PLANNING COMMITTEE 12 May 2016 [email protected]
References: P/2015/4055 00607/AM/P5
Site: Watermans Park, High Street, Brentford, London TW8 0DS
Description: Creation of 26 permanent moorings with a new 14 space car park and associated landscaping
This application is being taken to Planning Committee as it is a major application on Council owned land.
1.0 SUMMARY
1.1 The application proposes the creation of 26 permanent residential moorings with an associated structure for car parking, servicing and storage at Watermans Park, as well as new landscaping throughout the park itself.
1.2 The existing boats which are moored without consent or proper services would be replaced with new good quality residential mooring spaces that would include appropriate access and services including power, water and sewerage. Environmental impacts, including to the river are satisfactory, and the scheme would also remove unsightly wrecks and rubbish from the site, whilst new landscaping to the park would enhance its appearance and opportunities for its use.
1.3 Detailed conditions covering demolition work and construction, including within the river would minimise environmental effects, whilst other conditions controlling the management of the moorings would ensure ongoing operational impacts are satisfactory and not disruptive to the use of the river or adjacent park.
1.4 The application is recommended for approval subject to conditions.
2.0 SITE DESCRIPTION
2.1 The application site is comprised of Watermans Park and a stretch of the adjacent River Thames. Watermans Park is a landscaped open space alongside the Thames, with an area of appropriately 1.1 hectares. It is positioned between the river and Brentford High Street, and is to the east of Brentford town centre. The western end of the park adjoins the Watermans Arts Centre. The eastern end of the park adjoins a raised car parking area and access that serves ‘Victoria Steps Quay’, a residential mooring scheme that has a number of boats moored along the Thames downstream from the site (moorings for 6 boats).
2.2 Access to the park is provided at four points. Access is provided by graded pathways and stairs. Three of these are from the High Street, with these being located at both ends of the park, with there also being a set of stairs and a ramp in the eastern half of the park (around 95m and 135m respectively from the eastern boundary of the site). At the western end of the site there is also a pathway along the river in front of the Watermans Art Centre. The entrance of the High Street adjacent to the Watermans Art Centre is accessible to vehicles (for emergency access only). 2.3 The park contains landscaped areas with planter beds, ornamental shrub and tree planting, pathways, seating and a children’s playground. The park contains some sloping areas and is mostly set below the level of the adjacent roadway. A paved pedestrian pathway, enclosed by railings to one side runs alongside the river. This pathway is part of the Thames Path. Past the eastern side of the site the Thames path is diverted to the High Street as there is no through route owing to private land extending to the riverbank (Victoria Steps Quay).
2.4 The adjacent Thames River is tidal, with the river bed largely exposed at low tides. The river bed is formed of mud and shingle. The river at this location is split in two by Brentford Ait, a narrow island that is well vegetated, with the thick tree cover screening the urban development of Brentford from the green spaces of Kew. The main channel of the river is to the south of the Ait. On the opposite bank, beyond the Ait is a towpath and the Royal Botanic Gardens, Kew. The gardens are a World Heritage Site (WHS) and a WHS buffer zone extends to the high water mark on the site. Further upstream is Lots Ait an island with a boat repair yard and moorings.
2.5 The majority of Watermans Park is designated as Local Open Space (No. 57) in the Hounslow Local Plan, with the exception of an area of approximately 715sqm at the easternmost end of the park. The area of riverbed exposed at low tide is designated as Metropolitan Open Land and the river as a Site of Importance for Nature Conservation. The whole site is within the Thames Policy Area.
2.6 Over 30 boats including derelict and wrecked craft are moored parallel to the park and foreshore pathway, up to three abreast, with boats tethered to existing piles and to the foreshore. The boats vary in size, type and condition. It appears some of the boats are not capable of navigation.
2.7 The majority of the boats are occupied and appear to be used as primary places of residence. There is evidence boats are also rented with one known to provide visitor accommodation.
2.8 Access to boats is provided by climbing over existing fencing to ramps and gangplanks attached to the fence/ riverbank, with boats on the outside of the row being accessed via other boats.
2.9 Apart from a hotel and the Musical Museum, the area to the north of the High Street has predominantly residential development including high rise flats, townhouses and the converted former St George’s Church (undergoing conversion).
2.10 The site is served by regular bus services on the High Street (237 and 267) going to Brentford, Isleworth, Hounslow, Twickenham and Chiswick, and is within a reasonable walking distance from Kew Bridge railway station. It has a Public Transport Accessibility Level (PTAL) of 3, which is moderate.
3.0 HISTORY
Planning history
3.1 The site was once part of the Brentford Gas Works with the foreshore used for delivery of coal by barges. The area adjacent to the river was redeveloped as a public park (opened in 1983) with the remainder of the gas works site redeveloped for housing and the Watermans Art Centre. Improvements to the park have been ongoing with new tree planting and play equipment being provided.
3.2 The most relevant planning history relating to this site is given below.
3.3 00607/M/P9 Erection of 3-storey offices and arts centre comprising theatre, cinema, exhibition hall, bar, cafeteria & ancillary accommodation, with associated parking spaces and riverside walkway
Approved 25 August 1981
3.1 Victoria Quay Steps moorings (7-8 High Street Brentford) with its associated parking deck were developed in the late 1980s. Approval of these moorings followed refusal of a number of proposed schemes for moorings and associated development that were considered to be overdevelopment. The existing moorings (for 6 boats) have a dedicated car park and refuse storage area adjacent to the High Street, with moorings being fully serviced.
Mooring consents
3.2 Boats are able to be moored on the river as there is a public right of navigation, which permits mooring as required, provided there is no obstruction to navigation.
3.3 There is however no right to moor boats to structures or land owned by other parties without their permission. Therefore where mooring or access to the riverbank is sought, the permission of the land owner is needed.
3.4 In this instance the boats moored at the site utilise various river infrastructure and land that are owned or controlled by others, and no consents to moor permanently have been given to any of the boat owners, and so the existing permanent mooring of these boats is not authorised.
3.5 There is a current River Works Licence that covers structures within the river that is subject to jurisdiction of the Port of London Authority. This licence is to the benefit of the London Borough of Hounslow. The permanent mooring of vessels to these structures is not covered by the licence.
3.6 Other boats are permanently moored to railings and embankment of Watermans Park, which is owned by the London Borough of Hounslow, for which no consent as the riparian landowner has been given.
Planning permission
3.7 Given the particular circumstances of the site and its use, the present operational use for permanent residential moorings is considered to be a material change of use of the site that would have required planning permission from the Local Authority. In this regard the site is being used to provide permanent dwellings/primary places of residence for which planning permission is required, as opposed to the temporary or transient mooring of vessels and use of the river for navigational purposes which would be ancillary uses of a waterway, not requiring planning permission. Also various permanent structures, including gates, fencing and fixed ramps for access constitute development for which no planning permission has been obtained.
Previous enforcement
3.8 Action was taken against boats moored without consent alongside the park in 1999, and wrecked and abandoned vessels were also removed. However by 2004 some boats had returned with additional boats being permanently moored over time since then.
Redevelopment
3.9 The application has been submitted on behalf of the Council by consultants following resolution of the Council’s Cabinet on 9 September 2014 (and follows from a previous resolution of the Cabinet in 2002 to support a similar scheme). The 2014 resolution agreed a programme to proceed with a redevelopment scheme to provide a marina at Watermans Park to achieve the following benefits and objectives:
26 berths for permanent residential houseboat moorings; Environmental enhancements to Waterman’s Park with improvements to the riverside open space; Generate a positive capital receipt; Serve as the catalyst to remove the existing unauthorised moorings at Waterman’s Park; and Regulatory compliance with the Port of London Authority (PLA).
4.0 DETAILS
4.1 The application proposes the creation of 26 permanent residential moorings adjacent to Watermans Park. New landscaping as well as a building providing utilities and services for the moorings and car parking is also proposed in Watermans Park.
Moorings and car park
4.2 The new moorings are located alongside the park as well as the Watermans Art Centre. They would be accessed by a floating pontoon system linked to the foreshore at the eastern end of the park. Most of the moorings would be provided in a ‘chevron’ layout, with boats aligned at an angle to the riverbank, the exception being two moorings that would be parallel to the bank in front of the Arts Centre.
4.3 The floating pontoon walkways proposed to access the moorings rise and fall with the tide. Boats would be moored to new timber piles. As the river is tidal and the riverbed is partly sloping, each mooring space includes a timber framed grid that boats would rest on at low tide to ensure they are level. Some dredging is proposed adjacent to the existing river wall to remove sediment build up and permit level settling of vessels.
Image 1: Proposed mooring layout
4.4 A new car parking area providing 14 car spaces and refuse collection area is proposed at the eastern end of the park. The car park would provide open parking at the same level as the adjacent road, with the space beneath enclosed to provide plant rooms, refuse storage and general storage to serve the needs of residents of the moorings. All moorings are to be connected to utilities (water, sewerage and electricity).
4.5 The proposed car park building is adjacent to the car park serving the adjacent moorings at Victoria Steps Quay. The building is 16.2m long and 24.296m wide, and is located between 2.5m to 4m from the existing river edge. Timber fencing is to be provided along its riverside to screen overlooking of existing moorings at Victoria Steps Quay. The structure, excluding fencing to the riverside, would be 4.04m high to the top of the parapet of the car park. Access to the car park would be for residents and visitors only. Stairs and a platform lift would provide access to the park and lower level. It would be finished in face brickwork, with detail to openings.
