planning report D&P/3495/02 18 July 2016 South West Lands, Wembley in the London Borough of Brent planning application no. 14/4931

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

The proposal

A hybrid planning application, for the redevelopment of the site to provide seven mixed use buildings up to 19 storeys in height accommodating:

1. Outline planning permission for up to a total of 75,000 sq.m. to 85,000 sq.m. mixed floor space including up to 67,000 sq.m. of C3 residential accommodation (approximately 725 units); 8,000 sq.m. to 14,000 sq.m. for additional C3 residential accommodation, C1 hotel and/or sui generis student accommodation (an additional approximate 125 residential units; or 200-250 bed hotel; or approximate 500 student units; or approximate 35 residential units and 200 bed hotel); 1,500 sq.m. to 3,000 sq.m. for Classes B1/A1/A2/A3 /A4/D1/ D2; together with associated open space and landscaping; car parking, cycle storage, pedestrian, cycle and vehicle access; associated highway works; improvements to rear access to Neeld Parade; and associated infrastructure.

2. Full planning permission for a basement beneath Plots SW03 - SW05 to accommodate 284 car parking spaces and 19 motor cycle spaces; Building 3A within Plot SW03 to accommodate 183 residential units and 368 cycle spaces at ground floor; and associated infrastructure, landscaping and open space. The applicant The applicant is Quintain, and the agent is Signet Planning. Key dates Pre-application: 7 November 2014 Stage 1 reporting: 26 February 2015 Planning Committee date: 11 May 2016

Strategic issues summary  Urban design: Requested design changes and design guidance have been adopted. (Paragraphs 23 and 24).  Affordable housing: Initial offer of 10% has been increased to 32% by habitable rooms (30% affordable by unit). This offer has been independently verified, negotiation has taken place and options explored. A review mechanism has been adopted and Plots

page 1 SW01, SW02 and SW07 will be sold to an RSL. (Paragraphs 11 to 22).  Transport: The issues identified at Stage 1 have been resolved to TfL’s satisfaction. (Paragraphs 28 to 37). The Council decision In this instance Brent Council has resolved to grant planning permission. 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 or direct that he is to be the local planning authority.

Context

1 On 19 January 2016 the Mayor of London received documents from Brent Council notifying him of a planning application of potential strategic importance to develop the above site for the above uses. This was referred to the Mayor under Category 1A, 1B and 1C of the Schedule to the Order 2008:

1A: Development which comprises or includes the provision of more than 150 houses, flats, or houses and flats.

1B: Development (other than development which only comprises the provision of houses, flats, or houses and flats) which comprises or includes the erection of a building or buildings: (c) outside Central London and with a total floorspace of more than 15,000 square metres. (Insert additional text if other referral possibilities need to be discussed.)

1C: Development which comprises or includes the erection of a building of one or more of the following description: (c) the building is more than 30 metres high and is outside the City of London.

2 On 26 February 2016 the Mayor considered planning report D&P/3495/01, and subsequently advised Brent Council that the application did not comply with the London Plan, for the reasons set out in paragraph 95 of the above-mentioned report; but the possible remedies set out in that paragraph could address these deficiencies. A copy of the above- mentioned report is attached. The essentials of the case with regard to the proposal, the site, case history, strategic planning issues and relevant policies and guidance are as set out therein, unless otherwise stated in this report. Since then, the application has been revised in response to the Mayor’s concerns (see below). On 1 May 2016 Brent Council decided that it was minded to grant planning permission, for the revised application, and on 8 July 2016 it advised the Mayor of this decision. Under the provisions of Article 5 of the Town & Country Planning (Mayor of London) Order 2008 the Mayor may allow the draft decision to proceed unchanged, direct Brent Council under Article 6 to refuse the application or issue a direction to Brent Council under Article 7 that he is to act as the Local Planning Authority for the purposes of determining the application and any connected application. The Mayor has until 21 July 2016 to notify the Council of his decision and to issue any direction.

3 The environmental information for the purposes of the Town and Country Planning (Environmental Impact Assessment) Regulations 2011 has been taken into account in the consideration of this case.

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

page 2 Update

5 At the consultation stage Brent Council was advised that the application did not comply with the London Plan, for the reasons set out in paragraph 95 of the above-mentioned report; but the possible remedies set out could address these deficiencies:

 Principle of development: The principle of a residential led mixed use development on the applicant’s site is strongly supported as it reflects London Plan OAPF policy guidance, the Wembley AAP strategic aims and site specific policies and, with less material weight, the unimplemented 2004 planning permission.

 Housing mix: The housing mix for masterplan has only 10% three bedroom units, this offer is very low and should be reviewed by the applicant to provide a greater proportion of larger units. As the final quantum of residential units is subject to development phasing options, the applicant should agree a fixed percentage by unit type/size and this should be secured by condition.

 Affordable housing: The applicant should provide clarification on the affordable housing offer and its delivery before stage 2 referral. The current 10% offer appears to be low. There needs to be assurance that the phase 1 Building 3A delivery with no affordable housing is linked to remaining phases of the scheme. Once a finalised offer is made, the viability assessment should be independently reviewed on behalf of Brent Council and its findings shared with GLA officers.

 Urban design – outline Masterplan: The overall approach to the masterplan is supported but GLA officers believe the approach to defining South Way and its relationship with the residential development requires further consideration. Further assurance is required in the securing of design quality for the phased development through reserved matters, it is requested additional design coding is provided which with the parameter plans are secured by condition.

 Urban design – detailed phase 1, building 3A: The adopted approach to the design is supported, but the applicant is required to explore improvement options to improve the overall design quality. These relate to key a prominent inactive ground floor frontage in the north of the building facing The Terrace public space and the reconsideration of the floor plans to create better quality layout and possible increase in duel aspect units.

 Access: The applicant has responded positively to the comments made at the pre- application stage in its design & access statement, both the outline masterplan and detailed application set out clear guidelines to meet requirements of London plan policy. Conditions are required to secure the 10% wheelchair accessible units, Lifetime Homes compliance, 10% wheelchair accessible hotel rooms and 5% (and 5% adaptable) wheelchair accessible student rooms.

 Children & young person’s play: As the majority of outline masterplan will be developed through reserved matters applications it is required that the applicant agree to a condition that secures a quantum of floorspace based on a maximum and minimum figure basis. Furthermore Brent Council should consider if funds should be provided for the enhancement of existing facilities for off-site play provision.

 Sustainable energy: Based on the submitted energy assessment the carbon dioxide savings exceed the target set within Policy 5.2 of the London Plan however the comments set out in this report should be addressed in full before compliance with

page 3 London Plan energy policy can be verified. This should be completed before stage 2 referral.

 Flood risk/surface water run-off: The adopted approach is compliant with London Plan Policy 5.13 and the mitigation measures should be secured via an appropriate condition attached to any planning permission.

 Transport: Further consideration needs to be given to the proposed route below White Horse Bridge, taxi facilities and bus infrastructure around the site. Mitigation should also be secured to cover bus impacts and the council must consider how highway mitigation is secured and delivered. These issues must be resolved prior to the application being referred back to the Mayor at Stage 2.

Amendments since submission

6 Following stage 1 amendments to the scheme were submitted by the applicant in February 2016 relating to both the full and outline applications.

Full application

7 In relation to the detailed application the amendments include changes to Plot SW03A to the layouts of the residential floorplans; the addition of internal communal amenity areas; the addition of refuse chutes to each core; changes to the balconies general design especially at levels 17 and 18; and increase in size and landscaping of the courtyards. Other changes are to the basement parking, plant, levels, landscaping and building height. These changes have increased the number of residential units from 183 to 188 dwellings with a consequential amendment to the housing mix.

8 The proposed number of car parking spaces has been reduced from 284 to 158, and the basement car parking extent has been reduced. The number of cycle spaces has also been updated. These parking spaces will also serve the wider development and not just plot SW03A.

Outline application

9 The original submission for the outline application has also been amendment the key change is an alternative access to the basement car park under plots SW03 to SW05 through plots SW01/SW02 and under the access to the White Horse Bridge. This internal access road remains within the proposal allowing access to the Network Rail infrastructure adjacent to the tracks and the amendment does result in the removal of the access from this road to the basement car park. The only proposed access to the residential parking is now directly from South Way.

10 The amendments also result in increases in the heights of elements of the buildings on Plots SW03B, SW04 and SW05 by one storey. However, the proposed ground level is also reduced as a result of the changes to the car park, resulting in a relatively minor overall height change. Housing

11 At stage 1 issues were raised in relation to housing mix of both the full and outline applications, clarification was required to understand the affordable housing offer given that the initial offer of 10% was low given the current state of the market and a higher provision would be expected.

12 Since stage 1 the applicant has submitted an affordable housing viability assessment and this has been independently reviewed on behalf of Brent Council. Further negotiated has also taken place in relation to the affordable housing and housing mix.

page 4 Table 1: Housing mix and tenure

Studio 1 bed 2 bed 3 bed Total % Private 26 231 272 38 567 70.1% Affordable Rent 0 42 50 29 121 15% Discounted Market Sale 0 6 19 6 31 3.8% Intermediate 0 36 54 0 90 11.1% Total 26 315 395 73 809 100% Type/size % 4.6 40.7 48.0 6.7 100%

13 The housing mix was a result of negotiation with the applicant and sensitivity testing of the affordable housing mix to establish whether a lower percentage of 3 bed units would result in an increase in the level of affordable housing. The applicant subsequently revised some of the parameters for the application including the mix of housing by size and tenure.

