planning report PDU/2032/02 1 October 2008 Central Square in the Borough of Brent planning application no. 07/3548

Strategic planning application stage II referral (old powers) Town & Country Planning Act 1990 (as amended); Greater London Authority Act 1999; Town & Country Planning (Mayor of London) Order 2000

The proposal This scheme proposes the development of 117 residential units to be provided in a part 13-storey, part five-storey building. The proposal includes retail and restaurant uses operating at ground floor with active frontage onto both Wembley Central Square and Wembley High Road. This is an amendment application for a residential block that forms part of the larger redevelopment of the Wembley Central Square site.

The applicant The applicant is Sowcrest Ltd and the architect is Dexter Moren Architects.

Strategic issues The principle of this residential led, mixed-use development at Wembley Central Square is in the interest of good strategic planning in London. However, previous comments on the scheme identified a number of strategic planning concerns, which included the proposed energy strategy, affordable housing provision, play space, access and transport proposals. Further information has now been provided and these previous concerns have been satisfactorily resolved.

Recommendation That Brent Council be advised that the Mayor is content for it to determine the case itself, subject to any action that the Secretary of State may take, and does not therefore wish to direct refusal.

Context

1 On 30 November 2007 Brent Council consulted the Mayor of London on an application for planning permission for the above uses at the above site. This was referred to the Mayor under Category 1C of the Schedule of the above Order, i.e. “Development which comprises or includes the erection of a building that is more than 30 metres high and outside the City of London.”

2 On 22 January 2008 the former Mayor considered planning report PDU/2032/01, and subsequently advised Brent Council that the proposal was broadly acceptable in principle with regard to strategic planning policy, but that further discussion on energy, transport, play space, housing and access was required.

3 A copy of the above-mentioned report is attached. The essentials of the case with regard to the proposal, the site, case history, strategic planning issues and relevant policies and guidance

page 1 are as set out therein, unless otherwise stated in this report. Since then, the application has been revised in response to the Mayor’s concerns (see below). On 26 February 2008 Brent Council decided that it was minded to grant planning permission for the revised application, and on 24 September 2008 it advised the Mayor of this decision. Under the provisions of the Town & Country Planning (Mayor of London) Order 2000 the Mayor may direct Brent Council to refuse planning permission, and has until 7 October 2008 to notify the Council of such a direction. This report sets out the information needed by the Mayor in deciding whether to direct refusal.

4 The Mayor of London’s decision this case, and his reasons, will be made available on the GLA website www.london.gov.uk.

Update

5 This application is an amendment to a previous scheme for the complete redevelopment of Wembley Central Square, which was also considered by the former Mayor in May 2004 PDU/0898/01. The former Mayor previously stated that he was content for Brent Council to determine the application itself and that he did not wish to direct a refusal. Brent Council subsequently granted planning permission for that application. The previous application proposed the comprehensive redevelopment of Wembley Central Square, which included a number of land uses within four different buildings. The current application proposes sixteen additional residential units incorporated within two additional floors within building 1. This proposal increases the building height from eleven to thirteen storeys. Energy

6 On 22 January 2008 the Mayor commented that the energy proposal for this scheme was not in line with London Plan energy policies. Since these comments, discussions have been on going and the applicant has subsequently amended the proposed energy strategy to include a range of new energy measures across the whole building.

7 The applicant has now provided baseline-modelling work to demonstrate how the proposed energy efficiency measures for the building will achieve the minimum carbon dioxide reduction requirements as set out in Part L of the 2006 Building Regulations.

8 The application previously proposed to provide heat and power via electricity and individual gas fired boilers within each residential unit. Following the former Mayor’s previous comments, the applicant has now introduced a communal gas boiler to provide heat and power to each residential unit via a centralised energy plant. This system will be designed to allow the potential for future connection to a site wide district heating system should such a scheme be implemented in the surrounding area in the future.

9 The applicant has now introduced a site wide biomass boiler system. The applicant has now provided modelling work to demonstrate that the boiler has been sized accordingly and will achieve a minimum 10% reduction in carbon dioxide. The applicant has also provided updated basement plans to demonstrate there is sufficient space and access provided for the boiler. Housing provision

10 The previous Section 106 Agreement included a 33% provision of affordable housing across the whole application site, which equated to a total of 85 affordable units. These units are delivered as part of the first phase of the overall scheme and the building work on these units is near completion.

