planning report PDU/3078/01 20 February 2013 209 -213 Hanworth Road,

in the Borough of Hounslow planning application no. P/2012/3669/FUL

Strategic planning application stage 1 referral (new powers) Town & Country Planning Act 1990 (as amended); Authority Acts 1999 and 2007; Town & Country Planning () Order 2008

The proposal The development of a part 4 part 5 storey building providing car parking at basement and ground floor level, supermarket at first floor level and 57 residential units at third, fourth and part fifth level, with associated access, public realm and landscaping works. The applicant The applicant is Sainsbury’s Supermarkets Ltd, and the agent is Turley Associates.

Strategic issues The principle of the proposed out of centre retail development requires substantial justification and additional supporting evidence.

Other issues that need to be addressed before the application is referred back to the Mayor at stage two relate to urban design, access, children’s and young persons play, climate change mitigation, air quality. noise mitigation and transport.

Recommendation That Hounslow Council be advised that while the application is generally acceptable in strategic planning terms the application does not comply with the , but that the possible remedies set out in paragraph 111 of this report could address these deficiencies.

Context

1 On 10 January 2013 the Mayor of London received documents from Hounslow Council notifying him of a planning application of potential strategic importance to develop the above site for the above uses. Under the provisions of The Town & Country Planning (Mayor of London) Order 2008 the Mayor has until 20 February 2013 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 Category 3E and 3F of the Schedule to the Order 2008:

S:\Planning Decisions\Cases\3047\Stage page 1  3E (a) which does not accord with one or more provisions of the development plan in force in the area in which the application site is situated.

 3E (b) comprises or includes the provision of more than 2,500 sq.m. of floorspace for use falling within any of the following in the use class order – (i) class A1 retail.

 3F Development for a use other than residential use, which includes the provision of more than 200 car parking spaces in connection with the use.

3 Once Hounslow Council has resolved to determine the application, it is required to refer it back to the Mayor for his decision, as to whether to direct refusal or allow the Council to determine it itself, unless otherwise advised. In this instance if the Council resolves to refuse permission it need not refer the application back to the Mayor.

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

5 The site is located on A314 Hanworth Road, which is south west of Hounslow Town Centre. The site is currently levelled and vacant. At the north and north-west boundary of the site are new build flats. To the west is a Sikh Temple which has a boundary with the site. The eastern boundary of the site is light industrial units along Clarence Road and Thompson Road.

6 All of the above roads are part of the borough highway network. The nearest part of the Transport for London Road Network (TLRN) is the A4 Great West Road, which is located approximately 1.5 kilometres to the north. The section of Hanworth Road, 200 metres north east of this site is part of the Strategic Road Network (SRN). Hounslow rail station is located around 300 metres to the south east via Station Road. The nearest underground station is Hounslow Central, which is located 850 metres to the north. Hanworth Road itself is served by 3 bus routes; H28, 110 and 111 and a further 4 routes are available from Grove Road, 300 metres to the north; 81, 116, 117 and 203. As such the Public Transport Accessibility Level (PTAL) of the site has been calculated as a 5, within a range of 1 to 6 where 1 is very poor and 6 is classed as excellent.

Details of the proposal

7 The development of a part 4 part 5 storey building providing car parking at basement and ground floor level. The upper built form will contain a supermarket (7,309 sq.m.) at first floor level and 57 residential units at third, fourth and part fifth level, with associated access, public realm and landscaping works.

Case history

8 The applicant attended a GLA pre-application meeting on 20 December 2012. Strategic planning issues and relevant policies and guidance

9 The relevant issues and corresponding policies are as follows:

 Housing London Plan; Housing SPG; Housing Strategy; Revised Housing Strategy; Providing for Children and Young People’s Play and Informal Recreation SPG

S:\Planning Decisions\Cases\3047\Stage page 2  Affordable housing London Plan; Housing SPG; draft Affordable Housing SPG; Housing Strategy; draft Revised Housing Strategy  Density London Plan; Housing SPG  Urban design London Plan;  Mix of uses London Plan  Regeneration London Plan; the Mayor’s Economic Development Strategy  Transport London Plan; the Mayor’s Transport Strategy; Land for Industry and Transport SPG  Parking London Plan; the Mayor’s Transport Strategy  Retail/town centre uses London Plan  Access London Plan; Accessible London: achieving an inclusive environment SPG; Planning and Access for Disabled People: a good practice guide (ODPM)  Equal opportunities London Plan; Planning for Equality and Diversity in London SPG; Equal Life Chances for All (Mayor’s Equalities Framework); Equalities Act 2010  Ambient noise London Plan; the Mayor’s Ambient Noise Strategy;  Air quality London Plan; the Mayor’s Air Quality Strategy;  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

10 For the purposes of Section 38(6) of the Planning and Compulsory Purchase Act 2004, the development plan in force for the area is the Hounslow Unitary Development Plan Adopted 12 December 2003 (Saved Policies September 2007), Area Action Plan (Adopted 27 January 2009), Hounslow Employment Development Plan Document (Adopted 25 November 2008) and the 2011 London Plan.