14 Across the entire development (full and outline applications) the housing mix provides for only 6.7% large family 3 bed units. However, proportionally the majority of these relate to the affordable rent accommodation where 24% of units will be 3 bed and the discounted market rent units where 19.4% are 3 bed units. Although a lower proportion of private family sized housing is achieved, it is viewed as acceptable as this increases the proportion of affordable housing that the scheme achieves and is supported by Brent Council’s committee report as meeting local need.

15 The Brent Council committee highlights that the proportion of family sized affordable rent units is below the local policy level, with the proportion of intermediate family size homes, when averaged across both Intermediate tenures, being approximately 5 %. Although this provision is below local policy levels, the low provision of 3-bedroom intermediate homes is considered to be acceptable due to affordability issues for family sized intermediate units.

16 The ratio of Affordable Rented Homes to Intermediate homes is 50:50, which differs from the ratio specified in the London Plan 60:40, but it is accepted that the proposed tenure split has resulted in a significant increase in the proportion of affordable housing, with approximately 32% by habitable rooms (30 % by unit) being achieved and this non-compliant tenure split in this instance is supported.

Financial Viability Assessment Review

17 The applicant submitted an addendum to its Financial Viability Assessment (FVA) which sought to demonstrate that affordable housing offer represents the maximum reasonable proportion of affordable housing. It concludes that the revised affordable housing proposals will result in a reduced profit level of 14.0 % (IRR based on a present day basis) if the site value is based on ‘Historic Costs’, which meets their profit target and concludes that the proposal represents the maximum reasonable proportion of affordable housing.

18 Brent Council’s viability consultant has reviewed the applicant’s appraisal model and have undertaken then own assessment of the amended mix and concluded the assumptions that the applicant used in its addendum are not unreasonable and that applicant’s viability conclusions that 30 % affordable housing is the reasonable maximum the scheme can afford.

Review mechanism

19 As requested at stage 2 a review mechanism has been adopted given the phased delivery of the scheme over a number of years and this is secured through the Section 106 agreement. This will allow for the opportunity to increase the affordable housing provision in the event that scheme

page 5 performance improves. Sensitivity analysis shows that an increase in market housing sales values by 5% to 10 % could result in an increase in the profit levels from 17 % to 20.55 % respectively, demonstrating that a higher proportion of affordable housing may be achieved under certain circumstances. The reviews are to be undertaken with each residential Reserved Matters application (save for development that commences within 1 ½ years of the grant of outline consent).

20 The affordable housing review clause recommended by Brent Council specifies that the review mechanism is triggered for a plot (or part of a plot) if construction works on that plot (or part) do not meaningfully commence within 2 years of the approval of Reserved Matters. This allows the reconsideration of scheme viability if there are delays in the commencement of construction and the length of those delays may result in changes in the viability of the scheme. However, as the detailed design will have already been approved, it may be difficult provide any additional affordable housing in that plot and the applicant may therefore elect to provide any additional affordable housing in a subsequent plot.

Facilitating affordable housing delivery

21 In order to facilitate the early delivery of affordable housing, the applicant has proposed to dispose of (sell) Plots SW01, SW02 and SW07 to a Registered Provider (RP) of affordable housing, with the early delivery of those plots as 100 % affordable housing as a requirement of the purchase of the land. This would result in the delivery of Affordable Rent and Intermediate Shared Ownership units within those plots earlier than if they were delivered as a part of Plots SW03 to SW05. Plots SW01, SW02 and SW07 would not accommodate all of the affordable housing provision, and affordable homes would still be provided in Plots SW03 to SW05.

Conclusion

22 Substantial work and negotiation has taken place since stage 1 to secure 32% by habitable rooms (30 % of the units) as affordable housing as the maximum reasonable and a review mechanism is secured together with a the stated aim of facilitating early delivery of the affordable units through the disposal of plots SW01, SW02 and SW07 to a Registered Provider (RP). This aspect of the application is therefore complaint with the London Plan.

Urban design

Phase 1 detailed application

23 At stage 1 it was officer opinion that the design layout of building 3A (SW03) would be improved if the north facing elevation at ground floor facing The Terrace was amended to move the refuse store and mobility charging room to the rear and a further commercial unit provided. The applicant has responded to this by moving the principal residential entrance to face the Terrace and created a new commercial unit on the corner where entrance was previously located. Issues were also raised in relation to floorplans and the applicant has also been responded to by the applicant and this aspect of full application is therefore compliant with the London Plan.

Outline application

24 At stage 1 issues were raised in relation to the outline application proposals for plots SW3B and SW05 and the buildings relationship to South Way due to setting back of the building line from the street and the creation of a landscaped buffer. Brent Council have accepted that although the landscaped buffer is retained that high levels of natural surveillance of the street will be achieved through the incorporation of residential entrances and through the adoption of appropriate planting (trees with high canopies ) that allows for clear views of the street and the adoption of front gardens to the building plots. In addition further assurance has been also

page 6 provided in relation to securing residential design quality and this aspect of outline application is therefore compliant with the London Plan. Access and inclusive design

25 Since stage 1 the applicant has resolved issues relating to Blue Badge parking provision and has agreed to a condition that secures 10% of hotel bedrooms and 5% of student rooms are wheelchair accessible. This aspect of the application is therefore compliant with the London Plan. Children & young person’s play

26 The applicant’s child yield assessment has been amended since stage 1 and this estimates a yield of 230 children with requirement of 2,300 sq.m. of playspace and it is confirmed that local play for under 12 age group will be provided within the residential communal gardens. For the older age group the requirement will be met by Edward VII Park and Sherrans Farm Open Space which have been identified as being with 800 metres of the site together with new facilities proposed as part of the Wembley masterplan that include MUGA’s play areas. As requested at stage 1 a condition has been adopted that secures that children’s playspace is provided within each of the residential development plot areas. This aspect of the application is therefore compliant with the London Plan. Sustainable energy

27 Since stage 1 the applicant has provided the requested verification information and this aspect of the application is therefore compliant with the London Plan. Transport

28 At Stage 1 TfL identified a number of issues that the applicant needed to further consider. TfL expected that these issues would be resolved prior to reporting back to the Mayor at Stage 2. Since reporting at Stage 1 the applicant has provided information that clarifies a number of outstanding issues.

29 TfL expressed concerns about the potential for conflict between large vehicles reversing into the loading bay and cyclists accessing the development from South Way. TfL sought confirmation that an alternative access underneath White Horse Bridge would be available to cyclists at all times. The applicant has confirmed this in writing. TfL considers the matter to be resolved.

30 TfL expects the applicant to be committed to the package of highway works identified under the previous proposal. These highway works were aimed at facilitating servicing and delivery, taxis, coaches and buses. It is understood that the details of these highway works are subject to further discussions with Brent Council and TfL. The package of highway works will need to be secured by legal agreement.

31 At Stage 1 TfL expressed concerns that the current proposal ignores the safeguarding of land for bus stops on South Way, which was agreed as part of the bus strategy associated with the 2004 Stage 1 consent. The agreed bus strategy for the area would see a connection between Wembley Park Boulevard and South Way, with changes to the geometry of the Boulevard to allow it to be used by double-deck buses. This connection would need to utilise land that is within the applicant’s wider estate. The applicant would therefore be responsible for its delivery.

32 TfL considers the diversion of the bus route through Wembley Park Boulevard to be the best solution for bus access into the area, but it is understood that the applicant’s current preference is to retain the boulevard as a pedestrian only route. Brent Council has also expressed that it no longer wants buses to serve the boulevard directly in light of the pedestrianised nature

page 7 and seasonal alternative uses the boulevard now offers. If the boulevard route cannot be achieved, buses would have to use South Way to access the eastern area of Wembley, although this would provide poorer bus access to key destinations located along the Boulevard such as the London Designer Outlet and the Brent Civic Centre.

33 TfL understands the need for new services to be able to serve the east of the stadium in light of the residential offer being made. As such, land may need to be safeguarded within the South West Lands site to allow for bus stops on either side of the road at a point between Wembley Hill Road and Wembley Park Boulevard, close to trip attractors such as this development and Wembley Stadium station. The changes to the highway necessary to provide for these stops such as changes to kerb heights, bus shelters and bus flags should also be secured via an appropriate legal agreement.

34 TfL is supportive of the proposed amendments to the step free route to the eastbound (trains to London) platform on the basis that the amended route achieves a shallower gradient for users.

35 The transport assessment shows that the development will not create a significant impact on rail and underground services. TfL confirmed that it was satisfied with this conclusion and expressed support for the additional accommodation for Wembley Stadium station offered by the proposal. TfL considered the impacts of the development on buses in the context of the Wembley Area Action Plan, which is forecasted to generate a significant bus demand. A contribution of £270,000 towards bus capacity enhancements is sought.