11 The Mayor previously commented that further information should be provided to justify the provision of 33% affordable housing and to clarify the impacts of delivering additional affordable

page 2 housing units. Discussions between the applicant, the local planning authority and the Greater London Authority have been on going and further detail has been provided.

12 Brent Council has now agreed a ‘Deed of Variation’ with the applicant, whereby the proposed Section 106 Agreement for this application will require that the 33% proportion of affordable housing shall be applicable to this amended scheme. This will equate to an additional 4.8 social rented units being provided. Given that the affordable housing block is near completion, these social rented units can be provided off-site, or as a commuted financial sum. Play space

13 The Mayor previously requested that Brent Council include a financial contribution for amenity and play space requirements in line with the previous Section 106 Agreement. The Mayor also requested that the design of Wembley Central Square incorporate play space facilities.

14 Brent Council has included a financial contribution of £111,000 in the Section 106 Agreement for the delivery of education, transport, open space and sports regeneration. The Greater London Authority welcomes this financial contribution and would request that Brent Council ensure that sufficient play facilities are delivered within the Wembley Central Square area.

15 The applicant has now incorporated medium sized private residential balconies for all units, where technically feasible, which now provides an increased amount of private amenity space. Access

16 The applicant has not demonstrated how each of the residential units meet the 16 requirements of Lifetime Homes standards, which does not comply with the policy requirements of London Plan policy 3A.5. While the applicant has not carried out this assessment, the building design does include a range of satisfactory accessibility measures. • Two 8-person wheelchair access lifts. • The residential units are generously sized with adequate space to accommodate internal wheelchair-turning circles and would be easily adaptable for wheelchair use. • The fire escape routes incorporate wheelchair-standing points. • There are level gradients across the building. • There is a sufficient level of blue badge accessible car parking spaces on-site.

17 On balance, given the design will ensure that the building will achieve an environment accessible for all, the access proposals can be considered to be acceptable. Transport

18 TfL previously requested that the application should include one-for-one cycle parking. The local planning authority has included a requirement within the proposed Section 106 Agreement for sixteen additional cycle spaces to be provided, the application is in accordance with London Plan Policy 3C.22 Improving conditions for cyclists.

19 The previous Section 106 Agreement required the applicant to provide a detailed travel plan. TfL requests that the proposed Section 106 Agreement be amended to include provision of a full travel plan as defined in London Plan Policy 3C.2 Matching development to transport capacity. TfL would be pleased to provide further information in association with their best practice guidance on residential travel plans.

20 TfL previously commented on the appointment of the adjacent taxi rank as described in the submitted Transport Assessment. To ensure best practice guidance TfL would appreciate if the local authority discuss the design with TfL Public Carriage Office prior to implementation.

page 3 London Development Agency’s comments

21 The LDA welcomes the contribution of £111,000 (£3,000 per additional bed unit) index- linked from the date of committee for education, sustainable transportation, open space & sports or other regeneration improvements for Wembley Town Centre. However, the LDA is disappointed to learn that the section 106 agreement has not included a requirement to provide an employment and training initiative. In order to comply with the Economic Development Strategy and the London Plan objectives with regards to London's economy, local planning authorities are encouraged to secure an employment and training strategy from the applicant to ensure that local residents and businesses benefit from the development. Response to consultation

22 The local planning authority received one letter of objection in response to their public consultation process. This letter raised concerns relating to overcrowding, parking and impacts of the construction process. These concerns have been addressed throughout the two planning reports presented to the Mayor and do not raise any strategic planning concerns. Legal considerations

23 Under the arrangements set out in article 5 of the Town and Country Planning (Mayor of London) Order 2000 the Mayor has the power to direct the local planning authority to refuse permission for a planning application referred to him under article 3 of the Order. In doing so the Mayor must have regard to the matters set out in article 5(2) of the Order, including the principle purposes of the Greater London Authority, the effect on health and sustainable development, national policies and international obligations, regional planning guidance, and the use of the . The Mayor may direct refusal if he considers that to grant permission would be contrary to good strategic planning in Greater London. If he decides to direct refusal, the Mayor must set out his reasons, and the local planning authority must issue these with the refusal notice. Financial considerations

24 Should the Mayor direct refusal, he would be the principal party at any subsequent appeal hearing or public inquiry. Government guidance in Circular 8/93 (‘Award of Costs in Planning and Other (including Compulsory Purchase Order) Proceedings’) emphasises that parties usually pay their own expenses arising from an appeal.