4.6 Details of the mooring fee and finances are to be finalised separately, with the Council partnering with the Port of London Authority, but it is intended that the moorings will be let on a long lease with yearly management/ servicing fees. An Operational Management Plan covering all aspects of access, servicing and mooring of vessels would be required by a condition.
4.7 It is noted that ownership of the majority of the riverbed of the Tidal Thames up to the mean high water mark has been vested in the Port of London Authority (PLA). A River Works Licence from the PLA is necessary for works to the riverbed including dredging and installation of new mooring apparatus such as pilings and pontoons.
4.8 The proposed scheme follows from a decision of the Council’s Cabinet on 9 September 2014 for a development of a marina at the site to provide ongoing revenue for the Local Authority, resolve the long standing issue with unauthorised mooring to existing infrastructure and Watermans Park, and enhancement of the park’s landscape and recreational value (See Appendix 1 for Borough Council report and decision).
Watermans Park
4.9 The application also proposes alterations to the existing landscaping of Watermans Park. An existing concrete and timber platform and supporting piles at the foreshore are to be removed and replaced with new planting areas contained within timber posts and planks. These areas would be planted with reeds to enhance the ecological value of the site.
4.10 At the eastern end of the site an existing zig-zag walkway and steps into the park, seating and planted areas would be replaced with the new car parking structure. New stairs are to be provided along the western side of this new building. Elsewhere at the centre of the site a new flight of stairs is to be provided from the High Street.
4.11 Pathways, levels, planting and seating are to be rearranged to provide a more interesting layout. At the western end of the park there would be a space for a future ‘pop-up’ style café, a new performance area with small stage and stepped lawn seating areas. The existing playground would be relocated more towards the centre of the park and new equipment provided in a secure enclosure.
4.12 The application submission includes a:
Design and Access Statement, Archeological Report, River Impact Assessment, Habitat Survey, Ecological Enhancement Statement, Arboricultural Statement, Transport Statement, Contaminated Land Report, Navigational Risk Assessment, Flood Risk Assessment.
5.0 CONSULTATIONS
5.1 Prior to submitting the application a public exhibition was held at the Watermans Arts Centre, on: Tuesday 28th October 2014, 4pm – 7pm and Saturday 1st November 2014, 11am – 2pm. The events were attended by a total of approximately 80 people. Plans for the proposal were displayed at the Arts Centre from 28 October to 22 November 2014, and were also available on the Council’s website.
5.2 Subsequently a further public exhibition to display revised plans was held on Saturday 13th June, 9am – 12.30pm and Tuesday 16th June, 3pm – 7.30pm
5.3 Letters giving notification of the planning application were sent to over 190 neighbouring property owners and residents on 13 October 2015. Letters were also hand delivered on 16 October 2015 to all accessible post boxes (5) along the Watermans Park river frontage and to one person on a boat without a post box.
5.4 Additional notification included two site notices erected at the entrances to Watermans Park on 16 October 2015 and the publication of a press notice in the local newspaper on 23 October 2015. Note the application was subject to earlier consultation (two site notices erected on 1 October 2015 and a press notice published on 9 October 2015) but the application was later found to be invalid due to an error in the application site boundary. Following receipt of additional information those persons and groups that had made a submission were notified on 18 March 2015 and given 7 days for any further comments.
5.5 There were 12 respondents, with 11 objections received. A summary of the issues raised and a response is given in the table below.
Comment Response Impacts on Watermans Park environment The development on the park would None of the area of the park to be built result in harm to the Metropolitan Open on is designated as MOL. The majority Land (MOL) through loss of openness, of the site is designated in the Hounslow quality and permanence resulting from Local Plan as Local Open Space; the car park, which is an inappropriate however the site of the car park has no use on MOL. designations. See paragraphs 7.60 to 7.66. Loss of open space from park See above comment. (500sqm). The development does not respond to The new landscaping enhances wider context and character of the park, biodiversity in the park with additional and does not preserve the heritage, trees and planting areas, it creates a social and environmental aspects of the wider choice of spaces for play, park. recreation and cultural activities including performances, and maintains existing heritage such as remnant brick structures along the roadside. The new mooring layout would remove unsightly and derelict boats and encroachment on the riverside walkway, opening up more views of the water, respecting the riverside character of the site. There is no demand for changes to park The park is identified in the Thames or additional facilities. Landscape Strategy as providing opportunity for enhancement. The development fails to protect or This study provided an assessment of maintain the park as recommended by the needs for open space, sports and a previous study (PPG 17 study (2011). recreation facilities, and opportunities for new provision and helped inform the Hounslow Open Space Strategy 2013 and the policies of the Hounslow Local Plan. The new landscaping to the park enhances its appearance providing a greater variety of planting, more interesting spaces and retains areas for active and passive recreation, protecting its function and amenity value. New tree planting creates unsafe areas. A condition requires final details of the proposed hard and soft landscaping to be submitted for approval, with this to include new and enhanced lighting. Lighting, pathways and planting would be coordinated to ensure main pathways are well lit and visible to maximise security. The existing open, gently sloping, The existing area of the park that would eastern entrance is a vital part of green accommodate the proposed car park is thoroughfare and experience of a fairly barren space that lacks quality Watermans Park, the car park would landscaping. It is however a quiet corner destroy the quiet and tranquillity of the that also includes an access point. The space. introduction of the proposed building would result in the loss of this landscaped area and is a negative impact of the development. However the proposed car park and utility building provides full infrastructure and necessary facilities for the moorings and the siting of the building is the least intrusive option that has minimised encroachment into the park. New landscaping throughout the park and removal of unsightly boats and ad-hoc additions to the foreshore railings will enhance its overall amenity value, offsetting the harmful impact to this space. Addition of fill would raise area of park Some minor changes in level are resulting in loss of screening from noise proposed in the park to create small and pollution from adjacent roadway. terraces and slopes for sitting and to add interest to the landscape. The park will however remain much lower than the adjacent roadway whilst new buffer planting along the street side would enhance the screening of noise and pollution. Flat open areas are reduced leading to The originally submitted scheme was loss of space for informal games such revised to ensure new planting still as football allowed for grassy open spaces suitable for informal games to be maintained. Does not enhance heritage assets in See paragraphs 7.56-757 and 7.69 park. below. The scheme unduly alters layout and The new landscaping enhances its use of park and does not create appearance providing a greater variety attractive spaces. It provides sterile, of planting, more interesting spaces and lifeless landscaping, which detracts retains areas for active and passive from experience of park and does not recreation, protecting its function and meet needs of local community amenity value. Design and impacts of moorings Fails to correctly analyse effects on The effects on the waterway and local environment including Thames. riverside environment have been properly considered in consultation with the Environment Agency and Port of London Authority. Herringbone or chevron layout not The appropriateness and environmental found elsewhere on tidal Thames and is effects of the proposed mooring layout impractical and costly. has been considered by the Port of London Authority. The layout avoids a continuous line of boats parallel to the riverbank, maximising views of the waterway striking a balance between practical needs of the moorings and the visual amenity of the public open space. Adverse impact on natural river flows Assessment of environmental effects of causing sedimentation, erosion harming the proposed development including on adjacent Aits, ecology and navigation of the hydrology and ecology of the river river. found no significant adverse impacts. 400+ pilings for barge grid system will See above comment. have adverse effects on river environment, damaging biodiversity and surrounding area. Encourages sedimentation in and The new river structures would around grid system and will need potentially result in minor accumulation further dredging. of sediment, though it is noted existing permanent moorings have also resulted in sedimentation compared to the previous use. A condition requiring details of monitoring of river bed levels and a programme of management to control sedimentation has been recommended in line with comments from the Port of London Authority. Barge grid layout requires potential The low tide support system for boats concrete apron. consists only of timber barge grid system. Criteria for vessels. Minimum specifications for moored vessels would need to be agreed as part of an Operational Management Plan (to be secured by condition). This would ensure any boat moored is capable of navigation, is of an appropriate size for the moorings and in good condition. Variations in houseboat design require Moored boats would need to be different connections for utilities. compatible with proposed services and an Operation Management Plan, with minimum standards to be met. Safety of moorings – dangerous The impacts on navigational safety have impacts on river flow. been considered by the Port of London Authority, with it having no objections. Infrastructure layout for services is Services for the moorings are inefficient. centralised in the new building. Each mooring has its own service point. Disabled access inadequate. Moorings would be accessible for people with disabilities. Access has only one entrance to This layout minimises disruption to the moorings so this layout requires some other users of the park by having a mooring users to travel 400m. single entrance. Boats shown are long and The layout of the moorings provides perpendicular to bank so will not see spacing between boats allowing views much of river impacting on views from of the river from the park and nearby flats. neighbouring development. Alternative design from existing boaters The alternative design suggested by the that has fewer effects is better for objector appears to potentially involve environment and not as costly. the erection of fewer piles and supports in the river though it has 3 points of access from the park and no storage facilities. Full details of plant and connections for services such as for sewage, water and energy are not shown and no costs are given. In any event the assessment of the application proposal has shown no significant adverse environmental effects are likely, with these being acceptable subject conditions to minimise impacts. As such the development is not likely to have significantly greater environmental effects