Planning Committee 20/09/2017 Schedule Items 03 & 04

Ref: (A) 172221LBC and (B) 172220FUL

Address: TWYFORD ABBEY, TWYFORD ABBEY ROAD, PARK ROYAL NW10 7DR

Proposal: (A) Demolition of three-storey infill extension on western elevation, demolition of three-storey extension on eastern elevation, demolition of single-storey infill extension on southeast elevations, demolition of the gatehouse lodge and other structures on-site; internal works to repair and refurbish Twyford Abbey; external works to repair and refurbish the exterior surfaces of Twyford Abbey; repair and refurbishment of the walled garden; construction of single-storey building within the walled garden; construction of two part three-storey, part four storey buildings within the curtilage of the listed building; construction of single storey building with swimming pool within the curtilage of the listed building; construction of two gatehouses to provide ancillary offices and accommodation; tree works; boundary treatments, hard and soft landscaping including the provision of a multi-use games area; and access and parking provision associated with the redevelopment of the site for use as a secondary and sixth form school (D1 Use Class) (Listed Building Consent)

(B) Redevelopment of the site for use as a secondary and sixth form school (D1 Use Class) involving the construction of two part three-storey, part four storey buildings; construction of a single storey building within the walled garden; construction of a single storey building with swimming pool; construction of two gatehouses to provide ancillary offices and accommodation; exterior works to Twyford Abbey including demolition of later additions; and associated tree works, boundary treatments, hard and soft landscaping including the provision of a multi-use games area; and access and parking provision (Application for Planning Permission)

Drawing numbers: Site Location Plan 1612-PD-1000; Existing Site Plan 1612-PD-1001; Proposed Demolition Plan 1612-PD-1002 REV A; Proposed Site Plan – Ground Floor 1612-PD-1003 REV B; Proposed Site Plan – Roof 1612-PD-1004 REV B; Proposed Site Sections 1 1612-PD- 1200; Proposed Site Sections 2 1612-PD-1201; Abbey Existing Plans 1 1612-PD-AB1000; Abbey Existing Plans 2 1612-PD- AB1001; Abbey Existing Plans 3 1612-PD-AB1002; Abbey Demolition Plans 1 1612-PD-AB1005 REV A; Abbey Demolition Plans 2 1612-PD-AB1006 REV A; Abbey Demolition Plans 3 1612- PD-AB1007; Abbey Proposed Plans 1 1612-PD-AB1010 REV A; Abbey Proposed Plans 2 1612-PD-AB1011 REV A; Abbey Proposed Sections 1 1612-PD-AB1200; Abbey Proposed Sections Planning Committee 20/09/2017 Schedule Items 03 & 04

1 1612-PD-AB1201; Abbey Existing Elevations 1612-PD-AB1300; Abbey Proposed Elevations 1612-PD-AB1310; SP Proposed Plans 1 1612-PD-SP1000; SP Proposed Plans 2 1612-PD-SP1001; SP Proposed Sections 1612-PD-SP1200; SP Proposed Elevations 1612-PD-SP1300; IW Proposed Plans 1 1612-PD-IW1000; IW Proposed Plans 2 1612-PD-IW1001; IW Proposed Plans 3 1612- PD-IW1002; IW Proposed Sections 1612-PD-IW1200; IW Proposed Elevations 1612-PD-IW1300; WG Existing & Demolition Plans Ground Floor 1612-PD-WG1000; WG Existing & Demolition Plans Roof 1612-PD-WG1001; WG Proposed Plans 1612-PD-WG1010 REV A; WG Cottage and Workshop Elevations 1612-PD-WG1300 REV A; Gatehouses - Proposed Plans 1612-PD-L1000 REV B; Gatehouses - Proposed Elevations 1612-PD-L1300 REV A; AN1- Tool shed and composting area 1612-PD-AN1000; AN2 -Storage and service shed & Substation 1612-PD-AN1001; AN3- Sentry box 1612-PD-AN1002; Parking allocation Plan 70029921-SK-002 REV A

Supporting Documents: Design and Access Statement April 2017; Planning Statement May 2017; Heritage Statement May 2017; Acoustic Report and Environmental Noise Survey Issue 2 April 2017; Air Quality Assessment June 2017 and Air quality Addendum August 2017; Arboricultural Report 2 August 2017; Archaeological Statement January 2017; Bat Inspection Survey and Nocturnal Survey Version 002 October 2016; Conditions Reports (East Wing Nov 2016, Exteriors Nov 2016, Garden Wall Nov 2016 , North Wing Nov 2016 , South Wing Nov 2016, Gardeners Cottage Nov 2016, The Dairy Nov 2016, Twyford Abbey Render Nov 2016, Twyford Abbey roofscape Nov 2016, Twyford Abbey main house roof July 2017); Construction Management Plan April 2017;Delivery and Servicing Plan August 2017; Energy Statement 3 April 2017, Energy Statement Addendum 14 July 2017 and Email dated 15 August 2017; External Lighting Statement 13 April 2017; Flood Risk Assessment and Drainage Report July 2017; Ground Investigation Report August 2017; Landscape Statement April 2017; Preliminary Ecological Appraisal v002 October 2016 and MKA Ecology supporting letter dated 22 August 2017; Statement of Community Involvement April 2017; Structural Inspection Report April 2017 V4; Sustainability Report 5 April 2017 Rev 2; Transport Assessment April 2017; Travel Plan April 2017; Utilities Statement 13 April 2017; and Ventilation Statement 13 April 2017

Type of Applications: (A) Listed Building Consent; and (B) Full Application (Major)

Applications Received: 03/05/2017 Revised: 16/08/2017

Report by Katie Crosbie

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Recommendations:

(A) Grant Listed Building Consent subject to Conditions; and (B) Grant Planning Permission subject to –

1) Stage II Referral to the Mayor of London; 2) Section 106 agreement; and 3) Conditions of Consent

Executive Summary

Planning permission and listed building consent is sought to redevelop the Twyford Abbey site for use as a co-educational independent secondary school and sixth form for up to 1,150 students. This proposal would involve the restoration and reuse of the Grade II listed Twyford Abbey and Walled Garden, the latter of which would primarily accommodate the sixth form space; and the construction of four principal buildings ranging in height from single storey to part-four storeys that would accommodate the primary classroom, assembly and sports accommodation (the 'Inhabited Wall' building; the 'Sports and Community' building, the 'Walled Garden' building, and the Swimming Pool building). Ancillary structures are also proposed, namely a pair of 'gatehouses' that would provide for administration offices and security/groundskeeper living accommodation, a storage and service shed, tool shed and composting, a substation, a switch room and a sentry box. In addition the proposal includes a comprehensive landscaping scheme.

The applicant recently purchased the site in August 2017. However prior to this acquisition the site had been vacant since 1988, when the last known use as a nursing home ceased due to statutory changes in the requirements for healthcare premises. During the last thirty or so years the site has fallen into a state of significant disrepair, reflected in its inclusion in Historic England's 'Heritage-at-Risk' register as being in 'immediate risk of further rapid deterioration or loss of fabric'. Thus this heritage-led redevelopment would sympathetically restore Twyford Abbey into a viable use that would secure its removal from the 'At-Risk-Register' and enable the long-term stewardship of the wider heritage site.

Establishing the acceptability of the principle of the development requires a fine balance between the conservation of the heritage assets and the character and qualities of this designated Metropolitan Open Land (MOL), against ensuring that a viable use (and any associated facilitating development) can be secured that would ensure the long term sustainable future of the heritage assets. It is recognised that the proposals involve the construction of new school buildings and hardstanding, and would therefore constitute ‘inappropriate development’ on MOL. However these would be primarily located to the north of the site amongst the existing built development, and adjacent to the western site boundary. This is considered to be appropriate siting to minimise the impact on the open character of the MOL, and the amount and form of the development is considered to be the minimum required to ensure the proper functioning of the proposed secondary school and sixth form.

Therefore the proposed use and quantum of development is considered to be the optimum viable use that would secure the removal of Twyford Abbey from Historic England's 'Heritage-at-Risk register and ensure its long-term viability. These gains are considered to be ‘Very Special Circumstances’, and combined with the sympathetic design measures is considered to decisively outweigh the disbenefits of departing from policy that seeks to resist inappropriate development on MOL. These gains would also outweigh the ‘less than significant harm’ posed by the construction of new buildings within the settings of the heritage assets. As such, the principle of the school development on MOL and within the setting of listed heritage assets is considered to be on-balance acceptable.

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The proposals also involve a comprehensive and well considered landscape plan that seeks to restore and enhance the historic character and setting of the listed heritage assets, improve the biodiversity values on site, as well as improve the overall amenity. It is recognised that there would be some loss in woodland site coverage and the amenity value provided by established, mature trees. However on balance it is considered that the landscape proposals as a whole would contribute positively to the significance of the heritage listings, increase amenity and character values in the longer term (once planting has been established), and result in a net gain in biodiversity. The proper management of the landscape, which has been poorly lacking over the last decades, would also ensure its long-term stewardship for future generations to enjoy.

An assessment of the potential impacts on neighbouring properties has been carried out, and for reasons further discussed in the body of the report it is considered that the proposal is unlikely to result in undue impacts on residential amenity. The amenity impact most likely to arise from the scheme is the potential for noise disturbance from the change of use of a decades-long vacant site. However given the general operating times of a school, modern standards of sound insulation of building envelopes to minimise noise breakout, and pursuant to appropriate conditions of use, it is unlikely that the proposals would generate such levels of noise and disturbance that normal residential amenity would be harmed.

A total of fifty-nine (59) representations have been received in response to the proposals (both the planning application and application for listed building consent). This includes representations received from the Ealing Civic Society, the West Twyford Residents Association, The London Wildlife Trust, and the Campaign to Protect Rural England (CPRE). Three (3) representations received from neighbouring occupiers are in support of the proposal, albeit with caveats. The remaining fifty-two (52) representations from neighbouring occupiers object to the proposal. These objections predominantly concern adverse transport impacts (inadequate access, traffic congestion, parking concerns) but also the loss of MOL, woodland and trees (including ecological impacts), and impacts on residential amenity. These matters are addressed within the main body of this report.

The following report assesses the principle of the development; the potential impact on the historic significance of the listed buildings and their settings; the design and appearance of the proposed scheme; the potential impact on nature conservation; trees and landscaping; transport matters and servicing; contaminated land, air quality and noise mitigation; the potential amenity impacts on neighbouring properties; flood risk and surface water management; and energy and sustainability. It is considered that any adverse impacts resulting from development would be acceptably mitigated through conditions and S106 contributions, which would be directed towards the review and potential implementation of a controlled parking zone (CPZ); road safety measures; travel plan measures and monitoring; renewable energy monitoring; the provision of a private bus service; and the securing of a community use agreement. It is considered that the proposal on balance is consistent with the aims of the relevant planning policies, and therefore it is recommended that listed building consent should be granted with conditions, and that planning permission should be approved with conditions, subject to a legal agreement.

Recommendation (A)

That the committee GRANT listed building consent subject to the following conditions:

1. Time Limit

The development to which this consent relates must be begun no later than the expiration of three years beginning with the date on which the consent is granted.

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Reason: To comply with the provisions of Section 18(1) of the Planning (Listed Buildings and Conservation Areas) Act 1990, as amended, to prevent the accumulation of unimplemented listed building consents, and to enable the Local Planning Authority to review the situation at the end of this period if the development has not begun.

2. Approved Drawings

The development hereby approved shall be carried out in accordance with drawing title numbers: Site Location Plan 1612-PD-1000; Existing Site Plan 1612-PD-1001; Proposed Demolition Plan 1612-PD- 1002 REV A; Proposed Site Plan – Ground Floor 1612-PD-1003 REV B; Proposed Site Plan – Roof 1612-PD-1004 REV B; Proposed Site Sections 1 1612-PD-1200; Proposed Site Sections 2 1612-PD- 1201; Abbey Existing Plans 1 1612-PD-AB1000; Abbey Existing Plans 2 1612-PD-AB1001; Abbey Existing Plans 3 1612-PD-AB1002; Abbey Demolition Plans 1 1612-PD-AB1005 REV A; Abbey Demolition Plans 2 1612-PD-AB1006 REV A; Abbey Demolition Plans 3 1612-PD-AB1007; Abbey Proposed Plans 1 1612-PD-AB1010 REV A; Abbey Proposed Plans 2 1612-PD-AB1011 REV A; Abbey Proposed Sections 1 1612-PD-AB1200; Abbey Proposed Sections 1 1612-PD-AB1201; Abbey Existing Elevations 1612-PD-AB1300; Abbey Proposed Elevations 1612-PD-AB1310; SP Proposed Plans 1 1612-PD-SP1000; SP Proposed Plans 2 1612-PD-SP1001; SP Proposed Sections 1612-PD-SP1200; SP Proposed Elevations 1612-PD-SP1300; IW Proposed Plans 1 1612-PD-IW1000; IW Proposed Plans 2 1612-PD-IW1001; IW Proposed Plans 3 1612-PD-IW1002; IW Proposed Sections 1612-PD- IW1200; IW Proposed Elevations 1612-PD-IW1300; WG Existing & Demolition Plans Ground Floor 1612-PD-WG1000; WG Existing & Demolition Plans Roof 1612-PD-WG1001; WG Proposed Plans 1612-PD-WG1010 REV A; WG Cottage and Workshop Elevations 1612-PD-WG1300 REV A; Gatehouses - Proposed Plans 1612-PD-L1000 REV B; Gatehouses - Proposed Elevations 1612-PD- L1300 REV A; AN1- Tool shed and composting area 1612-PD-AN1000; AN2 -Storage and service shed & Substation 1612-PD-AN1001; AN3- Sentry box 1612-PD-AN1002; Parking allocation Plan 70029921- SK-002 REV A

Reason: For the avoidance of doubt, and in the interests of proper planning.

3. Details of Works

Notwithstanding the submitted documents, details in respect of the following shall be submitted to and approved in writing by the Local Planning Authority, in consultation with Historic England, before the relevant work is begun:

a. Details of the structural solution for the new building within the walled garden, including information regarding the current ground conditions and listed wall foundations b. Details of approach to the render repair and any necessary replacement, including technical specification and methodology, and details of any coating to be applied. c. Details of repairs to or any necessary replacement of original or early windows, as removed and stored on site as per earlier consent. Specific details required of windows with decorative timber tracery, and of any stained glass. Should replacement be accepted with any modification proposed (for example, for slim-line double glazing), a full-scale sample should be produced d. Details of repairs to or any necessary replacement of original or early doors, as removed and stored on site as per earlier consent. e. Details of proposed repair or rebuilding works to roof structures, following further information provided by Hutton and Rostron report and recommendations, and any further investigation.

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f. Details of roof structural repair and any necessary replacement works, including any changes to roof form based on identified design issues which have caused long-standing water ingress. g. Details of roof materials. h. Details of any required rebuilding to masonry walls, including explanation of structural necessity, brick samples and mortar mixes. i. Details of any intended deviations from previously agreed or existing floor structure bearings when constructing new permanent floors. j. Detailed design and materials of replacement and new staircases within the listed Abbey. k. Details of the treatment of the plaster ceiling to the former chapel within the Abbey north wing. l. Details of the restoration of a small number of principal interior schemes. m. Details of the proposed link structure.

The relevant work shall be carried out in accordance with such approved details.

Reason: To maintain and preserve the special architectural and historic interest of the listed buildings on site in accordance with policy 7C of the Ealing Development Management DPD (2013); policies 7.8 and 7.9 of the London Plan (2016); policies 1.1(h), 1.2(g) and 2.1 (c) of the Ealing Development (or Core) Strategy DPD (2012); and the National Planning Policy Framework (2012).

4. Archaeological Investigation

Prior to the commencement of the development hereby permitted, a written scheme of historic building investigation (WSI) for a recording to level 3 shall be submitted to and approved by the Local Planning Authority in consultation with Historic England. For buildings that are included within the WSI, no development shall take place other than in accordance with the agreed WSI. The WSI shall include the Statement of Significance and Research Objectives, and:

a) The programme and methodology of site investigation and recording, and the nomination of a competent person(s) or organisation to undertake the agreed works b) The programme for post-investigation assessment and subsequent analysis, publication and dissemination and deposition of resulting material. This part of the condition shall not be discharged until these elements have been fulfilled in accordance with the programme set out in the WSI.

Reason: To ensure that any archaeological remains on site and the cultural heritage of the site are protected in accordance with policy 7C of the Ealing Development Management DPD (2013); policies 1.1 (h) and 1.2 (g) of the Ealing Development Strategy 2026 DPD (2012); policy 7.8 of the London Plan (2016); and Section 12 of the National Planning Policy Framework.

5. Hidden Historic Features

Any hidden historic features which are revealed during the course of works shall be retained in situ, and any work potentially impacting on such features or their setting suspended and the Council as local planning authority notified immediately. Provision shall be made for the retention or salvage and/or proper recording of such hidden features, as required by the Council, as advised by Historic England.