25 Following an inquiry caused by a direction to refuse, costs may be awarded against the Mayor if he has either directed refusal unreasonably; handled a referral from a planning authority unreasonably; or behaved unreasonably during the appeal. A major factor in deciding whether the Mayor has acted unreasonably will be the extent to which he has taken account of established planning policy. Conclusion

26 The principle of this residential led, mixed-use development at Wembley Central Square is in the interest of good strategic planning in London. The proposal does not raise any tall building, strategic design or housing delivery concerns.

27 The Mayor previously raised a number of strategic planning concerns with relation to the applicant’s energy strategy, affordable housing provision, play space, access and transport proposals. Further information has now been provided and the majority of these previous concerns have been satisfactorily resolved.

page 4 28 It is disappointing that the applicant has not provided information demonstrating how each of the 16 Lifetime Homes standard design requirements have been addressed. However, the applicant has proposed a building design that will ensure that this building is fully accessible and on balance this approach is acceptable. The LDA are disappointed that the section 106 agreement does not include a requirement for the applicant to provide a training and employment strategy.

for further information, contact Planning Decisions Unit: Giles Dolphin, Head of Planning Decisions 020 7983 4271 email [email protected] Colin Wilson, Strategic Planning Manager (Development Decisions) 020 7983 4783 email [email protected] Michael Mulhern, Case Officer 020 7983 6535 email [email protected]

planning report PDU/2032/01

page 5 22 January 2008 Central Square Wembley in the planning application no. 07/3548

Strategic planning application stage 1 referral Town & Country Planning Act 1990 (as amended); Greater London Authority Act 1999; Town & Country Planning (Mayor of London) Order 2000

The proposal This scheme proposes the development of 117 residential units to be provided in a part 13-storey, part five-storey building. The proposal also includes retail and restaurant uses operating at ground floor with active frontage onto both Wembley Central Square and Wembley High Road. This is an amendment application for a residential block that forms part of the larger redevelopment of the Wembley Central Square site.

The applicant The applicant is Sowcrest Ltd, and the architect is Dexter Moren Architects.

Strategic issues The Mayor considers the principle of this residential led, mixed-use development at Wembley Central Square to be in the interest of good strategic planning in London. The proposal does not raise any tall building, strategic design or housing delivery concerns. There are however, a number of specific proposals that do not comply with London Plan policy, and further discussion and information is required before this application is returned to the Mayor:

• Additional detailed justification on the proposed 33% level of affordable housing is required.

• A detailed energy strategy and further modelling work is required.

• Further discussions surrounding the provision of child play space is required.

• Details of how the residential units achieve Lifetime Homes standards are required.

• TfL request that a Travel Plan be secured through the Section 106 Agreement.

Recommendation That Brent Council be advised that the principle of delivering additional residential units on this site is considered to be broadly in line with strategic planning policy. There are however, a series of specific concerns that need to be addressed before this application is returned to the Mayor.

Context

page 6 29 On 30 November 2007 Brent Council consulted the Mayor of London on a proposal to develop the above site for the above uses. Under the provisions of the Town & Country Planning (Mayor of London) Order 2000 the Mayor has the same opportunity as other statutory consultees to comment on the proposal. This report sets out information for the Mayor’s use in deciding what comments to make.

30 The application is referable under Category 1C of the Schedule of the Order 2000: ”Development which comprises or includes the erection of a building that is more than 30 metres high and outside the City of London.”

31 If Brent Council subsequently decides that it is minded to grant planning permission, it must first allow the Mayor an opportunity to decide whether to direct the Council to refuse permission.

32 The Mayor of London’s comments on this case will be made available on the GLA website www.london.gov.uk.

Site description

33 The application site sits on top of Wembley at the junction of Wembley High Road and London Road. The character of the surrounding Wembley area is that of high-density residential, office and retail development.

34 The site has now largely been cleared and construction works have already begun on the Station Grove affordable housing block. Prior to demolition, the site included 9,610 square metres of retail floor space set around the edge of the Central Square public space and 5,600 square metres of office space floorspace located predominately to the rear of Central Square.