than alternative designs. Additionally, various alternatives were explored during pre-application design and consultation with Environment Agency and Port of London Authority and the current layout was considered acceptable. Does not work with Kew Gardens or No significant adverse effects on the Richmond Council with environment of environment of the Aits or river are likely Ait islands being harmed. to result from the development. Construction will harm MOL and The development would enhance the environment of Thames. character of the MOL through removal of unsightly vessels and debris and provision of open areas between moored boats. In addition there would not be any significant adverse environmental effects. Ecological enhancements are The works proposed to the riverwall insignificant and do not maintain or provide new habitat and greenery to the enhance the river fauna and flora or river, aiding wildlife and enhancing the improve water quality, nor promote appearance of the site. education or appreciation of the environment. Existing riverwall is of inadequate The Environment Agency has condition to accommodate recommended further surveys of the enhancements proposed and so riverwall be undertaken following additional work is required. removal of the existing debris and boats, following which final details of the ecological improvements can be agreed, however these works are acceptable in principle. Rubbish in the river would collect along At present some rubbish accumulates new infrastructure. Management of amongst existing moorings and so this flotsam and jetsam. is likely to continue when the proposed development is operational. A condition requiring an Operational Management Plan which would include measures to control rubbish collection is therefore recommended. Construction impacts Disruption of High Street and adjacent Some temporary disruption to local roads which are heavily congested roads and footpaths is inevitable given including A315 which is already the nature of the site and the proposal. constrained and a primary road through Conditions including a restriction on the the borough to Heathrow Airport, during hours of work and a requirement to construction. New wastewater network submit and adhere to a Construction will require road closure putting strain Management Plan (CMP) are on transport links to Heathrow Airport. recommended to minimise impacts. The CMP would include measures relating to community liaison, deliveries, phasing, storage of materials, environmental protection, safety, access and egress, and any diversions. Disruption of usage of park during See above. construction, will be a building site Disruption of footpath along High See above. Street. Access and parking Adverse effect on disabled, cycles and See paragraphs 7.67-7.69. pushchair access to park. New vehicle access and car parking in The development would not generate area with very heavy traffic congestion. significant amounts of traffic. Car park is not required for boat users. Car parking is not essential, however this would make the development more attractive to a wider group of people, including the disabled, and this would also aid the commercial viability of the development noting nearby moorings offer car parking. Car park restricts current and future The car park would not prejudice any development of Park as the green link future link across the river between Kew between Kew and Syon Park. and Syon Park. Safety issue as the car park located on A condition requiring inclusion if stretch of road with bus stop and fuel sufficient visibility splays to either side of station where there are numerous the proposed access has been accidents. recommended. Future residential development on top No such development is proposed. A of car park. further planning permission would be required for such a proposal. Sustainability Not sustainable development. The new building would meet relevant The development produces vast energy efficiency and carbon emissions amounts of unsustainable engineering reduction standards from the London and construction, reduces green space, Plan. with no CO2 reductions. Development has not demonstrated See above comment. energy assessment instead provides over-engineered design. No use or low carbon or alternative energy, not high standards of sustainable design and construction. Does not attain BREEAM certification The proposed car park building has a as required as over 500sqm. floor area of less than 500sqm and is exempt from BREAM requirements. Does not promote prevention, re-use, The moorings would be provided with recycling and recovery of waste. refuse and recycling facilities. Contamination No measures to prevent contamination The Council’s Land Quality team and of river doing construction – disturbance the Environment Agency has considered of hazardous toxins and polluted river the proposal and supporting information, bed and park subsoil given former use and have no objections in this regard of site, harming wildlife. Current subject to safeguarding conditions that investigations are too shallow given would include physical and operations depth of construction activity proposed. controls during construction. No consultation with Health and Safety The application does not propose Executive (HSE) despite hazardous development requiring consultation with substances. the HSE. Other matters Inadequate consultation and Publicity for the proposal has been information about the project and its widespread and there have been a impacts and lack of community number of opportunities for community involvement in design. engagement and input. Consultation has been in accordance with the statutory requirements and the Council’s procedures, with there also being a number of public exhibitions. The development disregards These aspirations relate to a different aspirations of London Plan to link Kew stretch of the river where a possible across river to Syon Park. ferry or footbridge over the Thames between Kew and Brentford/ Syon Park has been suggested. The Thames Landscape Strategy promotes the re- introduction of the Brentford Ferry to link Syon House with Kew Gardens whilst the Kew Gardens Landscape Strategy suggests reinstating foot ferry or even building a pedestrian bridge between Brentford Dock and Ferry Lane. Description does not detail the full The proposed description adequately extent of the proposed works which describes the proposal, with more require extensive engineering, detailed information provided by the dredging, piling, and demolition, accompanying drawings and supporting provision of new infrastructure, statements. landscaping and closure of park during construction. Will produce noise pollution from vents A condition has been recommended to plant rooms. requiring that noise from any plant or associated equipment be no higher than 10dBA below the background noise level at the nearest sensitive receptor. Watermans Art Centre is to be Any redevelopment of the Arts Centre redeveloped affecting proposed would need to take account of existing moorings. and planned development on surrounding sites. The proposed moorings would not prejudice redevelopment of the Arts Centre site. Do not need another café. The development does not currently propose a café. The landscape layout makes provision for a possible café space at the western end of the park. This could potentially be a temporary ‘pop-up’ style facility, a more permanent structure or a space ancillary to a future café on the Watermans Art Centre site. Fails to conform to planning policies of The proposal is consistent with the Development Plan and National policies of the Development Plan and Planning Policy Framework. NPPF. Loss of local area of natural wildlife with Overall the scheme enhances the herons. environment through new tree and shrub planting, riverbank planting and removal of derelict vessels and rubbish from the riverbed. Loss of diversity in community. The current moorings do not have the Residents have lived next to park for owner’s consent to permanently moor at over 20 years. the site and lack proper facilities. Existing boat owners and residents would be able to apply for moorings on a commercial basis subject to boats meeting minimum standards. Evicts current community creating The existing occupants do not have further 40 low income and single parent consent to use the public park for families adding to housing demand. moorings. The Council has given adequate notice of the intent to remove unauthorised moorings and has given advice on alternative housing options. No affordable housing proposed. See paragraph 7.10 below. Removes low income properties replacing with high market value. Loss of views of river from adjacent The proposed tree planting adds housing due to new tree planting. greenery to the park and also replaces some trees to be removed. Details of species are to be submitted for approval with these to be suitable for the riverside character of the site and are likely to be small to medium sized when mature. The park is mostly lower than the level of nearby housing. As such there would not be a harmful impact on any views. Fails to meet goals of Hounslow See above comments. Together – Hounslow’s Local Strategic Partnership as results in loss of community diversity, does not enhance green space and results in loss of park will severely pollute environment and is not sustainable development.
5.6 Conclusions and recommendations from statutory bodies, and comments from local amenity societies are summarised below.
5.7 Port of London Authority: No objection subject to conditions.
Navigational Risk Assessment – Actions to reduce risk will need to be implemented and maintained at all times. Hydrodynamics – The hydrodynamic assessment covers the extreme cases of both dredging and height of barge grid, the later having greater impact on flows. The proposed scheme is essentially a 50:50 compromise between dredging and barge grid. This is still likely to induce some sedimentation particularly during periods of high land water flow within the development and could affect adjacent moorings. The applicant is proposing to monitor the bed levels within the development as a means of mitigation. It is agreed monitoring and mitigation would be an appropriate approach in this instance. The PLA will be securing this as part of the River Works Licence process. Ecology – The design has followed the recommendations in the EA document Estuary Edges. Recommend a condition on any grant of planning permission requiring the submission and approval of the detailed design for the ecological improvements/mitigations. This should include amongst other things the design life, the monitoring and maintenance measures, the specifications for the fill materials, timber materials and the planting. Size – A condition should limit the size of the vessels to those shown on the drawings: 30 metre houseboats at berths 1-14 and 25 metre houseboats at berths 15-26 in order to prevent their replacement at a later date with larger vessels which would extend further out into the river.
5.8 Environment Agency: No objection subject to conditions.
River wall survey – condition that the river wall survey can commence after the enabling works but prior to construction works. Water Framework Directive Assessment of the potential chemical water quality risks associated with the enabling works should be submitted before enabling work commences. WFD Assessment covering the risks/mitigation associated with the dredging/regarding activity to be submitted following the enabling works but prior to construction works.
5.9 Historic England: No objection.
5.10 Brentford Community Council: Welcomes efforts by the Council to improve the mooring arrangements and facilities at Waterman’s Park, however does not support the current proposal due to adverse physical and social impacts in the following areas:
Vehicle increase – Currently boaters have no cars and to provide parking at the expense of the public realm (green open space) is contrary to local policy and diminishes the rare amenity area in an otherwise densely built vicinity, which would also contribute to high mooring costs contrary to objectives to promote affordable housing.