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Recommendation (B)

That the committee GRANT planning permission subject to Stage II referral to the Mayor of London, the satisfactory completion of a legal agreement under Section 106 of the Town and Country Planning Act 1990 (as amended) in order to secure the following:

1. A financial contribution of £15,000 for the review and potential implementation of a Controlled Parking Zone (CPZ) on adjacent streets 2. A financial contribution of £82,000 to implement road safety measures in the vicinity of the school, comprising: new electronic school signs, zig–zag lines, yellow lines, road markings and guard railing (£12k); a raised mini-roundabout at Bodian Way/Twyford Abbey Road (£40k); wider pedestrian refuges outside Twyford Primary (£10K); and extending the raised table adjacent to the school entrance across the entire entrance (£20K) 3. A financial contribution of £10,000 to implement travel plan initiatives at the school 4. A financial contribution of £3,000 towards travel plan monitoring 5. A financial contribution of £15,584 towards the renewable energy monitoring of the ASHPs and Solar PV for a period of three years 6. The payment of a one-off ‘Carbon Dioxide Off -Setting Sum’ in the event that the carbon emissions target cannot be fully met on site 7. The requirement that the developer provide a private bus service to accommodate travel to and from the school (Monday to Friday) for at least 237 students, for a minimum period of ten years subject to a review mechanism upon expiry 8. A Community Use Agreement for the use of the Sports and Community building and MUGA 9. Provision to ensure that the restoration of Twyford Abbey is secured 10. Pay the Council’s professional and legal costs in preparing the agreement.

AND subject to the following conditions:

1. Time Limit – 3 years

The development permitted shall be begun before the expiration of three years from the date of this permission.

Reason : In order to ensure that this allocated site is brought forward for development as soon as practicable and to comply with the provisions of Section 91 of the Town and Country Planning Act 1990 (as amended).

2. Approved Plans

The development hereby approved shall be carried out in accordance with drawing title numbers

Site Location Plan 1612-PD-1000; Existing Site Plan 1612-PD-1001; Proposed Demolition Plan 1612- PD-1002 REV A; Proposed Site Plan – Ground Floor 1612-PD-1003 REV B; Proposed Site Plan – Roof 1612-PD-1004 REV B; Proposed Site Sections 1 1612-PD-1200; Proposed Site Sections 2 1612-PD- 1201; Abbey Existing Plans 1 1612-PD-AB1000; Abbey Existing Plans 2 1612-PD-AB1001; Abbey Existing Plans 3 1612-PD-AB1002; Abbey Demolition Plans 1 1612-PD-AB1005 REV A; Abbey Demolition Plans 2 1612-PD-AB1006 REV A; Abbey Demolition Plans 3 1612-PD-AB1007; Abbey Proposed Plans 1 1612-PD-AB1010 REV A; Abbey Proposed Plans 2 1612-PD-AB1011 REV A; Abbey Proposed Sections 1 1612-PD-AB1200; Abbey Proposed Sections 1 1612-PD-AB1201; Abbey Existing Elevations 1612-PD-AB1300; Abbey Proposed Elevations 1612-PD-AB1310; SP Proposed Plans 1

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1612-PD-SP1000; SP Proposed Plans 2 1612-PD-SP1001; SP Proposed Sections 1612-PD-SP1200; SP Proposed Elevations 1612-PD-SP1300; IW Proposed Plans 1 1612-PD-IW1000; IW Proposed Plans 2 1612-PD-IW1001; IW Proposed Plans 3 1612-PD-IW1002; IW Proposed Sections 1612-PD- IW1200; IW Proposed Elevations 1612-PD-IW1300; WG Existing & Demolition Plans Ground Floor 1612-PD-WG1000; WG Existing & Demolition Plans Roof 1612-PD-WG1001; WG Proposed Plans 1612-PD-WG1010 REV A; WG Cottage and Workshop Elevations 1612-PD-WG1300 REV A; Gatehouses - Proposed Plans 1612-PD-L1000 REV B; Gatehouses - Proposed Elevations 1612-PD- L1300 REV A; AN1- Tool shed and composting area 1612-PD-AN1000; AN2 -Storage and service shed & Substation 1612-PD-AN1001; AN3- Sentry box 1612-PD-AN1002; Parking allocation Plan 70029921-SK-002 REV A

Reason: For the avoidance of doubt and in the interests of proper planning.

3. Demolition and Construction Management Plan

Prior to the commencement of development (including site clearance and demolition), a site construction method statement and management plan shall be submitted to and approved in writing by the Local Planning Authority. The submission shall include the following:

a. The number of on-site construction workers and details of the transport options and parking facilities for them; b. details of construction hours; c. anticipated route, number, frequency and size of construction vehicles entering/exiting the site per day; d. delivery times and booking system (which is to be staggered to avoid morning and afternoon school-run peak periods); e. route and location of site access for construction traffic and associated signage; f. management of consolidated or re-timed trips; g. details of noise and vibration mitigation measures and monitoring arrangements for noise and vibration by suitably qualified noise specialists. Noise and vibration mitigation measures must accord with the Mayor’s 'Best Practice Guidance’, and BS 5228-1:2009 +A1:2014- Code of practice for noise & vibration control on construction & open sites-Part 1: Noise; h. details of site security, temporary lighting and the erection and maintenance of security hoarding including decorative displays and facilities for public viewing, where appropriate; i. secure, off-street loading and drop-off facilities; j. wheel washing provisions; k. vehicle manoeuvring and turning, including swept path diagrams to demonstrate how construction vehicles will access the site and be able to turn into and emerge from the site in forward gear and including details of any temporary vehicle access points; l. details as to the location(s) for storage of building materials, plant and construction debris and contractors welfare facilities and offices; m. procedures for on-site contractors to deal with complaints from members of the public; n. measures to consult cyclists, disabled people and the local schools with regard to delivery times and necessary diversions; o. details of all pedestrian and cyclist diversions; p. a commitment to be part of Considerate Constructors Scheme; q. confirmation of use of TfL's Freight Operator Recognition Scheme (FORS) or similar; r. the submission of evidence of the condition of the highway prior to-construction and a commitment to make good any damages caused during construction; s. Details of parking restrictions which may need to be implemented during construction work;

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t. An Air Quality and Dust Management Plan (AQDMP) that includes an Air Quality (Dust) Risk Assessment produced in accordance with current guidance ‘The Control of Dust and Emissions during Construction and Demolition SPG’, GLA, July 2014; and u. Details of all Non-Road Mobile Machinery (NRMM) to be used on the development site. All NRMM shall meet as minimum the Stage IIIB emission criteria of Directive 97/68/EC and its subsequent amendments unless it can be demonstrated that Stage IIIB equipment is not available. An inventory of all NRMM must be registered on the NRMM register https://nrmm.london/user-nrmm/register. All NRMM shall be regularly serviced and service logs kept on site for inspection. Records shall be kept on site which details the emissions standard of all equipment.

Prior to the commencement of any construction work, all sensitive properties surrounding the site shall be notified in writing of the nature and duration of the works to be undertaken, and the name and address of a responsible person to whom enquiries / complaints should be directed. These details shall also be displayed at regular intervals around the site construction compound.

The development shall be carried out strictly in accordance with the details so approved. Any areas to be used for the storage of building materials or other site activities outside of the relevant phase of the development shall be returned to the original condition immediately following the practical completion of the development.

Such details shall be implemented and phasing agreed in writing, prior to the commencement of works on site and thereafter retained for the duration of the works.

Reason: To protect the amenity of local residents and to ensure adequate highway and site safety in accordance with policy 7A of the Ealing Development Management DPD (2013); policies 6.3, 6.13, 7.13, 7.14 and 7.15 of the London Plan (2016); the National Planning Policy Framework (2012); Greater London Authority Best Practice Guidance 'The Control of Dust and Emissions from Construction and Demolition (2006); and BS 5228-1:2009 - Code of practice for noise and vibration control on construction & open sites-Part 1: Noise.

4. Archaeological Investigation

Prior to the commencement of the development (including site clearance and demolition), a written scheme of historic building investigation (WSI) for recording to level 3 shall be submitted to and approved by the Local Planning Authority in consultation with Historic England. For buildings that are included within the WSI, no development shall take place other than in accordance with the agreed WSI. The WSI shall include the Statement of Significance and Research Objectives, and:

a. The programme and methodology of site investigation and recording, and the nomination of a competent person(s) or organisation to undertake the agreed works b. The programme for post-investigation assessment and subsequent analysis, publication and dissemination and deposition of resulting material. This part of the condition shall not be discharged until these elements have been fulfilled in accordance with the programme set out in the WSI.

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5. Tree Protection – Demolition and Construction

No operations (including site clearance and demolition) shall commence on site in connection with development hereby approved until a revised scheme (Arboricultural Method Statement) for the protection of existing trees, shrubs and hedgerows has been submitted to and its installation on site has been approved in writing by the Local Planning Authority.

All protection measures must fully detail each phase of the development process taking into account demolition/site clearance works, all construction works and hard and soft landscaping works. Details shall include the following:

• Full survey of all trees on site and those within influencing distance on adjacent sites in accordance with BS5837*, with tree works proposals. All trees must be plotted on a site plan**, clearly and accurately depicting trunk locations, root protection areas and canopy spreads. • A plan** detailing all trees, shrubs, hedges planned for retention and removal. • Soil assessments/survey • Timing and phasing of works • Site specific demolition and hard surface removal specifications • Site specific construction specifications • Access arrangements and car parking • Level changes • Landscaping proposals • A Tree protection plan** in accordance with BS5837* detailing all methods of protection, including but not restricted to: locations of construction exclusion zones, root protection areas, fit for purpose fencing and ground protection, service routes, works access space, material/machinery/waste storage and permanent & temporary hard surfaces. • Soil remediation plans.

All tree protection methods detailed in the approved Arboricultural Method Statement shall not be moved or removed, temporarily or otherwise, until all works including external works have been completed and all equipment, machinery and surplus materials have been removed from the site, unless the prior approval of the Local Planning Authority has first been sought and obtained.

*Using the most recent revision the of the Standard ** Plans must be of a minimum scale of 1:200 (unless otherwise agreed by the Local Planning Authority)

Reason: To secure the protection during the demolition and construction phase of trees, shrubs and hedges growing within or adjacent to the site which are of amenity value to the area in accordance with policies 5.10 and 7.21 of the London Plan (2016), policy 5.10 the Adopted Ealing Development Management Development Plan Document (2013) and Ealing’s SPD9 - Trees and Development Guidelines.

6. Tree Protection – No-Dig Surfaces

No operations (including site clearance and demolition) shall commence on site in connection with development hereby approved until a suitable scheme for the installation of no-dig, 3-dimensional cellular confinement surfaces for the protection of existing trees, shrubs and hedgerows has been submitted to and its installation on site has been approved in writing by the Local Planning Authority.

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The trees requiring protection are detailed in the report Quaife Woodlands Arboricultural Survey AR/3267/jq (25 th April 2017), Section 10 – Tree Protection Measures and on Site Plan – Proposed Layout with Tree Protection Measures. Namely the identified sites: 2, 3, 5, 6, 10, 11, 15, 16 and 17.

The submitted details shall include the following: • Engineering appraisal for each location • Plan for each location

Reason: To secure the protection of trees, shrubs and hedges growing within or adjacent to the site which are of amenity value to the area in accordance with policies 5.10 and 7.21 of the London Plan (2016), policy 5.10 the Ealing Development Management DPD (2013) and Ealing’s SPG 9 - Trees and Development Guidelines.

7. Tree Protection Plan – Monitoring and Implementation

No operations (including site clearance and demolition) shall commence on site in connection with development hereby approved until a suitable program of monitoring of all approved tree protection measures has been submitted and approved by the Local Planning Authority. The monitoring program shall include the following:

a) Confirmation of who shall be the lead arboriculturalist for the development. b) Confirmation of the Site Manager, key personnel, their key responsibilities and contact details. c) Details of induction procedures for all personnel in relation to Arboricultural matters. d) A detailed timetable of events for arboricultural supervision concerning all tree protection measures named in the Tree Protection Plan, including: • Prestart meeting with an Ealing Council Tree Officer, • Initial implementation of the tree protection measures, • Installation of the House Deck system • Final removal of the tree protection measures

e) Provision of a report to Local Planning Authority detailing the result of each site visit by the lead arboriculturist. f) Procedures for dealing with variations or non-approved incursions into the construction exclusion zones as detailed in the approved Arboricultural Method Statement. g) Post development assessment of the retained and planted trees and any necessary remedial action.

The program of Arboricultural monitoring shall be taken in full compliance with the approved details. No variation of the approved monitoring program shall take place without the prior written agreement of the Local Planning Authority.

Reason: In order to safeguard trees and other vegetation considered to be worthy of retention in the interests of visual amenity for the area in accordance with policies 5.10 and 7.21 of the London Plan (2015), policy 5.10 the Ealing Development Management DPD (2013) and Ealing’s SPG 9 - Trees and Development Guidelines.

8. Nature Conservation Management Plan

A Nature Conservation Management Plan shall be submitted to and approved by the Local Planning Authority prior to the commencement of development (including site clearance and demolition). This

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Reason: To mitigate the potential harm to ecology within the green open space in accordance with policy 11 of the National Planning Policy Framework (2012), policy 7.19 of the London Plan (2015) and policy 5.4 of the Adopted Ealing Development (Core) Strategy 2012.

9. Intrustive Contaminated Land Investigation, Remediation Scheme and Verification

Prior to commencement of the development (excluding demolition and site clearance, and excluding approved tree removal subject to the discharge of Conditions 5, 6 and 7) the following shall be submitted to and subject to the approval in writing of the Local Planning Authority:

a) An intrusive contaminated land investigation and risk assessment of the site. This shall be carried out in accordance with BS1075:2011+A1:2013 and CR11 guidance to assess the nature and extent of any contamination on the site. This assessment must be undertaken by a competent person, and shall assess any contamination on the site, whether or not it originates on the site.

b) A remediation (de-contamination) scheme to bring the site to a condition suitable for the intended end use. It shall include all works to be undertaken, proposed remediation objectives and remediation criteria, timetable of works and site management procedures. The scheme must ensure that the site will not qualify as contaminated land under Part 2A of the Environmental Protection Act 1990 in relation to the intended use of the land after remediation.

Following completion of measures identified in the approved remediation (de-contamination) scheme part (b)

c) A verification report that demonstrates the completion of measures identified in the approved contamination remediation scheme shall be produced. The report shall be compiled in accordance with the Environment Agency guidance ‘Verification of Remediation of Land Contamination’, Report: SC030114/R1’.

Reason: To protect the health and living conditions of residents in accordance policy 5.21 of The Ealing Development Management DPD (2013); policy 1.1 (j) of the Ealing Development Strategy 2026 (2012); poicy 5.21 of the London Plan (2016); and the National Planning Policy Framework (2012).

10. Sustainable Urban Drainage Strategy - Detailed Design

Prior to commencement of the development hereby approved (excluding demolition and site clearance, and excluding approved tree removal subject to the discharge of Conditions 5, 6 and 7) a detailed surface water drainage design (including relevant specifications), and a maintenance plan, shall be submitted and approved in writing by the Local Planning Authority (in consultation with the Lead Local Flood Authority). The development shall be carried out strictly in accordance with the approved detailed drainage scheme.

Reason: To prevent flooding elsewhere by ensuring that sufficient storage of surface flood water is provided and achieved with appropriate sustainable drainage techniques, in accordance policies 1.1 & 1.2 of the Ealing Core Strategy (2012); policy LV 5.12 of the Ealing Development Management DPD

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(2013); policies 5.12 and 5.13 of the London Plan (2016); and the National Planning Policy Framework (2012).

11. Materials

Prior to commencement of the superstructure works details of the materials to be used for the external surfaces of the development shall be submitted to and approved in writing by the Local Planning Authority. The details shall include suitable façade glazing to minimise light trespass, glare and sky glow from internally transmitted or reflected artificial light where appropriate. This condition shall apply notwithstanding any indications as to these matters which have been given in this application. Development shall be carried out only in accordance with the approved details and permanently retained thereafter.

Reason: To ensure that the materials harmonise with the surroundings and settings of the listed heritage assets and minimise impacts on neighbouring occupiers, in accordance with policies 7.4, 7B, and 7C of the Ealing Development Management DPD (2013); policies 7.4, 7.6 and 7.9 of the London Plan (2016); and Sections 7 and 12 of the National Planning Policy Framework (2012).

12. Revised School Travel Plan

Notwithstanding the approved documents, a Revised School Travel Plan shall be submitted to and approved in writing by the Local Planning Authority prior to first occupation of the development. The details submitted shall be designed to manage the transport needs of school staff, pupils, parents, and visitors, in order to demonstrate a car restraint policy for the site, minimise car usage, promote alternative modes of transport, and rationalise servicing with the aim of reducing the total number of trips made, and especially to avoid critical times on the road network. The revised and detailed Travel Plan shall be prepared in accordance with the Transport for London Travel Plan Guidance and Ealing’s Sustainable Transport for New Development SPD in use at the time of its preparation. The development shall be carried out strictly in accordance with the approved Travel Plan.