36 The level of car parking is reduced from 284 car parking spaces to 158 car parking spaces, which represents a reduction in the ratio of car parking, from 0.4 under the 2014 application to 0.2 per residential unit. TfL welcomes the reduction in car parking and notes that the revised parking quantum is significantly lower than the maximum permissible car parking of 0.4 per residential dwelling set out in the Wembley Area Action Plan (WAAP).

37 The issues identified at Stage 1 have been resolved to TfL’s satisfaction. TfL expects the Travel Plan, Delivery and Servicing Plan (DSP) and Construction Logistics Plan (CLP) to be secured by legal agreement. The proposal is considered to be in conformity with the London Plan and as such is acceptable.

Letters to The Mayor/Deputy Mayor

The Football Association

38 The Football Association (FA) have raised concern over planning applications in the vicinity of Wembley Stadium and that they would damage the Stadium’s ability to host major events. Specifically this relates to the consequences of the new development on traffic flow, public order and safety on event days.

39 The issues relating to transport are addressed in this report and in Brent Council’ committee report. TfL have confirmed that the transport impacts of the scheme do not raise any strategic concerns subject to adoption of proposed conditions and s106 contributions. Response to consultation

page 8 40 Brent Council consulted the occupants of 225 existing properties and neighbouring properties to the estate as well as statutory and non-statutory organisations. Following the receipt of revised information a second round consultation was undertaken. A total of 4 letters of objections were received from local residents and businesses.

41 The objections raised the following issues: building height and relationship to the stadium; overlooking of existing residential properties; impact on privacy of Elizabeth House flat, loss of light on Elizabeth House due to height, impact on visual amenity and on stadium, impact on local infrastructure and amenities; inadequate parking; and housing type. These issues have been addressed in the Brent Council committee report and at stage 1.

The Football Association/Wembley National Stadium Limited (WNSL):

42 The Football Association (FA)/Wembley National Stadium Limited (WNSL) submitted two objections to the application relating to the original and amended applications.

43 The FA/WNSL have specified that they comment regularly on their support for the regeneration of the area surrounding the Stadium. However, they also highlight where they consider development proposals to have an effect on pedestrian and vehicular movement, car parking and the effective and safe operation of the Stadium. With regard to this proposal, they have commented on event day transport and parking, noise and views to Wembley Stadium.

44 The FA’s concerns regarding event day transport and parking relate to the secondary access to the larger of the car parks, which was originally proposed to run between SW01 and SW02, leading to the car park under plots SW03-SW05. The FA considers that the Event Day access management plan for the development will impact on Event Day traffic and crowd flow operations for Wembley National Stadium. They believe it will adversely impact the safety of the current Event Day operations and will in turn lead to a reduced passenger provision at Wembley Stadium Station. The FA refer to the paragraphs within the Wembley AAP which refer to the use of Station Square as a holding area for passengers boarding rail services and that car parking access should not conflict with pedestrian movements and the closure of South Way on event days.

45 WNSL also object to the quantum of residential accommodation as it exceeds the Wembley AAP Site proposals and the extant consent, the level of proposed student accommodation will result in the number of student rooms, the building heights and impact on key views of the stadium and that conditions should be adopted in relation to noise.

46 These issues have been addressed in Brent Council’s Committee report and TfL conclude that the transport impacts of the scheme do not raise any strategic concerns subject to adoption of proposed conditions and s106 contributions. Furthermore it is GLA officers opinion that the increased quantum of residential development is keeping with the aims of London Plan OAPF guidance.

47 Representations were also received from the following statutory organisations and bodies:

 Natural England: No objection.

 Network Rail: The principle of using the existing northern step free access for vehicles and pedestrians is acceptable subject to specified design criteria; Chiltern Rail will stay in the porta-cabin facilities (within the location of plots SW01 and SW02) for a maximum of 5 years after which time purposes built accommodation to an agreed specification and location will be provided; The development must ensure that all current rights of way in around the station are protected together with access to Chiltern’s generators and other operational railway equipment;� No works should commence on site until the developer has received confirmation from Network Rail that all necessary legal agreements, land transfers, clearances, or rights of access and asset protection issues have been agreed between

page 9 Network Rail, Chiltern and the developer; the inclusion of a number of conditions and/or informatives which are included in the committee report.

 Chiltern Railways: Have requested that the impact of both applications 14/4931 and 15/5550 are considered as a whole and that the Section 106 contributions that are proposed are examined. It requests a total of £674,000 from the combined schemes (15/5550 masterplan and 14/4931 SW Lands) towards: platform shelters and seating, customer information screens, canopy for staircases; and platform landing area. These contributions are subject to discussions between the applicant and Chiltern Railways.

 Environment Agency: No objection. Article 7: Direction that the Mayor is to be the local planning authority

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

49 Under the arrangements set out in Article 5 of the Town and Country Planning (Mayor of London) Order 2008 the Mayor has the power under Article 6 to direct the local planning authority to refuse permission for a planning application referred to him under Article 4 of the Order. He also has the power to issue a direction under Article 7 that he is to act as the local planning authority for the purpose of determining the application and any connected application. The Mayor may also leave the decision to the local authority. In directing refusal the Mayor must have regard to the matters set out in Article 6(2) of the Order, including the principal purposes of the Greater London Authority, the effect on health and sustainable development, national policies and international obligations, regional planning guidance, and the use of the River Thames. The Mayor may direct refusal if he considers that to grant permission would be contrary to good strategic planning in Greater London. If he decides to direct refusal, the Mayor must set out his reasons, and the local planning authority must issue these with the refusal notice. If the Mayor decides to direct that he is to be the local planning authority, he must have regard to the matters set out in Article 7(3) and set out his reasons in the direction.

Financial considerations

50 Should the Mayor direct refusal, he would be the principal party at any subsequent appeal hearing or public inquiry. Government Planning Practice Guidance emphasises that parties usually pay their own expenses arising from an appeal.

51 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.

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

page 10 Conclusion

53 Having regard to the details of the application, the matters set out in Brent Councils committee report, its draft decision notice and the draft heads of terms, the scheme is acceptable in strategic planning, transport and movement terms. Further information has been provided and conditions and planning obligations have been secured where appropriate, which address the outstanding issues that were raised at Stage 1. On this basis, there are no sound reasons for the Mayor to intervene in this particular case.

for further information, contact GLA Planning Unit (Development & Projects Team): Stewart Murray, Assistant Director -Planning 020 7983 4271 email stewart.murray@london .government.uk Colin Wilson, Senior Manager – Development & Projects 020 7983 4783 email [email protected] Jonathan Aubrey, Case Officer 020 7983 5823 email [email protected]

page 11

planning report D&P/3495/01 26 February 2015 South West Lands, Wembley in the London Borough of Brent planning application no. 14/4931

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

The proposal

A hybrid planning application, for the redevelopment of the site to provide seven mixed use buildings up to 19 storeys in height accommodating:

Outline planning permission for up to a total of 75,000 sq.m. to 85,000 sq.m. mixed floor space including up to 67,000 sq.m. of C3 residential accommodation (approximately 725 units); 8,000 sq.m. to 14,000 sq.m. for additional C3 residential accommodation, C1 hotel and/or sui generis student accommodation (an additional approximate 125 residential units; or 200-250 bed hotel; or approximate 500 student units; or approximate 35 residential units and 200 bed hotel); 1,500 sq.m. to 3,000 sq.m. for Classes B1/A1/A2/A3 /A4/D1/ D2; together with associated open space and landscaping; car parking, cycle storage, pedestrian, cycle and vehicle access; associated highway works; improvements to rear access to Neeld Parade; and associated infrastructure.

Full planning permission for a basement beneath Plots SW03 - SW05 to accommodate 284 car parking spaces and 19 motor cycle spaces; Building 3A within Plot SW03 to accommodate 183 residential units and 368 cycle spaces at ground floor; and associated infrastructure, landscaping and open space. The applicant The applicant is Quintain, and the agent is Signet Planning.

Strategic issues The principle of a mixed use development is strongly supported, but issues relating to urban design, housing mix, affordable housing, children’s play, sustainable energy and transport should be resolved before stage 2 referral.

Recommendation That Brent Council be advised that the application does not comply with the London Plan, for the reasons set out in paragraph 95, but that the possible remedies set out in that paragraph could address these deficiencies.

page 12 Context

1 On 19 January 2015 the Mayor of London received documents from Brent Council notifying him of a planning application of potential strategic importance to develop the above site for the above uses. Under the provisions of The Town & Country Planning (Mayor of London) Order 2008 the Mayor has until 27 February 2015 to provide the Council with a statement setting out whether he considers that the application complies with the London Plan, and his reasons for taking that view. The Mayor may also provide other comments. This report sets out information for the Mayor’s use in deciding what decision to make.

2 The application is referable under Categories 1A, 1B and 1C of the Schedule to the Order 2008:

1A: Development which comprises or includes the provision of more than 150 houses, flats, or houses and flats.

1B: Development (other than development which only comprises the provision of houses, flats, or houses and flats) which comprises or includes the erection of a building or buildings: (c) outside Central London and with a total floorspace of more than 15,000 square metres.