Decreased amenity – Filling of park raises levels closer to the adjacent main road, transforming it from a sheltered area to an area exposed to noise and visual blight, diminishing the peacefulness of a comparatively tranquil public space. Access will be restricted to a central entrance along the very narrow footpath alongside the main road, whereas at present those coming from the west can cut through from Watermans. Many residents from Brentford come from that direction and would therefore have to walk along the road further to gain access to the park. The stepped levels to the landscape would affect children and the elderly compared to existing gentle slopes The children’s play area looks to small and its equipment and fencing is unclear It is unclear whether (or with what materials) the proposed play area would be fenced. All flower beds will be lost. There are inadequate details of proposed planting. Strongly object to the diminution of the public amenity space in both area and character; it is presently valued as a safe playground for children as well as an area for adult enjoyment.
Cafe & stage - While a café would be welcome it is in direct competition with Watermans and would struggle to be financially viable, even if/when Watermans goes. A stage is proposed but with no details of how it is constructed or how it is to be used. It also looks to be too small for any real use.
Forced Dispossession - A very considerable proportion of the huge budget is allocated to the cost of enforcing removal and/or relocation of existing boats and their owners from the site. This approach is contrary both to common humanity and to government policy. To actively encouraged more moorings for houseboats on waterways. It should be clearly recognised that the boating community is comprised of an extraordinary and eclectic mix of diverse members of the community, from self-employed artisans to highly skilled and paid professionals. As such it is an exemplar of non-divided society which should be promoted by the Council. This scheme effectively ‘sanitises’ the area, restricting use of the moorings to those in a position to afford the artificially inflated costs of them. All communities need housing provisions catering to all income levels if they are to be vibrant, interesting and sustainable. Moorings provisions allow for an option that not only appeals to all income levels, but is affordable to all income levels. The Council has a duty of care in this respect that over-rides any perceived imperative to maximise the potential income from every one of their assets.
Practicalities - The infrastructure essential to make the ‘chevron’ design viable involves huge amounts of piling and heavy-duty engineering. No other such lay- out is evident anywhere nearby on the Thames. We strongly suggest that alternative schemes are considered, that can be brought in at minimal cost and disruption, minimal or no impact on public amenity space, and enabling all those boaters who desire it, the opportunity to avail themselves of affordable berths. The population of boaters at Watermans Park have been developing such a scheme, and we support this community effort, which should be recognised as positive indication of willingness to work with, rather than against, the Council.
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 from April 2014 National Planning Practice Guidance (NPPG) in the form of an online guidance resource to support the NPPF came into effect. The Local Planning Authority (LPA) considers that, where pertinent, the NPPF and NPPG are material considerations and as such, 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 London Plan
3.3 Increasing housing supply
3.16 Protection and enhancement of social infrastructure
5.3 Sustainable design and construction
5.12 Flood risk management
5.13 Sustainable drainage
5.14 Water quality and wastewater infrastructure
5.21 Contaminated land
6.9 Cycling
6.10 Walking
6.13 Parking 7.2 An inclusive environment
7.3 Designing out crime
7.4 Local character
7.5 Public realm
7.6 Architecture
7.8 Heritage assets and archaeology
7.10 World Heritage sites
7.13 Safety, security and resilience to emergency
7.14 Improving air quality
7.15 Reducing and managing noise, improving and enhancing the acoustic environment and promoting appropriate soundscapes
7.17 Metropolitan Open Land
7.19 Biodiversity and access to nature
7.21 Trees and woodlands
7.27 Blue Ribbon Network: Supporting infrastructure and recreational use
7.28 Restoration of the Blue Ribbon Network
7.29 The River Thames
8.2 Planning obligations
6.6 Hounslow Local Plan
SC1 Housing growth
CC1 Context and character
CC2 Urban design and architecture
CC4 Heritage
GB1 Green Belt and Metropolitan Open Land
GB2 Open space
GB4 The green infrastructure network
GB5 Blue Ribbon Network
GB6 Residential moorings
GB7 Biodiversity
GB9 Play space, outdoor sport facilities and burial space
EQ1 Energy and carbon reduction
EQ2 Sustainable design and construction
EQ3 Flood risk and surface water management
EQ4 Air quality
EQ5 Noise
EQ6 Lighting
EQ7 Sustainable waste management
EQ8 Contamination
EC2 Development a sustainable local transport network
IMP1 Sustainable development
6.7 Thames Landscape Strategy 2012 Review: Hampton to Kew
6.8 The Thames Landscape Strategy provides policies, projects and management proposals that seek to protect and enhance the distinct character if the different waterfront areas along the Thames. The most recent update to the strategy was in 2012. The document advises that new developments should be inspired by their context, complement the particular style, colours and materials of each waterfront and contribute to the required infrastructure and the public enjoyment of the river edge spaces and that the established diversity of riverfront uses should be retained as part of a varied and vital community.
6.9 Other objectives are to restore or re-design small, municipal waterside parks to make the most of the river and enhance nature conservation interest. Encourage the involvement of local interest groups to create spaces they can use and enjoy. To control mooring location and density and encourage off channel marinas, and to make improvements for sitting, walking, running, and cycling along the riverside.
Conservation areas and determining applications for Planning Permission
6.10 In considering whether to grant consent with respect to any buildings or other land in a conservation area, the authority shall pay special attention to desirability of preserving or enhancing the character or appearance of the conservation area. Listed buildings and determining applications for Planning Permission
6.11 In considering whether to grant consent for development which affects a listed building or its setting, the authority shall have special regard to the desirability of preserving the building or its setting or any features of special architectural or historic interest which it possesses.
7.0 PLANNING ISSUES
7.1 The main planning issues to consider are:
1. The principle of the proposed development
2. Environmental effects
(i) Land contamination (ii) Flooding (iii) River flow (iv) Archaeology (v) Other ecological effects (habitat, water quality, air quality, trees)
3. River activity and navigational impacts
4. Impacts on the character of the area including the river and heritage assets
(i) Moorings (ii) Car parking and landscaping
5. The quality of the residential moorings proposed
6. The impacts on the amenity of the area
(i) Neighbouring properties (ii) Watermans Park
7. Impacts on existing occupants
8. The impact on the local transport network
(i) Access (ii) Parking and servicing (iii) Thames Path
9. Sustainable design
1. The principle of the proposed development
7.2 The development proposes new permanent residential moorings and associated infrastructure, as well as improvements to Watermans Park. The National Planning Policy Framework (NPPF) emphasises three elements to sustainable development: economic, social and environmental, with new development to make a positive contribution to each. Paragraph 9 of the NPPF says pursuing sustainable development involves seeking positive improvements in the quality of the built, natural and historic environment, as well as in people’s quality of life, including (but not limited to): making it easier for jobs to be created in cities, towns and villages; moving from a net loss of bio-diversity to achieving net gains for nature; replacing poor design with better design; improving the conditions in which people live, work, travel and take leisure; and widening the choice of high quality homes.
7.3 London Plan policy 7.27 (Blue Ribbon Network: Supporting infrastructure and recreational use) says new infrastructure to support water dependent uses will be sought and that development proposals should enhance the use of the ‘Blue Ribbon Network’ (London’s waterways). Its supporting text says that although permanently moored vessels, including residential barges, can add to the diversity and vibrancy of waterways, their siting needs careful consideration so that the navigation, hydrology and biodiversity of the waterways are not compromised. It also says that consents for new moorings should respect the character of the waterway and needs of its users, and such waterways should not be used as an extension of developable land in London nor should parts of it be a continuous line of moored craft.
7.4 Policy GB6 (Residential Moorings) of the Local Plan states that proposals for new permanent residential moorings will be considered where they are compatible with waterways and their surrounding environment. This policy says that such moorings can play a role in contributing to the borough’s supply of housing, and in doing so contribute to communities and the unique water-oriented character of parts of the borough. However, the position and concentration of residential moorings require due consideration, so that conflicts with other water-related uses (such as economic activity, transport and recreation) are avoided. There are also environmental considerations that proposals should consider, such as a mooring’s compatibility with the waterbody in terms of flood risk, marine and riparian biodiversity, and water quality. Further, residential moorings should be provided with adequate services and facilities, such as electricity and other utilities, and provision for waste management.
7.5 The associated car park and storage/ utilities structure that is proposed provides infrastructure for the moorings. Unlike the remainder of Watermans Park, the area of the site of the proposed car park is not designated as Local Open Space in the Local Plan. The foreshore/ areas of the river exposed at low tide are designated as Metropolitan Open Land (MOL). London Plan policy 7.17 (MOL) and Local Plan policy GB1 (Green Belt and MOL) seek to protect the MOL from inappropriate development, with policy GB1 giving regard to conserving and enhancing its nature conservation, landscape, recreation and amenity value whilst increasing public access to it. It is also important to maintain its openness, setting and visual amenity and to give particular attention to the location, setting, design, materials, height and landscaping proposed.
7.6 The existing boats moored at the site, including occupied houseboats, are utilising the site without the necessary consents and in the case of residential moorings, without proper access or services, including rubbish and sewage collection. There are also derelict vessels and rubbish along the river bed and various structures have been added to the safety fencing along the river, colonising this public space. Existing boats would need to move to authorised moorings or elsewhere on the waterway to accommodate the scheme. Those existing boats that would meet the criteria for permanent mooring would be able to apply to moor at the site on a commercial basis. Similar commercial enterprises operate nearby including at the adjoining Victoria Steps Quay where there are permanent residential moorings for six boats, with a car parking and refuse store area on the adjacent land.