Reason: To promote sustainable modes of transport, and to ensure that the development does not exacerbate congestion on the local road network, in accordance with policies 1.1 (f) (g) of the Ealing Development Strategy 2026 (2012); policies 6.3, 6.11 and 6.13 of the London Plan (2016); and Ealing's Sustainable Transport for New Development SPG.

Reason: To promote the use of modes of transport, other than use of private motor vehicles, in pursuance of the Council's policies on sustainability in accordance with the Council's adopted Supplementary Planning Document 'Sustainable Transport for New Development (2013)' and policy 1.1 (f) of the adopted Ealing Development Strategy (2012).

13. Parking and Servicing Management Plan

Notwithstanding the approved documents a revised Deliveries and Servicing Plan, which shall include a Parking Management Plan for all site users and visitors, shall be submitted to and approved in writing by the Local Planning Authority prior to first occupation of the development. These details shall include: • Deliveries or collections shall only occur at the School between the hours of 06:00 - 07:00, and 09:00 - 15:00, and 18:00 - 21:00 on Monday to Friday, 09:00 -18:00 on Saturdays and at no time on Sundays and Public/Bank Holidays (to avoid peak school drop-off/pickup times, the PM peak, and to minimise impacts on neighbouring amenity from noise nuisance). • Measures to rationalise servicing with the aim of reducing the total number of trips made

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• Measures to ensure that the approved disabled parking bays are retained for use by disabled visitors and staff only • Measures to ensure that the service road and parking area are kept free from unauthorised parking to allow safe access for refuse and delivery vehicles including the drop off and collection of students by private coaches/minibuses • Measures to prevent parents and/or other visitors dropping off students onsite • Other measures to manage parking demand onsite

The approved details shall be implemented prior to first occupation of the development and retained thereafter.

Reason: In the interests of the conditions of general highway safety and the free flow of traffic on the neighbouring highway and in the interests of the amenities of the locality in accordance policy 6.9 and in the adopted London Plan (2015), policy 1.1 (f) of the adopted Ealing Development (Core) Strategy (2012) and the Supplementary Planning Document ‘Sustainable Transport for New Development’ (2013).

14. Cycle Parking

Notwithstanding the submitted documents details shall be submitted prior to the first occupation of the development to demonstrate the provision of at least 175 cycle parking spaces carried out to the specifications and adopted standards of the London Plan and the Local Planning Authority.The approved details shall be brought into use prior to first occupation and retained permanently.

Reason: To ensure adequate cycle parking is provided within the development in pursuance of the objectives of sustainability and encouraging the use of modes of transport other than private motor vehicles in accordance with policy 6.9 of the London Plan (2016), policies 1.1(k) and (g) of Ealing’s adopted Development (or Core) Strategy (2012), and Ealing’s Sustainable Transport for New Development SPG.

15. Hard and Soft Landscaping (including Tree Planting) and Boundary Treatments

Notwithstanding the submitted Landscape Design Statement (prepared by Bradley-Hole Schoenaich Landscape, dated April 2017), full details of hard and soft landscaping including tree planting, and boundary treatments, shall be submitted to and approved in writing by the local planning authority prior to first occupation. These details shall make specific provision for tree planting along the western site boundary to form screening between the internal access road/vehicle parking and the adjoining residences on Brentmead Gardens. The scheme shall include comprehensive details of the full planting specifications (size, species and numbers), the positions of all planting, ground preparation for tree planting, and staking/tying methods where applicable.

The details of the hard landscaping and boundary treatments shall be implemented prior to occupation and retained thereafter. The soft landscaping details shall be laid out and planted within the first planting season following the commencement of the development or other such period as may be agreed in writing with the local planning authority. Any trees or plants which die within 5 years of planting, are removed, or become seriously damaged or diseased shall be replaced with others of the same size and species and in the same positions within the next planting season. Reason: In the interests of protecting the neighbouring amenity, general public amenity, and in ensuring appropriate planting for the site designations as metropolitan open land, nature conservation, and the setting of heritage listed assets in accordance with policies 5.10, 7.4, 7.8 and 7.21 of the London Plan

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(2015), policies 7A, 7B, 7.4, 7D and 5.10 the Ealing Development Management DPD (2013) and Ealing’s SPG 9 - Trees and Development Guidelines.

16. Air Quality – Venitilation Strategy

Notwithstanding the submitted documents, prior to the first occupation of the development details of a ventilation strategy for the ‘Inhabited Wall’ building adjacent to the North Circular Road shall be submitted to the LPA for approval, which demonstrates that the development hereby approved would be served by good levels of air quality consistent with the relevant British Standards. The approved mitigation scheme shall be implemented prior to the first occupation and retained inperpetuity.

Reason: To minimise the exposure of occupiers to poor air quality in the interests of health and good standards of accomodation, in accordance with policies 3.2, 7.6 and 7.14 of the London Plan (2016); and policy 7A of Ealing’s adopted Development Management DPD (2013).

17. Improvement to Air Quality for Users of Outdoor Sports Facilities

Notwithstanding the submitted documents, prior to the first occupation of the development details of measures to improve the air quality for users of the outdoor sports facilities adjacent to the North Circular Road shall be submitted to the LPA for approval. The approved details shall be implemented prior to the first occupation and retained inperpetuity.

Reason: To minimise the exposure of occupiers to poor air quality in the interests of health and good standards of amentiy, in accordance with policies 3.2, 7.6 and 7.14 of the London Plan (2016); and policy 7A of Ealing’s adopted Development Management DPD (2013).

18. Noise Barriers for Mixed-Use Games Area

Prior to occupation of the development, details shall be submitted to and approved in writing by the Local Planning Authority, of sound barriers (height, thickness, material, fittings and construction) to minimise the impacts of noise nuisance from the mixed-use games area to adjacent residential premises. The approved details shall be implemented prior to first use of the external sports areas and thereafter be permanently retained.

Reason: To safeguard the amenities of the occupiers of nearby residential properties, in accordance with policy 7.15 of the London Plan 2016, policy 1.1 (j) of the Ealing Development (Core) Strategy 2026 and policy 7A of the Ealing Draft Development Management Development Plan Document (2013).

19. External Lighting and Security

Notwithstanding the submitted documents, prior to first occupation of the development, details of external artificial lighting shall be submitted to and approved in writing by the Local Planning Authority. The approved details shall be implemented prior to occupation of the development and thereafter be permanently retained. Reason: To safeguard the amenities of the occupiers of nearby residential properties, in accordance with policy 7.15 of the London Plan 2016, policy 1.1 (j) of the Ealing Development (Core) Strategy 2026 and policy 7A of the Ealing Draft Development Management Development Plan Document (2013).

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20. Swimming Pool – Plant Room

Prior to the first use of the swimming pool, details shall be submitted to and approved in writing by the Local Planning Authority, of the siting, appearance, installation, operation, and maintenance of a suitable arrestment plant and extract system for the proposed swimming pool, to demonstrate no nuisance will be caused to neighbours. The approved details shall be implemented prior to first use of the swimming pool and thereafter be permanently maintained and retained. Reason: To safeguard the amenities of the occupiers of neighbouring properties in accordance with policy 7.15 of the London Plan (2015), policy 1.1(j) of the adopted Ealing Development (Core) Strategy (2012), policy 7A of the adopted Ealing Development Management Development Plan Document (2013) and Interim Supplementary Planning Guidance 10 'Noise and Vibration'.

21. Cooking Extract System

Prior to the first use of the kitchen within the development hereby approved, details of the appearance and siting of any external equipment, installation, operation, and maintenance of the best practicable cooking extract system, including the provision of a suitable extract fan and odour control equipment, shall be submitted to and approved by the Local Planning Authority. The system, as approved, shall be completed before the first use of the school kitchen and thereafter permanently retained and maintained.

Reason: In the interests of protecting the amenity of prospective and neighbouring occupiers, and also to ensure that any external equipment does not detract from the appearance of the development or the setting of the heritage assets, in accordance DEFRA, 2005: Guidance on the Control of Odour and Noise from Commercial Kitchen Exhaust Systems, policies 7.4, 7.8, 7.9 and 7.14 of the London Plan (2016) and policies 7A, 7B and 7C of the Ealing Development Management DPD (2013).

22. BREAAM Non-Residential Standards

The approved school development, including refurbished and new buildings, shall be registered with the Building Research Establishment (BRE), achieve BREEAM Rating ‘Very Good’ and make reasonable endeavours to achieve ‘Excellent’ (based on the latest BREEAM Technical guidance).

• Within 3 months of the commencement of the approved school development, Interim BREEAM Assessments and related Certifications verified by the BRE shall be submitted to the Local Planning Authority for written approval.

• Within 6 months from the date of first occupation of the approved school development, BREEAM 'Post Construction Stage' Assessments and related Certifications verified by the BRE should be submitted to the Local Planning Authority for written approval confirming the BREEAM standard and measures have been implemented.

Following any approval of a 'Post Construction Stage' assessments and certificates of the development, the approved measures and technologies to achieve the BREEAM Very Good or higher standard shall be retained in working order in perpetuity.

Reason: In the interest of addressing climate change and to secure sustainable development in accordance with policies 5.1, 5.2, 5.3, 5.6, 5.7 and 5.9 of the London Plan (2016), policies 1.1(k) and 1.2(f) of the Ealing Development Strategy 2026 DPD (2012), and policies 5.2 and 7A of the Ealing Development Management DPD (2013).

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23. Details of Appearance of PV Panels, External Plant, Services or Machinery

Notwithstanding the submitted documents details of the siting and appearance of PV panels, external plant, services and/or machinery shall be submitted to the Local Planning Authority for approval prior to installation. The development shall be implemented in accordance with the approved details.

Reason: To ensure that any plant and machinery sited on the exterior of the buildings harmonise with the appearance of the development and the setting of the listed heritage assets in accordance with policies 7.4, 7B, and 7C of the Ealing Development Management DPD (2013); policies 7.4, 7.6 and 7.8 of the London Plan (2016); and Sections 7 and 12 of the National Planning Policy Framework (2012).

24. Noise Emissions from Plant or Machinery

The rating noise level emitted from any plant, machinery or equipment, as assessed under BS4142: 2014, shall be lower than the lowest existing background sound level by at least 10dBA, as measured at the nearest and/or most affected noise sensitive premises, with all machinery operating together at maximum capacity.

Reason: To safeguard the amenities of the occupiers of neighbouring properties in accordance with policy 7.15 of the London Plan (2015), policy 1.1(j) of the adopted Ealing Development (Core) Strategy (2012), policy 7A of the adopted Ealing Development Management Development Plan Document (2013) and Interim Supplementary Planning Guidance 10 'Noise and Vibration'.

25. No Amplified Sound

No amplified music or sound (including speech) emitted from the buildings or the external areas of the development shall be audible at any residential premises, other than between the hours of 09:00 -19:00 Monday to Friday, 10:00 -17:00 on Saturdays and at no time on Sunday and Public/Bank Holidays.

26. Hours of Use for External Sports Areas / Mixed-Use Games Area

The external sports areas / mixed-use games area shall not be used by the school other than between the hours of 09:00 -18:00 Monday to Friday, 10:00 -13:00 on Saturdays and at no time on Sunday and Public/Bank Holidays.

27. Sustainable Design and Construction

Prior to first occupation of the approved school development, the approved buildings shall incorporate and maintain sustainability measures in line with the Planning Sustainability Report Rev 2 (prepared by Max Fordham LLP, dated 5 April 2017).

Reason: In the interest of addressing climate change and to secure sustainable development in accordance with policies 5.1, 5.2, 5.3, 5.6, 5.7 and 5.9 of the London Plan 2015, policies LV5.2 and 7A

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Planning Committee 20/09/2017 Schedule Items 03 & 04 of Ealing’s Development Management DPD 2013, and policies 1.1(k) and 1.2(f) of Ealing’s Development (Core) Strategy 2012.

28. Low NOx Boilers

Ultra-low NOx boilers (35 mgNOx/kWh) to serve the energy requirements of the development shall be installed as set out in the Energy Statement Addendum (prepared by Max Fordham LLP, dated 14 July 2017) and the Mayor’s Sustainable Design and Construction SPG (April 2014).

Reason: To minimise the impact of building emissions on local air quality in the interests of health, in accordance with policies 3.2 and 7.14 of the London Plan (2016); the Mayor’s Sustainable Design and Construction SPG (2014); policies 1.1(e) and (j) of Ealing’s adopted Development (or Core) Strategy (2012), and policy 7A of Ealing’s adopted Development Management DPD (2013).

29. Overheating and Cooling

The approved development, including refurbished and new buildings, shall incorporate the mitigation measures to reduce the risk of overheating in line with the approved Energy Statement (prepared by Max Fordham LLP, dated 3rd April 2017) and Energy Statement Addendum (prepared by Max Fordham LLP, dated 14 July 2017). The mitigation measures shall follow the Mayor’s Cooling Hierarchy and comply with CIBSE TM52 and TM49 criteria.

Reason: To ensure that the development is energy efficient and takes steps to reduce the risk of overheating, while reduce the need for active cooling, improve ventilation and daylighting, in accordance with policy 5.2, 5.3 and 5.9 of the London Plan (2016).

30. Energy Strategy

A. Within six months of the superstructure works of the approved school buildings, additional technical information in relation to the low carbon and renewable energy technologies proposed for the development in line with Appendix B of Ealing’s energy statement guidance and Appendix 3 of GLA’s planning guidance for preparing energy assessments, March 2016, shall be submitted to and approved in writing by the Local Planning Authority.

B. Within three-months of the practical completion of each non-residential building in the approved development, Energy Performance Certificates [EPC’s] and detailed modelling output reports including the BER and TER from the “as built stage” to confirm compliance in terms of regulated carbon dioxide emissions savings achieved through the energy efficiency measures, shall be submitted to and approved in writing by the Local Planning Authority.

C. Within three-months of the practical completion of each non-residential building evidence that the renewable/low carbon technologies are certified under the Microgeneration Certification Scheme (MSC) and, if available, complies with the Enhanced Capital Allowances (ECS) product criteria shall be submitted.

D. Prior to the final completion of the development, including refurbished and new non-residential buildings, the approved school development shall incorporate and maintain measures to achieve an overall reduction in regulated CO2 emissions of at least 63.1% (equal to at least 277.8 tonnes CO2 per year) beyond Building Regulations Part L 2013 through the following carbon emission savings as detailed in the approved Energy Statement (prepared by Max

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Fordham LLP, dated 3rd April 2017) and Energy Statement Addendum (prepared by Max Fordham LLP, dated 14 July 2017):

1. energy saving measures to achieve at least annual carbon dioxide emission savings of 126.21 tonnes CO2 equating to 29% CO2 emissions reduction in regulated carbon dioxide (CO2) emission savings over the compliant BR Part L 2013 base case. 2. incorporation of Air Source Heat Pump (ASHP) systems to achieve at least annual carbon dioxide emission savings of 146.7 tonnes CO2 equating to 46.7% in CO2 emission savings over Be Lean stage of the Mayor’s Energy Hierarchy. 3. incorporation of at least 45kWp solar PV system on the roof of the new buildings including Inhabited Wall, Sports Building and Pool to achieve at least annual carbon dioxide emission savings of 4.91 tonnes CO2 equating to 2.93% in CO2 emission savings over the ASHP base case.

E. The Developer shall future proof the proposed plant rooms of the development by allowing extra space and providing incoming service ducts to the main LTHW header pipework to facilitate future connection to an offsite QHN in accordance with the Planning Application and the approved Energy Statement Addendum (prepared by Max Fordham LLP, dated 14 July 2017) and following connection to an offsite QHN, the QHN shall supply the Development with heating, hot water and where possible, cooling requirements.

The development shall be carried out strictly in accordance with the details so approved.

Reason: To ensure that the development hereby approved is energy efficient and to contribute to the avoidance of need for new fossil fuel or other primary energy generation capacity and to reduce emissions of greenhouse gases and to minimise the impact of building emissions on local air quality in the interests of health, in accordance with policies 3.2, 5.3, 5.5, 5.6 and 7.14 of the London Plan 2015 (with FALP 2011/REMA 2013), policies 1.1(e), 1.1(j), 1.1(k) and 1.2(f) of Ealing’s adopted Development (or Core) Strategy 2012, policies LV5.2 and 7A of Ealing’s Development Management DPD, and the Mayor’s Sustainable Design and Construction SPG.

31. Renewable/Low Carbon (&CO2) Energy Monitoring

Upon final completion of the development and prior to occupation, suitable devices for monitoring either the renewable/low-carbon energy technology(ies) incorporated into the development or heat and electricity imported into the site, shall be installed. The monitored data shall be submitted to the local planning authority at daily intervals for a period of three years from final completion. The installation of the monitoring devices should be in a compatible format and the submission of the data shall be carried out in accordance with the Council's approved specifications as indicated in Automated Energy (& CO2) Monitoring Platform [AEMP] document.

