London Borough of Hounslow Annual Monitoring Report

LONDON BOROUGH OF HOUNSLOW

ANNUAL MONITORING REPORT

2006/07

CONTENTS PAGE

LIST OF ABBREVIATIONS ...... 5 LIST OF FIGURES AND TABLES...... 6 EXECUTIVE SUMMARY – KEY FINDINGS ...... 8 1. INTRODUCTION...... 12 2. THE BOROUGH IN CONTEXT...... 13 3. HOUNSLOW’S LOCAL DEVELOPMENT SCHEME...... 16 LDS MILESTONES ACHIEVED IN THE PERIOD 1 OCTOBER 2006 TO 30 SEPTEMBER 2007...17 Development Plan Documents (DPD) ...... 17 Supplementary Planning Documents (SPD) ...... 18 PART 2 – PLANNING POLICY IMPLEMENTATION ...... 22 4. MONITORING FRAMEWORK ...... 23 5. DATA COLLECTION ...... 24 Development Monitoring...... 24 Planning Decisions...... 24 Planning Appeals...... 25 6. HOUSING...... 27 CONTEXTUAL INDICATORS...... 27 OUTPUT INDICATORS ...... 28 UDP OBJECTIVE H.1 ...... 28 Core Indicator(s)...... 28 UDP OBJECTIVE H.2 ...... 32 Core Indicator(s)...... 32 Local Indicator(s)...... 33 Significant Effects...... 38 UDP OBJECTIVE H.3 ...... 39 Local Indicator(s)...... 39 UDP OBJECTIVE H.4 ...... 43 Core Indicator(s)...... 43 Local Indicator(s)...... 44 UDP OBJECTIVE H.6 ...... 50 Local Indicator(s)...... 50 UDP OBJECTIVE H.7 ...... 51 Local Indicator(s)...... 51 Significant Effects...... 51 SUMMARY OF UDP HOUSING POLICY IMPLEMENTATION ...... 52 7. EMPLOYMENT ...... 54 CONTEXTUAL INDICATORS...... 54 OUTPUT INDICATORS ...... 56 UDP OBJECTIVE E.1 ...... 56 Core Indicator(s)...... 56 Local Indicator(s)...... 62 Significant Effects...... 68 UDP OBJECTIVE E.5 ...... 69 Local Indicator(s)...... 69 SUMMARY OF UDP EMPLOYMENT POLICY IMPLEMENTATION ...... 71

2 8. SHOPPING...... 72 CONTEXTUAL INDICATORS...... 72 OUTPUT INDICATORS ...... 73 UDP OBJECTIVE S.1 ...... 73 Local Indicator(s)...... 73 Significant Effects...... 76 UDP OBJECTIVE S.2 ...... 78 Local Indicator(s)...... 78 UDP OBJECTIVE S.3 ...... 81 Core Indicator(s)...... 81 Local Indicator(s)...... 82 SUMMARY OF UDP SHOPPING POLICY IMPLEMENTATION ...... 84 9. COMMUNITY AND LEISURE ...... 85 CONTEXTUAL INDICATORS...... 85 OUTPUT INDICATORS ...... 86 UDP OBJECTIVE C.1 ...... 86 Local Indicator(s)...... 86 Significant Effects...... 86 UDP OBJECTIVE C.2 ...... 88 Significant Effects...... 88 UDP OBJECTIVE C.3 ...... 89 Significant Effects...... 89 UDP OBJECTIVE C.5 ...... 90 Core Indicator(s)...... 90 Local Indicator(s)...... 90 UDP OBJECTIVE C.6 ...... 92 SUMMARY OF UDP COMMUNITY AND LEISURE POLICY IMPLEMENTATION...... 93 10. PLANNING OBLIGATIONS ...... 94 OUTPUT INDICATORS ...... 94 UDP OBJECTIVE IMP.6 ...... 94 Local Indicator(s)...... 94 11. ENVIRONMENTAL PROTECTION ...... 97 CONTEXTUAL INDICATORS...... 97 OUTPUT INDICATORS ...... 98 UDP OBJECTIVE ENV-P.1...... 98 Significant Effects...... 98 UDP OBJECTIVE ENV-P.2...... 99 Core Indicator(s)...... 99 Local Indicator(s)...... 100 Significant Effects...... 101 UDP OBJECTIVE ENV-P.3...... 103 Core Indicator(s)...... 103 SUMMARY OF UDP ENVIRONMENTAL PROTECTION POLICY IMPLEMENTATION...... 104 12. BUILT ENVIRONMENT...... 105 CONTEXTUAL INDICATORS...... 105 OUTPUT INDICATORS ...... 106 UDP OBJECTIVE ENV-B.1...... 106 Local Indicator(s)...... 106 Significant Effects...... 107 UDP OBJECTIVE ENV-B.2...... 109

3 Local Indicator(s)...... 109 Planning Decisions...... 109 Significant Effects...... 110 Summary of UDP Built Environment Policy Implementation ...... 111 13. NATURAL ENVIRONMENT ...... 112 CONTEXTUAL INDICATORS...... 112 OUTPUT INDICATORS ...... 114 UDP OBJECTIVE ENV-1 ...... 114 Core Indicator(s)...... 114 Local Indicator(s)...... 114 Significant Effects...... 118 UDP OBJECTIVE ENV-N.2...... 119 Core Indicator(s)...... 119 Significant Effects...... 119 SUMMARY OF UDP NATURAL ENVIRONMENT POLICY IMPLEMENTATION ...... 120 14. WATERWAYS...... 121 CONTEXTUAL INDICATORS...... 121 OUTPUT INDICATORS ...... 122 UDP OBJECTIVE ENV-W.2...... 122 Core Indicator(s)...... 122 Local Indicator(s)...... 122 Significant Effects...... 123 SUMMARY OF UDP WATERWAYS POLICY IMPLEMENTATION ...... 124 15. TRANSPORT AND DEVELOPMENT ...... 125 CONTEXTUAL INDICATORS...... 125 OUTPUT INDICATORS ...... 126 UDP OBJECTIVE T.1...... 126 Core Indicator(s)...... 126 Significant Effects...... 127

4 LIST OF ABBREVIATIONS

AMR Annual Monitoring Report AQMA Air Quality Management Area BAAP Brentford Area Action Plan BAP Biodiversity Action Plan BVPI Best Value Performance Indicators CABE Commission for Architecture and the Built Environment DCLG Department for Communities and Local Government Defra Department for Environment, Food and Rural Affairs DPD Development Plan Documents EA Environment Agency GLA Greater London Authority HMO Houses in Multiple Occupation LDD London Development Database LDF Local Development Framework LDS Local Development Scheme LNR Local Nature Reserve LP London Plan m2 Metres Squared PPG Planning Policy Guidance PPS Planning Policy Statement PSA Public Service Agreement REG Residential Extensions Guidelines Supplementary Planning Guidance SA Sustainability Appraisal SAP Species Action Plan SAMs Scheduled Ancient Monuments SCI Statement of Community Involvement SDC Sustainable Development Committee SPA Special Protection Area SSSIs Sites of Special Scientific Interest UDP Unitary Development Plan

5 LIST OF FIGURES AND TABLES

List of Tables

Table 1: BVPIs 200a – 200c...... 17 Table 2: Number of net additional dwellings completed from 2000 to 2005/06, and projected from 2006/07 to 2016/17...... 30 Table 3: Affordable Housing Completions 2006/07 ...... 33 Table 4: Permissions for developments proposing more than 20 residential units in 2006/07...... 34 Table 5: Affordable Housing Need in the Borough ...... 35 Table 6: Summary of type and size of affordable housing units in residential schemes of over 20 units granted planning permission in 2006/07 ...... 36 Table 7: Type and size of affordable housing units in residential schemes of over 20 units granted planning permission in 2006/07...... 36 Table 8: Percentage of Affordable Housing in proposals quoting H.2.1 as a reason for refusal...... 37 Table 9: Percentage of residential dwellings completed by density range ...... 43 Table 10: Density of major residential schemes approved at Sustainable Development Committee during the 2006/07 financial year relative to density ranges in the UDP and London Plan...... 45 Table 11: Range of housing in residential approvals of 20 or more units...... 47 Table 12: Bedroom Size Table 13: Family Housing Mix...... 48 Table 14: Number of Homeless Persons in the Borough ...... 51 Table 15: Ratio of planning permission to 3 year average starts...... 54 Table 16: Gross Internal Floorspace developed for employment 2006/07 ...... 56 Table 17: Amount of floorspace developed for employment by type...... 57 Table 18: Amount of floorspace developed for employment by type in employment areas ...... 58 Table 19: Amount of floorspace developed for employment in regeneration areas ...... 58 Table 20: Employment Proposal Sites (including Key Employment Locations) ...... 59 Table 21: Sites designated for employment uses in the Employment DPD ...... 59 Table 22: Employment land available by type in sites defined and allocated for employment use in the UDP...... 61 Table 23: Employment land available by type in approvals for Class B developments outside employment areas defined in UDP and Employment DPD...... 61 Table 24: Total Land Available for Employment by Type ...... 61 Table 25: Permissions for developments proposing new business (B1) uses in 2006/07.63 Table 26: Amount of completed retail, office and leisure in schemes proposing over 500m2 of floorspace ...... 81 Table 27: Percentage of completed retail, office and leisure development in town centres ...... 82 Table 28: Life expectancy at birth...... 89 Table 29: Total Number of Agreements Signed ...... 94 Table 30: Financial Contributions contained within Legal Agreements signed in 2006/07 94 Table 31: Benefits received by category through S106 agreements based on monies received in 2006/07 ...... 95 Table 32: Benefits delivered by category through S106 agreements based on spend in 2006/07...... 95 Table 33: Provision of Affordable Housing Units Contained within Legal Agreements signed in 2006/07 ...... 95 Table 34: Affordable Housing S106 Financial Contributions received during 2006/07...... 96 Table 35: Sources of noise pollution in the local area ...... 98

6 Table 36: Municipal Waste Arising by Type...... 99 Table 37: Renewable Energy Installed by Type ...... 99 Table 38: Summary of Listed Buildings Risk by Grade ...... 110 Table 39: Condition of SSSIs in the Borough ...... 119 Table 40: Amount of completed non-residential development complying with car parking standards for developments with over 500m2 of floorspace...... 126 Table 41: The amount of new residential development within 30 minutes public transport time of: a GP, a hospital, a primary school; a secondary school; areas of employment; and a major retail centre...... 127 Table 42: Mode of Transport uses for various trips ...... 128 Table 43: Rating of Public Transport in Hounslow...... 128 Table 44: Proportion of residents rating aspects of public transport in Hounslow as either fairly or very good – comparison of 2004 and 2006...... 129

List of Figures

Figure 1: Map of the London Borough of Hounslow ...... 14 Figure 2: Current LDS Timetable...... 19 Figure 3: Sample page from the AMR Appeals Database...... 25 Figure 4: London Borough of Hounslow Housing Trajectory 2006/07 ...... 31 Figure 5: LDA Borough Economic Profile...... 54 Figure 6: Permissions for B1 development started and not started in Hounslow 1990 FY - 2005 FY ...... 55 Figure 7: Key Performance Indicators for the Borough’s Four Town Centres ...... 76 Figure 8: Definition of Retail, Office and Leisure Uses in Core Indicator 4a...... 81 Figure 9: Ecological Footprint for Hounslow...... 101 Figure 10:Satisfaction with your neighbourhood as a place to live...... 108

7 EXECUTIVE SUMMARY – KEY FINDINGS

Part 1 – Local Development Scheme Implementation

• The Secretary of State approved the Council’s third revision to its Local Development Scheme in May 2007. The milestones in the document were revised in light of an improved national understanding of the timescales required to produce sound local development documents.

• Both the Brentford Area Action Plan and Employment Development Plan Document were submitted to the Secretary of State on July 30 2007. The submission date was three weeks after the Local Development Scheme Milestone of June 2007.

• Consultation on the Borough’s Core Strategy issues and options and possible future site allocations took place between May and August 2007 in accordance with the relevant Local Development Scheme Milestones.

• The third revised Local Development Scheme commits the Council to producing a Joint Waste Development Plan Document with the other West London waste planning authorities and sets out agreed milestones for its production.

• The first scheduled milestone for the Joint Waste Development Plan Document is the Issues and Options consultation in December 2007. However, the achievement of this milestone looks unlikely as the process of appointing consultants to produce the document is scheduled for completion in mid-December. The earliest the Council expects the Issues and Options consultation to take place is February 2008.

• Both the Planning Obligations and Air Quality Supplementary Planning Documents were scheduled for adoption in September 2007. However, the need to undertake a sustainability appraisal of both documents caused a delay to their publication for consultation. They are now both due for adoption in early 2008.

Part 2 – Planning Policy Implementation

Housing

• There has been a net increase of 1,432 residential units in the Borough during the financial year. This increase exceeds the London Plan annual monitoring target for the Borough of 470. This total excludes the completion of 843 (net) non-self contained units and 313 non-local authority owned vacant dwellings returned to occupation or demolished during the financial year as a direct result of action by the local authority (BVPI 64). Both these figures are included in the London Plan’s annual monitor of additional homes, which would give the Borough a total of 2,588 additional homes for the 2006/07 financial year, 5.5 times the Borough’s annual target.

• The outturn of net additional affordable dwellings for the financial year was 633, which represents 44.2% of total net housing completions. Although the outturn of 44.2% is below the Borough and London wide target of 50% it shows a significant improvement on the previous year when the proportion of completed affordable housing was only 24.7%.

8 • Although four applications were approved which did not meet the Borough’s target for 50% affordable housing, these particular schemes will provide a large number of affordable family units. This is reflected in the 43.8% of affordable housing provided as three bedrooms or more, which is a significant improvement on the 16.2% provided in the previous financial year. This increase achieved the Hounslow Plan Target of shifting the balance of affordable housing towards family sized dwellings.

• Hounslow exceeded both the national (60%) and local (90%) target for the proportion of housing built on previously developed land, with 93% of all new and converted dwellings in the Borough on brownfield land despite the completion of units within a scheme of greenfield land approved by the Planning Inspectorate on appeal.

• The mean average density for all completed dwellings in the Borough was 68 dwellings per hectare. This is a significantly less than the average density in the previous financial year when 102 units per hectare was achieved.

Employment

• 77,405m2 of gross internal floorspace was development for employment uses (Use Class B uses) during the 2006/07 financial year, of which half was made up from office buildings 4 and 5 at Chiswick Park. Of the total floorspace completed, 67% was developed within employment areas in the UDP and 84% was designated in the emerging Employment Development Plan Document.

• The total amount of employment land lost to non-employment uses was 3.691 hectares. Only 0.386 hectares of this land was lost to completed residential use. The remainder has been lost to employment generating uses which are not counted as Class B employment uses, including an hotel, a fuel depot and an MOT service centre.

Shopping

• 57,279m2 of new retail floorspace was completed in the financial year of which 88% was in Feltham town centre.

• The key performance indicators from the West London Retail Needs Study show contrasts in the performance and role of the Borough’s four town centres. Chiswick has the largest number of outlets whilst Hounslow contains the largest amount of retail floorspace. As the Borough’s only Metropolitan centre, Hounslow has the largest share of the comparison goods market (clothing, electricals, etc) and the lowest proportion of vacant units at 5.3%.

• Appeal decisions continue to highlight the need for evidence on the extent and make up of shopping parades in decisions for changes of use from retail to non-retail uses. An annual survey of uses in the Borough’s main shopping areas and parades is carried out by the Strategic Planning Policy Team.

Community and Leisure

• No new significant community or leisure developments were completed within the Borough during the financial year.

Environmental Protection

9 • Three wind turbines were installed in the Borough during the financial including two at Cranford Community College which generate 0.012MW/hr of electricity.

• There is one active aggregate recycling site in the Borough – Days Aggregates. The total output of recycled aggregates from this site in 2006/07 was 320,349 tonnes, an increase of 16% on the output of the previous financial year (Source: Day Group Ltd, 2007).

• The total amount of municipal waste collected in the financial year was 116,509 tonnes. This represents a 1.2% increase on the outturn of the previous financial year.

Built Environment

• Five out of the six advertisement appeal decisions related to advertisements along the Great West Road, of which only one, for a temporary display at Gillette Corner, was approved. The key issues in these decisions were the scale of the hoardings/ towers and their impact on the street scene at ground level.

• Hounslow’s first ever design awards were held this year with all developments completed before 1st July 2007 eligible for nomination. The judging took place in December 2007. In the New Build category an award was given to the Heart of Hounslow Centre for Health for Best Public Building. A commendation was also given in the new build category for Mows, 1-4 Barley Mow Passage, Chiswick as for New Infill Building. In the Reuse of Existing Building category commendations were given to 46-48 The Grove for refurbishment in a Conservation Area, and to the Light Box, 111 Power Road, Chiswick for refurbishment and reuse of a building for employment use. In the Public Open Space category a commendation for landscape and play was given to Dukes Meadow Water Play Area, Chiswick.

• There has been no change in the number of Listed Buildings at Risk in the Borough which remains at 19, including one Grade I listed structure, Boston Manor House.

Natural Environment

• Three parks in the Borough achieved Green Flag Award standard for the 2006/7 financial year. This equates to 12.4% of all publicly accessible open space in the Borough. The award is a marker of good quality in the management and maintenance of green spaces.

Waterways

• There were no planning decisions granted contrary to advice from the Environment Agency on flood risk or water quality.

• The Council has produced a Strategic Flood Risk Assessment to guide future planning policy and development control decisions on issues relating to flood risk.

Transport and Development

• Only 3% of completed non-residential floorspace in Hounslow did not comply with the Council’s maximum parking standards. In all cases this was due to the inclusion of existing parking provision on the site.

10 • All of the newly completed dwellings are within 30 minutes public transport time of a primary school. The vast majority (99%+) are within 30 minutes public transport time areas of a GP, secondary school, an area of employment and major retail centre.

• Only two thirds (26.7%) of newly completed dwellings are within 30 minutes public transport time a hospital. Of these newly completed dwellings not within 30 minutes public transport time a hospital, the largest numbers (mainly generated through two particularly large developments) are located at Boston Manor in Brentford and Feltham town centre, with the remainder spread between parts of Chiswick, Hounslow and Heston.

11 1. INTRODUCTION

1.1 Section 35 of the Planning and Compulsory Purchase Act 2004 requires every local planning authority to produce an Annual Monitoring Report (AMR) as part of their Local Development Framework (LDF). LDF is the collective term given to a portfolio of statutory and non-statutory documents that together will replace the Unitary Development Plan, and provide a new spatial planning framework for the Borough.

1.2 This AMR covers the period from 1 April 2006 to 31 March 2007. The document contains information on:

Part 1 – Local Development Scheme Implementation 1.3 A review of development plan preparation against the timetable and milestones set out in the Borough’s Local Development Scheme.

Part 2 – Planning Policy Implementation 1.4 An analysis of the extent to which the policies and targets in existing plans and policies are being achieved and the significant effects on social, environmental and economic objectives

1.5 A summary of all the matters to be addressed in the AMR are set out in Table 3.2 of the document Local Development Framework Monitoring: A Good Practice Guide (ODPM 2005).

12 2. THE BOROUGH IN CONTEXT

2.1 Geographically situated in outer West London, Hounslow is a large borough covering approximately 22 square miles. Stretching from Chiswick in the east to the boundaries of Heathrow Airport in the west, the transition from the urban environment of the suburbs to the semi-rural environment of the urban fringe takes place within Hounslow.

2.2 The Borough has a mix of residential, commercial and industrial land uses interlaced with several waterways, including the River Thames, large areas of open space and areas of cultural and architectural heritage. It is reasonably well served by public transport and ideally located for national transport links, with easy access to major roads and motorways linking Central London and the City to the south west, Wales, the Midlands and beyond via the A4, M25 and M4. As an outer London borough, Hounslow borders the London boroughs of Hillingdon, Ealing, Richmond-upon-Thames, Hammersmith & Fulham and also Spelthorne Borough and Surrey County Council.

2.3 Hounslow has large areas of green space with over 581 hectares of public open space and 1,246 hectares of urban green space - roughly 30% of the Borough’s surface land area. There are large areas of green belt in the west as well as a number of significant open spaces in the more built-up parts of the Borough. Osterley, Boston Manor, Chiswick House grounds, Duke’s Meadows, Syon and Gunnersbury Parks provide invaluable ‘green lungs’ which serve the environmental and recreational needs of the population living within and beyond the Borough’s boundaries. The River Thames and the Grand Union Canal also add considerably to the quality of the open space and residential areas in Chiswick, Brentford and Isleworth.

2.4 Although outside of the Borough’s boundaries, Heathrow Airport has a dominant influence on Hounslow’s economy. Employment in the west area of the Borough is dominated by airport related logistics, construction and services such as hospitality and catering. This area also contains nearly half of the Borough’s industrial and commercial estates. Elsewhere in the Borough, where the airport has less of a direct influence, the economy has restructured. Traditional industrial estates have been affected by nationwide decline in manufacturing and are characterised by ageing, sometimes obsolete commercial floorspace, some of which lies vacant or underused. At the same time there has been a shift towards service sector employment opportunities. The development of Chiswick Park has also created one of the strongest locations for office lettings outside of central London.

2.5 The Borough has four town centres – Brentford, Chiswick, Hounslow and Feltham. These centres as well as Chiswick Park, the Great West Road and Bedfont Lakes are the Borough’s key development nodes. Hounslow and Feltham town centres are undergoing significant redevelopment and the Council is currently developing plans to facilitate the regeneration of Brentford. A number of vacant employment sites on the Great West Road are also likely to be redeveloped for mixed-use.

2.6 Hounslow has one of the most culturally diverse communities in the UK. The 2001 Census recorded 212,344 people resident in the Borough with over 120 languages spoken and 35% of the population are from minority ethnic groups (Census 2001). Population projections predict an overall increase in the population of Hounslow of just over 10,000 people (approximately 5% of the current population) from 2003 to 2028. The population density of the Borough currently averages 37.9 people per hectare, compared to the London average of 45.6 people per hectare. Hounslow has the eighth highest population density of the 33 London boroughs.

13 2.7 Hounslow’s residents live in communities stretching from Bedfont at the fringe of Greater London in the west to the Victorian streets of Chiswick in the east. Local areas are very different in character and therefore have different needs. There have always been some affluent parts of the Borough and, taken as a whole, Hounslow is not poor in comparison to many other boroughs. However, there are notable and persistent areas of deprivation in the Borough in the wards of Bedfont, Brentford, Hanworth, Heston West and Syon. These areas are characterised by higher unemployment, skills mismatch, a large percentage of lone parent families, lower academic attainment, high crime rates and drug abuse, a higher amount of local authority housing, and areas of severe environmental and industrial decline.

Figure 1: Map of the London Borough of Hounslow

14 Part 1 – Local Development Scheme Implementation

15 3. HOUNSLOW’S LOCAL DEVELOPMENT SCHEME

3.1 The Local Development Scheme (LDS) was the first document to be produced as part of the Borough’s Local Development Framework (LDF). It is a project plan, which sets out the documents to be included in the LDF. For each document it provides information about timescales and when the public will be formally involved. It shows the geographical area that each document covers and explains how the documents are linked, and the need for conformity between them. It considers other aspects of LDF project management including leadership, political engagement and reporting, possible joint borough working, resources and risk assessment.

3.2 The role of the AMR is to compare actual local development document preparation against the stated milestones within the Local Development Scheme. If the Council is falling behind schedule or fails to meet a target the AMR will set out the reasons for this and what steps will be taken to address any problems.

3.3 The Council’s first LDS came into effect from 31 May 2005. Despite making all of the milestones in the first LDS, a number of changes were proposed by the Council in April 2006. These amendments were submitted to the Secretary of State who agreed the second version on 12th May 2006. This second LDS covered the 2006/07 financial year.

3.4 However, during the 2006/07 financial year it became apparent that two milestones within the second LDS could not be achieved. These were the submission of the Brentford Area Action Plan and the Employment Development Plan Document to the Secretary of State in December 2006.

3.5 In August 2006 the first two local development documents nationally to be considered by the Secretary of State were found to be unsound. As a consequence of these decisions and following advice from government offices, many local authorities delayed the submission of development plan documents in order make sure plans are sound.

3.6 The Council considered that whilst the Brentford Area Action Plan and Employment Development Plan Document were sound in procedural terms, further work was needed to past the tests relating to the robustness and credibility of the evidence base and the mechanisms for implementation. As a consequence, several new assessments and studies were commissioned including a retail needs assessment, a strategic flood risk assessment, a transport study and a Brentford urban design appraisal and workshop.

3.7 A secondary reason for delay was that there would be advantages in reconsidering submission dates in order to take account of the Council’s new Community Plan due for adoption in April 2007. Conformity with the Borough’s Community Plan is a key test of soundness and it is fundamental that all new development plan documents seek to the deliver the vision set out by the local community.

3.8 It was subsequently considered necessary to make further amendments to the Council’s LDS which were approved by the Secretary of State in April 2007. This third LDS provides the current milestones for the production of the Borough’s LDF.

3.9 The 2005/06 AMR used the second amended LDS to review progress on the preparation of local development documents for a 12 month period from October 2005. Following on from this the 2006/07 AMR reviews the period 1 October 2006 to 30 September 2007 using the third amended LDS.

16 3.10 Best Value Performance Indicators (BVPIs) 200a-200c shown in Figure 1 summarise the Council’s LDF progress against national performance targets during the financial year, and shows that all targets were achieved.

Table 1: BVPIs 200a – 200c

BVPI Description Target Outturn Did the local planning authority submit the Local 200a Development Scheme by 28th March 2005 and Yes Yes thereafter maintain a three year rolling programme Has the local planning authority met the milestones 200b Yes Yes which the current Local Development Scheme sets out?

Did the local planning authority publish an annual report 200c Yes Yes by 31st December each year?

LDS Milestones Achieved in the period 1 October 2006 to 30 September 2007

Development Plan Documents (DPD)

Employment Development Plan Document (Employment DPD) Brentford Area Action Plan (BAAP) 3.11 A new submission date of June 2007 was approved for these two documents in the Council’s third revised LDS.

3.13 Both the Brentford Area Action Plan and Employment Development Plan document were subsequently submitted to the Secretary of state on 20 July 2007, a delay of three weeks against the relevant LDS milestone. The small delay was caused by scheduling of Borough Council for late June and need to allow for the printing of all submission documents. The Council considered that the length of the delay is insufficient to warrant a review of the LDS at this time.

3.14 The next milestone for both these documents will be the Pre-Examination meeting. These dates are yet to be determined by the Planning Inspectorate but are expected early in the new year. This would be later than scheduled in the third amended LDS but is subject to determination by the appointed Planning Inspector.

Core Strategy Site Specific Designations and Policies Proposal Map Site Allocation Schedule Generic Development Control Policies 3.15 Consultation on the Borough’s Core Strategy Issues and Options and possible site allocations took place between May and August 2007 in accordance with the relevant LDS milestones.