7.7 As a secondary channel along the river away from the main river traffic, the site is in principle a good location for new moorings, and space for boats to be moored is supported as this would add to the vibrancy and activity of the river. This would be consistent with Brentford’s waterside character. The condition and appearance of the existing boats moored at the site varies, but overall the character of the site is presently blighted by a number of wrecks and by other boats in poor condition. Along with the unauthorised additions to riverside railings, and the lack of proper services for rubbish and sewage, the existing collection of moored boats detracts from the character of the park. The lack of proper services and access is disruptive to the use of the park and is likely to be harmful to the environment with noise and fumes from generators, as well as the potential for water contamination from derelict vessels and untreated sewage and grey water discharge. The continuous line of boats alongside Watermans Park and their proximity to the river wall also creates a dense mooring arrangement that diminishes the ability of people to appreciate the openness of the river. People standing at the edge of the riverside walkway are in some places immediately adjacent to moored boats which block views and also have windows and deck spaces directly overlooked by the public.
7.8 Watermans Park itself is an attractive riverside space that provides a pleasant relief from the adjacent urban areas and gives views of the river and space for recreation. The park is an important open space in the area. There are however opportunities to improve its appearance and infrastructure and maximise its use, noting some areas of sparse planting and infrastructure are in poor condition such as pathways and walls. It is noted that the Thames Land Landscape Strategy (2012 Review) identifies that in respect of spaces along the river “…considerable scope remains for the enhancement of small riverside gardens to:
• meet current demands; • relate to the water; • create greater nature conservation interest; • provide adequate seating; • provide adequate safety and disabled access; • control litter and dog faeces; • offer occasional performance spaces; • help manage flood risk by making space for water where appropriate, • have a fresh and inviting character; and • be maintainable within current budgets”.
7.9 Watermans Park is specifically identified as a riverside open space with scope for improvement.
7.10 The NPPF and the Council’s Development Plan emphasise the importance of providing affordable housing and this is a priority for the local authority, with schemes providing 10 dwellings or more to provide a proportion of affordable housing where viable. However this development is for moorings only and does not provide permanent dwellings or approval of any boats themselves. The type and amount of residential accommodation provided by boats that may moor at the site is not fixed as boats would be independently owned and moored with leases, with the boats being capable of coming and going from their moorings. As such, it is not practical to secure the proposed moorings as affordable rented accommodation or sold as affordable housing. Nevertheless houseboats are considered a more affordable alternative type of accommodation as boats would be likely to cost less than housing in the area and so by their very nature it is considered the development aids housing choice and affordable housing in the area. The cost of mooring fees is to be finalised, and would be agreed by the Council separately form the planning process, but given the existence of other commercial moorings in the area, these would need to be competitive to be viable.
7.11 Therefore given the existing condition of the site and its use, there is an opportunity to improve its appearance and provide good quality, fully serviced permanent residential moorings with some separation between boats and the riverside pathway. Redevelopment would remove unsightly craft and wrecks and clear the area of rubbish, and enhance the wider environment of Watermans Park. New permanent residential moorings also provide housing choice, and with appropriate infrastructure would be acceptable in principle, subject to associated impacts being satisfactory.
2. Environmental effects
7.12 The Thames is designated in the Local Plan as a Site of Importance for Nature Conservation. The waterway, the riverbed of mud and shingle, the landscaped areas of Watermans Park, and nearby Brentford Ait, contain areas of habitat and contribute to the green network along the river.
7.13 London Plan policies 7.19 (Biodiversity and access to nature) and 7.28 (Restoration of the Blue Ribbon Network) seek a positive contribution towards biodiversity, with the latter also saying development should restore and enhance the Blue Ribbon Network by increasing habitat value, with schemes that reduce biodiversity or involve new structures in the water space that do not serve a water related purpose being opposed.
7.14 Policy GB6 of the Local Plan requires mooring proposals to give consideration to the physical environment and compatibility with the river in terms of flood risk, marine and riparian biodiversity, and water quality.
7.15 Other Local Plan policies require consideration of wider environmental impacts including surface water management, air quality and noise, lighting, waste and land contamination. The site presently contains landscaped areas, having been redeveloped following decommissioning of the former Gas Works, as well as moored boats and pilings in the river. The key impacts of the proposal on the river and wider environment are discussed below.
(i) Land contamination
7.16 As both the park and adjacent river were once used for industrial purposes, with the site operating as part of the Brentford gasworks, the land, riverbed and groundwater are potentially contaminated. Policy EQ8 (Contamination) of the Local Plan requires investigation of the site to ensure any contamination appropriately mediated and risks are satisfactorily controlled.
7.17 The applicant’s investigation indicates that there is some contamination from industrial sources of both the subsoil of the riverbed and the park. Review of this investigation indicates that the risk to boat users from contamination is low, but there is greater risk from works to the park and river bank (where elevated lead and asbestos levels were identified). The alterations to landscaping including change to pathways and fencing, and the new infrastructure located in the river (dredging, piling and reed planting area) will result in works disturbing the potentially contaminated subsoil. To ensure this risk is appropriately managed a condition has been recommended to require detailed analysis of the risk and a scheme of decontamination if necessary during construction and operational periods.
(ii) Flooding
7.18 Local Plan policies GB6 and EQ3 (Flood risk and surface water management) require development to demonstrate through a Flood Risk Assessment that flood risk is reduced by ensuring that developments incorporate any necessary flood resistance and resilience measures, and also that occupants of moorings would be safe in the event of flooding.
7.19 The site is located mostly within Flood Zone 3a (High Probability) with it at risk of flooding from the river (fluvial flooding) and so it is not suitable for many built structures or dwellings. However moored residential boats are classified as ‘water compatible’ development. Additionally, the design of the proposed moorings are flood resilient and would accommodate flooding with water moving across and through the moorings.
7.20 Existing walls at the site along the river are generally in good condition, with these also acting as flood defences. Further investigations would be undertaken following removal of vessels and debris. These defence walls are to be retained, maintaining existing flood protection. Existing infrastructure along the riverbank will be retained, with the exception of the timber walkway, which is to be replaced with the new reed bed to provide a more natural edge to the river. An existing Thames Water outfall located beneath a section of suspended walkway would remain, with this adequately separated from the new pontoon walkway.
7.21 Given the area of the site and its riverside location, the scheme should incorporate a Sustainable Drainage System (SuDS) to assist in controlling flood impacts. A condition requiring such a system to reduce the rate of water runoff and potentially re-use rainwater has been recommended, in accordance with Local Plan policy EQ3.
7.22 Given the nature of likely flooding from the river, there would be ample warning of any impending serious flood event, as rising river levels and expected flood levels are monitored at numerous points upstream with flood water taking time to flow through various locks and weirs to the site. The Operational Management Plan for the moorings, which would be secured by condition, should include effective procedures for evacuation of moorings in the event of serious flooding events.
(iii) River Flow (hydrological impact)
7.23 The proposed mooring system is to consist of rise and fall pontoon walkways supported on timber piles. Additional structures proposed include a timber barge grid system for each mooring, allowing boats to sit level at low tide noting the existing riverbed has a slope, plus the proposed reed planter adjacent to the river wall.
7.24 The provision of this infrastructure and the mooring of boats have the potential to affect the flow of water in the river past the site in both the main channel of the river as well as the secondary channel alongside the Aits, with possible effects on:
Sedimentation around structures; Erosion in the low water channel between the moorings and adjacent Aits; and Deflection of flow onto the foreshore of the nearby Aits leading to erosion.
7.25 A hydrodynamic assessment of the likely environmental effects of the moorings, including on the movement of water has considered the proposed arrangement of barge grids, as well as an alternative scheme that would involve dredging of the intertidal area to allow boats to rest level at low tide.
7.26 The modelling of likely effects has accounted for worst case dredging and barge grid height, and makes a comparison with a site with no boats, and as such it is likely to overestimate effects given there are existing moored vessels. The modelling also accounts for high river flow conditions and the unusual mooring layout, which has boats positioned at an angle to the riverbank, this ‘chevron’ style layout not being found on other moorings on the tidal Thames.
7.27 The barge grid option involves some minor dredging of the intertidal area next to the wall, but less than the modelled alternative which would level the area under the proposed moorings to match the narrow low tide channel. Importantly the barge grid system would permit boats to sit above the intertidal mud and shingle riverbed at low tide, maintaining this as habitat, though there would be some minor effects from overshadowing from vessels. Presently vessels sit on the surface of the intertidal area at low tide smothering this estuarine habitat.
7.28 Both the Environment Agency and the Port of London Authority have reviewed this information and concluded that the effects of the development on the environment are not significant. There will be some diversion of water flow around each boat and sedimentation but limited impacts on the wider river currents. Sedimentation may occur around parts of the infrastructure and there are small increases and decreases in currents around the moorings. Dredging would require careful analysis of the best methods given the risk of encountering contaminated material and conditions in this regard are recommended. There is also a condition recommended which requires the submission and approval of an Operational Management Plan. This plan would confirm how any ongoing operational impacts from the moorings (sewerage, litter, lighting, sedimentation) are to be managed. The Port of London Authority has also advised that it intends securing a monitoring regime in respect if the river bed levels as part of the River Works Licence process, ensuring this matter is appropriately dealt with.
(iv) Archaeology
7.29 Policy 7.8 (Heritage assets and archaeology) of the London Plan looks to protect, conserve and utilise heritage assets including archaeology. Policy CC4 (Heritage) of the Local Plan has similar objectives.
