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PLANNING COMMITTEE 22nd June 2017 eamon.cassidy@.gov.uk

References: P/2016/0716 00707/E/P111

Address: Syon Park, , London, TW8 8JF

Proposal: Formation of a new allotment area with associated infrastructure.

This application is being taken to Planning Committee as a Major scheme with a Legal Agreement.

1.0 SUMMARY

1.1 Planning permission is sought for infrastructure and structures associated with the use of land for allotment gardens. The land would remain in agricultural use. The proposal is for 37 allotment plots of varying size. The plots would be demarcated with flush timber edging. The south of the site would feature an area of permeable gravel for vehicle drop off and turning.

1.2 The proposed development would relocate existing allotments from Park Road to facilitate a residential development on the Park Road site. The proceeds generated by this development would be reinvested into to fund important restoration work to this Grade I registered heritage asset. The application would secure a number of important heritage benefits, namely the restoration of Lion Gate and Lodges, the reinstatement of historic tree planting and the path leading to Syon House over Wyatt Bridge.

1.3 The proposed development is in general accordance with planning policy. It is considered that any limited harm resulting from the localised change to landscape character to the south of Lion Gate would be outweighed by the linked restoration works. The proposals taken together are therefore considered to preserve the historic interest of the listed buildings concerned and the character and appearance of the Riverside Conservation Area and would conserve the historic significance of Syon Park.

1.4 The application is recommended for approval subject to condition and the completion of a Section 106 Agreement. 2.0 SITE DESCRIPTION

2.1 The site is within the grounds of Syon Park, a Grade l Registered Park and Garden, and to the north west of Syon House, a Grade l listed building. The 1.31ha site (irregular in shape) lies in Syon Park; between the Grade l listed Lion Gate and the Serpentine Lake. .

2.2 The site is currently part of open parkland used for grazing and is therefore in agricultural use.

2.3 The site is part of Syon Park which is a Grade l Registered Park and Garden, it also lies within the setting of a number of listed buildings, namely Syon House and Lion Gate, both Grade l listed. The site also lies in the Isleworth Riverside Conservation Area, in a Buffer Zone to the Royal Botanic Gardens, Kew, World Heritage Site and within Metropolitan Open Land. 3.0 HISTORY

00707/E/P93 Erection of a 155 bed hotel & health spa, covered walkway, glass house, creation of service access from London Road, the reinstatement of the historic landscape at Syon Park including formal and informal landscaping reconfiguration of car parking and garden centre storage areas and demolition of various buildings. Approved: 08/03/2004 00707/E/P97 Erection of a temporary marquee for five years for daytime and evening private/corporate events from 1st May to 30th September for each year period for 2009, 2010, 2011, 2012, and 2013. Approved: 22/01/2010 00707/E/P98 Alterations to the approved and substantially completed approved scheme (reference 00707/E/P93) for the erection of a 155 bedroom hotel involving use of the second floor roof loft area of the bedroom wing as guest lounges and a servery kitchen, together with formation of a roof terrace on the single storey conference wing and alterations to room layouts. Approved: 13/05/2010 00707/E/P99 Construction of a temporary (3 years) single storey garden centre sales building. Approved: 30/06/2010 00707/E/P100 The refurbishment of existing adventure warehouse and the construction of an outdoor maze. Approved: 25/06/2010 00707/E/P105 Refurbishment of existing adventure warehouse and construction of an outdoor maze. Approved: 30/11/2012 00707/E/P106 Change of use of garden to erect a temporary marquee every year for 10 years between 1st May and 30th September for daytime and evening private/ corporate events from 2014 to 2023 Inclusive. Approved: 29/07/2013 00707/E/P107 Variation of condition 1 of approved planning permission 00707/E/P106 dated 29/07/2013 to read as follows: The permission hereby granted shall be for a limited period of nine years for the erection of the marquee from 1st May to 30th September for each consecutive year and the permission shall expire on 30th September 2023 when the use shall cease and the marquee removed within one week of that date. For 2015 only, the erection of the marquee will be extended to 31st October to cater for seven events relating to the 2015 Rugby World Cup. The site of the marquee shall be made good, levelled and laid to grass no later than one month after its removal for each yearly period. Approved: 27/11/2014 00707/E/P110 Erection of eight blocks of three- and four-storey buildings to create 119 flats and eight houses with car parking at basement and street level and associated works. Recommendation: Approval Planning Committee 22nd June 2017 4.0 DETAILS

4.1 Planning permission is sought for infrastructure and structures associated with the use of land for allotment gardens. The land will remain in agricultural use.

4.2 The proposal would provide 37 allotment plots of varying size. Each plot would be demarcated with flush timber edging. The south of the site would feature an informal area of permeable gravel for vehicle drop off and turning. The development would also feature:

 1 small tool chest (1.2m x 0.9m x 0.95m high provided per allotment plot;  1 allotment shed per two allotment plots (1.8m x 1.2m x 1.88m high);  WC and community shelter/notice board provided with power source;  Galvanised steel dip tanks provided per 6-8 allotment plots;  Retention of existing stock proof fence boundaries; realignment of northern boundary fence line;  New stock proof fence with native hedge planting to enclose the site to the west and new pedestrian gate to the south-east;  Retention of landscape levels and all existing mature trees; and  Enhancement of the grassland habitat with planting and native shrub screen planting around structures.

4.3 Northumberland Estates, supported by its gardening team, would manage the allotment gardens to ensure that they are well maintained and that the plots are fully utilised. The landscape proposal aims to be ‘light’ touch and all existing levels are retained where possible. The proposed structures would be low rise and materials have been carefully selected so that they are natural and sympathetic to the historic landscape.

4.4 The application includes a commitment to the restoration of Lion Gate and Lodges, and the reinstatement of a historic band of tree planting and the path leading to Wyatt Bridge. These works lie within the Northumberland Estate’s ownership and would be secured via a legal agreement.

5.0 CONSULTATIONS

5.1 Neighbouring residents and local action and amenity groups were notified on 07/03/2016. Site notices posted on 14/03/2016. Press notice posted on 18/03/2016. Eleven responses were received.

Comment Response

Objection

Syon Estate is not a suitable The use of the site for allotment alternative allotment site. purposes, in planning terms, is acceptable. See paragraph 7.1 – 7.13.

Harm to the appearance of the See paragraph 7.14 – 7.28. Park.

Concerns in relation to the See paragraph 7.44 – 7.75. financial need.

Harm view into Capability Brown See paragraph 7.14 – 7.28. landscape.

Lack of public consultation. Consultation event undertaken January 2017.

Conflict between grazing cattle Stock proof fence with native and allotments. hedge planting would enclose the allotments.

Failure to provide costed plans to Information contained with support the case that Enabling Development Case development will raise funds for prepared by Nathaniel Lichfield & work on Syon House and gardens. Partners dated 1 January 2017.

