Bentley Wood High School, Stanmore in the London Borough of Harrow Planning Application No

planning report D&P/3429/02 7 October 2014

Bentley Wood High School, Stanmore in the London Borough of Harrow planning application no. P/1322/14

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

The proposal Construction of a 3-storey classroom block and relocation of mobile classroom blocks.

The applicant The applicant is Harrow Council Children’s Services, and the architect is Howard-Fairbairn- MHK.

Strategic issues Outstanding issues in relation to transport are resolved satisfactorily.

The Council’s decision In this instance Harrow Council has resolved to grant permission. Recommendation That Harrow Council be advised that the Mayor is content for it to determine the case itself, subject to any action that the Secretary of State may take, and does not therefore wish to direct refusal.

Context 1 On 12 May 2014 the Mayor of London received documents from Harrow Council notifying him of a planning application of potential strategic importance to develop the above site for the above uses. This was referred to the Mayor under Category 3D of the Schedule of the Order 2008: “Development – (a) on land allocated as Green Belt or Metropolitan Open Land in the development plan, in proposals for such a plan, or in proposals for the alteration or replacement of such a plan; and (b) which would involve the construction of a building with a floor space of more than 1000 square metres or a material change in the use of such building.” 2 On 17 June 2014 the Mayor considered planning report D&P/3429/01, and subsequently advised Harrow Council that the application did not comply with the London Plan, for the reasons set out in paragraph 33 of the above-mentioned report; but that the possible remedies set out in that paragraph of the report could address these deficiencies. 3 A copy of the above-mentioned report is attached. The essentials of the case with regard to the proposal, the site, case history, strategic planning issues and relevant policies and guidance are

page 1 as set out therein, unless otherwise stated in this report. Since then, the application has been revised in response to the Mayor’s concerns (see below). On 25 June 2014 Harrow Council decided that it was minded to grant planning permission, for the revised application, and on 26 September 2014 it advised the Mayor of this decision. Under the provisions of Article 5 of the Town & Country Planning (Mayor of London) Order 2008 the Mayor may allow the draft decision to proceed unchanged or direct Council under Article 6 to refuse the application. The Mayor has until 9 October 2014 to notify the Council of his decision and to issue any direction. 4 The decision on this case and the reasons will be made available on the GLA’s website www.london.gov.uk. Update 5 At the consultation stage Harrow Council was advised that the application did not comply with the London Plan, for the reasons set out in paragraph 33 of the above-mentioned report; but that the possible remedies set out in that paragraph of the report could address these deficiencies:  Green Belt: Very special circumstances have been demonstrated that justify the school expansion on Green Belt. The development impact on the openness of the Green Belt is limited. The proposal is acceptable in land use context.  Transport: Financial contribution towards bus service improvement, increasing the number of cycle parking spaces, pedestrian safety and submission of updated travel plan, including CLP & DSP should be addressed before the scheme is referred back to the Mayor. Transport for London’s comments 6 At stage 1, TfL raised a number of matters including pupils pick up/ drop off, cycle parking travel plan and most importantly, the potential over-crowding on bus route 340 due to additional demand from the expanded school. 7 TfL initially agreed with Harrow Council that the applicant would enter into an agreement to undertake post school expansion surveys to determine the need for any bus service improvement with a contribution being paid if necessary. This arrangement will now be secured through a Grampian condition by Harrow Council along with bus stop shelter upgrade on Clamp Hill rather than by legal agreement, which both parties are satisfied. 8 TfL also welcomes that Harrow Council is to impose conditions ensuring that (a) the provision of proposed the new pupils pick up/ drop off area and associated access in Clamp Hill; (b) provision of cycle parking adhering to the London Plan standards, (c) the production of the revised travel plan, (d) submission of construction method and logistics statement. 9 In summary, TfL considers that the proposals are in conformity with London Plan transport policies. Response to consultation 10 A public consultation was undertaken which included statutory bodies and local residents, together with 443 individual letters of notification being sent to surrounding occupiers, as well as press and site notices advertising the application as a departure from the Development Plan were also published. 11 Responses from Residents: It is noted that only two replies were received from local residents, one supporting and the other objecting the proposal. The objection letter stated, “Should the proposal in anyway exacerbate the existing traffic congestion along Masefield Avenue and unless other proposals are provided regarding school traffic such as the access at Clamp Hill, we cannot support this development.” 12 Statutory consultees: The responses received following these consultation exercises are indicated below:

page 2  Sport England: Sport England has considered the application in light of its playing field policy and is satisfied that the proposed development would meet its policy requirements.  Environment Agency: No objection provided the suggested advice is considered. This site is in Flood Zone 1 and is under a hectare (the Council was not required to send consultation). The main flood risk issue is the management of surface water run-off and ensuring that drainage from the development does not increase flood risk either on-site or elsewhere. EA recommended that the surface water management good practice advice in its Flood Risk Standing Advice is used to ensure sustainable surface water management is achieved as part of the development. 13 In summary, concerns raised have been addressed in this and the stage 1 report of the GLA, and the Council’s committee report. Legal considerations 14 Under the arrangements set out in Article 5 of the Town and Country Planning (Mayor of London) Order 2008 the Mayor has the power under Article 6 to direct the local planning authority to refuse permission for a planning application referred to him under Article 4 of the Order. The Mayor may also leave the decision to the local authority. In directing refusal the Mayor must have regard to the matters set out in Article 6(2) of the Order, including the principal purposes of the Greater London Authority, the effect on health and sustainable development, national policies and international obligations, regional planning guidance, and the use of the River Thames. The Mayor may direct refusal if he considers that to grant permission would be contrary to good strategic planning in Greater London. If he decides to direct refusal, the Mayor must set out his reasons, and the local planning authority must issue these with the refusal notice. Financial considerations 15 Should the Mayor direct refusal, he would be the principal party at any subsequent appeal hearing or public inquiry. Government Planning Practice Guidance emphasises that parties usually pay their own expenses arising from an appeal. 16 Following an inquiry caused by a direction to refuse, costs may be awarded against the Mayor if he has either directed refusal unreasonably; handled a referral from a planning authority unreasonably; or behaved unreasonably during the appeal and this unreasonable behaviour has directly caused another party to incur unnecessary or wasted expense. A major factor in deciding whether the Mayor has acted unreasonably will be the extent to which he has taken account of established planning policy. 17 Should the Mayor take over the application he would be responsible for holding a representation hearing and negotiating any planning obligation. He would also be responsible for determining any reserved matters applications (unless he directs the Council to do so) and determining any approval of details (unless the Council agrees to do so). Conclusion 18 Outstanding planning issues have been resolved. The proposed development is supported in terms of good strategic planning in Greater London.

For further information, contact: GLA Planning Unit (Development & Projects Team): Colin Wilson, Senior Manager - Planning Decisions 020 7983 4783 email: [email protected] Justin Carr, Strategic Planning Manager (Development Decisions) 020 7983 4895 email: [email protected] Tefera Tibebe, Case Officer 020 7983 4312 email: [email protected]

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planning report D&P/3429/01 17 June 2014 Bentley Wood High School, Stanmore in the London Borough of Harrow planning application no. P/1322/14

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

The proposal Construction of a 3-storey classroom block and relocation of mobile classroom blocks. The applicant The applicant is Harrow Council Children’s Services, and the architect is Howard-Fairbairn- MHK.

Strategic issues School provision on Green Belt and transport are the most relevant strategic issues to this application.

Recommendation That Harrow Council be advised that the application does not comply with the London Plan, for the reasons set out in paragraph 33 of this report; but that the possible remedies set out in that paragraph of the report could address these deficiencies.

Context

1 On 12 May 2014 the Mayor of London received documents from Harrow Council notifying him of a planning application of potential strategic importance to develop the above site for the above uses. Under the provisions of The Town & Country Planning (Mayor of London) Order 2008 the Mayor has until 23 June 2014 to provide the Council with a statement setting out whether he considers that the application complies with the London Plan, and his reasons for taking that view. The Mayor may also provide other comments. This report sets out information for the Mayor’s use in deciding what decision to make. 2 The application is referable under Category 3D of the Schedule to the Order 2008: ”Development – (a) on land allocated as Green Belt or Metropolitan Open Land in the development plan, in proposals for such a plan, or in proposals for the alteration or replacement of such a plan; and (b) which would involve the construction of a building with a floor space of more than 1000 square metres or a material change in the use of such building.”