3.16 The Issues and Options questionnaire sought views on potential growth and sustainable development as well as on more detailed issues relating to how best land use and spatial planning can contribute to achieving the objectives in the Community Plan. Through the site allocations consultation the Council invited developers and landowners to put forward

17 potential sites considered suitable for development and reconsider those in the existing Unitary Development Plan, which have not yet been developed.

3.17 Each of the options and sites put forward were subject to assessment against 15 sustainability objectives as part of an initial Sustainability Appraisal.

Joint Waste DPD 3.18 The third LDS commits the Council to producing a Joint Waste Development Plan Document along with the other West London Waste Planning Authorities, and sets out agreed milestones for its production.

3.19 The six constituent boroughs have agreed a Memorandum of Understanding and work has commenced on a brief to commission consultants to undertake the first stage of the project. No milestones for the production of the document occur during the period under review.

3.20 The first scheduled milestone is for consultation on issues and options to take place in December 2007. However, the achievement of this milestone looks unlikely as the process for the appointment consultants to produce the document is scheduled to run until mid-December 2007. The earliest the Council expect the issues and options consultation to take place is February 2008.

Supplementary Planning Documents (SPD)

Planning Obligations Air Quality 3.21 Both the Planning Obligations and Air Quality SPDs were scheduled for adoption in September 2007 in the third LDS. However, the need to undertake a sustainability appraisal of the two SPDs caused a delay in their production. The documents were subsequently published for consultation for a four-week period from July 12th 2007. Both SPDs are now due for adoption in early 2008.

18 Figure 2: Current LDS Timetable

21 PART 2 – PLANNING POLICY IMPLEMENTATION

4. MONITORING FRAMEWORK

4.1 This section of the AMR analyses the performance of policies in Hounslow’s UDP against policy and sustainability targets. Government guidance proposes that three types of indicator are used to monitor the performance and effects of local planning policies through the AMR:

1. Contextual indicators describe the wider social, economic and environmental background against which the UDP policies operate.

2. Output indicators are used to assess the performance of planning policies. Their purpose is to measure development activity and outputs in the borough that are related to, and are a consequence of, the implementation of planning policies.

The Council are required to monitor a set of nine core output indicators set by the Department for Communities and Local Government (DCLG) to allow for the consistent monitoring of particular policy outcomes. This enables comparison between boroughs and also collation to arrive at figures for sub-regional and London- wide levels.

Local output indicators are any other indicators that the Council chooses to measure the performance of UDP policies against their objectives, and have been assessed through analysis of planning decisions, planning appeals and development monitoring.

3. Significant effects indicators measure the effects of implementing UDP objectives on the social, economical and environmental sustainability objectives set out in the Council’s Sustainability Appraisal Scoping Report 2005.

4.2 Each type of indicator plays a specific role in different stages of the plan making process. Contextual indicators are intended to enhance understanding of the wider context for the development of spatial planning policies. Output indicators inform policy progress and achievement. Significant effects indicators inform monitoring of the impact of planning policies on sustainability.

4.3 The group of indicators set out above have been used to monitor the performance and effects of the policies in Hounslow’s Unitary Development Plan (UDP). The UDP adopted in December 2003 was saved for a three year period from the commencement of the Planning and Compulsory Purchase Act in September 2004 to allow local planning authorities a period of time to replace their existing development plans with local development documents. However, as the majority of local planning authorities did not achieve this by September 2007, the Government has required all local planning authorities to undertake a review of its development plan policies to assess their conformity with national and regional guidance, and as a consequence a number of UDP policies were not saved beyond 28th September 2007. As the review in this AMR only looks at the use of policies up until the 31st March 2007 includes all UDP policies, not just the ones saved beyond September.

4.4 The findings from each type of indicator have been structured and presented in the AMR on a thematic basis by each UDP topic e.g. Housing, Employment, Shopping etc and within each topic, by UDP objective. The findings are supported by data and commentaries as necessary. If there were no relevant core, local or significant effects indicators available for monitoring a particular objective, it has not been included in the report.

23 5. DATA COLLECTION

5.1 With the increased emphasis on monitoring within the LDF process, a number of measures have been implemented by the Council’s Strategic Planning Policy team to improve the scope and quality of data available to assess the Council’s performance. The three key methods of data collection are outlined below.

Development Monitoring 5.2 The London Development Database (LDD) allows for the storage and retrieval of information, to agreed criteria, on planning permissions, starts and completions throughout London.

5.3 The monitoring system depends upon the Council’s Strategic Planning Policy team providing up to date information on planning permissions, starts and completions, which meet the following criteria:

Classes A1 – A5 ) Classes B1-B2 & B8 ) Proposes 500 m2 or more Class C2 Other ) of gross floorspace in one Classes D1 – D2 ) or more of these categories No specified class (Sui Generis) )

Class C1 ) Proposes 10 or more Class C2 Residential Homes ) bedrooms in one of these No specified class (SG Hostels) ) categories

Class C3 ) Proposes a loss or gain of 1 or more residential units or no net gain but new units built

Open Space Proposes a loss or gain of Site area or a change of use

Planning Decisions 5.5 A report was produced from the Council’s ‘Planning’ database to identify applications approved/refused during the financial year, and when a decision notice made reference to specific UDP policies.

5.6 More detailed information was then obtained from the committee report and planning file. This analysis enabled consideration of: • Whether UDP targets were being achieved through planning decisions. • Exceptional circumstances where the Council have approved proposals where a UDP target was not met.

5.7 The data extracted and presented in the AMR varies according to the indicator and target. Tables are presented in the appendices to show the proposals approved/refused, and where applicable, the issues or circumstances where a UDP target was not met are summarised. Despite every effort to ensure the information is accurate, it is important to note that there may be some errors or omissions to the information provided due to errors in data entry and retrieval.

Planning Appeals 5.9 A database has been created (see Figure 3 for sample page) to monitor planning appeal decisions for each financial year. Appeal statements from the Planning Inspectorate are recorded onto the database.

Figure 3: Sample page from the AMR Appeals Database

5.10 Information recorded includes details of the appeal and the issues raised by the planning inspectors. Each issue is identified in the planning statement is recorded by the most relevant UDP chapter and policy. The issue is also defined as either one of interpretation of policy or a judgement of the issue as summarised below:

5.11 Interpretation of policy - There are instances where the issue considered by the inspector is the appropriate weight given to a specific policy or Supplementary Planning Guidance (SPG), or the way in which the policy has been interpreted or used by the Council. There are examples of appeals where the inspector disagrees with the approach taken by the Council. In such cases it will be necessary to reconsider both the specific wording and meaning of the policy and if it is being used as intended.

5.12 Judgement of the issue - Other issues arise in appeals over the subjective assessment of impact, and differences in the interpretation of impacts on amenity, highway safety, and character of an area as examples. Whilst there is a policy on which the assessment is made, it is a judgement of the planning officer based on the information available. Such examples are important to consider in improving best practice.

25 5.13 Reports are then produced from the database and a summary is prepared of the issues arising in implementation of UDP policies.

5.14 Whilst the Council’s database enables monitoring of appeal decisions, there are limitations including the extent of the work to identify issues in appeal decisions.

26 6. HOUSING

CONTEXTUAL INDICATORS

Housing Stock 6.1 The Housing Investment Programme Report (April 2004) shows that the total number of dwellings in the Borough was 89,169, an increase of 1,609 since 2001/02. At the time of the 2001 Census, the proportion of the total dwelling stock provided as houses was 62%, of which semi-detached was the most common form. 38% of dwellings were provided as purpose built flats or maisonettes.

Housing Tenure 6.2 The proportion of owner-occupier households in the Borough is higher than the London average (61% compared to 57%) but lower than the average for outer London boroughs of 68%. The proportion of households renting from the Council (17.1%) is in line with the London-wide average (17.2%) but nearly 6% above the outer London average of 11.6%. The number of households renting privately in Hounslow is 15.9%, which is below the London average of 17.3%, but higher than the outer London average of 13.9%.

Household Size 6.3 The average household size in the Borough of 2.51 is greater than the London wide average of 2.35 persons per household. The average number of rooms per household in the Borough is 4.73, lower than the averages for outer London (4.99) and England and Wales (5.34).

House Prices 6.4 The average price of all properties in the Borough for the period October to December 2006 was £288,768, which represents a 10.7% increase on the same period last year. Although the average house price in Hounslow remains below the London average, the percentage increase in the Borough was significantly above the national average.

27 OUTPUT INDICATORS

UDP Objective H.1

6.5 To ensure the provision of a minimum net additional 6,100 completed dwellings between 1992 and 2006 and 8,250 between 1997 and 2016, representing the Borough’s contribution to RPG 9’s annual target of 23,000 dwellings in London, whilst taking account of any future requirements contained within the Mayor’s spatial development Strategy. New housing should be appropriately located in relation to employment opportunities, community, social and leisure uses, to shops and to transport facilities.

6.6 The London Plan and Early Alterations to the London Plan have since superseded Objective H.1 setting a minimum housing target for the Borough of 470 units per annum for 2006/07. This target will decrease to 445 units per annum from 2007/08 until 2016/17.

Core Indicator(s)

2a Housing Trajectory

6.7 Table 1 and Figure 3 below present a summary of the net additional dwellings completed in the last seven years, including the 2006/07 financial year, as well as projected net additional dwellings1 to 2016/17 to reflect the time period of the additional homes target set out in Table 3A.1 of the London Plan. The annual dwelling requirement of 470 for 1997-2006/07 is from the London Plan Table 3A.1. The annual requirement from 2006/07 to 2016/17 of 445 is taken from the London Plan First Alterations.

6.8 Figure 4 on page 29 shows the London Borough of Hounslow Housing trajectory for 2006/07. The graph has been prepared on the basis of criteria (i) - (v) of Core Output Indicator 2a and guidance from the Government Office for London to Local Planning Authorities on Housing Trajectories.

6.9 In calculating the housing pipeline (projected net additional dwellings) for the period 2008/07 to 2016/17 the following sources have been used -

a. unimplemented permissions b. permissions started and under construction c. approvals subject to S106 d. adopted allocations (UDP Proposals Sites) * e. development site allocations in the submitted Brentford Area Action Plan * f. windfall estimates including: - small site allowance of 146 units per year (London Housing Capacity Study 2005) - non-self contained units (London Housing Capacity Study 2005).

6.10 There are no dwellings projected to come forward through vacant units returning to use, as reflected in the London Housing Capacity Study 2005. However, it is considered that on the basis of adding homes provided through non-self contained units, the projected number of homes is comparable with the London Plan target.

* Information on when an adopted allocation in the UDP or proposed allocation (Proposal Sites) in the Brentford Area Action Plan is likely to come forward is not available unless

1 15% of the projected dwellings have been deducted from the total for each year, based on the assumption that 15% of the housing in the pipeline will not be built.

28 there have been discussions at a pre-application or application stage. As a part of the Core Strategy, which is at an early stage in preparation, the Council will be in contact with landowners to discuss their proposals for development of allocated sites, and possible new allocations.

6.11 It is proposed that in the future, an assessment of when a site is likely to come forward will be based on discussions with landowners and developers. For the Housing trajectory presented for the AMR 2006/07, the Council has allocated potential housing coming forward on adopted or proposed housing or mixed use proposal sites to one of two phases (the first phase to the end of 2011/12, the second phase from the beginning of 2012/13 to 2016/17). The phasing reflects the approach in the London Housing Capacity Study 2005.

6.12 Phase 1 includes • Units approved, but which have not been implemented • Units under construction or not started on sites under development • Units approved subject to the signing of a legal agreement • Potential units on adopted (UDP) or submitted (BAAP) housing and mixed-use allocation sites, for which there is a current application, application expected or where there has been developer interest. Where there is a current application, application expected or where there has been interest on a part of a large mixed use or housing proposals Site (more than 5 hectares), the potential housing on the site has been split between Phases 1 and 2.

6.13 Phase 2 includes • Potential units on adopted (UDP) or submitted (BAAP) housing and mixed-use allocation sites where there has been no interest to date incl. parts of a large site (more than 5 hectares).

6.14 As is evident from past trends, not all pipeline development is implemented. To reflect this, 15% of the projected dwellings in each year from 2007/08 to 2016/17 have been subtracted from the total projected homes for the particular year.

Potential dwellings on allocation sites (Proposal Sites)

6.15 Where an allocation or proposal site adopted in the UDP or proposed in the BAAP has not been developed for the proposed use, an assessment has been made on the proportion of the site that may be developed for residential based on the proposals site description (For the purpose of calculating total projected dwellings and not appropriate for considering in assessment of a planning application).

6.16 For a housing proposals site, the proportion calculated has been 100%, whereas for mixed-use sites a proportion of the site’s area has been used for calculations. Upon arriving at a net figure for the area of each housing and mixed-use proposals site, the mid point in the appropriate range (subject to its location and setting) of Table 4B.1 Density Location and parking matrix in the London Plan is used to calculate the potential dwellings on the site.

6.17 Table 2 and Figure 4 below present the total net additional dwellings completed in each of the last seven years including the current year (2006/07) and the projected net additional dwellings for each year from 2007/08 to 2016/17.

29 Table 2: Number of net additional dwellings completed from 2000 to 2005/06, and projected from 2006/07 to 2016/17

Year Completed Projected 2000 487 2001 399 2002 572 2003 850 2004/05 570 2005/06 481 (1015) 2006/07 14322 (1505) 2007/08 1240 2008/09 1240 2009/10 1240 2010/11 1240 2011/12 1240 2012/13 555 2013/14 555 2014/15 555 2015/16 555 2016/17 555

2 This total excludes the completion of 843 (net) non-self contained units and 313 non-local authority owned vacant dwellings returned to occupation or demolished during the financial year as a direct result of action by the local authority (BVPI 64). Both these figures are included in the London Plan’s annual monitor of additional homes, which would give the Borough a total of 2,588 additional homes for the 2006/07 financial year, which is 5.5 times the Borough’s annual target.

30 Figure 4: London Borough of Hounslow Housing Trajectory 2006/07

31 UDP Objective H.2

To promote the provision of affordable housing by the Council, the private sector and Registered Social Landlords, using partnership arrangements and legal agreements where necessary.

Core Indicator(s)

2d Affordable Housing Completions

6.18 The London Plan sets the strategic target for the completion of 50% of new homes as affordable each year, from 2004 to 2016, and within that, a London-wide objective of 70% social housing and 30% intermediate provision3. Hounslow’s UDP (policy H.2.1) also sets a target of 50% of all housing completions as affordable. All housing developments in the Borough capable of providing 20 or more residential units or sites of 0.75 hectare or above should make provision for on site affordable housing.

6.19 Table 3 shows the gross and net number of additional affordable dwellings completed in the 2006/07 financial year. Of the 1,432 net additional housing completions 633 (44.2%) were affordable comprising 27.8% intermediate (63% of affordable only completions) and 16.3% socially rented units (37% of affordable only completions).

6.20 Although the outturn of 44.2% affordable dwellings is below the Borough and London wide target of 50% it shows a significant improvement on the previous year when the proportion of affordable housing was only 24.7%.

6.21 There are a number of ongoing reasons the Council may not achieve the target of 50% affordable housing, as a proportion of net additional housing completions: • The target of 50% only applies to proposals that meet the thresholds for affordable housing (Housing developments capable of providing 20 or more dwellings and/or residential sites of 0.75 ha or more). Completions on sites where less than 20 units are proposed may not include any affordable housing and therefore do not contribute to the affordable housing completed as a proportion of total dwellings. • Historic permissions being implemented now, which were approved under a former version of the UDP with a lower affordable housing target • To achieve a higher proportion of large family units, schemes are measured against the percentage of habitable rooms provided as affordable accommodation (see paragraph 6.25) • Site specific circumstances including issues of viability that make achieving 50% affordable housing unrealistic.

6.22 It is expected in the future that the proportion of affordable housing will continue to increase to reflect the current London Plan and UDP targets.

3 Social housing is housing provided by a landlord where access is on the basis of housing need, and rents are no higher than target rents set by the Government for housing association and local authority rents. In order to enable the provision of social housing, the Council seek to make available an element of public subsidy i.e. Social Housing Grant. Intermediate housing is sub- market housing, which is above target rents, but substantially below open market levels. This category can include shared ownership, sub-market rent provision and key worker housing.

32 Table 3: Affordable Housing Completions 2006/07

Affordable Private Total Gross Net Gross Net Gross Net TOTAL 704 633 825 799 1529 1432

6.23 The tenure split of affordable units is 63% intermediate and 37% social rented which does not reflect the strategic of 30% and 70% respectively. However, a large number of this year’s completions were within a high-density scheme in Feltham town centre which has provided a significant amount of key worker housing.

Local Indicator(s)

UDP Policy H.2.1 Affordable Housing

Purpose: Secure the highest achievable provision of affordable housing for households in local housing need. The Council will negotiate the provision of up to half of all new housing as affordable dwellings on suitable residential sites taking into account the suitability of the site, the economics of provisions and the need to achieve a successful housing development.

A. Use of Policy H.2.1 in Planning Decisions and Appeal Decisions

Planning Decisions Appeal Decisions Approved Refused Allowed Dismissed 6 2 1 2

B. Policy Outcomes

Target: All sites capable of providing 20 or more dwellings and/or residential sites of 0.75 hectare or more should make provision for affordable housing, with an overall aim of achieving 50% of new housing as affordable. The Mayor of London has also adopted a strategic target that 50% of all additional housing should be affordable, and within that, a London-wide objective of 70% social housing and 30% intermediate provision.

Indicator 1: Number and percentage of affordable dwellings approvals for 20 or more residential dwellings.

Outcome 6.24 Table 4 below shows that the gross provision of affordable housing in approved developments proposing 20 or more residential units is 666. This represents 44% of gross units in schemes above the 20-unit threshold, which is below the Borough’s target of 50% and lower than the outcome of the previous financial year when gross provision was 53.8%.

6.25 Table 4 shows that there were four approvals in the financial year where less than 50% affordable housing is provided. The Brunel University proposal (Planning ref: 00131/A/P58) whilst only including 43% affordable housing, the provision was considered to directly respond to the housing needs of the residents given the large proportion of family-size units provided as affordable housing. The percentage of affordable housing provided as habitable rooms is 50% and 60% of the units will be provided as social rented accommodation. In addition, 10% of the units, all of which are three-bed, are designed to provide full wheelchair accessibility and use.

6.26 The second permission where less than 50% affordable housing is provided was the Wallis House site (Planning ref: 00505/P/P59). In the scheme originally submitted the great majority of the affordable accommodation would have been one-bedroom units. The revised scheme responded more appropriately to the Borough’s housing needs. Sixty-two per cent of the affordable accommodation provided is two-bedroom units and 15% is three-bedroom. Of the three-bed units, more than half would have their own front doors and gardens (ground floor maisonettes) and none of the remainder would be above the third floor.

6.27 On the site of 455 London Road (Planning Ref: 00707/455/P55) the original scheme provided 36% of units as affordable. The revised scheme provided 39% of units as affordable, however affordable housing measured as a percentage of habitable rooms was 50%, which is normally the minimum level that the Council would expect on a former employment site such as this. The scheme also provided a large number of family dwelling houses which meets an identified need and target within the Borough. From the entire development the affordable provision would consist of 32% of the two bed units and 100% of three and four bed units. The Housing Strategy team were very supportive of this scheme as it helps meet the Borough’s need for larger units.

6.28 The Council sought the maximum possible level of affordable housing on the former employment site of 26 Glenhurst Road (Planning Ref: 00485/26/P2) in accordance with UDP Policy H.2.1. Following discussions with council officers, the applicant raised the level of provision from 40% to almost 50%, a figure corresponding more closely to the Council’s overall target.

6.29 The remaining four permissions all proposed 100% affordable housing.

Table 4: Permissions for developments proposing more than 20 residential units in 2006/07

Provision of Proposed Total Percentage Met UDP Total Affordable on site Borough Reference Address Residential of Affordable Target of Units Affordable Units Housing 50% Housing

Granted Full Planning Permission Brunel University, Osterley Campus, 00131/A/P58 Borough Road, 366 156 Yes 43% No Isleworth

Wallis House, Great 00505/P/P59 West Road, 755 243 Yes 32% No Brentford

26 Glenhurst Road 00485/26/P2 Brentford, London 41 20 Yes 48.8% No TW8 9BY

455 London Road, 00707/455/P55 Isleworth 174 68 Yes 39% No 137 Hatton Road 00576/137/P20 Feltham, London 35 35 Yes 100% Yes TW14 8LR

The Heath Business Centre, Heath Road Hounslow, London 00586/H/P1 43 43 Yes 100% Yes TW3 2NF

Approved Subject to Satisfactory Completion of Legal Agreement

34 101 New Heston 00798/101/P7 Road, Heston 28 28 Yes 100% Yes 01253/P/P2 Victoria Works, Victoria Road, 73 73 Yes 100% Yes Feltham

Totals 1515 666 43.9%

Indicator 2: Types and size of affordable housing units in residential schemes of over 20 units granted planning permission in 2006/07. The current need for ‘social housing’ is mainly for larger dwellings.

Outcome 6.30 Table 5, taken from the Council’s Housing Investment Programme 2003-2006, shows that 5% of the units should be one bed units, 40% two bed units (to be mainly for four person households) 40% three bed units (for a minimum of five persons and preferably six persons) and 15% 4 bed units (for at least 7 person households). For below market housing 20% should be one bed units, 50% two bed units and 30% three bed units. These proportions form the basis of negotiation with the applicant. However, the Council will negotiate different proportions of social rented and intermediate housing having regard to the existing proportion of social rented provision in an area, the overall amount of affordable housing proposed, the suitability of the site and location for family housing, individual site costs, the availability of public subsidy and other planning requirements.

Table 5: Affordable Housing Need in the Borough

Social Rented Intermediate Size of Dwelling Need Need 1 bedroom 5% 20% 2 bedrooms 40% 50% 3 bedrooms 40% 30% 4 bedrooms + 15%

6.31 Table 6 shows all but one of these approved schemes propose a range of affordable housing units either in terms of the size of units and/or tenure type. The proposal at 26 Glenhurst Road, Brentford (Planning ref: 00485/26/P2) provides solely two bedroom units as affordable housing. However, the Council’s Housing Strategy team recognised that larger family units were not suitable for this site given that refurbishment of the site is constrained by the existing building and has limited amenity space. Moreover, in light of the sites location next to the A4/M4 and the relatively hostile environment the provision of family accommodation was considered inappropriate.

6.32 In terms of unit size, Table 7 shows that the majority 78.4% of affordable housing will be provided as family accommodation (two or more bedspaces). The proportion of affordable housing provided as three bedrooms or more was 43.8% of the social housing provision compared to 16.2% in the previous financial year. This significant shift exceeds the target set out in The Hounslow Plan for 35% of new social rented dwellings in the Borough to be 3-bedroom plus houses. The overall split in terms of tenure in the approved schemes is 54.5% social housing and 45.5% intermediate provision.

35 Table 6: Summary of type and size of affordable housing units in residential schemes of over 20 units granted planning permission in 2006/07

Total Tenure 1 bed 2 bed 3 bed 4+ bed Total Percentage %

Social Rented 45 159 121 38 363 54.5 Percentage (%) 12.4 43.8 33.3 10.5 Intermediate 99 197 7 0 303 45.5 Percentage (%) 32.7 65 2.3 0 Total 144 356 128 38 666 Total Percentage 21.6 53.5 19.2 5.7 (%)

Table 7: Type and size of affordable housing units in residential schemes of over 20 units granted planning permission in 2006/07

Total Borough Number of Affordable Total Number Address Unit Type Tenure Type Affordable Reference Bedrooms Units of Units Units Granted full Planning Permission 1 Flat or Maisonette Intermediate 35

1 Flat or Maisonette Social Rented 17 Brunel University, Osterley 2 Flat or Maisonette Intermediate 24 00131/A/P58 Campus, 2 Flat or Maisonette Social Rented 29 156 366 Borough Road, Isleworth 3 Flat or Maisonette Intermediate 4 3 Flat or Maisonette Social Rented 37 4 Flat or Maisonette Social Rented 10 1 Flat or Maisonette Intermediate 38

Wallis House, 1 Flat or Maisonette Social Rented 18 00505/P/P59 Great West 2 Flat or Maisonette Intermediate 85 243 755 Road, Brentford 2 Flat or Maisonette Social Rented 65 3 Flat or Maisonette Social Rented 37 26 Glenhurst Road 00485/26/P2 Brentford, 2 Flat or Maisonette Social Rented 20 20 41 London TW8 9BY 2 Flat or Maisonette Intermediate 36 455 London 00707/455/P55 3 Flat or Maisonette Social Rented 5 68 174 Road, Isleworth 4 House or Bungalow Social Rented 27 1 Flat or Maisonette Intermediate 6

137 Hatton Road 1 Flat or Maisonette Social Rented 5 00576/137/P20 Feltham, London 2 Flat or Maisonette Intermediate 8 35 35 TW14 8LR 2 Flat or Maisonette Social Rented 5 3 Flat or Maisonette Social Rented 11 1 Flat or Maisonette Intermediate 6 The Heath 1 Flat or Maisonette Social Rented 1 Business Centre, Heath Road 2 Flat or Maisonette Intermediate 19 00586/H/P1 43 43 Hounslow, 2 Flat or Maisonette Social Rented 8 London TW3 2NF 3 House or Bungalow Social Rented 8 4 House or Bungalow Social Rented 1 Approved Subject to Satisfactory Completion of Legal Agreement

36 3 House or Bungalow Social Rented 3 1 Flat or Maisonette Intermediate 8 101 New Heston 00798/101/P7 28 28 Road, Heston 2 Flat or Maisonette Intermediate 10 2 Flat or Maisonette Social Rented 2 3 Flat or Maisonette Social Rented 5 1 Flat or Maisonette Intermediate 6 1 Flat or Maisonette Social Rented 4 Victoria Works, 2 Flat or Maisonette Intermediate 15 01253/P/P2 Victoria Road, 73 73 Feltham 2 Flat or Maisonette Social Rented 30 3 Flat or Maisonette Intermediate 3 3 Flat or Maisonette Social Rented 15 Totals 666 666 1515

Indicator 3: Use of policy H.2.1 as reason for refusing planning permission (see Appendix 1)

Outcome 6.33 There have been two refusals quoting policy H.2.1 during the 2006/07 financial year. Table 8 shows that both schemes were for the same site and that they each proposed an element of affordable housing. However, the proportion and mix of affordable housing proposed was not considered suitable and was given as a reason for refusal.