In support

Improved management of Noted. allotments.

Similar of better quality soil – less Noted. clay.

Likelihood of better security. Noted.

Similar of better services – water, Noted. storage and toilets.

Vehicle access is easier as site Noted. has a car park.

More accessible to the wider Noted. community due to better bus access.

Proposals include landscaping to Noted. minimise visual impact on Park.

5.2 The following responses were received from local action and amenity groups:

The Isleworth Society (Linked to Planning Application 00707/E/P110)

5.3 “We consider the proposal to build 127 housing units on the existing allotment site would be overdevelopment of a green open space which contributes to the rural nature of this particular area of Old Isleworth, and forms an integral part of the context and character of the Isleworth Riverside Conservation Area. Where there are now allotments, trees, shrubs and grass there will instead be buildings and concrete and the views from Park Road, the properties in Snowy Fielder Waye and from Charlotte House will be completely different.

5.4 The allotment site falls within the Isleworth Riverside Conservation Area, conservation being the operative word. As the main purpose of conservation area designation is to acknowledge the special character of an area, it is therefore vital that the allotments and the open green space on which they stand are retained. To erect buildings on this site would be detrimental to the character of the Isleworth Riverside Conservation Area and would devalue its status as a whole;

5.5 Hounslow’s Local Plan, recently approved by the Planning Inspectorate, does not designate this space for building

5.6 The estate maintain that they have to replace the Park Road Allotment site with housing in order to provide a long term income stream for necessary repair work to Syon House. To justify this proposal then this application and the application for relocating the allotments to within Syon Park (Ref:07707/E/P111) are integral to each other. As such the state should provide a costed schedule of necessary work to Syon House and details of how they propose to ring fence the rent from the new houses on the Park Road site in order to fund this. The National Planning Policy Framework (NPPF) states that harm caused to heitage asset may be outweighed by the public benefits of the proposal; funding a long term repair programme for Syon House and other listed buildings and structures within the grounds may be used as a public benefit and must be taken into account during the planning process. No evidence is given in either application of public benefit.

5.7 The proposed new allotment site will have severe restrictions imposed upon it and prospective allotment holders, which is contrary to the requirements of the NPPF for equivalent or better.

5.8 As to the location proposed, Syon Park is designated as Metropolitan Open Land (MOL). The parkland was designed by Lancelot ‘Capability’ Brown; the Lion Gates were designed by Robert Adam and are Grade 1 listed. These gates were designed as the 18thC entrance to the main carriageway drive. Thus the site proposed is not suitable for allotments, not least in light of the adverse effect on vistas and sight lines both within the estate and from the London Road. This is evidenced in the Landscape and Visual Assessment Report by the many references to the need to minimise and screen the proposed allotment site to reduce impact. The suggested measures will in no way entirely obviate this impact and are insufficient to maintain the openness, setting and visual amenity of the existing MOL.

5.9 On suitability for allotments, it is acknowledged one role of great estates such as Syon was to provide produce. This was usually within kitchen gardens and in less prominent parts of a designed landscape. The walled kitchen garden at Syon was to the north of London Road and subsumed by residential developments in the mid-20thC. The proposed allotment site is within an area historically designed as parkland and intended to support the impression of the status and importance of the landowner, indicated architecturally by the entrance gate. These listed gates and the parkland setting make an important contribution to the estate both in architectural terms and historic value. The development of allotments within this part of the Historic England registered parkland would very obviously change the character of the landscape and thereby harm the contribution it makes both as part of the park and also as part of the setting to the gate and the house.

5.10 The NPPF states that harm caused to a heritage asset may be outweighed by the public benefits of the proposal Justification of the proposal to relocate the allotments from the Park Road Allotment Gardens to within Syon Estate, requires the estate to provide a costed schedule of necessary work to Syon House with details of how they propose to ring fence the rent from the new houses on the Park Road site in order to fund this. This has not been demonstrated in the application. It is also noted the Northumberland Estate is appealing against LBofH’s decision to grant Asset of Community Value to the existing Park Road site. This raises doubts as to the Northumberland Estate’s future long term intentions in regard to that land.

5.11 In summary, the proposal does not meet the very special circumstances criteria to allow development on MOL nor does it provide sufficient justification that the harm caused to the historic landscape by the development is clearly outweighed by other considerations. It should therefore be refused.”

External Statutory Consultation Responses

5.12 The following external bodies were notified of the application and their response are detailed where these have been received:

The Gardens Trust

5.13 Objection – Further information is required to justify the necessity of this scheme.

Response: The application has since submitted a case for Enabling Development. It is considered that the proposed heritage works are necessary for to secure the long term future of the heritage asset; are acceptable in principle; and the costed schedule of repairs are broadly reasonable and representative of the level of work involved.

Natural England

5.14 No objection – No conditions requested.

Transport for London

5.15 No objection – Informatives requested.

Historic England

5.16 No objection – It is for the Council to decide whether a proposal should be considered ‘Enabling Development’. The proposed allotments would cause minor harm to the significance of the Grade l registered park, but this minor harm could be outweighed by public benefits, in this case the securing of long term funding for the repair of the Grade l listed house. The proposed heritage works are necessary to secure the long term future of the heritage asset; are acceptable in principle; and the costed schedule of repairs are broadly reasonable and representative of the level of work involved. 6.0 POLICY

Determining applications for full or outline planning permission

6.1 The determination must be made in accordance with the development plan unless material considerations indicate otherwise. Local finance considerations must also be assessed. The National Planning Policy Framework

6.2 The National Planning Policy Framework (NPPF) came into force on 27 March 2012 and has replaced national policies and guidance formerly contained in Planning Policy Statements and Planning Policy Guidance notes and some other documents. The Local Planning Authority (LPA) considers that, where pertinent, the NPPF is a material consideration and as such, it will be taken into account in decision-making as appropriate. The Development Plan

6.3 The Development Plan for the Borough comprises the Council's Local Plan (adopted by the Council on 15 September 2015), the West London Waste Plan and the London Plan Consolidated with Alterations since 2011.

6.4 The Local Plan documents can be viewed on the Planning Policy pages of the Hounslow website.

6.5 Relevant London Plan Policies

5.12 Flood Risk Management 5.13 Sustainable Drainage 6.3 Assessing Effects of Development on Transport Capacity 6.12 Road Network Capacity 6.13 Parking 7.4 Local Character 7.6 Architecture 7.8 Heritage Assets and Archaeology 7.10 World Heritage Sites 7.17 Metropolitan Open Land 7.18 Protecting open space and address deficiency 7.19 Biodiversity and access to nature 7.21 Trees and woodlands 8.2 Planning Obligations 8.3 Community Infrastructure Levy

6.6 Local Plan

CC1 Context and Character CC2 Urban Design and Architecture CC4 Heritage GB1 Green Belt and Metropolitan Open Land GB4 The Green Infrastructure Network GB7 Biodiversity GB8 Allotments, Agriculture and Local Food Growing EQ3 Flood Risk and Surface Water Management EC2 Developing a Sustainable Local Transport Network IMP1 Sustainable Development

7.0 PLANNING ISSUES

The acceptability in principle

7.1 The National Planning Policy Framework (NPPF) sets out the planning policy guidance from central government to be used by all local authorities in England when preparing development plans. A key principle underpinning the NPPF is a presumption in favour of sustainable development, which should be seen as a golden thread running through both plan-making a decision-taking.