11 The following are also relevant material considerations:  The National Planning Policy Framework and Technical Guide to the National Planning Policy Framework.  The draft revised Early Minor Alteration to the London Plan

 Draft Town Centres SPG (February 2013)

Principle of development

12 London Plan policy 2.15 (Town Centres), policy 4.7 (retail & town centres) and policy 4.8 (supporting a successful & diverse retail sector), provide the strategic policy context in which the applicant’s proposals are considered. The London Plan states in relation to policy 2.15 paragraph 2.76:

The Mayor requires a proactive partnership approach to identifying and bringing forward capacity for different types of town centres related uses within or on the edges of town centres whilst restraining inappropriate out of centre development (see policy 2.15)

13 At the pre-application stage the applicant was requested to provide further retail impact analysis in relation to the proposed extension of its existing supermarket. The main issues raised were:

 The sequential test.

S:\Planning Decisions\Cases\3047\Stage page 3  Justification on the scale of development.

 Impact on proposed investment in existing centres.

 Impact on the vitality and viability of centres in the London Plan hierarchy.

 Evidence of discussion with the Hounslow Council and surrounding boroughs in the preparation of retail impact assessment.

Development background

14 The retail proposals for development are for a Sainsbury’s supermarket with 7,309 sq.m. (gross)/ 3,912 sq.m net sales area.

15 The site is outside of the designated town centre in both the UDP and in the masterplan being prepared for Hounslow town centre (which is currently being revised by Hounslow Council). The site is part of a larger site in the UDP (site reference M17) for mixed residential (70%) and light industrial use (30%). The residential element comprising 135 dwellings has been completed. This designation is being reviewed as Hounslow Council develops its Local Plan.

16 The retail development is therefore out of centre located outside Hounslow Metropolitan town centre, as identified within the London Plan, on a site not designated for retail use. The centre is identified in Table A2.1of the London Plan as having medium growth potential – which is identified as town centres with moderate levels of demand for retail, leisure or office floorspace and with physical and public transport capacity to accommodate it and is in need of regeneration.

Sequential test

17 London Plan policy in line with the NPPF places a requirement that retail development should be subject to a sequential test with policy 4.7 stating:

“(b) retail, commercial, culture and leisure development should be focused on sites within town centres, or if no in-centre sites are available, on sites on the edges of centres that are, or can be, well integrated with the existing centre and public transport.”

18 The applicant has stated in its planning and retail statement (paragraph 5.4) and the local UDP policy identify that the proposed supermarket is out of centre. It has completed a sequential site assessment as required by London Plan policy as evidence to support the proposals this assessment identified and assessed three sites identified in the UDP.

19 Following discussion with Hounslow Council it is considered that the sequential test is inadequate. Whilst the applicant acknowledges that its site is located outside of the town centre and has good access to public transport, the examination of alternative sites is limited. The sequential test in the Planning and Retail Statement primarily focuses on sites designated in the Hounslow UDP. There is an additional need to make reference to the Hounslow Town Centre Masterplan prepared (and being reviewed) by the Hounslow Council and specifically to the identified key opportunity sites. This is a deficiency in the sequential test should respond to the masterplan.

Assessment of impact

20 The London Plan, in coordination with the NPPF, requires an assessment of impact and states under policy 4.17 “(c) proposals for new, or extensions to existing, edge or out of centre development will be subject to an assessment of impact.”

S:\Planning Decisions\Cases\3047\Stage page 4 21 The assessment of impact is required to have particular focus on the impact of new proposed floorspace on the vitality and viability of retail centres in the London Plan town centre classification and smaller neighbourhood centres. A further requirement is an assessment of the impact on proposed investment within the town centre classification.

22 Whilst the applicant’s catchment area is considered extensive, following discussions with Hounslow the catchment area should include all of the following wards in Hounslow: East; Heston Central; Heston West; ; Hounslow Central; Hounslow South; ; Syon; and and Spring Grove. This would allow the assessment to be consistent with the catchment area used for the purposes of Hounslow town centre master planning.