7.30 The site is covered by two Archaeological Priority Areas as designated in the Local Plan. It is close to the site of the main Roman Road from London to the southwest and also within the historic settled area of Brentford, with finds in the area from the pre- historic, Roman, and medieval and post-medieval periods, the latter including the industrial history of the site as the Brentford gasworks.
7.31 Given this designation there is potential for archaeological interest at the site, and in accordance with the NPPF and development plan policies, the applicant has carried out assessment of the potential archaeology.
7.32 The assessment confirms there is some potential for archaeological items, though it has been the subject of redevelopment and landfill. The assessment has been considered by Historic England who recommends a condition requiring a written scheme of investigation (WSI) be submitted to further investigate the site, including directing a programme and methodology of site investigation and recording, and mitigation of impacts if necessary.
(v) Other environmental effects (habitat, water quality, air quality, trees) 7.33 Watermans Park and the Thames River make a positive contribution to the local environment which is otherwise urban. The Park is designated as Local Open Space with the adjacent mud and shingle riverbed being designated as MOL. The Thames River including its mudflats, shingle beaches, inter-tidal vegetation, islands and the river banks are recognised as being a Site of Metropolitan Importance for Wildlife.
7.34 Local Plan policy GB4 (The green infrastructure network) says the Council will protect and enhance the green infrastructure networks throughout the borough. 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.
7.35 Policy GB7 (Biodiversity) of the Local Plan says the Council will protect and enhance the natural environment and seek to increase the quantity and quality of the borough’s biodiversity. London Plan policy 7.21 (Trees and Woodland) seeks retention of existing trees of value and additional planting where appropriate. Other policies of the Local Plan and London Plan encourage development proposals to protect and enhance of the natural environment.
7.36 The applicant has undertaken detailed habitat and arboricultural surveys covering the river and park. There are sites with important nature conservation value nearby. Kew Gardens is located across the river and is a World Heritage Site (WHS) with natural woodlands and a nature reserve. Brentford Ait opposite the site, is an uninhabited island and bird sanctuary, supporting important bird and invertebrate species. This island is designated as a Site of Nature Conservation Interest.
7.37 The proposed scheme is an opportunity to improve the natural environment through creation of new habitats from landscaping, tree planting and the retention of existing trees, use of artificial nesting structures for bats or birds, a new reed planting area and improvement of the mudflat habitat.
7.38 The proposals will not have any significant or long term impact on habitats within the park, with most mature trees being retained as part of the scheme. There are likely to be temporary disturbance to the grassland areas and some shrubs. However, these are of limited ecological value and do not have the potential to support protected species, whilst the new landscaping would look to provide a greater diversity of species and increased planting areas. Reconfiguration and improvement of the landscaping throughout the park will result in removal of some existing trees. Trees along the boundary with Victoria Steps are retained though some will require pruning. None of the trees to be removed are rare species or of the highest quality, though they do have amenity value. Removal of some trees as proposed is acceptable as new landscaping would include replacement and additional tree planting, which would retain and enhance the contribution of trees on the site to the amenity of the area and the network of green spaces along the river.
7.39 It is likely that bats use the site for opportunistic foraging and for moving across the local landscape including areas of Brentford Ait, Syon Park and Kew Gardens, all of which provide habitat for bats. As noted the park itself does not support diverse habitats and the species poor grassed area is less likely to support a diverse range of invertebrates which bats would feed off. However, the mature trees are likely to support invertebrates and cover, providing some habitat for bats. The park is open and is likely to have high ambient light levels, due to the surrounding development. It is considered that the proposals will not affect the site in terms of the ability for bats to move across the landscape nor foraging in and around the trees as replacement and additional trees are proposed and the site has existing moorings along its full length. The scheme also proposes installation of bat boxes at the site. Therefore impacts on bats would not be significant. Various conditions are recommended to confirm details of hard and soft landscaping, including new tree planting, as well as protective measures for retained trees.
7.40 Clearly the site is already used for mooring of boats with this affecting the river environment. In respect of the river, the ecological survey did not find any protected species, but identified the area as species poor and polluted. The new reed bed planting area along the riverwall would enhance the ecology of the river, whilst the installation of timber piles and grids provides habitat and ensures boats rest above the riverbed at low tide, reducing compaction of the mudflat areas. New piling work and dredging will result in some disturbance of areas of the riverbed though dredging is limited to areas of sedimentation accrual near the existing river wall. However such impacts are considered against the overall benefits to the river’s ecology resulting from the removal of derelict boats, rubbish and provision of fully serviced moorings (including power, water and sewerage), mandatory on-board sanitary facilities including sewage holding tanks or treatment systems, which would improve the appearance of the site and have a positive effect on water quality through reducing potential sources of pollution. Connection to mains power supply also eliminates or reduces the need for electricity generators, gas cylinders and diesel engines, as well as wood-burning stoves. Such sources of power and cooking can be noisy, smoky and creates fumes, creating air and noise pollution, and potentially water pollution given the lack of management of the existing mooring arrangements and deliveries to the site.
7.41 A key ecological enhancement is the proposed reed bed area which would replace the existing timber walkway along part of the river frontage, with a pathway retained along the riverbank. The removal of this structure will expose the area to sunlight and a new timber post and panel support system would allow a new reed bed to be made, creating new habitat and improving the appearance of the riverwall. This is consistent with London Plan policies 7.28 (Restoration of the Blue Ribbon Network) and 7.19 (Biodiversity and access to nature) which encourages enhancement of the river’s biodiversity, the latter looking to increase natural habitat primarily through small interventions along river walls. Although environmental impacts are minor and not significant, conditions have been recommended which require further details of the ecological enhancements including the reed bed construction and methodology for dredging, demolition and construction work along and in the river to ensure potential environmental effects are minimised and managed appropriately.
3. River activity and navigation impacts
7.42 As noted above London Plan policy 7.27 encourages new infrastructure to support water dependent uses but their siting needs careful consideration so that the navigation and needs of its users are not compromised.
7.43 Policy GB5 (Blue Ribbon Network) of the Local Plan says proposals within waterbodies will be assessed for the impacts on navigation, in line with the London Plan and guidance from the licensing stakeholder, which in this case is the Port of London Authority (PLA).
7.44 The proposed moorings are located on a secondary channel, which is not navigable at low tide and so it will not affect main river navigation. Other users of the river such as rowers are generally confined to the main channel though kayakers, paddlers and small boats use more of the river, and at high tide the channel may be used by boats. Impacts on neighbouring sites including moorings near Lots Ait and at Victoria Steps have also been considered. 7.45 The mooring design has satisfactorily accounted for other river users, as it would not block navigation or significantly affect river flows, and it maintains access to adjacent berths at Victoria Steps and Lots Ait. The PLA has considered the proposed development in respect of navigational hazards, impacts on the development itself, and impacts on other river users. The PLA does not object to the development subject to conditions covering both construction and operational aspects of the development regarding:
External lighting; Life saving equipment; An Operational Environmental Management Plan (setting out how any ongoing environmental impacts of the moorings can be minimised (sewage, refuse storage, vessel maintenance lighting etc)); Construction Method Statement (including for piling and timber grid works, demolition of timber walkway); and Size limits (30 metre houseboats at berths 1-14 and 25 metre houseboats at berths 15-26).
7.46 Conditions in line with the PLA’s comments are included in the recommendation, and with these the development would not adversely affect river activity or the safety of navigation for other users or those within the development.
4. Impacts on the character of the area including the river and heritage assets
7.47 The NPPF states good quality design is an integral part of sustainable development and that decision takers should always seek high quality design. The NPPF also says permission should be refused for development of poor design that fails to take the opportunities available for improving the character and quality of an area and the way it functions. It is proper to seek to promote or reinforce local distinctiveness. However planning permission should not be refused for buildings and infrastructure that promote high levels of sustainability because of concern about incompatibility with an existing townscape, if mitigated by good design (unless the concern relates to a designated heritage asset and the impact would cause material harm to the asset or its setting which is not outweighed by the proposal’s economic, social and environmental benefits).
7.48 The London Plan has policies in respect of design and heritage. Policy 7.4 (Local character) requires high quality design that has regards to surrounds and makes a positive contribution to the character of the area, whilst policy 7.5 (Public realm) seeks legible, high quality landscaping, lighting and signage, opportunities for greening and tree planting. Development should reinforce the connection between public spaces and existing local features like the Blue Ribbon Network (river). Policy 7.8 (Heritage assets and archaeology) says development should identify, value, conserve, restore, re-use and incorporate heritage assets where appropriate, and be sympathetic to heritage assets and their setting. The site is located within the Kew Gardens World Heritage Site (WHS) Buffer Zone, which adjoins the riverbank. Policy 7.10 of the London Plans says development should not cause harm to WHS or its setting. In particular it should not compromise a viewer’s ability to appreciate its Outstanding Universal Value, integrity, authenticity or significance.
7.49 Policy CC1 (Context and character) says development should respond to the wider context and history of the area, its communities, its natural landscape and its urban structure, form and function and look to conserve and enhance features or qualities that add to the character of the area. Policy CC2 (Urban design and architecture) of the Local Plan promotes high quality design and seeks safe, legible and durable public realm and routes. Policy CC4 (Heritage) looks to 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. Policy GB6 (Residential moorings) requires proposed moorings to have regard to the context and character of the waterway and wider landscape. There is one Listed Building (Grade II) nearby, the St George’s church on the opposite side of Brentford High Street from the park.