7.2 Local Plan Policy IMP1 (Sustainable Development) states that the Council will take a plan-led approach to all growth and development within the borough that is considered to be in accordance with the principles of sustainable development as set out in the NPPF, with a balance of social, environmental and economic dimensions.

7.3 The Local Plan acknowledges the site is currently in agricultural use. It states that “There are also a number of farms in the borough, largely located in the west, in the Green Belt, but there is also agriculture present further east, at Osterley and Syon Parks.”

7.4 Cultivation of the land for allotment gardens is consistent with the current agricultural use of the land and as such, planning permission is sought for the infrastructure and structures associated with the land for allotment gardens, but not for change of use as this is not necessary. Full details of the allotment plots and associated landscaping have been submitted to support the application.

7.5 The site is located in Metropolitan Open Land (MOL). Local Plan policy GB1 (Green Belt and Metropolitan Open Land) is therefore relevant and states that the Council will protect and enhance Green Belt and Metropolitan Open Land to maintain its openness, quality and permanence. This will be achieved through the positive management of both designations and improving public access. The Council will achieve this by:

 Establishing a Green Belt boundary, to ensure that it is strong and permanent;

 Establishing the extent of Metropolitan Open Land in line with the Mayor of London’s designation;

 Protecting Green Belt and Metropolitan Open Land by ensuring that any development is not inappropriate and meets the purposes of the Green Belt and Metropolitan Open Lane; and  Working with partners to improve public access to the Green Belt and Metropolitan Open Land, including the promotion of sports, recreation, leisure and cultural uses that fall within the acceptable uses outlined in the NPPF.

7.6 The Council will expect development proposals to:

 Be compatible with and not inappropriate development in the Green Belt (as set out in the NPPF) or Metropolitan Open Land (as outlined in the London Plan);  Carefully consider the cumulative impact of extensions and alterations to existing development in the Green Belt and Metropolitan Open Land;  Conserve and enhance the nature conservation, landscape and recreation and amenity value of Green Belt and Metropolitan Open Land through positive management;  Improve public access to the Green Belt and Metropolitan Open Land; and  Maintain the openness, setting and visual amenity where it is located near the Green Belt and Metropolitan Open Land, with particular attention given to the location, setting, design, materials, height and landscaping.

7.7 In relation to inappropriate development in the Green Belt, NPPF policy is relevant as the London Plan makes clear “The policy guidance of paragraphs 79-92 of the NPPF on Green Belts applies equally to Metropolitan Open Land (MOL)”. Paragraph 89 of the NPPF states that “a local planning authority should regard the construction of new buildings as inappropriate in the Green Belt”. Exceptions to this are, amongst others, “buildings for agriculture and forestry”. The development of infrastructure and small structures associated with allotments, an agricultural use, would therefore not be inappropriate development in the MOL.

7.8 The proposed allotment site was specially chosen following analysis of a number of sites across the parkland. This proposed location was chosen on a heritage-led basis as there is an opportunity to restore the Grade l listed Lion Gate and Lodges, which would be a public benefit, and the visual impact of the proposed location is considered less adverse than other proposed sites as belts of mature tree planting partially screen views of the site. The proposed location was also chosen on more practical bases, given its orientation, shade and shelter.

7.9 The proposed development includes several improvements to the surrounding historic landscape. This improvements include:

 Restoration of Lion Gate and Lodges, offering a significant heritage benefit.  Reinstatement of historic tree planting, as identified on the 1786 Sauthier map of Syon Park.  Reinstatement of the path leading to Syon House over Wyatt Bridge.

7.10 It is considered that these works would help to enhance the setting of the Grade 1 listed Lion Gate and wider parkland and therefore help to conserve and enhance the landscape and amenity value of the MOL.

7.11 The proposed development would open an area of the park which is not currently publicly accessible. Access for vehicles would be via Park Road as is currently the case and pedestrians would access the site using existing entrances to Syon Park.

7.12 The principle of agricultural use at this site is established. The proposed development of infrastructure and structures to support the new allotments would be appropriate, having regard to NPPF paragraph 89. The proposed development would bring important public benefits opening up a hitherto private space to allotment holders. While there would be minor adverse visual and landscape impacts these would be entirely reversible and, in any event, must be balanced against the wider amenity benefits, improved access, tree planting, and the important heritage benefits arising from the restoration to Lion Gate and Lodges and the reinstatement of historic tree planting and the path to Wyatt Bridge. The proposed development is in keeping with the agricultural use of the land and is considered to comply with the requirements of Local Plan policy GB1 (Green Belt and Metropolitan Open Land).

7.13 For these reasons outlined above, it is considered that the proposal is acceptable in principle. Notwithstanding this, the other main planning issues to be considered are:

 Design and Appearance  Archaeology and Heritage  Landscaping and Arboriculture  Transport, Accessibility and Access  Flood Risk and Drainage  Ecology  Enabling Development  Planning Obligations

Design and Appearance

7.14 London Plan policy 7.4 (Local Character) encourages new development to have regard to the form, function and structure of an area, place or street and the scale, mass and orientation of surrounding buildings. The new development should improve an area’s visual or physical connection with natural features and contribute to establishing an enhanced character for the future function of the area.

7.15 Local Plan Policy CC1 (Contact and Character) states that the Council will recognise the context and varied character of the borough’s places and seek to ensure that all new development conserves and takes opportunities to enhance their special qualities and heritage.

7.16 Local Plan Policy CC2 (Urban Design and Architecture) states that the Council will retain, promote and support high quality urban design and architecture to create attractive, distinctive, and liveable places.

7.17 The proposal has been designed to ensure that the allotments sit comfortably within the landscape. All the trees on site would be maintained and there would be no significant change to ground levels. Low rise design features are proposed to ensure that they are not visually prominent. This would include the use of natural materials for the sheds, plot demarcation and fencing. The plots would be arranged around existing, retained trees that would help to filter views and soft landscape would reduce the potential visual impact of proposed structures. These measures would help maintain the openness, setting and visual amenity of the site and surrounding area.

Archaeology and Heritage

7.18 The NPPF (Section 12) and London Plan policy 7.8 (Heritage Assets and Archaeology) emphasise that the conservation of heritage is a material consideration in the planning process.