Assessment of need

23 Hounslow Council has commissioned an update to the Joint Retail Needs Assessment’s floorspace projections for the borough; the draft report states that the need for additional convenience floorspace is limited and for Hounslow town centre supply is sufficient. The update does establish a requirement for comparison floorspace both borough-wide and in Hounslow town centre, however this has decreased since 2010 and the majority of floorspace need is delayed until later in the plan period.

24 The applicant is required to respond to the findings of the Hounslow Joint Retail Needs Assessment report in context of its assessment of retail need and impact across the identified town centre network.

Impact on vitality and viability

25 The applicant has completed an assessment of the impact on vitality and viability of exiting centres and the impact on competitor supermarkets within and outside the identified centres. This analysis is welcome.

26 In assessing the baseline position on which assessment of impact has been made the applicant has presented evidence of centre impacts in context of expected expenditure growth. Whilst this analysis is broadly acceptable the applicant is requested to place this assessment of impact in context of broader centre health check that sets out trends within the centres of floorspace vacancy rates, footfall and rents – this is to allow for a clear understanding of strength of the centre over time, for example is the trend showing a centre under stress due increases in vacant floorspace etc and therefore would be under greater stress if new development comes forward.

27 There is concern that the scheme would impact on the vitality and viability of Hounslow town centre and its proposed regeneration through the centre masterplan. The applicant is requested to further justify its assessment of vitality within this context.

Impact on investment

28 A key element of the NPPF and the London Plan policy is the assessment of impact on proposed investment in existing centres.

29 The regeneration of Hounslow town centre is a recognised as a priority by Hounslow Council. This is supported and being directed by Hounslow town centre masterplan (February 2012) which has been prepared to facilitate change and maintain the vitality and viability of the centre. It is understood this is being further updated as an ongoing priority of Hounslow Council. It is considered that the proximity of the proposed supermarket is likely to impact on the town centre regeneration aims and objects in relation to brining forward investment within the

S:\Planning Decisions\Cases\3047\Stage page 5 Metropolitan centre. The applicant will need to thoroughly justify its proposals in this context of the potential impact on regeneration masterplan delivery of sites and retail floorspace. Housing

Housing mix

30 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 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. Recent guidance is also set out in the London Plan Interim Housing SPG (April 2010). Also relevant is policy 1.1, part C, of the London Housing Strategy, which sets a target for 42% of social rented homes to have three or more bedrooms. As the applicant is intending bring forward the housing as an outline application the mix will be required to be agreed and included in any future s106 agreement.

Table: Hanworth Road housing mix

Size No. units % one bed 10 18 two bed 41 72 three bed 6 11 57 100

31 The residential element of the development will contain 57 flats over three floors and the development mix will be primarily one and two bed units (table 1). It is evident that on 11% of unit are proposed as larger three bedroom units. The applicant should enhance the mix to accommodate a higher percentage of family units.

Affordable housing

32 London Plan policy 3.12 requires borough councils to seek the maximum reasonable amount of affordable housing when negotiating on individual private residential and mixed-use schemes. In doing so each council should have regard to its own overall target for the amount of affordable housing provision. This target should take account of the requirements of London Plan Policy 3.11, which include the strategic target that 60% of new affordable housing should be for social rent and 40% for intermediate rent or sale. The Mayor has published an early minor alteration to the London Plan to address the introduction of affordable rent, with further guidance set out in a draft Affordable housing SPG. With regard to tenure split the Mayor’s position is that both social rent and affordable rent should be included within the 60%.

33 While the Mayor has set a strategic investment benchmark that across the affordable rent programme as a whole rents should average 65% of market rents, this is an average investment output benchmark for this spending round and not a planning policy target to be applied to negotiations on individual schemes.

34 Policy 3.12 is supported by paragraph 3.71, which urges borough councils to take account of economic viability when estimating the appropriate amount of affordable provision. The ‘Three Dragons’ development control toolkit or other recognised appraisal methodology is recommended for this purpose. The results of a toolkit appraisal might need to be independently verified. Paragraph 3.75 highlights the potential need for re-appraising the viability of schemes prior to implementation.

S:\Planning Decisions\Cases\3047\Stage page 6 35 The applicant affordable housing statement states that the level of affordable housing is to be six units equating to 10.5% on a unit basis, this level of provision is supported by a financial viability assessment. None of the units will be for rent and only shared ownership units will be offered due to the limitations of the design not allowing for a duel core – which would allow a separate core access for a registered provider.

36 The Hounslow Council local requirement is for 50% of any future housing development to be affordable housing. Given the clear disparity between the applicant offer and the Council requirement the applicant viability assessment should be independently reviewed by the Council.