6.34 The Council’s decision to refuse the schemes for 391-407 Chiswick High Road (Planning ref: 00248/BX/P3 and 00248/BX/P4) was appealed by the applicant and subsequently dismissed by the Planning Inspectorate. In the first appeal (relating to Planning ref: 00248/BX/P3) the inspector reasoned on the basis of the appellant’s viability appraisal that the proposal did not make the highest reasonable provision in terms of the quantum of affordable housing. In addition, the inspector considered that neither scheme would ensure a contribution towards meeting the need for social rented housing.

Table 8: Percentage of Affordable Housing in proposals quoting H.2.1 as a reason for refusal

Planning Ref Address Proposal Total Number Total Number Percentage of Proposed of Affordable of Affordable Units Units

00248/BX/P3 391-407 Chiswick Erection of 4-7 storey block of 66 91 25 27.5 High Road Chiswick residential units (2 x 3-bed, 29 x 2- London W4 4AR bed and 35 x 1-bed flats) on vacant land to the east of Chaseley Court and the timber yard land at the rear of 391-407 Chiswick High Road. Erection of a 4 storey rear extension to 391-397 Chiswick High Road and conversion of existing upper floor flats to create 25 residential units (7 x 1 bed flats and 18 studios) for affordable housing on the 2nd - 4th storeys, and extension to Nos. 391 and 395 and alteration to the ground floor shop units.

37 00248/BX/P4 391-407 Chiswick Erection of 6 storey block of 55 74 19 25.7 High Road Chiswick residential units (7x 3-bed, 23 x 2- London W4 4AR bed and 25 x 1- bed flats) with amenity space, on vacant land to the east of Chaseley Court and the timber yard land at the rear of 391- 407 Chiswick High Road. Erection of 4-storey rear extension to 391- 397 Chiswick High Road and 2nd floor extension to No 399 and conversion of existing upper floor flats to create 19 residential units (7 x1 bed flats, 6 x 2-bed flats and 6 studios) for affordable housing on the 2nd - 4th storeys, and extension to No 397 and alteration to the ground floor shop units.

Indicator 4: Appeals quoting policy H.2.1 (see Appendix 2).

Outcome 6.35 There were three appeals during the 2006/07 financial year quoting policy H.2.1. Of these, two were dismissed and one was allowed.

6.36 In the first dismissed appeal at Gable House, 20-28 Turnham Green Terrace (Planning ref: 00135/20-28/P11) the inspector found that the level of affordable housing was less that the 50% sought in the development plan. Even based on habitable rooms the amount of affordable units proposed would fall short of the target of 50% of affordable units advocated in the development plan. The inspector did not consider that the practicalities of a mix of affordable and private market housing on one floor were insurmountable. Therefore the circumstances put forward by the appellant did not justify a reduction in the amount of affordable accommodation.

6.37 The other dismissed appeal concerned an outline application at 83-93 Staines Road (Planning Ref: 01054/83-93/P12). Whilst the inspector did not agree with the Council that the type of accommodation failed to meet the overall housing need in the Borough they did agree that insufficient justification had been given for the proposed quantity of affordable housing (40%) which falls below the Council's 50% target.

6.38 The appeal allowed was for a change of use on the site of the former Metropolitan Police Training Centre, Vickers Way (Planning ref: 01618/A/P6). Although affordable housing was not the key issue in this appeal, the inspector agreed with the council that the proposed affordable housing would be an acceptable alternative use to the Health Centre and that it would be consistent with the aims of UDP Policy H.2.1 which seeks to secure the highest achievable provision of affordable housing on every suitable site.

Significant Effects

Sustainability Objective 3: To ensure that everyone has the opportunity to live in a decent, sustainably constructed and affordable home.

Indicator: Difficulty of access to owner-occupation. This is an indicator score, which gives measure of access to affordable housing based on house prices and income/earnings.

Outcome

38 6.39 The estimated proportion of households unable to afford to enter owner-occupation on the basis of their incomes was 84.4% in January 2006. This represents a significant increase from the January 2004 outturn of 69.52% (Source: Neighbourhood Statistics, 2007)

UDP Objective H.3

To resist the loss of land or buildings in or designated for residential use and maximise efficient use of existing housing stock.

Local Indicator(s)

UDP Policy H.3.1 Presumption Against the Loss of Residential

Purpose: Maintain existing stock of housing and conserve the potential for future housing development.

A. Use of Policy H.3.1 in Planning Decisions and Appeal Decisions

Planning Decisions Appeal Decisions Approved Refused Allowed Dismissed 5 7 0 0

B. Policy Outcomes

Target: No net loss of residential, or part residential, land or accommodation to other uses.

Indicator 1: Net change in existing housing stock

Outcome 6.40 There was a net increase of 1,4324 residential units in the Borough during 2006/07 compared to the existing London Plan annual monitoring target of 470 (Table 3A.1, p56).

Indicator 2: Approvals resulting in a net loss of residential (see Appendix 3).

Outcome 6.41 Approval was granted for three development proposals that would result in a net loss of residential units.

6.42 The application at 138 The Crossways, Heston (Planning ref: 00329/138/P4) for the continued use of the 1st and 2nd floors as offices was refused by the Council and taken to appeal by the applicant. The inspector found that the appeal scheme met the criteria as an exception to UDP policy H.3.3 which allows for the loss of residential use of upper floors above shops in special circumstances. While the inspector acknowledged that the exception to UDP policy H.3.3 and UDP policy H.3.1 pull in different directions, he

4 This total excludes the completion of 843 (net) non-self contained units and 313 non-local authority owned vacant dwellings returned to occupation or demolished during the financial year as a direct result of action by the local authority (BVPI 64). Both these figures are included in the London Plan’s annual monitor of additional homes, which would give the Borough a total of 2,588 additional homes for the 2006/07 financial year, which is 5.5 times the Borough’s annual target.

39 considered that policy H.3.3 should prevail as it specifically deals with the use of upper floors above shops.

6.43 Two proposals resulted in a net loss of residential units following the conversion of existing separate residential units into larger family accommodation. At 56 Hanworth Road, Feltham (Planning ref: 00553/56/P2) the Council noted that the proposal to convert the ground and 1st floor flats to a 4-bedroom house provided the desired type of family accommodation within an established residential area. On the site of 148 Chiswick High Road (Planning ref: 00248/148/P9) the Council considered that the proposal to convert three bedsits and a 1-bedroom flat into a single three bedroom flat would not harm the character of the building and would result in a more effective and clear use of the upper floors of the building.

Indicator 3: Refusals quoting policy H.3.1 (see Appendix 4).

Outcome 6.44 During the 2006/07 financial year there were seven refusals of planning permission citing policy H.3.1.

6.45 Two of the proposals related to the continued use of 74 Kingsley Road, Hounslow as an estate agent (Planning refs: 00667/74/P1 and 00667/74/P2). The proposal was refused as it resulted in a reduction of the quality of residential accommodation at the property through the loss of living space and unsuitable access arrangements.

6.46 The proposal to retain two self-contained flats at 222 Kingsley Road, Hounslow (Planning ref: 00667/222/P2) was refused on the basis that it resulted in the unacceptable loss of a family dwelling house, inappropriate for sub-division and as a result has led to the creation of flats with poor internal amenity for current and future occupants.

6.47 Two of the applications at 309 Hatton Road, Feltham (Planning Ref: 00576/309/P4) and 9 Gresham Road, Hounslow (Planning ref: 00519/9/P11) related to a change of use from residential dwellings to a children’s nursery and to a care home respectively. Both applications were refused as they would result in the loss of small family houses for which there is a known need. The conversion of an existing house to three self-contained flats at 6 Bulstrode Avenue, Hounslow (Planning ref: 00170/6/P2) was considered unacceptable for the same reason.

6.48 The outline application for the demolition of two family homes and the erection of a building to provide nursing home accommodation at 133-141 Vicarage Farm Road, Hounslow (Planning ref: 01151/AC/P1) was also considered unacceptable. While the nursing home facility would mean the land would be retained in residential use, there would be a loss in the number of family sized homes and the applicant failed to provide sufficient evidence that there is a need for additional nursing home beds in the Borough.

UDP Policy H.3.4A Houses in Multiple Occupation

Purpose: To protect residential properties in multiple occupation which meet a known and established need for such accommodation, so long as the property provides or is capable of providing a reasonable standard of accommodation.

A. Use of Policy H.3.4A in Planning Decisions and Appeal Decisions

Planning Decisions Appeal Decisions Approved Refused Allowed Dismissed

40 0 1 1 0

B. Policy Outcomes

Target: Retain such accommodation where it meets a known and established need.

Indicator 1: Decisions quoting policy H.3.4A (see Appendix 5).

Outcome 6.49 There was one decision on an application concerning houses in multiple occupation (HMOs). The application at 7 Sutton Dene, Hounslow (Planning Ref: 01092/7/P1) for continued use of the premise for temporary residential accommodation for up to six homeless persons was recommended for approval but refused by members on the basis that the premises were poorly managed and that neighbours’ living conditions were harmed. The loss of a family house for which there is an identified need in the Borough was also highlighted. On appeal the inspector considered that the need for such accommodation outweighs the loss of single family accommodation. In response to concerns raised over the impact on living conditions of neighbouring residents, the inspector considered that the continued use would not amount to a material change in the character of the premises from that of a residential use. Furthermore the inspector noted that the Council’s Homeless Person Unit had confirmed that the property is run to a particularly high standard.

Indicator 2: Appeals quoting policy H.3.4A (see Appendix 6)

Outcome 6.50 There was one appeal quoting policy H.3.4A and this was allowed. The appeal concerned the continued use of 44 Basildene Road as a HMO for a maximum of 6 homeless people (Planning Ref 0081/44/P2). The inspector concluded that the development would not significantly harm the character of the area or the living conditions of neighbouring residents. The proposal met an established need and the inspector was not convinced that the conversion of one dwelling unit would materially prejudice the overall supply of family housing in the residential area.

UDP Policy H.3.4 Conversions of Houses to Flats

Purpose: Retain a balance between houses and converted properties to ensure an adequate stock of family accommodation and to safeguard the character of established residential areas.

A. Use of Policy H.3.4 in Planning Decisions and Appeal Decisions

Planning Decisions Appeal Decisions Approved Refused Allowed Dismissed 7 26 2 2

B. Policy Outcomes

Target: To resist the sub-division of small houses suitable for single-family occupation unless in accordance with policy.

Indicator 1: Approvals and refusals for the conversion of house to flats (see Appendix 7).

41 Outcome 6.51 There were a total of 33 proposals for the conversion of houses to flats quoting policy H.3.4 of which seven were approved and 26 refused. All of the approved applications comply with the criteria set out in policy H.3.4 including the provision of at least one family sized unit (3 bed spaces), internal and amenity space provision, in keeping with the character and appearance of the property, and no undue loss of neighbouring amenity.

6.52 However, the majority of applications for conversions were refused as they would have led to the loss of a small house suitable for single-family occupation, or because the converted dwellings would have low amenity value and provide an unsatisfactory standard of accommodation.

6.53 Although there were a further three proposals which quoted policy H.3.4 none of these proposals actually involved the conversion of houses to flats. Two of these relate to a property at 416 Staines Road, Feltham (Planning refs: 01054/416/P5 and 01054/416/P6) where the proposals involved the conversion and extension of an existing flat to provide additional bedrooms. At 871 Great West Road, Hounslow (Planning ref: 00505/871/P3) the proposal concerned the erection of two-storey side extension to the existing house resulting in a separate dwellinghouse.

Indicator 2: Appeals quoting policy H.3.4 (see Appendix 8)

Outcome 6.54 There were four appeals where the inspector considered the suitability of conversion to flats, two of which were dismissed. In the first dismissed appeal at 7 Beeston Way, Feltham (Planning ref: 00101/7/P3) the inspector found that proposal failed to meet three of the criteria set out in the policy, namely, an original net internal floor area of 120 square metres; provision of at least one family-sized unit; and that the converted property should meet the Council’s guidelines for amenity space and minimum room sizes. The inspector also acknowledged the Council’s need to protect family sized houses in an area where such accommodation is needed. This point was underlined in the second dismissed appeal where although the proposal met many of the aforementioned criteria, the inspector considered that the harm caused by the loss of a small family house was significant and overriding.

6.55 The first allowed appeal related to the conversion of 64 Eastbury Grove, Chiswick (Planning ref: 00383/64/P1). In this case the appellant suggested that if planning permission was not given he would exercise permitted development rights to erect a larger roof extension that that the subject of the appeal proposal and also a ground floor side extension. These proposed extensions were the subject of a Certificate of Lawfulness previously granted by the Council. The inspector considered that the harm that would follow from these extensions to be so great that the fallback position of conversion to flats outweighed the limited conflict with policy H.3.4.

6.56 The second allowed appeal, for the retention of the conversion to six flats at 678 Great West Road, Isleworth (Planning ref: 00505/678/P11), was permitted on the basis that it would provide satisfactory living conditions for occupiers of the flats and would not cause harm to neighbouring occupiers. In this instance the loss of a family dwelling was not considered the main issue.

42 UDP Objective H.4

To allow for new housing development within existing residential areas and on suitable brownfield sites close to facilities and which are capable of being served by good public transport and to encourage housing in mixed-use developments.

Core Indicator(s)

2b Percentage of new and converted dwellings on previously developed land

6.57 The Government’s Planning Policy Statement 3: Housing (PPS3) sets the national target that 60% of additional housing (including the conversion of existing buildings) should be provided on previously developed land. The Council’s own Best Value target for brownfield land is set annually, with the target of 90% of all new homes to be completed on previously development land in 2006/07.

6.58 The Best Value Performance Indicator (BVPI) 106 for the 2006/07 financial year shows that 93% of all new and converted dwellings in Hounslow were on previously developed land compared to 99.8% in 2005/06. This shows that Hounslow has exceeded both the national and local targets.

6.59 The decrease in the total proportion of new dwellings on brownfield land in the 2006/07 financial year is due to the completion of units within a scheme (Planning ref 00287/J/P41) on greenfield land in the Bedfont Lakes area of the Borough which was approved by the Planning Inspectorate following an appeal against refusal by the Council’s Sustainable Development Committee.

2c Percentage of new dwellings completed by density range

6.60 Density is a measure of the number of dwellings which can be accommodated with a development site. PPS3 Housing sets out an indicative minimum density range of 30 dwellings per hectare. Table 9 shows that approximately 98.1% of all residential dwellings completed in Hounslow in 2006/07 had a density range of more than 30 units per hectare. This represents a slight increase on the previous financial year’s outturn of 97.6%.

6.61 The median density for all completed dwellings in Hounslow in 2006/07 was 111 dwellings per hectare whilst the mean average density is 68 dwellings per hectare.

Table 9: Percentage of residential dwellings completed by density range

Density Range Number of Dwellings Percentage of total Completed dwellings completed Less than 30 units per hectare 13 0.85 Between 30 and 50 units per hectare 72 4.71

More than 50 units per 1428 93.39 hectare Information not 16 1.05 available

1529 100

Local Indicator(s)

UDP Policy H.4.2 Density

Purpose: This policy sets a range of densities to guide and control residential development. A minimum density is appropriate in order to ensure the best use of urban land. However, the policy does not advocate a rigid approach to residential density. It establishes a density range that is normally appropriate and provides examples of when a higher figure may be appropriate i.e. higher densities for predominantly non-family accommodation will be considered in town centre locations, areas of good public transport or in locations where there is no established residential character and the proposal conforms with criteria for housing standards and good design.

Since the UDP was adopted in December 2003 it has been joined by the London Plan, which was adopted in February 2004. Both of these documents comprise the development plan and are used to assess planning applications. The London Plan contains a Density and Location Matrix (page 177, table 4B.1) with appropriate density ranges that relate to location, setting in terms of existing building form and massing, and the index of public transport accessibility. In certain circumstances the density advocated in this matrix is higher than that in the local plan.

The Planning and Compulsory Purchase Bill ‘Part 3 –Development: Development Plan’ states ‘If to any extent a policy contained in a development plan for an area conflicts with another policy in the development plan the conflict must be resolved in favour of the policy which is contained in the last document adopted, approved or published (as the case may be).’ (Para 37(5))

As the London Plan was adopted three months after the UDP, the density standards in the London Plan take precedence. Significant weight needs to be afforded to the London Plan density matrix and the higher density figures it considers appropriate in specific circumstances and locations. Thus in an urban setting with good public transport accessibility a development for mostly flats has an appropriate density of between 450- 700 habitable rooms per hectare as contained in the London Plan. This is significantly above the suggested density within the UDP. (NB. The UDP Inspectors report recommended Policy H.4.2 be amended to be in line with the London Plan Matrix but as at the time this was only a draft document and subject to an Examination in Public the Council considered it to be premature to make such a change.)

A. Use of Policy H.4.2 in Planning Decisions and Appeal Decisions

Planning Decisions Appeal Decisions Approved Refused Allowed Dismissed 4 16 2 4

B. Policy Outcomes

Target: Individual schemes should comply with standards in policy

Indicator 1: Density of major new residential schemes granted planning permission in 2006/07 (HRHA)

Outcome

44 6.62 Table 10 shows that two out of the seven major planning permissions approved at SDC (subject to S106) in the 2006/07 financial year were within the density range specified in the UDP, and five were within the relevant London Plan range.

6.63 There were two major residential schemes at Beavers Lane, Hounslow (Planning ref: 00092/I/P2) and New Heston Road, Heston (Planning ref: 00798/101/P7) that were granted full planning permission despite exceeding both the UDP and London Plan density ranges. In both cases it was felt that the density of the proposed scheme was acceptable taking into account the character of the area and the standard of the accommodation to be provided.

Table 10: Density of major residential schemes approved at Sustainable Development Committee during the 2006/07 financial year relative to density ranges in the UDP and London Plan

SDC Planning Ref Address No of HRHA UDP Density LP Density Range Units Range Within UDP and LP range 11-Dec-06 01341/D/P2 The Garages Site, Chinchilla 16 227 150-250 200-250 Drive, Hounslow 15-Jan-07 00176/F/P4 Chiswick War Memorial Homes, 36 168 150-250 150-200 Burlington Lane, Chiswick, London W4 3EU

Above UDP range but within LP range 11-Dec-06 00083/210/P13 210 Bath Road, Hounslow 16 342 150-250 250-350

15-Jan-07 01286/H/P2 Chiswick Lodge, Chiswick Mall, 11 292 150-250 200-450 Chiswick 26-Feb-07 01253/P/P2 Victoria Works, Victoria Road, 73 559 150-250 450 – 700 Feltham Above UDP and LP Range 05-Jul-06 00092/I/P2 57, Beavers Lane and land 13 300 150-250 200-250 adjacent, Hounslow 09-Oct-06 00798/101/P7 101 New Heston 28 272 150-250 200-250 Road, Heston

Indicator 2: Refusals quoting policy H.4.2 (Appendix 9)

Outcome 6.64 During the period under consideration there were 16 refusals quoting policy H.4.2. However, a planning application cannot be refused simply because it exceeds a density range provided in a planning policy. The excessive density needs to result in ‘demonstrable harm’, for example its impact on an area’s character, and that the harm can justify refusal of permission.

6.65 In the case of all refusals there were circumstances that made the proposed density inappropriate. These included being out of keeping with the character of the surrounding area, causing unacceptable harm to the living conditions of neighbouring occupiers, lack of amenity space, failure to meet internal space standards for new residential developments and inadequate parking.

Indicator 3: Appeals decisions quoting policy H.4.2 (see Appendix 10)

45 Outcome 6.66 There were six appeal decisions quoting policy H.4.2 of which two were allowed and four were dismissed.

6.67 The first appeal allowed related to alterations to the listed Waverley House to create 14 residential units (Planning ref: 00715/10/P3). The inspector accepted that the density of the scheme would be both higher than the level set out by policy H.4.2 of the UDP and the relevant London Plan density range. However he underlined that policy H.4.2 also notes that density will be of secondary importance after taking account of the individual requirements of each site and the merits of each scheme. To this end he rejected the council’s assertion of overdevelopment and concluded that the density would not result in unacceptable harm to future or neighbouring occupiers.

6.68 The other proposal to be allowed was for 19 units at 210 Bath Road (Planning ref: 00083/210/P12). Although the density exceeded the UDP range and that suggested for suburban areas in the London Plan, the inspector considered that the site was in fact somewhere between urban and suburban in nature. With this in mind the density proposed would be at the lower end of the density range set out in the London Plan. The inspector also took into consideration that policy H.4.2 allows for higher densities for non- family accommodation in areas of good public transport accessibility and that this policy also recognises that the stated density figures may not be appropriate for corner sites in which case proposals should be considered on their own merits. It was the inspector’s opinion that the ‘above average’ level of public transport accessibility (PTAL rating of 4) created an appropriate location for higher density development.

6.69 Density was not the main determining factor in two of the appeals that were dismissed. The density of the proposal for 36 flats at 83-93 Staines Road (Planning ref:01054/83- 93/P12) was considered acceptable as the site was within a town centre and near to pubic transport. However the inspector found that both the design and layout of the proposed development as well as the inadequate floor areas failed to accord with the Council’s standards. In respect of the proposal for 86 houses and flats at the former Metropolitan Training Centre, Vickers Way (Planning ref: 01618/A/P4) the inspector stated that the proposed density fell with the range set in UDP policy H.4.2 but failed to provide adequate and appropriate private open space contrary to UDP policy H.4.1.

6.70 In both the other two dismissed appeals the proposed density was a significant factor. At Spring Grove Court, Isleworth, (Planning ref: 01048/H/P1) the inspector considered that the proposal for 2 flats in a backland location would result in a density considerably in excess of the typical density of neighbouring dwellings. He stated that the proposed development’s adverse effects on the character and appearance of the area and neighbouring living conditions outweighed any benefits in terms of additional residential units. In respect of the proposal for 12 houses and 40 flats at Elmwood Avenue, Feltham (Planning Ref: 00403/V/P4), the inspector concluded that the site would be over- developed and in particular, that there would be inadequate open amenity space for the occupiers of the proposed houses.

UDP Policy H.4.3 Residential Mix

Purpose: To encourage the provision of a range of housing to meet the needs of a diverse workforce and population and create genuine mixed communities. The priority need in Hounslow is for larger family sized dwellings.

A. Use of Policy H.4.3 in Planning Decisions and Appeal Decisions

46 Planning Decisions Appeal Decisions Approved Refused Allowed Dismissed 2 0 0 0

Target: In schemes of 20 or more units there should normally be a mix of family (3 or more bedspace units – one double bedroom and a single bedroom) and non-family units. The priority need in Hounslow is for larger family sized dwellings.

Indicator 1: Mix of units in full residential approvals for schemes of over 20 units residential units

Outcome 6.71 Table 11 shows that all of the residential schemes of over 20 units granted planning permission in the 2006/07 financial year have a mix of family and non-family accommodation. It also highlights that almost all of the applications provide a majority of family accommodation. This is reflected in the summary (Table 13 below), which shows that 65.4% of all residential units approved in schemes of over 20 units provide family accommodation. Table 12 shows that the proportion of housing that could be considered as larger family size units with 3 or more bedrooms was 14.4%. This is a significant increase compared to the previous financial year when only 5% was provided.

Table 11: Range of housing in residential approvals of 20 or more units

Number Total Borough Type of Number Address Proposal of Percentage Number of Reference Accommodation of Units Bedrooms Units

Granted full Planning Permission Creation of 366 residential Non-family 1 142 39% Brunel University, units through conversion of Osterley Campus, Lancaster House and Family 2 131 36% 00131/A/P58 George Little Building and 366 Borough Road, Family 3 45 12% Isleworth new build flats and town houses Family 4 48 13% The retention and Non-family 1 292 39% alteration of Wallis House and International House. Family 2 415 55% Wallis House, The demolition of all other 00505/P/P59 Great West Road, buildings on the site and 755 Brentford redevelopment for mixed employment, community Family 3 48 6% and private and affordable residential use. Demolition of two small Non-family 1 18 50% Chiswick War blocks and garages and Memorial Homes erection of 3 blocks with Family 2 14 39% Burlington Lane refurbishment of retained 00176/F/P4 36 Chiswick blocks to create 22 one and two bedroom flats, 6 London Family 3 4 11% W4 3EU houses, 6 wheelchair flats and 2 'wheelchair' houses.

26 Glenhurst Change of use from former Non-family 1 21 51% 00485/26/P2 Road, Brentford, council offices to create 41 41 London TW8 9BY residential flats Family 2 20 49%

00707/455/P 455 London The demolition of the Non-family 1 28 16% 174 55 Road, Isleworth existing office buildings fronting the site and Family 2 114 66% redevelopment to provide Family 3 5 3%

47 174 residential units Family 4 27 15% Redevelopment involving Non-family 1 11 31.5% the erection of a three and 137 Hatton Road four storey building Family 2 13 37% 00576/137/P Feltham, London comprising of 35 x one, two 35 20 TW14 8LR and three bed residential units for affordable Family 3 11 31.5% housing. The Heath Demolition of the existing Non-family 1 7 16% Business Centre, buildings and Heath Road redevelopment of site as Family 2 27 63% 00586/H/P1 residential comprising 43 x 43 Hounslow, Family 3 8 19% London 1, 2, 3 and 4 bed units in 2- TW3 2NF 5 storey blocks Family 4 1 2% Approved Subject to Satisfactory Completion of Legal Agreement

Erection of 4 x part 4, part Non-family 1 8 28.5% 101 New 3 and part 2 storey blocks 00798/101/P HestonRoad, comprising 30 x one, two Family 2 12 43% 28 7 Heston and three bed flats and 2 x 3 bed houses Family 3 8 28.5%

Demolition of the existing Non-family 1 10 14% Victoria Works, building and the erection of Family 2 45 61.5% 01253/P/P2 Victoria Road, a part four part five storey 73 Feltham building comprising 73 affordable housing units Family 3 18 24.5%

Table 12: Bedroom Size Table 13: Family Housing Mix

Unit Type Unit Size Total Percentage Unit Type Total Percentage Number of Units Non-family 1 Bed 537 34.6 Non-family 537 34.6 Family 2 Bed 791 51 Family 1014 65.4 Family 3 Bed 147 9.5 Family 4 Bed 76 4.9 Grand Total 1551

Indicator 2: Refusals quoting policy H.4.3

Outcome 6.72 There were no refusals quoting policy H.4.3 in 2006/07

Indicator 3: Appeals decisions quoting policy H.4.3

Outcome 6.73 There were no appeals quoting policy H.4.3 in 2006/07

Significant Effects

Sustainability Objective 13: To promote regeneration that makes use of existing assets

Indicator: BVPI 64 – Number of non-local authority-owned vacant dwellings returned to occupation or demolished during the financial year as a direct result of action taken by the local authority.

Outcome

48 6.74 The outturn for the 2006/07 financial year was 318, this is above the target of 250 and broadly similar to the previous year’s outturn of 315.

49 UDP Objective H.6

To protect and enhance the environmental quality of existing residential areas, and to promote the improvement of existing residential properties and associated community facilities.