7.19 Paragraph 128 of the NPPF says that applicants should submit desk-based assessments, and where appropriate undertake field evaluation, to describe the significance of heritage assets and how they would be affected by the proposed development. This information should be supplied to inform the planning decision. If planning consent is granted, paragraph 141 of the NPPF says that applicants should be required to record and advance understanding of the significance of any heritage assets to be lost (wholly or in part) and to make this evidence publicly available.

7.20 Paragraph 134 of the NPPF says that where a development proposal would lead to less than substantial harm to the significance of a designated heritage asset, this harm should be weighed against the public benefits of the proposal, including securing its optimum viable use.

7.21 Local Plan policy CC4 (Heritage) states that the Council will identify, conserve and take opportunities to enhance the significance of the borough’s heritage assets as a positive means of supporting an area’s distinctive character and sense of history. The Council expect development proposals to have regard to any harm to, or loss of, the significance of a non-designated heritage asset, including from both direct and indirect effects. Non-designated heritage assets include locally listed buildings, Archaeological Priority Areas and areas of special local character.

7.22 With regards to sites of Archaeological Importance, the Council will expect development proposals to submit an Archaeological Evaluation Report if the proposal falls within or adjacent to an Archaeological Priority Area.

7.23 A Historic Environment Impact Assessment (HEA) has been submitted to support the application. The HEA notes that the site does have some potential for archaeological findings, however as excavations will be to a limited depth (maximum of 800mm depth for tree planting), it is considered that the works can proceed with archaeological supervision.

7.24 A Heritage Impact Assessment (HIA) has been submitted to support the application. The HIA articulates the historic significance of the heritage assets likely to be affected by the proposed development, and identifies the potential effects on that significance, including considerations of setting.

7.25 It is considered that, due to the surrounding trees and the proposed planting, the visual effects would be contained to a small area immediately south of the Lion Gate. Within public views from London Road through Lion Gate, the proposed allotments would change the historic landscape character of a small section of the Registered Park from open parkland to a gardening landscape.

7.26 The reduction of the open parkland as a whole would affect the historic value of a designated landscape and, by implication, the Isleworth Riverside Conservation Area, the setting of Syon House, and the Buffer Zone of the Royal Botanic Gardens, Kew World Heritage Site. In reality this change would have a limited effect on perceptions of these heritage assets, since it would only be visible in passing from London Road. In addition, the proposed allotments are entirely reversible.

7.27 It is considered that these effects, in isolation, are considered as minor ‘less that substantial’ harm having regard to the policies set out in the NPPF. In this instance, however, heritage mitigation works are proposed. These include the restoration of the Lion Gate and Lodges which would enhance the special architectural and historic character of this heritage asset and Registered Park, as well as the view into the Park from London Road, which would help to outweigh the minor harm caused. This is considered a public benefit. 7.28 It is therefore considered that, on balance, the minor harm caused from the localised change to the landscape character to the south of Lion Gate would be outweighed by the linked proposed restoration works to the Lion Gate and Lodges. The net effect overall is that the proposal would result in the conservation of the relevant heritage assets and would make a positive contribution to securing the long term repair and conservation of Syon Park. The public benefits associated with the proposal are therefore considered to outweigh the minor ‘less than substantial’ harm associated with the development of infrastructure and structures associated with the proposed allotments.

Landscape and Arboriculture

7.29 London Plan Policy 7.21 (Trees and Woodlands) states that existing trees of value should be retained and any loss as the result of development should be replaced following the principle of ‘right place, right tree’. Furthermore, wherever appropriate, the planting of additional trees should be included in new developments, particularly large-canopied species.

7.30 Local Plan policy GB4 (Green Infrastructure Network) states that the Council will protect and enhance the green infrastructure networks throughout the borough, particularly those identified as part of the Mayor of London’s All London Green Grid. The network will be improved to maximise the diverse benefits and multiple functions, and improved public access to, and links between open spaces will be encouraged. The Council expect development proposals to demonstrate that there will be no significant adverse impact on the borough’s green infrastructure.

7.31 Local Plan policy GB7 (Biodiversity) states that the Council will protect and enhance the London Borough of Hounslow’s natural environment and seek to increase the quantity and quality of the borough’s biodiversity. The Council will achieve this by encouraging the greening of the borough, through landscaping and tree planting, and protecting existing trees through Tree Preservation Order (TPOs).

7.32 A Tree Condition Plan and Tree Survey have been submitted to support the application. The site includes a number of A and B rated trees. All of these would be retained in addition to existing ground levels. In addition, woodland planting would be undertaken to restore tree belts along the north and west of the park. These would reinstate historic tree belts which were identified on the 1786 Sauthier map of Syon Park.

7.33 A Landscape and Visual Impact Assessment has been submitted to support the application. The Landscape and Visual Impact Assessment considers the effect of the proposal on visual amenity and landscape and concludes that while there would be adverse effects, but that these would be minor, reversible and should be considered in the context of the landscape improvements the scheme would bring, notably tree planting and the reinstatement of the path over Wyatt Bridge to restore the historic setting of the Lion Gate, plus the wider heritage benefits associated with the development. This includes the restoration of Lion Gate and Lodges. Transport, Accessibility and Access

7.34 Local Plan Policy EC2 (Developing a Sustainable Local Transport Network) state states that the Council will secure a more sustainable local travel network that maximises opportunities for walking, cycling and using public transport, reduces congestion, improves the public realm and improves health and well-being.

7.35 Vehicle access to the site would be via the main entrance to Syon Park, on Park Road. Vehicle tracking modelling has been carried out and the small gravel area at the south of the site would offer sufficient turning space for cars and small vans bringing deliveries to the allotments. No additional parking would be provided. Parking is however available for allotment holders within the main car park which represents a significant improvement upon the arrangement for the existing allotment. The additional trip generation associated with the provision of allotment gardens within Syon Park would be negligible.

7.36 The new allotment site would have easy vehicular and pedestrian access as it would be accessed via the existing main entrance to Syon Park, which is on Park Road. The relocated allotments are close to the existing allotments and would therefore be easily accessible on foot to the local community and the community more widely. Parking will be available for allotment holders in the main car park which is close to the relocated allotments and there would also be a dedicated drop off facility. In addition, the proposed location of the allotments is close to the other facilities in the Park, including the Garden Centre and less isolated than at present, which would be of benefit to both uses..

Flood Risk and Drainage

7.37 London Plan policy 5.12 (Flood Risk Management) outlines the importance of compliance with the flood risk assessment and management requirements set out in the NPPF and associated technical guidance, and Catchment Flood Management Plans.

7.38 London Plan policy 5.13 (Sustainable Drainage) highlights the importance of new developments utilizing sustainable urban drainage systems (SUDS) unless there are practical reasons for not doing so. Policy further states that development proposals should aim to achieve greenfield run-off rates and ensure that surface water run-off is managed as close to its source as possible. Policy goes on to provide a drainage hierarchy for development proposals to refer to. The hierarchy includes rainwater harvesting and discharge to watercourses.

