within the development. The introduction of this creates a playful route to Canons Park and is not designed to be spaces for children to dwell. Play-on-the-way is a key element of the Mayors ‘Healthy

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Streets’ initiative and this is proposed to be an opportune location to incorporate this. Whilst there will be traffic movement, this will be significantly reduced given the reduction in car parking. The parking bays will be inset and will be paved to reduce visual impact and to give the impression of a narrower street.

Transport

Amendments The proposals for the highway layout The proposals have been to the are not supported due to the narrow updated and no longer include Highway carriageway width. localised road narrowing. Donnefield Avenue remains as As part of the landscaping theme to per the existing condition. approach the park, the proposals include raised tables and other street The proposed raised table has play facilities. been reduced in scale and now

forms a small area in front of 23

Canons Park, creating a Page

reduction of vehicle dominance adjacent to the park.

Car Free LB Harrow requested demonstration Information supporting this has Development that the car free nature of the been included within the proposal is suitable for this location. Transport Assessment prepared by WSP. APPLICATION ADVI CE AND CONSULTATION -

The site is in an accessible and PRE sustainable location adjacent to Canons Park Underground Station and in line with National and Regional policy is therefore considered to be wholly appropriate for a car free development. Initiatives to support modal shift, including high quality cycle parking, a car-club space and a TfL cycle hub are incorporated into the development.

Cycle Hub The cycle hub initiative is welcomed The cycle hub remains within the and at the Station but further development and is directly Infrastructure infrastructure will be required to accessed from Donnefield assist with modal shift. Avenue.

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Technical

Drainage It was confirmed during pre- The drainage proposals have application stage that the scheme been developed and they are would need to meet the LB Harrow now in line with the LBH standards for Drainage. requirements. A Drainage Design Study has been submitted in support of this application and provides design detail.

DESIGN REVIEW PANEL AND MAYORAL DESIGN ADVOCATES

Given the strategic nature of this site and the applicant being TfL, the proposals have undergone review by both the LB Harrow Design Review Panel and have been through the Mayoral Design Advocate process.

The following were the meetings that took place in relation to the proposals for the Canons Park car park site:

 10 June 2019 – Design Review Panel One  12 September 2019 – Design Review Panel Two

 16 January 2020 – Chair Review Page

The following table provides a summary of the main points included within the three feedback letters received from the Panel sessions, these comments have been considered and incorporated as far as possible into the proposals.

Following the Chair Review in January 2020, the Panel welcomed the approach taken to E AND CONSULTATION incorporate comments from previous sessions and were pleased to see the key move of the Car Parking entrance. APPLICATION ADVI C - THEME DRP & MDA COMMENT SCHEME RESPONSE PRE

Defensive The Panel considered that there was The scheme integrates incidental Boundary an opportunity to create ‘doorstep play along Donnefield Avenue, play’ and learn from the spaces on this creates a playful and soft the eastern side of Donnefield landscape approach to the street. Avenue to reduce the defensive This softens the boundary boundary to street. between the buildings and the street frontage. The incidental play creates a route which connects the open space within Canons Park with Whitchurch Lane.

Park Gateway There was considered to be an The design team welcomed this opportunity to celebrate the comment and as a result of the entrance to Canons Park to make a car park access re-location were positive entrance. able to increase the size of the pocket par adjacent to Canons

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Park to create a more meaningful and connected space. The proposals also include the incorporation of a raised table which creates a seamless integration from street to park. The materials for the raised table have been carefully considered to respect the Park whilst being sufficiently robust as a highways’ intervention.

Car Park The Panel were concerned about the The car parking entrance was a Entrance location of the entrance and how key move made by the design this encouraged vehicle movements team. This has been relocated to the full length of the site and between Building B and C. This encouraged the relocation of this. re-location reduces the car dominance along Donnefield Avenue. The re-location also creates an opportunity to deliver an additional amenity space adjacent to Canons Park.

Amenity The panel were concerned that Building A now incorporates deck Page some of the units would be access to units. compromised due to the location of All units have been designed to a the embankment and suggested high standard and deliver high including deck access. quality residential units in line with the relevant standards and guidance. APPLICATION ADVI CE AND CONSULTATION - PRE Articulation The Panel suggested including The Design and Access Statement greater articulation on the elevations prepared by KCA provides detail to reduce overbearing and on the proposed articulation and relentless. architectural treatment. This has been developed to ensure a high-quality development which responds to the existing heritage and local context.

Active The Panel encouraged a review of The ground floor has been Frontage the ground floor to ensure that there revised throughout the re- is a good level of active frontage. application process. The buildings incorporate the maximum amount of active frontage including the TfL Cycle Hub, residential lobbies and front doors. The remaining frontage is

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required for access to cycle storage and ancillary spaces. However, it is considered that Donnefield Avenue will be activated by the combination of landscaping and architectural approach.

Adjacent The proposed cycle hub was queried The cycle hub is located as close Development as there were concerns that it would as possible to Canons Park Site be underutilised in this location. The Station. The adjacent panel also queried whether the development site is not included adjacent site could be incorporated within the red line boundary of into to the development to create a this application and it is outside holistic approach. the scope of this proposal. However, an initial ‘masterplan’ is included for illustrative purposes within the Design and Access Statement.

Engagement with the Mayoral Design Advocates and the LB Harrow Design Review Panel was positive: the guidance provided by the Panel has helped to develop and shape the

scheme. The scheme submitted for full planning is considered to reflect a number of the key 26

elements raised by Panel members and has responded positively to comments made during Page

the process.

STAKEHOLDER ENGAGEMENT

LB Harrow Major Development Panel

As part of the wider engagement on these proposals, the scheme was presented to the LB APPLICATION ADVI CE AND CONSULTATION Harrow Major Development Panel in July and November 2019. The scheme was presented - PRE alongside the proposals for both Rayners Lane and Stanmore.

At both of the Panel sessions Members raised a number of key matters, these are predominantly in line with comments made by Planning Officers and the Design Review Panel, however in summary the comments included:

 There is a greater need for family housing.  Concerns were raised over the expectation of a significant modal shift through the removal of car parking, although they welcomed that some parking for commuters was retained.

 Consideration needed to be given to how residents of the proposed development could be restricted from parking on neighbouring streets.

 Members raised concerns in relation to the scale of development on Donnefield Avenue given the local context.

 The proposed materials for Canons Park were not welcomed and were considered to be unattractive.

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Through this planning submission the comments that were raised by Members at both Panel sessions have been addressed with responses included within the relevant supporting documentation.

With regard to housing mix, the proposed mix of units has been informed through discussions with the LB Harrow and the proposed mix on site has been agreed and confirmed. This includes three bedroom and larger two bedroom units which are considered to be family sized units.

The concerns raised over the transport and parking elements were also raised by LB Harrow Officers, as part of the Transport Assessment, WSP have considered and responded to matters relating to modal shift. As part of the s106 agreement there will be a restriction on residents applying for parking permits and further when the units are marketed all tenants and potential owners will be notified that the scheme is car free.

The design has developed further since the Major Development Panel and the concerns raised by Members have been addressed fully within the Design and Access Statement.

Transport for London (Spatial Planning)

A meeting was held on 28 August 2019 with Transport for London (Spatial Planning) to discuss the proposed development at Canons Park. A number of points were raised by Officers and these have been summarised below.

 TfL Spatial Planning was supportive of the ‘car-free’ nature of the schemes, as well as

27 the provision of blue-badge parking in convenient locations; Page

 Spatial Planning was supportive of the reduction in station car parking and welcomed further reductions in line with the strategic transport aims for both the Draft London Plan and Mayoral Transport Strategy.

 It was confirmed that Spatial Planning did not require junction modelling due to the overall reduction of trips associated with the development.

 Consideration needs to be given to the impact of TfL operations on residents and APPLICATION ADVI CE AND CONSULTATION should be mitigated during development stage where possible. - PRE Engagement with TfL Spatial Planning was generally positive with a number of comments welcoming the proposed approach to reducing car parking on the site. TfL were also welcoming of encouraging modal shift and introducing car-free developments.

Specific comments were also received regarding the Transport Assessment and other supplementary documents, these have been incorporated into the relevant documentation.

Historic England

Initial feedback on the proposals was received in October 2019, and subsequently a meeting was held in January 2020 to discuss the proposals. Following the meeting Historic England provided formal feedback.

It was concluded that the proposals would cause harm to the setting of the adjacent heritage assets, but this could be overcome through a reduction in height. The feedback concludes noting that the harm should be weighed up against the public benefits of the scheme.

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The balance of harm and public benefits is a matter for the decision maker, however further commentary is provided on this in Section 8.0 of this report and within the Heritage Statement, prepared by MOLA.

Defence Infrastructure Organisation

Given the Site’s location within RAF Northolt Safeguarding Zones, in September 2019 the design team engaged with the Defence Infrastructure Organisation (DIO) with regard to the proposals.

The DIO have confirmed that they had no concerns with the proposed building heights at Canons Park. There is a request for information at future planning stages and if the heights of any buildings proposed exceed 91.4m Above Ground Level (AGL) to ensure that air safety at RAF Northolt is not compromised.

The proposed buildings have not changed in height since the consultation with the DIO in September 2019. The DIO will be consulted as part of the statutory consultation period.

NATS Safeguarding

An assessment of the proposals was undertaken by NATS Safeguarding to ensure that the development proposals would not impact upon the Primary and Secondary radar at Heathrow Airport.

It was concluded that the scheme would not impact upon the radars at Heathrow Airport

28 and NATS would not raise any objections should a scheme come forward for planning. Page

MET Office

The site is located in close proximity to Chenies weather station and as such, the applicant engaged with the MET Office at pre-application stage.

It was confirmed that the proposals would not have any impact on the weather station and therefore no further engagement was required. APPLICATION ADVI CE AND CONSULTATION - PUBLIC CONSULTATION PRE

In addition to the comprehensive engagement with the LB Harrow and Statutory bodies, the applicants have held a number of public consultation events, full details of the engagement with the public is set out in the Statement of Community Involvement prepared by Lowick. The following events were held in relation to Canons Park:

 17 July 2019;  25 November 2019; and,  26 November 2019. Overall, a high number of local residents engaged with the applicants and their consultant team at these engagement events. Generally, there were a number of concerns raised by residents and local community groups and these are addressed in detail within the Statement of Community Involvement prepared by Lowick.

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7.0 Planning Policy Overview

This section provides an overview of the key national, regional and local planning policies relevant to the application.

The Town and Country Planning Act (the “1990 Act”) and the Planning Compulsory Purchase Act 2004 (“the 2004 Act”) establish the legislative basis for town planning in England and Wales. Together these acts establish a “plan led” system which requires planning authorities to determine planning applications in accordance with the statutory development plan (the development plan) unless material considerations indicate otherwise.

Section 38(6) of the Planning and Compulsory Purchase Act 2004 requires that proposals are determined in accordance with the Development Plan, unless material considerations indicate otherwise.

The National Planning Policy Framework (NPPF) (February 2019) is a material consideration in the determination of planning applications. In assessing and determining development proposals, the NPPF (2019) sets out the circumstances in which local planning authorities should apply the presumption in favour sustainable development.