7.50 The site is also in the Thames Policy Area, which is recognised by the London Plan and Local Plan, with this designation seeking to ensure that development has a positive influence on the river and its waterside environment. Planning decisions in the Thames Policy Area require specific attention to the impact on the character and conservation of the Thames landscape, with London Plan policy 7.29 (The River Thames) saying development within the policy area should be consistent with the published Thames Strategy for that stretch of the river. The site is in the Hampton to Kew policy area. The original strategy was revised in 2012, with this to be the subject of further consultation. In respect of the Brentford-Kew character area, which the site falls within, there is a long distance view of St George’s Church on Brentford High Street from the river and towpath to the southwest past Brentford Dock (approximately 900m away). This vista between Lots Ait and Brentford Ait would not be affected by the proposal as it is only the upper parts of the Church that are readily visible, its lower sections largely obscured by vegetation on each Ait. The development comprising moorings and boats would result in minimal change to this view, whilst the car park is located further downstream and would not be seen at all in the vista.
(i) Moorings
7.51 As noted above at paragraphs 7.8-7.9 there is considerable scope to enhance the appearance and function of Watermans Park and the adjacent stretch of river, the latter dominated by the continuous line of boats alongside the park with this including some derelict vessels, debris and unauthorised additions to the river fencing, as well as lack of satisfactory services and access.
7.52 The revised Thames Strategy says the Brentford waterfront is now a mixture of regeneration and former industrial areas. It notes that “… most of the moored vessels on the Waterman’s Park frontage are unlicensed, many are in poor condition and some are wrecks. There are conflicts between occupiers of the unlicensed boats and the adjoining licensed occupiers.” In its guidance (at 12.9P) it says that the Council and the PLA “…should work together to regularise the unauthorised moorings by providing fully serviced moorings and removing abandoned vessels at the former wharf at Waterman’s Park”.
7.53 The provision of permanent moorings at the site is appropriate given this is an urban stretch of the river and there are similar moorings nearby. Boats moored along the river and activity associated with this use is part of the riverside character of the area and is an expected feature of an active waterway. As noted in the London Plan, care should be taken to avoid an overly dense provision or continuous line of boats, which can obstruct views of the river for people on the riverbank.
7.54 The proposed layout will enhance the character of the area as the layout provides separation between moorings and the riverbank and has gaps between the moorings allowing the waterway itself to be appreciated. The proposal complements the openness and action of the river, with boats to rise and fall with tide. In addition there are controls recommended by conditions on the maximum size, including length and height (air draft), as well as condition of boats, to ensure they are suited to the site and not dominant through excessive size or height, nor harmful to the appearance of the area due to poor condition. Importantly, all boats would have proper access and servicing, ensuring the problems associated with the poor appearance and environmental impacts associated with the operation of the existing moorings are addressed.
7.55 London Plan 7.3 (Designing out crime) requires development to reduce opportunities for criminal behaviour and contribute to a sense of community. The proposal achieves this by providing secure access, good separation from river bank, and an Operational Management Plan for the moorings, in contrast to the uncoordinated moorings that have no management plan and boats adjacent to the riverbank with unauthorised security gates attached to the public pathway.
7.56 There are non-designated heritage assets in the river with some infrastructure associated with the previous industrial use (gasworks and coal wharf). These remnants and are of minor significance, though they are a reminder of the industrial heritage of Brentford. Some of the existing timber posts in the river to be removed are capped with cast iron plates inscribed 'GLCC BD 1930' (Gas Light & Coke Co.).
7.57 Loss of these assets has been considered against the overall wider benefits to the character of the area from the proposals, and is acceptable with their loss significantly outweighed by the improvement to the environment from the more attractive appearance of the site and the ecological enhancements and benefits of appropriately managed and serviced moorings. Additionally, a condition has been recommended to require the careful removal of these plates and an investigation for their re-use or storage if possible. For example this could be within the site or on new mooring posts or a landscape feature, conservation in a local museum, or if this is not practical, their recording for posterity.
(ii) Car parking and landscaping
7.58 Local Plan policy GB2 (Open space) seeks to protect and enhance local open space, with new development to avoid intrusion into an open aspect. Development ancillary to the open space use must preserve its predominantly open character.
7.59 Local Plan policies GB4 (The green infrastructure network) and GB7 (Biodiversity) requires proposals to make a positive contribution to the green infrastructure network by improving its quality, functions, linkages, accessibility, design and management; and the greening of the borough to promote biodiversity respectively. Policy GB9 (Play space) seeks improvements to play areas and open space.
7.60 The proposed car park building would occupy an area of the site at the eastern end of the park, replacing ramps, stairs, planter beds and paving. The building is not located on land designated Local Open Space. In 2015 the land was also formally appropriated by the Council from recreational use to enable its use for ancillary development related to the proposed moorings.
7.61 The new building would be single storey with fencing and is set amongst a backdrop of more substantial buildings. At street level there would be a parapet/ balustrade around its edges enclosing surface car parking and refuse store areas. Owing to the fall in the land it would be positioned mostly below street level with the exception of the perimeter balustrade. It would have a minor impact on the streetscene, and from Brentford High Street in would be similar to the adjacent surface level car park the serves the adjacent Victoria Steps moorings. As such there would also be no harm to the setting of the nearby listed building (St George’s Church).
7.62 The introduction of a new built element along the river would alter the character of the eastern end of the park, which is presently landscaped, and this would reduce the open aspect of this area and opportunities for planting though not significantly overall given the length of the site, and it would not encroach on Local Open Space. The form of the building is appropriately simple to reflect its function, and its materials (brick with timber) are compatible with the site where other brick walls are found. Owing to the position of the nearby Brentford Ait, which lies between the site and Kew Gardens, there would be minimal impact on views from the Kew side of the river the trees on the Ait block most views, ensuring no harm to the Kew Gardens WHS.
7.63 Although the character of the eastern end of park is altered, and its open nature is diminished in part, this harmful impact is offset by the improvements to the overall situation and environment of the park and waterway, including new tree planting. Consideration would also be given to the quality of its external finishes, with a condition requiring details of materials to be submitted for approval being recommended. Consideration could be given to use of the outer walls for artwork.
7.64 The building provides necessary infrastructure including utilities, servicing and storage for the moorings, as well as some car parking. Additionally, the scheme has minimised the overall loss of greenery on the site through siting of the building at one end of the site in an area that presently mostly paved with some lawn and shrubs. No trees would be removed from the area where the car park is proposed, whilst the large, tall trees on the adjacent site along the eastern boundary are to be retained, ensuring the green edge of the park is retained. New planting along the western side of the car park provide screening from views inside the park.
7.65 Hard and soft landscaping throughout the remainder of the park is to be enhanced with a greater amount and diversity of planting, and more variety as to how spaces can be used. Active and passive use spaces are provided, with new play equipment and a performance area also proposed. In summary the improvements include:
Retaining the existing entry location points into the park and creating a new one approximately halfway along the existing northern boundary; New planted buffer along the northern boundary with the road to reduce noise, dust and vehicle pollution into the park; Creation of four new distinct but linked areas within the park including: an outdoor café space (for a pop-up style operator) and eating area, a space for performances, a seating and viewing area which seeks to maximise the attractive views across the river and a new play area based on natural play principles; Removal of raised beds which are expensive and difficult to maintain and replacing them with new planting and areas of grass; New avenue of trees alongside the existing riverside walk; New path system within the park to create a pedestrian friendly surface; New seating; New tree planting throughout to establish a new planted structure as well as shade and shelter with the park (and replace trees to be removed); New reed bed to replace the timber walkway that is in poor condition; Areas of naturalising bulbs to increase biodiversity and seasonal interest; and Gentle re-profiling of the existing slopes to create earthworks that create more interesting but useable spaces within the park.
7.66 This work is consistent with the Thames Strategy which identifies the park as an area to enhance, possibly with improved planting with input from Kew Gardens (see guidance objective 12.4P).
7.67 The existing stairs and ramped walkway at the eastern end of the site would be replaced by the new utility, storage and car park building. New stairs would be provided adjacent to the car park maintaining a point of entry at the eastern of the park. However cyclists, people with pushchairs and wheelchair users approaching from the east and exiting the park would need to use the existing ramps located adjacent to the traffic light controlled crossing approximately 110m further east than the current ramp. Although the current ramp at the eastern end of the park is not fully compliant with standards for disabled access owing to its grade and lack of proper transition areas (and the Thames Path to the immediate east of the site also has steep stairs), it does provide an accessible route into the park from the far eastern end of the site. Loss of this ramp reduces direct accessibility to the park at this location, and means those people wishing to walk across the length of the site and beyond would use the ramp located before the end of the park or loop back to the ramp, though the river can still be viewed from the High Street footpath, with the scheme enhancing those views.