7.39 Local Plan Policy EQ3 (Flood Risk and Surface Water Management) states that the Council will ensure that flood risk is reduced by ensuring that developments are located appropriately and incorporate any necessary flood resistance and resilience measures. In addition, surface water will be managed through an increase emphasis on sustainable urban drainage. The Council will achieve this by:  Promoting the opening up of river corridors and making space for water through the creation of buffer zones to water courses and increasing floodplain connectivity.

7.40 The Council expect development proposals to:

 Prepare flood risk assessments, consistent with the requirements of the Environment Agency and the Strategic Flood Risk Assessment, and apply the sequential approach within site boundaries to ensure flood risk is further deceased.

7.41 A Flood Risk Assessment (FRA) has been submitted which identifies the site is primarily located in Flood Zone 3, with some northern sections of the site located in Flood Zones 1 and 2. The proposed use of the site is classified as a ‘water-compatible development’ in Table 2 of the Technical Guidance to the NPPF. The proposed allotment gardens are therefore an ‘appropriate’ use having regard to Table 3 of the Technical Guidance to the NPPF.

7.42 The existing site is a greenfield site and is 100% permeable. The site would remain 100% permeable other than for some small hard standing features, including the allotment sheds. The FRA proposes that runoff from these would be managed through the use of infiltration techniques. It is considered that greenfield runoff rates would be achieved as a result of the proposal. Details of the proposed infiltration techniques to mitigate the slight loss of permeable footprint of the site would be secured via condition 5.

Ecology

7.43 A Phase 1 and 2 Ecology Assessment has been submitted in support of the application. As the mature trees on the site have the potential to support some protected species it recommends they are not removed. As stated above, all trees will be retained and any species nesting within these trees will not be affected. A Phase 2 Reptile Survey found that the site does not support any reptiles.

Enabling Development

7.44 ‘Enabling development’ is development that would be unacceptable in planning terms but for the fact that it would bring public benefits sufficient to justify it being carried out, and which could not otherwise be achieved. The key public benefit to significant places is usually the securing of their long-term future. Enabling development that would secure the future of a significant place, but contravene other planning policy objectives, should be unacceptable unless the proposals comply with the seven criteria set out in Historic England’s ‘Enabling Development and the Conservation of Significant Places’ (2008) document (see paragraphs 7.53 – 7.75). An Enabling Development Case has been submitted in support of the application and the linked planning application for residential development on the existing allotment site on Park Road reference number 00707/E/P110. 7.45 Syon House and Syon Park belong to the Duke of Northumberland and it is his family’s historic London residence. Syon House is Grade l listed and the park is included on Historic England’s Register of Historic Parks and Gardens as Grade l. Both are important, national statutory designations. The cost of maintaining and repairing Syon House and its grounds is considerable. A number of important works need to be undertaken comprising the internal conservation and refurbishment of the state rooms and repairs to the stone façade, and the restoration of Lion Gate and its Lodges. The Estate’s objective is therefore to secure the long term funding for the ongoing maintenance, conservation and restoration of this heritage asset so that it can continue to remain as a unique example of a rural estate located in a major conurbation, to be enjoyed by future generations.

7.46 To generate the funding necessary, Northumberland Estates is therefore proposing to build 127 dwellings on land that it owns on Park Road. This land is occupied by allotment holders and, as such, it is proposed that replacement allotment gardens are provided in the grounds of Syon Park. The residential development would comprise high quality Private Rented Sector (PRS) housing, to be retained in the long-term ownership and management of Northumberland Estates. This would ensure a long- term income stream is generated so it is able to fund a schedule of costly dilapidations, thereby ensuring the long-term sustainable future of this nationally significant heritage asset. These are important works which the Northumberland Estates intends to undertake over a period of 25 years.

7.47 Based on current estimates of the repair programme the Estate needs to invest £9,562,625 in conservation and repair works. The façade repairs to Syon House is a very important project as it would protect the house from further deterioration and water ingress. If the Estate does not undertake these repairs, it is anticipated that the rate of deterioration could accelerate and that this could cost more to repair in the long run. The façade repairs have been costed at £6,330,000.

7.48 The State Rooms have seen very little recent conservation work, with the exception of works to the Great Hall undertaken in 2009. Over the years there have been a number of problems with the fabric of the rooms due to water penetration through defective roof finishes and rainwater disposal systems, and through defects in the stone façade. This has resulted in the delamination of ceiling and wall finishes and some structural defects. Whilst the defects to the roof and rainwater disposal system have been addressed, the legacy of this remains, and as such a number of the state rooms are in need of significant and important repairs. This work will amount to £3,059,000.

7.49 The Lion Gate and its Lodges are also in need of refurbishment. The associated cost of these repair works will amount to £173,625.

7.50 The accounts submitted with the Enabling Development Case set out the financial position in respect of the Syon Estate, demonstrating that the Northumberland Estate does not have surplus funds to support the required heritage works. Northumberland Estates has therefore explored whether there are potential granted/funding sources that could be used, including Historic England Grant, Heritage Lottery Fund and Private/Charitable Fundraising, however none of these is suitable.

7.51 Given this, the only way that these long-term maintenance costs can realistically be met, and for the Northumberland Estates to be financially self-sufficient and sustainable in heritage terms is to deliver additional income-generating developments.

7.52 The proposed PRS housing on the Park Road site would generate an annual income of £1,887,840 (the net annual income would amount to £1,038,312, taking into account taxation). It is estimate that the rental income from the units, deducting the finance (borrowing costs) for the development, taxation on income and management costs would provide a minimum assured income stream from which the Estates can commit £400,000 per annum to the scheduled heritage repairs.

7.53 The Enabling Development Case considers the proposals against the seven criteria in Historic England’s Enabling Development Policy:

a) It will not materially harm the heritage values of the place of its setting.

7.54 In relation to the proposed allotment gardens, the Heritage Impact Assessment which accompanies the planning application considers that any limited harm resulting from the localised change to landscape character to the south of Lion Gate could be considered minor ‘less than substantial’ harm having regard to the policies set out in the National Planning Policy Framework. However, it submits that the linked restoration works would considerably enhance the Lion Gate, including the view into the Park from London Road. The works would, it says, also enhance the Registered Park, Conservation Area, World Heritage Site Buffer Zone and the setting of Syon House.

b) It avoids detrimental fragmentation of management of the place.

7.55 The development would not result in the detrimental fragmentation of management of the place. As above, the proposed allotment gardens would result in a localised change to the landscape character to the south of Lion Gate but would remain integral to the park. The new allotments would be managed by the Syon Estate.

c) It will secure the long-term future of the place and, where applicable, its continued use for a sympathetic purpose.