Reason: To monitor the effectiveness of the renewable/low carbon energy equipment in order to confirm compliance with energy policies and establish an evidence base on the performance of such equipment in accordance with policies 5.2, 5.3, 5.5, 5.6 and 5.7 of the London Plan 2015, adopted Ealing’s Development (Core) Strategy 2026 (3rd April 2012) and Development Management DPD (December 2013).

32. Obscure-Glazed Windows – Gatehouses

Before the development hereby permitted is first occupied, the first floor window in the west-facing elevation of the Gatehouse closest to the western site boundary shall be glazed with obscure glass and

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Planning Committee 20/09/2017 Schedule Items 03 & 04 non-opening unless the parts of the window which can be opened are more than 1.7 metres above the floor of the room in which the window is installed, and shall be retained permanently.

Reason: To safeguard the amenities and privacy of the occupiers of adjoining properties in accordance with Section 7 of the National Planning Policy Framework, policy 7B of the Ealing Development Management DPD (2013), policy 1.1 (g) of the Ealing Development (Core) Strategy 2012 and policies 7.4 and 7.6 of the London Plan 2016.

33. Neutral Building Emissions

The development shall comply with the Air Quality Neutral Building Emissions benchmarks for the Class D1(c-h) use as stated in Appendix 5 of the Sustainable Design and Construction (2014) Supplementary Planning Guidance.

Reason: To ensure that the building emissions from the development does not contribute to poor air quality to the detriment of future occupiers, neighbouring occuipiers and general public health, in accordance with policy 7.14 of the London Plan (2016), policy 7A of the adopted Ealing Development Management DPD (2013), and the GLA Sustainable Design and Construction SPG (2014).

34. Electric Vehicle Charging Points

At least thirteen parking spaces for electric vehicle charging points shall be implemented prior to the first occupation of the approved development and permanently retained thereafter. At least nine of these parking spaces shall provide active charging points; and the other parking spaces shall be provided with passive charging provision.

Reason: To ensure the provision of sufficient electric car charging points in accordance with policy 6.13 of the London Plan (2016), policy 1.2(k) of Ealing Development (Core) Strategy (2012) and Ealing’s 'Sustainable Transport for New Development' SPD.

35. Vehicle Parking Arrangements

The parking arrangements for 43 vehicles (including four disabled parking bays) shown on the approved plans shall be marked out on the site prior to first occupation of the development. These spaces shall be kept continuously available and shall not be used for any other purpose. No additional car parking shall be formed or made available.

Reason: To ensure that there is adequate parking provision within the site and to ensure that excessive parking is not provided, in accordance with policies 1.1 (f) (g) of the Ealing Development Strategy 2026 (2012); policies 6.3, 6.11 and 6.13 of the London Plan (2016); and section 4 of the National Planning Policy Framework (2012).

Informatives

1. The decision to grant listed building consent* and planning permission has been taken having regard to the policies in the Ealing Development Management Development Plan Document (2013) ; the Ealing Development (Core) Strategy DPD (2012) ; the London Plan (2016) ; the National Planning Policy Framework (2012); and to all relevant material considerations including Supplementary Planning Guidance:

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National Planning Policy Framework

4 Promoting Sustainable Transport 7 Requiring Good Design 8 Promoting Healthy Communities 11 Conserving and Enhancing the Natural Environment 12 Conserving and Enhancing the Historic Environment*

London Plan (2016)

2.18 Green Infrastructure: The Multi-Functional Network of Green Space 3.1 Ensuring Equal Life Chances for All 3.16 Protection and Enhancement of Social Infrastructure 3.18 Education Facilities

5.2 Minimising Carbon Dioxide Emissions 5.3 Sustainable Design and Construction 5.9 Overheating and Cooling 5.10 Urban Greening 5.12 Flood Risk Management 5.13 Sustainable Drainage

6.3 Assessing Effects of Development on Transport Capacity 6.9 Cycling 6.11 Smoothing Traffic Flow and Tackling Congestion 6.13 Parking

7.1 Building London’s Neighbourhoods and Communities 7.3 Designing out Crime 7.4 Local Character 7.6 Architecture 7.8 Heritage Assets and Archaeology* 7.9 Heritage Led Regeneration* 7.14 Improving Air Quality 7.15 Reducing and managing noise, improving and enhancing the acoustic environment and promoting appropriate soundscapes 7.17 Metropolitan Open Land 7.19 Biodiversity and Access to Nature 7.21 Trees and Woodlands

8.2 Planning Obligations

Ealing Development (Core) Strategy (2012)

1.1 Spatial Vision for Ealing 2026 (e) (f) (h)* (j) (k) 1.2 Delivery of the Vision for Ealing 2026 (f) (g)* 5.2 Protect and Enhance Metropolitan Open Land 6.2 Social Infrastructure

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Ealing Development Management DPD (2013)

2.18 Green Infrastructure: The Network of Open and Green Spaces 5.2 Minimising Carbon Dioxide Emissions 5.10 Urban Greening 5.12 Flood Risk Management 7A Amenity 7.3 Design out Crime 7.4 Local Character 7B Design Amenity 7C Heritage* 7D Open Space

Draft Ealing Development Plan Document

Planning for Schools (2013)

Adopted Supplementary Planning Documents

Sustainable Transport for New Development (2013)

Interim Ealing Supplementary Planning Guidance

SPG 3 Air Quality SPG 4 Refuse and Recycling Facilities SPG 9 Trees and Development Guidelines SPG 10 Noise and Vibration

In reaching the decision to grant listed building consent and planning permission, specific consideration was given to the impact on and benefits to the special architectural and historic interest of the listed building and walled garden; the principle of the development, including development on metropolitan open land; the design and appearance; trees, landscaping and ecology; the potential impact on neighbouring occupiers; servicing and highway matters; environmental health; flood risk; energy and sustainability; and representations received. It is not considered that there are any other material considerations in this case that would warrant a refusal of the application.

2. Concerning the submission of a revised School Travel Plan as part of the Planning Permission (Condition 12) it is strongly recommended that the provision of afterschool clubs (to stagger the volume of trips to and from the school); and the provision of personalised travel solutions for individual students be included in the detailed measures.

3. The provisions of the s106 legal agreement that will secure a Community Use Agreement for the use of the Sports and Community building should include details of the hours of use (and a mechanism for review) to ensure that the use outside of regular school hours does not adversely impact upon the amenity of neighbouring occupiers. This agreement should not supersede any other conditions of this planning permission.

4. For Conditions 4 (Archaeological Investigation) of the Planning Permission and Listed Building Consent The written scheme of investigation will need to be prepared and implemented by a suitably professionally accredited heritage practice in accordance with Historic England’s Guidelines for Archaeological Projects in Greater London.

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Site Description

The site is comprised of the Grade II listed Twyford Abbey and walled garden (separately listed), set within approximately 5.4 hectares of grounds. The last known use of the site was as a nursing home, but this use ceased circa 1988 due to statutory changes in the requirements for healthcare premises. The site has been vacant since, and the abbey has fallen into a state of significant disrepair, reflected in its inclusion in Historic England's 'Heritage at Risk' register as being in 'immediate risk of further rapid deterioration or loss of fabric'.

The entirety of the site is designated Metropolitan Open Land (MOL), a Site of Importance for Nature Conservation (SINC), and a blanket Tree Preservation Order (TPO) covers all trees onsite. The site is also located within an Archaeological Interest Area, specifically in relation to the potential for remains of a medieval moated manor house. The majority of the site is located within Flood Zone 1 (low probability); however smaller areas in the north of the site are within Flood Zones 2 and 3 (medium to high probability) which are at risk of fluvial flooding from the River Brent.

The North Circular (A406) and Twyford Abbey Road bound the site to the north and south, respectively. To the east of the site are the rear gardens of residences on Iveagh Avenue, and West Twyford Primary School to the south-east. To the west of the site are the rear gardens of residences on Brentmead Gardens, and St Mary's West Twyford Church (another Grade II listed building).

Vehicular access to the site is via two entrances, both from Twyford Abbey Road. The Public Transport Accessibility Level (PTAL) rating for the site is '2' (poor), albeit the south-western corner of the site is '3' (moderate). The nearest tube stations to the site are approximately a 600m walk (Hanger Lane - Central Line) and 800m walk (Park Royal - Piccadilly Line).

The site was purchased by the applicant in August 2016 for the purpose of providing a senior school to accommodate Year 8 leavers of Notting Hill Preparatory School, which currently provides education to pupils from Reception (Year 4) to 13 years of age (Year 8).

Proposals

It is proposed to redevelop the site as a co-educational independent secondary and sixth form school for 1,150 pupils and 150 staff. This would involve the restoration and conversion of Twyford Abbey and the Walled Garden (and attached cottage and workshop), and the construction of four main buildings ('Inhabited Wall' building, Sports and Community building, Walled Garden building, and Swimming Pool building) with other ancillary buildings and structures (a pair of ‘gatehouses’ for ancillary administration offices and lodging for groundskeepers), storage and service shed, tool shed and composting, substation, switch room and sentry box). The proposal would also involve the demolition of later additions to Twyford Abbey, structures attached to the exterior wall of the walled garden (stables and mortuary), the entrance lodge, and other twentieth century agricultural structures.

Relevant Planning History

The planning history of the site contained within the current Council database is comprised of proposals for residential redevelopment ranging from 92 to a maximum of 400 residential units. None of these proposals have been granted planning permission or listed building consent.

The most recent decision notices issued for the site are in relation to the proposals currently under consideration. Specifically, listed building consent was granted in April this year to carry out urgent works to the Abbey to prevent further deterioration of the building fabric, and to allow safe access to

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An outline of the planning history records currently available on the Council database is as follows:

Ref. Decision Date Proposal P/2000/3718 (PP) Withdrawn 10-12-2002 Planning Permission (and associated Listed Building P/2000/3554 (LBC) Consent) sought for the redevelopment of the site to provide a total of 121 residential units, involving the restoration and conversion of the listed Abbey to provide 14 flats, the conversion of other buildings (including the gatehouse) to provide a further 10 residential units, and the construction of other buildings to provide an additional 97 residential units. The proposals also involved the demolition of buildings within the curtilage of the listed heritage assets, and internal alterations.

P/2005/0163 (SO) EIA not required 21-02-2005 Screening Opinion sought for the conversion and redevelopment of the site to provide up to 400 residential units and associated parking.

P/2005/1168 (PP) Refused 22-06-2005 Planning Permissions (and associated Listed Building P/2005/1170 (LBC) Refused 22-06-2005 Consents) sought for the restoration, conversion and P/2005/1169 (LBC) Refused 22-09-2005 redevelopment of the site to provide a total of 317 P/2005/1167 (PP) Minded to Refuse 22-09-2005 residential units (29 apartments within the listed Abbey and 288 new-build units). The proposals also involved Appeals withdrawn the demolition of extensions to the Abbey, and the removal of internal walls and alterations.

P/2009/2023 (SO) EIA not required 03-08-2009 Screening Opinion sought for the conversion and redevelopment of the site to provide up to 210 residential units and associated parking. P/2012/2620 (PP) Not determined N/A Planning Permission (and associated Listed Building P/2012/2622 (LBC) Consent) sought for the restoration, conversion and redevelopment of the site to provide a total of 92 residential units (25 units within the listed Abbey, the restoration of the gatehouse for residential use, and 66 new-build units comprised of houses and flats). The proposals also involved the demolition of demolition of extensions to the Abbey and other ancillary structures. 170678LBC (LBC) Approved with 26-04-2017 Listed Building Consent sought for Internal and Conditions external alterations (including the removal of structural elements and fabric), involving the partial demolition of timber floors and ceiling, removal and replacement of timber joists, removal of timber beams, insertion of steel beams to form a concrete deck at ground floor level, and removal of window frames and glazing. 172269SCE (SO) EIA not required 22-05-2017 Screening Opinion sought for the redevelopment of the Twyford Abbey site to provide a secondary and sixth form school

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Consultation

Public Consultation

On 12 th May 2017 a press notice was published in the Ealing Gazette, and on 10 th May nineteen (19) site notices were displayed on Brentmead Gardens, Twyford Abbey Road and Iveagh Avenue.

Fifty-one (51) representations were received in response to the application for planning permission, and eight (8) were received in response to the application for listed building consent, albeit the matters raised apply to the overall proposed scheme (a total of 59 representations received). These figures include representations from the Ealing Civic Society, the West Twyford Residents Association, The London Wildlife Trust, and the Campaign to Protect Rural England (CPRE) - which are all outlined separately in the table further below.

Objections to the Proposals

Fifty-five (55) representations received from neighbouring occupiers object to the proposals based on the following summarised matters:

• Inadequate access – Twyford Abbey Road has a very narrow access routes at both end, difficult to exit Twyford Abbey Road to Hanger Lane Gyratory or Abbey Road. • Increased traffic to an already highly trafficked and congested location • There are existing high levels of on-street parking from the existence of the West Twyford Primary School and Nursery, employment and commercial uses which cause anti-social parking issues, which will be exacerbated by the proposed school development and would extend to weekends • Opposed to a fee-paying school. The area needs a state secondary school to accommodate local children • The site is holy land • Loss of heritage • Loss of woodland and trees protected by a Tree Preservation Order • Loss of Metropolitan Open Land (MOL) • Loss of ecological value • The proposed school is overdevelopment and will accommodate too many students (1150 pupils and 150 staff) • Loss of privacy to residential properties abutting the application site • Extent of proposed internal roads within the site is excessive • Use of the school at weekends and for sporting events would result in parking congestion, noise disturbance and light pollution to the neighbouring residents • Crime would increase • Loss of the residential character of the area • Increased air pollution

Planning Officer's Response : The nature of the school as fee-paying, and the previous use of the land as a monastery are not matters strictly within the remit of the assessment of the planning and listed building consent applications. All other matters are addressed throughout the body of this report.

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In Support of the Proposals

Three (3) representations received from neighbouring occupiers were in support of the proposal, with caveats as summarised as follows:

• There should be an access from A406 (North Circular) and be restricted to staff cars only (i.e. no student or goods vehicles). • There should be some facilities or activities for the local community • A school would be an excellent use of the site, but not at the scale proposed. • There should be a Controlled Parking Zone (CPZ) and the road linking Twyford Abbey Road and Lakeside Drive (which is bus only route) should be opened to help with parking and congestion issues. • Traffic lights should be installed on the exit of Twyford Abbey Road onto Hanger Lane. • Increase the time between the existing traffic lights on Hanger Lane. • Install red light cameras on Hanger Lane traffic lights

Planning Officer's Response : The suggestions made in relation to transport infrastructure have been noted, however the suggested access from the North Circular (managed by TfL) would cause traffic safety concerns; the opening up of Lakeside Drive would inappropriately create rat running traffic; it’s considered unnecessary to introduce red lights at the site entrance; and the traffic lights on Hanger Lane are managed by TfL and monitored and adjusted as necessary. It is noted however that a financial contribution has been sought to review the need for a CPZ, and implement as necessary. In relation to suggestions for facilities or activities for the local community, the applicant has agreed to a ‘Community Use Agreement’, the details of which would be secured through the proposed S106 legal agreement.

Representations from Residents Association and Amenity Groups

The comments received from the Ealing Civic Society, the West Twyford Residents Association, the London Wildlife Trust, and the Campaign to Protect Rural England (CPRE) are outlined as follows:

Ealing Civic Society Supports this enabling development in principle as it would result in the restoration of the long derelict Twyford Abbey site, which is highly commendable. However, we have reservations about the designs of the new buildings, which we consider could have been more sympathetic to the context within which they sit. It is therefore important that the conservation officer has an input into consideration of the design to ensure that the proposed structures will not detract from the listed buildings

Planning Officer's Response :

Amendments to the proposals, specifically to the proposed Garden Wall building, and the pair of gatehouse have been secured. The impact of the new build components is assessed within the following section titled ‘Impact on the Historic Significance of the Listed Buildings and their Settings’, and is considered acceptable.

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West Twyford Residents Association Supports a school use as the most appropriate use of the site, given the past applications. However, strongly urges that some aspects of the proposal are revisited to lessen its impact.

We have serious reservations regarding the impact of 1150 students would have on the local community in general, with respect to essential services, transport and the environment.

Transport issues predominate in an area, which already suffers from high traffic and parking densities. Consequently, we suggest that the option of a coach/bus drop-off zone in Lakeside Drive be given serious consideration. This has a two- fold benefit as it removes the pressure of traffic in Twyford Abbey Road (TAR) and utilises a lightly used road, as only essential services traffic is permitted through Bodiam Way, the link road to TAR.

Should this option be adopted then the necessity for the ‘Coach loop’ and car parking through the wooded area on the TA site would be removed. This would ensure that the essential elements of the woodland would be preserved together with the added benefit of maintaining the trees with TPOs.

Raise concerns over the loss of MOL.

Planning Officer's Response :

Comments and suggestions made in relation to transport infrastructure have been considered and where appropriate financial contributions have been sought to implement highway safety improvements (including yellow lines), parking restrictions and a review of CPZ need etc. These are detailed in the section of this report outlining the proposed heads of terms to be secured through the s106 agreement. Other matters are addressed throughout the body of this report.