LB HARROW’S DEVELOPMENT PLAN

The Site is located in the London Borough of Harrow (‘LBH’) and as such the statutory development plan comprises the following:

 Harrow Core Strategy (2012);

 Development Management Policies Local Plan (2013); 29

 Harrow Council Site Allocations (2013); Page

 West London Waste Plan (2015); VIEW  Adopted Policies Map (2013);  Harrow Biodiversity Action Plan (2015); and PLANNING POLICY OVER  London Plan incorporating Further Alterations to the London Plan (MALP) (2016) Where there is a conflict between policies in the development plan, Section 38(5) of the 2004 Act provides that the most recently adopted policy takes precedence. As the London Plan and Development Management Plan are the most recently adopted development plan policies, where there is a difference in policy these documents take precedence although in all cases, where possible, the proposals have sought to achieve the highest defined standards.

A comprehensive review of the planning policies has been undertaken to inform the proposals for the Canons Park Station Car Park. Appendix A sets out the adopted emerging policies at national, strategic and local levels that are relevant to the proposal.

Following a review of the key policies as set out above and identified the key matters to be considered in the planning assessment has been identified. These issues are addressed within the next section.

MATERIAL CONSIDERATIONS

There are a range of documents that constitute material considerations in relation to these proposals, the most relevant of which are summarised below.

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National Planning Policy Framework (2019)

The NPPF states that the purpose of the planning system is to contribute to the achievement of sustainable development. Sustainable development has three core objectives: economic, social and environmental which contribute to building a strong economy, vibrant communities and protecting and enhancing the natural, built and historic environment. Plans and decisions should apply a presumption in favour of sustainable development. For decision-taking, this means approving development proposals that accord with an up to date Development Plan without delay.

Draft London Plan (2019)

The London Plan is the statutory Spatial Development Strategy for Greater London prepared by the Mayor of London (“the Mayor”) in accordance with the Greater London Authority Act 1999 (as amended) (“the GLA Act”) and associated regulations.

The current 2016 Plan (the London Plan consolidated with alterations since 2011) is the adopted plan, although the Draft London Plan (2019) is being given significant weight in planning decisions as it has now gone through Examination in Public. Once adopted, this document will provide a new set of policies to steer development within the Greater London area for the next 20-25 years. Given the status of the Draft London Plan we have considered the proposals against the relevant draft policies contained within it.

The Examination in Public (EiP) on the Draft London Plan was held between 15 January and

22 May 2019. The Panel of Inspectors appointed by the Secretary of State issued their 30

report and recommendations to the Mayor on 8 October 2019. The Mayor has considered Page

the Inspectors’ comments and, on 9 December 2019, issued to the Secretary of State his

intention to publish the London Plan, along with the Intend to Publish London Plan. It is VIEW anticipated that the new London Plan will be adopted in Spring 20206.

Canons Park Estate Conservation Area Appraisal and Management Strategy PLANNING POLICY OVER Supplementary Planning Document (SPD) (2013)

This SPD provides an analysis of the character and appearance of the Conservation Area and identifies elements that should be protected as well as opportunities for change or improvement. The management strategy uses this analysis to set out how this can be achieved, including guidance and controls.

Harrow Access for All SPD (2006)

This SPD guides designers and developers in creating an environment that enables residents and visitors to Harrow to easily access all buildings, facilities and surroundings.

Harrow Residential Design Guide SPD (2010)

This SPF provides guidance for those involved in the design and planning of new homes and is aimed at improving the overall quality of all new residential development across the borough.

6 On 14 February 2020, the Secretary of State (SoS) confirmed that he will require a further four weeks to review the Intend to Publish version of the Draft London Plan. The SoS response is due on or before Monday 16 March 2020.

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7.0 Planning Policy Overview

Harrow Planning Obligations and Affordable Housing SPD (2013)

This SPD was published to clearly set out the Council’s approach, policies and procedures in the use of planning obligations in relation to the Harrow Community Infrastructure Levy (CIL).

London Plan Affordable Housing and Viability Supplementary Planning Guidance (SPG) (2017)

This SPG focuses on affordable housing and viability. It is broken into four parts: background and approach, the threshold to viability assessments, detailed guidance on viability assessments, and a specific approach to Build to Rent schemes.

London Plan Housing Supplementary Planning Guidance (2016)

This SPG provides guidance on a range of strategic policies including housing supply, residential density, housing standards, build to rent developments, student accommodation and viability appraisals.

Mayor’s Transport Strategy (2018)

This document sets out the Mayor’s policies and proposals to reshape transport in London over the next two decades. It was developed in conjunction with Transport for London.

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VIEW PLANNING POLICY OVER

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8.0 Planning Assessment

This section provides an assessment of the proposed development in relation to the planning policies and material considerations set out in the previous section and the review contained within Appendix A

The key planning matters for the proposal to be assessed against are:  Principle of Development; − Loss of existing use; − Principle of residential use; − Affordable Housing; − Housing Mix and Tenure; − Accessible Homes; − Density.  Design;  Heritage;  Transport and access;  Sustainability and energy;  Flood risk and drainage;

32  Amenity (including daylight/ sunlight, noise, microclimate and air quality); Page

 Landscaping; and,  Biodiversity. Each of these sections should be read in conjunction with the relevant report, prepared by specialist consultants, as set out in Section 2.0 above and submitted in support of this PLANNING ASSESSMENT application.

PRINCIPLE OF DEVELOPMENT

The site is currently used as a commuter car park for TfL operated by NCP, providing 162 car parking spaces. The car park is predominantly used by those accessing Canons Park underground station which is adjacent to the site. The proposals involve the redevelopment of the site to provide 118 new residential units across three seven-storey buildings, and flexible ground floorspace to be used as a TfL Cycle Hub and a public car park, along with associated residential and visitor cycle parking, public realm works and landscaping.

The scheme will be 100% affordable bringing forward much needed new homes including both London Affordable Rent (LAR) and Shared Ownership units. Loss of Car Park

The proposed redevelopment of Canons Park Station car park will result in the loss of 102 car parking spaces with the proposed car park re-providing 60 car parking spaces. The proposals include infrastructure for electric vehicles, with a provision of 20% active electric charging spaces and 80% passive electric charging spaces.

The site is located in an accessible area, particularly considering its close proximity to Canons Park tube station, bus stops and cycle routes. The proposed development will give

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priority to pedestrian and cycle movements and facilitate an improved public realm and streetscape to enable safe access to neighbouring public transport (NPPF, Paragraph 110).

The existing car parking use is not protected through planning policy at local or regional level and it is considered that the reduction in car parking numbers is wholly in accordance with the wider aspiration of the London Mayor to reduce car dependency and promote a modal shift towards more sustainable modes of transport, and LB Harrow policy, which also seeks to promote modal shift (LP Policy 6.1, LBH DM 42, LBH CS1). The development will prioritise sustainable modes of travel and will be inclusive of infrastructure to support more sustainable choices.

Further to there being no protective policy in place, the Draft London Plan goes further, identifying that car parks provide an opportunity for delivering optimised levels of housing (DLP, Policy H1).

The existing site allocation also confirms that a reduction in commuter car parking would be acceptable on the site; the reduced quantum sought through this application has been informed through survey work by both TfL and WSP and is considered to be appropriate for this location (Site Allocation, H17).

It is considered that this reduction in commuter car parking will contribute to the Mayor’s strategic target of reaching 80% of all trips in London to be made by foot, cycle or public transport by 2041 (DLP, Policy T1).

It is considered that the proposed loss of commuter car-parking is wholly in line with

33 policies at the national, regional and local level and that these proposals will contribute to

strategic objectives to promote modal shift and more sustainable modes of travel. Page

Principle of Residential Use

The application site is allocated within the LB Harrow Site Allocations Local Plan document. The allocation establishes the principle of redeveloping the site for residential use alongside PLANNING ASSESSMENT the re-provision of commuter car parking. The housing capacity figure shown is indicative, based on half of the site being redeveloped for housing. As part of this application, surveys have been undertaken which result in scope for further car parking reductions, and the design has been carefully developed and considered to ensure site optimisation, therefore exceeding the capacity within the allocation.

The principle of utilising the site for residential development has been established through the site allocation, and in addition to this there is a significant housing need within London, with the most recent London-wide Strategic Housing Market Assessment (SHMA) identifying a need for over 66,000 additional homes per year to be delivered across London, which is considered to be a single housing market area.

The focus for housing delivery within London is to be in the most sustainable locations and where possible through the optimisation of brownfield sites, especially those with PTAL levels between 3-6 or located within 800m of public transport (DLP, Policy H1).

The Draft London Plan sets a ten-year housing delivery target for Harrow of 8,020 new homes, as well as a ten-year housing target of 3,750 for net housing completions on small sites. This housing target is a significant increase on the previous target from the current London Plan of 5,927 homes over the previous ten-year period. This target also far exceeds the current LB Harrow target of delivering 3,250 new homes on previously developed land.

It is therefore considered that given the significant overarching need for new homes across London and in LB Harrow, the existing site allocation and the sustainable, brownfield and

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accessible nature of this site, that the proposed redevelopment for housing is wholly in accordance with the relevant planning policies at all levels.

Affordable Housing

The proposals will deliver 118 affordable housing units in a high-quality tenure-blind development located on a sustainable and accessible site within Harrow.

Harrow has a small social housing stock and has a very high demand for housing from homeless tenants, home seekers and tenants waiting for alternative accommodation.

The London Assembly reported in June 20197 that Harrow’s total affordable completions were 176 units between 2016 and 2019. The report also stated that the total affordable starts in Harrow between 2016 and 2019 were also considerably low, at 774 units. This demonstrates a real need for the delivery of planning consents which will contribute to the overall affordable housing need within Harrow.

The Annual Monitoring Report (October 2019)8 indicates that in 2017/18 in Harrow affordable housing made up 4% of the borough’s total net conventional supply which was a total of 27 new affordable homes (completed).

The delivery of this quantum of affordable housing is wholly in accordance with the strategic objectives of the London Mayor and the LB Harrow; the provision of 100% affordable on- site significantly exceeds the targets set within planning policy which sets a strategic target of 50% within the Draft London Plan and 40% within the Harrow Core Strategy. Further to this,

the land is owned by TfL (public sector land) and therefore in accordance with Policy H4 of

the Draft London Plan the requirement for at least 50% affordable housing to be delivered Page again is exceeded through these proposals.

The Site is part of a wider TfL portfolio of sites which are coming forward for the purposes of development and delivering high quality affordable housing on accessible, previously

developed public sector land. In line with Policy H4, all of the affordable housing is being PLANNING ASSESSMENT delivered on site in a tenure blind approach.

Housing Tenure

The proposals seek to provide 118 units (Table 3 and 4 provide the details). The proposed mix and tenure has been discussed and agreed with the LB Harrow.

The development is providing 100% affordable housing at a policy compliant level split between London Affordable Rent and Shared Ownership. The inclusion of two types of affordable housing is in line with policies which seek to ensure that housing developments deliver a range of products suitable for the context, size, type and tenure of housing needed for the whole community (NPPF, Paragraph 61).