page 4 3 Once Harrow Council has resolved to determine the application, it is required to refer it back to the Mayor for his decision, as to whether to direct refusal or allow the Council to determine it itself, unless otherwise advised. In this instance if the Council resolves to refuse permission it need not refer the application back to the Mayor. 4 The Mayor of London’s statement on this case will be made available on the GLA website www.london.gov.uk. Site description 5 The application site which has an area of 10.23ha is located at Stanmore on land designated as Green Belt. It is accessed by Bridges Road to the south east and Clamp Hill to the south west. The closest stations to the school are Headstone Lane train station and Stanmore tube station that are 1.5 and 1.3kms from the school respectively. 6 The site has a very poor public transport accessibility level (PTAL) of 1b, on a scale of 1 to 6 where 6 is the highest. There are school bus route services and the bus stop outside the school’s Clamp Hill entrance is approximately 300m from the main school building, and a further two routes serve the stops approximately 550m from the site on A410 Uxbridge Road, which forms part of the Strategic Road Network (SRN). Details of the proposal 7 The proposal is part of the Harrow Council’s schools expansion programme which incorporates the construction of a 3-storey classroom block to the north east of the existing school building and temporary relocation of mobile classroom blocks, enlargement of the sports hall, new vehicle access from Clamp Hill and associated parking spaces. 8 The proposal would increase the capacity of the school from currently 1,035 pupils, and 183 staff by phases to 1,245 pupils with 218 staff by September 2020. Case history 9 There is no relevant case history available. Strategic planning issues and relevant policies and guidance

10 The relevant issues and corresponding policies are as follows:  Green Belt London Plan  Education London Plan  Transport London Plan; the Mayor’s Transport Strategy 11 For the purposes of Section 38(6) of the Planning and Compulsory Purchase Act 2004, the development plan in force for the area is the 2012 Harrow Core Strategy, and the 2011 London Plan (with Alterations, 2013).

12 The following are also relevant material considerations:  The National Planning Policy Framework and Technical Guide to the National Planning Policy Framework  The draft Further Alterations to the London Plan (January 2014). Principle of Land Use: Education facility on Green Belt

13 The school is a girls-only school for pupils from Year 7 to Year 13 in five-forms of entry. The proposal for extension will increase the numbers of forms of entry to six, thus increasing the number of pupils from approximately 1,035 to 1,245. Staff numbers will also increase from 183 to 218.

page 5 14 In relation to the provision of educational facilities, policy 3.18 'Education facilities' of the London Plan states that “Development proposals which enhance education and skills provision will be supported, including new build, expansion of existing facilities or change of use to educational purposes”. The policy states ‘The Mayor will support provision of early years, primary and secondary school and further education facilities adequate to meet the demands of a growing and changing population and to enable greater educational choice, particularly in parts of London with poor educational performance. …Development proposals which enhance education provision will be supported, including new build, expansion of existing facilities or change of use to educational purposes. 15 The Mayor within the draft FALP 2014 notes that access to high quality school education is a fundamental determinant of the future opportunities and life chances of London’s children and young people. This document taking the most up to date available census data notes London’s population will continue to be younger than elsewhere in England and Wales and by 2036, its school age population is projected to increase by 18 per cent further highlighting the wider London need for increase capacity within the capitals schools. The Mayor’s 2020 vision identifies a need for 4,000 extra primary classes by 2020. 16 Para 72 of the NPPF states ‘The Government attaches great importance to ensuring that a sufficient choice of school places is available to meet the needs of existing and new communities. Local Planning Authorities should take a proactive, positive and collaborative approach to meeting this requirement and to development that will widen the choice of education. They should give great weight to the need to create, expand or alter schools.’ 17 The application site is part of a larger area identified as Green Belt. The National Planning Policy Framework (paragraph 89) and the London Plan (policy 7.16) set out that only development associated with agriculture, forestry, outdoor sport and recreation, limited infilling and redevelopment of existing sites is appropriate in the Green Belt. All other forms of development are, by definition, ‘inappropriate’. In order for ‘inappropriate’ development to be acceptable in the Green Belt, very special circumstances must apply. 18 The NPPF in Para 87 sets out that inappropriate development is, by definition, harmful to the Green Belt and should not be approved except in ‘very special circumstances’. When considering any planning application, local planning authorities should ensure that substantial weight is given to any harm to the Green Belt. ‘Very special circumstances’ will not exist unless the potential harm to the Green Belt by reason of inappropriateness, and any other harm, is clearly outweighed by other considerations. 19 The applicant has identified the ‘very special circumstances’ that may justify the proposed school development on the Green Belt. They can be summarised as pressing educational needs and limited impact on the character, appearance and openness of the Green Belt.  Educational needs: In common with the majority of London local authorities and given London’s ever increasing population, Harrow is experiencing an unprecedented increase in demand for school places and because of the increased demand is primarily birth rate the pressure is currently focussed in the primary phase. The increased demand for primary school places progresses into the secondary phase and will exceed available permanent places by 2015. The overall numbers of pupils in secondary schools in Harrow is projected to rise from 10,373 in September 2014 to 13,123 in September 2021. As things stand, and without a strategy to increase the capacity in the secondary sector, the total secondary places available in 2021/22 will be 10,740 (a deficit of -22.07%). The Council as a statutory provider of sufficient school places launched its School Place Strategy (2010) and identified this pressing need of educational places arising from increased demand and aimed to secure school places through the creation of additional permanent school places to a sustainable level, supplemented by planned temporary additional classes to meet peaks and fluctuations in demand, and contingency temporary classes opened if required.