Local Indicator(s)

UDP Policy H.6.4 Extensions and Alterations

Purpose: To ensure that proposals for extensions or alterations respect the design of the existing building, the amenity to existing residents in surrounding properties, and the character of the residential area.

Indicator: Key issues in appeals quoting H.6.4 (see Appendix 11)

Outcome 6.75 There were eight appeals decisions quoting policy H.4.2 of which three were allowed and three were dismissed. A further 2 were split decisions where part of the appeal was allowed and part was dismissed.

6.76 It is apparent from a number of appeal statements that the inspector has given considerable weight to the Hounslow’s Residential Extension Guidelines (REGs) as SPG, particularly given that it has been subject to public consultation (see Appendix 11 for examples).

6.77 However, inspectors have also given flexibility to standards specified in the REGs. For example, in the allowed appeal relating to 52 Chatsworth Crescent, Hounslow (Planning ref: 00236/52/P1) the inspector found that although the proposed 4.5m extension would not comply with the maximum depth of 3.65m stated in the REGs the inspector considered that, in this particular instance, no harm would be caused to the living conditions of neighbouring occupiers. Similarly in the allowed appeal for the retention of the garage/playroom at 46 Cambridge Close Hounslow (Planning ref: 00195/46/P3), the inspector considered that the failure to comply with the REG requirement to set the building in from the site boundary did not, in this case, result in any harm.

6.78 In each of the three dismissed appeals (Planning refs: 00192/24/P1, 01079/43/P3 and 00248/46/P3), as well as in the 2 part-dismissed appeals (Planning refs: 01116/164/P4 and 00313/16/P3), the inspector’s report concluded that the proposals would cause serious harm to the character and appearance of the area. In each of the allowed appeals the inspector disagreed with the council’s judgement in term of a scheme’s impact on character and appearance. There are difficulties in overcoming variations in judgement and a standard approach cannot be applied given the individuality of each case. For example the inspector found that the proposed mansard roof extension to 4 terraced houses at 82-88 The Drive, Feltham (Planning Ref: 00368/82-88/P1) did not rise so much above its neighbours that it would noticeably out scale them, hence the inspector concluded that the local street scene would not be adversely affected.

6.79 SPG 1997 was referred to in only two out of the eight appeals. In one appeal (Planning ref: 01116/164/P4) the inspector stated that there was no evidence that the SPG was subject to public consultation and afforded it only limited weight. This is despite the Council being able to provide evidence that consultation has taken and other inspectors affording the guidance considerable weight as a consequence. In the other appeal

50 (Planning ref: 00313/16/P3) the inspector state that whilst the SPG is a material planning consideration, more recent policies in the UDP and the REG may carry more weight.

UDP Objective H.7

To promote the provision of supported and other types of housing development where necessary

Local Indicator(s)

UDP Policy H.7.4 Bed and Breakfast Accommodation

Purpose: To protect single family dwellings as well as houses in multiple occupation which are meeting recognised housing needs.

A. Use of Policy H.7.4 in Planning Decisions and Appeal Decisions

Planning Decisions Appeal Decisions Approved Refused Allowed Dismissed 0 0 0 0

B. Policy H.7.4 Outcomes

Indicator: Key issues from appeals quoting H.7.4

Outcome 6.80 The were no appeal decisions quoting H.7.4 in the 2006/07 financial year.

Significant Effects

Sustainability Objective 3: To ensure that everyone has the opportunity to live in a decent, sustainably constructed and affordable home.

Indicator: Homelessness and temporary accommodation

Outcome 6.81 In the 2006/07 financial year there were 1,252 homeless persons in the Borough, including those in temporary accommodation, the homeless at home and three rough-sleepers (BVPI 202). The figures in Table 12 for the last four financial years show some fluctuation in the number of homeless persons, but with an overall decline

Table 14: Number of Homeless Persons in the Borough

End of Financial Year Number of Homeless* Persons 2003/04 1570 2004/05 1386 2005/06 1447 2006/07 1252 * including those in temporary accommodation, the homeless at home and rough-sleepers (Source: LBH Housing and DCLG Statutory Homelessness 2007)

51 Summary of UDP Housing Policy Implementation

6.82 An assessment has been made on the implementation of policies and analysis of the decisions to enable the Council to determine whether there is a need for amending or replacing policies.

UDP Policy H.2.1 6.83 Of the applications approved, there were four where the Borough’s target for 50% affordable housing was not met. Whilst this may indicate that the policy is not being implemented as intended, the policy also states that regard should be had to “specific local need for affordable housing … site circumstances, the economics of provision, and the need to achieve a successful development”. Policy H.2.1 also seeks to secure a mix of housing types and sizes for affordable housing, having regard to priority need. The Borough’s priority need is for larger family sized dwellings as indicated in Table 5. The schemes that failed to meet the 50% target provide a large number of affordable family units (reflected in the higher percentage of affordable housing when provided as habitable rooms) and this provision contributed to these schemes being acceptable. The proportion of affordable housing provided as three-bedrooms or more showed a significant increase from the previous financial year and achieved The Hounslow Plan target (Target 2.5(i)) of shifting the balance of affordable housing towards family sized dwellings.

6.84 Applications quoting Policy H.2.1 that were refused were on the basis that the proportion and mix of affordable housing proposed was not considered suitable. This decision has been supported by an inspector in their dismissal of the scheme at 391- 407 Chiswick High Road.

Policy H.3.1 6.85 The one application allowed on appeal, contrary to Policy H.3.1, was on the basis that compliance with Policy H.3.3 outweighed the presumption against the loss of residential (H.3.1) as Policy H.3.3 explicitly allows for the loss of residential use of upper floors above shops in defined circumstances. Whilst the inspector applied this ruling, the individual circumstances of each scheme need to be considered. In other decisions assessed against policy H.3.1, the Council has considered the circumstances of the case, and applied the policy accordingly.

Policies H.3.4A and H.3.4 6.86 The one application quoting policy H.3.4A that was recommended for approval but refused by members and overturned on appeal strengthens the observation that inspectors have consistently and regularly found that the Council was wrong to refuse such cases.

6.87 Although an inspector noted in another appeal that policies H.3.4A and H.3.4 pull in different direction this issue has been resolved to the extent that policy H.3.4A has not been saved in the amended UDP as it was already reflected in the London Plan and PPS3.

6.88 Whilst Policy H.3.4 is generally being implemented effectively in terms of the conversions from a house to flats, there were a number of instances when policy H.3.4 was quoted but where the proposal did not actually involve the conversion of a house to flats.

Policy H.4.2 6.89 Policy H.4.2 does not advocate a rigid approach to residential density. It establishes a density range that is normally appropriate and provides examples when a higher figure may be appropriate. This has been reflected in planning decisions where ‘demonstrable harm’ has been the key issue in terms of a developments impact on an area’s character or

52 a lack of amenity space provision. Significant weight has also been given in decisions to the London Plan density matrix.

Policy H.4.3 6.90 The policy has been implemented as intended with all applications of over 20 units granted having a mix of family and non-family accommodation. It should be noted that the definition of family accommodation includes three bedspace units, which are often two bedroom units. Even so, there was still a significant increase in the proportion of housing providing larger family size units with 3 bedrooms or more compared to the previous financial year.

Policy H.6.4 andResidential Extension Guidelines 2004 (REGs) 6.91 The decisions by inspectors in assessment of the REGs have varied reflecting the site circumstances and other matters for consideration. It is considered the guidance in the documents can continue to be applied, with flexibility given to take account of the circumstances of each site.

Policy H.7.4 6.92 Policy H.7.4 was not used in any planning or appeal decisions during the financial year.

7. EMPLOYMENT

CONTEXTUAL INDICATORS

London Development Agency (LDA) Borough Economic Profile 7.1 Figure 5 below shows the employment rate, proportion of population with no qualification and VATS registered/ deregistered as a proportion of all businesses are generally similar to the London average.

Figure 5: LDA Borough Economic Profile

80 London Hounslow

0 Employment Rate ILO Unemployment % of Pop. With No VAT Registrations as VAT Deregistrations (w orking age) Rate Qualifications a % of All as a % of All Businesses Businesses

Ratio of planning permission to 3-year average starts (by m2)

Table 15: Ratio of planning permission to 3 year average starts

Year Ratio of planning permissions* to 3 year average starts FY 2002 5.68:1 FY 2003 9.66:1 FY 2004 19.94:1 FY 2005 3.51:1 * Planning permissions only includes those developments not started in any given year.

7.2 The Mayor of London sets a target for the stock of office planning permissions to be at least three times the average rate of starts over the previous 3 years. This is to ensure that the future pipeline of office supply is maintained at an adequate level to respond to an increase in demand for office floorspace with changes in the economic cycle. New build developments typically take up to three years from conception to completion according to

54 Estates Gazette (13th October 2007), with more than 3 years un-built supply allowing the market time to respond to any upturn.

7.3 Table 15 and Figure 6 present this indicator at a borough level, the figures demonstrating the floorspace granted permission but not started in the 2005 financial year is approx. three and a half times the average amount of floorspace started over the previous 3 years.

7.4 This reflects the implementation of planning permissions for Buildings 4 and 5 at Chiswick Park and indicates that the office market is improving in the eastern part of the Borough with further development at Chiswick Park and increasing rents within Chiswick Town Centre as demand extends from the West end.

Figure 6: Permissions for B1 development started and not started in Hounslow 1990 FY - 2005 FY

400,000

350,000

300,000

250,000

Permission not started 200,000 Permission started

150,000

100,000 Gross amount of floorspace

50,000

Financial Ye ar

55 OUTPUT INDICATORS

UDP Objective E.1

To maintain and enhance the importance of Hounslow as an employment centre which is significant in both the West London and London-wide context; to maintain a robust local economy with a variety of employment sites and uses; and to encourage economic development which leads to more effective use of land and is compatible with the Council’s environmental objectives.

Core Indicator(s)

1a Amount of floorspace developed for employment by type

7.5 Table 16 shows that 77,405m2 of gross internal floorspace was developed for employment in the Borough during the 2006/07 year.

Table 16: Gross Internal Floorspace developed for employment 2006/07

Borough Site name/ No. Type of B1a B1b B1c B2 B8 Employment Regeneration Employment Reference development site, UDP area, UDP DPD

00108/69- Land at 69-71 Redevelopment 151 Yes (Proposal No No 71/P5 Bell Road and site E4) 159 Hanworth Road, TW3 3NX

00133/67A/L 67A Boston Continued use 300 No Yes No AW1 Manor Road, Brentford, TW8 9JQ 00229/HC/P Duratube Ltd Site, Redevelopment 1,277 5,947 Yes (Proposal Yes Yes (SIL) 23 Land Off Central site E16) Way, North Feltham Trading Estate, Feltham, TW14 0XD 00248/D4/P1 Building 4, New 17,466 Yes (Proposal No Yes (Key Chiswick Park, Development site E12 and existing and Chiswick High Key Preferred Road, Chiswick, Employment Office Location London, W4 5YA Location)

00248/D5/P2 Chiswick Park, New 15,309 Yes (Proposal No Yes (Key Building 5, Development site E12 and existing and Chiswick High Key Preferred Road, Chiswick, Employment Office Location W4 5YA Location)

00329/138/P 138 The Continued use 129 No No No 4 Crossways, Heston, TW5 0JR

00379/4A/P5 4A East Street, Redevelopment 800 No Yes Yes (SIL) Brentford, TW8 8LR 00428/P/P35 The Site of St. Redevelopment 1,509 3,696 3,695 No No Yes (LSIS) Vincents Home, Faggs Road, Feltham, TW14 0NQ

56 00607/56- 56 – 57 High Redevelopment 93 Yes (Town Yes Yes (Town 57/P5 Street, Brentford, Centre) Centre) TW8 0AH 00768/J/P30 Tesco Stores Ltd, Extension 240 No Yes No Isleworth, Mogden Lane, TW7 7JY 01137/223/P 223 Twickenham Continued use/ 607 No Yes No 10 Road, Isleworth, change of use TW7 6DH

01271/B/P3 Frontier House, New 333 Yes (Proposal Yes Yes (SIL) Pier Road, Development Site E16) Feltham

01359/A/P14 Former Fujitsu Redevelopment 1,607 4,516 4,516 No Yes No Premises, Forest Road, Feltham, TW13 7EJ

01378/A4- Space Waye New 3,411 2,444 2,444 Yes (Proposal Yes Yes (SIL) 12/P1 Industrial Estate, Development Site E16) Space Waye, Feltham, TW14 0TH 01405/C9/P3 Links Industrial Change of use 176 Yes (Proposal Yes Yes (LSIS) Estate, Unit 9 Site E14) Popham Close, Feltham

01430/3/P1 Unit 1, 2 & 3, The Change of use 2,547 No No Yes (LSIS) Heston Centre, International Avenue, Heston, TW5 9NJ

133469P2 Unit 69, Phoenix Redevelopment 1,405 No No Yes (LSIS) Way, Heston, Middlesex, TW5 9NB 609BHP2 Feltham Town Redevelopment 1,213 Yes (Town Yes Yes (Town Centre, High Centre) centre) Street, Feltham

609BHP3 Feltham Town New 1,574 Yes (Town Yes Yes (Town Centre, High Development Centre) Centre) Street, Feltham

38,628 0 10,479 17,403 10,895

7.6 As shown in Table 17 below, the largest proportion of floorspace was developed for B1a use (50%) largely comprising the floorspace completed at Chiswick Park (Buildings 4 and 5).

Table 17: Amount of floorspace developed for employment by type

Amount of floorspace developed for Percentage Use Class employment by type (m2) B1a 38,628 50% B1b 0 0% B1c 10,479 14% B2 17,403 22% B8 10,895 14%

57 Total 77,405 100%

1b Amount of floorspace developed for employment by type, in employment or regeneration areas

7.7 Table 18 shows that 67% of employment floorspace was developed within employment areas as defined in the UDP (84% within designated areas defined in the emerging Employment DPD).

7.8 In the context of the UDP, Employment areas are defined as those areas designated or allocated as key employment locations, employment proposal sites and town centres.

7.9 As stated in paragraph 3.13, the Employment DPD was submitted to the Secretary of State on the 20th July 2007. Whilst the Employment DPD is not adopted, the proportion of completed B class development taking place within Employment areas designated in the DPD (Strategic Industrial Locations (SIL); Locally Significant Industrial Sites (LSIS); Key Existing Office Locations (KEOL) and Preferred Office Locations (POL)) is important to the function of these sites upon adoption of the DPD.

Table 18: Amount of floorspace developed for employment by type in employment areas

Amount of floorspace Percentage of total Amount of floorspace Percentage of total developed for floorspace developed developed for floorspace developed employment within for employment in employment within for employment in Use Class employment areas as employment areas employment areas as employment areas defined in UDP (m2) (UDP) defined in Emp DPD (Emp DPD) (m2) B1a 37,592 49% 37,411 48% B1b 0 0% 0 0% B1c 3,411 4% 8,872 11% B2 8,391 11% 12,887 17% B8 2,444 3% 6,139 8% Total 51,838 67% 65,309 84%

7.10 Table 19 shows that 41% of floorspace developed for employment was within the regeneration areas shown on the UDP Proposals map.

Table 19: Amount of floorspace developed for employment in regeneration areas

Amount of floorspace developed for Percentage of total Use Class employment which is in existing floorspace developed for regeneration areas (m2) employment B1a 5,573 7% B1b 0 0% B1c 5,018 6% B2 13,707 18% B8 7,200 9% Total 31,498 41%

58 1c Amount of floorspace by employment type, which is on previously developed land

7.11 All completed employment (Class B) developments in the Borough in 2006/07 were on previously developed land.

1d Employment land available by type

7.12 Employment land (in hectares) is defined as (i) employment sites defined and allocated in the UDP/ Employment DPD, and (ii) sites for which planning permission has been granted for Class B developments.

(i) Land allocated/ designated for employment use in UDP/ Employment DPD

Sites defined and allocated for employment use in the UDP 7.13 The UDP contains a proposals schedule of employment sites within the Borough. Table 20 lists each of these sites and provides the site area in hectares and proposed type of employment development.

Table 20: Employment Proposal Sites (including Key Employment Locations)

Employment Ref Site Address Area (ha) Type E1 Extension to Shield Road Industrial Estate, Bedfont B1/B8 2.14 E2 Feltham Marshalling Yards (East) B1c/B2/B8 11.43 E4 Bell Road / Hanworth Road, Hounslow Flexible B1 0.67 E7 Lionel Road Goods Yard, Brentford B2/B8 3.01 E8 Power Road Estate, Chiswick High Road Flexible B1 6.45 E9 Acton Works, Bollo Lane B1/B2/B8 12.67 E10 Great West Road Employment Area Flexible B1 53.76 E11 Area north of Challenge Road Industrial Area, Feltham B1c/B2/B8 4.67 E12 Chiswick Business Park B1a 13.78 E13 Industrial land west of Green Lane B1c/B2/B8 14.01 E14 Hanworth Trading Estate B1c/B2/B8 11.71 E15 Ascot Road and land to east B1c/B2/B8 9.5 E16 North Feltham Trading Estate B1c/B2/B8 37.73 E17 Bedfont Lakes High Technology Business Park B1a/B1b 18.8 E18 Twickenham Trading Estate B1c/B2/B8 6.42 E20 Clocktower Road and land shown south of Worton Road B1c/B2/B8 7.64 E21 Western International Market B1c/B2/B8 12.17 Grand Total (Hectares) 226.56

Sites designated for employment use in the Employment DPD 7.14 The Employment DPD designates sites as Strategic Industrial Locations (Preferred Industrial Locations (PIL); Industrial Business Parks (IBP), Locally Significant Industrial Site (LSIS), Key Existing Office Locations KEOL) and Preferred Office Locations (POL). The designation and area of each site are specified in the table below. Whilst the policies for SILs and LSISs allow for industrial, warehousing and related uses, the uses specified in the table below indicate the general uses that the designated areas are intended for.

Table 21: Sites designated for employment uses in the Employment DPD

Ref Desig Site name Site address Primary use(s) Site area (ha) 1 KEOL Bedfont Lakes Business Park B1a 14.83 KEOL/ B1a 2 POL Feltham Town Centre Feltham High Street 38.53 KEOL/ B1a 3 POL Hounslow Town Centre Hounslow High Street 44.07

59 Great West Road Key Existing B1a 4 KEOL Office Location 3.36 KEOL/ B1a 5 POL Brentford Town Centre Brentford High Street 42.00 KEOL/ B1a 6 POL Chiswick Business Park Chiswick High Road 13.04 KEOL/ B1a 7 POL Chiswick Town Centre Chiswick High Road 33.67 Great West Road Industrial B1b/ B1c/ B2 8 IBP Business Park Great West Road, Brentford 31.08 Great West Road Industrial B1b/ B1c/ B2 8 IBP Business Park Great West Road, Brentford 3.50 North Feltham Preferred B2, B8 9 PIL Industrial Location 52.49 Brentford Preferred Industrial B2, B8 10 PIL Location Commerce Rd, Brentford 6.76 Brentford Preferred Industrial B2, B8 10 PIL Location Transport Ave, Brentford 15.76 11 LSIS Cargo Service Centre Stanwell Road, Bedfont B2, B8 20.59 12 LSIS Ascot Road Industrial Estate Staines Road, Bedfont B2, B8 8.65 13 LSIS Ashford Industrial Estate B2, B8 5.15 14 LSIS Challenge Road Industrial Esate Challenge Road, Bedfont B2, B8 2.43 North of Challenge Road, B2, B8 15 LSIS Bedfont North Industrial Park Bedfont Lakes 4.82 16 LSIS Maple Industrial Estate Maple Way, Feltham B2, B8 0.51 17 LSIS Feltham Corporate Centre Plane Tree Crescent, Feltham B2, B8 2.62 18 LSIS Plane Tree Crescent Feltham B2, B8 4.53 19 LSIS Five Ways Business Centre Aspen Way, Feltham B2, B8 1.33 20 LSIS Felthambrook Industrial Estate Felthambrook Way, Feltham B2, B8 1.44 21 LSIS Hanworth Trading Estate Mount Road, Feltham B2, B8 7.54 22 LSIS Popham Close Hanworth B2, B8 2.86 23 LSIS Feltham Marshalling Yards Godfrey Way B2, B8 13.57 24 LSIS Radius Park St Antony's Way, Hatton B2, B8 7.92 25 LSIS Sun Life Trading Centre Hounslow B2, B8 4.04 26 LSIS Heathrow Causeway Estate Ariel Way, Hounslow B2, B8 5.26 Haslemere Heathrow Industrial B2, B8 27 LSIS Estate Silver Jubilee Way, Hounslow 11.01 Heathrow International Trading B2, B8 28 LSIS Estate Green Lane, Feltham 4.70 29 LSIS Prologis Park Green Lane, Hounslow B2, B8 11.42 30 LSIS Parkway Trading Estate Cranford Lane, Heston B2, B8 7.56 31 LSIS Heston Industrial Estate Cranford Lane, Heston B2, B8 1.38 32 LSIS Heston Phoenix Distribution Park Cranford Lane, Heston B2, B8 3.49 33 LSIS Victory Way Heston B2, B8 1.31 34 LSIS The Heston Centre Southall Lane, Heston B2, B8 4.62 35 LSIS Spitfire Estate Heston B2, B8 0.90 36 LSIS Airlinks Industrial Estate Spitfire Way, Heston B2, B8 3.30 37 LSIS Harlequin Centre Southall Lane, Heston B2, B8 1.58 38 LSIS Serco Southall Lane, Heston B2, B8 2.39 39 LSIS Bulls Bridge Industrial Estate Bulls Bridge, Heston B2, B8 3.03 40 LSIS Worton Hall Industrial Estate Worton Road B2, B8 1.64 41 LSIS Victory Business Centre Fleming Way, Isleworth B2, B8 2.13 Clock Tower Road Industrial B2, B8 42 LSIS Estate Worton Road, Isleworth 5.64 43 LSIS Phoenix Trading Park Great West Road, Brentford B2, B8 3.27 44 LSIS Kew Bridge Distribution Centre Great West Road B2, B8 4.64 45 LSIS Power Road Industrial Estate Brentford B2, B8 6.15

60 46 LSIS Bollo Lane Industrial Estate B2, B8 11.11 GRAND TOTAL (ha) B2, B8 483.60

7.15 For each site, the area of the site has been divided by the number of use classes (where the designation has more than one primary use class) to give an approximation of the amount of employment land available by type (see Table 22 below).

Table 22: Employment land available by type in sites defined and allocated for employment use in the UDP

Employment B1a B1b B1c B2 B8 Total Area (ha) Type UDP 45.23 31.45 60.49 44.16 45.23 226.56

Emp DPD 189.5 11.5 11.5 141.3 129.8 483.6

(ii) Employment Land Pipeline

7.16 Table 23 summarises the amount of land on for which planning permission has been granted for Class B developments outside designated employment areas

Table 23: Employment land available by type in approvals for Class B developments outside employment areas defined in UDP and Employment DPD

Employment B1a B1b B1c B2 B8 Total Area Type UDP 1.482 0.018 2.214 1.576 2.447 7.737

Emp DPD 0.669 0.014 0.018 0.848 3.021 4.57

Table 24: Total Land Available for Employment by Type

Employment B1a B1b B1c B2 B8 Total Area Type UDP 46.712 31.468 62.704 45.736 47.677 234.297

Emp DPD 190.169 11.514 11.518 142.148 132.821 488.17

7.17 Using the definition of employment land set out above, Table 24 shows that the total amount of land available for employment use in Hounslow is approximately 234 hectares if employment sites allocated in the UDP are considered or 488 hectares if those in the Employment DPD are considered.

7.18 As a benchmark, the figures of 234 and 488 hectares are considered to be an underestimate of the total stock of industrial and commercial land in the Borough. Outside the office and industrial sites identified above, there are a significant number of non- designated sites, which contribute to the total land supply of Class B uses in the Borough but have not been identified.

7.19 Due to the information available on the total stock in Class B use, it is considered appropriate to use the figure of 488.17 hectares as a benchmark with the caveat that this figure includes town centres, which comprise a mix of uses including employment.

61 1e Losses of employment land in (i) employment/regeneration areas and (ii) local Authority area.

(i) Regeneration Area The amount of employment land lost to completed non-employment uses in regeneration areas for the 2006/07 financial year was 3.808 hectares

(ii) Employment Areas The amount of employment land lost to completed non-employment uses in employment areas as defined in the UDP (incl. Key Employment Locations, Employment Proposal Sites and Town centres) in the 2006/07 year was 3.691 hectares.

The majority of employment land has been lost to employment generating uses such as hotels, a fuel depot and car service centres that do not fall within B Use Classes monitored through Core Indicator 1e.

7.20 In the context of the emerging Employment DPD, the amount of employment land lost to non-employment uses in employment areas incl. Strategic Industrial Locations, Locally Significant Industrial Sites, Key Existing Office Locations and Preferred Office Locations) in the 2006/07 year was 2.943 hectares.

(iii) Local Authority Area The total amount of employment land lost to completed non-employment uses in the 2006/07 year was 5.027 hectares.

1f Amount of employment land lost to residential development

7.21 Of the 5.027 hectares of employment land lost to non-employment uses, 0.386 ha of this was to residential use. Whilst this is low, there has been significant pressure on employment sites across the Borough, particularly smaller industrial estates in largely residential areas. Planning permissions for the release of land to non-employment continues to be monitored at a borough and sub-regional level to enable an assessment against benchmarks for the release of industrial land in the Mayor’s Draft SPG on Industrial Capacity (October 2007).

Local Indicator(s)

UDP Policy E.1.2 Locations for business (B1) use

Purpose: Encouraging patterns of development, which provide jobs, which are accessible and reduce the need to travel, particularly by car.

A. Use of Policy E.1.2 in Planning Decisions and Appeal Decisions

Planning Decisions Appeal Decisions Approved Refused Allowed Dismissed 9 1 0* 0 *Whilst Policy E.1.2 was not referred to in appeal decisions in the 2006/07 year, criteria ii of Policy E.1.1 was assessed, which reflects Policy E.1.2 and has therefore been included for monitoring purposes.

B. Policy Outcomes

Target: In the first instance B1 uses, particularly office uses should be directed to the Borough’s town centres, which offer the greatest accessibility, by all modes of transport. In the event that suitable sites are not available within town centre or edge of town centres, new B1 developments that generate a high number of trips should be within the Great West Road, Chiswick Park and Bedfont Lakes, which are defined as development nodes in the West London Strategic Development Framework. Other sites considered appropriate for business (B1) development are included in the proposals schedule.

Indicator 1: Location of approved proposals for business (B1) uses (see Table 23 below).

Outcome 7.22 As Table 25 below shows, only three of nine approved permissions were for B1 use in a town centre location or Key Employment Location. The Council’s reasons to allow B1 use outside these sequentially preferable locations are explained below.