London Wildlife Trust Objects to the proposed development in the following grounds:

• The proposed development is highly likely to damage the interest and/or reduce the functionality of the site’s designation as a Site of Borough Importance for Nature Conservation (SINC). • Much of the site had already been stripped of its vegetation prior the Preliminary Ecological Appraisal being undertaken, giving a poorer overall value than its SINC designation would indicate. • The bat surveys are not comprehensive enough as the surveys were restricted to certain areas. Much of the broad-

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leaved woodland areas do not appear to have been effectively surveyed. • The proposed development will significantly reduce the wildlife valuable habitat on site and this is not adequately mitigated for.

Planning Officer's Response :

The ecological impacts of the proposal are assessed within the section titled ‘Impact on Nature Conservation’, and are considered acceptable.

Campaign to Protect Rural England Objects to the proposals on the following basis:

• That they are expanding unnecessarily onto protected Metropolitan Open Land and that the swimming pool and other new buildings could be configured to minimise loss of space. • The MOL protection should clearly be retained given this is the only green space in a wide area. However, the encroachment, and the siting of the swimming pool in particular – as it is away from the other buildings – compromises the protected status of the land now and in future: a) The siting of the new buildings in the development could be used to argue a case to remove the MOL designation on the basis that it is no longer open. b) There is the likely outcome that there will be future applications to ‘fill in’ between the buildings which would mean the loss of open land entirely. • That the early indications are that the woodland is being lost and that every effort must be made to retain environmentally valuable trees and wildlife habitat.

Requests that the applicant is asked to modify the proposals to take account of these issues, in particular to configure the new buildings so they are not dispersed around the site to minimise loss of protected land; and to retain the woodland and concomitant habitat.

Planning Officer's Response :

The impact of the proposal on MOL and landscape/ecology is considered in the sections titled ‘The Principle of the

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Development’, ‘Impact on Nature Conservation’, and ‘Trees and Landscape’. On balance the potential impacts are considered acceptable. The proposed siting of the buildings is considered the most appropriate locations, as discussed in the aforementioned sections of the report.

Internal Consultation

Transport Services No objection , subject to conditions concerning the submission of a revised travel plan, delivery and servicing management plan, construction management plan; and details on cycle parking and electric vehicle charging points; and s106 contributions for:

• £15,000 for the review and potential implementation of a Controlled Parking Zone (CPZ) on adjacent streets • £82,000 to implement road safety improvements within the vicinity of the school • £10,000 to implement travel plan initiatives at the school • £3,000 towards travel plan monitoring

Planning Officer's Response : Noted, and all recommendations have been accepted and included in this report.

Heritage Consultant No objection , subject to conditions requiring the submission of details concerning:

The Abbey • External treatment and appearance of walls, roof, doors, fenestration, rainwater goods, and walls exposed by the demolition of extensions • Detailed design of the proposed bridge link • Internal treatment and methods of joinery, wall finishes, staircases, and features to be retained

Walled Garden • Identification of sections of wall to be re-built, the re- use of existing bricks, new bricks to match, and details of bonding and pointing • Proposed walled garden building – details of external materials, further details of the visual exposure of the garden wall, details of structural attachment to garden wall and foundations • Detailed works to cottage concerning the roof, fenestration, door, and external brickwork

New Buildings • Details of materials, including fenestration • No plant and machinery without consent

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Landscape • Details of hard and soft landscaping, boundary treatment, lighting and signage

Planning Officer's Response : Noted, and all recommendations have been accepted and included in this report.

Education Services No objection

Environmental Services Refuse No objection

Lead Local Flood Officer No objection , subject to conditions concerning the submission of a detailed SUDS design and maintenance plan

Planning Officer's Response : Noted, and all recommendations have been accepted and included in this report.

Energy and Sustainability Officer No objection , subject to conditions requiring compliance with the submitted documents concerning BREEAM standards, sustainable design and construction, the use of low NOx boilers, overheating and cooling, the energy strategy and energy monitoring; and s106 obligations as follows: • £15,584 for energy monitoring • The payment of a ‘Carbon Dioxide Off -Setting Sum’ in the event that the emissions target cannot be fully met on site

Planning Officer's Response : Noted, and all recommendations have been accepted and included in this report.

Landscape Services No objection . The proposed landscaping is well thought out.

Planning Officer's Response : Noted. A condition has also been included in this report requiring the submission of a Nature Conservation Management Plan.

Pollution-Technical Officers No objection , subject to conditions concerning:

Air Quality - Revised construction management plan; revised ventilation strategy for the proposed 'Inhabited Wall' building adjacent to the North Circular; and detailed measures to improve air quality for users of the proposed outdoor sports facilities adjacent to the North Circular.

Noise Mitigation - Revised construction management plan; restrictions on the levels of noise emissions from plant and machinery, and music and amplified sound; regularisation of hours of operation and deliveries and collections; details of sound barriers to minimise noise impacts from sporting activities on adjacent residential properties; and sound insulation of the building envelopes. Page 30 of 56

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Odour Control - Details of suitable arrestment plant and extraction system for the proposed swimming pool; and details of suitable extraction and odour control system for non- domestic kitchen.

Light Pollution - Details of external lighting scheme; and details of suitable facade glazing to minimise light trespass, glare and sky glow from internally transmitted or reflected artificial light.

Contaminated Land - Details of further intrusive land contamination investigations, a remediation scheme, and a verification report.

Planning Officer's Response : Noted, and appropriately worded recommendations have been included in this report.

Tree Services No objection to the proposal in principle; however strong concerns are raised with regards to:

• Large number of tree removals and possible low level of replacement tree planting (including in locations with limited rooting zones) • Removal of trees along the North Circular and woodland area along the eastern site boundary which reduces amenity • Incursions into root protections areas

Should planning permission be granted then Tree Services request either an s106 payment of £387,200 for tree planting within the ward, or a detailed landscaping proposal to account for the lost amenity. In addition conditions have been recommended concerning the submission of revised tree protection measures (including no-dig road surfaces) and the monitoring of their implementation.

Planning Officer’s Response: The recommended conditions that concern a detailed landscaping proposal and tree protection measures have been included in this report. The concerns raised by Tree Services are addressed more fully in the section of this report titled ‘Trees and Landscape’.

External Consultation

Greater London Authority (GLA) The following is a verbatim summary of the comments received from the GLA concerning the strategic issues:

Metropolitan Open Land

“The proposal constitutes inappropriate development on Metropolitan Open Land, but development of this site is necessary to facilitate the restoration and stewardship of the Page 31 of 56

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Grade II listed building, which is in a ruinous condition. This is the optimum viable use. Very special circumstances have therefore been demonstrated and the proposal is supported in principle as enabling development. It has been demonstrated that the amount of development sought is required to enable the school and sixth form to function, so the impact on openness has been minimised”.

Design and Heritage

“The proposal to restore the listed Abbey building, demolish the 1960s additions, and reinstate much of its historic plan form and interiors is strongly supported. The siting and design of the new buildings has been well considered and there would be no harm to the listed buildings, the settings of which would be significantly enhanced”.

Historic England No objection , subject to various conditions requiring the submission of more specified details.

Planning Officer's Response All of the recommended conditions The EA comments will be provided in the Committee Briefing Notes.

Historic England (GLAAS) No objection , subject to condition requiring the submission of a written scheme of historic building investigation (WSI)

Environment Agency (EA) No comments have been received addressing the submitted flood risk assessment and proposed mitigation scheme, at the time of writing this report. The EA have advised that they are unable to assess the proposal and provide their advice within the statutory timeframe. However they have confirmed that the scheme would be assessed prior to the Planning Committee meeting.

Planning Officer's Response The EA comments will be provided in the Committee Briefing Notes.

Transport for London (TfL) No objection , subject to the provision of a private school bus; details on on-site parking demand management; details on the proposed catchment area of the school; the provision of before-and-after school clubs; cycle parking details; a delivery and servicing management plan; a construction management plan; a travel plan; and improvements to the pedestrian environment.

Planning Officer's Response These recommendations have been incorporated within the s106 heads of terms and suggested conditions.

Brent Council No response received to requests for comments

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Hammersmith and Fulham Council No response received to request for comments

Planning Policies

These are set out in the informative above.

Reasoned Assessment

The proposals have been assessed against the relevant planning policies and supplementary planning guidance/documents. The key matters in the assessment of these proposals are:

• The principle of the development; • The potential impact on the historic significance of the listed buildings and their settings; • Design and appearance, particularly in relation to the proposed new buildings and their impact on the character and visual amenity of the area; • The potential impact on nature conservation; • Trees and landscaping; • Transport matters and servicing; • Environmental health - contaminated land, air quality and noise mitigation; • Potential amenity impacts on neighbouring properties; • Flood risk and surface water management; and • Energy and sustainability

Principle of the Development

The principle of the development needs to be considered within the context of the provision of an educational facility, the restoration and stewardship of Statutory Listed Grade II heritage assets (the abbey and the walled garden), and the site’s location on land designated as Metropolitan Open Land (MOL).

Principle of Educational Use

Paragraph 72 of the NPPF states that “the Government attaches great importance to ensuring that a sufficient choice of school places is available to meet the needs of existing and new communities” and that Local Authorities should give “great weight to the need to create, expand or alter schools”. This is supported by Policy 3.18 of the London Plan (2016) which states that proposals for new schools should only be refused where there are demonstrable negative local impacts.

Furthermore, Ealing's Planning for Schools DPD identifies a need for 23 secondary forms of entry (FE) to be delivered by September 2019, with the earliest and greatest need identified in the areas of Ealing, Acton and Hanwell. Twyford Abbey is not an allocated site within the DPD, and was discounted in the early consultation stages of the DPD due to the potential constraints of its MOL and heritage designations, and the resultant concern that school places would not be delivered in time.

Notwithstanding that these site constraints are considered to be appropriately addressed (as discussed elsewhere throughout this report), and that the nature of a fee paying school would mean that local needs would not be fully satisfied, the provision of a sixth form and secondary school would nevertheless be entirely consistent with these planning policies and assist in delivering an identified shortfall in school places. In addition, public access and use of the proposed 'Community and Sports'

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Balancing the Conservation of Heritage Asset, Inappropriate Development on MOL, and Enabling/ Facilitating Development

Paragraph 140 of the National Planning Policy Framework states that "local planning authorities should assess whether the benefits of a proposal for enabling development, which would otherwise conflict with planning policies but which would secure the future conservation of a heritage asset, outweigh the disbenefits of departing from those policies". In this regard this NPPF policy is expressed as a straightforward balancing exercise, whereby it needs to be assessed whether the proposed development on Metropolitan Open Land (the departure from planning policy) would do more harm than the benefits gained from securing the conservation of the Abbey and Walled Garden.

London Plan Policy 7.17 affords the “strongest protection” to Metropolitan Open Land (MOL), giving the same level of protection as Green Belt, where inappropriate development should be refused except in very special circumstances. Paragraph 87 of the NPPF states that inappropriate development is, by definition, harmful to the Green Belt and should not be approved except in very special circumstances. In addition, paragraph 89 of the NPPF states that “a local planning authority should regard the construction of new buildings as inappropriate in Green Belt” and lists exceptions to this. Similarly, policy 2.18 of Ealing's Development Management DPD states that only development ancillary to the use of the open space should be permitted.

The proposed construction of the school buildings, by definition, would be 'inappropriate development' on MOL. However, it is accepted that some form of enabling development is required to secure the conservation of the Grade II listed Abbey and Walled Garden, particularly in light of the deteriorating state of the Abbey and the pressing risk of the further degradation of this heritage asset. Thus it is considered that the urgent need to secure the future of this heritage asset sufficiently demonstrates 'Very Special Circumstances'.

While there is no statutory definition of enabling development, the principle of enabling development is that it will involve a scheme that would otherwise be unacceptable in planning terms, but is also the minimum amount of development required to restore the heritage asset. As such, the conservation of the Abbey and the character of the MOL needs to be balanced with identifying a viable use that would be most compatible with the heritage values of the site and would secure the restoration and the long-term stewardship of the site. In this regard the proposed educational use is compatible with the room layout of the Abbey, minimising the loss of historic fabric, while also considered to have less of an impact on the open character of the MOL and the historic setting than previous unacceptable proposals for residential development. In this regard the proposed educational use is acceptable.

In regards to the quantum of the proposed development, a report prepared by educationalist Geoff Cocksworth has been submitted which details the curriculum, staffing and accommodation requirements for the proposed school. This report concludes that from an education perspective the proposed accommodation and facilities would be suitable for the intended number of staff and pupils, with most rooms ranging from 66-84% occupancy, which is considered normal for a school with such a wide curriculum. Indoor and outdoor sports facilities are also proposed as part of the scheme; however it is recognised that students would sometimes need to travel off-site to use larger facilities. Accordingly it is accepted that the amount of floor space proposed is the minimum required to enable the proper

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It is recognised that the proposals involve the construction of new school buildings and hardstanding. However these would be primarily located to the north of the site amongst the existing built development, and adjacent to the western site boundary. This is considered to be appropriate siting to minimise the impact on the open character of the MOL, and the amount and form of the development is considered to be the minimum required to ensure the proper functioning of the proposed secondary school and sixth form.

In summary, the proposed use and quantum of development is considered to be the optimum viable use that would secure the removal of Twyford Abbey from Historic England's 'Heritage-at-Risk register and ensure its long-term viability. These gains, combined with the design measures intended to minmise the impacts on the character of the MOL, would outweigh the disbenefits of departing from policy that seeks to resist inappropriate development on MOL (consistent with paragraph 140 of the NPPF), and would also constitute the very special circumstances required under paragraphs 87 and 89 of the NPPF and London Plan policy 7.19. As such, the principle of the school development on MOL, in the amount of development proposed, is considered to be on-balance acceptable.

Impact on the Historic Significance of the Listed Buildings and their Settings

Significance of the Heritage Assets

The site contains two Grade II listed heritage assets - the Abbey, and the Walled Garden. The site also forms part of the setting of St Mary’s Church (also listed Grade II) adjacent to the western site boundary. The grounds themselves are also of historic interest. While not statutorily listed, these are recognised in the London Parks and Gardens Trust Inventory of Historic Spaces. The site as a whole demonstrates evidential, historic, aesthetic and communal values of significance. A detailed Heritage Statement has been submitted with the applications. This sensitive site, which has been disused for years and identified by Historic England as Heritage-at- Risk, needs to be considered in terms of the potential impact of the proposals on the special interest and setting of the listed buildings, as well as the quality of the surrounding landscape.

Policy Framework for Assessment

NPPF Section 12, London Plan policies 7.8 and 7.9, Ealing’s Development Strategy 1.1(h) and 1.2 (h) and Development Management DPD policy 7C are relevant to the development of heritage assets.

Section 66 of the Planning (Listed Buildings and Conservation Areas) Act 1990 (as amended) sets out the obligation on local planning authorities in respect of development, to pay special regard to safeguarding the special interest of listed buildings, preserving their settings or any features of special architectural or historic interest which it possesses. Section 7(1) sets out the requirement for any work to listed buildings to be subject to an application for listed building consent.

The National Planning Policy Framework (NPPF) sets out the Government's policies for decision making on development proposals. At the heart of the framework is a presumption in favour of 'sustainable development'. Conserving heritage assets in a manner appropriate to their significance forms one of the 12 core principles that define sustainable development.

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The potential impact of the proposal needs to be balanced against securing the ‘optimum viable use’ of the building and the public benefit the scheme brings. Section 12 of the NPPF covers the historic environment and defines listed buildings and conservation areas as “designated heritage assets”. Paragraph 132 of the NPPF gives great weight to the conservation of a heritage asset’s significance.

The case for proportionality is outlined in terms of the greater the importance of the asset, then the greater this weight should be to its conservation. Paragraph 133 advises that where a proposal would lead to substantial harm or total loss of significance to a designated heritage asset then consent should be refused unless it can be demonstrated that it is necessary to achieve substantial public benefits that outweigh the harm. Paragraph 134 advises that where a proposal would lead 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 securing its optimum viable use.

Viable uses fund future maintenance of buildings and ensure the future conservation of an asset. The optimum viable use is defined as one “which causes the least harm to the significance of the asset, not just through necessary initial changes but also as a result of subsequent wear and tear and likely future changes”. The London Plan also sets out the Mayor’s commitment to protect and enhance London’s historic built environment, to promote conservation-led regeneration, and the re-use of redundant or under-used buildings.

The main issue for consideration is the potential impact that the proposals would have on the significance of the designated heritage assets, having regard for the overall merits of the scheme. An assessment and conclusions drawn of the impact of the proposals on the significance of the Abbey, the walled garden, and the adjacent St Mary’s Church, is set out as follows:

Assessment of Heritage Impact

Demolition

To enable the development to take place, some demolition is proposed that would affect the Abbey, the Walled Garden and some ancillary structures. In relation to the Abbey itself, it is proposed to remove two large three-storeyed 1960s additions. Neither of these is of architectural merit and their removal would better reveal the significance of the building. A smaller, non-original addition to the southeast corner of the building will also be removed, to return the Abbey closer to its original layout and appearance. Listed Building Consent has recently been granted for some internal demolition to prevent the further deterioration of the building fabric and to make the building safe for further surveying (ref. 170678LBC, dated 26/04/2017).