The inclusion of a mix of tenure types within the development also ensures that the redevelopment of the Canons Park car park site provides a genuinely affordable, inclusive and mixed community (Draft London Plan, GG4).

7 London Assembly Affordable Housing Monitor – Reviewing the Mayor’s housing commitments (June 2019) https://www.london.gov.uk/sites/default/files/affordable_housing_monitor_publication_18- 19.pdf 8 GLA Annual Monitoring Report - https://www.london.gov.uk/sites/default/files/amr_15_final.pdf

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The proposed tenure being delivered on the site is in line with the definitions of Affordable Housing provided within the Affordable Housing and Viability SPG (2017), the intermediate (Shared Ownership) homes are provided for households within the range of incomes set out within the abovementioned SPG ensuring that they are a considered to be a genuinely affordable product.

The proposed development triggers an affordable housing requirement by nature of scale, and as such the threshold approach as set out within the Draft London Plan (Policy H5) is applicable. This requires that 50% of the quantum of housing is delivered as an affordable product. The proposals are in excess of this, delivering 100% affordable housing and are the scheme therefore qualifies for the Fast Track route and no viability assessment has been submitted with this application.

The proposals deliver a policy compliant tenue split. On a habitable room basis 40% of the homes are delivered in line with the relevant policy, including a split of 70% London Affordable Rent and 30% Shared Ownership. The remaining 60% overall is delivered as Shared Ownership. The quantum of Shared Ownership has been agreed with the LB Harrow and is in accordance with Policy H6 of the Draft London Plan.

It is considered that the delivery of 100% affordable homes on this suitable, available and accessible brownfield site is wholly in accordance with the relevant policies of the national, regional and local plans and in many instances provides development in excess of the policy requirement.

35 Tenure Total units % of total Total habitable % of total

rooms Page

Affordable Rent 22 19% 99 29%

Shared 96 81% 248 71% Ownership PLANNING ASSESSMENT

Table 3: Housing Tenure

Housing Mix

The below table (Table 4) provides a breakdown of the proposed tenure and unit mix in the development. The housing mix has been agreed with the LB Harrow and reflects the greater need for family sized and larger dwellings to be provided in London Affordable Rent tenures.

The proposed development provides a range of unit sizes, and in line with Draft London Plan Policy H10, consideration has been given to the following key elements:

 Local evidence;  The need to deliver inclusive and mixed communities;  The need to deliver a range of options; and,  The location of the site. The proposed mix of units in the below table contributes to the development of a mixed and balanced community and is in line with policy.

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1 BED 2BED 3 BED TOTAL

London Affordable Rent 0 11 11 22

Shared Ownership 48 44 4 96

Total 48 55 15 118

Percentage Mix 41% 46% 13% 100%

Table 4: Housing Mix

Accessible Homes

The development includes 10% of dwellings meeting Building Regulation requirement M4(3) ‘wheelchair user dwellings’, the remaining 90% will be delivered in line with Building Regulation requirement M4(2) ‘accessible and adaptable dwellings’, this is in accordance with Draft London Plan Policy D7.

Following discussions with the LB Harrow, the scheme will deliver the 10% M4(3) dwellings as fully adaptable on completion of the development.

Density

The density of the proposed development at the Cannons Park station site is 544 habitable

rooms per hectare (185 units per hectare). 36

When applying the density matrix within the London Plan (table 3.2), the site would fall Page within an ‘suburban’ context and has a PTAL’ of 3. The site is located to the immediate north of Canons Park underground station, which has direct connections to Central London via the Jubilee Line. The surrounding area consists of a parade of retail units to the south-

west of the site and a mix of low-rise flats, semi-detached and detached housing. PLANNING ASSESSMENT

The Draft London Plan (Policy GG2) notes that higher density development should be promoted, particularly in locations that are well-connected to jobs, services, infrastructure and amenities by public transport, walking and cycling. The policy goes on to note that the appropriate density of a site should be arrived at through a design-led approach. The Draft London plan removes the Density Matrix that was previously included in order to promote a design lead approach rather than the application of a prescriptive matrix. Specifically, the Draft London Plan identifies the role that car parks can play in delivering high density residential development.

The development has been designed to respond positively to the local context. Throughout the design process, in response to comments from Officers and the Design Review Panel and MDAs, the design has evolved to mitigate the perception of overlooking across each of the surrounding street elevations. The development is in-keeping with the surrounding residential context and is of a high-quality and innovative design. It is considered that the proposed design of the site effectively optimises development on an accessible, brownfield site, whilst responding to the local context.

The development has been designed sensitively and consideration has been given to the wider impacts of the development, these matters are discussed later in this section. Overall, the proposals represent an optimised use of the site for much needed affordable housing.

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DESIGN Design Principles

Section 5.0 sets out the key principles which have informed the design of the proposed development, which responds to the character and constraints of the site and its surrounds. The design team have responded to feedback from and engagement with stakeholders, LBH and the Design Review Panel and MDAs, in order to maximise the positive contribution of the proposals. This section should be reviewed in conjunction with the KCA Design and Access Statement. The approach taken has been a design-led and tenure blind consistent with planning policies at all levels. The key principles and objectives of the proposals are as follows:  To provide a high-quality, tenure blind design with well-integrated public realm improvements;

 To incorporate high quality new cycling facilities for station users;  To positively impact the local context through the creation of a new, safe neighbourhood with a sense of inclusion;

 To produce high quality architecture and public realm design, that positively impacts the existing neighbourhood;

37  To design buildings that maximise their utility, efficiency and minimise future maintenance; Page

 To design buildings that positively respond to the historic setting and conservation area; and  To meet the sustainability standards set out in the Draft London Plan.

PLANNING ASSESSMENT Height, Scale and Massing

The proposals consist of three buildings, A, B and C, all buildings are seven storeys in total, with the seventh storey setback from street level to reduce the visual impact of the development.

The LB Harrow Development Plan identifies that ‘tall buildings’ are buildings which are taller than those in the surrounding context and would change the skyline. The proposal, by nature of its height is therefore considered to be a tall building.

Given the definition of a ‘tall building’ in line with Draft Policy D9 consideration has been given to a range of views of the proposals from different receptors in the immediate context, these have been assessed in a separate Townscape and Visual Impact Report.

The proposed development is for three buildings of the same height. The buildings do not form a cluster of tall buildings and are considered to be buildings which aid legibility and wayfinding in the local area by denoting the location of the Canons Park Station.

The proposals are taller than the immediate context, although as set out in Section 4.0 there have been recent permitted developments which have increased the overall height context in specific locations to between five and six storeys. However, the proposed development height is considered to be the most appropriate form of development which directly responds to the site’s context and capacity for growth (Draft London Plan Policy D3).

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Detailed Design

Full details of the proposed architectural design and treatment have been set out within the Design and Access Statement prepared by KCA.

The design approach taken is in line with policies at all levels including national, regional and local policies which promote and encourage the delivery of high quality design on sites across London. Specifically, the proposals have been developed to use materials and a design approach which enhances local context through building design and materials which respond to local distinctiveness (Draft London Plan, Policy D3).

Consideration has also been given to Policy DM1 of the LB Harrow Development Management Policies which sets out that all development must achieve a high standard of design and layout. Regard has been given to the appearance of the proposed buildings, including the roof form, architectural inspiration, materials and entrances.

Overall, it is considered that the proposals represent a high quality intervention into this area of Canons Park, providing a development which is complimentary to and integrated

38 into the local context. Page

HERITAGE Overarching Principles

As set out previously in Section 2.0 of this Planning Statement, the site is subject to the following heritage designations: PLANNING ASSESSMENT

 Adjacent to a Site of Importance for Nature Conservation; and,  Part of the site is designated within the Canons Park Estate Conservation Area. The application is supported by a Heritage, Townscape and Visual Impact Assessment which considers the proposals from three aspects:

 Heritage Assessment – Considers the significance of heritage assets and the impact of the proposals upon that significance.

 Townscape Assessment – Considers the proposals within its urban context, including the buildings, the relationship between them, the different types of urban open spaces, and the relationships between buildings and open space.

 Visual Assessment – Considers the impact of the proposals upon visual receptors. The assessment relates to how people will be affected by changes in views and visual amenity at different places, including publicly accessible locations.

Throughout the pre-application process, the applicant agreed the key views with the LB Harrow Officers which would need to be assessed as part of the application and these are all included within the Townscape and Visual Impact Assessment which has been submitted in support of this application.

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Heritage Impact

The proposed development is located in the setting of two heritage assets, as set out above. Heritage assets range from sites and buildings of local historic value to those of the highest significance. In line with Paragraph 189 of the NPPF, the submitted Heritage Assessment takes into consideration the significance of the heritage assets affected by the proposed development proportionate to the assets’ importance.

Throughout the pre-application process the applicant has engaged with Historic England to discuss the proposals for Canons Park as they have developed and evolved.

The Heritage Assessment prepared by MOLA outlines that the two heritage assets (the Registered Park and Garden and the Conservation Area) and confirms that the significance of the assets are of a high significance. Paragraph 196 of the NPPF sets out that where a development proposal will lead to less than substantial harm to the significance of a designated heritage asset, that this harm should be outweighed by the public benefits of the proposal. This includes, where appropriate, securing its optimum viable use.

In assessing the proposals, MOLA have concluded in their Heritage Assessment that there is less than substantial harm caused to the setting of the heritage assets identified, and that this harm is at the lower end of the threshold.

Given that it is considered that the proposals will lead to ‘less than substantial harm’, Paragraph 196 of the NPPF will be applied in the assessment and the harm should be weighed against the public benefits of the proposal including, where appropriate securing

39 its optimum viable use. Page

Planning Practice Guidance (PPG) notes that public benefits may follow from many developments and could be anything that delivers economic, social or environmental objectives as described and set out within the NPPF.

The scheme at Canons Park is considered to deliver a significant amount of public benefit PLANNING ASSESSMENT which, in our view, will outweigh the less than substantial harm caused to the setting of the Registered Park and Garden and the conservation area. The following are considered to be the key areas of public benefit generated by these proposals: Social

 Delivery of 118 high quality affordable homes in a sustainable, mixed and balanced new community. These homes will contribute to the overall housing need within Harrow and the London-wide housing market. The units are tenure blind and designed to be of the highest quality, including a mix of tenures to meet local need.

 The delivery of high quality public realm which will integrate into and improve the existing landscape.

 Enhancements to the entrance of Canons Park, through the inclusion of a raised table to access the park and improvements to the route to Canons Park from Whitchurch Lane. Environmental

 The proposals significantly reduce the quantum of commuter car parking on site which will reduce the level of car traffic in this location. This will contribute to promoting wider sustainable objectives and will encourage modal shift to more sustainable modes of transport including cycling and pedestrian.

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 Inclusion of a dedicated cycle hub providing cycle parking infrastructure which will further contribute to sustainability objectives and modal shift.

Further to the NPPF, the Draft London Plan (Policy HC1) also states that developments affecting heritage assets and their settings should conserve their significance, by being sympathetic to their significance and surroundings. As is set out in the previous section the design of the development has been carefully curated to respond to and reflect the immediate context.

Developments should also identify assets of archaeological significance and use this information to avoid harm or identify appropriate mitigation measures. Policy CS1 of the LBH Core Strategy and DM7 of the Local Plan echo the key principles of Policy HC1.