35 The site also includes two residential tower blocks, Manor Court and Lodge Court, located to the east and west of Central Square, which do not form part of this application and will continue to remain in use.

36 There is also an underground multi-storey public car park with 315 spaces operating beneath the proposed site. Pedestrian access to Central Square is achieved from the Wembley High Road and from Station Grove/Montrose Crescent. Vehicular access to the underground car park is achieved by a rear service road with a ramped access from London Road.

37 The site is located on the eastern side of Wembley Central Square. Wembley High Road runs along the northern boundary of the site and forms part of the Strategic Road Network. The nearest Road Network road is the A406 , which is 1.8 km south east of the site. The Public Transport Accessibility Level of the site is five. There are ten regular bus services, including a 24-hour service, and two night buses that run within 400 metres of the site. The nearest bus stops are located on Wembley High Road. The development site is immediately adjacent to Wembley Central station, which is served by the Bakerloo line as well as and services towards Euston station.

Details of the proposal

38 The current application is an amendment to a previous scheme that was considered by the Mayor on 24 May 2004, and formally granted planning permission by Brent Council in October 2005, following detailed discussions on a Section 106 Agreement.

39 The current application seeks to deliver a residential led, mixed-use building with 117 residential units. The proposed building is comprised of two joined residential blocks: a five-storey block facing onto the improved Central Square space and a 13-storey block facing onto Wembley

page 7 High Road. This linked block includes retail and restaurant uses on the ground floor that offer active frontage onto both the newly proposed public square and Wembley High Road.

40 The current application is largely consistent with the proposals of the previous application. The key variation is the introduction of 16 additional residential units within the eleven-storey residential tower facing onto Wembley High Road. This inclusion has increased the building height from 11 to 13 storeys. Case history

41 In October 2005, detailed planning permission was granted for the comprehensive redevelopment of Wembley Central Square shopping centre. The approved scheme delivers a mixed of uses, including 223 residential units with retail, restaurant, hotel and leisure floorspace. This scheme includes four new buildings arranged around an improved public space:

• Two residential buildings fronting onto Wembley High Road and Central Square (one four-storey building and one eleven-storey building). These two buildings include private residential units with a range of ground floor retail, restaurant, leisure uses and access to the London Underground.

• Ramsey House, to the rear of Central Square, is an eight-storey building with a 120- bedroom hotel facility and ground floor retail and affordable housing units.

• Station Grove building is a five to eight storey residential building that is comprised solely of affordable housing units.

42 This previous application included 223 residential units, 10,649 square metres of retail and restaurant space, 2,172 square metres of leisure space and a 120-bedroom hotel facility. To date, the previous application has undergone a series of amendments that has resulted in the following alterations:

• The removal of the hotel facility and the redesign of Ramsey House to provide ground floor retail space, three floors of office space and 31 affordable housing units.

• The delivery of eight additional private units within the four-storey building facing onto Wembley High Road, which has also resulted in an increase in the buildings height from four to five storeys.

43 In February 2004 planning permission was granted for the erection of an overbridge to the rear of Wembley Central station and associated stairs/ramps and crowd marshalling areas for passengers on event days. This bridge is now complete and has been designed to handle up to 12,000 passengers hourly.

44 In June 2002 Brent Council resolved to grant planning permission for an outline application to redevelop Central Square subject to the completion of a Section 106 Agreement. The application was to determine the siting, design and means of access for a mixed use development comprising the demolition of 475-491 and units 1-41 Central Square and the redevelopment of the Square to retain 2,515 square metres of existing retail (use class A1) and food and drink (use class A3) floor space and to provide 6,200 square metres of additional A1, A3 and health and fitness (use class D2) floor space. The scheme also included the refurbishment of 5,740 square metres of accommodation within Ramsey House for office use (use class B1) or hotel use (use class C1) and the provision of 16,593 square metres of new residential accommodation as well as the complete refurbishment of Wembley Central Square car park and the capacity to provide a footbridge across the railway tracks to the rear of the station.

page 8 45 In 1999 outline planning permission was granted but not implemented for the comprehensive redevelopment of Central Square, comprising the enclosure of the open piazza area and a mixture of change of use/new-build to provide 2,150 square metres of retail floor space, 630 square metres of retail storage, 4,530 square metres of multi-screen cinema, 5,830 square metres of hotel or office accommodation, 900 square metres of family entertainment centre, 280 square metres of restaurant space, 940 square metres of office accommodation and 2,400 square metres for the provision of a library or leisure use including works to Central Square car park.