Various small buildings that are either attached to or close to the Walled Garden would also be removed. While these have some significance in terms of the previous use of the garden and grounds for cultivation and animal husbandry by the Alexian Brothers, their later date and poor condition suggests that demolition would not be harmful to the special architectural or historic interest of the site as a whole. It is also proposed to demolish the lodge next to Twyford Abbey Road. This is not original, having been constructed at the end of the nineteenth century, and has been altered and extended since. Very little of its original significance remains, and therefore it is not considered that any harm to the setting of the heritage assets would result from its demolition. This lodge would be replaced by a pair of ‘gatehouses’ in this general location marking the main entrance.

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Alterations and Extensions to the Abbey

It is proposed to restore much of the exterior of the Abbey to its original appearance. This is considered to be a real enhancement of its special architectural and historic interest, and conditions have been included in this recommendation to ensure that the details are correct. Unfortunately the long-term deterioration of the building has meant that little of the interior remains. However, much of the original plan form will be retained and those few remaining features of interest would be retained. Again, conditions for the submission of details have been recommended to ensure that as much of the original building fabric as possible is preserved or reinstated where appropriate. A new enclosed bridge link connecting the north-west and south-west at the first floor level is proposed, which would replace the 1960s extension that would be demolished. This would enable the original open courtyard to be revealed and is considered to be an acceptable addition to the Abbey subject to appropriate detailing.

Alterations and Extensions to the Walled Garden

The main works to the Walled Garden involve the construction of a new multi-purpose single-storey building that would be lightly attached to the north wall and extend the whole width of the garden. Its intrusion into the garden has been minimised as much as possible. It has been designed to attach lightly to the wall, albeit conditions have been included requiring the submission of further details concerning the structural solution for the building to ensure that the interventions are kept to a minimum and ensure the integrity of the wall. The wall would remain exposed within the new building, which has a part-glazed and part brown roof. There is evidence of greenhouses having existed in this part of the garden and the new structure would continue this precedent in a more contemporary manner. On the other side of the wall from the new structure, the ‘cottage’ will be refurbished for re-use. This would entail the provision of a new internal floor level and ‘raised-height’ door to take account of the proposed raised ground level around this part of the building. This would preserve the special interest of the listed structure by bringing a currently derelict building back into use.

The remainder of the garden would be used for its original purpose, and the walls repaired and partially rebuilt as necessary to ensure its long-term survival. The basic structure of the former, non-original workshop attached to the south wall will be retained, but re-glazed and re-roofed to bring it back into use. More flexibility on its design is considered to be appropriate in view of its non-original character.

New Buildings

Any new buildings on the site are going to affect the setting of the listed buildings, and would also impact on the landscaped grounds. The strategy employed to minimise the impact of the development has been to concentrate the new buildings to the north of the site. This has the benefit of generally leaving the southern aspect of the Abbey open and free of buildings, and thus enabling some public view of the listed building. Another facet of this strategy is the proposed ‘Inhabited Wall’ to the north of the site, which would act as a barrier, shielding the school from the noise and fumes from the North Circular Road.

The ‘Inhabited Wall’ building would fill the narrow gap between the Walled Garden and the North Circular Road. While it is inevitable that it would loom large above the garden, its height has been kept down as low as possible. The proposed roofline has been kept ‘clean’ of plant and other structures (and any external plant or machinery would require permission via the submission of details), and the proposed design and materials are restrained to minimise its impact. Similarly the design and limited palette of materials proposed for the swimming pool and sport/community buildings are also restrained. These proposed buildings are both set away from the listed Abbey, but have a formal relationship on plan to reinforce the sense of a campus environment.

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The other significant new-build is the construction of a pair of ‘gatehouses’ at the site entrance on Twyford Abbey Road which would serve as ancillary administration offices and accommodation for groundskeepers and security staff. The single storey ‘gatehouse’ would be located on the site of the existing lodge. Its location, height, bulk and scale are considered to be appropriate to the informal and romantic character of the listed Abbey and its grounds. The two-storeyed ‘gatehouse’ would be set back further within the site and away from the smaller proposed ‘gatehouse’ to maintain this character.

Landscaping and Boundaries

As has been described above, the proposed new buildings (apart from the proposed ‘gatehouses’) would be located in the northern half of the site, thus maintaining the open character of the landscaped setting of the Abbey. The main access road and car parking would be located along the western boundary, with a service road and small sentry building adjacent to the eastern site boundary. This arrangement would minimise the intrusion of vehicles onto the site, and again preserve the setting of the Abbey. Soft landscaping is also proposed around the perimeter of the site adjacent to St Mary’s Church. This has been designed to maintain its setting, but at the same time acknowledging its former visually permeable connection with the site, whereby the original main entrance to the Abbey was designed and sited to overlook St Mary's Church.

Apart from the proposed ‘Inhabited Wall’ to the north, the main public boundary of the site is the southern edge along Twyford Abbey Road. The need for security demands that there would be a high fence along this boundary. However, it is important that at the same time, public views are maintained across the open landscape towards the Abbey. The detailed design of boundary treatments would be covered by a condition, as well as the hard and soft landscaping, external lighting and any signage to be used on the remainder of the site.

Summary

Taken as a whole, the alterations and extensions to the Abbey and Walled Garden along with the new buildings and proposed landscaping are considered to preserve the special interest of the listed buildings and their settings.

The proposals would ensure the long-term survival of the Abbey and the Walled Garden, and would l ensure their removal from Historic England’s ‘Heritage-At-Risk’ register. Elements such as the Inhabited Wall and the new structure in the Walled Garden, which may be seen as harmful to the settings of the listed structures, would in terms of the NPPF be considered to be ‘less than substantial harm’ and outweighed by the improvements to the listed buildings and the other public benefits of the proposals.

Archaeological Impacts

The site is also located within an Archaeological Interest Area, specifically in relation to the potential for remains of a medieval moated manor house. An Archaeological Assessment (prepared by CgMS, dated January 2017) has been submitted in support of the application and reviewed by Historic England’s Greater London Archaeological Advisory Service (GLAAS). The comments received from the GLAAS note that the submitted report “has built on the results of an earlier phase of evaluation and it is clear from both phases, that the site as a whole has a generally low archaeological potential. The main potential lies around the existing house where remains of the medieval moat and associated evidence are likely to be encountered. The proposed new buildings would not impact the medieval moat, and instead, the archaeological remains that are likely to be impacted are those associated with

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Planning Committee 20/09/2017 Schedule Items 03 & 04 landscaping dating from the early 19th century onwards, as indicated by the results of the evaluation. No further assessment or conditions for archaeology are therefore necessary”.

However it is noted that some historic buildings are of archaeological interest and that this interest can be harmed by the loss of historic fabric. In light of the significance of the Grade II Twyford Abbey, the GLAAS has advised that a Historic Building Recording should be carried to a level 3. The scope of which should also include a watching brief during the development to ensure that any previously unrecorded historic fabric within the building, which is uncovered during the development, is also recorded. Accordingly, the recommended condition requiring the submission of a written scheme of historic building investigation (WSI) has been included in this report.

Design and Appearance

Sections 6, 7, 8 and 12 of the NPPF, London Plan policies 3.5, 7.1, 7.2, 7.3, 7.4, 7.5, 7.6, 7.7 and 7.8; Ealing Local Variation to London Plan policies 3.5 and 7.3; and policies 7.4, 7B and 7C of the Development Management DPD are relevant with regards to the design of new development.

In most respects the design and appearance of the proposed buildings have been discussed above in relation to their acceptable impact on the heritage listed assets, and the potential residential amenity impacts resulting from the proposed scale and siting is discussed further below ('Potential Impacts on Neighbouring Occupiers' section). Furthermore the proposed scale and siting in relation to the acceptable impacts on the open character of the MOL, has also been discussed above (please refer to 'Principle of the Development' section).

Nevertheless, it can be summarised that the proposed arrangement of form, scale and massing of the buildings responds sympathetically to the different character, scale and settings both within the site itself but also that of the adjoining land uses. The mass of the larger 'Inhabited Wall' and 'Community and Sports' buildings is visually broken by the proposed variation in the elevation treatments and the use of projections and recesses from the general building line, creating the impression of a series of interconnected smaller volumes. The proposed materials would also contribute to achieving an attractive and muted appearance, which is supported.

In combination with the landscape proposals, the restoration of the Abbey and Walled Garden, and the good quality contemporary new buildings, the proposal would result in a well-designed, architecturally interesting school that would contribute positively to the character of the surrounding area and the visual amenity of the street scene.

Impact on Nature Conservation

The Twyford Abbey grounds is a designated Site of Importance for Nature Conservation (SINC) (‘Borough Importance’ Grade II) due to the presence of extensive areas of woodland and other natural habitats (e.g. scrub, grasslands, scattered trees, tall herbs and bare ground) that have the potential to support birds, mammals and invertebrates. A key reason for the SINC designation is that the site is the largest area of open space in a heavily built-up area.

A Preliminary Ecological Appraisal (dated October 2016) and Addendum/Letter (dated 22/08/17); Daytime Bat Survey (dated October 2016); and Nocturnal Bat Survey (dated October 2017) (all prepared by MKA Ecology) has been submitted in support of the proposals.

The submitted appraisal notes that the SINC citation for Twyford Abbey and its grounds recognises that the habitats onsite “are not currently of a particularly high ecological value, which is due to a lack of

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Planning Committee 20/09/2017 Schedule Items 03 & 04 management”. This appraisal further identifies that while the habitats themselves are of relatively low ecological value in their current state, there is significant potential to enhance existing habitats; greatly increase the diversity of habitats; and to positively and sensitively manage these habitats over the long- term (which has previously been lacking).

The appraisal (and addendum/letter) recognises that there would be approximately 3,000sqm of woodland cleared as part of the proposals, and that “woodlands are a Habitat of Principal Importance under the Natural Environment and Rural Communities Act (NERC Act, 2006), and their ecological value often goes beyond that afforded to protected species; invertebrates and fungi in particular being particular beneficiaries”. However, as noted above, given the low ecological value of the under- managed habitats in their present state, it is in the potential for the woodland at the site, and their enhancement, that the ecological value lays. Therefore while a considerable area of woodland would be cleared (3,000sqm approx.), this is considered to be appropriately off-set (and improved) through the following measures and ecological enhancements:

• The creation of a better quality woodland, leading to an area of 4,184sqm of retained and new mixed woodland in the western area of the site, including at least 1,194 new trees; • A greater diversity of habitats would be created through the inclusion of: o species-rich grassland meadow (5,641 m 2) o hedgerows (1,202 m 2) o traditional orchard (1,811 m 2) o open mosaic habitats on previously developed land and brown roofs (1,866 m 2) All of these being ‘Habitats of Principal Importance’ (as defined by the NERC Act, 2006), and; • The retained and enhanced habitats would be positively managed over the long term

In summary, while there would be some clearance of existing woodland, these are not of particularly high present ecological value. The landscape and ecology proposals as a whole (to be refined through conditioned details), would still retain the features identified in the citation for the SINC (i.e. a large open space in a heavily built-up area; extensive areas of woodland; and additional habitats such as scrub, grassland, scattered trees, tall herbs and bare ground), but would also deliver a greater diversity of habitats and ultimately a net gain in biodiversity. Significantly the creation of an Ecological Management Plan (to be secured by condition) will improve the biodiversity value of the site and maintain its integrity over the long-term, which has been lacking on this neglected site. Therefore it is considered that the proposals would deliver beyond a level of protection commensurate with the SINC designation as being of ‘Grade II borough importance’, but would make a significant contribution to biodiversity creation and enhancement, consistent with policy 7.19 of the London Plan and section 11 of the National Planning Policy Framework.

In regards to the bat surveys no evidence of roosting bats were identified. However it is noted that due to time constraints, nocturnal surveys were only carried out on one occasion (rather than the recommended two or three surveys for features of the site identified as having moderate to high potential for bat roosts). Nevertheless, the submitted appraisal considers the data gathered to be sufficient for the purposes of this planning application, and that it is likely that “any impacts on bat roosts at the Site will be easily mitigated against”. This is accepted. In accordance with the recommendations outlined in the submitted bat surveys, further surveys and the pre-caution to double- check for the absence of bats should be carried out to prevent the potential for committing offences under relevant wildlife legislation. These mitigation measures, and the measures to be taken should active bat roosts be identified during the demolition and construction phases, should form part of the Nature Conservation Management Plan (NCMP), the details of which are to be secured by condition. The NCMP should also include other recommendations contained within the submitted appraisals such

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Planning Committee 20/09/2017 Schedule Items 03 & 04 as the provision of bat boxes, a native planting scheme, a sensitive lighting scheme to maintain, if not improve, the potential for bat habitats. Overall, the suite of ecological benefits referenced above would increase the biodiversity value of the site, including for roosting, commuting and foraging bats.

Trees and Landscaping

Policies 5.10 and 7.21 of the London Plan (2016) require new developments to integrate green infrastructure such as tree planting and to retain trees of value. Any loss of trees as the result of development should be replaced following the principle of ‘right place, right tree’. Policy 5.10 of the Local Plan (2013) states where trees are proposed to be removed, re-planting is required on the basis of no net loss of amenity. While the extent and location of the planting need not necessarily be the same afterward as it was before, the quality and type of amenity offered should be the same or better.

The proposed landscaping strategy has been developed through a multi-disciplinary approach which seeks to restore and enhance the historic character and setting of the listed heritage assets (Twyford Abbey, the Walled Garden, and the adjacent St Mary's West Twyford Church). Some key features of the proposed landscape masterplan include:

• A planting strategy that seeks to retain and enhance key existing character areas, and introduce others, for example: o The eastern boundary would retain its ‘woodland character’ with woodland planting and management, the introduction of more native specimens and hedging for screening o The ‘parkland’ area to the front of the Abbey, which contains some of the best trees on site, would remain as open grassland in character. Native meadow species grass would be introduced and cut two to three times per annum to provide a clear contrast to the formal lawn which would be used for recreation o Ornamental planting including herbaceous borders would be introduced adjacent to the proposed new buildings o The proposed Abbey courtyard planting would be based on ‘architectural foliage’ that is historically inspired by William Atkinson’s (architect of Twyford Abbey) interest in new plant introductions and semi-hardy plants o The restored Walled Garden would be planted with an orchard (including historic apple cultivars) and ‘Order Beds’ that are formally laid out reminiscent of its former use, and would include a ‘science garden’ and other curriculum linked garden uses o A formal line of disease resistant Elms along the eastern boundary as a memory of the double Elm Avenue that lead into the estate in the mid-19 th Century • Biodiverse roofs - brown roofs on the proposed swimming pool building, and the proposed Walled Garden building • The reintroduction of a visual connection between the Abbey and St Mary’s Church • Hard landscaping that has been minimised as much as possible to enable circulation around the site, but would also include the use of materials such as reinforced grass for vehicle parking beneath existing and proposed trees, and gravel to reduce the visual impact of hardstanding (details to be secured through condition)

The proposed landscaping masterplan as a whole is considered to be a thoughtfully conceived strategy, which subject to the submission of the detailed aspects of the proposals, would significantly enhance the setting of the heritage assets, contribute positively to the visual amenity of the overall site, and provide the long-term stewardship of the landscape for future generations to enjoy. The Council’s Landscape Architect has also reviewed the proposal and considers that it is well thought-out.

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However there have been concerns raised by the Council’s Tree Services that need to be more thoroughly addressed. As noted in the ‘Internal Consultation’ section above, while Tree Services do not object to the proposal in principle, there are strong concerns raised with regards to:

• A large number of tree removals and possible low level of replacement tree planting (including in locations with limited rooting zones); • The removal of trees along the North Circular Road and woodland area along the western site boundary (TPO ref. W1) which reduces amenity; and • Incursions into root protections areas

Therefore Tree Services have recommended that should planning permission be granted then either a financial contribution of £387,200 should be secured for tree planting within the ward to off-set the loss of amenity, or a revised landscaping proposal would need to be submitted to account for the lost amenity. In addition conditions have been recommended concerning the submission of revised tree protection measures (including no-dig road surfaces) and the monitoring of their implementation (which have been included in this report). In short, it has been recommended within this report that the detailed scheme of tree planting be submitted (through condition) to demonstrate the feasibility of the proposed planting locations, and that the amenity loss would be sufficiently replaced. Subject to compliance with these conditions, it is not considered that seeking the requested financial contributions via a s106 legal agreement would be necessary to make the development acceptable in planning terms, or fairly and reasonably related in scale to the proposals (i.e. two of the tests for the use of planning obligations contained within regulation 122 of the CIL regulations).