1C: Development which comprises or includes the erection of a building of one or more of the following description: (c) the building is more than 30 metres high and is outside the City of London.

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

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

5 The site is located between Wembley Stadium and Wembley town centre and occupies an area that will form a key gateway linkage joining the town centre to the stadium comprehensive development area that has recently seen the development of Brent Council’s new Civic Centre, the refurbished Wembley Arena and Quintain’s stage 1 retail London designer outlet centre and residential development.

6 The site is split into two areas, the first area is located between the stadium and railway line and includes the recently built Station Square, with a northern boundary edge defined by South Way. A further smaller site parcel is located south of the railway line across the new White Horse Bridge and is part of the core area of Wembley town centre and has a frontage to White Hill Road. Both development sites have been cleared and are ready for development.

7 The site is located adjacent to Wembley Stadium station and is served by Chiltern Railways services between Marylebone and Gerrards Cross and Aylesbury. However, outside of event days, services are relatively infrequent, with two or three trains per hour in each direction. Approximately 950 metres to the west of the site is Wembley Central station, which is served by London Underground services on the Bakerloo line as well as London Overground services between Watford Junction and Euston and Southern rail services between Watford Junction, Clapham Junction and Brighton. Five bus routes (83, 92, 182, 223 and 224) stop outside Wembley Stadium station on Wembley Hill Road, with the 18 service stopping approximately 350 metres away on Harrow Road. In addition, the 206 service is within 550 metres walking distance of part of the site

D&P/3495/01 South West Lands Stage 2 page 13 further east on South Way, and the 79, 204 and 297 services within 600 metres of part of the site further west on Wembley High Road. As such, the public transport accessibility level (PTAL) of the site ranges from 3 (representing average accessibility) in the east to 5 (representing very good accessibility) in the west. This is primarily due to the western plots being closer to Wembley Central station and bus services on Wembley High Road.

8 The road network adjacent to this site is mainly the responsibility of Brent Council, with the closest part of the Transport for London Road Network (TLRN) being the A406 North Circular Road approximately 1.5km to the south-east. However, the A404 Harrow Road / Wembley High Road 150 metres to the south form part of the Strategic Road Network (SRN).

Details of the proposal

9 A hybrid planning application, for the redevelopment of the site to provide seven mixed use buildings up to 19 storeys in height accommodating:

10 Outline planning permission for up to a total of 75,000 sq.m. to 85,000 sq.m. mixed floor space including up to 67,000 sq.m. of C3 residential accommodation (approximately 725 units); 8,000 sq.m. to 14,000 sq.m. for additional C3 residential accommodation, C1 hotel and/or sui generis student accommodation (an additional approximate 125 residential units; or 200-250 bed hotel; or approximate 500 student units; or approximate 35 residential units and 200 bed hotel); 1,500 sq.m. to 3,000 sq.m. for Classes B1/A1/A2/A3 /A4/D1/ D2; together with associated open space and landscaping; car parking, cycle storage, pedestrian, cycle and vehicle access; associated highway works; improvements to rear access to Neeld Parade; and associated infrastructure. Key design elements of the masterplan are:

 A gateway development that defines the new pedestrian route across White Horse Bridge and public square linking to Wembley Boulevard.

 The eastern residential driven part of the master plan facing South Way is formed by series of U and L shaped blocks with the latter having stepped back form. The three predominately residential blocks are separated from the road by a landscape garden edge.

D&P/3495/01 South West Lands Stage 2 page 14  The U-shaped block together with the western perimeter block create key defining edges to White Horse Square, South Way and White Hill Road.

 South of the railway line a further two building plots define the entrance to White Horse Bridge. The western block has a freestanding building and the eastern takes a U shaped form with small courtyard.

 Parking is provided predominantly in block under the proposed podium gardens.

11 Full planning permission for Building 3A within Plot SW03 to accommodate 183 residential units and 368 cycle spaces at ground floor and associated infrastructure, landscaping and open space together with the development of basement beneath Plots SW03 - SW05 to accommodate 284 car parking spaces and 19 motor cycle spaces.

Case history

12 The application proposals were subject to the GLA pre-application process and a pre- application report was issued on 7 November 2014.

13 The site has a previous consent dating from 2004 for 85,000 of development comprising 43,160 sq.m. residential, 21, 747 sq,m. commercial (B1), 7,475 sq.m. retail (A1-A4) and 12,961 sq.m. community (D1) and leisure (D2). The land was the subject of a compulsory purchase order by the London Development Agency and is now in GLA ownership.

Strategic planning issues and relevant policies and guidance

14 The relevant issues and corresponding policies are as follows:

 Mix of uses London Plan;

D&P/3495/01 South West Lands Stage 2 page 15  Housing London Plan; Housing SPG; Housing Strategy; draft Revised Housing Strategy; Shaping Neighbourhoods: Play and Informal Recreation SPG; draft Shaping Neighbourhoods: Character and Context SPG;  Affordable housing London Plan; Housing SPG; Housing Strategy; draft Revised Housing Strategy;  Density London Plan; Housing SPG;  Urban design London Plan; draft Shaping Neighbourhoods: Character and Context SPG; Housing SPG; London Housing Design Guide; Shaping Neighbourhoods: Play and Informal Recreation SPG;  Access London Plan; Accessible London: achieving an inclusive environment SPG;  Sustainable development London Plan; Sustainable Design and Construction SPG; Mayor’s Climate Change Adaptation Strategy; Mayor’s Climate Change Mitigation and Energy Strategy; Mayor’s Water Strategy;  Ambient noise London Plan; the Mayor’s Ambient Noise Strategy;  Transport and parking London Plan; the Mayor’s Transport Strategy;  Crossrail London Plan; Mayoral Community Infrastructure Levy; Crossrail SPG.

15 For the purposes of Section 38(6) of the Planning and Compulsory Purchase Act 2004, the development plan in force for the area are the Brent Core Strategy (2011), the Site Specific Allocations DPD (2011), saved policies from the Brent Unitary Development Plan (2004) and the 2011 London Plan (with 2013 alterations).

 The following are also relevant material considerations:  The National Planning Policy Framework and Technical Guide to the National Planning Policy Framework.  The draft Further Alterations to the London Plan (FALP) (2014).  Brent Council, Site Allocations DPD & Saved UDP Policies  Wembley Area Action Plan (2014) Principle of development

16 The development proposals are for a residential led mixed development with a total floorspace area of between 75,000 and 85,000 sq.m (Table 1). This includes the provision of 725 residential units (and either an additional 125 units, hotel or student accommodation space), together with 1,500 to 3,000 sq.m. commercial/retail/leisure use.

Table 1: Land use mix

Land use Class sq.m. Units Residential C3 67,000 725 Hotel or C1 200 Student accommodation or Sui generis 500 Residential C3 125 Commercial, retail, leisure B1, A1-A5, D1-D2 1,500 - 3,000

Total 75,000 -85,000

D&P/3495/01 South West Lands Stage 2 page 16 17 The uses are spread through the masterplan which consists of 7 development plots (Table 2) with predominantly active ground floor uses and residential upper floors.

Table 2: Masterplan plot mix

Land use Ground Floor Upper floors Plot SW01 A1-A4 retail, D1 community and/or D2 assembly and leisure Residential Plot SW02 A1-A4 retail, D1 community and/or D2 assembly and leisure Hotel or Student Halls Plot SW03 Western frontage A1-A4 retail, D1 Buildings 3A, community and/or D2 assembly and 3B, 3C leisure Residential Plot SW04 buildings 4A and 4B Possible D2 assembly and leisure Residential Plot SW05 buildings 5A and 5B Possible D2 assembly and leisure Residential Plot SW06 Non-residential A1-A4 retail, D1 community and/or D2 assembly and leisure Plot SW07 A1-A4 retail, D1 community and/or D2 assembly and leisure Residential

18 The site has a previous consent dating from 2004 for 85,000 of development comprising 43,160 sq.m. residential, 21, 747 sq,m. commercial (B1), 7,475 sq.m. retail (A1-A4) and 12,961 sq.m. community (D1) and leisure (D2). The principle of a residential led mixed use development has previously been supported.

Wembley Opportunity Area Planning Framework

19 The site is identified located within the Wembley Opportunity Area where development is guided by London Plan policy 2.13 (opportunity areas and intensification areas) and as set out in Table A1.1 Opportunity Areas, the Opportunity Area is identified as having employment capacity for 11,000 jobs and 11,500 new homes. The development rationale is defined as the following:

“New housing and leisure-related development should be integrated with the iconic and world-class stadium and other facilities, including the Arena and Conference Centre. Supported by upgrades to the three stations, improved public transport will play a key role in managing heavy demand for mass movement, links between the stations and the strategic leisure facilities should be improved. Development should contribute to the regeneration, vitality and viability of Wembley as a town centre, including its expansion eastwards. Proposals should enhance permeability and connectivity to the wider hinterland and the potential to locate a civic facility including a school adjacent to Olympic Way should be explored.”