7.23 The first of these was the renewal of an office permission for Europa House, 804 Bath Road (Planning ref: 00083/AB/P18). The application could only be assessed in the context of changes to the policy context since the original permission was granted in 2001. As there had not been any significant changes, the proposal was considered to be in accordance with Policy E.1.2.

7.24 The second permission granted for offices in an out of centre location was at 100 Lampton Road (Planning ref: 00676/100/P1), where the Council allowed a small increase to an existing premises (196m2). Policy E.1.1 allows for limited extensions of up to 565m2 are acceptable in unsustainable locations.

7.25 The redevelopment of the former Fujitsu premises on Forest Road (Planning ref: 01359/A/P14) and Airport Works on Green Lane (Planning ref: 00507/S/P14) proposed B1c floorspace (Light industrial) in out of centre locations. Whilst Policy E.1.2 requires the sequential approach to be demonstrated for all B1 uses, it was not considered appropriate to require this, as offices are the only B use identified in PPS6 as a town centre use.

7.26 The development of six B1 units on Turnham Green Terrace Mews (Planning ref. 01136/B/P2) whilst an edge of centre location was acceptable. The location on the boundary of Chiswick Town Centre has access off Turnham Green Terrace, which is within the town centre and therefore accessibility to the site by sustainable modes of transport is comparable to a town centre site. This demonstrates the need for a ‘common sense’ approach in application of policy.

7.27 The other two permissions quoting Policy E.1.2 were for the amendment of conditions, which restricted the proportion of office floorspace (condition 3) and limited the uses allowed (condition 4). Whilst the purpose of the condition to restrict the proportion of office floorspace (condition 3) was to ensure offices remained ancillary to the industrial units on the estate, the amendment to condition 4 limited the uses to B1b and B1c of the B1 use class. As research and development (B1b)/ light industrial (B1c) uses are not identified in PPS6 as town centre uses it was not appropriate to require the sequential approach.

Table 25: Permissions for developments proposing new business (B1) uses in 2006/07

Borough Development Description Address Within Town Centre/ Edge of Centre Reference or Key Employment Location

63 00083/AB/P18 Following approval of Europa House 804 Bath Road No Out of centre 00083/AB/P15 for erection of a five Hounslow London TW5 9US storey office building, variation of Condition 1 (Timescale implementation) to allow for a further three years upto 1 August 2009

00676/100/P1 Erection of a two storey office The Lawn 100 Lampton Road No Out of centre building to rear of existing offices Hounslow London TW3 4EB with associated landscaping and boundary treatment

00248/147/P15 Erection of a conservatory to rear 147 Chiswick High Road Chiswick Yes Town centre elevation of first floor office. London W4 2DT 01359/A/P14 Redevelopment of the existing Former Fujitsu Premises Forest No Out of centre office/industrial building to provide Road Feltham London TW13 7EJ a mixed B1(C), B2 and B8 floorspace with ancillary offices, yard, car parking and landscaping 00505/429/P10 Erection of a single storey rear 429 Great West Road Hounslow No Out of centre extension to provide additional London TW5 0BY office space and disabled WC facilities to the existing office. 01136/B/P2 Formation of six self contained B1 North Block Turnham Green Yes Edge of town centre units at ground and first floor level, Terrace Mews Chiswick London erection of first floor rear extension W4 1QU and re-cladding the roof and front and rear elevations at first floor level

00505/Y/P39 Removal of Condition 3 (The level Phoenix Trading Park Ealing Road Yes Great West Road Key of ancillary offices showed not Brentford London TW8 9PL Employment Location exceed 20% of the total floorspace) LSIS (emerging Emp of approved planning permission DPD) reference 00505/Y/P36 dated 02/12/1982.

00505/Y/P38 Variation of Condition 4 (The site Phoenix Trading Park Ealing Road Yes Great West Road Key shall only be used for purposes Brentford London TW8 9PL Employment Location under classes III, IV or X) to permit LSIS (emerging Emp use for class B1 (b); class B1 (c); DPD) class B2 and Class B8 of approved planning permission reference 00505/Y/P36 dated 02/12/1982. 00507/S/P14 Redevelopment to provide new Airport Works 109 Green Lane No SIL in emerging light industrial (B1c), general Hounslow London TW4 6DG Employment DPD industrial (B2) and warehouse/distribution (B8) building with associated external works.

Indicator 2: Refusals quoting policy E.1.2 (see Appendix 12)

Outcome 7.28 There was one planning application refused, which quoted Policy E.1.2 as a reason for refusal. The application for one office unit at 4-6 Hounslow Road, Hanworth failed to demonstrate there were no appropriate town centre or edge of centre locations more suitable for the proposed office use in accordance with the sequential approach.

Indicator 3: Appeal decisions quoting policy E.1.2 (see Appendix 13)

Outcome 7.29 Whilst Policy E.1.2 was not referred to in appeal decisions in the 2006/07 financial year, criteria ii of Policy E.1.1 which Policy E.1.2 reflects was assessed. Policy E.1.1 (criteria ii) applies the sequential approach to all major trip-generating developments including offices the inspector considered the requirement in policy E.1.1 to reduce the need to travel and encourage more sustainable forms of development was pertinent to the case (138 The Crossways, Heston, Planning Ref. 00329/138/P4). The inspector accepted the appellant’s argument that the proposed use served local residents and the location was therefore more convenient and sustainable to local residents than a town centre.

Policy E.1.5 Development involving loss of or changes in employment uses

Purpose: To maintain a diverse and robust mix of employment uses on a suitable variety of sites within the Borough and through its proposal sites, town centres, regeneration areas and key employment locations. The UDP aims to channel development into the most appropriate areas.

A. Use of Policy E.1.5 in Planning Decisions and Appeal Decisions

Planning Decisions Appeal Decisions Approved Refused Allowed Dismissed 10 8 0 4* *Whilst four appeal decisions quoting Policy E.1.5 were dismissed, the loss of or change in existing employment use was addressed and was not a reason for dismissal.

B. Policy Outcomes

Target 1: Proposals for a loss or change of use that would result in the loss of high trip generating employment uses in town centres, edge of centre sites or in key employment locations will not be permitted.

Indicator 1: Planning decisions E.1.5 for development proposals involving loss or changes in use of high trip generating employment uses in town centres, edge of centre sites or key employment locations (see Appendix 14).

Outcome 7.30 There were five approvals for a change of use from employment use in town centres, edge of centre locations and Key Employment Locations.

7.31 Two of the permissions - No’s. 139 – 147 (Planning ref: 01254/139-147/P3) and 179 – 183 Hanworth Road (Planning ref: 01254/179-183/P4) for changes of use from employment in edge of centre locations were assessed in accordance with Policy E.1.5. Evidence was submitted for both applications to demonstrate there was limited or no demand for employment use and it was not viable to retain the sites in commercial use.

7.32 A proposal for the development of B1 units at Turnham Green Terrace Mews, whilst resulting in the loss of B2 units, proposed an increase in employment floorspace and jobs. Furthermore, the site itself was considered to be a good location for the proposed B1 use. Whilst an edge of centre location the site is accessed from Turnham Green within Chiswick town centre.

7.33 Planning permission for the mixed-use redevelopment of Wallis House, part of the Great West Road Key Employment Location was considered to be justifiable in planning terms when assessed against Policy E.1.5. Whilst the site had not been actively marketed for

65 wholly employment use and reliance placed on market forecasting and trends, the site had been vacant due to the relocation of GlaxoSmithKline Kline elsewhere in the Borough and Westgate House being derelict for some time. The likelihood of the existing office floorspace being fully occupied was therefore not high.

7.34 The proposal was also considered in the context of an amendment to PPG3 that required Local Planning Authorities to consider favourably planning applications for housing or mixed-use development on land allocated for industrial or commercial use or redundant land or buildings in industrial or commercial land, which was no longer needed.

7.35 The amended proposal for mixed-use development was on balance justified on the basis that it provided substantial benefits including employment. The amount of employment floorspace proposed was at a level comparable to the existing viable employment floorspace and could be delivered together with a substantive amount of affordable housing, the restoration and beneficial re-use of the listing building.

7.36 The last of the five applications was for a variation of conditions on a previously approved change of use from offices to an education and training centre for one year in Chiswick Town centre. The amended condition allowed for the life of the permission to be extended beyond one year and was acceptable on the basis that the educational use supported the local economic base by enhancing the working skills of the local population. Should the application have been refused, the applicant would have been forced to look elsewhere, potentially outside the Borough.

7.37 Of the eight applications refused, three were in a town centre or edge of centre location.

7.38 Two of the applications (North Block, Turnham Green Terrace Mews, Planning ref. 01136/B/P3 and 4 Dolman Road, Chiswick, Planning ref. 01431/4/P3) were refused on the basis that insufficient evidence had been provided to justify the loss of employment. In the former application, no evidence had been provided to demonstrate there was no demand for the existing B1 units. Furthermore, the proposed live-work units on Turnham Green Terrace Mews would reduce the flexibility and area available for business use.

7.39 The third application for Pharmacia House in Hounslow Town Centre sought a change of use from offices to residential on the basis that reuse for employment was unlikely. However, another application for the same site for change of use to a D1 employment use supported the view that there was demand for employment on the site. The proposal was therefore contrary to Policy E.1.5 and refused accordingly.

Indicator 2: Appeals quoting policy E.1.5 for development proposals involving loss or changes in use of high trip generating employment uses in town centres, edge of centre sites or in key employment locations (see Appendix 15)

Outcome 7.40 Two of the appeal decisions related to two different proposals for conversion of an existing office building (20 – 28 Turnham Green Terrace) to residential in a town centre location (Planning ref. 01135/20-28/P11 and Planning ref. 01135/18-28/P12). The inspector in the two appeal decisions for conversion of the office building considered there to be sufficient evidence that the reuse for employment (offices in this instance) was unlikely and therefore complied with Part 4 to Policy E.1.5. Evidence was presented demonstrating the existing offices were not suitable for modern requirements and there was alternative supply.

7.41 In an appeal decision for a proposed change of use from commercial premises to residential in a town centre (Planning ref. 01431/4/P2), the inspector considered the fitting

66 of refrigeration units was not a high trip generating use the use employing three persons, all of whom spent considerable time off site. The inspector went on to conclude that it was unlikely the premises would be attractive to another employment use, which was supported by marketing. The inspector pointed out the Council had advanced no specific evidence relating to employment generally in the area or to the consequences of the loss of employment from the site. This is most difficult to provide evidence on and further work from a policy perspective is required.

Target 2: Changes of use from employment will not be permitted within proposal sites, business parks, industrial estates and warehousing estates in accordance with Policy E.1.5

Indictor 1: Key issues in planning decisions for development proposals involving changes of use from employment generating uses within proposal sites, business parks, industrial estates and warehousing estates citing policy E.1.5 (see Appendix 14)

Outcome 7.42 There were six applications approved for a change of use from employment in locations outside town centres, edge of centre and Key Employment Locations. 2 of these applications were within proposal sites, industrial or warehousing estates to which part 3 of Policy E.1.5 applies.

7.43 The first of the applications approved was development of an industrial site for parking and refuelling of heavy goods vehicles (622 & 631 Central Way, North Feltham Trading Estate, Planning ref: 00229/ME/P4). The proposal was accepted on the basis that there was not demand for industrial use and the site would in fact retain an employment use on the site. This was in accordance with part 3 of Policy E.1.5, which seeks to retain employment- generating uses.

7.44 Permission was also granted on North Feltham Trading Estate (Unit 6 Armadale Road, Planning ref: 01321/K/P3) for a change of use from B2 to a training facility. The proposed construction-training centre was considered to be an employment related use supporting the development of a skilled labour force. It was therefore retaining an employment generating use on the site in accordance with Policy E.1.5.

7.45 Two of eight refusals quoting Policy E.1.5 were on proposal sites, industrial or warehousing estates, both of which related to the same proposal (one for consent for works to a listed building, Planning Ref. 01239/H/L7, the other for planning permission, (Planning ref. 01239/H/P36) – for the conversion of a listed building from employment to residential. Whilst the building was largely vacant, there was no evidence provided to demonstrate that reuse for employment was unlikely or that the existing occupier intended to vacate the premises. This was contrary to parts 3 and 4 of Policy E.1.5.

Indicator 2: Key issues in appeal decisions for development proposals involving changes of use from employment generating uses within proposal sites, business parks, industrial estates and warehousing estates citing policy E.1.5 (see Appendix 15)

Outcome 7.46 An issue previously arising in implementation of Policy E.1.5 is the definition of an ‘employment generating use’. In an appeal decision (00707/542/P4) for a change of use from retail to tyre fitting/ tyre retailing, the inspector concluded that the proposed use was an employment generating use and did not conflict with Policy E.1.5.

67 Significant Effects

Sustainability Objective 21: To maintain and attract new economic development that provides a range of jobs in appropriate locations.

Indicator: Change in the number employed in the Borough by industry

Outcome 7.47 Reflecting national trends, there has been a steady decline in employment in the manufacturing sector from 9.7% of total employment in 1995 to 4.1% in 2005. Meanwhile, service related employment has increased by 6.1% (since 1995) to 92.5% in 2005, with the largest sectors being ‘Finance, IT, other business activities’ (25.8%) and ‘Distribution, hotels & restaurants‘ (23.9%) (Nomis, 2005).

Sustainability Objective 22: To maintain and enhance the importance of Hounslow as an employment centre in both the West London and London wide context

Indicator: Change in number of employee jobs

Outcome 7.48 In 2005 there were a total of 121,400 employees in the Borough, of which 76.2% were full- time. The total is still significantly less than in 2001 when there was 137,700 but is on the increase after a decline between 2003 and 2004 when jobs declined from 119,00 to 117,900.

Sustainability Objective 23: To improve accessibility for all sections of the community to jobs, education, skills training and life long learning

Indicator: Qualifications by NVQ (Nomis web up to December 2006)

Outcome 7.49 The proportion of the working age population with no qualifications (11.2%) is less than the London (13.9%) and UK average (13.8%). Across all levels of qualifications, the proportion of the Borough’s working age population with NVQ1 and above, NVQ2 and above and NVQ3 and above is higher than for London with the exception of NVQ3 and above (32.6% relative to 34.6%.

7.50 In comparison to the UK, the proportion of residents with NVQ2 and above and NVQ1 and above is less at a borough level, the latter category comprising 71.5% compared to the UK average of 77.7%. However, there has been a greater increase in the proportion of working age population with NVQ2 and above at a borough level since March 1999 with 7.7% rise relative to the UK (5.9%).

68 UDP Objective E.5

To encourage employment opportunities and other benefits to the local economy through the development of Hounslow’s visitor attractions, hotel, conference and exhibition facilities, whilst having regard to the wider environment.

Local Indicator(s)

UDP Policy E.5.1 Visitor Accommodation

Purpose: While the Council is keen to accommodate some growth and recognises the contribution to the local economy, particularly through the provision of local jobs, new development does need to be appropriately located in relation to public transport and to the character of the local area

A. Use of Policy E.5.1 in Planning Decisions and Appeal Decisions

Planning Decisions Appeal Decisions Approved Refused Allowed Dismissed 5 4 1 1

B. Policy Outcomes

Target: Proposals for large-scale visitor accommodation (greater than 1000 sq. m) are well placed in terms of access by a wide choice of transport modes and to Heathrow, Central London, local visitor attractions and businesses by public transport

Indicator 1: Planning Decisions quoting policy E.5.1 (see Appendix 16)

Outcomes 7.51 There were five applications approved for visitor accommodation, of which two were outside a town centre. The first of two proposals was for additional floorspace to the existing Thorncliffe Hotel on North Hyde Lane, Southall (Planning ref: 00815/A/P21). Whilst the scale, nature of the development and location of the land was not seen to prejudice the implementation of the development plan, the sequential approach was not considered in assessment of the proposal.

7.52 The second permission was for the addition of a conservatory to the Shalimar Hotel, 215- 221 Staines Road (Planning ref: 01054/215-221/P16), which had been previously approved and was therefore in accordance with Policy E.5.1.

7.53 Three of the four applications refused were for visitor accommodation in out of centre locations. A 376-room hotel at 804 Bath Road, Hounslow (Planning ref: 00083/AB/P19) was acceptable in terms of criteria (ii) to Policy E.5.1 as the principle had been accepted in a previous application.

7.54 The location of a proposed hotel on a site adjacent (820 – 844 Bath Road, Hounslow – Planning ref: 00083/820-844/P26) was accepted based on evidence provided of the sequential approach and the location being appropriate for an airport hotel. Whilst the proposed site was well served by buses to/from Heathrow, it was not well placed relative to train/ underground stations and to address this, a green travel plan was required. The application was therefore assessed in accordance with UDP Policy E.5.1 (ii).

69 7.55 The third application refused was for visitor accommodation on a site where ancillary accommodation had previously been approved (New England, 52 York Road, Brentford, Planning ref: 01244/AB/P2). However, due to the scale of development proposed (more than 1,000 sq m), criteria (ii) of Policy E.5.1 was relevant. The site was considered to be in an area poorly served by public transport and because of this, the increase in guest rooms would attract car borne patrons, particularly given the need to carry luggage.

Indicator 2: Appeals quoting policy E.5.1 (see Appendix 17)

Outcome 7.56 There were two appeal decisions assessed against criteria (ii) of Policy E.5.1. Whilst it was the inspectors conclusions that both schemes did not have good access to a wide range of public transport services contrary to Policy E.5.1, the proposed change of use of the New England Bar and Restaurant (Planning ref: 01244/AB/P2) was not considered to be ‘as significant’ as the Council suggested and resulted in fewer vehicle trips relative to the permitted scheme.

7.57 In an appeal decision for a new 324-room hotel at 366 Great West Road (Planning ref: 00505/366/P18), the inspector considered the location as not being well placed for access by public transport, not benefiting from close proximity to Heathrow Central, which the inspector described as a “major public transport node”. It was also concluded that this would not be overcome by the Heathrow Hoppa bus service, which would not assist staff access, benefit non-airport business (which accounted for three quarters of the present hotel’s business) and would often run empty or nearly empty “adding unnecessarily to emissions and congestion”.

70 Summary of UDP Employment Policy Implementation

7.58 An assessment has been made on the implementation of policies and analysis of the decisions has enabled the Council to determine whether there is a need for amending or replacing policies.

Policy E.1.2 7.59 The application of the policy to the Council's own decisions highlighted the issue arising in previous years that the policy whilst referring to B1 uses is not appropriate to apply to B1c light industrial uses reflecting PPS6 that only identifies B1a offices as a town centre use. Whilst the policy allowed for small scale class B1 uses in residential areas, which may be inconsistent with the sequential approach, the policy has not been saved following the direction of the Government Office. Whilst an appeal decision allowed small scale offices in a suburban location on the basis that the use would serve local residents and would be more convenient and sustainable in this location, the floorspace proposed was of a scale that the sequential approach was not appropriate.

Policy E.1.5 7.60 Planning decisions were assessed in accordance with Part 1 to Policy E.1.5 of the UDP with evidence to demonstrate that reuse for employment was unlikely and/or there was the retention of employment on the site. Whilst the Council in the previous year (2005/06) refused applications for the conversion of an office building to residential (Planning refs: 01135/20-28/P11, 01135/18-28/P12) in Chiswick Town Centre on the basis that there was not sufficient evidence to demonstrate that reuse was unlikely, this was overturned by an inspector who concluded that the existing offices were not suitable for modern office requirements. Whilst this approach does not undermine the tests to demonstrate reuse is unlikely, it highlights the need to consider what issues need to be considered when assessing reasons why there is not demand.

7.61 Another appeal decision (Planning ref: 01431/4/P2) highlighted an issue of policy E.1.5 not addressing the loss of a low trip generating use in a town centre. Despite this the applicant demonstrated to the inspector that reuse was unlikely. The inspector made a point at the inquiry that no specific evidence relating to employment generally in the area or consequences of the loss of employment had been provided by the Council to support the argument that the site should be retained to "protect employment opportunities". The Council does not currently have the evidence to assess the consequences of the loss of employment and the tests of marketing/ alternative supply enable the Council to consider whether there is demand for employment. If these tests are met, the consequences of the loss are irrelevant.

7.62 Decisions made with reference to Part 3 to Policy E.1.5 were made in accordance with the development plan

Policy E.5.1 7.63 Proposals for visitor accommodation were assessed in accordance with the plan although the sequential approach was not considered in a proposal for additional floorspace to the Thorncliffe Hotel (Planning ref: 00815/A/P21). However, it was concluded that the proposal was not seen to prejudice the development plan. To ensure consistency, it is important the sequential approach is applied to all proposals for large scale accommodation.

7.64 Whilst an appeal decision concluded that the impacts of proposed visitor accommodation as part of the New England Bar and Restaurant (Planning ref: 01244/AB/P2) were not as significant as the Council suggested, this was on the basis of a previous permission granted for the site. Criteria (ii) of Policy E.5.1 is therefore still working as intended.

71 8. SHOPPING

CONTEXTUAL INDICATORS

The Borough’s Town Centres 8.1 Hounslow as a metropolitan town centre is highly accessible with two London Underground stations, an overland railway station and acts as an interchange for a number of bus routes. It is mainly a linear high street with two managed shopping centres - the Treaty Centre and the newly developed Blenheim Centre. Hounslow already has a large variety of multiple retailers and the completion of a new supermarket as part of phase one of the Blenheim Centre has significantly increased the proportion of convenience floorspace in the town centre. There is strong market interest in Hounslow at present this is set to increase as phase two of the Blenheim Centre is progressed. In terms of the overall environment of the centre, the quality remains mixed and the appearance of buildings and street frontages decline towards the periphery.

8.2 Located in the east of the Borough, Chiswick is defined as a major centre in the London Plan. The centre is well served by public transport with two London Underground stations, and Chiswick High Road is a major bus corridor that provides links to Hammersmith, Ealing and Hounslow. The retail offer in the centre is made up of a small number of major retailers alongside a number of smaller niche and boutique shops that serve a local catchment. Chiswick also contains the largest proportion of restaurants, cafes and bars of any of the Borough’s town centres. In terms of built environment, Chiswick has an attractive and well-maintained public realm and features some high quality architectural styles.

8.3 Feltham is the larger of the Borough’s two district centres. It has numerous bus links with Hounslow and Staines and a railway station served by routes from Surrey into central London. The retail offer and environmental quality of Feltham has significantly improved following a major redevelopment which has also introduced more pedestrianised areas.

8.4 Brentford is also identified as a district centre within the London Plan. It has the lowest public transport accessibility levels of all of the Borough centres with Brentford railway station located north of the High Street. There are however a number of bus routes that run along the congested High Street that provide links primarily with Ealing and Hounslow. The centre itself is currently in a state of transition with the Council promoting it as a focus for redevelopment. There is currently little in terms of comparison retail within Brentford, whilst the relatively high proportion of convenience floorspace is mainly provided by the existing Somerfield supermarket. The proportion of leisure uses and restaurants has increased through a number of new mixed-use redevelopments however the majority of these are located away from the main frontage.

72 OUTPUT INDICATORS

UDP Objective S.1

To maintain and enhance the character, vitality and viability of the Borough’s town centres by directing inappropriate non-retail uses away from primary frontages and towards shopping parades that have less retail significance. See Appendices 18 and 19 for the Borough’s shopping hierarchy and the list of frontages within the Borough’s main shopping centres5.

Local Indicator(s)

UDP Policy S.1.2 Non-retail uses in primary frontages

Purpose: Maintain and enhance the character, vitality and viability of the Borough’s town centres by directing inappropriate non-retail uses away from primary frontages and towards parades that have less retail significance. Non-retail uses do have a place in town centres, although these should be carefully controlled and not allowed to weaken the attractiveness of the primary shopping areas.

A. Use of Policy S.1.2 in Planning Decisions and Appeal Decisions

Planning Decisions Appeal Decisions Approved Refused Allowed Dismissed 7 4 1 0

B. Policy Outcomes

Target: The Council will generally resist a change of use from retail (use class A1) proposed use would not contribute to the character, vitality and viability of the town centre.

Indicator 1: Key issues in planning decisions for non-retail uses in primary frontages citing policy S.1.2 (See Appendix 20).

Outcome 8.5 In the 2006/07 financial year, there were seven approvals and four refusals for non-retail uses within the primary frontages across the Borough’s main shopping areas. Each approval was considered to enhance the character of the relevant parade, whilst retaining the vitality and viability of the area.

8.6 All four refusals related to sites in the Bath Road shopping parade of Hounslow West. The key reason in all cases was that the further loss of A1 retail uses could potentially damage the already fragile retail function of the parade. In one decision (Planning ref: 00083/346/P3) the officer highlighted that the proposed takeaway was not seen as a ‘necessary function in the primary frontage’ and considered that that there was already a proliferation of such uses in the parade such that a further change of use would alter the character of the parade.

5 Non-retail uses are defined in the UDP as those uses outside use class A1 (shops)

73 8.7 In two of the cases (Planning refs: 00083/316-320/P10 and 00083/338/342(U1)/P1) a further key reason was the likelihood of the proposed restaurants generating noise and encouraging antisocial behaviour in the parade.

Indicator 3: Key issues in appeals decisions citing policy S.1.2 (See Appendix 21)

Outcome 8.8 There was one appeal (Planning ref: 00083/234-326/P7) quoting policy S.1.2, which was approved by the Inspector. The application site was for unit that had been sub-divided into a small shopping arcade with a mix of nine units including retail and non-retail uses. The application was for a change to a single restaurant use. In their decision the inspector commented that they had not been provided with any detail on the extent of the designated shopping frontage or the criteria that led to the designation to help inform their decision. Consequently the Inspector determined that the change of use would not harm the character of the parade and predominant retail function of the parade would not be undermined.

UDP Policy S.1.3 Non-retail uses in secondary frontages

Purpose: To help assess the contribution or harm a non-retail use would have within a on the character and vitality and viability of the secondary frontage. UDP paragraph 10.4 states that whilst having an important supporting retail function, secondary frontages are areas where there is increased scope for a diversification of uses.

A. Use of Policy S.1.3 in Planning Decisions and Appeal Decisions

Planning Decisions Appeal Decisions Approved Refused Allowed Dismissed 4 0 0 0

B. Policy Outcomes

Target: Non-retail uses, or that of a particular non-retail use, should not be allowed to dominate the secondary area so as to undermine the retail function.

Indicator 1: Planning decisions for non-retail uses in secondary frontages quoting policy S.1.3 (see Appendix 22).

Outcome 8.9 There were four planning decisions quoting policy S.1.3, all of which were approved. Two of the developments (Planning refs: 01054/487/P10 and 00610/107/P3) proposed the change of use from a retail use to A3 restaurant uses. In both cases the proposed change of use was considered to improve the variety and activity within the parade.

8.10 The remaining two applications were of little relevance to the purpose of policy S.1.3. The first proposal was for the erection of an extension to a house (Planning ref: 00724/36/P1) located within a secondary frontage whilst the second was for the variance of a condition to allow the premises to sell alcohol (Planning ref: 00707/AL/P16).