37 The GLA will normally expect the affordable element to reflect the strategic target of 60% social and affordable rented and 40% for intermediate rent or sale, although the issue of a single core may have some merit. The applicant should enter early discussions with registered providers to ensure that the affordable products reflect the priorities of the Mayor, particularly with regard to affordable rented housing.

Housing density

38 London Plan policy 3.4 seeks to optimise the potential of sites having regard to local context, design principles and public transport accessibility. The applicant should provide an estimate of development density and this should relate to table 3.2 of the London Plan. Urban design

39 In circumstances where an out of centre retail development is viewed as being acceptable, a key criterion in is the quality of the building design and contribution to local placemaking. This is given weight along side the retail impact assessment, sequential test and impact on investment in the defined town centre network

Layout and urban form

40 To accommodate the preferred large store format and parking/ service areas the development has had to utilise the entire site area. The proposed layout raises the retail store sales and support services on stilts above a ground floor basement level car park.

41 A residential development is proposed on top of the store and this mix of use is welcome. There are however concerns over the integration of the residential element and the residential quality ad amenity space.

42 An atrium provides an entrance into the store and escalators to the supermarket retail sales floorspace on the first floor this provides a frontage to Hanworth Road, but as raised at the pre- application meeting it is not affectively an active frontage. There is concern that the angular frontage creates additional impacts to the street and the building line should continue that established for the Hanworth Road.

43 The angular form of the building disposition has created a paving area outside the store but together with access for both parking and servicing at the basement levels has resulted in a disconnection in the public realm on Hanworth Road. In adopting this approach the round about would become a dominant element to the street, a less intrusive solution should be adopted preferably through a traffic light controlled junction. This would allow to street building line to be continued and still allow for an area of public realm in front of the building.

S:\Planning Decisions\Cases\3047\Stage page 7 Scale and massing

44 The massing and scale of the building appears substantially greater than the surrounding buildings and because of the need to accommodate the large scale supermarket format adopted and the related serving and car parking required. This has resulted in a limited opportunity to set the building back from the Sikh temple or the residential buildings and with the addition of the residential unit blocks in the adopted arrangement results a degree of canyoning of Clarence Terrace and the massing overall dominating the surrounding area.

Activation and public realm

45 The new supermarket provides a new frontage to Hanworth Road with the creation of the atrium entrance, which fronts the ground floor entrance. The orientation of the building entrance is welcome, there are however concerns over the impact on the public realm being generated. There is particular concern with the new entrance junction created to enable access to service and car park, this has resulted a substantial severance of the public realm and the ability of pedestrians walking along and crossing Hanworth Road.

46 The relationship between the development edge and the car and service access ramp and the Gurdwara Temple grounds requires further attention though increased landscaping and softening of the harsh edge generated. A more comprehensive approach could be the extending of the car park concrete floor base over part of the ramped access and its landscaping should be explored.

47 The relationship between the development edge service area and the existing residential development to the north of the site requires further consideration, although some articulation is offered to the wall, the option of a vertical green landscaped living wall should explored to soften the impact. Overall more attention should be given to landscaping of this edge.

Residential quality

48 The proposals include residential apartments above the supermarket and, in terms of seeking to maximise the use of the site, this is welcome. There is however concern over the quality of the residential accommodation proposed and in particular the lack of consideration of amenity space for residents.

49 The apartment accommodation sits on a podium created by the supermarket there is however no consideration of how the podium could provide for both amenity space for residents and allow for the creation of units which have entrances at podium level.

50 The use of long corridors fails to meet the requirements of London Plan housing design guide where a maximum of 8 units per floor is encouraged, the applicant should adopted this approach. Furthermore, the non-inclusion of duel core access has been stated as reason for limiting the level of affordable housing within the proposals.

51 The only area of children’s play space is indicated to be on the top floor of the building at roof level at the furthest point away from a number of the apartments. This solution appears to be an afterthought in the design and should be more integrated into the design solution where residents are able to supervise play and recreation.

52 The applicant has indicated that all apartments are compliant with GLA space standards there is however concern over the number of single aspect units and these should be minimised or converted in duel aspect.

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Play space provision

53 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.

54 The applicant has not made reference to The Shaping Neighbourhoods: Play and Informal Recreation SPG (2012), which relates to the implementation of London Plan policy 3.6 and provides detailed guidance through benchmark standards. The design and access statement should provide a calculation of child yield using the GLA calculator and provide a clear strategy on children and young persons play. The location of existing playspace does not allow for monitoring of use and is a substantial distance from those living in the north of the residential development. Access

Residential comments

55 The applicant confirmed that all residential units will be designed to the Lifetime Homes standard and of these 10% will be wheelchair accessible units. This is welcomed and should be clearly stated in the design and access statement.