20 London plan policy 2.13 states: “Development proposals within opportunity areas and intensification areas should: a support the strategic policy directions for the opportunity areas and intensification areas set out in Annex 1, and where relevant, in adopted opportunity area planning frameworks b seek to optimise residential and non-residential output and densities, provide necessary social and other infrastructure to sustain growth, and, where appropriate, contain a mix of

D&P/3495/01 South West Lands Stage 2 page 17 uses c contribute towards meeting (or where appropriate, exceeding) the minimum guidelines for housing and/or indicative estimates for employment capacity set out in Annex 1, tested as appropriate through opportunity area planning frameworks and/or local development frameworks d realize scope for intensification associated with existing or proposed improvements in public transport accessibility, such as Crossrail, making better use of existing infrastructure and promote inclusive access including cycling and walking e support wider regeneration (including in particular improvements to environmental quality) and integrate development proposals to the surrounding areas especially areas for regeneration”

21 The optimisation of residential and non-residential output and densities is expected in Opportunity Areas, Necessary social and other infrastructure necessary to sustain this growth will also need to be secured. The scheme as proposed makes a significant contribution towards meeting the minimum guidelines for housing and employment capacity as set out in the London Plan, and is welcomed in principle.

Wembley AAP

22 The Brent Council Wembley Area Action Plan sets out the strategy for growth and regeneration for Wembley over the next 15 years. The plan has been through several rounds of consultation and was the subject of an examination in public earlier this year. The principles and policies have assessed at a strategic level by GLA officers and the plan has been found to be in accordance with the London Plan and supported by the Mayor.

23 The site is located in the sub area identified in the APP as the Stadium Comprehensive Development Area (SCDA) with the area designated as a strategic cultural area where leisure, tourism and cultural uses are encouraged. The development proposal’s location is specifically identified as site W6 in the SCDA where a major mixed use development is encouraged and a limited scale of development south of the White Horse Bridge. Retail and leisure component in proposals is strongly supported and residential use is encouraged away from the new White Horse Square/ Bridge pedestrian route.

Wembley Town Centre

24 The south west edge of the site is also within the Wembley Town Centre, identified as a major town centre in the London Plan. Development proposals are expected to sustain and enhance the vitality and viability of the centre, and accommodate economic and/or housing growth. The provision of a mix of uses, including retail and potentially hotel or student accommodation are appropriate for this town centre location. As noted above, the proposals include potential for 1,500 sq.m. to 3,000 sq.m. commercial/retail/leisure floorspace, in addition to potiential hotel or student accommodation uses.

25 Such proposals would assist in activating White Horse Square/ Bridge linkage route and White Hill Road. This approach is in keeping with AAP strategic aim of linking Wembley town centre with the emerging retail floorspace in the Comprehensive Development Area to evolve an enlarged major centre. The expanded town centre will have a contiguous boundary with Wembley Park district centre, which was agreed with the GLA for the purpose of eventually evolving into a single major centre. The commercial, retail, hotel and leisure uses are therefore strongly supported.

D&P/3495/01 South West Lands Stage 2 page 18 Conclusion

26 The principle of a residential led mixed use development on the applicant’s site is strongly supported as it reflects London Plan OAPF policy guidance, the Wembley AAP strategic aims and site specific policies and, with less material weight, the unimplemented 2004 planning permission. Housing

27 London Plan Policy 3.3 confirms the pressing need for more homes in order to promote opportunity and provide a real choice for all Londoners in ways that meet their needs at a price they can afford. Part B of this policy states that the Mayor will seek to ensure that the housing need identified in paragraphs 3.17 and 3.18 of the London Plan is met, particularly through provision consistent with at least an annual average of 32,210 net additional homes across London. The FALP increases this projection to 42,000. London Plan Table 3.1 sets a target for Brent Council to deliver a minimum of 1,065 new residential units a year until 2021. The FALP sets out new targets for the period to 2025 with Brent Council’s annual monitoring target increasing to 1,525 homes. The proposal would make a welcomed contribution to the supply of housing, meeting up to 80% of the annual target and over 7% of the opportunity area target.

Housing mix

28 London Plan policy 3.8 encourages a full range of housing choice. This is supported by the London Plan Housing SPG, which seeks to secure family accommodation within residential schemes, particularly within the social and affordable rented sector, and sets strategic guidance for councils in assessing their local needs. Policy 3.11 of the London Plan states that within affordable housing provision, priority should be accorded to family housing. Also of note is Policy 1.1, part C, of the London Housing Strategy, which sets a target for 42% of social/affordable rented homes to have three or more bedrooms. The housing mix set out in table 1 and table 2 are derived from figures set out in the applicant’s design & access statement and its viability assessment. Both set a target quantum of 804 units.

Table 1: Design Access Statement residential mix & tenure

Studio 1B/2P 2B/3P 2B/4P 3B/5P 3B/6P Flat Flat Flat Flat Flat Total % Private sale 31 248 143 175 39 13 649 81 Intermediate 0 50 42 19 14 0 125 16 Social Rent 0 5 4 6 14 1 30 4 Total 31 303 189 200 67 14 804 100 % 4 38 24 25 8 2 100

Table 2: Design Access Statement residential mix & tenure

1B/2P 2B/3P 2B/4P 3B/5P 3B/6P Studio Flat Flat Flat Flat Flat Total % Private sale 31 284 185 187 39 13 739 92 Intermediate 0 10 0 5 10 0 25 3 Social Rent 0 9 4 8 18 1 40 5 Total 31 303 189 200 67 14 804 100 % 4 38 24 25 8 2 100

D&P/3495/01 South West Lands Stage 2 page 19 29 The proposed overall percentages of housing unit size/tenure is strongly skewed towards smaller units with only c10% three bed dwellings, although the predominance of larger units in the affordable intermediate/social provision appears reasonable. The Wembley AAP policy WEM 19 identifies at least 25% (in line with the Core strategy requirement) of new homes in Wembley should be family sized, with 3 bedrooms or more and this is strongly supported. The applicant is encouraged to increase the overall percentage of 3 bed private units.

1B/2P 2B/3P 2B/4P 3B/5P Studio Flat Flat Flat Flat Total Private sale 5 67 41 51 19 183 % mix by unit 3 37 22 28 10 100 % mix by hab rooms 1 27 25 31 15 100

30 The full application for phase 1, building 3A sets out a housing mix which is reflective of the overall masterplan with 10% large 3 bed units. The applicant should consider revising the housing mix reducing the percentage of Studio/1 bed flats and increase and increasing the number of 3 bed flats. The design comments (set out below) indicate that scheme would benefit from a review of some floorplans to improve the quality of the residential development.

31 Whilst it is accepted that the applicant is requesting flexibility in housing numbers to explore alternative development options, GLA officers require that the potential 725 to 750 residential units have an agreed unit set as a percentage by type/size and that this mix is secured by condition, this because these phases will be approved through reserved matters and the Mayor does not have statutory powers to review reserved matters applications.

Affordable housing

32 London Plan policy 3.11(affordable housing targets) requires borough councils to “seek the maximum amount of affordable housing”. In order to give impetus to a strong and diverse housing sector, 60% of affordable housing provision should be for social rent and affordable rent and 40% for intermediate rent or sale. Priority should be accorded to the provision of affordable family housing.

33 London Plan policy 3.12, as revised, requires that the maximum reasonable amount of affordable housing should be sought when negotiating on individual private residential and mixed use schemes. Negotiations on sites should take account of their individual circumstances including development viability, resources available from registered providers (including public subsidy), the implications of phased development including provisions for re-appraising the viability of schemes prior to implementation (‘contingent obligations’), and other scheme requirements.

34 Brent Council’s affordable housing requirement set by its Core Strategy is for 50% as a starting point for negotiations in all developments. The AAP adopts the London Plan policy 3.12 requirement of securing the maximum reasonable amount rather than an absolute figure. The AAP indicates the quantum of affordable housing is negotiable given the regeneration aims of the Wembley AAP, if supported by a viability assessment.

35 The affordable housing offer requires clarification to understand the offer being made and the type being proposed. As this is an outline application, the Mayor and GLA officers would not be party to subsequent negotiations at reserved matters stage, and there needs to be clarity provided on what the baseline affordable housing provision would be and when it would be provided, noting London Plan requirements that the “maximum reasonable amount” of affordable housing is expected.

D&P/3495/01 South West Lands Stage 2 page 20

36 The applicant has submitted a viability assessment report to support its affordable housing offer. This establishes sets out an indicative scheme which provides for 40 social rented units equating to 60% of the total affordable housing delivery and 25 intermediate units equating to 40% of the total affordable delivery. This is based on a scheme of 804 units and equates to 8.1% affordable housing across the development phases, with all units to be delivered on site. This figure is different form the design & access statement illustrative masterplan.

37 GLA officers have had a further discussion with the applicant’s agent since the stage 1 submission in relation to the affordable offer and have been informed this will be 10% for the entire masterplan area and that the affordable could be delivered as affordable rent not social rent (as set out in documentation) or possible through land being given over to a registered provider in the eastern part of the site. This offer is relatively low given the current state of the housing market and higher provision would be expected. The affordable offer was subject to further negotiation with Brent Council. Clarification is therefore required on this potential approach to affordable housing delivery.