46 In 1996 an application for external alterations to the open space in Central Square to include the erection of canopies, parking and landscaping was granted but not implemented. Strategic planning issues and relevant policies and guidance

47 The relevant issues and corresponding policies are as follows:

• Housing London Plan; PPS3; Housing SPG; draft Providing for Children and Young People’s Play and Informal Recreation SPG • Affordable housing London Plan; PPS3; Housing SPG • Density London Plan; PPS3; Housing SPG • Urban design London Plan; PPS1 • Mix of uses London Plan • Regeneration London Plan; the Mayor’s Economic Development Strategy • Parking London Plan; the Mayor’s Transport Strategy; PPG13 • Retail London Plan; PPS6; PPG13 • Access London Plan; PPS1; Accessible London: achieving an inclusive environment SPG; Planning and Access for Disabled People: a good practice guide (ODPM) • Tall buildings/views London Plan; London View Management Framework SPG • Sustainable development London Plan; PPS1, PPS3; PPG13; PPS22; PPS Planning and Climate Change Supplement to PPS1; the Mayor’s Energy Strategy; Sustainable Design and Construction SPG

48 For the purposes of Section 38(6) of the Planning and Compulsory Purchase Act 2004, the development plan in force for the area is the 2004 Unitary Development Plan and the 2004 London Plan (with 2006 Alterations).

49 The draft Further Alterations to the London Plan, to which very significant weight can now be attached, as it has undergone public consultation, Examination in Public and is not subject to any Direction from the Secretary of State and the submission stage Core Strategy are also relevant material considerations. Land use principle

50 The Mayor and Brent Council previously approved the principle of delivering a scheme that incorporates the proposed mix of uses within Wembley’s Central Square site. It is considered that the identified land uses are appropriate town centre uses that will help provide added vitality to a site that is currently underutilised.

51 The proposed application building sits on top of Wembley Central station and has an existing planning permission to construct an eleven storey residential building with ground floor retail and restaurant uses with elevations facing onto Wembley High Road and Wembley’s Central Square,

page 9 this building also includes a smaller five storey residential block to the rear of the High Road with frontage solely on the Central Square.

52 The principle of increasing the number of residential units on this highly accessible town centre location is considered to be in accordance with the London Plan density matrix and London Plan policy 4B.3 on ‘Maximising the potential of sites’.

Housing provision 53 The previous Section 106 Agreement required a 33% provision of affordable housing units on- site, which equated to the delivery of 85 affordable housing units. The applicant provided detailed financial information to adequately justify this shortfall beyond the London Plan’s 50% affordable housing target. These 85 affordable housing units are delivered in two linked buildings, situated to the rear of the Central Square: • 31 affordable units are located on floors five to eight of Ramsey House, which also includes office and retail space on the lower floors.

• 54 affordable units are located in a new residential building along Station Grove.

54 These affordable units are being delivered as part of the first phase of building and are currently under construction. The applicant has predicted a June 2008 hand-over to Genesis, who is acting as the identified Registered Social Landlord for this scheme.

55 Brent Council and the applicant are currently in the process of preparing a ‘Deed of Agreement’ for the entire Central Square site. This agreement would require the applicant to provide a financial contribution for the delivery of off-site affordable housing should there be any increase in the provision of residential units on-site. This financial contribution would ensure that any future amendments to the previously approved scheme would continue to deliver 33% affordable housing.

56 The current application is for 16 new private residential units. The applicant is not proposing to provide any of these 16 units as affordable housing units on-site. Further information on the level of financial contribution for the delivery of off-site affordable housing is required.

57 The previous application for the Central Square site was granted planning permission in 2005. Consequently, additional financial information should be provided to justify the proposal to continue the 33% affordable housing contribution, to ensure that the maximum level of affordable housing is being achieved.

58 London Plan policy 3A.4 requires that residential developments should provide a range of housing mixes and choice. The proposed 16 residential units are private apartments and comprise eight 1-bed units and eight 2-bed units. Given that these 16 private units are located in a highly accessible area, the proposed private housing mix is considered to be acceptable. However, the introduction of any additional affordable units should comply with the affordable housing mix requirements of the London Plan. Design

59 The 2005 planning permission for this site approved the design details, layout and orientation of this residential block. The Mayor previously stated that ‘the overall design is likely to result in buildings of a satisfactory appearance, while the proposal represents a high density mixed use development that seeks to make the best use of scarce urban land and regenerate an important focal area of Wembley Central’. The applicant has proposed to maintain the building design,

page 10 orientation, roofline, fenestration placement and material use as set out in the previously consented scheme.