56 In line with London Plan Policy 3.8 Housing Choice the applicant should demonstrate that the design of the residential units meet the 16 Lifetime Home standards (see the Quality and Design Standards in the Mayor’s Supplementary Planning Guidance ‘Housing’), and that the 10% of new housing is wheelchair accessible and meet the standards set out in Annex 2 Best Practice Guidance for Wheelchair Accessible Housing, of the GLA's Supplementary Planning Guidance ‘Housing’ (see http://www.london.gov.uk/sites/default/files/Housing-SPG-highres.pdf.) Typical flat layouts and plans of the wheelchair accessible homes and the Lifetime Homes units should be included in the design and access statement to illustrate the relevant features. It should be clear on the plans where the wheelchair accessible flats are located and how many there are. These should be distributed across tenure types and flat sizes to give disabled and older people similar choices to non disabled people (unless the council through their Accessible Housing Register work can advise on the need in this part of the borough for a particular size of wheelchair accessible unit). The checklist in the GLA’s best practice guide provides a useful reference for ensuring that the key features of wheelchair accessible homes have been addressed. Generous use of space and careful layout can help to ensure that more than the minimum number of homes are easily adaptable helping to provide greater choice for people who use a wheelchair or who benefit from a wheelchair accessible flat (such as older people who also have mobility equipment storage needs and benefit from level access showers).

57 Extending the Lifetime Home concept to the neighbourhood level can help to ensure that the public realm, the parking areas, the routes to the site and links to adjacent public transport and local services and facilities are also designed to be accessible, safe and convenient for everyone, particularly disabled and older people. This concept can also help to meet the specific needs of older people (see the CLG report ‘Lifetime Homes Lifetime Neighbourhoods a National Strategy for Housing in an Ageing Society’ and the emerging advice from the Lifetime Neighbourhoods Foundation (see http://www.lifetimehomes.org.uk/pages/lifetime-neighbourhoods.html). The

S:\Planning Decisions\Cases\3047\Stage page 9 design code should address these criteria and have regard to other best practice standards in achieving inclusive access.

58 The design of the landscaping and the public realm is crucial to how inclusive the development is for many people. The proposals should ensure that the routes from the public transport facilities to the new entrance points are legible and clearly identifiable, and that way finding is easy to make access easy, safe and comfortable. The design and access statement should show how disabled people access each of the entrances safely, including details of levels, gradients, widths and surface materials of the paths and how they are segregated from traffic and turning vehicles etc, and how any level changes on the routes will be addressed.

59 Residential parking- the provision and future management of the blue badge parking bays for the residents should be in line with the advice in the Lifetime Homes standards and the Wheelchair Housing Design Guide, and these bays should be located as close as possible to the relevant entrances/ cores.

60 If the wheelchair accessible units are to be ‘easily adaptable’ rather than ‘kitted out’ as wheelchair accessible from the outset, it may be acceptable to have some of the parking bays associated with these flats large enough to be used as or marked up as disabled persons parking bays if required at a later date, and the management of these bays (to ensure that they are available at a later date) should be highlighted in the parking management plan.

61 It is recommended that some of the disabled persons parking bays incorporate a 2.6m vertical clearance both to it and for the area of the parking bay. This requirement could be accommodated externally, the reason for this recommendation being BS8300:2009 + A1:2010 states (referring to garaging and enclosed parking spaces):

62 “The access to the spaces, including the vehicular entrance and the ceiling level, should permit the use of a wheelchair hoist and have a vertical clearance of not less than 2.6m.”

63 The fact that residents can use any of the 3 lifts proposed (if they can negotiate the very long corridors) is positive in terms of access for disabled people, as it means if one breaks down, others are available. Lift access should also be available up to the roof garden area.

64 The fact that the applicant has looked into different balcony barrier treatments for the units which are to be ‘easily adaptable’ is excellent and will benefit any wheelchair users who do move in.

Supermarket design

65 Currently 6% of the parking bays appear to be proposed as disabled persons parking bays. They appear to be well positioned and designed. However, London Plan Table 6.2 requires the following levels of disabled persons parking for shopping, recreation and leisure facilities:

 one space for each employee who is a disabled motorist.

 6% of the total capacity for visiting disabled motorists.

66 4% of the total capacity to be ‘enlarged standard spaces’ which are defined as “Enlarged standard spaces 3.6m wide and 6m long that can be adapted to be parking spaces designated for use by disabled people to reflect changes in local population needs and allow for flexibility of provision in the future.”