7.56 The underlying principle of the proposals is to secure the long term future not only of Syon House but also the remainder of the Estate so that it can continue to be accessible to the public, as it has been for many years. The proposed development would allow for the redevelopment of Park Road site for housing (assessed under Planning Application 00707/E/P110) to fund the restoration of the State Rooms, the stone façade to Syon House and the restoration of the Lion Gate and its Lodges. As such, the enabling development would make a significant contribution to the longer term preservation of Syon Park.

d) It is necessary to resolve problems arising from the inherent needs of the place, rather than the circumstances of the present owner, or the purchase price paid.

7.57 The proposed heritage repairs are a direct response to the need to carry out significant conservation and restoration work to the State Rooms, the stone façade of Syon house and the Lion Gate and its Lodges to ensure that their fabric is maintained in good condition. As such, the project is driven solely by the heritage needs of the house and wider estate and not by the circumstances of the owner, The Trustees of the 10th Duke’s Will Trust. Furthermore, the proposed works bear no relationship to the price of the house, which was acquired in 1594 by Henry Percy, 9th Earl of Northumberland (1564-1632), and has remained in the family since this time.

7.58 Condition surveys and reports have been submitted in support of the application which explain the need for the heritage works to be undertaken, which make clear the enabling development is necessary to deal with problems directly associated with Syon Park.

7.59 The Estate is a responsible custodian of this Grade l listed building and is looking to invest £9,562,625.00 to safeguard its future. The façade repairs to Syon House is a very important project for the Estate as it would protect the house from further deterioration and water ingress for the longer term future. If the Estate does not undertake these repairs, it is anticipated that the rate of deterioration could accelerate and that this could cost more to repair. Moreover, further deterioration of the façade could give rise to increased water penetration and health and safety concerns, which could jeopardise public access to the building. This would compromise an important income stream from the Estate and would make on-going repairs and maintenance more difficult and costly to achieve.

e) Sufficient subsidy is not available from any other source.

7.60 Northumberland Estates has explored whether there are potential grant/funding sources that could be used, including Historic England Grant, Heritage Lottery Fund and Private/Charitable Fundraising, however none of these is suitable. No subsidies are therefore available from any other source to finance these works.

f) It is demonstrated that the amount of enabling development is the minimum necessary to secure the future of the place, and that its form minimises harm to other public benefits.

7.61 The proposed heritage works have been costed at £9,562,625 at 2016 prices, which includes the works to Lion Gate and its Lodges. The breakdown is as follows:  Work to Stone Façade: £6,330,000

 Work to State Rooms: £3,059,000

 Work to Lion Gate and Lodges: £173,625

Total: £9,562,625

7.62 A Business Plan has been submitted in support of the application which identifies a sum of £13,447,000 for heritage works which includes not only the £9,562,000 identified above but other major works which are required to heritage property over the coming years but which will be financed out of the Estates’ existing revenue streams for Syon Park, including the hotel. The Business Plan demonstrates the Estates’ actual and planned income and expenditure over the period of 2011/12 to 2016/17. This shows that Northumberland Estates does not have a surplus of funds sufficient to fund the proposed heritage works.

7.63 The proposed allotments would not directly provide an income to secure the future of the place however their relocation for the Park Road would instead allow for the redevelopment of the Park Road site for housing (assessed under Planning Application 00707/E/P110).

7.64 The proposed development has been carefully assessed as part of the planning application and it is considered that there is no harm arising with respect to other public interests. This is considered further below.

g) The public benefit of securing the future of the significant place through such enabling development decisively outweighs the disbenefits of breaching other public policies.

7.65 There are significant public benefits arising from the proposed development which decisively outweigh the disbenefits of breaching other public policies.

7.66 First, via a section 106 legal agreement it would secure important restoration works to Syon House and Lion Gate and its Lodges both of which are Grade 1 listed buildings. This will secure the long term future of this important national, Grade 1 registered heritage asset.

7.67 Second, it would safeguard Syon Park as a nationally important visitor attraction, thereby enhancing its contribution to tourism strategies.

7.68 The Estate provides extensive public access - both paid and unpaid - to Syon Park and it is estimated that some 750,000 people come to or pass through the estate annually to visit Syon House and its gardens, the Garden Centre, the Hilton Hotel, the Snakes & Ladders Adventure Playground or simply to enjoy the open space and parkland from the main drive area and the Duchess Gate path. Its contribution towards tourism strategies both local and nationally should not be underestimated. Many areas are freely available without charge although the Estate still has the obligation and responsibility to maintain these areas. It is estimated that approximately 10% of visitors to the Park pay to visit the House or Gardens and directly support their maintenance.

7.69 Third, it would secure allotment gardens for existing allotment holders within close proximity to the existing allotments and with improved facilities.

7.70 Paragraph 134 of the National Planning Policy Framework (NPPF) advises that where a development proposal would lead to less than substantial harm to the significance of a designated heritage asset, this harm should be weighed against the public benefits of the proposal, including securing its optimum viable use. The test as set out in the NPPF is similar to criterion ‘g’ of Historic England’s enabling development policy.

7.71 In relation to the proposed allotments in Syon Park, the Heritage Impact Assessment demonstrates that the slight reduction of the open parkland within Syon Park as a whole would affect its historic value as a designed landscape, and by implication, the Isleworth Riverside Conservation Area, the setting of Syon House, and the Buffer Zone of the Royal Botanic Gardens, Kew World Heritage Site. In reality this change would have a limited effect on perceptions of these heritage assets, since it would only be visible in passing from London Road. The proposed allotment scheme is also entirely reversible. Considered in isolation, these effects could be considered as minor ‘less than substantial’ harm having regard to the policies set out in the NPPF. However, the harm arising must be balanced against the heritage benefits arising directly from the proposal, comprising the reinstatement of an historic tree belt and the restoration of the Lion Gate and its Lodges. The proposed restoration work would considerably enhance the Lion Gate, including the view into the Park from London Road. The works would also enhance the Registered Park, Conservation Area, World Heritage Site Buffer Zone and the setting of Syon House.

7.72 As such, on balance, any limited harm resulting from the localised change to landscape character to the south of Lion Gate would be decisively outweighed by the linked proposed restoration works to the Lion Gate and its Lodges. The net effect overall is that the proposals would result in the conservation of the relevant heritage assets.

7.73 It is acknowledged that the relocation of allotment gardens into the grounds of Syon Park would result in a localised change to the landscape character in Syon Park. However, this impact or disbenefit, is decisively outweighed by the significant heritage and public benefits, which carry considerable weight in planning terms.