60 The additional 16 units are to be located in the high-rise tower block that faces directly onto Wembley High Road, and as set out in paragraphs 11 and 12 would result in an increase in the tower height from 11 to 13 storeys. Given the location of this site within the Wembley Town Centre and the context of the redevelopment of the wider Central Square site, the principle of delivering an increased tower height with additional residential units is considered to be in line with London Plan 3A.1 on ‘Increasing London’s supply of housing’ and policy 4B.9 on ’Large-scale buildings – design and impact’.

61 The proposed delivery of 16 additional residential units will allow the applicant to undertake a series of minor design and material use improvements across all the residential units within the Wembley Central Square area. These improvements are welcomed and include: • Change all window frames from PVC to aluminium • Introduce additional balconies to the residential units on the southern elevations. • Change the materials used in all balconies from galvanised metal to steel and glass. Access

62 This application includes 20 blue badge accessible car-parking bays. This level of accessible car parking is consistent with the London Plan Lifetime Homes residential car parking requirements and with the British Standard employment and commercial car parking requirements.

63 The applicant has provided detailed, scaled plans, demonstrating points of entry and egress from the site and has set out levels and gradients across the site, which are considered to be in accordance with the requirements of Part M of the 2006 Building Regulations.

64 The applicant has not provided a commitment to design 100% of residential units to meet the Lifetime Homes standards, and as such, the proposal is currently not considered to be consistent with London Plan policy 3A.4 on ‘Housing choice’. Play space

65 The previous application was submitted and assessed prior to the formal adoption of the Mayor’s London Plan and the draft Supplementary Planning Guidance on ‘Providing for Children and Young People’s Play and Informal Recreation’. However, the previous Section 106 Agreement for this site, required the applicant to provide a financial contribution of £80,000 to deliver child play space and play equipment within the Wembley Central Square public space. This financial contribution should be reprovided in any future Section 106 Agreement for this site.

66 In line with the Supplementary Planning Guidance on ‘Providing for Children and Young People’s Play and Informal Recreation’, the proposed building could have a child occupancy level of approximately 13 children. These play space requirements could be delivered either within the design of the Central Square public amenity space, or potentially incorporated within the footprint of the proposed buildings surrounding the Central Square. To ensure the adequate provision of child play space, further discussions between the Greater London Authority, Brent Council and the applicant are required. Energy

page 11 67 The London Plan energy policies 4A.7-4A.9 aim to reduce carbon emissions by requiring the incorporation of energy efficient design and technologies, and renewable energy technologies where feasible. An energy demand assessment is expected along with a demonstration of how heating and cooling systems have been selected in accordance with the Mayor’s hierarchy. The policies also require a demonstration of how the scheme meets a proportion of its energy demand from renewables with a 10% minimum target.

68 The draft further alterations to the London Plan require developments to make the fullest contribution to tackling climate change by minimising carbon dioxide, adopting sustainable design and construction and prioritising decentralised energy including the adoption of on-site renewable energy systems with a target of reducing carbon dioxide emissions by 20%, In line with the Mayor’s energy hierarchy the applicant has prepared an Energy Statement that has assessed a series of energy efficiency measures, the possibility of introducing a combined heat and power plant and a range of renewable energy sources.

69 The previous application was submitted and assessed prior to the formal adoption of the Mayor’s London Plan. Consequently, the previous application does not propose the delivery of energy measures consistent with the Mayor’s current energy hierarchy.

70 A detailed energy strategy has not been provided with this application. This application is, therefore, not considered to be in line with London Plan energy policies 4A.7 to 4A.9.

71 In response, the applicant has stated that, subject to detailed feasibility studies, the following energy proposals could be introduced on-site. These proposals would be delivered across all 117 units and go beyond the energy proposals of the scheme granted planning permission in 2005. • Change from an electric heating system to a gas heating system. • The installation of energy efficient and PIR lighting. • Grey water recycling. • AAA energy related appliances in all apartments.