The archaeology assessment concludes that there is generally low potential of the site to contain significant archaeological assets. As such, no mitigation measures are required.

Therefore, whilst there is a level of harm caused, this is considered to be less than substantial and would be outweighed through the public benefits associated with the scheme. The development has considered the wider heritage context and has been designed to reflect and be sympathetic to the local context. Townscape

A TVIA was carried out by Landscape Visual, which involved an initial desk study on potential townscape and visual receptors.

40 The Townscape and Visual Impact Assessment has regard to the policies contained within

the Draft London Plan on Tall Buildings (D9) which states that proposals should consider the Page long-range views, mid-range views and immediate views. The assessment provides a commentary on the impact of the proposals.

In terms of the height of the proposals, the TVIA remarks that although this will be a marked

change from the predominantly two storey buildings in the surrounding area, the impact on PLANNING ASSESSMENT the setting of the heritage assets is considered to have less than substantial harm. Mitigating factors include the gaps between the three proposed blocks reducing the impact on the skyline, as well as the dense and mature vegetation to the north of the site and in the fringes of Canons Park. TRANSPORT AND ACCESS

The proposals seek to deliver a car-free residential development in a highly accessible and sustainable location. The proposals will deliver wheelchair accessible residents’ parking in line with the Draft London Plan, with a total of four spaces delivered on implementation of the scheme and a further eight being made available should the need arise.

The proposals also include the provision of an on-site Car Club bay which will be provided for the use of incoming residents, the location which can be secured by way of legal agreement.

The station car park will re-provide 60 car parking spaces, including six wheelchair accessible parking spaces and 6% will feature electric vehicle charging points.

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located within the ground floor of Building A and comprises space for circa 100 cycle parking spaces for use by visitors and commuters.

The implementation of a car-free scheme is also considered to be acceptable and planning policy states that car-free should be the starting point for all development proposals in well- connected locations. The site is very well connected with a PTAL of 3, located approximately 100m north of Canons Park Underground Station and numerous bus stops on Whitchurch Lane.

WSP confirm in the Transport Assessment that the cycle parking for residents and commuters are policy compliant and that the proposed delivery and servicing arrangements from Donnefield Avenue will be able to accommodate the full need of the development.

The Transport Assessment also states that the development will not negatively impact on surrounding pedestrian, cycle and public transport networks nor the operation of the local highway network due to the overall reduction in vehicle movements.

The assessment demonstrates that the location of the site benefits from easy access to both walking and cycling facilities, as well as public transport provision, by both buses and the underground. WSP is satisfied that a (residential) car-free development can be sustained in this area without detrimental impacts on the existing on-street parking, as the area is already covered by Controlled Parking Zones.

The Transport Assessment provides an analysis of the Active Travel Zone and applies the Healthy Streets principles set out in the Draft London Plan (Policy T2), the proposals reduce

41 the dominance of vehicles on the street and provide an active landscape which promotes

active travel methods. Page

A Framework Travel Plan has also been prepared by WSP and submitted as part of this application. This will be implemented for the residential development, in order to promote sustainable transport modes amongst residents to and from the site. PLANNING ASSESSMENT A Car and Cycle Parking Management Plan will also be implemented, in order to manage the private and public parking, and to ensure that mechanisms are in place to provide the 10% accessible car parking (3% active and 7% passive) that is required by the Draft London Plan.

The proposals are wholly in accordance with the policies contained within the relevant national, regional and local policy framework which are seeking to encourage and facilitate a modal shift in means of transport, away from private car use and towards more sustainable methods of transport such as walking, cycling and public transport (Draft London Plan Policy T6). SUSTAINABILITY AND ENERGY

A substantive benefit of the scheme includes the opportunity to deliver a sustainable new development in line with the Draft London Plan. An Energy Strategy and Sustainability Report has been prepared in support of the application, setting out the key measures which are employed to achieve the required sustainability targets set out in national and local policy.

The proposed development will use Air Source Heat Pump (ASHP) technology to address the policies within the Draft London Plan, achieving a 26% improvement in the ‘Be Green’ stage of the relevant London Plan Policy (SI 2). In addition to this a further 22% improvement is achieved in the ‘Be Lean’ stage of the policy, with an overall 49%

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improvement on Part L (2013) of the Building Regulations which is in line with the 35% requirement that is set out within the Draft London Plan (Policy SI 2).

In line with policy SI 2, the remaining shortfall will be addressed through a cash in lieu contribution to be secured via the S106 Agreement.

Opportunities to connect the planned development to existing or future decentralised heat distribution networks have been investigated with reference to the London Heat Map. No such networks exist or are planned in the vicinity of the proposed development and therefore a centralised proposal has been pursued (Policy SI 3).

It is considered that the proposed development is in line with the relevant policies on sustainability and energy and the scheme will deliver a highly sustainable new development. FLOOD RISK AND DRAINAGE

The site is located in Flood Zone 1, and therefore has a low (less than 0.1%) annual probability of flooding. Paragraph 163 of the NPPF states that an appropriate Flood Risk Assessment (FRA) is required for all development proposals of 1 ha or greater, in Flood Zone 1. As the site measures 0.64 ha, a full FRA is not required.

Price and Myers have therefore prepared a report summarising the flood risk as well as a sustainable drainage strategy, including a detailed sustainable urban drainage system (SUDS) assessment, using the Harrow SUDS proforma.

42 The report concludes that the site is at low risk from flooding from all sources, and that the development proposals significantly reduce surface water runoff rates from the site. Water Page attenuation measures such as blue roofs, permeable paving, below ground cellular storage and a tree pit will attenuate surface water up to 1.95l/s, up to the 1 in 100 year rainfall event, plus 40% climate change. In terms of drainage, a new connection to the foul and

surface water sewer will be construction in Donnefield Avenue, which will be secured PLANNING ASSESSMENT through the Section 106 Agreement.

As such, the report concludes that the proposals have an acceptable flood risk within the terms and requirements of the NPPF and are therefore considered to be policy compliant. The proposals use appropriate sustainable drainage measures to control the rate and volume of surface water run-off to achieve the required Harrow standard of 5 l/s per hectare (Policy DM10). AMENITY Daylight and Sunlight

GIA have advised the applicant and KCA throughout the design process, in relation to light matters. They have undertaken daylight, sunlight and overshadowing analysis and have prepared three Daylight and Sunlight Report that are submitted with this application.

Impact on neighbouring properties

As set out in the report, it is essential to consider the existing context of the site (as an open space with no existing structures which has been allocated for residential development) when determining what level of changes in light are acceptable.

The report concludes that the overall retained daylight and sunlight values, the site context and the benefit of the proposals outweigh the ‘harm’ identified by the BRE methodology,

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which is not considered to have a detrimental impact. Therefore, the proposals are considered to be in accordance with the relevant national, GLA and local planning policies.

In addition, the report concludes that when considering overshadowing, each of the five identified amenity spaces will comply with the BRE Guidelines for Sun Hours on Ground (SHOG) assessment.

Internal Daylight and Sunlight

An Internal Daylight/Sunlight Report has also been carried out to assess the proposed residential development, the conclusions of this report demonstrate the following:

 The proposed development performs very well, with 85% of the rooms meeting or exceeding the levels of Average Daylight Factor;

 In terms of sunlight, 84% of the living rooms within 90 degrees of due south meet or exceed the guidelines set out within BRE’s guidance;

 The proposed amenity spaces within the development have all been tested and both spaces perform well, exceeding BRE’s recommendations.

Given the proximity to the railway line an assessment of solar glare has been undertaken, this concludes that the development will not give rise to any instances of solar glare.

It is considered that this demonstrates that the proposed development achieves a high standard of amenity and provides adequate light within the proposed development and is

therefore in accordance with Policy DM1. Page Noise

Paragraph 180 of the NPPF, Policy D14 of the Draft London Plan and Policy DM12 (Sustainable Design and Layout) of the Local Plan set out the requirements for measuring, mitigating and managing noise impacts, both internal and external. PLANNING ASSESSMENT A Noise and Vibration Assessment has been carried out at the site by ACCON, and a detailed noise model has been prepared for the proposed development.

The initial site noise risk assessment has identified that the site is generally of a low noise risk during the daytime and a medium noise risk during the night. The report has identified a range of noise mitigation measures which have been incorporated into the proposals.

In terms of internal noise levels, the report states that internal noise levels within the flats during the day would be considered to be reasonable with open windows for ventilation. At night-time, the noise levels would exceed the target, due to the frequency of train services. Again, a number of mitigation measures were suggested an incorporated into the development to ensure compliance.

In terms of the vibration assessment, the report concludes that vibration mitigation measures will not be required for this site.

As such, in terms of noise and vibration, we are satisfied that the proposals accord with the relevant planning policies (Policy DM1). Microclimate

A pedestrian level wind assessment of the proposed development has been carried out to assess the amenity spaces within the proposed development, this report assesses the communal spaces at ground level as well as the proposed private amenity spaces which take the form of balconies.

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The private balconies delivered within the development are suitable for their intended use in most cases, and where there are transgressions these are minor and do not impact upon safety.

The proposed amenity spaces within the development were also tested and found to be suitable for their intended use.

It is therefore considered that the microclimate of the development is suitable for intended use and will not have any adverse impacts on the surrounding area. Air Quality

The Air Quality report prepared by ACCON assesses the impacts of the proposed development on air quality and the air quality constraints on the development proposals. In terms of operational impact, the report states that the proposed development is not expected to contribute an increase to vehicle trips on the local road network, as the traffic generated will be offset by the overall reduction in station car parking movements. Therefore, the proposed development will have no impact on air quality and no mitigation measures are required. As such, the proposals are considered to be compliant with the relevant planning policy requirements (DLP Policy GG3 and DLP Policy SI 1). LANDSCAPING, PUBLIC REALM AND BIODIVERSITY

The proposals include a carefully curated landscape and public realm design, created by Townshend Landscape Architects and developed through the extensive consultation, as

outlined in Section 6.0 above. The design was developed to create successful amenity space 44

for residents, deliver high quality play space, to improve the public realm and to create a Page

gateway to the adjacent park. The key principles of the design are:

 Applying the TfL Healthy Streets guidance;  Creating comfortable and safe amenity spaces to provide a new, improved character and ambiance; PLANNING ASSESSMENT

 Enabling moments for informal play within everyday life;  Creating moments for social interaction between neighbours and locals; and  Designing comfortable spaces where people will want to spend time and socialise. The key character areas of the landscape design are the social street (Donnefield Avenue), the pocket park at the park entrance, the semi-private Community Garden and the plant buffering to provide an improved buffering and enhancing biodiversity adjacent to the SINC.

The proposals will deliver 274sqm of amenity space including play space for residents. The provision of play space delivers the required quantum in line with the LB Harrow requirements which require 4sqm of playable space to be provided per child (Policy DM 19). The Draft London Plan Policy S4 requires that developments deliver 10sqm of playable space for children. Due to the constraints of the site, there is a shortfall against the Draft London Plan. The site is, however, immediately adjacent to Canons Park which includes dedicated play space which is less than 500m from the development.