38 The full application for phase 1 Building 3A has no affordable housing within the development proposals. The applicant’s agent has confirmed that this is because the affordable housing will be delivered in later phases of the masterplan. GLA officers require that some assurance is given to the linkage between phase 1 Building 3A and the later phases of masterplan when the affordable housing will be delivered.

39 Given the evolving and uncertain nature of the potential affordable offer and type of affordable units to being provided, GLA officers request an update on affordable housing discussions between Brent Council and the applicant before stage 2 referral. Brent Council are requested to have the applicant’s viability assessment independently review to ensure the maximum affordable housing is being provided on-site. As this is a hybrid application this should include the viability assessment of maximum hybrid application of up to 850 residential units as well as the 804 units so far assessed. The findings Brent Council’s evaluation of the applicant’s viability report should be shared with GLA officers prior to stage 2.

40 As noted under policy 3.12 of the London Plan and in the Housing SPG, there are also circumstances where boroughs should consider whether it is appropriate to put in place provisions for re-appraising the viability of schemes prior to implementation, in order to maximise affordable housing provision. Given the hybrid nature of the scheme, and possibility to phase the development, such an approach might be appropriate for this scheme, particularly given the length of time that could pass from the initial toolkit appraisal to actual build out and also given the current low affordable housing offer. The draft s106 agreement would need to be provided to the GLA as part of the Stage 2 referral.

Density

41 London Plan policy 3.4 requires development to optimise housing output for different locations taking into account local context and character, the design principles in Chapter 7 and public transport capacity. Table 3.2 provides density guidelines in support of this and should be read alongside the opportunity area policies, which expect high density development in such locations.

42 The site is located in a town centre, which is a Central setting, and has a PTAL level of between 3 and 5, density levels ranging from 300 to 650 habitable rooms and 650 to 1,100 are suggested in London Plan Table 3.2. The applicant has completed calculation of density and this estimates the development will result in a residential development of 337 dwellings per hectare or 876 habitable rooms per hectare. The residential density appears reasonable given the existing

D&P/3495/01 South West Lands Stage 2 page 21 PTAL which will improve as Wembley sees further major development coming forward that requires improvements to the public transport network.

Urban design & access

Indicative masterplan

43 As discussed at the pre-application stage, the design of the proposed scheme is considered an improvement on the existing permission, creating a more legible street network with a focus on South Way and better defined and enclosed public realm, which is welcomed.

44 The applicant has submitted a hybrid application consisting of an outline masterplan for the entire development and a detailed application for building three in SW03 that forms the edge to the square together with the podium and parking. The outline masterplan establishes the broad layout and design principles for development over five sites, whilst the detailed design establishes an exemplar development for the later phases of development. The masterplan is based on five character areas which will structure the developments urban form:

 Station Square: North of the railway line defined by plots SW01 and SW02 (outline application) and plot SW03 (full application), whilst to the south defined by SW06 and SW07 and provide gateway buildings from Wembley town centre defining south entrance to Station Square.

 The Terrace: Development terminating views for the north and included in detailed application which is part of SWO3 including the full application for phase 1.

 South West Gardens: A series of hard and soft landscaped spaces facing South Way fronting plots SW03, SW04 and SW05.

 Residential Gardens: Formed within the residential podium blocks and South Way road edge to plots SW03, SW04 and SW05.

 The Wilderness: Natural landscaping edge between the podium plots SW03, SW04 and SW05 and the railway line.

Layout

45 The indicative masterplan layout is viewed as acceptable in that it defines a key gateway along White Horse Way into Wembley and responds positively to the constraints of site topography and the railway line. At the pre-application stage there was difference of opinion on the relationship of the residential development and how it addresses South Way.

46 It is GLA officers opinion that the parkland approach in front of the residential blocks results in a degree of separation that does not do enough to ensure that South Way will feel safe, active and well used by residents and visitors to the development. Brent Council have steered the applicant in this direction and it is accepted the approach has some merits given that Wembley Stadium has servicing areas at ground level. However, although the plans have evolved with landscaping treatment and the introduction of balconies to the ground floor units, there still remains some concern over a lack of front entrances to activate the space between the road and the building line together with how the gardens area will function. This issue could be resolved through adoption of ground floor maisonettes or flats with entrances fronting South Way and the parameters indicating a minimum number of entrances into the residential blocks.

Building height & massing

D&P/3495/01 South West Lands Stage 2 page 22 47 The Wembley AAP identifies the site north of the railway line as suitable for tall buildings. The south west corner site is sensitive to tall buildings, noting its position within the protected viewing corridor to the Wembley Stadium Arch. The extant permission includes a range of plots with buildings up to 15 storeys, whilst the proposed buildings would be up to 23 storeys. Having considered the design rationale and various illustrative viewpoints, the height and massing of the scheme is supported, contributing to the legibility of the new street network and ensuring that public spaces are well enclosed and defined which is welcomed.

Securing design quality

48 Given that the application is in outline and will require reserved matters application, the applicant has provided parameter plans to establish to secure the guiding concepts of the master plan these are:

 Parameter Plan 1: Site boundary.  Parameter Plan 2: Extent of reserved matters.  Parameter Plan 3: Existing ground levels.  Parameter Plan 4: Proposed ground and podium levels.  Parameter Plan 5: Proposed plot extent.  Parameter Plan 6: Proposed extent of parking and servicing areas beneath podium level.  Parameter Plan 7: Proposed access & circulation plan.  Parameter Plan 8: Proposed uses.  Parameter Plan 9: Proposed heights  Parameter Plan 10: Proposed critical dimensions  Parameter Plan 11: Proposed open space

49 GLA officers welcome the inclusion of these parameter plans in securing the overall layout and development form and these should be secured by condition. There is however some concern with aspects of design quality standards in Housing SPG Best Practice standards have not been secured. In particular design coding is required for Plots SW01, SW03 (building 3B & 3C), Plot SW05 (building 5A and 5B) and Plot SW07 that secures that the residential blocks have a maximum number of 8 units sharing each core on each floor, clear floor to ceiling heights of 2.6 metres, minimum unit sizes that accord to GLA space standards and a maximum number of single aspect units (this relates to all buildings containing residential use). Further assurance is also required to secure the palette of materials across the development phases. The design coding should also be secured by condition.

Phase 1 detailed design

50 The full application includes a detailed design for building 3A and podium gardens in plot SW03. This development will set a number of benchmarks for the remaining phases of the masterplan and will define the eastern edge of Station Square.

51 The height scale and mass of the building is appropriate to the location and responds positively to the square will for most servicing, refuse stores and cycle stores to the rear with access from the basement parking. It is officer opinion that the design layout would be improved if the north facing elevation at ground floor was amended to move the refuse store and mobility charging room to the rear and a further commercial unit provide to give an active use facing The Terrace public space – the CGI illustrating The Terrace shows an active frontage, whilst ground floor the plan indicates the previously stated uses.

52 The development has two cores with entrances from Station Square and The Terrace, further access points are from podium level. This approach results in 9 units per core, which is in

D&P/3495/01 South West Lands Stage 2 page 23 excess of Housing SPG Best Practice standards, but will be acceptable if slight amendments are considered. The mezzanine floorplan has a number of single aspect units which is acceptable given what is being achieved by the overall design; however the corner studio units should be reconsidered by the applicant by rearranging the layout to create two 2 bed units of better quality layout space. The floorplan for levels 2-5 could also be improved through increasing the percentage of duel aspect units. These changes can be viewed as also relating to comments made in the housing mix section of this report. Access and inclusive design

53 The applicant has responded positively to the comments made at the pre-application stage in its design & access statement, both the outline masterplan and detailed application set out clear guidelines to meet requirements of London plan policy.

54 Level changes across the site, which create a challenge to ensuring that everyone will have comfortable, convenient and equal access to all of the buildings and open spaces have been assessed. The information presented sets out site levels across the development and building thresholds and the applicant has confirmed its commitment to the design of the landscaping and the public realm as well as into and within the proposed buildings. The adopted approach is strongly supported and given the applicant’s extensive involvement in the area and its access working group, it is expected the scheme will provide a strong exemplar project.

55 The design & access statement demonstrates for both outline master plan and detailed application that all new homes to meet the Lifetime Home standards and at least 10% will be wheelchair accessible or easily adaptable for occupants, for the outline phases this should be secured by condition. The applicant has demonstrated each of the 16 Lifetime Homes criteria have been addressed and layouts are provided illustrating how full wheelchair accessible units of different types achieve guidance requirements. The applicant has set out detailed and parameter plans that show all cores will be located as close as possible to South Way / Wembley Hill Road; with taxi and drop off strategy on South Way. It has been confirmed that there would be step-free access to common areas, with lift access to all public areas and residential flats. Corridors, lobbies and doors are designed to meet relevant accessibility standards.

56 The applicant has ensured that a proportionate of wheelchair accommodation is provided within the private market and family sized units in order to ensure a genuine housing choice in accordance with London Plan policies. This is shown in the accommodation schedule of the detailed application and is commitment for the outline phases, in the latter case this should be secured by condition.

57 The applicant’s landscaping strategy has confirmed that the communal courtyards and access routes are accessible for all, and that access to and from the entrances cores will be full accessible. This extends to the commercial spaces as well as the public realm, which should be provided with level, step-free routes.