To elaborate on, and address more fully the concerns raised by the Council’s Tree Services, it is proposed to fell 184 of the 311 trees on site (an overall number that excludes the trees present in the TPO woodland ref. W1 that extends along the western site boundary, as these cannot be readily quantified given the number of saplings incorporated). Thirty-nine (39) of the proposed trees for removal are accepted by Tree Services to be dead or dangerous. It is also proposed to plant 108 individual replacement trees. Given the restricted wider public views of the trees proposed for felling, Tree Services have based the CAVAT Value only on the Category B trees (18 trees) and the Category C trees on a 1 for 1 replacement value. The CAVAT Value has been calculated as £452,000. The amenity value of the proposals has been calculated on the replacement cost value, specifically 108 trees valued at £600 per tree (£64,800 in total). Therefore the suggested financial contribution sought (in lieu of a detailed tree replacement scheme) has been calculated by Tree Services to be £387,200 (i.e. £452,000 CAVAT valuation - £64,800 estimated replacement tree costs).

This method of calculating a financial contribution does reflect Tree Services legitimate concerns that the proposed landscaping with juvenile plants (whereby the amenity value would be similar to its cost price) would not produce similar levels of amenity benefits for the first 25-30 years of tree planting. This method is consistent with Ealing’s Tree Strategy (which is not adopted planning policy). However, in accordance with policy 7.21 of the London Plan, this method does not take into account the ‘future value’ of the proposed trees. In the absence of an alternative and widely accepted method for carrying out a cost-benefit analysis that does take into account the ‘future value’ more akin to the London Plan, it is most useful to outline the proposals, the potential impacts, and the planning assessment which takes into account the concerns raised by Tree Services.

Large Number of Tree Removals

As with all planning considerations, the loss of trees must be finely balanced against the benefits of the overall scheme. In this instance, the key planning benefit (and public gain) is the restoration of the Grade II listed Twyford Abbey and associated Walled Garden, and its removal from the Heritage at Risk Page 42 of 56

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Register. The poor state of the building after thirty years of neglect, and the threat of the heritage loss should not be understated. This in no manner negates the adverse impacts as a result of the immediate loss of established mature trees; but rather is intended to bring into relief the need to balance the overall benefits of the proposal with the dis-benefits.

There is no doubt that the proposal would result in a notable loss of established mature trees, and that these amenity values would unavoidably take considerable time to become re-established from the proposed planting. Nevertheless in the longer term the proposed landscaping plan (including tree planting) which has been prepared by specialist heritage landscape architects (with technical input from an arboriculturalist) has been carefully considered to be commensurate with and compliment the site's historical status, and to ensure that the amenity of the site can be enhanced and sustainably managed for future generations to enjoy. In this regard the proposed 108 individual trees to replace the 145 healthy individual trees proposed for felling (39 are dead or dangerous, resulting in a 1-for-1 shortfall of 37 trees), is considered on balance to be acceptable. The specific tree numbers proposed should also take into account the proposed woodland planting which, while densities and management regimes have not yet been fixed (these details are conditioned), it is anticipated that ten to fifteen percent of the original woodland planting would be encouraged to grow to full maturity. This would represent another 50 to 70 mature trees in this area, additional to the 108 individual trees shown on the proposed landscape master plan. Therefore, in numerical terms, the proposed replacement planting may be considered similar to the proposed number of felled trees. In regards to the appropriateness of the tree re-planting (including limited root zones), it is considered acceptable that the more detailed specifications of the tree planting regimes, types, sizes and the like can be conditioned. This is consistent with Tree Services advice requiring the submission of detailed tree replacement scheme, or the securing of financial contributions.

Removal of Woodland adjacent to the Western Site Boundary for Vehicle Access and Parking

Concerning the proposed removal of woodland area along the western site boundary (TPO ref. W1), it is recognised that approximately 3,000sqm of woodland would be cleared (as previously discussed above in the section 'Impacts on Nature Conservation'). The Arboricultural Report submitted in support of the proposal notes that this woodland is over land that appears more consistent with park land than woodland, with a density of trees that does not match that of the trees to the immediate east of the Abbey. In this regard the submitted report considers that the woodland character that was apparent at the time that the TPO was made (in 1974) would have developed as a result of lapsed management, as there is nothing about the woodland that is consistent with it being an ancient woodland. This is not disputed by the Council.

In addition, it is noted that the woodland proposed for felling within this section of the site would consist of a significant proportion of elms, many of which are dead, with the remainder to die within the next few years. This woodland does have a good structure, and the elms would re-grow as sucker growth from their root stock; however given the characteristics of the existing woodland described above, the proposed indigenous replacement woodland planting (described above in the section 'Impacts on Nature Conservation'), has considerable potential to re-generate the habitat and amenity value of the woodland for the benefit of wildlife, the school and local residents in the longer term. In this regard Tree Services does agree that the woodland is in need of management, and that if this section of woodland can indeed be improved (subject to conditioned details on densities, specifications, careful planting management etc.) this would be of benefit to the site, although not so much to the neighbouring properties due to the proposed vehicular roadway adjacent to the western site boundary.

In regards to the potential amenity impacts on the adjacent neighbouring properties from the proposed removal of woodland, this is primarily considered further below within the section 'Potential Impacts on

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Neighbouring Occupiers'. In summary however, while it is recognised that the land area of tree coverage adjacent to the western boundary would be reduced, subject to the submission of the detailed planting scheme and woodland management plan, it is considered that an acceptable level of soft landscaped boundary screening would be achievable in the intermediate term. This is shown in the Image 1 further below.

In regards to public views from Twyford Abbey Road, the proposed coach turning loop would be largely obscured behind proposed and existing tree planting where visible from the highway. Therefore, subject to the submission of the detailed planting scheme and woodland management plan the potential impact on public amenity from the loss of woodland is considered acceptable. In regards to public amenity as experienced from within the site, as discussed further above, the overall proposed landscaping scheme is considered to be a good quality strategy that would enhance both the site's ecological and amenity value.

In balancing all aspects of the planning proposal it should also be noted (as reiterated in various sections of this report) that the siting of the proposed coach loop has been developed to respond to the various competing needs - i.e. ensuring that the potential highway impacts can be managed within the confines of the site, reducing the levels of hardscaped surfaces to minimise the potential impact on the MOL, and minimising any impacts that vehicle circulation and hardscaped surfaces would have on the setting of the listed heritage assets, while also seeking a sustainable landscape strategy that would enhance the amenity and ecological values of the site. In this manner it the location of the proposed roadway (coach turning loop), parking areas and the proposed swimming pool building are considered to be on-balance the most appropriate siting, and therefore the loss of woodland land area is on- balance acceptable and would be appropriately mitigated.

Figure 1 Indicative tree planting (screening) adjacent to the western boundary at 10 years after implementation.

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Removal of Trees along the North Circular Road to be replaced by the 'Inhabited Wall' Building

The principle of positioning the proposed 'Inhabited Wall' building on the northern boundary of the site has been developed in consultation with various Council officers (including pre-application site visits carried out by Tree Service Officers), the Greater London Authority and Historic England. Again the proposed siting has resulted from the nuanced balancing of competing needs - specifically, the functional requirements of the school; ensuring the retention of the open parkland to the south of the Abbey which has ecological, landscape, and heritage value as well minimises the impact on the open character of the MOL; and also this building has been designed to create a barrier between the remainder of the site and the North Circular Road, reducing noise pollution and air quality concerns on the wider site. There would not be any opportunity to set the building back from the boundary with the North Circular Road (to accommodate tree planting), as this siting would then be in very close proximity to the listed Walled Garden. This would cause concerns both in relation to the impact on the heritage values, but also in the functioning of the circulation space between the building and the walled garden which would be relatively tight even as currently proposed.

While the concerns raised by Tree Services as to the loss of greenery along the North Circular Road is appreciated, it is considered that on-balance the proposed loss of trees along this boundary is both necessary and acceptable.

Transport Matters and Servicing

Policies 6.3, 6.9, 6.10, 6.11, 6.12 and 6.13 of the London Plan (2016) require developments to provide adequate cycle and car parking spaces, ensure high quality pedestrian environments, and to be assessed on the effects it would have on the highway network in respect to transport capacity, traffic flow and congestion. Concurrently policy 5.17 requires developments to provide suitable waste and recycling facilities, to which the Council’s refuse services do not raise any concerns with the proposal.

Site Context

The site has a PTAL rating of 1b to 3 which represents a poor to moderate level of access to public transport modes. The nearest bus stop is located on Bodiam Way, approximately 100m south-west of the site. This is served by the 226 bus route which runs from Ealing to Golders Green. The 224 bus route which runs from Wembley to St Raphael's Estate, via Alperton, can currently be caught from a stop 250m east of the site; however there are proposals to re-route this bus service directly past the site and down Bodiam Way which should improve the PTAL level of the site. In addition the 112 bus from Ealing to Brent Cross can be caught from the North Circular. The nearest tube stations are Hanger Lane (approximately 700m) which serves the Central Line, and Park Royal Station (approximately 800m) which serves the Piccadilly Line. Overall there are two tube stations within a 10 minute walking distance from the site; and three bus routes within an 8 minute walking distance.

The site is not within a Controlled Parking Zone (CPZ), and some on-street parking is available on both sides of Twyford Abbey Road (due to the absence of parking restrictions). Twyford Abbey Road is protected by a 20 mph speed limit, and there is a bus gate approximately 100m east of the main site access. The narrowing of the carriageway either side of the bus gate results in a width restriction (1.9m or 6'6") between the two site accesses.

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Access and Internal Layout

The proposed school would use two existing vehicular access points from Twyford Abbey Road. Both of these accesses would be available for pedestrians and cyclists, with a third pedestrian/cyclist entrance proposed for the north of the site which would enable direct access from the North Circular.

The western-most vehicular access from Twyford Abbey Road would serve as the main site entrance for visitors, school minibuses and coaches. A turning area in this eastern section of the site has therefore been incorporated into the proposal to ensure that vehicles can enter and exit the site in a forward gear. The eastern-most vehicular access from Twyford Abbey Road would be used solely by delivery and servicing vehicles, which would not be permitted to service the school during AM and PM peak periods.

These separate vehicular entrances are considered appropriate to minimise potential conflict points between visitors, students and service vehicles; but also to avoid potential damage to protected cedar trees adjacent to the Abbey, and to minimise any impact on the setting of the listed Abbey that regular vehicles passing in front of the Abbey would pose.

Parking

There are 43 parking spaces proposed for the site which would be comprised of 12 spaces for maintenance vehicles; 9 spaces for school minibuses; 10 spaces for staff; 8 spaces for visitors; and 4 accessible spaces allocated for blue badge holders. A coach parking bay would also be provided in addition to these spaces. This level of parking provision has been reviewed by the Council’s Transport Officer and is considered acceptable to minimise impacts on surrounding streets.

The submitted Travel Plan confirms that parents would not be permitted to pickup or drop-off students onsite. This is considered appropriate to discourage parents from driving students to and from school, and assist in the aim of the Travel Plan in reducing the number of car trips. The submission of a Parking Management Plan secured by condition should also include details to demonstrate how this would be enforced onsite (e.g. through staff marshalling).

Financial contributions have also been sought for the review and potential implementation of a Controlled Parking Zone (CPZ) on adjacent streets to further address any parking concerns, and the school would be providing a private bus service which would be secured through the legal agreement.

Servicing

Deliveries and serving are proposed to take place outside of school peak periods and outside of the AM and PM peaks. This is encouraged and would be secured through the submission of a revised as Delivery & Servicing Management Plan (DSMP) (secured by condition), which should also include further details on the number of deliveries to site, which at 20 per day may be considered excessive. Subject to compliance with an approved revised DSMP the proposed servicing arrangements are unlikely to result in adverse impacts on the highway, and are considered acceptable.

Summary

Subject to financial contributions to implement the CPZ review referred to above, road safety improvements, for travel plan initiatives and monitoring; compliance with the recommended conditions which also require further details for the travel plan, delivery and servicing management plan, construction management plan, parking demand management, and cycle parking; and a legal

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Planning Committee 20/09/2017 Schedule Items 03 & 04 agreement that secures the provision of a private school bus service, it is considered that on-balance the proposal would not raise any adverse road safety concerns nor would it be considered to have a detrimental impact on the surrounding road network. The proposal would therefore be in accordance with policies 6.3, 6.9, 6.11 and 6.13 of the London Plan.

Environmental Health

London Plan Policies 5.21, 7.14 and 7.15 seek to manage potential impacts concerning contaminated land, air quality, and noise emissions (affecting both proposed occupants of the development and adjoining occupiers). These are supported by policies LV 5.21 and 7A of the Ealing DM DPD, interim SPG 10 ‘Noise and Vibration’ and the GLA Sustainable Design and Construction SPG.

Contaminated land

A Desk Study and Ground Investigation Report has been submitted (prepared by GEA, dated July 2017) and reviewed by the Council’s Pollution-Technical Officer. This report identifies elevated levels of lead and asbestos, and insufficient data on gas monitoring to draw conclusions at this early stage. Therefore more intrusive land investigations will be required, together with a remediation scheme to ensure that the health of prospective school users would not be at risk. A condition has been included to secure these matters. Subject to compliance with this condition, the development would be in accordance with policy 5.21 of the London Plan, and local variation 5.21 of the Ealing DM DPD.

Air Quality

An Air Quality Neutral Calculation has been submitted to demonstrate that the atmospheric emissions from the development are ‘Air Quality Neutral’ when compared to the benchmark levels specified within the GLA Sustainable Design and Construction SPG (2014). Accordingly the proposal would not contribute to the further deterioration of the poor air quality in this Air Quality Management Area (AQMA) which covers the entire borough.

In regards to potential exposure to poor air quality for occupants of the proposed school, the GLA has raised concerns that given the high concentration levels of Nox that the entire length of the ‘Inhabited Wall’ building would be exposed to adjacent to the North Circular Road, then further details of how the proposed mechanical ventilation would prevent the ingress of polluted air into the classrooms should be demonstrated prior to the determination of the application. The applicant has prepared an addendum in response to these comments that provides further information on the specialist Nox filters that would be used to ensure that the incoming air supply would be sufficient, the methodology used when preparing the modelling for the air quality assessment, the site characteristics that assist with emissions dispersal, as well as summarising key factors of the proposed ventilation strategy, specifically that:

• No façade openings are proposed on the northern façade (adjacent to the North Circular Road); while some classrooms may use this façade, all windows would be fixed. Mechanical cooling would be provided during the summer months; • All classrooms would be mechanically ventilated with NOx filters incorporated; • Intakes for the ventilation system would be at high level (approx. 14m above ground) and on the southern side of the inhabited wall building (the opposite side to the North Circular Road); and • Atrium spaces would be naturally ventilated, taking air from the southern façade only. These spaces would be transiently occupied.

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This addendum has been sent to the GLA for further consideration; however at the time that this report was written no comments have been received. An update will be provided in the Committee Briefing Notes. It can however be noted that in any event, should the Planning Committee resolve to grant planning permission then the proposal would need to be referred to the GLA for a Stage II response and direction as to whether planning permission should be granted or not. It may also be noted, that while the borough pollution-technical officer also raises concern with the high Nox concentration levels arising from the North Circular Road, contrary to the GLA officer, the borough officer does not object to the details of the ventilation strategy being secured through condition.

A condition has also been included requiring the submission of a Construction Method Statement which will need to be prepared with regard to the best practice guidance on dust control and air quality contained within the GLA Sustainable Design and Construction SPG (2014).

Noise impacts

A Noise Impact Assessment has been submitted (prepared by Max Fordham, dated April 2017) and reviewed by the Council’s Pollution-Technical Officer. This report identifies the North Circular Road as a significant source of noise generation experienced across the site. The proposed ‘Inhabited Wall’ building adjacent to the North Circular (and proposed solid fence structure on either side) would function as a significant noise barrier, enabling ambient noise levels across the majority of the completed site to be suitable for an urban school use. To further ensure that prospective school users would be provided with an acceptable acoustic environment, prescriptive conditions have been included recommending compliance with the relevant British Standards. This includes restrictions on plant and machinery noise emissions.

Concerning impacts on neighbouring occupiers there is potential for noise disturbance from the change of use of a long-vacant nursing home to a school. In general, given the general operating times of the school and restricted community-use hours (to be confirmed by a legal agreement) the development would be unlikely to generate such noise and disturbance that normal residential amenity would be adversely affected. In addition the potential noise breakout from the proposed school buildings would be minimised through standard sound insulation of the buildings envelope, managed through Building Regulations; and a condition has been included restricting noise emissions from music and amplified sound.

However it is recognised that particular areas of the site may be more sensitive to noise disturbance, specifically the residences on Iveagh Avenue along the eastern site boundary, which would be adjacent to the proposed Mixed Use Games Area (MUGA); and the residences on Brentmead Gardens in the south-western section of the site which would be adjacent to the proposed vehicle parking and coach turning area. To mitigate potential noise disturbance in these locations (beyond restrictions on the hours of use, and for deliveries and collections), conditions have been included requiring the submission of details of a sound barrier along the boundary with the MUGA; and the requirement for coaches/vehicles to not allow their engines to idle (to be included in a Parking Management Plan conditioned to be submitted). It is also recognised that soft landscaping and tree planting is proposed along the boundary shared with residences on Brentmead Gardens (details of planting conditioned) which would also assist in minimising any noise disturbance from vehicle use.