The proposals incorporate private amenity space for each proposed unit in line with policies in the Draft London Plan, which require 5sqm of amenity space for 1-2 person dwellings with an additional 1sqm being provided for each additional resident.

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As is noted above, the proposals incorporate a high quality and standard of public realm both within the development and along Donnefield Avenue. This incorporates elements of the TfL Healthy Streets guidance including play on the way and incidental planting. The public realm delivered is accessible and inclusive whilst drawing on contextual elements from Canons Park to integrate into the existing streetscape. The public realm proposals are considered to be wholly in accordance with Draft London Plan Policy D8.

Ecological

The Site is located immediately east of a designated SINC which forms the railway boundary. Middlemarch have carried out an Ecological Impact Assessment, which provides an overview of the effects on ecological features that may result during the construction and operational phases of the proposed development.

The adjacent railway embankment has the potential to support foraging and commuting bats and also reptiles. The Site itself is also considered to offer suitable habitat for nesting birds. Foraging terrestrial mammals, including badger and hedgehogs may occasionally pass through the Site.

The report sets out the following recommendations, in order to mitigate impacts and provide improvements:

 Implementation of a Construction Ecological Management Plan (CEcMP);  Implementation of a Biodiversity Enhancement and Management Plan (BEMP);

45  A Lighting Strategy;

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 Implementation of habitat creation proposals including street planning, herbaceous planting, green roofs, lawn and small sections of hedgerows;

 The provision of refugia/hibernacula; and PLANNING ASSESSMENT  Management of the woodland edge adjacent to the SINC, to provide a suitable combination of basking/refuge habitat for reptiles.

As set out in the report, these measures have been implemented through the Landscape and Public Realm Strategy prepared by Townshend Landscape Architects, and the Lighting Strategy prepared by AECOM. The additional CEcMP and BEMP are considered to be appropriate to be secured by way of planning condition.

The report concludes that, provided all recommended avoidance and mitigation measures are implemented, and compensation and enhancement are delivered, the predicted ecological effects can either be avoided entirely or reduced to negligible significance.

We are satisfied that all of these measures have been incorporated into the proposals, as demonstrated above, and as such the proposals are considered to be compliant with the relevant planning policy at the national, regional and local level.

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9.0 Planning Obligations and CIL

SECTION 106 PLANNING OBLIGATIONS

Section 106 of the Town and Country Planning Act 1990 allows the entering into of an obligation, by agreement or otherwise, between the local planning authority and any person interested in the land for the purposes of:

(a) Restricting the development or use of the land in any specified way; (b) Requiring specified operations or activities to be carried out in, on, under or over land;

(c) Requiring the land to be used in any specified way; or (d) Requiring a sum or sums to be paid to the local planning authority (or, in a case where section 2E of the 1990 Act applies, to the Greater London Authority) on a specified date or dates periodically.

Regulation 122 of the Community Infrastructure Levy Regulations (2010) states that planning obligations may only constitute a reason for granting planning permission for the development if the obligation is:

(a) Necessary to make the development acceptable in planning terms; (b) Directly related to the development; and (c) Fairly and reasonably related in scale and kind to the development.

Paragraph 54 of the NPPF states that ‘Local planning authorities should consider whether 46 otherwise unacceptable development could be made acceptable through the use of Page

conditions or planning obligations’. Paragraph 56 reinforces the requirement that planning

obligations meet the tests set out in regulation 122 of the CIL Regulations. D CIL AN

Discussions are ongoing with the LB Harrow regarding the proposed s106 obligations associated with the development at Canons Park. At the time of planning submission the following are the proposed Draft Heads of Terms for the scheme: PLANNING OBLIGATIONS  Affordable housing;  Carbon offset payment;  Design contribution;  Travel Plan;  Highways improvements;  Car Club;  Controlled Parking Zone survey and review;  Biodiversity enhancements;  Play space contribution;  Landscaping management and maintenance;  Public art;  Employment and training; and,  Legal costs, administration and monitoring.

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9.0 Planning Obligations and CIL

COMMUNITY INFRASTRUCTURE LEVY

Under the terms of the Planning Act 2008 (as amended) and Community Infrastructure Regulations 2010 (as amended), the Mayor of London’s Community Infrastructure Levy (MCIL2) and Harrow Community Infrastructure Levy (HCIL) will be chargeable on this application commencement. This will be calculated in accordance with the Mayor’s and Harrow’s adopted Community Infrastructure Levy Charging Schedules at the point of determination of that application. London Borough of Harrow CIL

The London Borough of Harrow CIL Charging Schedule was adopted in September 2013 and is applied to certain uses over 100sqm gross internal floor space. The schedule includes a £110sqm CIL rate for residential uses (Use Class C3). The CIL Regulations 2010 (as amended) provide relief from the levy on those parts of a chargeable development which are intended to be used as affordable housing (as defined by CIL Regulation 49). Mayoral CIL

The Mayoral CIL2 Charging Schedule was adopted in January 2019, and came into effect on 1 April 2019. Harrow is in ‘Band 2’ of the charging bands, and the rate for all development is £60. Social housing is exempt from MCIL, under the Planning Act 2008 and the Community Infrastructure Levy Regulations 2010.

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AND CIL

PLANNING OBLIGATIONS

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10.0 Summary and Conclusion

This Planning Statement has been prepared in support of the full planning application submitted to LB Harrow for the redevelopment of the Site at Canons Park London Underground Station, on Donnefield Avenue.

The application seeks approval for the redevelopment of the existing commuter car park to deliver 118 affordable residential units along with a proportion of retained commuter car parking, TfL Cycle Hub (for public use), landscaping improvements and associated public realm. The description of development is as follows: “Redevelopment of existing public car park to provide new residential accommodation (Use Class C3) and flexible ground floor space and a public car park along with associated works”.

This Planning Statement has assessed the provisions of the NPPF and the Development Plan. It is considered that the proposed development fully accords with the Development Plan, representing sustainable development in accordance with the NPPF. The proposed residential use wholly accords with policies which encourage the optimisation of sustainable, accessible, brownfield sites for high quality residential accommodation. The proposals are inclusive of a range of tenure types, all of which are affordable products in line with the definitions within the relevant policy documents.

The full impacts of the development have been assessed and any mitigation required has been identified within the supporting technical reports and summarised within this Statement.

48 It is considered that there are numerous key benefits that arise from the proposals, including: Page

 The provision of 118 residential units in a sustainable location which will support the ON overall housing need and requirements within the London Borough of Harrow.

 The provision of a 100% affordable housing scheme which will provide genuinely

affordable housing meeting the needs of local residents and creating a mixed and SUMMARY AND CONCLUSI balanced community. This will be provided as a mix of London Affordable Rent and Shared Ownership.

 A significant reduction in commuter car parking which supports the overarching Mayoral Transport Strategy and will seek to promote and encourage sustainable modes of travel whilst retaining quantum of wheelchair accessible spaces.

 The introduction of a secure Cycle Hub providing dedicated cycle parking for the local community and commuters from further afield.

 A highly sustainable design that sets a high standard for future developments.  A high-quality building that has been designed with character to respond to its local context.

Therefore, in accordance with Section 38(6) of the Planning and Compulsory Purchase Act (2004), it is considered that this application accords with the local Development Plan for LB Harrow. The NPPF presumption in favour of sustainable development should be applied in full, and the application approved without delay.

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APPENDICES SUMMARY AND CONCLUSI

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The below provides a summary of the key relevant planning policies:

LOSS OF CAR PARKING

 Draft London Plan Policy H1 (Increasing Housing Supply) recognises that boroughs should optimise the potential for housing delivery on all suitable and available brownfield sites. In addition, it states that mixed-use redevelopment of car parks and low-density retail parks and supermarkets should be encouraged.

PRINCIPLE OF RESIDENTIAL

 Within the Core Strategy (2012) Harrow Council has outlined a housing requirement of a minimum of 3,250 new homes on previously-developed land across the Borough between 2009-2026), which excludes the Harrow and Wealdstone Intensification Area.

 London Plan Table 3.1 (Annual average housing supply monitoring targets 2015-2025) highlights a minimum target of 5,927 new homes between 2015 and 2025.

 Draft London Plan has identified that the LBH has a 10-year housing target (2019/20- 2028/29) of 8,020 net housing completions and 3,750 completions on smaller sites (below 0.25 hectares).

 Draft London Plan Policy H1 (Increasing Housing Supply) sets out guidelines to ensure the ten-year housing targets are met. The policy states boroughs should optimise the potential for delivering housing on all suitable and available brownfield sites through

50 development plans and planning decisions, especially sites with existing or planned PTAL levels between 3-6 or located with 800m of public transport. Page

 London Plan Policy 3.7 (Large Residential Developments) encourages large residential development proposals in areas of high public transport accessibility. PLANNING POLICIES  London Plan Policy 3.8 (Housing Choice) states that all Londoners should have a genuine choice of homes which are affordable and can meet local requirements for different types and sizes of homes.

 Policy DM2 (Achieving Lifetime Neighbourhoods) states that new residential APPENDIX A: RELEVANT development must ensure good access to services and facilitates, and provide accessible homes, whilst being safe and secure. The developments must demonstrate how they contribute to the creation of lifetime neighbourhoods within and beyond the site boundary. Affordable Housing

 NPPF Paragraph 61 sets out that the context, size, type and tenure of housing needed for different groups in the community should be assessed and reflected in planning policies.

 NPPF Paragraph 62 states when affordable housing is identified to be need, policies should specify the type of affordable housing required and require it to be met on-site unless the provision off site or financial contributions in lieu can be robustly justified and the agreed approach contributes to the objective of creating mixed and balanced communities.

 NPPF Paragraph 64 outlines that where major development involves housing, policies and decisions should expect at least 10% of affordable housing, as part of the overall affordable housing contribution from the site unless it would exceed the level of

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affordable housing required in the area of prejudice the ability to meet the identified needs.

 NPPF Paragraph 122 states that planning policies and decisions should support development that makes efficient use of land, taking into account:

a) The identified need for different types of housing and other forms of development, and the availability of land suitable for accommodating it;

b) Local market conditions and viability; c) The availability and capacity of infrastructure and services – both existing and proposed – as well as their potential for further improvement and the scope to promote sustainable travel modes that limit future car use;

d) The desirability of maintaining an area’s prevailing character and setting (including residential gardens), or of promoting regeneration and change; and

e) The importance of securing well-designed, attractive and healthy places.  Draft London Plan Chapter GG4 (Delivering the homes Londoners need) states that to create a housing market that works better for all Londoners, within planning and development it must ensure more homes are delivered, support the delivery target of 50% of new homes being genuinely affordable, create inclusive and mixed communities whilst ensuring good quality and high standard designs and provide for identified needs.

51  Policy CS1 J (Housing) states that the council will aim for a Borough wide affordable Page housing target of 40%, based on housing numbers delivered from all sources of supply

across Harrow (between 2009 and 2026). In addition, the council will seek the maximum reasonable amount of affordable housing on all development sites with a capacity to provide ten or more homes (gross). The following would be taken into PLANNING POLI CIES

consideration in the decision; the availability of public subsidy, the need to promote housing mix and choice, the priority accorded to family affordable housing in both the London Plan and the Council’s Housing Strategy, the size and type of affordable

housing needed, the site circumstances and other scheme requirements, development APPENDIX A: RELEVANT viability and the need to meet the borough wide 40% target.