Indicator 3: Appeals quoting policy S.1.3

Outcome 8.12 There were no appeals quoting policy S.1.3 in the 2006/07 financial year.

UDP Policy S.1.4 Non retail uses in locations outside the primary and secondary frontages within the main shopping areas

Purpose: In Hounslow and Chiswick town centres there are also areas that have not been designated as either secondary or primary, but where parades play an important service support function and where most opportunity for change of use to non-retail exists.

A. Use of Policy S.1.4 in Planning Decisions and Appeal Decisions

Planning Decisions Appeal Decisions Approved Refused Allowed Dismissed 2 3 1 0

B. Policy Outcomes

Target: The proposed change of use would not adversely affect the remaining retail function of the parade.

Indicator 1: Planning decisions for non-retail uses in locations outside the primary and secondary frontages within the Hounslow and Chiswick town centres, quoting policy S.1.4 (see Appendix 23).

Outcome 8.13 There were two approvals and three refusals for changes of use to non-retail in locations outside the primary and secondary frontages of Hounslow and Chiswick town centres. A proposed A3 restaurant in Bell Road, Hounslow (Planning ref 00108/53/P3) was approved because of the strong representation of A1 uses in the parade, and a relatively small proportion of food and drink establishments. It was also considered that the development would promote the activity on the street outside of core shopping hours.

8.14 The second approval for a change of use of from a hairdresser to a restaurant on Kingsley Road, Hounslow (Planning ref 00667/22/P6) was recommended for refusal by officers on the grounds that the proposal would result in the loss of an essential retail unit and would be likely to result in an unacceptable concentration of non-retail uses within the parade. The application was called in to Central Hounslow Planning Committee where Members resolved to grant planning permission because the site was not part of the main retailing area with the town centre, there were retail and non-retail uses in the parade, residents were supportive of the application and demand existed for the type of restaurant proposed.

8.15 Two applications (Planning ref 00108/44/P6 and 00667/22/P5) both proposing a change the use from A1 units to A3 restaurants (one of which was also part takeaway) were refused as the proposals were considered to have a negative effect upon the retail function of their relative parades. Also, due to the nature and cumulative effects of the takeaway proposed in one of the applications (Planning ref 00108/44/P6) was thought likely to bring further decline to environmental conditions through increase noise, litter and disturbance from patrons.

8.16 The third refusal under policy S.1.4 was a variation of conditions 3 (opening hours) for the Moon Under Water Public House in Hounslow. The development applied to extend opening hours, including specific days of the year when events occurred like New Year or Good Friday for example. This was refused, as there was lack of consideration for neighbours living conditions with prolonged noise late at night, which brought adverse affects on the environment.

Indicator 2: Appeals quoting policy S.1.4 (see Appendix 24)

Outcome 8.17 There was one appeal quoting policy S.1.4 in the 2006/07 financial year which was approved. The application (Planning ref: 00108/54/P3) was for a change of use from A1 to A3. The officer’s recommendations for refusal had identified that the proposal would increase the proportion of non-retail uses on the parade to 35%. However, the inspector did not consider the impact of the proposed change of use on the retail function of the parade. He identified the main issues as the effect on on-street parking and highway safety, and the effect on the living conditions of nearby residents. In both these regards the Inspector considered the proposal was acceptable.

Significant Effects

Sustainability Objective 20: To provide opportunities and benefits to the local economy especially in town centres, whilst having regard to the wider environment.

Indictor: Key Performance Indicators from the West London Retail Needs Study December 2006

Outcome

Figure 7: Key Performance Indicators for the Borough’s Four Town Centres

8.18 The Key Performance Indicators shown in Figure 7 above highlight some clear contrasts in the roles and performance of the Borough’s four town centres.

76 8.19 Hounslow has the most retail floorspace despite Chiswick containing a larger number of units. This reflects the contrast between the presence of large multiples in Hounslow and the boutique style shopping provision in Chiswick.

8.20 Comparison retail (clothes and goods) provision is most significant in Hounslow at 41.7% but only 4% higher than Chiswick. Feltham and Brentford have significantly lower proportions at 28.4% and 22.4% respectively, reflecting their district status. As a consequence Hounslow dominates the comparison goods market share in the Borough at 21%, and this is in part reflected that Hounslow is the only town centre to contain a department store.

8.21 Another key indicator of the economic prosperity of the Borough’s town centres is the proportion of vacant units, which at approximately 15% in Feltham and Brentford is twice that of Chiswick and three times that of Hounslow. However, the circumstances behind these figures are very different. In Feltham the higher vacancy rate is likely to reflect the recent completion of new retail floorspace that has yet to be filled. In contrast other indicators suggest a gradual decline in the performance of Brentford as a District centre. The Council recognises that new development is needed to revitalise the town centre and has sought to deliver this through a Brentford Area Action Plan.

8.22 A further indicator as to the role of the town centres in the local economy is the proportion of those visiting the centre for work/ business activities. None of those surveyed for the West London Retail Needs Study gave this as reason for visiting Hounslow town centre. However in Brentford and Chiswick, 20% and 15% of visitors respectively gave business/ work as the sole reason for their visit perhaps reflecting their proximity to key office locations on the Great West Road and at Chiswick Park.

77 UDP Objective S.2

To maintain and enhance local shopping parades to give good quality, convenient and accessible facilities for all residents.

Local Indicator(s)

UDP Policy S.2.1 Non-Retail Uses in Minor Neighbourhood Centres and Key Local Parades

Purpose: To protect parades which meet the essential and local shopping requirements of local communities. Inappropriate non-retail uses can weaken the attractiveness of a centre and threaten the feasibility of existing retail uses from an economic standpoint.

A. Use of Policy S.2.1 in Planning Decisions and Appeal Decisions

Planning Decisions Appeal Decisions Approved Refused Allowed Dismissed 4 6 0 0

B. Policy Outcomes

Target: Retaining shops of an appropriate type, number and quality, which provide for the day-to-day needs of local residents.

Indicator 1: Planning decisions for non-retail uses in minor neighbourhood centres and key local parades quoting policy S.2.1 (see Appendix 25)

Outcome 8.23 There were four approvals and six refusals in relation to changes of use from retail to non- retail in minor neighbourhood centres and key local parades.

8.24 The approval for a change of use from a vacant travel agent’s (A1) to a hot food takeaway (Planning ref 00139/178/P5) was approved, as the existing use was not seen as providing an essential service to local residents.

8.25 Two applications for changes of use from A2 (financial and professional services) to restaurants (A3) were approved. A proposal on Vicarage Farm Road in Hounslow was approved on its fourth application, having reduced the size of the development. As the proposal would have been the only restaurant on the parade, it was seen to have no affect on the neighbours or the character or viability of the key parade. Another change of use on the Great West Road (Planning ref: 00505/508/P1) was approved as it was not considered harmful to the retail function of the parade.

8.26 The final approval under policy S.2.1 (Planning ref: 00550/F/P14) was for the change of use of an MOT service centre to a car rental business. The key issue in this application was the effect on neighbouring residents rather than the impact on retail function and day- to-day needs.

8.27 Only two of the refusals quoting policy S.2.1 related directly to the effect of the proposed change of use on the function of the parade. A proposed change of use from retail to residential on South Street in Isleworth (Planning ref: 01031/3/P2) was refused because it would introduce a ‘dead frontage’ into the parade that could jeopardise its vitality. The change of use of retail unit on Thornbury Road, Isleworth (Planning ref: 01119/159/P8)

78 was similarly refused on the principle that it was the only remaining unit in the parade providing for the ‘day to day’ need of the local community.

8.28 The remaining four refusals under policy S.2.1 related to criteria other than that of providing diversity and serving local need.

Indicator 2: Appeals quoting policy S.2.1.

Outcome: 8.29 There were no appeals in the financial year of 2006/07 that quoted policy S.2.1.

UDP Policy S.2.2 Non-retail uses in other shopping areas

Purpose: To protect parades and shops which meet the essential and local shopping requirements of local communities

A. Use of Policy S.2.2 in Planning Decisions and Appeal Decisions

Planning Decisions Appeal Decisions Approved Refused Allowed Dismissed 7 8 1 1

B. Policy Outcomes

Target: No loss of retail units except in accordance with policy

Indicator 1: Planning decisions for non-retail uses in other shopping areas quoting policy S.2.2 (see Appendix 26).

Outcome 8.30 There were seven approvals and eight refusals in the 2006/07 financial year quoting policy S.2.2. There were two approvals for the change of use of retail unit to residential (Planning refs: 01217/67/P12 and 00702/138/P9). In both cases the retail units adjoined other residential properties, and had been vacant for some time therefore not contributing to local shopping needs. A third vacant retail unit was also proposed for a change of use to a chauffeuring and office business (Planning ref: 00505/AV1/P3) because it had lay vacant for some time. The change of use of an occupied retail unit (Planning ref: 01054/487/P10) was also approved because the proposal was not seen to undermine the retail function of the parade. A fifth approval was deemed acceptable, as there were alternative services within 400m of the existing site.

8.31 In the two remaining approvals the protection of essential and local shopping requirements is not the key issue. The approval for a change of use at 30 Bell Road Hounslow (Planning ref: 00108/38/P1) should have been assessed against policy S.1.4 because although the unit is not within the primary or secondary frontage, the unit lies within Hounslow town centre. The other was for the extension to the existing residential unit (Planning ref: 00724/36/P1) that was assessed under policy S.2.2 because of the potential for the proposed development to detract from the retail frontage.

8.32 Of the eight refusals quoting policy S.2.2, three of them included reasons relating to retail function or local service provision. Of these three, two applications related to the same site on Twickenham Road, Isleworth (Planning ref: 01137/193/P7 and 01137/193/P8) with one proposing a change of use to a restaurant and the second for a takeaway. The effect of the proposal in diminishing the main retail function of the parade was cited as a reason

79 for refusals in both applications. The application for the restaurant was also unsuccessfully appealed. The Planning Inspector agreed with the Council’s assessment that the change to A3 use may well result in making the parade even less attractive for their day-to-day needs. The third proposal in Strand on the Green (Planning ref: 01076/108/P3) for a change of use of newsagents to a takeaway was refused because in its present form, the premises were used as a newsagents and deemed to serve the needs of local residents who otherwise would have walk further to access another convenience shop.

8.33 The remaining five applications were refused under policy S.2.2 because the proposed change of use would have a negative impact on neighbouring amenity and/or because of issues relating to parking and traffic.

Indicator 2: Appeals quoting policy S.2.2 (see Appendix 27)

Outcome 8.34 There were two appeals quoting policy S.2.2 in the financial year of 2006/07, one of which was approved and the other dismissed.

8.35 The appeal at 35-41 London Road (Planning ref: 00707/35-41/P5) for the sub-division of a retail unit from A1 to A1 and A3 uses was allowed by the Planning Inspector. The Council did not use an objection to the principle of a change of uses to A3 as a reason for refusal but did identify the principle of a change of use as being unacceptable in their submitted appeal statement. The inspector commented in his statement that the proposal would retain an A1 retail shop that would be utilised more efficiently. The main issues considered by the inspector were therefore the impacts of the proposal on residential amenity and highway safety. The inspector considered that both issues could be resolved through planning conditions.

8.36 The key issue in the dismissed appeal for the change of use of an A1 computer shop to an A5 takeaway (Planning ref: 01137/219/P4) was highway safety caused by patrons searching for parking spaces. Contrary to the Council, the Inspector considered that the proposal would not have a negative effect on the balance of retail to non-retail and identified that there were no existing takeaways in the parade.

80 UDP Objective S.3

To maintain and enhance the role of the Borough’s town centres by channelling new retail development into existing centres which will result in a more sustainable pattern of development in the Borough.

Core Indicator(s)

4a Amount of completed retail, office and leisure development

8.37 The use classes shown below in Figure 8 defines the retail, office and leisure developments included within this core indicator:

Figure 8: Definition of Retail, Office and Leisure Uses in Core Indicator 4a

Use Class Description of Development

Retail A1: Shops The retail sale of goods to the public – shops, post offices, travel and ticket agencies, hairdressers, funeral directors, domestic hire shops, dry cleaners, sandwich bars and internet cafes. A2: Financial and Financial services: banks, building societies and professional services bureau de change. Professional services (other than health and medical services) – estate agents, employment agencies and betting shops. Office B1a: Business Offices, other than a use within Class A2. Leisure D2: Assembly and Cinemas, dance and concert halls, sports halls, Leisure swimming baths, skating rinks, gymnasiums, bingo halls and casinos. Other indoor and outdoor sports and leisure uses, not involving motor vehicles of firearms.

8.38 Table 26 below shows that 57,279m2 of gross retail, office and leisure floorspace has been completed within the Borough during 2006/07, of which the majority (66%) is for office uses (B1a).

Table 26: Amount of completed retail, office and leisure in schemes proposing over 500m2 of floorspace

Use Class Amount of floorspace developed (m2) A1 18,419 A2 0 B1a 37,446 D2 1,414 Total 57,279

4b Percentage of completed retail, office and leisure development in town centres.

8.39 Table 27 shows that the proportion of completed retail floorspace within town centres in the 2006/07 financial year was high at 88%. All of the town centre floorspace was

81 provided as part of the redevelopment of Feltham town centre. The remaining retail development was provided as an extension to Ivybridge Retail Park, Isleworth and as ancillary floorspace within the Chiswick Park office development.

8.40 Only 7% of class B1a offices completed was within an existing town centre as part of the redevelopment of Feltham town centre. The most significant proportion (87.5%) was part of the ongoing development of Chiswick Park, a suburban office park and established employment on the edge of Chiswick town centre. The remaining out of centre floorspace was provided as ancillary offices in a warehousing development and through the redevelopment of an existing office building for employment and residential uses.

8.41 The only D2 development completed in the financial year was the erection of an extension to an existing school to provide recreation and changing room facilities.

Table 27: Percentage of completed retail, office and leisure development in town centres

Percentage of completed retail, office and leisure Use Class development in town centres

A1 88% A2 Not applicable – no completed development B1a 7% D2 0%

Local Indicator(s)

UDP Policy S.3.1 New Retail Development

Purpose: To channel new retail development into town centre locations, edge of centre, major and minor neighbourhood centres and only out of centre or out of town in exceptional circumstances.

A. Use of Policy S.3.1 in Planning Decisions and Appeal Decisions

Planning Decisions Appeal Decisions Approved Refused Allowed Dismissed 8 0 0 0

B. Policy Outcomes

Target: Sequential approach demonstrated in accordance with PPS6.

Indicator 1: Planning Decisions quoting policy S.3.1 (see Appendix 28)

Outcome 8.42 There were eight approvals and no refusals quoting policy S.3.1 in the 2006/07 financial year.

8.43 The Wallis House development on the Great West Road (Planning ref: 00505/P/P59) was the largest of the new retail developments as part of larger mixed- use redevelopment of a vacant employment site also including offices and over 700 residential units. This was approved out-of-centre due to the size of the comprehensive nature of the development.

82 The application did not propose to simply create new retail floorspace, but offices and residential as well, which would therefore provide for the large numbers of people that will eventually work or live at the development.

8.44 There were two proposals for the subdivision of units to create further retail developments. One was for the selling of alcohol and sundry items on the existing premises (Planning ref: 00707/AL/P16) which was approved as there would not have been any additional retail floorspace provided, and the nature of the proposed retailer Majestic Wine, sell in bulk, therefore the location of the development would not be best suited to a town centre location. The other approval (Planning ref: 00707/317-331/P6) was for the subdivision of an existing unit to provide two new retail units. The additional units were approved, as there was not considered to be any appreciable increase in the level of activity associated with them.

8.45 Three proposals were for the change of use of non-retail uses to retail. One application was the proposal for the change of use to a hairdresser (Planning ref: 00328/R/03/P1), which due to the nature of the activity and the small size of the unit was considered acceptable despite not being in a town centre. The application also had a condition imposed upon it stating that the unit only had permission for use as a hairdresser. The second proposal for the change of use was from five live/work units to commercial units (Planning ref: 01254/179-183/P4). With sufficient information, the application was approved as it was thought that the live/work use of the building was no longer viable. The third application was for the redevelopment on the edge of Brentford town centre that would include A3 and A2 uses on the ground floor. The applicant did provide a sequential test. However the planning officer identified that the town centre was fully occupied in terms of A3 provision and on that basis the application site in a edge of centre location would be sequentially preferable. The proposed A3/A2 development is also modest in terms of floorspace and will restore the small-scale historical restaurant and shop frontage of the ground floor of this site at the entrance to the High Street, helping to re-activate the existing ‘dead’ ground floor fascias.

8.46 An application for the use of Belmont Primary School as a farmers market on Saturdays was also approved under policy S.3.1. The temporary nature of the market, which is to be comprised of small stall holdings with goods brought to the site and removed at the close of the market, restricts suitable sites to areas with large open spaces. Suitable and viable spaces are lacking in the town centre so making use of the school grounds, which adjoins the town centre, is appropriate. The farmers’ market itself would add to the vitality and viability of the nearby town centre through adding to the number and variety of food sellers.

8.47 The final application was a proposal for the variation of a condition for delivery times set upon Tesco Express on the London Road. This did not require the application of the sequential test.

Indicator 2: Appeals quoting policy S.3.1

Outcome 8.48 There were no appeals quoting policy S.3.1 in the 2006/07 financial year.

83 Summary of UDP Shopping Policy Implementation

8.49 An assessment has been made on the implementation of policies and analysis of the decisions has enabled the Council to determine whether there is a need for amending or replacing policies.

Policies S.1.2, S.1.3 and S.1.4 8.50 A key issue arising from an appeal decision were the inspector’s comments that they had not been provided with any detail on the extent of the designated shopping frontage or the criteria that had led to that designation to inform their decision. This highlights the need to use evidence from existing retail monitoring in the decision making process, as well as the need to develop future policies with a clear and accessible evidence base.

8.51 In another appeal, policy S.1.4 has been used to refuse a change of use because it would have resulted in an increase in non-retail uses. However, because the policy does not identify that an increase in the proportion of non-retail uses could not be considered in isolation from the impact of the change on the retail function of the parade, the inspector did not consider the issue in his decision.

Policies S.2.1 and S.2.2 8.52 The aim of these policies is to protect local shopping provision and particularly those shops which serve a local need. In accordance with policy the likely impact of the loss of the current use i.e. essential local shops such as newsagent or chemist, and has been the key issue in determining proposed changes of use.

Policy S.3.1 8.53 For all retail applications outside of one of the Borough’s town centres it was demonstrated that there were no sequential preferable sites available for the proposed development.

84 9. COMMUNITY AND LEISURE

CONTEXTUAL INDICATORS

Ethnicity 9.1 According to the 2001 census, there were 74,587 people (35%) living in the London Borough of Hounslow from minority ethnic communities. The Borough has a higher number of non-white ethnic minority residents (35%) compared to outer London (25%) and London (29%), and significantly higher than England (9%). Within Hounslow, the Central Hounslow (53%) and Heston and Cranford areas (63%) have the largest of non-white residents compared to others.

Religion 9.2 The wide range of faith groups in the Borough is manifested through the diversity of places of worship throughout the Borough – churches, chapels, gurdwaras, mosques, synagogues and temples. The Census 2001 found 52% of residents said they were Christian, but there were significant proportions of the population who were Muslim (9%), Sikh (9%) and Hindu (8%).

Deprivation 9.3 The Indices of Multiple Deprivation 2004 (IMD 2004) combine information on income, employment, education, health, skills and training, barriers to housing and services, and crime to provide an overall measure of deprivation at the local level. On this basis the most deprived areas in the Borough were identified in the wards of Bedfont, Brentford, Hanworth, Heston West and Syon. The wards of Feltham West, Hanworth and Isleworth are in the top 10% most deprived area in England, which equate to 15.7% of people residing in the Borough

Life Expectancy at Birth 9.4 The life expectancy in Hounslow was 80.2 years for women and 76.2 years for men. Male life expectancy is slightly lower than the average for England and whilst generally increasing over time its rate of increase is slower than for England. Female life expectancy is also lower than the average for England and has shown no real increase in recent years. Life expectancy in the most deprived areas for males and females is 74.0 and 80.3 years, 4.3 and 1.3 years less than the least deprived areas. The rate of early deaths from heart disease and stroke is higher than the England average and is decreasing more slowly than in England.

85 OUTPUT INDICATORS

UDP Objective C.1

To protect, improve and promote the provision of accessible community and religious meeting places, particularly in town centres, and to cater for the needs of all of Hounslow’s communities.

Local Indicator(s)

UDP Policy C.1.3 Existing Social and Community Facilities

Purpose: To resist the loss of existing social and community facilities (such as community centres, youth clubs and public houses)

A. Use of Policy C.1.3 in Planning Decisions and Appeal Decisions

Planning Decisions Appeal Decisions Approved Refused Allowed Dismissed 0 3 0 0

B. Policy Outcomes

Target: No net loss except in accordance with policy

Indicator 1: Refusals quoting policy C.1.3 (see Appendix 29).

Outcome: 9.5 There were three refusals quoting policy C.1.3, all for the same site on Prince of Wales Terrace in Chiswick (Planning refs: 00895/B/P5, 00895/B/P6 and 00895/B/P7). In all cases the loss of community facilities on the site was resisted because no assessment of the potential alternative community uses for the existing building had been submitted with the applications.

Significant Effects

Sustainability Objective 4: To improve opportunities for developing community cohesion through increasing understanding and learning between our many communities.

Indicator: Percentage of residents that agree that their local area is a place where people from different backgrounds get on well together (Source: Hounslow Residents’ Panel Surveys, February 2004 and June 20056).

Outcome 9.6 In the June 2005 survey, 61% of respondents agreed that their local areas is a place where people from different backgrounds get on well together, whilst 22% disagreed with

6 The London Borough of Hounslow’s Residents’ Panel has been running since 2003. The purpose of the panel is to provide a co-ordinated and cost-effective approach to public consultation. The panel is made up of 2000 Hounslow residents, who are selected at random to be representative of the community and who have agreed to take part in up to 4 surveys a year, as well as in some focus group sessions.

86 this assertion. This represents a significant decrease from the February 2004 survey when 84% of respondents agreed with this statement, whilst only 9% disagreed.

Sustainability Objective 7: To reduce discrimination and promote equality of opportunity and fair treatment for all our communities

Indicator 1: BVPI 174 - The number of racial incidents reported to the local authority, and subsequently recorded, per 100,000 population.

Outcome 9.7 The return for 2006/07 showed that there were 203 racial incidents per 100,000 population. This represents an increase from 148 incidents in 2006/07 and is in above the Council’s target of 150. The outturns for the last three financial years shows that the number of racial incidents is fluctuating and no overall trend is discernible.

87 UDP Objective C.2

To ensure the distribution of education facilities throughout the Borough relates to local needs and to ensure the widest community use of education facilities.

Significant Effects

Sustainability Objective 8: To improve the education and skills of the overall population

Indicator: BVPI 38 - Percentage of 15 year old pupils in schools maintained by the local education authority achieving five or more GCSEs at grades A*-C or equivalent.

Outcome 9.8 The outturn for the 2006/07 financial year was 62.7%. This represents a 5.1% increase on the previous year’s performance and is 4.2% above the national average. This places Hounslow in the top 25% of London authorities.

Sustainability Objective 23: To improve accessibility for all section of the community to jobs, education, skills training and lifelong learning.

Indicator: Qualification Levels Jan 2006 – Dec 2006 (Source: NOMIS, ONS, 2007)

Outcomes 9.9 The proportion of Hounslow residents of a working age with no qualification during the calendar year 2006 was 11.2 %. This was below both the London and national averages of 13.9 % and 13.8 % respectively. The figure for 2006 was an improvement on the 2005 figure where 12.5% of Hounslow residents held no formal qualification. Again this was below the London and national averages of 14.3% and 14.3% respectively.

9.10 The proportion of residents of a working age with NVQ level 4 qualification equivalent qualifications (HND, degree and higher degree) was 32.6%. This proportion was above the national average by 5.2%, but 2% below the London average of 34.6%. There has been a 4.4% increase in the proportion of people with NVQ level 4 qualification equivalent qualifications in comparison to 2005 where only 28.2% of residents of a working age held this type of qualification.

88 UDP Objective C.3

To ensure the adequate provision and design of community services by statutory undertakers and other agencies, appropriate to the needs of the Borough, subject to environmental considerations.

Significant Effects

Sustainability Objective 1: To maintain and improve the health of the population in the Borough.

Indicator: Life expectancy (Source: Neighbourhood Statistics, 2007)

Outcome 9.11 There has been an improvement in the health of the population in the Borough. The trend in life expectancy figures at the Borough level has increased in line with London and England figures.

9.12 The Office of National Statistics (ONS) provides an estimate of life expectancy at birth. The figures highlighted in Table 28 are a three-year average produced by combining deaths and population estimates for a three-year period. The borough level figures indicate that life expectancy at birth for males and females has increased since the period 2001 to 2005.

Table 28: Life expectancy at birth

Life expectancy at birth: Male Life expectancy at birth: Female Hounslow London England Hounslow London England January 2001 to December 2003 75.4 76 76.24 79.8 80.8 80.72 January 2002 to December 2004 75.7 76.5 76.55 79.9 81.1 80.91 January 2003 to December 2005 76.2 76.9 76.92 80.2 81.4 81.14 (Source: Neighbourhood Statistics, 2007)

89 UDP Objective C.5

To promote and facilitate the provision of sport and leisure facilities which are accessible to all members of the community, and to protect, and where necessary, increase the provision of open space.

Core Indicator(s)

4a Amount of completed leisure (D2) development respectively

9.13 Total amount of completed leisure (D2) development in the 2006/07 financial year was 1,414 square metres. The completed development was for the erection of new changing rooms, community facilities and a multi use games area for a school.

4b Percentage of completed leisure development respectively in town centres

9.14 None of the leisure development completed in the 2006/07 financial year was within one of the Borough’s four town centres.

Local Indicator(s)

UDP Policy C.5.1 New Leisure Development

Purpose: To apply the sequential test whereby new leisure development, in particular high trip generating leisure uses, should be located within existing town centres. Where town centre sites or buildings suitable for conversion are not available, edge of centre sites, followed by district and local centres should be considered next.

PPS6 also places new emphasis on local planning authorities to promote and enhance existing town centres by encouraging the overall diversification of uses, and by ensuring the provision of tourism, leisure and cultural activities. The community and leisure uses that PPS6 identifies as main town centre uses, and to which policies apply are: • Leisure, entertainment facilities, and the more intensive sport and recreation uses (including cinemas, restaurants, night-clubs, casinos, health and fitness centres, indoor bowling centres and bingo halls • Arts, culture and tourism facilities (theatres, museums, galleries and concert halls, and conference facilities. The sequential approach to site selection will apply to each of the community and leisure uses listed above.