page 6 To that effect the Council set out and identified suitable sites for expansion in the borough, in which Bentley Wood High School has been selected for expansion.  Limited impact on Green Belt: The applicant has stated that the educational use of this site is long established and that it contains a variety of substantial educational building blocks and associated hard-standing including tennis courts and is therefore is considered to be a brownfield site within the Green Belt. The applicant pointed out that the Council’s Planning Policy on Green Belt and Metropolitan Open Land allows for redevelopment or infilling of previously developed sites but only where it would not have a greater impact on the openness of the Green Belt. Having regard to the above, the applicant has analysed the proposal as shown below: - Height : The height of the existing school building is approx.12m whilst the proposed development will have a height of 11.7m. In addition to this decrease in height, there will be more screening that would ensure a limited impact of the scheme on the character and openness of the Green Belt. - Footprint, spread & proportion of development: The existing buildings on the site have an overall footprint of 4,313sqm (which equates to 4.22% of the overall school site), with the proposals resulting in a marginal increase in this figure to 5,400sqm (which equates to 5.28% of the overall school site). However, the proposed buildings will be sited on over an area of existing hard surface and will be designed in a more compacted and clustered form ensuring a limited visual impact on the character and openness of the Green Belt. Furthermore, when this slight increase (1.04%) is considered in the context of the overall school site which has an area of 10.23ha, its impact on the openness of the Green Belt is limited. - The relationship of the proposal with any development on the site that is to be retained. The new permanent school buildings would be a carefully controlled expansion of the existing school and would reasonably relate to the existing buildings and hard standing and therefore cannot be described as unrestricted sprawl. There would be no encroachment into the countryside given the relationship of the proposals with the existing school boundaries and existing hard-standing on the site. 20 The applicant concluded that the harm caused by the proposals would be limited by reason of their proposed siting, design and landscape setting. Whilst it would be preferable, in planning policy terms, to develop on land not currently included within the Green Belt, no such realistic option is available. The education and community needs case in these circumstances are compelling and amount to a very special circumstances case. Furthermore, the proposals would enhance access to indoor leisure facilities both for pupils on the site and those members of the community given access under the proposals. On balance therefore, the proposals would be acceptable with the need to improve school facilities and aims of the NPPF outweighing the limited harm the additional buildings would have on the character, appearance and openness of the Green Belt. 21 GLA officers assessment of the applicant’s very special circumstances case is as follows:  Educational needs: The Mayor supports the expansion of schools and acknowledges that there are various factors that limit potential sites and configurations to address the pressing need of school places. In this instance, the applicant has clearly set out the predicted demand for school places across the borough and how this is being met. It has evidenced that there are no other suitable and available sites in the catchment area. Therefore, the case for educational needs is accepted as a very special circumstance.  Limited impact on Green Belt: The NPPF allows for redevelopment of previously developed sites but only where it would not have a greater impact on the openness of the Green Belt. In this instance, although the proposals appear to result in a marginal increase in built form (the