 London Plan Policy 3.9 (Mixed and Balanced Communities) encourages communities to be mixed and balanced by tenure and household income through developments which foster social diversity, redress social exclusion and strengthen communities’ sense of responsibility form and identity with, their neighbourhoods. In addition, a more balanced mix of tenures is encouraged across London.

 London Plan Policy 3.11 (Affordable Housing Targets) outlines the London wide target of an annual average of at least 17,000 more affordable homes in London over the term of the plan. Moreover, to deliver a more diverse and strong intermediate housing sector, 60% of affordable should be social and affordable rent and 40% for intermediate rent or sale. Albeit, priority should be accorded to provision of affordable family housing.

 London Plan Policy 3.10 (Definition of Affordable Housing) outlines the parameters of affordable housing. It states that affordable housing is social rented, affordable rented and intermediate housing that is provided to eligible households whose needs are not met by the market.

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 Development Management Policies (6.5) states that Harrow applies the London Plan affordable housing mix. Therefore, there is a target of 60% social / affordable rent and the remaining 40% intermediate products.

 The Harrow Planning Obligations SPG sets out the following mix targets for social and intermediate housing:

Size Social / Affordable Intermediate

1B2P 12% 20%

2B4P 48% 50%

3B5P / 6P 28% 20%

4B6P – 8P 7% 10%

5B10+P 5% -

 Draft London Plan Policy H4 (Delivering affordable housing) states that affordable housing targets are a key strategic issue for London and the strategic target for genuinely affordable housing for all new homes delivered across London is 50%. The plan sets out the following measures to achieve this including; requiring major developments that trigger affordable housing requirements to provide the need through the threshold approach and the use of grants to increase the provision of affordable

52 housing beyond the level that would be otherwise provided. Page

 Draft London Plan Policy H4 outlines that to meet the affordable housing need of circa 43,500 homes per year, as recognised in the 2017 Strategic Housing Market Assessment, the policy recognises the need for increased affordable housing

contributions from all sources. It is expected that all schemes maximise the delivery of PLANNING POLICIES

affordable housing and make use of available resources efficiently.

 Draft London Plan Policy H4 states that all major developments over 10 units trigger requirements for affordable housing, whilst minor housing developments within some APPENDIX A: RELEVANT boroughs may be required to contribute to affordable housing. All schemes are expected to meet the threshold of affordable housing without a grant or public subsidy and to increase the proportion through grants and other subsidies. Where clear barriers to the delivery of affordable housing are evident, through detailed viability, should a lower level of affordable housing be considered.

 Draft London Plan Policy H5 (Threshold approach to applications) outlines the threshold approach to viability in order to increase certainty and delivery of affordable housing. The policy states that schemes that meet or exceed the threshold without public subsidy and consistent with the threshold approach requirements are not required to submit viability information. The threshold level of affordable housing on gross residential development is initially set at a minimum of 35% affordable housing and 50% on public sector land where there is no portfolio agreement with Mayor.

 Draft London Plan Policy H6 (Affordable housing tenure) identifies the split of affordable products to be applied to residential development. It states that there should be a minimum of 30% low cost rented homes (either London Affordable Rent or Social Rent) and a minimum of 30% intermediate products which meet the definition of genuinely affordable housing, including; London Living Rent and London Shared Ownership. The

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remaining 40% can be determined by Harrow as either low cost rented homes or intermediate products, based on the identified needs of the borough. Housing Mix

 Core policy CS1 I (Housing) sets out that new residential development shall result in a mix of housing in relation to type, size and tenure within neighbourhoods across the borough. This should include a range of affordable housing tenures including social and affordable rent, intermediate, shared ownership and shared equity.

 Core strategy policy CS1 J highlights the council’s aim of 40% affordable housing across the borough from all sources of supply. Affordable housing will be required on sites with the capacity to deliver 10 or more homes.

 Core strategy policy CS 7 (Stanmore & Harrow Weald) outlines that the council will bring forward Stanmore Car Park and Anmer Lodge together for comprehensive, mixed use development that contributes to the vitality and viability of the district centre and makes appropriate contributions to the housing supply.

 Policy DM 24 (Housing) stipulates that proposals which secure an appropriate mix of housing on site and contribute to the creation of inclusive and mixed communities will be supported. The appropriate mix of housing will be determined having regard to the target mix for affordable housing, the priority to be afforded to the delivery of affordable family housing and the location of the site, character of the surrounding area and the need to optimise housing output on previously-developed land.

 Draft London Plan Policy H10 (Housing size mix) states that developments should Page

generally consist of a range of unit sizes. In order to determine the appropriate unit mix, the following should be taken into consideration; robust local evidence of demand, the need to deliver inclusive and mixed neighbourhoods, the need to deliver a range of PLANNING POLICIES

price points for different unit types, the mix of uses, range of tenures, the location of the site, (with a higher proportion of smaller units closer to town centres and stations) and the role of smaller units in freeing up family housing.

HERITAGE APPENDIX A: RELEVANT

 NPPF paragraph 8 outlines that a key environmental objective to achieving sustainable development is to contribute to protecting and enhancing our natural, built and historic environment.

 NPPF paragraph 189 sets out that planning authorities should require an applicant to describe the significance of any heritage assets affected, including any contribution made by their setting. Where a site on which development is proposed includes, or has the potential to include, heritage assets with archaeological interest, local planning authorities should require developers to submit an appropriate desk-based assessment and, where necessary, a field evaluation.

 NPPF paragraph 196 outlines that development proposals leading to less than substantial harm to the significance of a designated heritage asset, this harm should be weighed against the public benefits of the proposal including, where appropriate, securing its optimum viable use.

 Core strategy policy CS1 C states that proposals that would harm the significance of heritage assets including their setting will be resisted and the enhancement would be supported and encouraged.

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 London Plan Policy 7.8 (Heritage Assets and Archaeology) requires that development affecting heritage assets and their settings should conserve their significance, by being sympathetic to their form, scale, materials and architectural detail.

 London Plan Policy 7.4 (Local Character) outlines that development should have regard to the form, function, and structure of an area, place or street and the scale, mass and orientation of surrounding buildings.

 Policy CS1(Overarching Policy) requires for new development to enhance heritage assets, and which do not harm the significance of heritage assets including their setting.

 Policy DM2 (Achieving Lifetime Neighbourhoods) states the sensitive adaptation of heritage assets that contribute to the creation of lifetime neighbourhoods will be supported.

 Draft London Plan Policy HC1 (Heritage conservation and growth) states that development plans and strategies should demonstrate understanding of the historic environment and the heritage values of sites or areas and their relationship with the surroundings. This knowledge should be used to inform the effective integration of London’s heritage in regenerative change by:

1) setting out a clear vision that recognises and embeds the role of heritage in place-making

2) utilise the heritage significance of a site or area in the planning and design

process 54

3) integrating the conservation and enhancement of heritage assets and their Page settings with innovative and creative contextual architectural responses that contribute to their significance and sense of space

4) delivering positive benefits that conserve and enhance the historic environment, PLANNING POLICIES

as well as contributing to the economic viability, accessibility and environmental quality of a place, and to social wellbeing.

 Draft London Plan Policy HC1 additionally notes that development proposals affecting APPENDIX A: RELEVANT heritage assets and their settings should conserve their significance by being sympathetic to the assets’ significance and appreciation within their surroundings. Moreover, heritage asses and their settings should be actively managed from the cumulative impacts of incremental change from development. Opportunities to integrate heritage in the design process should be considered early on.

 Policy DM7 (Managing Heritage Assets) supports proposals that secure the preservation, conservation or enhancement of a heritage asset and its setting, or which secure opportunities for sustainable enjoyments if the historic environment. Moreover, when considering proposals within the conservation area; the council will support the redevelopment of sites that detract from the character or appearance of the conservation area; and exploit opportunities to restore lost features or introduce new ones that would enhance the character and appearance of the conservation area.

 Policy DM6 (Areas of Special Character) states that proposals that affect an area of special character will be considered having regard to:

a. The impact of the proposal upon the strategic value of the area of special character;

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b. The desirability of preserving or enhancing the environmental, architectural, historic and landscape features that contribute to the area of special character;

c. The protected views to and from areas of special character.  Stanmore and Edgware Conservation Area SPG (2013) states that to ensure Stanmore and Edgware’s townscape and built character is preserved or enhanced states that development should respect the existing layout and historic form of the townscape and street scene, especially its building lines and heights, and not diminish the gap between buildings. In addition, it should complement and respect existing properties and areas of open space in terms of bulk, scale and siting.

DESIGN

 NPPF Paragraph 127 requires that planning decisions should ensure developments meet the following criteria:

a) Will function well and add to the overall quality of the area, not just for the short term but over the lifetime of the development;

b) Are visually attractive as a result of good architecture, layout and appropriate and effective landscaping;

c) Are sympathetic to local character and history, including the surrounding built environment and landscape setting, while not preventing or discouraging

appropriate innovation or change (such as increased densities); 55

d) Establish or maintain a strong sense of place, using the arrangement of streets, Page spaces, building types and materials to create attractive, welcoming and distinctive places to live, work and visit;

e) Optimise the potential of the site to accommodate and sustain an appropriate PLANNING POLICIES

amount and mix of development (including green and other public space) and support local facilities and transport networks; and

f) Create places that are safe, inclusive and accessible which promote health and APPENDIX A: RELEVANT well-being, with a high standard of amenity for existing and future users; and where crime and disorder and the fear of crime, do not undermine the quality of life or community cohesion and resilience.

 Draft London Plan Policy D1 (London’s form, character and capacity for growth) states that boroughs should undertake area assessments to define the characteristics, qualities and value of different places within the plan area to develop an understanding of different areas’ capacity for growth. Area assessments should cover elements such as; housing types and tenure, urban form and structure, historical evolution and heritage assets, views and landmarks.

 Draft London Plan Policy D1 sets that development plans should follow the design led approach to identify optimised site capacities for site allocations. Therefore, boroughs are encouraged to set acceptable building heights, scale, massing and indicative layouts for allocated sites.

 Draft London Plan Policy D3 (Optimising site capacity through the design-led approach) recognises that consideration of design options to determine the most appropriate form of development that responds to a site’s context and capacity for growth, and existing and planned supporting infrastructure capacity. Moreover, development proposals should enhance local context through the delivery of buildings and spaces which

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positively respond to local distinctiveness. This can be achieved through layout, orientation, scale, appearance and shape, regarding the existing and emerging street context and character.

 Draft London Plan Policy D4 (Delivering good design) requires that development proposals referable to the Mayor must have undergone at least one design review early on in their preparation.

 Core Policy CS1 K outlines that the council will require a high standard of residential design and layout consistent with the London Plan and associated guidance. Moreover, mixed tenure schemes there should be a consistent standard of design and layout. The policy states that all new homes must meet ‘Lifetime Home’ standards and at least 10% must achieve the enhanced ‘Wheelchair Home’ standards.