S:\Planning Decisions\Cases\3047\Stage page 10 67 The applicant should therefore highlight on the plans and in their design and access statement where the 4% enlarged standard spaces will be provided within the layout.

68 The applicant confirmed that the floor to ceiling height of the retail car park will be higher than 2.6m therefore sufficient for people using hi-top vehicles or roof boxes.

69 Seating should be provided under the ‘public realm improvements’ to Hanworth Road. Some of the seating should incorporate back rests and arm rests to make it as usable as possible for as many people as possible, further guidance on this can be found in BS8300:2009 + A1:2010 5.1 (general) and the DfT’s ‘Inclusive Mobility’.

70 A significant number of bollards were illustrated to the front of the retail store. The number of bollards should be kept to a minimum (whilst still maintaining their original purpose), and should be designed in accordance with the guidance found in BS8300:2009 + A1:2010 5.7.1.2.

71 The distance to the lifts to the supermarket lobby is fairly significant for someone travelling from the High Street side of the development. It is appreciated that an alternative arrangement may be difficult given the site and space; however it should be ensured that the route to the lifts is clearly signed.

72 The only other concern is the highway alterations which are to be proposed as part of this scheme. The new mini roundabout appears to be set very close to the store and vehicle entrances. It is felt that this could cause difficulties/ an inconvenience for general pedestrians passing this development. There is no clear pedestrian line across this area, if someone were following the kerb line; they would end up walking into the traffic towards the mini round about. The proposals appear to prioritise vehicle movements over pedestrians.

73 There are also concerns regarding the width of the pedestrian crossing point across the entrance/ exit to the store car park- even with a central island each leg of the crossing is significant in length, especially for an uncontrolled crossing point. It is not clear whether the tactile paving provided to each side of the crossing would direct people in the right direction.

74 It is currently felt that the proposals would represent a worsening for pedestrians passing and accessing the development, there are concerns regarding the navigability and safety of the area for, in particular, disabled people, and this area is therefore felt to require further work.

Climate change mitigation

Overview of proposals 75 The applicant has broadly followed the energy hierarchy to reduce carbon dioxide (CO2) emissions. Sufficient information has been provided to understand the proposals as a whole. Further revisions and information is required before the proposals can be considered acceptable and the carbon dioxide savings verified.

Be Lean: energy efficiency standards

76 A range of passive design features and demand reduction measures are proposed to reduce the carbon dioxide 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 provision of mechanical ventilation heat recovery (MVHR) within the residential units and daylight control of high efficacy lighting within the retail area. The demand for cooling will be minimised through design and possible use of solar control glazing.

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Be clean: district heating

77 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 has, however, provided a commitment to ensuring that the development is designed to allow future connection to a district heating network should one become available.

78 The applicant should follow the energy systems hierarchy set out in Policy 5.6 and propose a communal heating system (site heat network) that will provide space heating/hot water to the proposed development. The applicant should confirm that all apartments and non- domestic building uses will be connected to the site heat network.

79 The site heat network should be supplied from a single energy centre. Information on the floor area and location of the energy centre should be provided

Combined Heat and Power

80 The applicant has investigated the feasibility of CHP. However, due the intermittent nature of the heat load, CHP is not proposed. This is accepted in this instance.

Be green: renewable energy technologies

81 The applicant has investigated the feasibility of a range of renewable energy technologies and is proposing to install solar photovoltaic (PV) panels for the residential apartments, air source heat pumps (ASHP) and a biomass boiler to serve the retail area.

82 The applicant should provide specific details of each of the renewable energy technologies (as set out in Appendix 1 of Energy Planning - GLA Guidance on preparing energy assessments, - September 2011) the GLA guidance on energy strategy preparation. In addition, the applicant should indicate how two competing heat producing technologies, i.e. the biomass boiler and air source heat pump (ASHP) will operate together.

83 The applicant should calculate and state the reduction in regulated carbon dioxide emissions in tonnes per annum that will be achieved through this third part of the energy hierarchy.

Overall carbon savings 84 The applicant should state the estimated regulated carbon emissions of the development in tonnes of carbon dioxide per annum before (baseline) and after the cumulative effect of energy efficiency measures, district heating, CHP and renewable energy has been taken into account and at each interim stage of the energy hierarchy and complete the table overleaf.

S:\Planning Decisions\Cases\3047\Stage page 12 Table: Carbon dioxide emission reductions from application of the energy hierarchy

Total residual regulated Regulated CO2 emissions CO2 emissions reductions (tonnes per annum) (tonnes/annum) (% cent) Baseline i.e. 2010 Building Regulations Energy Efficiency CHP Renewable energy Total

85 A reduction of [Y] tonnes of carbon dioxide per year in regulated emissions compared to a 2010 Building Regulations compliant development is expected, equivalent to an overall saving of [Z]%.