58 Blue badge parking will be provided for each wheelchair unit in accordance with London Plan standards, although for the non-residential uses it is anticipated that blue badge holders would need to use the Red Car Park on the opposite side of South Way. Given that blue badge provision is normally provided on site, the applicant should explore with Brent Council where this can be accommodated. The transport assessment has been cross references with the access statement to demonstrate where accessible bus stops and taxi and community transport drop off points are located in relation to the site and residential entrances.

D&P/3495/01 South West Lands Stage 2 page 24 59 For the non-residential uses, the applicant has confirmed that at least 10% of hotel bedrooms and 5% of student rooms are provided as wheelchair accessible and this commitment should be secured by condition. Children & young person’s play

60 Children and young people need free, inclusive and accessible spaces offering high-quality play and informal recreation opportunities in child-friendly neighbourhood environments. Policy 3.6 of the London Plan seeks to ensure that all children and young people have access to such provision. The challenge facing boroughs and their partners in play provision will be to find opportunities to retain and increase the provision of play and informal recreation, particularly in housing developments.

61 The applicant has completed detailed work on the child yield based on two scenarios of potential housing mix using the Mayor’s Shaping Neighbourhoods: Play and Recreation SPG (2012). A playspace strategy has also been established for the outline masterplan and detailed application. As the majority of outline masterplan will be developed through reserved matters applications it is required that the applicant agree to a condition that secures a quantum of floorspace based on a maximum and minimum figure basis.

Table 3: Play provision

Age Group Scenario 1 (sq.m.) Scenario 2 (sq.m) Under 5 480 600 5 to 11 230 350 Total 710 950 12 + 150 220 Total 860 1170

62 The applicant play space strategy identifies where door step playable space (0-5 years) will be met on site and where local playable space (0-11 years) and that 12+ age group can be met by existing off-site facilities in the area. Both Edward VII Park and Sherrans Farm Open Space are with 800m of the site and provide MUGA’s, Tennis Courts and Play areas. Other youth space facilities are proposed on Quintain’s Stage 1 and NW Lands masterplans to the north of South Way and will be available in future phases. This is approach appears reasonable but Brent Council should consider if funds should be provided for the enhancement of existing facilities. Sustainable energy

63 The applicant has broadly followed the energy hierarchy and sufficient information has been provided to understand the proposals as a whole. The proposals are broadly acceptable; however, further information is required before the carbon savings can be verified.

64 A range of passive design features and demand reduction measures are proposed to reduce the carbon emissions of the proposed development. Both air permeability and heat loss parameters will be improved beyond the minimum backstop values required by building regulations. Other features include low energy lighting and reduced thermal bridging. Further information should be provided on the strategy proposed to reduce the thermal bridges across the dwellings.

65 The demand for cooling will be minimised through shading from overhanging balconies, solar control glazing, blinds and openable windows. The applicant has stated that the dwellings have been tested against the high summer temperature criterion in SAP2012 and all pass with a low or slight risk of overheating. Sample Part L Compliance Checklists should be provided to

D&P/3495/01 South West Lands Stage 2 page 25 support the statements made. The development is estimated to achieve a reduction of 26 tonnes per annum (2%) in regulated carbon dioxide emissions compared to a 2013 Building Regulations compliant development. Sample DER and TER sheets for efficiency measures alone should be provided to support the savings claimed.

66 The applicant has carried out an investigation and there are no existing or planned district heating networks within the vicinity of the proposed development. The applicant states that the closest centralised plant is provided within stage 1 of the Wembley masterplan development but that there is no excess capacity to serve the application site. Evidence of correspondence with the operators of the energy centre should be provided to support the statements made. The applicant has provided a commitment to ensuring that the development is designed to allow future connection to a district heating network should one become available.

67 The site is divided in two by the Chiltern Railway Line. The applicant is proposing to install a site heat network for the buildings in the northern part of the site. Following discussions with Network Rail and a review of potential routes for the heat network mains, the applicant has ruled out district heating network in the southern part of the site (34 flats and retail) due to installation and access challenges. This is accepted in this instance.

68 The applicant has confirmed that all apartments and non-domestic building uses in all phases in the northern part of the development will be connected to the site heat network. A drawing showing the route of the heat network linking all buildings on the site has been provided. The site heat network will be supplied from a single 250 sq.m energy centre located over two floors, in the basement and ground floor, of block SW03A. An indicative layout of the plant room has been provided and this allows space for installing up to two CHP engines, thermal stores and gas fired backup boilers.

69 The two sites to the south of the railway will be served by a separate energy centre. A plan showing the proposed energy centre should be provided and the applicant should also confirm what type of plant will be used to serve these buildings. The applicant is proposing to install 1 or 2 gas fired CHP units as the lead heat source for the site heat network in the Phase 1 of the development. The CHP is sized to meet 65% of heat demand for space heating and hot water. The installed capacity of the system will be dependent on the final accommodation mix for the development. Monthly profiles have been provided for the different CHP options. A reduction in regulated CO2 emissions of 426 tonnes per annum 35% is claimed to be achieved through this second part of the energy hierarchy.

70 The applicant has investigated the feasibility of a range of renewable energy technologies but is not proposing to install any renewable energy technology for the development.

71 A reduction of 452 tonnes of carbon dioxide per year in regulated emissions compared to a 2013 Building Regulations compliant development is expected, equivalent to an overall saving of 36%. Based on the submitted energy assessment the carbon dioxide savings exceed the target set within Policy 5.2 of the London Plan however the comments above should be addressed before compliance with London Plan energy policy can be verified. Noise

72 Policy 7.15 (Reducing noise and enhancing soundscapes) of the London Plan states that development proposals should seek to reduce noise by minimising the existing and potential adverse impacts of noise on, from, within, or in the vicinity of, development proposals as well as separating new noise sensitive development from major noise sources wherever practicable through the use of distance, screening or internal layout in preference to sole reliance on sound insulation. The Mayor will also support new technologies and improved practices to reduce noise at source,

D&P/3495/01 South West Lands Stage 2 page 26 especially in road, rail and air transport. In addition standard 5.2.1 of the Mayor’s Housing SPG states that developments should avoid single aspect dwellings that are north facing, exposed to NEC C or D or contain three or more bedrooms.

73 The applicant has completed a noise impact assessment that assess the impact of the Chiltern Railways services Marylebone railway line on the development that sets out potential mitigating measures through a higher performance construction such as double leaf walls in the blocks closest to the railway line.

Flood risk/surface water run-off

74 The site is within Flood zone 1 and as such is acceptable in principle. The proposals include the provision of several techniques to limit the discharge of rainwater to greenfield run-off rates up to the 1 in 100 year + climate change storm event. This is supported as there are local surrounding areas which are at risk of surface water flooding. The proposals include the provision of green and blue roofs, permeable paving, and sub-surface storage tanks. The approach is compliant with London Plan Policy 5.13 and should be secured via an appropriate condition attached to any planning permission.

Transport

75 The application will amend the step free route onto the southbound platform of Wembley Stadium station, which results in a shallower gradient for users and this is welcomed. It is also noted that a formal 1.8 metre footway will be provided on the route below White Horse Bridge. Although primarily an issue for the borough to agree, TfL questions whether a shared space would provide a better environment for pedestrians given that vehicle access will only be required on event days and vehicle speeds will be low. Management of this access outside of event days may need to be controlled by condition.

76 Car parking is to be provided at a maximum ratio of 0.4 spaces per unit. This is in line with the requirements of the emerging WAAP, and is therefore welcomed. The applicant has committed to providing electric vehicle charging points in line with London Plan standards and preventing occupiers from applying for permits in the surrounding Controlled Parking Zone (CPZ) - this is welcomed and should be secured by condition or through the Section 106 agreement for the site, along with a Parking Management Plan. However, because a large amount of this parking is being provided in phase 1, suitable conditions will need to be placed on any consent restricting the amount of car parking that can be used by phase. It may also be sensible to monitor the uptake of car parking through the parking management plan to inform car parking provision in future phases.

77 It is accepted that a car club operator has been contacted and does not feel there is sufficient demand to justify provision of additional car club spaces on site. However, residents will be provided with car club membership as part of the residential Travel Plan, which is welcomed.

78 The applicant has committed to providing cycle parking in accordance with the standards set out in the Further Alterations to the London Plan (FALP) and in accordance with best practice set out in TfL’s recently revised London Cycle Design Standards (LCDS). As most of the proposals are in outline, details of cycle parking should be secured by condition along with details of showers and lockers for the commercial uses on site. Cycle parking for the first phase is accessed via the basement ramp into the car park from South Way. Some service vehicles will have to reverse into the loading bay from this ramp, which may create conflicts between cyclists and vehicles and it is noted that access on event days may be problematic. As such, TfL welcomes confirmation from the applicant that the alternative access underneath White Horse Bridge would be available for use by cyclists at all times.

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79 Trip generation was discussed at the pre-application stage and is considered acceptable. It is accepted that the anticipated vehicle trip generation of the scheme is lower than that assumed for the previous 2004 consent. Brent Council have nonetheless promoted highway improvements on Wembley Hill Road and the Triangle junction on the basis that the 2004 permission would be built out. These areas are where the development would have most impact.