 Policy DM1 (Achieving a High Standard of Development) requires all development to achieve a standard of design and layout. Moreover, the assessment of the design and layout will have regard to;

− The massing, bulk, scale and height of the proposed buildings in regard to the location, surrounding area and impact on neighbouring occupiers;

− The appearance of the proposed buildings, including but not limited to detailing, roof form, architectural inspiration, materials and colour, entrances, windows and external services;

− The context of the surrounding buildings and character of the local area and pattern 56

of development; Page

− Appropriate provision of space around the building for landscaping as a resource for occupiers to secure privacy and amenity;

− PLANNING POLICIES The need to retain or enhance existing landscaping, trees, biodiversity and other natural features of merit;

 Policy DM 12 (Sustainable Design and Layout) outlines the design and layout guidelines for new development. This should be: APPENDIX A: RELEVANT a) Utilise natural systems such as passive solar design and, wherever possible, incorporate high performing energy retention materials, to supplement the benefits of traditional measures such as insulation and double glazing;

b) Make provision for natural ventilation and shading to prevent internal overheating; c) Incorporate techniques that enhance biodiversity, such as green roofs and green walls (such techniques will benefit other sustainability objectives including surface water attenuation and the avoidance of internal and urban over-heating); and

d) Where relevant, the design and layout of buildings should incorporate measures to mitigate any significant noise or air pollution arising from the future use of the development.

 London Plan Policy 3.5 (Quality and Design of Housing Developments) states housing development should be of the highest quality internally, externally and in relation to their context and to the wider environment. All new housing development designs should enhance the quality of local places, taking into account physical context including; local character, density, tenure and land use mix, and relationships with and provision of public, communal and open spaces, taking particular account of the needs of children, disabled and offer people. Moreover, new homes should have adequately

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sized rooms and convenient and efficient room layouts which are functional and fit for purpose, meet the changing needs of Londoners over their lifetimes, address climate change adaptation and mitigation and social inclusion objectives and should be conceived and developed through an effective design process.

 Policy 7.1 (Lifetime Neighbourhoods) requires that the design of new buildings and the spaces they create should help reinforce or enhance the character, legibility, permeability and accessibility of the neighbourhood.

 Draft London Plan Policy D5 (Inclusive design) highlights that developments should achieve the highest standards of accessible and inclusive design, taking into consideration to needs of a diverse population and provide spaces that are designed to facilitate social interaction and inclusion. In addition, development should be inclusive with no disabling barriers or prohibit individuals accessing and using the building.

 Draft London Plan Policy D6 (Housing quality and standards) outlines the standards for the housing development. It states that it should meet a high-quality design, provide adequately sized rooms, with functional and comfortable layouts and fit for purpose, meeting the needs of all tenures.

 Draft London Plan Policy D7 (Accessible housing) requires for new homes to provide a suitable housing and genuine choice to the diverse population of London. Therefore, it is required that at least 10% of dwellings should meet the standards of ‘wheelchair user dwellings’ whilst the remaining units meet building regulations for ‘accessible and

adaptable dwellings’. This is applicable for all tenures. 57

Height, Scale and Massing Page

 Draft London Plan Policy D2 (Infrastructure requirements for sustainable densities) states development density should link to planned levels of infrastructure proposed in the PLANNING POLICIES

future rather than current levels. In addition, the density levels should be proportionate to job and services connections and accessibility from the site to jobs through walking, cycling and public transport. Within the policy, several measures of density are required to be provided to help assess, monitor and compare development proposals. The measures include; the number of units per hectare, number of habitable rooms per APPENDIX A: RELEVANT hectare, number of bedrooms per hectare and number of bed spaces per hectare.

 Draft London Plan Policy D3 (Optimising site capacity through the design-led approach) states all development must make best used of the land by using a design-led approach which optimises the capacity of sites, including site allocations. The approach requires consideration of design options to establish the most appropriate form of development that responds to a site’s context and capacity for growth and that best delivers the below requirements: - form and layout - experience - quality and character

 In addition, policy D3 stipulates that in relation to density and site capacity the following measurements of density should be provided for all planning applications that include new residential units: 1. number of units per hectare 2. number of habitable rooms per hectare

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3. number or bedrooms per hectare 4. number of bedspaces per hectare.

 Draft London Plan Policy D6 (Housing quality and standards) requires development to be a high-quality design, with functional layouts and provide adequately sized rooms that are fit for purpose to meet local needs, without differentiating between tenures. The provision of dual aspect should be utilised.

AMENITY SPACE

 Policy DM1 (Achieving a High Standard of Development) requires a high standard of privacy and amenity space to be achieved for all development and change of use. Any proposal that would be detrimental to the amenity and privacy of neighbouring occupiers or fail to achieve satisfactory privacy and amenity for future occupiers of the development would be resisted.

 Policy DM 27 (Amenity Space) recognises that the provision of appropriate amenity space will be supported in residential development proposals. The appropriate form and amount of amenity space should be informed by the Mayor’s London Housing Design Guide and have regard to:

− The location and dwelling mix; − The likely needs of future occupiers of the development;

58 − The character and pattern of existing development in the area; Page

− The need to safeguard the privacy and amenity of neighbouring occupiers; − The quality of space proposed including landscaping.

 PLANNING POLICIES As stated in Policy DM 28 (Children and Young People’s Play Facilities) new residential development which increases the net child yield will be required to provide on-site children and young people’s play facilities. Where an unsatisfactory level of play facilities is provided, the council will seek a financial contribution towards the

improvement of existing play facilities within the local area. APPENDIX A: RELEVANT

 Draft London Plan Policy D6 (Housing quality and standards) outlines that where there are no higher local standards in the borough plan, a minimum provision of 5 sqm is required of private outdoor space for 1-2 person dwellings and an additional 1 sqm should be provided for every additional person. In addition, the policy states that all dwellings should have access to one or more forms of private outdoor space including a garden, terrace, roof garden, courtyard or balcony.

 Draft London Plan Policy S4 (Play and informal recreation) outlines that a minimum of 10 sqm of play space should be provided per child that provides stimulating environments, can be accessed independently from the street, forms an integral part of the surrounding neighbourhood, incorporates elements of greenery and is not segregated by tenure.

SUSTAINABILITY AND ENERGY

 London Plan Policy 5.3 (Sustainable Design and Construction) stipulates that the highest standards of sustainable design and construction should be achieved in London to improve the environmental performance of new developments and to adapt to the effects of climate change over their lifetime. Moreover, proposals should demonstrate

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that sustainable design standards are integral to the proposal, including the construction and operation, and ensure that they are considered at the beginning of the process.

 NPPF Paragraph 50 requires that new development be planned for in ways that avoid increased vulnerability to the range of impacts arising from climate change. When new development is brought forward in areas which are vulnerable, care should be taken to ensure that risks can be managed through suitable adaptation measures. Any local requirements for the sustainability of buildings should reflect the Government’s policy for national technical standards.

 NPPF Paragraph 153 requires that when determining planning applications, local planning authorities should expect development to comply with and development plan policies on local requirements for decentralised energy supply unless it can be demonstrated by the applicant, having regard to the type of development involved and its design, that this is not feasible or viable. Developments should also take account of landform, layout, building orientation, massing and landscaping to minimise energy consumption.

 Policy DM 13 (Decentralised Energy Systems) supports development with decentralised energy networks and developments that are connected to existing decentralised energy networks where possible.

 Policy DM 14 (Renewable Energy Technology) requires developments to incorporate

renewable energy technology where feasible. 59

 Draft London Plan Policy SI 2 (Minimising greenhouse gas emissions) requires that Page major development should be net zero-carbon. This means reducing carbon dioxide emissions from construction and operation, and minimising both annual and peak energy demand in accordance with the following energy hierarchy: PLANNING POLICIES

Be lean: use less energy and manage demand during construction and operation Be clean: exploit local energy resources (such as secondary heat) and supply energy efficiently and cleanly. Development in Heat Network Priority Areas should follow the APPENDIX A: RELEVANT heating hierarchy in Policy S13 Energy Infrastructure. Be green: generate, store and use renewable energy on site.

 London Plan Policy 5.5 (Decentralised Energy Networks) outlines the Mayor expectations for 25% of the heat and power used in London to be generated through the use of localised decentralised energy systems by 2025. Therefore, the Mayor prioritises the development of decentralised heating and cooling networks at the development and area wide levels.

 Policy DM12 (Sustainable Design and Layout) requires for the utilisation of natural systems such as possible solar design and incorporate high performing energy retention materials where possible to supplement the traditional measures. In addition provisions should be made for natural ventilation and shading. Moreover design that enhances biodiversity such as green roofs and green walls will be encouraged.

Biodiversity

 Draft London Plan Policy GG2 (Making the best use of land) provides that development must protect and enhance London’s open spaces, including Metropolitan Open Land, and promoted the creation of new green infrastructure and urban greening, including aiming to secure net biodiversity gains where possible.

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 Draft London Plan Policy G5 (Urban Greening) states that major development proposals should contribute to the greening of London by including urban greening as a fundamental element of site and building design. This should be achieved by incorporating measures such as high-quality landscaping, green roofs, green walls and nature-based sustainable drainage. The Urban Greening Factor model has been developed to identify the appropriate amount of urban greening required in new developments. Boroughs should tailor the model to local circumstances but in the interim, a target score of 0.4 is set for developments that are predominantly residential.

 London Plan Policy 5.10 (Urban Greening) states that urban greening will be promoted and supported, including planting in the public realm and multifunctional green infrastructure to contribute to the adaption to, and reduction of the effects on climate change. In addition, developments should incorporate green infrastructure from in initial design process to contribute to urban greening. Elements include; tree planting, green roofs and walls and soft landscaping.

 Policy DM 20 (Protection of Biodiversity and Access to Nature) states that proposals should not be detrimental to locally important biodiversity or increase local deficiencies in access to nature. In addition, new development design and layout should retain and enhance any significant existing features of biodiversity value within the site. Appropriate mitigation should be sought to avoid potential impacts on biodiversity.

 Policy DM 20 states that replacement features of equivalent biodiversity should be provided where loss of a significant existing biodiversity is unavoidable either on site or

60 through contributions towards the implementation of relevant projects within Harrow’s Biodiversity Action Plan. Page

 Policy DM 21 (Enhancement of Biodiversity and Access to Nature) states that opportunities to enhance locally important habitats and to support locally important PLANNING POLICIES

species will be sought in accordance with the Harrow Biodiversity Action Plan. In addition, where possible, proposals should secure the restoration and re-creation of significant components of the natural environment as part of the design and layout of development. Particular attention will be paid to: APPENDIX A: RELEVANT − Green corridors and green chairs, including the potential to extend or add to the network;

− Gardens, including planting for wildlife, green roofs and green walls; − Landscaping, including trees, hedgerows of historical or ecological importance and ponds;

− Allotments; and − Habitat creation, such as nesting and roosting boxes, especially when replacing an old building that provided certain habitats.

FLOOD RISK AND DRAINAGE

 NPPF Paragraph 163 requires local planning authorities to ensure that development do not increase flood risk elsewhere when determining planning applications. Where appropriate, applications should be supported by a site-specific flood-risk assessment.