86 The carbon dioxide savings exceed the targets set within Policy 5.2 of the London Plan.

Noise Mitigation & air quality assessment

Noise mitigation

87 The applicant should be aware that no single aspect apartments should be located in noise category C and D, and if this is the case housing layouts should be modified to create duel aspect units or an alternative design mitigation approach adopted.

88 The applicant has provided a noise mitigation assessment and this is welcome. At the pre- application stage it was requested the applicant the applicant include winter gardens on balconies facing Hanworth Road, this should be include in the design.

Air quality

89 The applicant has provided an air quality assessment and this is welcome. It is requested details of the different renewable energy technologies are include in the air quality assessment as adjustments are made in response to the energy strategy comments. Transport

90 Pending disposal, this site is currently in TfL’s ownership. As such these comments relate to the strategic transport policies of the London Plan and not to any other matter that is relevant to TfL, including any property interest.

Retail parking

91 A total of 294 retail parking spaces are proposed; 1 space for every 23 square metres of floorspace. This exceeds the London Plan maximum standards of 1 space per 25 to 38 square metres and should therefore be reduced in line with the low end of this range. As considered below, the surrounding road network is already congested and capped parking levels will assist in minimising additional vehicular trips. The applicant should also identify the location and number of

S:\Planning Decisions\Cases\3047\Stage page 13 blue badge spaces as well as electric vehicle charging points (10 percent active and 10 percent passive provision).

Residential parking

92 A total of 50 residential parking spaces are proposed, which is equivalent to a ratio of 0.88 spaces per dwelling. For locations with such good public transport accessibility, London Plan policy 6.3 states that provision should be significantly less than one per unit. Similarly as above, TfL therefore considers this level of provision should be further reduced. Furthermore, the applicant should enter into a ‘permit free’ agreement with the local authority, to ensure ineligibility for on- street permit of future occupier, which should be secured by section 106 agreement.

93 A total of 10% (5 spaces) of the residential parking spaces will be equipped with electric vehicle charging points (EVCPs). Base on the current quantum of spaces proposed, this should however be increased to 10 spaces, or the equivalent of 20%, in line with London Plan policy. Passive provision should also be made for a further 20% to be equipped with EVCPs in the future.

94 Regardless of the overall level of provision that is ultimately agreed, a site wide car parking management plan should be adopted to control and minimise its impact. This may, for example, prioritise the allocation of residential spaces for family dwellings and ensure that 10% of spaces are available for Blue Badge holders.

Transport modelling

95 For the residential element of the proposals, data from the four TRAVL survey sites selected to estimate the trip generation associated with this specific use are considered reasonable. However, with the publication of latest Census 2011 data, the modal split should be further reviewed to ensure that it is robust.

96 For the assessment of retail trips, the applicant should consider whether there is representative data from the intended operator with store size, locations and parking levels comparable to the application site. It is also recommended that the use of survey data from the TRAVL database should be for referencing purposes only.

97 In context of concerns over the design impact on the public realm. A mini-roundabout has been proposed on Hanworth Road to provide access to the proposed supermarket. The design of the junction has been supported by junction modelling. The applicant should therefore supply evidence to demonstrate that this modelling has been developed, validated and calibrated in line with TfL guidance. In addition, both the preliminary design and stage 2 safety audit should be reviewed by Hounslow Council and TfL before the application is determined to ensure the safety of all road users and the reliability of bus operations in line with London Plan policy 6.11.

98 TfL has identified that three signal controlled junctions in the vicinity of the sites currently experience peak hour congestions. As such the applicant should undertake an assessment of these junctions to demonstrate that highway capacity would be maintained with the trips likely to be generated from this development; and to identify any necessary mitigation. As above, any junction modelling should be in accordance with TfL guidance.

Public transport

99 The assessment of additional bus demand does not account for the 850m distance to Hounslow Central Station. As such a significant proportion of underground trips are likely to include a short journey on routes 111 and H28 to either Hounslow Central or Hounslow East stations; this would have an impact to bus service capacity and further assessment is needed to

S:\Planning Decisions\Cases\3047\Stage page 14 determine if service improvement is required. Nevertheless there will still be a significant increase in bus travel; TfL therefore consider that the nearest two shelters on Hanworth Road should be upgraded to improve accessibility. As such TfL requests a section 106 contribution of £15,000.

Cycle parking

100 A total of 20 cycle parking spaces are proposed for the retail element of the development in line with London Plan policy 6.13 ‘Parking’ and are therefore welcomed. The cycle stands should be secured and covered, and conveniently located. Shower and changing facilities should also be provided to encourage employees to cycle.