72 To demonstrate how this scheme successfully achieves the Mayor’s energy hierarchy as set out in the London Plan and the further alterations to the London Plan, the applicant should provide a detailed energy strategy with information on the proposed energy efficiency measures, the carbon dioxide savings achieved through the alteration from an electric to a gas heating system, the potential to introduce a district heating system or combined heat and power plant system and an assessment of renewable energies. Transport for London’s comments

73 TfL previously commented on the application that was presented to the Mayor on May 2004. TfL considered that the proposed level of car parking was broadly in accordance with London Plan standards and cycle parking was considered to be broadly satisfactory. The development was considered unlikely to have a significant impact on the Transport for London Road Network.

74 TfL requested that the proposed taxi and interchange facilities be delivered as set out in the application and requested consultation with the applicant on the details of the proposed taxi facilities. TfL would like to reiterate the above comments and request further consultation on these proposals with the applicant.

page 12 75 The applicant has not proposed to introduce any further car parking spaces for the additional 16 residential units, and consequently TfL does not consider that the proposed amendments would result in any significant additional impact on the Transport for London Road Network.

76 TfL welcomes the proposal to provide a cycle parking space for each additional residential unit.

77 The previous Section 106 Agreement required the applicant to provided a detailed Travel Plan. TfL would request that this application should also be provided with a Travel Plan.

London Development Agency’s comments

78 In accordance with the London Plan and the Economic Development Strategy, the London Development Agency seeks to promote sustainable and economic growth and deliver healthy, sustainable, high quality communities and urban environments.

79 The site is located within the West London sub-region and one of the strategic priorities for West London is to create high density mixed use developments with an emphasis on strategic leisure, including hotels, restaurants, offices, shops with a civic core and housing to meet local as well as strategic needs. Consequently, the proposed development is in accordance with London Plan policy 3B.4 Mixed Use Development.

80 In line with London Plan policy 2B.12 on ‘Improving the Skills and Employment Opportunities for Londoners’ the local planning authority should encourage the applicant to ensure that local communities benefit from this new development. In particular, initiatives to create training opportunities for local people and to address other barriers to employment should be formalised through an agreement between the applicant and the local planning authority. Similarly, the use of local businesses during construction should be encouraged. Within the Section 106 agreement the applicant should submit an Employment and Training Strategy to secure implementation, stakeholder and developer involvement, employment and training targets, monitoring requirements and identify relevant initiatives. The LDA are happy to provide detailed guidance on this.

81 The applicant should also consider investment in tackling barriers to employment and the provision of good quality, affordable childcare to help meet objective 4 of the Economic Development Strategy. Local Planning Authorities position

82 Brent Council resolved to issue planning permission for the previous Wembley Central Square application in October 2005. At the time of writing this report, the formal views of Brent Council are not known.

Legal considerations

83 Under the arrangements set out in article 3 of the Town and Country Planning (Mayor of London) Order 2000 the Mayor has an opportunity to make representations to Brent Council at

page 13 this stage. If the Council subsequently resolves to grant planning permission, it must allow the Mayor an opportunity to decide whether to direct it to refuse planning permission. There is no obligation at this present stage for the Mayor to indicate his intentions regarding a possible direction, and no such decision should be inferred from the Mayor’s comments unless specifically stated. Financial considerations

84 There are no financial considerations at this stage.

Conclusion

85 The principle of this residential led, mixed-use development at Wembley Central Square is in the interest of good strategic planning in London. The proposal does not raise any tall building, strategic design or housing delivery concerns.

86 However, there are a number of specific proposals that do not comply with London Plan policy. Consequently this application is not in line with the policy objectives of the London Plan. The issues set out in the report would need to be address before this application is returned to the Mayor.

• Additional detailed justification on the proposed 33% level of affordable housing is required.

• Additional detailed energy information is required.

• Further discussions surrounding the provision of child play space is required.

• Details of how the residential units achieve Lifetime Homes standards are required.

• Further discussions with TfL are required regarding the provision of an up to date Travel Plan.

for further information, contact Planning Decisions Unit: Giles Dolphin, Head of Planning Decisions 020 7983 4271 email [email protected] Colin Wilson, Strategic Planning Manager (Development Decisions) 020 7983 4783 email [email protected] Michael Mulhern, Case Officer 020 7983 6535 email [email protected]

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