7.74 For the avoidance of doubt, the heritage benefits comprise the works to the State Rooms and the stone façade of Syon House, the restoration of Lion Gate and its Lodges plus the reinstatement of historic tree planting in the vicinity of Lion Gate. This would safeguard the future of this nationally important Grade 1 listed building. Other public benefits include the important contribution that Syon House and Park makes to tourism in London and which would be cemented via the proposed works; and allotment holders being provided with new and improved allotment gardens with associated utilities.

7.75 As set out above, the heritage benefits would safeguard the investment of £9,562.625.00 in a nationally important Grade I heritage asset and enable the restoration of the State Rooms and remedial works to the façade of Syon House over a 25 year period. This would be secured via a section 106 legal agreement. If these important works are not planned for and undertaken, the defects could deteriorate at an accelerated rate, which could result in more costly repairs. Moreover, there is a risk that if the works are not undertaken and the fabric of the house is left to deteriorate further that this could jeopardise public access currently afforded to the house.

Planning Obligations

7.76 The NPPG provides guidance on use of planning obligations, which may impose a restriction or requirement, or provide for payment to make acceptable development proposals that might otherwise not be acceptable in planning terms.

7.77 Local Plan policy IMP3 (Implementing and monitoring the Local Plan) states that the Council will ensure that new development in the borough contributes towards the provision of infrastructure needed to support growth and will achieve this by supporting the delivery of infrastructure through the use of Hounslow CIL receipts and planning obligations and expecting development proposals to mitigate the impacts of the development on the area through a section 106 agreement, where necessary and appropriate.

7.78 The Council’s Supplementary Planning Document on Planning Obligations (adopted March 2008) contains guidance on imposition of planning obligations in compliance with such guidance. These obligations may offset shortfalls in the scheme or mitigate a development’s impacts.

7.79 If approval were to be considered, the main areas listed below are to be included in any legal agreement:

 To undertake repair and restoration works to the Lion Gate and its Lodges.  To undertake the reinstatement of historic tree planting.  To undertake the reinstatement of the path leading to Syon House over Wyatt Bridge.  To carry out the works within a period not exceeding three years following commencement of construction of the allotments. 8.0 EQUALITIES DUTIES IMPLICATIONS

8.1 The public sector equality duty applies to all council decisions. 8.2 A public authority or any person who exercises public functions must, in the exercise of those functions, have due regard to the need to:

(a) eliminate discrimination, harassment, victimisation and any other conduct prohibited by or under the Act; (b) advance equality of opportunity between persons who share a relevant protected characteristic and persons who do not share it; (c) foster good relations between persons who share a relevant protected characteristic and persons who do not share it.

8.3 Having due regard to the need to advance equality of opportunity, this involves having due regard, in particular, to the need to:

(a) remove or minimise disadvantages suffered by persons who share a relevant protected characteristic that are connected to that characteristic; (b) take steps to meet the needs of persons who share a relevant protected characteristic that are different from the needs of persons who do not share it; (c) encourage persons who share a relevant protected characteristic to participate in public life or in any other activity in which participation by such persons is disproportionately low.

8.4 This shall include, in particular, but is not limited to steps to take account of disabled persons' disabilities.

8.5 The exercise of public functions must have due regard to the need to foster good relations between persons who share a relevant protected characteristic and those who do not, in particular, to the need to:

(a) tackle prejudice; and (b) promote understanding.

8.6 Compliance with these duties may involve treating some persons more favourably than others. This is not to be taken as permitting conduct that would otherwise be prohibited by or under the Act.

8.7 The relevant protected characteristics are: age; disability; gender reassignment; pregnancy and maternity; race; religion or belief; sex; marriage and civil partnership; and sexual orientation.

8.8 Due regard needs to be demonstrated in the decision making process and requires an analysis of the material with the specific statutory considerations in mind. It does not follow that the considerations raised will be decisive in a particular case the weight given to them will be for the decision maker. The equalities duty is not a duty to achieve a particular result. Some equalities considerations are covered under other legislation such as building control matters. Officers have in considering this application and preparing this report had regard to the public sector equality duty and have concluded that due regard has been given to the Council’s duty in respect of its equalities duties and that if approving or refusing this proposal the Council will be acting in compliance with its duties.

9.0 COMMUNITY INFRASTRUCTURE LEVY

9.1 Some new developments granted planning permission will be liable to pay Community Infrastructure Levy (CIL) to the Mayor of London and Hounslow.

9.2 CIL is payable on m2 of new floor space or where a new dwelling is created or the net floor area increase exceeds 100 m2.

Mayors £35 per m2 Hounslow: Housing: Supermarkets, Health care, All other East £200m2 superstores education and uses: 2 Central £110m2 and retail emergency £20m warehousing: services West £70m2 £155 m2 facilities: £0

9.3 This proposal would not be liable to pay Community Infrastructure Levy.

10.0 CONCLUSION

10.1 The proposed development would retain the agricultural use within this area of Syon Park and introduce low key infrastructure and structures associated with an allotment use. As this development would support an agricultural use, it is not considered inappropriate development in Metropolitan Open Land. Furthermore, it would open up a currently private area of the park to allotment holders.

10.2 The proposed development would relocate existing allotments from Park Road to facilitate a residential development on the Park Road site. The proceeds generated by this development would be reinvested into Syon House to fund important restoration work to this Grade 1 registered heritage asset. The new allotments would offer improved facilities for allotment holders, including access to parking and WC facilities, and importantly the provision of allotment gardens for allotment holders. The allotments would be managed by the Northumberland Estates, supported by a team of on-site specialist gardening and horticultural staff. The application would also secure a number of important heritage benefits, namely the restoration of Lion Gate and Lodges, the reinstatement of historic tree planting and the path leading to Syon House over Wyatt Bridge. These works are secured via a legal agreement.

10.3 The proposed development is in general accordance with planning policy. While the proposal would involve some minor adverse visual impacts, these are entirely reversible due to the light touch approach to new infrastructure and structures and would be mitigated with sensitive boundary treatment. Furthermore, the proposal should be considered having regard to the benefits that opening up this hitherto private area to allotment holders would bring, notably the provision of allotment gardens for the allotment holders and improved facilities. It is considered that any limited harm resulting from the localised change to landscape character to the south of Lion Gate would be outweighed by the linked restoration works. The proposals taken together are therefore considered to preserve the historic interest of the listed buildings concerned and the character and appearance of the Isleworth Riverside Conservation Area and would conserve the historic significance of Syon Park.

11.0 RECOMMENDATION: APPROVE

11.1 That planning permission be granted subject to the following conditions and securing the abovementioned planning obligations by prior completion of a satisfactory legal agreement or unilateral undertaking under Section 106 of the Town and Country Planning Act 1990 and/or other legislation (including any agreements under Section 278 or Section 38 of the Highways Act 1980), the exact terms of which shall be negotiated by appropriate officers in the Department of Regeneration, Economic Development & Environment on the Head of Governance’s advice.