In regards to potential noise disturbance during the temporary construction phase, these would be minimised though good-practice, and a condition has been included requiring the submission of a revised Demolition and Construction Management Plan.

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Impact upon Amenity of Neighbouring Properties

Policy 7.6 of the London Plan (2016) requires new development not to cause unacceptable harm to the amenity of surrounding land and buildings, particularly residential buildings, in relation to privacy, and overshadowing. Policy 7B of the Ealing Development Management DPD (2013) similarly requires development to achieve high standards of amenity for adjacent uses by ensuring good levels of daylight and sunlight, privacy, and a positive visual impact.

The form, massing and site layout of the proposed buildings has been designed in consideration of minimising any potential impact on neighbouring residential amenity. The proposed buildings closest to the boundaries shared with adjacent residences are the Sports and Community building; the 'Inhabited Wall' building; the Swimming Pool building; and the proposed Gatehouses. The potential impact of these buildings on residential amenity is considered as follows:

Sports and Community Building

This part-two and part-three storey building would be setback 12m from the rear garden boundary of residences on Iveagh Avenue; and 36m from the principal rear elevations at the closest point. The proposed height in relation to the separation distance from the rear elevation windows on Iveagh Avenue houses complies with BRE guidelines indicating that a detailed sunlight and daylight assessment would not be required, and are therefore acceptable. The following images illustrate these separation distances and compliance with the BRE '25 degree' test:

Figure 2 Extract from Site Plan showing separation distance from neighbouring houses on Iveagh Avenue. Taken from p.64 of the Design and Access Statement (prepared by Walters & Cohen Architects, dated April 2017).

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Figure 3 Section sketch showing BRE ’25 degree’ test. Taken from p.64 of the Design and Access Statement (prepared by Walters & Cohen Architects, dated April 2017).

It is recognised that views from these properties into the site will change. However given the above separation distances in relation to the height it is considered unlikely that the proposal would result in harm to outlook or in the development appearing unduly overbearing. Tree planting along this boundary (and to the front of the building), and the vertical articulation of the facade treatment would also assist in reducing and screening the appearance of mass.

There are no side elevation windows proposed for the first or second floors that would facilitate undue overlooking onto these properties and overlooking.

The 'Inhabited Wall' Building

This part-three and part-four storey building would be oriented at an oblique angle from the eastern site boundary shared with the rear gardens of residences on Brentmead Gardens. Given the oblique angle the separation distances from the site boundary range from approximately 10m at the closest point to 19m, and between approximately 39m and 43m to the rear elevations of residences on this road. In addition the following image illustrates compliance with the BRE '25 degree' test, which while specified at a 19m separation distance from the boundary would also apply to the lesser separation distances:

Figure 4 Section sketch section showing BRE 25 degree test Taken from p.56 of the Design and Access Statement (prepared by Walters & Cohen Architects, dated April 2017).

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While 10m at the closest point on face value appears in very close proximity, this would be directly adjacent to a substation. The neighbouring residential property adjoining the substation would also be minimally impacted given the built-up nature of the rear of this site (outbuildings) and that the proposed building splays away from this boundary to increase its separation distance. The siting of the proposed ‘Inhabited Wall’ in relation to the western site boundary is shown in the image below:

Figure 5 Siting of 'Inhabited Wall' building (top of image) and proposed Swimming Pool building (bottom of image) shown in relation to western site boundary and residences on Brentmead Gardens. The substation is shown as the neighbouring structure closest to the proposed building (Extracted from Drawing No. 1612-PD-1003)

Overall, given the separation distances, the vertical articulation of the proposed facade, and existing and proposed tree planting to soften the appearance of bulk, it is considered that the proposal is unlikely to result in an adverse loss of light or outlook, or appear harmfully overbearing.

There are side elevation windows proposed for the first, second and third floors. However the closest distance to the boundary would be 15m, and greater still to the rear elevations of the houses. These separation distances are considered acceptable to not result in undue overlooking and loss of privacy.

Swimming Pool Building

The proposed swimming pool building would be single-storey (double-height) with the swimming pool sunken below ground level. It would be sited in an oblique angle from the boundary of the rear gardens on Brentmead Gardens, with a separation distance ranging from approximately 12m to 17m. Given the relatively minimal height in relation to the boundary, and existing and proposed woodland planting adjacent to the boundary it is considered unlikely that this building would result in loss of light, harm to outlook or would appear unduly overbearing. Given the single-storey nature of the building there would not be any upper floors to facilitate undue overlooking onto neighbouring properties. The above figure shows the siting of the proposed swimming pool building in relation to the site boundary.

Gatehouses

The proposed gatehouse nearest to the western site boundary would be two-storeys in height and a separation distance of approximately 1m at the closest point to the rear garden boundaries of houses on Brentmead Gardens. This separation distance is recognised to be very close on face value. However, due to the oblique angled siting of the gatehouse in relation to the partial rear boundaries of

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Planning Committee 20/09/2017 Schedule Items 03 & 04 two properties (as shown in the image below), it is not considered that this two-storey house would result in undue loss of light, overshadowing or outlook. The separation distance from the rear elevations of the houses on Brentmead Gardens would be approximately 21m, which is considered acceptable to mitigate residential amenity impacts on the dwellings.

Figure 6 Image showing siting of proposed gatehouses in relation to residences on Brentmead Gardens (Extract taken from Drawing No. 1612-PD-L1000 Rev A)

The only proposed first-floor window on the west-facing elevation of this gatehouse would serve a bathroom, and a condition has been included requiring this to be obscure-glazed to prevent undue overlooking and loss of privacy.

Other Affected Properties

Due to separation distances there are no other properties where the residential amenity is considered directly impacted by the proposed buildings.

Nonetheless it is recognised that the establishment of a coach loop and parking bays in the south- western section of the site would result in the removal of woodland adjacent to the rear gardens of residences on Brentmead Gardens. This would undoubtedly alter the outlook from these gardens, particularly in the short term. However many trees adjacent to this boundary would be retained, and the submitted Landscape Strategy proposes woodland planting along the western site boundary, and also on the median strip around which the proposed road would loop.

Therefore while the tree coverage directly adjoining the boundary in this location would be reduced in density, in combination with proposed woodland planting on the median area of the loop, it is anticipated that the longer term overall density of tree coverage as viewed from these gardens would be acceptable. A condition has been included requiring the submission of full soft landscaping and boundary treatment details. This includes specific provision for tree planting details along this boundary to ensure adequate screening/softening of potential amenity impacts.

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The potential noise nuisance on residential amenity is discussed in the sections 'Environmental Health - Noise Impacts' and 'Transport Matters and Servicing', and is considered acceptable subject to conditions.

Flood Risk and Surface Water Management

London Plan Policy 5.12 relates to flood risk management and seeks to minimise risks associated with flooding; and Policy 5.13 seeks the implementation of sustainable urban drainage systems (SUDS) in all development where feasible.

A Flood Risk Assessment and Drainage Strategy (prepared by Price & Meyers) have been submitted to support the proposal. The majority of the site is located within Flood Zone 1 (low probability); however smaller areas in the north of the site are within Flood Zones 2 and 3 (medium to high probability) which are at risk of fluvial flooding from the River Brent. Therefore the proposed flood mitigation measures include voids beneath the proposed ‘Inhabited Wall’ building to allow flood water to pass underneath essentially unobstructed. Some obstructions by structures such as piles and ramps would be necessary, but minimal, and in accordance with Environment Agency guidelines flood compensation storage would be provided to off-set these obstructions by lowering the existing ground levels of the proposed MUGA. The raised finished floor level of the proposed ‘Inhabited Wall’ building would provide a freeboard of more than 300mm above the 1 in 100-year plus climate change fluvial flood event.

Given that the proposal is for a major development, and a ‘more vulnerable’ educational use within a large site (5.4ha) that contains an area within Flood Zone 3, it is a requirement that the flood risk assessment and mitigation measures be assessed by the Environment Agency. Unfortunately the EA has confirmed that they are unable to carry out the required modelling assessment within the statutory timeframes. Following several discussions with the EA in order to prevent delay in the determination of the proposal, it has been agreed that should the flood risk mitigation be revised to accommodate a more onerous 1 in 1,000 year flood event as a proxy for climate change, then this would require a less intensive analysis by the EA and expedite the process. Accordingly, two proposed schemes have been submitted to the EA. However at the time of publication of this Committee Report, regrettably no assessment of either scheme has been received.

Nevertheless the EA has confirmed that the schemes will be assessed in advance of the Committee Meeting. Therefore, pending approval from the EA, their comments and any corresponding condition/s will be provided in the Committee Briefing Notes.

In regards to surface water management, and the use of sustainable urban drainage strategies, the Lead Local Flood Authority Officer does not raise any objections subject to the submission of the detailed design and maintenance plan through condition.

Energy and Sustainability

The provision of sustainable development is a key principle within the National Planning Policy Framework (2012), which requires the planning process to support the transition to a low carbon future. London Plan policies 5.2 and 5.3 require the submission of an energy demand assessment, along with the adoption of sustainable design and construction measures, and demonstration of how heating and cooling systems have been selected in accordance with the Mayor’s energy hierarchy. In particular, policy 5.2 requires that new development achieve at least a 35% reduction in regulated CO2 emissions above Building Regulations 2013. The 35% reduction target covers only regulated emissions and there is a priority for such reductions to be realised through ‘Be Lean’ measures (passive measures).

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A Planning Sustainability Report (Rev2) including BREEAM Pre-Assessment reports (dated 5th April 2017), an Energy Statement (dated 3rd April 2017) and an Energy Statement Addendum (dated 14 th July 2017) (all prepared by Max Fordham) has been submitted to demonstrate compliance with current Building Regulations (BR) Part L (2013), the London Plan and Ealing Local Variation energy and sustainability policies.

Sustainability

In terms of sustainability, to demonstrate compliance with Ealing LV policy 5.2, the applicant has submitted BREEAM NC Pre-Assessment and BREEAM Refurbishment and Fit-out Pre-Assessment reports for the converted/refurbished and new buildings, respectively, that predict a score of 57.99% and 62.37% , respectively (>55% Very Good rating).

In particular, all buildings would meet good standards of sustainable design and construction, including energy efficiency and fabric performance, water reduction systems and equipment, smart metering and leak detection systems, environmentally friendly and responsibly sourced materials, good levels of daylight, waste management during construction and operation, sound insulation standards in line with Building Regulations or better, best practice construction standards by registering to the considerate Constructor Scheme, improvement of biodiversity by applying a brown roof on the roof of the proposed pool building, and good public transport accessibility and cyclist storage facilities to encourage the use of alternative and more sustainable and affordable ways of travel.

The sustainability statement demonstrates that the proposed development would be designed in line with the requirements set by the Mayor’s Sustainable Design and Construction SPG, and policy 5.3 of the London Plan.

Energy Efficiency

A range of energy measures for all buildings within the development are proposed that improve upon the Building Regulation requirements, including improved U-Values, thermal mass and air permeability, low g glazing, natural ventilation and mechanical ventilation with heat recovery in the occupied spaces, low energy lighting and appropriate controls and sensors, high performing solar control glazing in all areas containing atriums etcetera. These measures would achieve an annual reduction in regulated CO2 emissions of approximately 29% (equating to 126.21 tonnes CO2) beyond Building Regulations Part L 2013.

The above measures have been also considered to reduce the risk of overheating. An Overheating Analysis has been submitted as part of the energy strategy and energy strategy addendum which demonstrates that all naturally ventilated spaces comply with the CIBSE, TM52 and TM49 criteria with the exception of spaces that are considered as ‘unoccupied’ such as stairs and the like.

An investigation into existing district heating networks has been conducted through the London Heat Map and has found no close network to which this development could currently connect. While this may be correct, it should be noted that the new school development is located very close to the OPDC Opportunity Area where a decentralised heating network is proposed. A commitment has therefore been provided by the applicant (and secured through condition 30(d)) to ensure that the proposed school complex would be future-proofed to facilitate connection to the OPDC area-wide DHN when it becomes available at a later date. Plant room layouts showing how the buildings would be future- proofed to connect to an offsite heat network have been submitted. Due to the different heat demands of each building and high heat losses related to a site-wide network, the applicant has discounted the option of a local distribution network connecting all buildings. An investigation into using CHP has also

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Planning Committee 20/09/2017 Schedule Items 03 & 04 been carried out but has also been discounted. No CO2 emission savings are proposed at this stage of the Mayor’s Energy Hierarchy.

A number of renewable technologies have been investigated with solar PV and ASHPs found to be the most suitable for this development. Solar PV panels with a total capacity of 45kWp would be installed on the roof of the new buildings, including the ‘Inhabited Wall’, Sports and Community Building and the Swimming Pool building. An annual reduction of 40 tonnes in regulated CO2 emissions, equating to approximately 17% CO2 emissions reduction beyond the ‘Be Lean’ stage is predicted from the proposed renewable technologies.

Additional technical information for both technologies in line with Appendix B of Ealing’s energy statement guidance and Appendix 3 of GLA’s planning guidance for preparing energy assessments (March 2016), have been requested through condition to assist with verification of the information provided within the energy statement. Roof plans showing solar PV panels have been submitted for the Inhabited Wall and Sports Building. However, no roof plan showing PV panels on the roof of the Pool building has been submitted and it therefore has been requested through a condition. With regards to the Abbey building, gas boilers are proposed with no additional renewable or low carbon technology.

The combination of all the above mentioned measures in the refurbished and new buildings predict an overall reduction in regulated CO2 emissions of 63.1%, equating to 277.8 tonnes per year, over the compliant BR Part L 2013 baseline. This shows compliance with London Plan policy 5.2.

Overall the proposals are considered to comply with the relevant London Plan and Ealing policies relating to low carbon technologies, and would result in a sustainable development with appropriate energy and CO2 savings. Conditions have been included requiring compliance with these policies; and post-construction renewable and low energy monitoring of the ASHP and solar PV would be secured through the legal agreement.

Fire Safety

Large schemes may require a number of different consents before they can be built. For example, Building Control approval needs to be obtained to certify that developments and alterations meet building regulations. Highways consent will be required for alterations to roads and footpaths ; and various licenses may be required for public houses, restaurants and elements of the scheme that constitute 'house in multi-occupation'.

The planning system allows assessment of a number of interrelated aspects of development when planning applications are submitted to the Council. The proposed materials to be used may be approved under a planning permission based on the details submitted as part of the planning application, or they may be subject to a condition that requires such details to be submitted and approved prior to the commencement of the development. Whichever the case, planning officers' appraisal of materials is focused on the visual impact of such materials in relation to the design of the overall scheme itself, the character of the local area or indeed on the amenities of local residents.

The technical aspects of the materials to be used in any development, in relation to fire safety, are considered under the Building Act (1984) and specifically the Building Regulations (2010). These require minimum standards for any development, although the standards will vary between residential and commercial uses, and in relation to new build and change of use/conversions. The regulations cover a range of areas including structure and fire safety.

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Any person or organisation carrying out development can appoint either the Council’s Building Control Service or a Private Approved Inspector to act as the Building Control Body (BCB), to ensure that the requirements of the Building Regulations are met. The BCB would carry an examination of drawings for the proposed works, and carry out site inspection during the course of the work to ensure that the works are carried out correctly. On completion of work the BCB will issue a Completion Certificate to confirm that the works comply with the requirements of the Building Regulations. In relation to fire safety in high rise residential developments, some of the key measures include protected escape stairways, smoke detection within flats, emergency lighting to commons areas, cavity barriers/fire stopping and the use of sprinklers and wet/dry risers where appropriate.

Conclusion

For all the reasons outlined in this report it is recommended that listed building consent be granted subject to conditions; and that on-balance, planning permission should be granted, subject to Section106 obligations and planning conditions to mitigate potential adverse impacts of the proposal.

Mayoral Community Infrastructure Levy (MCIL)

The development would not be liable to pay MCIL as education schemes are exempt.

Human Rights Act

In making your decision, you should be aware of and take into account any implications that may arise from the Human Rights Act 1998. Under the Act, it is unlawful for a public authority such as the London Borough of Ealing to act in a manner which is incompatible with the European Convention on Human Rights.

You are referred specifically to Article 8 (right to respect for private and family life), and Article 1 of the First Protocol (protection of property). It is not considered that the recommendation to approve the grant of permission in this case interferes with local residents’ right to respect for their private and family life, home and correspondence, except insofar as it is necessary to protect the rights and freedoms of others (in this case, the rights of the applicant). The Council is also permitted to control the use of property in accordance with the general interest, and the recommendation for approval is considered to be a proportionate response to the submitted application based on the considerations set out in this report.

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