80 The WAAP identifies that this site must safeguard land for the Wembley Hill Road improvements through the section 106 agreement. Brent Council should also clarify whether they expect the developer to undertake the improvements or whether they are seeking developer contributions. Clarification on timescales and triggers for these works should also be provided given the impacts on the 224 bus route and the need to mitigate any highways impact arising from this application.

81 The applicant has considered public transport impact to a good level of detail. On this basis, it is accepted that the impact on rail and underground services is acceptable. Furthermore the scheme provides additional accommodation for Wembley Stadium station which TfL supports.

82 The 2004 consent safeguarded land for bus stops on South Way, which is not proposed as part of this application. This is based on an agreed bus strategy for the area that would see a connection built between Wembley Park Boulevard and South Way, with changes to the geometry of the Boulevard to allow it to be used by double deck buses. This connection would need to be delivered with the applicant, as it would utilise land within their wider estate. TfL considers that this would provide the best solution for bus access into the area, but it is now understood that the applicant’s current preference is to retain the Boulevard as a pedestrian only route. Therefore if this cannot be achieved, buses would have to use South Way to access the eastern area of Wembley, although this would provide poorer bus access to key destinations located along the Boulevard such as the London Designer Outlet and the Brent Civic Centre. As such, land should now be safeguarded within this site to allow for bus stops on either side of the road at a point between Wembley Hill Road and Wembley Park Boulevard, close to trip attractors such as this development and Wembley Stadium station. The changes to the highway necessary to provide for these stops such as changes to kerb heights, bus shelters and bus flags should also be secured via an appropriate mechanism.

83 Bus capacity impacts are also a concern in the context of a significant increase in bus demand in the WAAP area, which is forecast to further increase with new development. As such, TfL are seeking a £270,000 contribution from this site towards bus capacity enhancements.

84 The proposals identify an area where coach, taxi and private hire pick up and drop off could take place, though they do not include a formal taxi rank or coach parking area, for which it is stated there are already adequate facilities nearby. TfL considers nonetheless that should a hotel come forward as part of the proposals, then a formal taxi rank will be necessary and would expect to work with the applicant and Brent Council to find a mutually acceptable solution for this, which would need to be secured by condition.

85 A Pedestrian Environment Review System (PERS) audit of the existing pedestrian network has been carried out, looking at routes to key public transport facilities and local schools. Although this is welcomed, some audit information is missing from the submission and this should be provided.

86 The WAAP highlights the need for any development on this site to make adequate provision for event day pedestrian flows, given the proximity to Wembley Stadium. The application safeguards an area for an ‘Arrival Square’, providing queuing space in front of White Horse Bridge

D&P/3495/01 South West Lands Stage 2 page 28 and Wembley Stadium station. Although this space appears to have been designed to the same dimensions as the existing queuing area, there is no specific analysis of event day pedestrian flows. The size and design of this area should therefore be determined at the reserved matters stage to maximise queuing capacity for spectators as necessary.

87 A Travel Plan for the development has been provided and is comprehensive. This, and the measures it covers, should be secured through the section 106 agreement for the site. A framework Delivery and Servicing Plan has been submitted with the application and should be secured by condition on any consent. The content of the plan is generally good, with consideration given to targets and monitoring. Similarly, a framework Construction Logistics Plan has been submitted and should be secured. Again, this goes into a good level of detail on likely impacts. The final CLPs for each development phase will however need to consider how construction will be managed on event days.

88 In summary, further consideration needs to be given to the proposed route below White Horse Bridge, taxi facilities and bus infrastructure around the site. Mitigation should also be secured to cover bus impacts and the council must consider how highway mitigation is secured and delivered. These issues must be resolved prior to the application being referred back to the Mayor at Stage 2.

Mayoral CIL

89 In accordance with London Plan policy 8.3, the Mayoral Community Infrastructure Levy (CIL) came into effect on 1st April 2012. All new developments that create 100 sq.m. or more of additional floor space are liable to pay the Mayoral CIL. The levy is charged at £35 per square metre of additional floor space in the London Borough of Brent.

90 The applicant can estimate the future CIL charge by referring to the Greater London Authority website http://www.london.gov.uk/publication/mayoral-community-infrastructure-levy.

91 Brent Council adopted its Community Infrastructure Levy (CIL) charging schedule in July 2013. Residential uses (including student accommodation) are charged at £200 per square metre, hotels at £100 per square metre and retail uses at £40 per square metre. The council’s Regulation 123 list identifies that this can be spent on ‘roads and other transport facilities’ and TfL welcomes further discussion with the council as to how CIL may be used in the Wembley area.

Local planning authority’s position

92 At the pre-application stage Brent Council were supportive of the principle of development. Legal considerations

93 Under the arrangements set out in Article 4 of the Town and Country Planning (Mayor of London) Order 2008 the Mayor is required to provide the local planning authority with a statement setting out whether he considers that the application complies with the London Plan, and his reasons for taking that view. Unless notified otherwise by the Mayor, the Council must consult the Mayor again under Article 5 of the Order if it subsequently resolves to make a draft decision on the application, in order that the Mayor may decide whether to allow the draft decision to proceed unchanged, or direct the Council under Article 6 of the Order to refuse the application, or issue a direction under Article 7 of the Order that he is to act as the local planning authority for the purpose of determining the application and any connected application. There is no obligation at this present stage for the Mayor to indicate his intentions regarding a possible direction, and no such decision should be inferred from the Mayor’s statement and comments.

D&P/3495/01 South West Lands Stage 2 page 29 Financial considerations

94 There are no financial considerations at this stage. Conclusion

95 London Plan policies on housing, urban design, inclusive design, climate change, and transport are relevant to this application. Whilst the principle of mixed use development is supported, a number of strategic concerns are raised, and consequently the application does not accord with London Plan Policy. The following could address these deficiencies:

 Principle of development: The principle of a residential led mixed use development on the applicant’s site is strongly supported as it reflects London Plan OAPF policy guidance, the Wembley AAP strategic aims and site specific policies and, with less material weight, the unimplemented 2004 planning permission.  Housing mix: The housing mix for masterplan has only 10% three bedroom units, this offer is very low and should be reviewed by the applicant to provide a greater proportion of larger units. As the final quantum of residential units is subject to development phasing options, the applicant should agree a fixed percentage by unit type/size and this should be secured by condition.

 Affordable housing: The applicant should provide clarification on the affordable housing offer and its delivery before stage 2 referral. The cuurent 10% offer appears to be low. There needs to be assurance that the phase 1 Building 3A delivery with no affordable housing is linked to remaining phases of the scheme. Once a finalised offer is made, the viability assessment should be independently reviewed on behalf of Brent Council at its findings shared with GLA officers.

 Urban design – outline Masterplan : The overall approach to the masterplan is supported but GLA officers believe the approach to defining South Way and its relationship with the residential development requires further consideration. Further assurance is required in the securing of design quality for the phased development through reserved matters, it is requested additional design coding is provided which with the parameter plans are secured by condition.

 Urban design – detailed phase 1, building 3A: The adopted approach to the design is supported, but the applicant is required to explore improvement options to improve the overall design quality. These relate to key a prominent inactive ground floor frontage in the north of the building facing The Terrace public space and the reconsideration of the floor plans to create better quality layout and possible increase in duel aspect units.

 Access: The applicant has responded positively to the comments made at the pre- application stage in its design & access statement, both the outline masterplan and detailed application set out clear guidelines to meet requirements of London plan policy. Conditions are required to secure the 10% wheelchair accessible units, Lifetime Homes compliance, 10% wheelchair accessible hotel rooms and 5% (and 5% adaptable) wheelchair accessible student rooms.

 Children & young person’s play: As the majority of outline masterplan will be developed through reserved matters applications it is required that the applicant agree to a condition that secures a quantum of floorspace based on a maximum and minimum figure basis.

D&P/3495/01 South West Lands Stage 2 page 30 Furthermore Brent Council should consider if funds should be provided for the enhancement of existing facilities for off-site play provision.

 Sustainable energy: Based on the submitted energy assessment the carbon dioxide savings exceed the target set within Policy 5.2 of the London Plan however the comments set out in this report should be addressed in full before compliance with London Plan energy policy can be verified. This should be completed before stage 2 referral.

 Flood risk/surface water run-off: The adopted approach is compliant with London Plan Policy 5.13 and the mitigation measures should be secured via an appropriate condition attached to any planning permission.

 Transport: Further consideration needs to be given to the proposed route below White Horse Bridge, taxi facilities and bus infrastructure around the site. Mitigation should also be secured to cover bus impacts and the council must consider how highway mitigation is secured and delivered. These issues must be resolved prior to the application being referred back to the Mayor at Stage 2

for further information, contact GLA Planning Unit : Stewart Murray, Assistant Director -Planning 020 7983 4271 email stewart.murray@london .government.uk Colin Wilson, Senior Manager –Development & Projects: 020 7983 4783 email [email protected] Jonathan Aubrey, Case Officer 020 7983 5823 email jonathan.aubrey @london.gov.uk

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