 London Plan Policy 5.13 (Sustainable Drainage) requires development to utilise sustainable urban drainage systems (SUDS) unless there are practical reasons for not doing so and should aim to achieve greenfield run-off rates and ensure that surface

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water run-off is managed as close to its source as possible in line with the following drainage hierarchy: 1. store rainwater for later use 2. use infiltration techniques, such as porous surfaces in non-clay areas 3. attenuate rainwater in ponds or open water features for gradual release 4. attenuate rainwater by storing in tanks or sealed water features for gradual release 5. discharge rainwater direct to a watercourse 6. discharge rainwater to a surface water sewer/ drain 7. discharge rainwater to the combined sewer.

 Draft London Plan Policy SI13 (Sustainable drainage) requires that development proposals should aim to achieve greenfield run-off rates and ensure that surface water run-off is managed as close to its source as possible.

 Policy DM 10 (On Site Water Management and Surface Water Attenuation) requires that new development proposals make provisions for the installation and management of measures for the efficient use of mains water and the control and reduction of surface water run off. In addition, the design and layout of major development proposals will be required to:

a. Use appropriate sustainable drainage measures to control the rate and volume of 61 surface water run-off; Page

b. Ensure separation of surface and foul water systems; c. Make reasonable provision for the safe storage and passage of flood water in excessive events; and PLANNING POLICIES

d. Demonstrate adequate arrangements for the management and maintenance of measures used.

TRANSPORT APPENDIX A: RELEVANT

 NPPF Paragraph 110 requires that applications for development should: a) Give priority first to pedestrian and cycle movements, both within the scheme and with neighbouring areas; and second - so far as possible – to facilitating access to high quality public transport, with layouts that maximise the catchment area for bus or other public transport services, and appropriate facilities that encourage public transport use;

b) Address the needs of people with disabilities and reduced mobility in relation to all modes of transport;

c) Create places that are safe, secure and attractive – which minimise the scope for conflicts between pedestrians, cyclists and vehicles, avoid unnecessary street clutter, and respond to local character and design standards;

d) Allow for the efficient charging of plug-in and other ultra-low emission vehicles in safe, accessible and convenient locations.

 NPPF Paragraph 111 set out that all developments that will generate significant amounts of movement should be required to provide a travel plan, and the application

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Appendix A: Relevant Planning Policies

should be supported by a transport statement or transport assessment so that the likely impacts of the proposal can be assessed. Highways

 London Plan Policy 6.1 (Strategic Approach) supports patterns of development that reduce the need to travel by car and supports development that generates high level of trips at locations with high levels of public transport accessibility.

 London Plan Policy 6.3 (Assessing Effects of Development on Transport Capacity) sets out that development proposals should ensure that impacts on transport capacity and the transport network, at both a corridor and local level, are fully assessed. Development should not adversely affect safety on the transport network.

 Draft London Plan Policy T4 (Assessing and mitigation transport impacts) requires that transport assessments should be submitted with development proposals to ensure that any impacts on the capacity of the transport network (including impacts on pedestrians and the cycle network), at the local level, network-wide and strategic level, are fully assessed.

 Policy DM 42 (Parking Standards) states for the design and layout of parking areas to be safe, secure and fit for purpose. In addition, access to and from the public highway should maintain and where necessary improve safety whilst giving priority to the convenience of cyclists and pedestrians.

Car Parking 62

 Policy DM 42 (Parking Standards) requires on-site car parking provision to meet the Page maximum London Plan standards. The policy states for every 20 car parking spaces, 1 motorcycle/ scooter space should be provided; applicable to development with more than 10 parking spaces having a minimum of 1 space. PLANNING POLICIES

 The policy (DM 42) also outlines that where the provision of car parking spaces is not consistent with the London Plan, it will be assessed in relation to any operational requirements, special safety considerations and the desire to achieve a modal shift away from private car use. APPENDIX A: RELEVANT

 Draft London Plan Policy T6 (Car parking) encourages for car parking to be restricted in line with levels of existing and future public transport accessibility and connectivity. Car free development is recommended to be the starting point for all development proposals in well-connected places near to public transport, however provision for disabled parking should still be required. In addition, the policy states that 0.5 spaces should be provided at all residential developments in Outer London Opportunity Areas.

 Draft London Plan Policy T6.1 (Residential Parking) requires development of over 10 units to provide a minimum of 3% of dwellings at least one designated disabled persons parking bays per dwelling to be available from the outset. Additionally, it is required that an additional 7% can be demonstrated which could be provided for future residents if required.

 London Plan Policy 6.13 (Parking) states developments should ensure that 1 in 5 spaces (both active and passive) provide an electrical charging point to encourage the uptake of electric vehicles, provide sufficient disabled parking and meet minimum cycle parking standards. In addition, the policy states that in places with high public transport accessibility, car-free developments should be promoted albeit still providing disabled spaces.

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Appendix A: Relevant Planning Policies

 London Plan Policy 6.13 (Parking) outlines in table 6.2 (Car Parking Standards) that in urban locations with a PTAL rating of 5-6, up to one space per unit is required. The maximum requirements for unit types are as follows; 4 or more beds, up to 2 spaces per unit; 1.5 spaces per unit for 3 beds, 1-2 beds less than 1 space per unit.

Cycle Parking

 Policy DM 42 (Parking Standards) stipulates the provision of cycle parking spaces would meet or exceed the minimum London Plan standards.

 London Plan Policy 6.9 (Cycling) states development should provide secure, integrated, convenient and accessible cycle parking facilities

 London Plan Policy 6.9 (Cycling) requires development to provide sure, integrated, convenient and accessible cycle parking facilities in line with the minimum cycle parking standards set out below (and in Table 6.3): Long stay: 1 space per studio and 1-bedroom unit, 2 spaces per all other units. Short stay: 1space per 40 units.

 Draft London Plan Policy T5 (Cycling) requires development to secure the provision of appropriate levels of cycle parking which should be fit for purpose, secure and well- located. Cycle parking should be in accordance with the minimum cycle parking

standards set out below: 63

Long stay: 1 space per studio or 1 person 1-bedroom dwelling, 1.5 space per 2 Page person 1 bedroom dwelling and 2 spaces per all other dwellings. Short stay: 5 to 40 dwellings requires 2 spaces, thereafter 1 space per 40

dwellings. PLANNING POLICIES

AMENITY

Privacy and Amenity Considerations APPENDIX A: RELEVANT

 Policy DM1 (Achieving a High Standard of Development) requires all development to achieve a high standard of privacy and amenity and must not be detrimental to the privacy and amenity of neighbouring occupiers or fail to achieve satisfactory privacy and amenity for future occupiers of development.

 The policy outlines the considerations when assessing privacy and amenity provisions: a) The prevailing character of privacy and amenity in the area and the need to make effective use of land;

b) The overlooking relationship between windows and outdoor spaces; c) The distances between facing windows to habitable rooms and kitchens; d) The relationship between buildings and site boundaries (applying the Council’s 45- degree code where relevant);

e) The visual impact of development when viewed from within buildings and outdoor spaces (applying the Council’s 45-degree code where relevant);

f) The adequacy of light and outlook within buildings (habitable rooms and kitchens) and outdoor spaces (applying the Council’s 45-degree code where relevant);

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Appendix A: Relevant Planning Policies

g) The adequacy if internal layout of buildings in relation to the needs of future occupiers and any impact on neighbouring occupiers;

h) The impact of proposed use and activity upon noise, including hours of operation, vibration, dust, air quality and light pollution; and

i) The need to provide a satisfactory quantum and form of amenity space for future occupiers of residential development. Daylight sunlight

 Draft London Plan Policy D6 (Housing quality and standards) outlines that development should provide sufficient daylight and sunlight to new and surrounding housing that is appropriate for its context, whilst avoiding, minimising overshadowing and maximising the usability of outside amenity space. Noise

 NPPF Paragraph 180 set out that new development should be appropriate for its location, taking into account the likely effects of pollution on health, living conditions and the natural light. This requires that development mitigate and reduce to a minimum, the potential adverse impacts resulting from noise. Ensuring that noise giving rise to significant adverse impacts on health and the quality of life is avoided.

 London Plan Policy 7.15 (Reducing and Managing Noise, Improving and Enhancing the Acoustic Environment and Promoting Appropriate Soundscapes) requires that

64 development proposals manage noise by mitigating and minimising the existing and potential adverse impacts of noise on, from, within, as a result of, or in the vicinity of Page new development without placing unreasonable restrictions on development.

 Draft London Plan Policy D14 (Noise) requires development proposals to manage noise PLANNING POLICIES

by avoiding significant adverse impacts on health and quality of life and by mitigating and minimising the existing and potential adverse impacts of noise on, from, within, as a result of, or in the vicinity of new development without placing unreasonable restrictions on development. APPENDIX A: RELEVANT  Policy DM12 (Sustainable Design and Layout) highlights that the design and layout should incorporate measures to mitigate any significant noise or air pollutions arising from the future use of the development. Wind and Micro climate

 London Plan Policy 7.6 (Architecture) sets out that development should not cause unacceptable harm to the amenity of surrounding land and buildings, particularly residential buildings, in relation to privacy, overshadowing, wind and microclimate. Air Quality

 Paragraph 181 of the NPPF sets out that planning decisions should sustain and contribute towards compliance with relevant limit values or national objectives for pollutants, taking into account the presence of Air Quality Management Areas and Clean Air Zones, and the cumulative impacts from individual sites in local areas. Opportunities to improve air quality or mitigate impacts should be identified, such as through traffic and travel management, and green infrastructure provision and enhancement.

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Appendix A: Relevant Planning Policies

 NPPF Paragraph 103 requires that development should be focused in sustainable locations, limiting the need to travel. Opportunities to improve air quality or mitigate impacts should be identified.

 GLA Sustainable Design and Construction SPG (Mayor of London, 2014) requires that an air quality neutral assessment be undertaken using the latest information about the proposed development.

 London Plan Policy 7.14 (Improving Air Quality) requires that development minimise increased exposure to existing poor air quality and make provisions to address local problems of air quality.

 Draft London Plan Policy SI1 (Improving air quality) sets out that development proposals should use design solutions to prevent or minimise increased exposure to existing air pollution and make provision to address local problems of air quality. Particular care should be taken with developments that are in Air Quality Focus Areas or that are likely to be used by large numbers of people particularly vulnerable to poor air quality, such as children or older people.

LANDSCAPING AND PUBLIC REALM

 Policy DM 22 (Trees and Landscaping) requires for development to include soft and hard landscaping. The design must be appropriate to the character of the area and well laid out in regard to access, car parking and living conditions for future occupiers and

neighbours. In addition, there should be sufficient space for new or existing trees and 65

planting to grow whilst supporting biodiversity. Page

 Draft London Plan Policy D8 (Public realm) states that proposals should create new public realm and it should be encouraged and explored where appropriate. The public realm should be inclusive and accessible in design to all, whilst being well-designed PLANNING POLICIES and in keeping to the surrounding area. Moreover, green infrastructure should be incorporated to support rainwater management through sustainable drainage, reduce exposure to air pollution, moderate surface and air temperature and increase

biodiversity. APPENDIX A: RELEVANT

Page

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APPENDIX A: RELEVANT