page 7 slight increase in footprint), the development is contained on the existing hard surface with a reduced height and that the overall development will be designed in a more compact and clustered form limiting its impact on the character and openness of the Green Belt. Therefore, the case for limited impact on the Green Belt is accepted as a very special circumstance. 22 In conclusion, it is considered that the applicant has successfully demonstrated the very special circumstances that justify the inappropriate development on Green Belt. On balance, it is considered that the benefits of the scheme, its contribution in overcoming shortages of school places in London, would outweigh the limited harm it would have on the character, appearance and openness of the Green Belt Transport for London’s comments 23 The proposal would increase the capacity the school from currently 1,035 pupils, and 64 full time staff to 1,253 pupils with 73 full time staff by September 2018. Given the school’s relative remote location and its wider catchment area, a significant proportion (32%) of pupils and staff (73%) are currently travelling by car. It is therefore predicted that the enlarged school would generate an additional 94 two way car trips. TfL therefore supports the measures proposed to mitigate parking stress and resulting congestions on Maesfield Road, Bridge Road and Binyon Crescent, this would prevent knock on impact to A410 Uxbridge Road, in particular the Uxbridge Road/Masefield Avenue priority junction. 24 To divert school run trips away from Masefield Avenue and surround local roads, it is proposed to create a pick up/ drop off area near the Clamp Hill entrance; this includes improving the existing site access and creating the secondary egress access on Clamp Hill. TfL supports the pragmatic approach to divert trips away from Uxbridge Road and local roads in the vicinity. Harrow Council, however needs to be satisfied that the proposal is acceptable in highway and safety terms. TfL also requests that adequate footpath be provided allowing pupils/staff to walk safely between Clamp Hill bus stop, pick up/drop off area and the main school site. TfL also welcomes the applicant’s proposal that Harrow council to strengthen parking enforcement on surrounding local roads to deter inconsiderate/illegal parking to minimise impact to local borough roads and subsequently Uxbridge Road. TfL supports this arrangement and recommends this forms part of the updated school travel plan measure. 25 TfL is disappointed that, the proposal does not include additional cycle parking to enlarge the existing 20 spaces for staff and pupils that improves the current low cycle mode share. As such, additional cycle parking spaces and shower/changing facilities should be provided, with reference to the standard in to the emerging Draft Further Alterations to London Plan ‘FALP’. The school shall also monitor the use cycle parking and usage through the updated school travel plan. 26 TfL understands that the school will expand at a rate of 30 students per year until 2020 when the school will reach capacity; and predicts that an additional 111 bus trips will be generated during school days once the school reaches capacity. As such, TfL considers that an additional journey on route 340 toward Edgware for the PM will be needed to ease potential over-crowding between Harrow Weald, Clamp Hill and Stanmore Broadway. TfL therefore seeks a contribution of £60,000 per annum for the period of 5 years, which equates to £300,000 in total; this should be secured by appropriate mechanism. In order to accommodate additional bus demand at bus stop on Clamp Hill outside the school entrance, TfL recommends that the existing bus stop shelter be upgraded to an four-bay shelter at a cost of £12,300. TfL also welcomes further discussion on the applicant’s aspiration to extend the existing school bus route 640 into the school site in the long term. 27 TfL expects that Harrow Council to secure the submission and delivery of an updated travel plan which shall be accredited by the ‘Sustainable Travel Accreditation & Recognised – STAR’ scheme. Tougher targets for walking, cycling and use of public transport should be set to achieve greater shift to sustainable modes of transport; along with the monitoring of cycle usage and cycle

page 8 parking provision, and strengthen parking enforcement. TfL also recommends the staggering of school start/finish time to disperse impact to the highway network. 28 It is expected that Harrow Council is to secure the submission of full construction management plan, construction logistics plan, delivery & servicing plan by conditions. 29 In summary, the applicant is required to address the above issues satisfactorily to ensure the proposal is fully London Plan compliance. Local planning authority’s position 30 Harrow Council planning officers have yet to confirm their position Legal considerations 31 Under the arrangements set out in Article 4 of the Town and Country Planning (Mayor of London) Order 2008 the Mayor is required to provide the local planning authority with a statement setting out whether he considers that the application complies with the London Plan, and his reasons for taking that view. Unless notified otherwise by the Mayor, the Council must consult the Mayor again under Article 5 of the Order if it subsequently resolves to make a draft decision on the application, in order that the Mayor may decide whether to allow the draft decision to proceed unchanged or direct the Council under Article 6 of the Order to refuse the application. There is no obligation at this present stage for the Mayor to indicate his intentions regarding a possible direction, and no such decision should be inferred from the Mayor’s statement and comments. Financial considerations 32 There are no financial considerations at this stage. Conclusion 33 London Plan policies on Green Belt and transport are the most relevant strategic issues to this application. The proposed development broadly complies with the London Plan. However, there are few issues that must be addressed as set out below:  Green Belt: Very special circumstances have been demonstrated that justify the school expansion on Green Belt. The development impact on the openness of the Green Belt is limited. The proposal is acceptable in land use context.  Transport: Financial contribution towards bus service improvement, increasing the number of cycle parking spaces, pedestrian safety and submission of updated travel plan, including CLP & DSP should be addressed before the scheme is referred back to the Mayor.

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