Pedestrian network

101 An audit of the local pedestrian network is understood to have been undertaken. TfL therefore requests details of the audit in order to determine the appropriate level of pedestrian improvements that should be secured by Hounslow Council in line with London Plan policy 6.10.

Travel plan

102 The applicant’s commitment to provide a full travel plan is welcomed. However, the draft Travel Plan submitted has failed the ATTrBuTe Travel Plan assessment. Improvements required including the revision of modal split based on latest 2011 Census data; distinguishing targets between short, medium and long term; ensuring sufficient time allowed for the travel plan co- ordinator to perform its role; and most importantly, the travel plan shall be secured and monitored by section 106 agreement in line with London Plan Policy 6.3.

103 In order to manage the impact of construction and servicing traffic on highway network a construction logistic plan (CLP) and a delivery servicing plan (DSP) should also be secured by condition.

Conclusion

104 In summary, TfL considers the current proposal does not comply with the transport policies of the London Plan for the reasons stated above. As such, the applicant is required to address all of the issues raised; these include, but are not limited to reviewing trip generation and modal split, parking provision and undertaken further modelling to assess capacity impact to the highway network. Community Infrastructure Levy

105 The Mayor has introduced a London-wide Community Infrastructure Levy (CIL) to help implement the London Plan, particularly policies 6.5 and 8.3. The Mayoral CIL formally came into effect on 1 April 2012, and it will be paid on commencement of most new development in Greater London that was granted planning permission on or after that date. The Mayor's CIL will contribute towards the funding of Crossrail

106 The Mayor has arranged boroughs into three charging bands. The rate for Hounslow Council is £35/sq.m. The required CIL should be confirmed by the applicant and council once the components of the development or phase thereof have themselves been finalised. See the 2010 regulations: http://www.legislation.gov.uk/ukdsi/2010/9780111492390/contents as amended by the 2011 regulations: http://www.legislation.gov.uk/uksi/2011/987/made

S:\Planning Decisions\Cases\3047\Stage page 15 107 London borough councils are also able to introduce CIL charges which are payable in addition to the Mayor’s CIL. Hounslow Council has yet to adopt a scheme. See the council’s website for more details. Local planning authority’s position

108 Hounslow Council officers have expressed concern over the retail proposals and in particular impact on Hounslow town centre regeneration. Legal considerations

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

110 There are no financial considerations at this stage. Conclusion

111 London Plan policies on retail/ town centre uses, employment, housing, urban design, access, climate mitigation change and transport are relevant to this application. The application does not comply with a number of these policies and needs addressing, for the following reasons:

 Retail: the proposed out of centre retail development requires substantial justification and additional supporting evidence: the defined retail catchment should be adjusted to respond to the additional centres required by Hounslow Council; the sequential test should be further expanded to account for town centre sites in Hounslow town centre masterplan; further justification is required on impact on investment in the identified town centre retail hierarchy and in particular in context of Hounslow town centre masterplan; the applicant is required to respond to the findings of the Hounslow Joint Retail Needs Assessment report in context of its assessment of retail need and impact across the identified town centre network.  Design: the applicant should respond to concerns raised in relation to layout and urban form, scale and massing, activation of the public realm and residential quality.  Access: the applicant should provide the requested additional information and respond to comments on public realm, car parking and public facilities.  Children and young persons play: the design and access statement should provide a calculation of child yield using the GLA calculator and provide a clear strategy on children and young persons play. The location and provision of playspace should be reconsidered.  Climate change mitigation: the applicant should provide the requested additional information and respond to required clarifications in relation to energy efficiency standards, district heating, renewable energy technologies and overall carbon savings.

S:\Planning Decisions\Cases\3047\Stage page 16  Air quality: The applicant should resubmit the air quality assessment responding to comments made.  Noise mitigation: the applicant should include winter garden balconies for single aspect units facing Hanworth Road. In context of these units being the primary out door space and noise generated by road traffic increasing through store usage.  Transport TfL considers the current proposal does not comply with the transport policies of the London Plan. The applicant is required to address all of the issues raised; these include, but are not limited to reviewing trip generation and modal split, parking provision and undertaken further modelling to assess capacity impact to the highway network.

for further information, contact Planning Decisions Unit: Colin Wilson, Senior Manager – Planning Decisions 020 7983 4783 email [email protected] Justin Carr, Strategic Planning Manager (Development Decisions) 020 7983 4895 email [email protected] Jonathan Aubrey, Case Officer 020 7983 5823 email [email protected]

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