11.2 The satisfactory legal agreement or unilateral undertaking outlined above shall be completed and planning permission issued by 22nd June 2018 or such extended period as may be agreed in writing by appropriate officers within the Department of Regeneration, Economic Development & Environment or Head of Governance’s Office.

11.3 If the legal agreement or unilateral undertaking is not completed by the date specified above (or any agreed extended period), then the Executive Director Regeneration, Economic Development & Environment or Director – Community Safety, Environment and Regulatory Services, Chief Planning Officer or the Head of Development Management is hereby authorised to refuse planning permission for the reason that the proposal should include planning obligations required to make the development acceptable in planning terms in accordance with Regulation 122 of the Community Infrastructure Levy Regulations 2010, development plan policies and the Planning Obligations SPD described above.

11.4 Following the grant of planning permission, where (a) requested to enter into a deed of variation or legal agreement in connection with the planning permission hereby approved and by the person(s) bound by the legal agreement authorised in paragraph 1 above, and (b) where the planning obligations are not materially affected, and (c) there is no monetary cost to the Council, the Executive Director Regeneration, Economic Development & Environment or Director – Community Safety, Environment and Regulatory Services or the Head of Development Management is hereby authorised (in consultation with the Chair and upon the advice of the Head of Governance) to enter into a legal agreement(s) (deed of variation) made under Sections 106 and/or 106A of the Town and Country Planning Act 1990 and or other appropriate legislation.

11.5 If planning permission is refused, the Executive Director Regeneration, Economic Development & Environment or Director – Community Safety, Environment and Regulatory Services or the Head of Development Management (in consultation with the Chair) is hereby authorised to approve any further application for planning permission or listed building consent validated within 12 months of the date of refusal of either application, provided that it (a) duplicates the earlier application, and (b) that there has not been any material change in circumstances in the relevant planning considerations, and (c) that a satisfactory legal agreement or unilateral undertaking securing the obligations set out in the report is completed within any specified period of time.

Conditions:

1 A1A Time Limit The development hereby permitted shall be begun before the expiration of three years from the date of this permission. Reason: To accord with the provisions of Section 92(1) of the Town and Country Planning Act 1990 (as amended).

The proposed development shall be carried out in all respects in accordance with the proposals contained in the application and the plans submitted therewith and approved by the Local Planning Authority, or as shall have been otherwise agreed in writing by the Local Planning Authority (before the building(s) is/are occupied/used). 2 E6 Landscape management plan A landscape management plan, including long term design objectives, management responsibilities and maintenance schedules for all hard and soft landscape areas, shall be submitted to and approved by the local planning authority prior to the occupation of the development or any phase of the development, whichever is the sooner, for its permitted use. The landscape management plan shall be carried out as approved. Reason: To ensure a satisfactory appearance of the site and improve the visual amenities of the locality. 3 E15 Provision for tree planting If within a period of two years from the date of the planting of any tree, that tree, or any tree planted in replacement for it, is removed, uprooted or destroyed or dies, (or becomes, in the opinion of the local planning authority, seriously damaged or defective,) another tree of the same species and size as that originally planted shall be planted at the same place, unless the local planning authority gives its written consent to any variation. Reason: To ensure a satisfactory appearance of the site and improve the visual amenities of the area. 4 E16 Existing trees which are to be retained In this condition "retained tree" means an existing tree which is to be retained in accordance with the approved plans and particulars; and paragraphs (a) and (b) below shall have effect until the expiration of 5 years from the date of the commencement of the site for its permitted use. (a) No retained tree shall be cut down, uprooted or destroyed, nor shall any retained tree be topped or lopped other than in accordance with the approved plans and particulars, without the written approval of the local planning authority. Any topping or lopping approved shall be carried out in accordance with British Standard [3998 (Tree Work)] or any other BS replacing. (b) If any retained tree is removed, uprooted or destroyed or dies, another tree shall be planted at the same place and that tree shall be of such size and species, and shall be planted at such time, as may be specified in writing by the local planning authority. (c) The erection of fencing for the protection of any retained tree shall be undertaken in accordance with the approved plans and particulars before any equipment, machinery or materials are brought on to the site for the purposes of the development, and shall be maintained until all equipment, machinery and surplus materials have been removed from the site. Nothing shall be stored or placed in any area fenced in accordance with this condition and the ground levels within those areas shall not be altered, nor shall any excavation be made, without the written consent of the local planning authority. Reason: To enable the Local Planning Authority to ensure the retention of the maximum number of trees on the site and their protection from damage, in the interests of visual amenity. 5 Drainage Infiltration Details No development shall take place until details of drainage infiltration techniques have been submitted to and approved in writing by the Local Planning Authority. The development shall be carried out in accordance with the approved details. Reason: In the interests of sustainability and to ensure the satisfactory management of surface water run-off from the development hereby permitted, including by preventing increased risk of flooding and pollution of the water environment, and in accordance with adopted Local Plan policy EQ3 (Flood Risk and Surface Water Management) and the London Plan (2015).

Informatives:

1 To assist applicants, the London Borough of Hounslow has produced planning policies and written guidance, which are available on the Council’s website. The Council also offers a pre-application advice service. In this case, the scheme was submitted in accordance with guidance following pre application discussions.

2 An archaeological watching brief that includes observation of groundworks and investigation of features of archaeological interest which are revealed will need to be implemented during the course of any excavation. A suitable working method with contingency arrangements for significant discoveries will need to be agreed. The outcome will be a report and archive.

3 The footway and carriageway on London Road should not be blocked during the conversion of the building. Temporary obstructions during development should be kept to a minimum and should not encroach on the clear space needed to provide safe passage for pedestrians or obstruct the flow of traffic on London Road.

Drawing Numbers:

Design and Access Statement dated December 2015, Flood Risk Assessment dated September 2015, Syon House The Lion Gate Survey of Condition dated October 2015, Ecological Assessment dated December 2015, Soil Assessment of Proposed Allotment Site at Syon Park dated 2 September 2015, Landscape & Visual Impact Assessment dated December 2015, Tree Survey dated 16th September 2015, FHA636L101 Rev. P2, FHA636L102 Rev. P2, FHA636L103 Rev. P2, FHA636D101 Rev. P1, Syon House Lion Gate Drawing 1, 2, 3, 4 and 5, 8974/01. Received: 23/02/2016. 2015-2334-AT-001 Rev. A, 2015-2334-AT-002 Rev. A, 2015-2334-AT-003, Farm Tractor & Trailer. Received: 12/05/2016. Statement of Community Involvement dated February 2016. Received: 01/03/2016. FHA636L101 Rev. P4. Received: 07/03/2016. Heritage Impact Assessment dated February 2016, Historic Environment Assessment dated February 2016, Planning Statement dated 15 February 2016. Received: 22/03/2016. Syon Park Projects Enabling Development Case dated 1 January 2017. Received: 14/02/2017.