A. Use of Policy C.5.1 in Planning Decisions and Appeal Decisions

Planning Decisions Appeal Decisions Approved Refused Allowed Dismissed 0 0 0 0

B. Policy Outcomes

Target: New leisure development to be in accordance with the sequential test.

Indicator 1: Approvals for new leisure developments quoting policy C.5.1 (see Appendix 30)

90 Outcome 9.15 There were no approvals for new leisure developments quoting policy C.5.1 in the 2006/07 financial year.

91 UDP Objective C.6

To promote and protect the provision of arts, cultural and entertainment facilities in the Borough.

Core Indicator(s)

9.16 See Core Indicators 4a and 4b under Objective C.5 on page 88.

92 Summary of UDP Community and Leisure Policy Implementation

9.17 Policy C.1.3 has been used effectively in the case of all three refusals where the applicant has failed to demonstrate the potential for alternative community uses has been fully explored.

9.18 There have been no applications for new leisure uses during the 2006/07 financial year.

93 10. PLANNING OBLIGATIONS

OUTPUT INDICATORS

UDP Objective IMP.6

To encourage the provision of appropriate planning obligations in association with new development.

Local Indicator(s)

Legal Agreements signed in 2006/07 10.1 Table 29 shows that 26 legal agreements including Unilateral Undertakings and Deeds of Variation were signed during 2006/7.

10.2 Of those that required financial obligations the total value of contributions secured exceeded £5.1 million (see Table 30 for breakdown).

Table 29: Total Number of Agreements Signed

Type of Agreement No. S106 20 Deeds of Variation 1 Unilateral Undertakings 5 Total No. of Agreements signed: 26

Table 30: Financial Contributions contained within Legal Agreements signed in 2006/07

Type Value Amenity/Open Space £917,000 Public Transport £875,928.09 Education £1,359,000 Environmental Improvements £437,876.51 Employment & Training £415,079.77 Highways/Parking £363,700 Adult Learning Disability Centre £250,000 Air Quality £60,000 Community Infrastructure & Programmes £300,000 Health £200,000 Total Value £5,178,584.37

10.3 In addition to financial contributions various other community benefits have been secured in line with the UDP policies and with the priorities in the Community Plan. These include Car sharing schemes, over 700 affordable housing units (see Table 33) and nature conservation provision.

94 Value of benefits received

10.4 Table 31 below identifies the total financial contributions received by category of contribution during the financial year 2006/7. This totalled £1,976,243.56

Table 31: Benefits received by category through S106 agreements based on monies received in 2006/07

Contribution Category Value Environmental Improvements £488,613 Parking & Traffic Management £303,296.93 Amenity Space £33,257 Education £105,212 Public Transport £394,895 Employment /Training £11,461 Affordable Housing £54,545 Street Lighting £11,184 Play club/youth projects £40,000 Shopmobility £55,000 Tree Planting £700.00 Music Museum £331,124 Triangle £146,955.63 Total £1,976,243.56

Table 32: Benefits delivered by category through S106 agreements based on spend in 2006/07

Area of Spend Value Environmental Improvements £60,110.44 Parking & Traffic Management £197,596.41 Parks & Open Space/ Leisure £409,345.33 Education £15,245 Employment/Training £41,705 Housing other £80,089 CED £343,227 Total £1,147,318.18 Note: Table 33 shows S106 monies spent in 2006/7, which were not necessarily received in 2006/7.

Affordable Housing 10.5 Five S106 agreements were signed during the year containing an element of affordable housing at the following locations:

Table 33: Provision of Affordable Housing Units Contained within Legal Agreements signed in 2006/07

Location Number of affordable Units Wallis House, Great West Road, Brentford 355 455 London Road, Isleworth 174 139-147 Hanworth Road Hounslow 46 26 Glenhurst Road Brentford 41 Brunel University Campus, Borough Road, Isleworth 156 Total 772

10.6 The Council’s affordable housing policy (Policy H.2.1) also allows for payments in-lieu for the provision of affordable housing in exceptional circumstances. During the 2006

95 financial year a total of £135,532.00 was received towards affordable housing secured through legal agreements.

Table 34: Affordable Housing S106 Financial Contributions received during 2006/07

Opening Balance 2006 £4,479,971 Receipts during 2006/7 £135,532 Closing Balance £4,615,503

96 11. ENVIRONMENTAL PROTECTION

CONTEXTUAL INDICATORS

Noise Pollution 11.1 Noise is a problem for many residents in Hounslow. In addition to noise generated from flights in and out of Heathrow airport (there are approximately 471,000 flights per annum), road traffic is also a major contributor to noise pollution across the Borough.

Air Quality 11.2 The majority of air pollution within London Borough of Hounslow comes from transport sources, associated with busy or congested roads including the A4, M4, A30 and the use of cars, delivery vehicles and heavy goods vehicles related to the close proximity of Heathrow airport. In the west of the Borough, the level of air pollution is dominated by the presence of Heathrow airport.

11.3 Hounslow exceeds the Nitrogen Dioxide levels set by the National Air Quality Strategy. Council policy aims to reduce the level of specific pollutants, especially those associated with road traffic. The whole borough is now classified as an Air Quality Management Area (AQMA). An AQMA is an area where one or more air quality objectives are not expected to be met unless action is taken to improve air quality.

11.4 Currently, carbon monoxide, sulphur monoxide and ozone levels in the Borough do not exceed EU targets, and existing policies are seen to be sufficient. The levels of these pollutants are not considered a priority for local air quality management in Hounslow.

Gas and Electricity Consumption 11.5 Average domestic gas and electricity consumption was 18,684 kWh and 4,345 kWh respectively. This pattern of consumption was higher than the London average but somewhat lower than the typical consumption at the regional and national level.

Waste 11.6 The number of kilos of household waste collected was 500 per head of population which is above the London wide average. The West London Waste Authority’s (WLWA) Joint Municipal Waste Management Strategy, which was endorsed by Hounslow in September 2006, commits Hounslow to recycling and composting 40% of waste by 2010.

97 OUTPUT INDICATORS

UDP Objective ENV-P.1

To protect residents and workers in the Borough from further detrimental effects due to noise, poor air quality, contaminated land and general environmental pollution.

Significant Effects

Sustainability Objective 5: To reduce as far as practicable noise from all sources

Indicator: Percentage residents who think that noise pollution is a slight or serious problem in their local area (Source: Hounslow Residents’ Panel Survey - March 2004 and June 2006).

Outcome 11.7 Certain sources of noise were listed on the survey sent out to panel members who were asked to rate the seriousness of each type of noise in their local area. In both surveys aircraft noise is most frequently described as a problem by approximately 80% of all respondents in both surveys. The noise created by road traffic and road works are the second and third most significant sources and the percentage of panel members considering them to be a problem has increased over the two-year period between surveys.

Table 35: Sources of noise pollution in the local area

Source March 2004 March 2006

Aircraft 79% 80%

Road Traffic 65% 72%

Road works 45% 48%

Neighbours 35% 36%

Dogs and other animals 35% 35%

Construction/Demolition 27% 32%

Pubs, clubs and other 19% 20% entertainment Industrial/Commercial 16% 16% premises

Trains 15% 15% (Source: Hounslow Residents’ Panel Survey)

Sustainability Objective 16: To improve air quality in the Borough

Indicator: Air quality objectives achieved (2006)

Outcome 11.8 The Council’s Air Quality Action Plan progress update (2006) shows that 16 out of 20 air quality objectives for 2006 were achieved (see Appendix 30).

UDP Objective ENV-P.2

To promote the conservation of resources, including energy, by promoting and providing facilities to support a comprehensive and sustainable waste management strategy for the Borough.

Core Indicator(s)

6a Capacity of new waste management facilities by type

11.9 No new waste management facilities were approved or completed in the Borough during the 2006/07 financial year.

6b Amount of municipal waste arising, and managed by management type

11.10 Table 36 provides a summary of the composition of municipal waste managed by type. The total amount of municipal waste collected in the financial year was 116,509 tonnes. This represents a 1.2% increase on the outturn of the previous financial year.

Table 36: Municipal Waste Arising by Type (Source: LBH Recycling Team)

Muncipal Waste by Type Amount of waste Percentage of total (tonnes) Collected household waste 79,417 68.16 Collected trade waste 10,198 8.75 Collected Clinical (domestic) waste 33 0.03 Street Cleansing waste 6,115 5.25 Council Offices waste 8 0.01 Collected Recycled waste 16,578 14.23 Collected Composted waste 4,160 3.57 TOTAL 116,509 100%

9. Renewable energy capacity installed by type

11.11 Table 37 summarises renewable energy technologies installed in the Borough in 2006/07.

Table 37: Renewable Energy Installed by Type Location Renewable Energy Quantity Capacity Type (MW/hr) Cranford Community Wind turbine 2 0.012 MW/hr College Sunbury Road, Feltham Wind turbine 1 Not available

99 Local Indicator(s)

UDP Policy ENV-P.2.6 Renewable Energy/ London Plan Policies 4A.7 and 4A.9

Purpose: Promote and encourage the uses of renewable energy in new and existing developments.

A. Use of Policy ENV-P.2.6/ London Plan Policies 4A.7 and 4A.9 in Planning Decisions and Appeal Decisions

Planning Decisions Appeal Decisions Approved Refused Allowed Dismissed 2 4 0 0

B. Policy Outcomes

Target: Strategic developments7 that are referable to the Mayor of London are expected to reduce carbon emissions from the total energy needs of the proposal (heat, cooling and power) by at least 10% from on-site generation of renewable energy. London Plan policy 4A.9 also encourages boroughs to require all major developments8 to show how the development would generate a proportion of the site’s electricity or heat needs from renewables, wherever feasible.

Indicator 1: Strategic developments granted full planning permission in 2006/07 (see Appendix 31)

Outcome 11.12 There were two strategic development proposals granted full planning permission (with Legal Agreements approved) in 2006/07: • Brunel University, Osterley Campus redevelopment • Wallis House

11.13 Appendix 31 shows that both these developments met the London Plan’s requirements to provide 10% of energy from renewable sources.

11.14 The Council has also included planning conditions for a 10% reduction of carbon emissions and the on site generation of energy if appropriate, in full permissions for the following major development proposals (see Appendix 32): • 139-147 Hanworth Road • Chiswick War Memorial Homes • Thorncliffe Hotel, North Hyde Lane

11.15 Two proposals from the previous year with conditions relating to the provision of renewable energy – Ramada Jarvis hotel and Western International Market - both submitted reserved matters applications that were subsequently approved for demonstrating that 10% of the development’s energy requirements would be met by onsite renewable energy.

7 Examples include large developments proposing 500 or more dwellings, 15,000 m2 of commercial floorspace, buildings over 25 metres high adjacent to the River Thames and buildings over 30 metres high elsewhere, developments within the Thames Policy Area and developments that would increase the height of an existing building by more than 15 metres. 8 Major developments are defined as those where 10 or more dwellings are proposed and where 1000m2 of floorspace is proposed for all other uses.

100 Indicator 2: Refusals quoting UDP policy ENV-P.2.6 and/or London Plan policies 4A.7 and 4A.9 (see Appendix 33).

Outcome 11.16 There were four refusals in the 2006/07 financial year quoting either London Plan or UDP renewable energy policies. In all cases the reason for refusal was the failure to provide sufficient detailed to assess how a proportion of each development’s total energy needs would be provided from onsite renewable energy sources.

Significant Effects

Sustainability Objective 11: To ensure the quantitative and qualitative conservation of resources (soil, mineral aggregates, water, energy)

Indicator: Ecological Footprint of the Borough9

Outcome 11.17 The ecological footprint of each of Hounslow’s residents has been calculated as 5.32 global hectares per capita (Source: Stockholm Environment Institute, 2006). Figure 9 provides a breakdown of the activities that contribute most significantly to each resident’s ecological footprint. The sustainable global footprint for each resident is 1.8 global hectares per capita. If everyone in the world were to consume natural resources and generate carbon dioxide at the same rate as the residents in Hounslow, we'd need three planets to support us.

Figure 9: Ecological Footprint for Hounslow

Government and Other 4 Capital Investment Holiday Activities Services 3 Consumables Housing Land Travel 2 Energy Food and Drink Ecological Footprint (gha/cap)

(Source: Stockholm Environment Institute, 2007)

9 An ecological footprint is a measure of the number of global hectares ‘required to produce the food, fibre and minerals we consume, absorb the waste we produce (including carbon dioxide emissions), and provide the space for our infrastructure’ (WWF-UK, 2006). A global hectare is one hectare of biological productive space with world-average productivity

101

Sustainability Objective 15: To reduce negative contributions to climate change

Indicator: Carbon Dioxide Emissions

Outcome 11.18 The release of carbon dioxide into the atmosphere as a result of human activity is also thought to have led to changes in the Earth’s climate. Local estimates of domestic carbon dioxide emissions in Hounslow in 2004 total 495 kilo tonnes per annum, or 2.3 tonnes per person. This compares to a Greater London average of 2.4 tonnes per person. Domestic emissions account for approximately one third (495 kilo tonnes) of the Borough’s total emissions (Source: Defra, 2006).

Sustainability Objective 17: To minimise the production of waste

Indicator: BVPI 84a - Number of kilograms of household waste collected per head of population.

Outcome 11.19 The outturn for 2006/07 shows that 500 kilos of household was collected per head of population. This represents an increase of 0.2% on the outturn of the previous financial year, and does not meet the Council’s target for 2006/07 of 480 kilos per capita.

102 UDP Objective ENV-P.3

To protect the environment and amenities of the residents whilst having regard to the need for minerals in the London area.

Core Indicator(s)

5a Production of primary land won aggregates

11.20 There were no primary land won aggregates produced in Hounslow during the financial year.

5b Production of secondary/recycled aggregates

11.21 There is one active aggregate recycling site at Brentford rail depot – Days Aggregates. The total output of recycled aggregates from this site in 2006/07 was 320,349 tonnes. This represents an increase in of 16% on the output of the previous financial year (Source: Day Group Ltd, 2007).

103 Summary of UDP Environmental Protection Policy Implementation

11.22 Policy ENV-P.2.6 promotes and encourages the use of renewable energy in new development. Whilst the wording of the UDP policy is not strong, it has been used with London Plan policy 4A.9 to require a 10% reduction of carbon emissions and the on site generation of energy if appropriate. The submission of details for reserved matters on planning conditions relating to renewable energy provision show that the policy is being successfully implemented.

11.23 In review of the policy as a part of the Core Strategy and Development Control policies, this will be considered to ensure general conformity with Policy 4A.7, 4A.8 and 4A.9. In the interim, the London Plan policies will continue to be used as they form part of the development plan for the Borough.

104 12. BUILT ENVIRONMENT

CONTEXTUAL INDICATORS

Conservation Areas 12.1 The Borough has 26 designated conservation areas.

Listed Buildings 12.2 There are 887 listed buildings in the Borough, including 60 Grade I structures, 35 Grade II* and 792 of Grade II status.

Scheduled Ancient Monuments (SAMs) 12.3 There are five SAMs within the London Borough of Hounslow. • Romano-British site, 910 metres west of East Bedfont Parish Church • Double ditched enclosure beside A30 road, 460 metre west of East Bedfont Parish Church • Kempton Park Pumping Stations, Hanworth • Pair of late 18th century garden features at Tudor House, Hanworth • Chiswick House, Chiswick

105 OUTPUT INDICATORS

UDP Objective ENV-B.1

To promote high quality design, urban design and a sense of place and identity throughout the Borough, and promote improvements which prioritise a safe, sustainable, accessible and pedestrian friendly environment for all.

Local Indicator(s)

UDP Policy ENV-B.1.4 Advertisements

Purpose: To ensure that advertisements are not detrimental to public safety, do not impinge upon residential areas, and action is taken against unauthorised advertisements.

A. Use of Policy ENV-B1.4 in Planning Decisions and Appeal Decisions

Planning Decisions Appeal Decisions Approved Refused Allowed Dismissed 86 21 1 5

B. Policy Outcome

Indicator 1: Key Issues in advertisement appeals (see Appendix 34).

Outcome 12.4 As in the 2005/6 financial year the majority of advertisement appeal decisions (five out of six) relate to sites along the Great West Road. Of the five appeals only one, for a temporary display at Gillette Corner (Planning ref: 00505/AF/A25) was allowed. In this case, the inspector disagreed with the Council that the proposal would be detrimental to visual amenity because their temporary nature and location at a major road intersection was acceptable.

12.5 The scale of advertisement hoardings was a prominent theme in four dismissed appeals for sites along the Great West Road. All of the proposals were for advertising towers that would be visible from the elevated M4. The impact of the structures at ground level on the surrounding street scene, often exacerbated by the illumination, was the common theme. In one case the inspector also highlight the potential distraction to drivers on the motorway (Planning ref: 01508/B/P9).

12.6 The principle issue in the remaining appeal for a display unit on Hanworth Road (Planning ref: 01254/359/AD2) was the effect on of unit on the amenity of the area. The inspector agreed with the Council’s view that the proposal’s excessive size, design and position would represent an overbearing and obtrusive feature that would not be compatible with the character of the site and appearance of the street scene and surrounding area.

ENV-B.1.7 Telecommunications

Purpose: To assess proposals for telecommunications equipment in terms of its operation requirements and impacts on the local environment.

A. Use of Policy ENV-B.1.7 in Planning Decisions and Appeal Decisions

106

Planning Decisions Appeal Decisions Approved Refused Allowed Dismissed 9 9 1 0

B. Policy Outcome

Indicator 1: Key issues in telecommunications appeals (see Appendix 35)

Outcome 12.7 There was a one telecommunications appeal during the 2006/07 financial year, which was approved. The appeal was for the installation of telecommunication equipment (Planning ref: 01239/292/P15) in the Isleworth Riverside Conservation Area. The inspector in his decision saw no objection to the proposal because its height and position near to the centre of the roof would prevent it being seen from surrounding roads or properties, therefore having no material effect on the Conservation Area.

Significant Effects

Sustainability Objective 2: To reduce crime and the fear of crime

Indicator: BVPI 126 Domestic Burglaries per year, per 1,000 households in the local authority area.

Outcome 12.8 The number of domestic burglaries per 1,000 households in 2006/07 was 18.78, which is below both the Borough target of 20.14 and the 2005/06 outturn of 20.75.

Sustainability Objective 9: To improve the quality of where people live

Indicator: Percentage of residents who are satisfied with their neighbourhood as place to live (Source: Residents’ Panel Survey – March 2005 and August 2006).

Outcome 12.9 Figure 10 shows that 60% of respondents are satisfied with their neighbourhood as a place to live, whilst 24% state that they are dissatisfied. This is similar to the results seen in March 2005 whereby 63% were satisfied, 13% were neither satisfied nor dissatisfied, and 22% were dissatisfied with their neighbourhood as place to live.

107

Figure 10:Satisfaction with your neighbourhood as a place to live

Very Sat isf ied 9% 17 %

Sat isfi ed 15 %

Neither satisfied or dissatisfied

16% Dissatisfied

43 % Very dissatisfied

Sustainability Objective 13: To promote regeneration that makes use of existing assets

Indicator: Percentage of new development on previously developed land

Outcome: 12.10 See Core Indicator 2b on page 42.

Sustainability Objective 18: Promote high quality urban design and the use of sustainable building materials where appropriate.

Indicator: Hounslow Reward Design 2007

Outcome 12.11 Hounslow’s first ever design awards were held this year with all developments completed before 1st July 2007 eligible for nomination. The judging took place in December 2007 with representatives from CABE Space, Design for London and Boyasky/Murphy Architects as well as the Borough’s Design Champion Councillor Barbara Reid. In the New Build category an award was given to the Heart of Hounslow Centre for Health for Best Public Building. A commendation was also given in the new build category for Mows, 1-4 Barley Mow Passage, Chiswick as for New Infill Building. In the Reuse of Existing Building category commendations were given to 46-48 The Grove for refurbishment in a Conservation Area, and to the Light Box, 111 Power Road, Chiswick for refurbishment and reuse of a building for employment use. In the Public Open Space category a commendation for landscape and play was given to Dukes Meadow Water Play Area, Chiswick.

108 UDP Objective ENV-B.2

To protect and enhance the built environment from the adverse implications of development, particularly views and landmarks, conservation areas, listed buildings, areas of townscape value, the built Thames landscape and other water features.

Local Indicator(s)

UDP Policy ENV-B.2.1 Designation of Conservation Areas and Boundary Review of Existing Areas

Purpose: To protect areas of special historic or architectural interest.

Targets: BVPI 219b - 100% of conservations areas in the local authority area to have an up-to-date character appraisal

Indicator: Percentage of conservation areas in the local authority area with an up-to-date character appraisal

Outcome 12.12 The Council produced character appraisals for all conservations areas during the financial year. The Council’s Sustainable Development Committee adopted the baseline appraisals for current use on 21 March 2006.

UDP Policy ENV-B.2.2 Conservation Areas (criteria ii)

Purpose: To preserve and enhance the character or appearance of existing (and proposed) conservations areas.

A. Use of Policy ENV-B.2.2 in Planning Decisions and Appeal Decisions

Planning Decisions Appeal Decisions Approved Refused Allowed Dismissed 10 13 4 17

B. Policy Outcomes

Target: There will be a presumption in favour of retaining any building in a Conservation Area.

Indicator 1: Approvals for the demolition of buildings within existing conservation areas (see Appendix 36).

Outcome 12.13 Of the 23 applications received for the demolition of buildings within conservation areas ten applications were approved and 13 were refused. In all cases the buildings approved for demolition were not of conservation interest, and without any particular architectural or historic merit to warrant their retention. Examples include the demolition of a shed as it was not judged integral to the character of the conservation area (Planning ref: 00847/48C/CA1) and the demolition of a bungalow that was in poor condition (Planning ref: 00222/A/CA2).

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UDP Policy ENV-B.2.4 Demolition of Listed Buildings

Purpose: The Council will resist proposals to demolish listed buildings and will closely scrutinise applicants’ evidence that all reasonable efforts have been made to preserve them either through an existing or new use.

Target: No loss except in accordance with policy

Indicator: Approvals for the demolition of listed buildings (see Appendix 37).

Outcome 12.14 A total of six demolitions relating to listed structures were approved in the 2006/07 financial year.

12.15 Approvals relate primarily to external alterations, or the demolition of extensions and outbuildings. There were no approvals for the total demolition of any listed structure.

Significant Effects

Sustainability Objective 19: To conserve and enhance the quality and character of the Borough’s landscape and townscape including the historic environment.

Indicator: Percentage of Listed Buildings at Risk

Outcome 12.16 The 2007 Register of Listed Buildings at Risk shows that 2% (19) of the Borough’s 887 listed buildings are at risk (see Appendix 37).

12.17 Table 38 below shows that the number and type of listed buildings at risk in the Borough has not changed during the 2006/07 financial year.

Table 38: Summary of Listed Buildings Risk by Grade

Grade Number at Risk Year 2005 2006 2007 I 1 1 1 II* 5 4 4 II 15 14 14

110 Summary of UDP Built Environment Policy Implementation

12.18 The decisions made by inspectors on proposed advertisements and telecommunication masts have been in accordance with policies ENV-B.1.4 and ENV-B.1.7 and the key issue has been the impact on the surroundings including amenity, character and appearance. It is not considered necessary to amend or replace the policies, which are in general conformity with national guidance/ regulations.

12.19 in terms of the conservation policies assessed (ENV-B.2.1, B.2.2 and B.2.4), all decisions have been made in accordance with the relevant UDP policies. Those applications approved for demolition or alterations to a listed building or a building in a conservation area have been acceptable on the basis that no harm would be caused or there was not sufficient architectural or historic merit for their retention.

111 13. NATURAL ENVIRONMENT

CONTEXTUAL INDICATORS

Parks and Open Spaces 13.1 Hounslow has approximately 1,238 hectares of publicly accessible open space, which includes 74 public parks and recreation grounds.

Priority Species and Habitats 13.2 Hounslow’s Biodiversity Action Plan (BAP) was launched in June 2003. The plan contains details of prioritised actions for protecting, conserving and enhancing wildlife and habitats. For species, the BAP identifies two Species Action Plans (SAPs) for Red Data Book Intertidal Snails (German Hairy and Two-lipped Door Snail) and Thames Terrace Invertebrates (principally bees and wasps of nutrient-poor and gravel soils). There are also eight Habitat Action Plans (HAP) covering the following habitats across the Borough: Lowland Heath and Acid Grassland, Rivers and Streams, Standing Water (Lakes and Ponds), Tidal Thames, Wasteland, Gardens and Allotments, Hedgerows, Parkland and Veteran Trees.

Areas Designated for their Intrinsic Environmental Value 13.3 It is estimated that 954 hectares of land in the Borough is managed either wholly or partly for nature conservation. Designated nature conservation sites within the Borough include:

Special Protection Areas and Ramsar Sites 13.4 Kempton Nature Reserve is part of the South West London Waterbodies SPA and also a Ramsar site. Ramsar sites are areas, which have been formally designated as Wetlands of International Importance. The SPA Directive 79/409/EEC on the Conservation of Wild birds applies to birds, their eggs, nests and habitats provides protection, management and control of all species of naturally occurring wild birds in the European territory or Member States.

Sites of Special Scientific Interest 13.5 Sites of Special Scientific Interest (SSSIs) are the finest sites for wildlife and natural features in England, supporting many characteristic, rare and endangered species, habitats and natural features. The purpose of SSSIs is to safeguard for present and future generations a series of sites, which are individually of high natural heritage importance. Many areas designated as SSSIs make important contributions to the local economy and often provide opportunities for people to enjoy and appreciate nature. Notification of a SSSI gives legal protection to nationally important sites for wildlife and geology. There are two SSSIs within the Borough in Kempton Nature Reserve and Syon Park.

Local Nature Reserves (LNRs) 13.6 LNRs are sites that have been identified as areas of high value to nature conservation. The land is managed for the purpose of preserving flora and fauna, geological or physiological features or to provide special opportunities for the study of matter relating to flora and fauna, geological and physiological features. There are about 160 hectares of LNR in the Borough.

Other Sites of Significance 13.7 As well as the statutory sites there are also other sites of importance for nature conservation across the Borough including Sites of Metropolitan Importance. These include the River Thames, it tributaries and islands, The Crane Corridor and Feltham

112 Marshalling Yards. There are also sites of Borough importance, including Syon Park, Osterley Park, Chiswick House Grounds and parts of the Longford River. Sites of local importance include Thorncliffe Waste and Gunnersbury Park.

113 OUTPUT INDICATORS

UDP Objective ENV-1

To protect, maintain and improve, the open nature, amenity, ecological value, recreational value and the quality of Green Belt, Metropolitan Open Land, Local Open Space, Heritage Land, Historic Parks and Gardens, Green Corridors, Green Chains and other open spaces.

Core Indicator(s)

4c Percentage of eligible open spaces managed to green flag award standard

13.8 The following three parks achieved the Green Flag Award standard in 2006/07 (Source: Civic Trust, 2006): • Bedfont Lakes Country Park (77 hectares) • Boston Manor Park (14 hectares) • Cranford Park (63 hectares) This equates to 12.4% of all publicly accessible open space in the Borough.

Local Indicator(s)

UDP Policy ENV-N.1.2 Acceptable Development in the Green Belt

Purpose: To retain the open nature of the Green Belt and reaffirm its purposes.

A. Use of Policy ENV-N.1.2 in Planning Decisions and Appeal Decisions

Planning Decisions Appeal Decisions Approved Refused Allowed Dismissed 10 3 0 0

B. Policy Outcomes

Target: No development in the greenbelt except in accordance with policy.

Indicator 1: Planning decisions quoting policy ENV-N.1.2 (see Appendix 38)

Outcome 13.9 There was one non-referable departure from the development plan in 2006/07 for the extension and refurbishment of Thorncliffe Hotel which is located within the Green Belt (Planning ref: 00815/A/P21). The existing hotel was considered to be in poor condition and is identified within Comprehensive Project Area 6 (CPA6) which states that the comprehensive treatment of this area is required to protect and enhance land which is of ecological significance, and to encourage appropriate redevelopment of the Thorncliffe Hotel in a manner which enhances an important Green Belt site. Although the proposal would significantly increase the floorspace of the hotel, the extensions would be primarily contained within the existing footprint. Consequently, the proposed development by reason of its scale and nature and the location of the land, was considered not to significantly prejudice the implementation of development plan policies and proposals.

114 13.10 Three applications were approved as the proposed developments were considered ancillary to existing uses and of a scale that would not harm the purposes or appearance of the Green Belt. The proposals approved were for the erection of a extension to a clubhouse to provide changing room facilities (Planning ref: 00576/D/P18), the retention of a portable building at the rear of a sports hall for use as a nursery (Planning ref: 01145/F/P11) and the erection of new floodlights around an existing football pitch (Planning ref: 00859/Q/P4).

13.11 A further three applications were approved as they were considered to be limited extensions or alterations in accordance with policy. A proposal for the conversion of a chalet bungalow into three one bedroom flats (Planning ref: 01054/776/P4) was approved because the physical works proposed would have nothing more than a minimal impact on the Green Belt, not adversely affecting the visual amenities it provides nor its sense of openness and integrity. It was also not considered that there were any grounds for opposing the development on the basis of intensification of use. Two other developments approved, were the installation of new cladding (Planning ref: 01054/BD/P29), and the erection of a new loggia to the front of the main building within South West Crematorium, Hanworth. Both proposed developments were considered to be within the envelope of the existing buildings and due to their siting, materials and design were not visually detrimental to the Green Belt.

13.12 A proposal for a temporary car park required during the redevelopment of Western International Market (Planning ref: 01032/E/P26) was considered to be a ‘very special circumstance’ and was therefore granted permission in accordance with policy. However conditions were imposed stating a maximum use of two years would be allowed and requiring the return of the land to open green belt once the permission had expired.

13.13 The final approval was for the development of a disinfection building within Kempton Park Water Treatment Works (Planning ref: 00438/S/P1). Policy ENV-N.1.2 provides that Kempton Park Waterworks is designated a major existing developed site within the Green Belt. Within the boundary of the site, limited infilling for purposes related to the continuance of the existing use will normally be permitted provided such infilling represents the filling of small gaps between existing development, has no greater impact on the purposes of including land in the Green Belt than existing development, does not exceed the height of existing buildings or lead to a major increase in the developed proportion of the site. The proposed development due to its small scale and location within the existing developed part of the site was considered to be infill that would not contribute to the sprawl or harm the openness of the Green Belt.

13.14 Of the three refusals citing policy ENV-B.1.2, two related to a proposal for a single storey rear extension on to the same bungalow on Hatton Road, Feltham (Planning refs: 00576/256/P2 and 00576/256/P4). One of the reasons for the first refusal was that extension was considered excessive and not sufficiently subordinate to the existing house, or within the spirit of its sensitive Green Belt location. The second refusal for the same site citing policy ENV-B.1.2 stated that although the appearance and bulk of the proposal had been reduced the proposed dormer continued to project too far forward in relation to the open land to the southwest. It was also considered that the proposal impacts unduly on the nature and integrity of the Green Belt, because of the proximity of the development to the open land to the southeast.

13.15 The third refusal was an outline application for the erection of a 160-bedroom hotel on Bath Road, Hounslow (Planning ref: 00083/820-844/P26). The proposal was refused as the applicant had not demonstrated an over-riding need for the building mass on the site to be increased. It was therefore judged to be an inappropriate form of development within

115 and adjoining designated Green Belt land, which would detract from the appearance, open character and function of the Green Belt in this location.

Indicator 2: Appeals citing policy ENV-N.1.2

Outcome 13.16 There were no appeals in the financial year of 2006/07 quoting policy ENV-N.1.2.

UDP Policy ENV-N.1.6 Metropolitan Open Land: Acceptable Uses

Purpose: To protect Metropolitan Open Land (MOL) from inappropriate development except in very exceptional cases.

A. Use of Policy ENV-N.1.6 in Planning Decisions and Appeal Decisions

Planning Decisions Appeal Decisions Approved Refused Allowed Dismissed 2 1 0 0

B. Policy Outcomes

Target: No development in the Metropolitan Open Land that is not compatible with its open character and defined acceptable uses.

Indicator: Planning decisions quoting policy ENV-N.1.6 (See Appendix 39)

Outcome 13.17 There were two approvals and one refusal in accordance with policy ENV-N.1.6. The first approval was for the installation of radio equipment cabinet (Planning ref: 00567/K/P2), which because of its location adjacent to the road and within a site already occupied by existing telecommunications infrastructure, would not occupy or obscure any significant area of open land.

13.18 The second approved application (Planning ref: 00946/B/P25) was for the retention of a temporary meeting and catering unit, which was in line with policy as it will provide open- air recreational facilities and had ancillary buildings, the purpose of which are identified as compatible with the principles in the policy.

13.19 There was one refusal related to the installation of a telecommunications column on metropolitan open land (Planning ref: 00503/AF/COM1). The proposal was not deemed acceptable, as the site was in a highly visible location with no screening vegetation. Moreover the proposed column would significantly exceed the height of existing road signs and traffic lights in the vicinity. The proposed use was therefore considered to detract from the open land character of the site and the appearance of the street scene.

Indicator 2: Appeals citing policy ENV-N.1.6

Outcome: There were no appeals in the financial year of 2006/07 quoting policy ENV- N.1.6.

UDP Policy ENV-N.1.11 Protection and Improvement of Local Open Space

116 Purpose: To protect, maintain and enhance the openness and wildlife habitats of Local Open Spaces within the Borough. These open spaces include private sports grounds, allotments, cemeteries, school fields, covered reservoirs, nature reserves and incidental open spaces found in housing areas.

A. Use of Policy ENV-N.1.11 in Planning Decisions and Appeal Decisions

Planning Decisions Appeal Decisions Approved Refused Allowed Dismissed 4 4 0 0

B. Policy Outcomes

Target: No development in areas of Local Open Space except in accordance with policy.

Indicator 1: Planning decisions quoting policy ENV-N.1.11 (see Appendix 40)

Outcome 13.20 Each of the four approvals were considered neither to result in a loss of open space nor be an intrusive element on the overall open aspect. For example the erection of a single storey classroom at Springwell Infants and Nursery (Planning ref: 01051/E/S13) was granted planning permission because it infilled an existing courtyard and would not prejudice the open character of the site or the large playing fields to the rear of the school. Another development was for the erection of a single storey conservatory adjacent to an area of Local Open Space (Planning ref: 00936/5/P2). It was considered that existing vegetation would provide reasonable screening of the proposed development and minimise its appearance within the setting of the Local Open Space.

13.21 The proposal for the erection of railings to playing fields at The Green School (Planning ref: 00707/AJ/P22) was approved as the fencing was seen to be of a certain height, type and proposed a degree of transparency that ensured it did not appear as an intrusive element in the overall aspect of the Local Open Space. The final proposal was for the installation of a telecommunications pole (Planning ref: 00505/FU/COM1), which was approved, as the proposal would be seen against a backdrop of trees and as far as possible had minimised its effect on the appearance of the street scene and the surrounding area.

13.22 Of the four refusals only two appear directly related to the purpose of policy ENV.N.1.11 to protect and improve local open space. The proposal for the demolition of an existing house and erection of three-storey building containing five flats on Gresham Road, Hounslow (Planning ref: 00519/21/P3) was in part refused for doubling the footprint of building on the site which would result in an unacceptable encroachment upon and an unacceptable development in the overall aspects of an area of public open space.

13.23 Similarly the redevelopment of Worton Hall (Planning ref: 01239/H/P36) proposed the loss of approximately a quarter of the existing open space. The proposal site itself was also located within an area of local open space deficiency as the open space on site is currently not accessible to the public. However, it does provide a visual break in the built (largely industrial to the rear of the site) environment that contributes to local amenity. Therefore the Council disagreed with the applicant’s argument that the local open space is currently of little benefit to the local community. The site contributes to the character of the area and its loss is therefore harmful. The applicant did not provided evidence to show that the loss of the open space, in an area of open space deficiency, was justified, either through the benefit it would bring to the listed building on the site, or through the benefits it would bring to the local community.

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13.24 The remaining two refusals related to two proposed residential developments located within area of local open space deficiency where the provision of amenity space for future residents was below the Council’s standards (Planning ref: 00566/A/P5 and 00586/H/P2. However, as neither proposal site is within or adjacent to an area of local open space, the refusals did not relate to the purpose of the policy in seeking the protection or improvement of local open space.

Indicator 2: Appeals citing policy ENV-N.1.11

Outcome 13.25 There were no appeals in the financial year of 2006/07 quoting policy ENV-N.1.11.

Significant Effects

Sustainability Objective 14: To maintain and improve the quantity and quality of public open space.

Indicator: Total area of the Borough in Public Open Space Deficiency

Outcome 13.26 Many people in the Borough do not have ready access to publicly accessible open space. Areas of Publicly Accessible Local Open Space Deficiency are defined as areas in the Borough that are more than 400 metres from any publicly accessible open space, taking into account barriers such as railways and major roads. Approximately 1,827 hectares of the Borough are currently identified as being areas of open space deficiency.

118 UDP Objective ENV-N.2

To protect, provide, enhance and promote Sites of Special Scientific Interest, Local Nature Reserves ad other areas of nature conservation interest with reference to the Hounslow Biodiversity Action Plan.

Core Indicator(s)

8a Change in priority habitats and species by type

13.27 There has been no change in biodiversity priority habitats and numbers of priority species since the Hounslow Biodiversity Action Plan was published in 2003.

8b Change in areas designated for intrinsic environmental value

13.28 There has been no change in areas designated for their intrinsic environmental value.

Significant Effects

Sustainability Objective 12: To maintain and enhance existing biodiversity (areas of nature conservation interest, wildlife and habitats)

Indicator: Condition of SSSIs

Outcome 13.29 English Nature assesses the condition of SSSIs and the results of these are shown in Table 39. The Government’s public service agreement target on SSSIs is to have 95% in favourable or recovering condition by 2010. Hounslow’s current situation is that 92% of the area in SSSI designation is in a favourable or recovering condition. When compared to London (60%) and England (67%), this shows that Hounslow is currently performing well. However, Hounslow needs to reverse any decline in the condition of SSSIs where possible.

Table 39: Condition of SSSIs in the Borough

SSSI Name Main Habitat Type Condition Kempton Nature Neutral grassland – lowland Favourable Reserve Improved grassland Favourable Neutral grassland - lowland Favourable Broadleaved, mixed and yew Favourable Syon Park woodland – lowland Fen, marsh and swamp Favourable Littoral sediment Unfavourable, declining (Source: Natural England, October 2007)

119 Summary of UDP Natural Environment Policy Implementation

13.30 The implementation of Policy ENV-N.1.2 in planning decisions has been consistent in 2006/07 with exceptional circumstances clearly demonstrated where the proposal was not consistent with policy. Reasons for refusal were in accordance with the policy, namely that the proposed new development would adversely impact on the openness of the green belt.

13.31 Policy ENV-N.1.6 was also applied in accordance with its objective. The applications approved either had no impact on the purpose of metropolitan open land or were in accordance with the criteria of the policy, whilst the one refusal was on the basis of adverse impacts to the openness of MOL. Policy ENV-N.1.11 was also implemented consistently. The applications approved did not result in a loss of open space and/or did not form an intrusive element whilst the proposals refused planning permission resulted in unacceptable encroachment on local open space.

13.32 The policies have therefore been applied consistently and there is not a need to amend the policy.

120 14. WATERWAYS

CONTEXTUAL INDICATORS

Waterways 14.1 The major water bodies within the Borough include the River Thames, River Crane, Longford River, Duke of Northumberland’s River and Grand Union Canal. They are key elements of the Borough’s environment and make a significant contribution to the landscape, ecology and local amenity of the area.

Flood Risk 14.2 The Council’s Strategic Flood Risk Assessment (SFRA) was approved by the Environment Agency in October 2007. It determines that there are parts of the Borough in flood risk areas, and differentiates the level of flood risk in these areas into zones. To summarise, the areas at risk of flooding are: • Along the length of the River Thames in the east of the Borough covering extensive areas of Isleworth, Syon, Brentford and Chiswick. • Along parts of the River Brent and Grand Union in the east of the Borough in the Brentford area. • Along the length of the River Crane in the west of the Borough in the Cranford and Feltham areas.

14.3 The SFRA outlines the various types of flood risk and sets out the approach the Council will take in both allocating land and determining planning applications in the different flood risk zones, depending on the vulnerability of the proposed use. It sets out the responsibilities of different parties in ensuring that development is located in areas of least flood risk and does not increase the risk of flooding either on site or elsewhere. The SFRA details the evidence that developers will need to provide (eg the sequential and exception tests as part of a Flood Risk Assessment) if proposing particular types of development in flood risk zones.

Water Supply 14.4 Thames Water and Three Valleys Water are the providers of water services for the London Borough of Hounslow. Thames water provides sewer services for the whole of the Borough. The Thames Water supply area covers 5,000 square miles across London and the Thames Valley Water is the largest water-only supplier in the UK, covering parts of North and West London, Middlesex and Hertfordshire. In Hounslow, Thames Water covers a majority of the east and central parts of the Borough and Three Valleys covers areas in the west of the Borough.

121 OUTPUT INDICATORS

UDP Objective ENV-W.2

To protect and enhance the status, quality and vitality of all the Borough’s water features and the waterside environment and to prevent an increased risk of flooding.

Core Indicator(s)

7 Number of planning permissions granted contrary to the advice of the Environment Agency

No planning permissions were granted contrary to the advice of the Environment Agency.

(i) Flood Risk 14.5 The Environment Agency made 16 initial objections to planning applications on flood risk grounds (see Appendix 41). Only one of these applications was subsequently granted planning permission.

14.6 In this case, the Environment Agency’s objection was withdrawn following agreement of a solution, and implementation of relevant planning conditions to reduce and mitigate flood risk. The Environment Agency initially objected to a proposal for the erection of two semi-detached houses on the site of the Former Scout Hall in the Market Place, Brentford. They had previously objected to an earlier, similar proposal which was withdrawn and discussed in 2005-06’s AMR. However, the objection was withdrawn following agreement that approval of the planning application carries with it a condition requiring that no development take place until the applicant provide a report showing that the life expectancy of the existing flood defence corresponds with the life time of the development (at least 100 years).

(ii) Water Quality 14.7 The Environment Agency did not make any objections to planning applications on water quality grounds.

Local Indicator(s)

UDP Policy ENV-W.2.4 Floodwater

Purpose: To prevent developments that would constrict the width of the Borough’s floodplains or prevent drainage of floodwater into the ground and increase the risk of flooding both upstream and downstream.

A. Use of Policy ENV-W.2.4 in Planning Decisions and Appeal Decisions

Planning Decisions Appeal Decisions Approved Refused Allowed Dismissed 1 5 0 0

B. Policy Outcome

122 Target: No increased risk of flooding either on site or elsewhere.

Indicator: Key issues in refusals quoting Policy ENV-W.2.4 or with flood risk issues (see Appendix 42).

Outcome 14.8 Five planning applications were refused quoting ENV-W.2.4 and/or flood risk grounds. The key issues were the provision of insufficient information on flood risk and/ or a failure to demonstrate that the proposal site and sites affected by the proposal are adequately safeguarded.

Significant Effects

Sustainability Objective 11: To ensure the qualitative and quantitative conservation of resources (soil, minerals, aggregates, water, energy)

Indicator: Average water consumption per person per day.

Outcome 14.9 Within the Thames Water supply area in Hounslow the average daily domestic water consumption use is 161 litres per person per day. In the Three Valleys area of the Borough, the average water consumption per person per day is 172 litres (Source: LB Hounslow State of the Environment Report, 2006).

123 Summary of UDP Waterways Policy Implementation

14.10 The publication of Planning Policy Statement 25: Development and Flood Risk in December 2006 has introduced new requirements for the council to review the variation of flood risk across the Borough and steer vulnerable development such as housing to areas of lowest risk. A Strategic Flood Risk Assessment (SFRA) is the first step in this process, providing the building blocks upon which the Council’s planning and development control decisions will be made. The Council’s SFRA was completed in October 2007 and will replace the use of policy ENV-W.1.4 in development control decisions until a new flood risk policy is adopted as part of the Borough’s Core Strategy.

124 15. TRANSPORT AND DEVELOPMENT

CONTEXTUAL INDICATORS

Major Roads 15.1 Hounslow’s proximity to Heathrow Airport has created a role for the Borough as a gateway to the capital for many visitors. The major roads within the Borough include the M4 and M3, and a number of primary and secondary roads – the A4, A312, A315, A30, A316, A205 and A406 cut through the Borough providing links with metropolitan centres across London and the rest of the country.

Mode Share for Travel to Work 15.2 The proportion of Hounslow’s residents using public transport to travel to work is 30%, which is lower than the Outer London average of 36% and London average of 42%. Use of National Rail for work trips has increased significantly in recent years and the percentage of trips made by walking and by van/lorry has declined (Source: Neighbourhood Statistics, 2006).

15.3 The percentage of people travelling to work by car in Hounslow is 54%. This percentage is significantly higher in comparison to the Outer London average of 45% and London average of 36%. Hounslow is ranked 7 out of 33 in terms of travel to work by car out of the 32 London boroughs and the City of London. The high use of the car in Hounslow to get to work can be attributed to a number of factors; the location of the Borough in Outer London, the large number of residents that work outside the Borough at Heathrow airport or areas beyond Greater London, and some areas of the Borough being poorly served by public transport.

Public Transport 15.4 Public transport in the Borough is provided by the London Underground (Piccadilly and District lines), the North London, Hounslow Loop and Waterloo to Reading national railway lines, and numerous bus services, which primarily serve to link communities within town centres and major employment area. There are also areas that are very poorly served by public transport particularly in the west of the Borough and in other out of centre locations. Access to public transport in London is measured using Public Transport Accessibility Level (PTAL) scores. The majority of the Borough has below average to very low PTAL scores apart from central Hounslow and areas around Feltham town centre, Hounslow West, Hounslow East, Gunnersbury, Turnham Green and Stamford Brook London Underground stations.

Road traffic statistics 15.5 In 2005, the estimated traffic flows of all vehicles in the Borough amounted to 1,646 million kilometres (km). From 1995 when there was a total of 1,620 million km, there was an increase to a peak in 1999 of 1,733 million km before a gradual decline closer to 1995 levels since.

15.6 In the context of car flows in the Borough, the trend since 1995 have been similar with 1,380 million km in 1995 increasing to 1,467 million km in 1999 but falling below 1995 levels with 1,375 million km in 2005. As a proportion of total vehicle flows, car flows have been static at between 84% and 85% since 1995 (Source: Department for Transport's National Road Traffic Survey 2005).

125 OUTPUT INDICATORS

UDP Objective T.1

To promote sustainability development within the Borough through integrating transport and land use policies in order to reduce the need to travel, reduce reliance on the private car and promote the use and implementation of environmentally friendly modes and initiatives.

Core Indicator(s)

3a Amount of completed non-residential development complying with car parking standards

15.7 Table 40 shows that 95% (115,495m2) of completed non-residential floorspace complied with the Council’s parking standards (see Appendix 43 for the list of developments). It was not possible to determine whether 2% (2,198m2) of completed non-residential floorspace complied with parking standards, as the information was not available.

15.8 A total of 3,755m2 (3%) of floorspace did not comply with the Council’s car parking standards. Appendix 43 shows that this amount is split between four developments. In all four, the existing provision of parking was above the Council’s parking standards. In two of these developments, both located in Heston and proposing employment uses (one for an Airline Caterers and the other offices) no new parking spaces were proposed. On the other two sites, new parking spaces were proposed. One of these proposals was for the new conference and dining facilities at the Civic Centre, Hounslow, where 75 new parking spaces were proposed. This is well within the maximum standard for a new conference facility but is in addition to the 600 existing parking spaces on the site (a maximum of 120 would be required under current standards for a new office building the size of the Civic Centre). The proposed number of parking spaces takes account of existing over-provision but also the need for 'overspill' parking at the Civic Centre and pressures on local streets for parking.

Table 40: Amount of completed non-residential development complying with car parking standards for developments with over 500m2 of floorspace.

A1 A2 A3 A4 A5 B1 B2 B8 D1 D2 TOTAL TOTAL amount of completed non- 19,580 93 3,452 0 0 49,107 17,403 10,895 19,504 1,414 121,448 residential floorspace

Amount COMPLY A1 A2 A3 A4 A5 B1 B2 B8 D1 D2 TOTAL Yes 19,580 93 3,452 0 0 44,693 17,403 10,895 17,965 1,414 115,495 No 0 0 0 0 0 3,009 0 0 746 0 3,755 Unable to determine 0 0 0 0 0 1,405 0 0 793 0 2,198

Percentage COMPLY A1 A2 A3 A4 A5 B1 B2 B8 D1 D2 TOTAL 92% Yes 100% 100% 100% N/A N/A 91% 100% 100% 100% 95% No 0% 0% 0% N/A N/A 6% 0% 0% 4% 0% 3% Unable to Determine 0% 0% 0% N/A N/A 3% 0% 0% 4% 0% 2%

126

3b Amount of new residential development within 30 minutes public transport time of a GP, hospital, primary and secondary school, areas of employment and a major retail centre(s)

15.7 The net number of completed residential dwellings during the 2005/06 financial year was 1,432.

15.8 Table 41 below shows the total number and percentage of these dwellings that were within 30 minutes public transport time of a GP, hospital, primary and secondary school, an area of employment; and a major retail centre (see Appendix 44 for the methodology).

15.9 All of the newly completed dwellings are within 30 minutes public transport time of a primary school. The vast majority (99%+) are within 30 minutes public transport time areas of a GP, secondary school, an area of employment and major retail centre.

15.10 However, only two thirds (26.7%) of newly completed dwellings are within 30 minutes public transport time a hospital. Of these newly completed dwellings not within 30 minutes public transport time a hospital, the largest numbers (mainly generated through two particularly large developments) are located at Boston Manor in Brentford and Feltham town centre, with the remainder spread between parts of Chiswick, Hounslow and Heston.

Table 41: The amount of new residential development within 30 minutes public transport time of: a GP, a hospital, a primary school; a secondary school; areas of employment; and a major retail centre.

Primary Secondary Areas Of Major Retail Service GP Hospital School School Employment Centre

No. of new residential dwellings within 30 minutes public transport 1430 386 1432 1428 1430 1418 time

No. of new residential dwellings not within 30 minutes public transport 2 1046 0 4 2 14 time

Percentage of new residential dwellings within 30 minutes public 99.9% 26.7% 100.0% 99.7% 99.9% 99.0% transport time

Significant Effects

Sustainability Objective 10: To minimise the need to travel, increase the use of sustainable transport modes (walking, cycling and public transport) and reduce reliance on the car.

Indicator 1: Mode of transport used for various trips (Source: Residents’ Panel Survey, July 2004 and August 2006)

Outcome 15.11 Four different activities were provided for respondents who were then asked to state how they would normally travel to each of the different activities. Table 42 below shows the responses given for each of the activities mentioned. The private car was the favoured mode of transport for all four of the activities mentioned.

127 15.12 The question was also asked of the Residents’ Panel in July 2004. Table 43 shows that there have been no significant changes to the responses given in the surveys, the overall use of the private car has reduced, and use of buses has increased.

Table 42: Mode of Transport uses for various trips

Work/Education Food Leisure Visiting Friends % Shopping Activities or Family % % % 2004 2006 2004 2006 2004 2006 2004 2006 Private Car 42 40 70 68 54 46 72 64 Taxi * * 1 1 * * 1 * Motorcycle * * * 0 * * 1 * Cycle 3 2 2 1 5 3 2 1 Train 12 9 1 * 3 3 6 4 Bus 9 7 9 9 8 14 8 10 Walking 7 8 14 13 11 14 6 7 Other 1 1 1 1 1 1 1 1 Not Applicable 26 33 3 9 18 18 4 12 * Denotes figure lower than 0.5%

Indicator 2: Rating of public transport in Hounslow (Source: Residents’ Panel Survey, August 2006)

Outcome 15.13 All respondents were asked to rate six aspects of public transport in Hounslow. The overall ratings provided are shown in Table 43 below. The aspect rated most highly is the ease of accessing the bus or train (55% rate this as good) followed by the availability and frequency of public transport during the week (53% rate this as good). The aspect most frequently rated as poor is value for money (36% rated this as poor).

Table 43: Rating of Public Transport in Hounslow

Very Good Average Poor Very Don’t Good % % % Poor Know % % % The availability and frequency of public transport during the day 15 38 23 4 2 18 Monday-Friday The availability and frequency of public transport in evenings and 5 26 29 10 3 27 weekends The availability of suitable 8 33 25 10 3 23 connections and routes

Ease of accessing the bus or train 14 41 22 6 2 15

Value for money 6 16 23 24 12 18

Punctuality and reliability 4 26 33 16 5 16

15.15 This question was also asked of the panel in July 2004 and Table 44 compares the response for ‘fairly good’ or ‘very good’ with 2006. As shown ratings for the majority of aspect of public transport have risen significantly since 2004.

128 Table 44: Proportion of residents rating aspects of public transport in Hounslow as either fairly or very good – comparison of 2004 and 2006

2004 2006 % % The availability and frequency of public transport during the day 41 53 between Monday and Friday The availability of suitable connections and routes 19 41 The availability and frequency of public transport at weekends 22 31 Ease of accessing the bus or train 41 55 Value for money 19 22 Punctuality and reliability 15 30

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131