7.68 Those people with buggies, cycles and wheelchairs wishing to enter the park from the east, would use the existing entrance ramped entrance noted above, resulting in additional distance to journey time of around 1 ½ minutes (using an average speed of 5km/hr), which is not unreasonable. Many local residents arrive from the north at the existing central access which is unchanged by the proposal, using the traffic lights to cross the road, with this entrance providing stairs and a ramp. A new ramp could be provided at the eastern end of the site but this would result in further encroachment into the usable area of the park and given there is an alternative ramp a reasonable distance away this is not considered necessary. Therefore this impact has been considered with regard to the overall benefits of the scheme, including the improved moorings access and improvements throughout the park, though Members must weigh the implications from the loss of the exiting ramp against other public benefits of the scheme.
7.69 New stairs are also proposed between the western entrance and the existing ramp (near traffic lights). This provides a further access which would help improve access to the park to residential areas to the north. Extension of the Thames Path beyond the eastern end of the site is not possible owing to the adjacent development, with this route already blocked, so people will continue to need to use the footpath along the adjacent road to divert around Victoria Steps Quay. Within the park new landscaping includes wide pathways with no steps or significant changes in level thereby ensuring inclusive access to all its facilities and leisure opportunities. The new landscaping provides an opportunity to upgrade the condition of walkways and stairs, and provide cycle parking, with enhanced pathways shared between pedestrians and cyclists, and adequate access for the ambulant disabled and wheelchair users maintained. Therefore good access to the park would remain, consistent with the objectives of London Plan policies 6.9 (Cycling), 6.10 (Walking) and 7.2 (Inclusive access).
7.70 New paths, lighting, seating and play equipment will improve the quality of infrastructure in the park, whilst the new layout of circulation and planting areas creates more diverse spaces that can be used by different groups in the community. The new performance stage offers opportunities for small cultural events, whilst a space suitable for a future ‘pop-up’ café is also provided. Areas suitable for active use such as park football are retained.
7.71 Some trees are to be removed as part of the landscaping proposals. All trees were assessed for their arboricultural, landscape and historical (or cultural) contribution that they make within the landscape setting and have been categorised as A, B or C with A being the highest and C the lowest.
7.72 A group of 6 small Hornbeam trees (all Category C) growing close to the existing riverside path and classed as C are to be removed as they are stunted and in poor condition possibly due to wind exposure from the river and they are poorly suited to the location. A further three trees (T6, G7 and T8) are also to be removed. These trees are all Category B and not of significant amenity value. T6 is Lime Tree, and G7 and T8 are Ash Trees. Limes are known to cause nuisance from honey dew drop and ash trees are under threat from ash dieback disease. The arboricultural survey states that “…although a number of small trees and woody shrubs have been recommended for removal their loss should not be detrimental to the wider landscape or have an adverse impact on local visual amenity”.
7.73 Removal of these trees is acceptable as they are either trees of low quality, or those that have a limited life expectancy due to disease or nuisance. The new landscaping includes extensive new tree planting, including at least 42 new specimen trees and a large area of structure planting along the northern boundary which will offset the limited tree removal proposed. Some minor changes in level are introduced to break up the space and providing seating areas but the park would remain below the level of the adjacent roadway ensuring it remains somewhat sheltered from noise and traffic.
7.74 Within the park there are some remnants of the former industrial use with the existing wall along the roadside including brickwork and some iron-work from that period. These non-designated heritage assets are largely retained as existing by the proposals ensuring there is no undue effect on the heritage of the site.
7.75 Overall the proposed development would have a positive effect on the character of the area through enhancing the green space along the river and removal of unsightly debris and derelict vessels. Conditions are recommended in respect of the materials to be used in the external surfaces of the building and moorings to ensure these are good quality and satisfactory for the use, and for details of the hard and soft landscaping including protection of existing trees to be retained on the site and neighbouring properties.
5. The quality of the residential moorings proposed
7.76 Local Plan policy GB6 requires new residential mooring proposals to provide adequate servicing where appropriate, including provisions for water, electricity, waste and sewage, as well as secure access to the river bank.
7.77 The moorings would be accessible via a secure access point leading to a timber and steel supported pontoon walkway. Each mooring would have full facilities provided by service bollards incorporated into the mooring system (utilities would run in the pontoon substructure). These will provide electricity, telephone, mains water, and a vacuum foul water pump-out system. Facilities would be operated on a pre-pay card system or meters. Conditions requiring submission of full details for approval of the servicing arrangements for the moorings are recommended however the pontoon system and ancillary space in the car park building are considered to make satisfactory provision for the necessary services/ utilities with this form of servicing found at other locations along the river. The details required by condition would include colour, size, height, material, illumination type, and the range of services.
7.78 As the proposal is for permanent residential moorings, space for refuse and personal storage is necessary. Some car parking has also been proposed to maximise the viability of the development by making the moorings as attractive as possible to the widest market, as some boat owners would have cars, especially noting the PTAL that is only moderate.
7.79 Access to the moorings would be controlled by a secure gate, whilst trespassing would be prevented as the pontoon walkways are set off the river wall by an average gap of approximately 2.5m.
7.80 A condition will require the approval of an Operation Management Plan that would cover the use of the moorings, including access and services, emergency egress, as well as the size of boats and their on-board facilities, ensuring that all moorings have good quality facilities and security so that they have good quality accommodation.
6. The impacts on the amenity of the area
7.81 The NPPF requires sustainable development, and as part of this development should aim to minimise adverse effects on the local environment, which includes neighbouring properties. Local Plan policy CC2 says development should respond sensitively to site constraints and avoid harming the environment of neighbours having regards to outlook, privacy and access to daylight and sunlight. Local Plan policy GB6 says the position and concentration of residential moorings require due consideration, so that conflicts with other water-related uses are avoided, and that the moorings and associated development and servicing do not impede other waterside uses, paths or access to the waterway.
(i) Neighbouring properties
7.82 The riverside site has few neighbouring properties as the moorings would adjoin Watermans Park and the Watermans Art Centre. The only adjoining residents are occupants of the existing houseboats at Victoria Steps Quay, immediately downstream from the site.
7.83 As mentioned above the proposed moorings are compatible with the surrounds, where moored boats are part of the character of the river. As all moorings are to be fully serviced, including with water and electricity, and there are storage facilities for refuse and personal items within the car park building, there would be minimal impacts on neighbouring houseboats. This is in contrast to the present situation where there are inadequate utilities, resulting in potential adverse effects from noise and odours from electricity generators, irregular utility connections and lack of sewerage management on all vessels.
7.84 The proposed car park building is sited next to the car park of the adjacent Victoria Steps Quay moorings. There would be no adverse impacts on the living conditions of these neighbouring residents as the car park has screening to ensure privacy along the river side. The proposed access point to the moorings is at least 15m from the nearest existing boat. The OMP would prohibit the use of generators and foul water would be pumped out to the infrastructure. Some boats would be moored next to the existing Watermans Art Centre, which may be redeveloped in the future. The mooring layout ensures future interaction with any redevelopment on the site would be accounted for as moorings here are at least 5m from the river wall.
(ii) Watermans Park
7.85 The proposals would remove the unauthorised additions to the railing fence along the river edge of the park, including high security gates and gangplanks. The new moorings are separated from the river wall and have a single access point. This separation returns a sense of public ownership of the river bank and would allow park users more views of the river and minimises disruption to park users from multiple access ramps. Dedicated storage areas for each mooring would ensure no materials are placed on the public footpath as has occurred on occasion at present.
7.86 Changes to the park create a more diverse landscape that offers opportunities for different uses including walking, sitting, children’s play, active sports and performances, with the new planting enhancing its contribution to the green network along the river.
7. The impact on the local transport network
7.87 Local Plan policy EC2 (Development a sustainable local transport network) seeks to 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. It says cycle and parking provision should have regard to London Plan standards. London Plan policies such as 6.9 (Cycling), 6.10 (Walking), 6.12 (Road Network Capacity) and 6.13 (Parking) also provide guidance for transport assessment.
(i) Access and traffic
7.88 The new car park would be located next to an existing car park at Victoria Steps Quay and would also be accessed from Brentford High Street, to the west of an existing bus stop. Subject to appropriate visibility splays being provided there are no objections to the proposed vehicular access. Traffic generation from the development is likely to be low. The High Street has been proposed for the route of cycle improvements for which the scheme has adequately accounted for.
(ii) Parking and servicing
7.89 London Plan policy 6.13 seeks to limit parking provision and aims to strike an appropriate balance between promoting new development and preventing excessive car parking provision that can undermine cycling, walking and public transport use
7.90 The site has a public transport accessibility level (PTAL) of 3, which is moderate. There are a number of local convenience stores within reasonable walking distance of the site. The proposed development has 14 new car parking spaces, located on the ground level parking area of the new car park building. This is a parking ratio of 0:54:1 (26 moorings). Although car parking is not an essential facility for boaters, some provision of car parking is reasonable given the PTAL for the site is only moderate. A condition requiring a management plan for the car parking to include a proportion of disabled spaces has been recommended. Provision of car parking would be likely to aid the long term viability of the development as it would make the moorings more attractive to a wider number of boaters (i.e. those with cars). Each mooring would also have a storage space for cycles. A space for deliveries (e.g. internet shopping) and drop offs should also be provided, and this would also be included in the car park plan to be secured by condition.
7.91 Refuse and recycling areas are located at the front of the ground floor level of the car park in secure enclosures. Refuse and recycling collection would take place on-site with collection vehicles able to enter and exit the site in forward gear. This would satisfy Local Plan policy EQ7 (Sustainable waste management) that requires development to make suitable arrangements for waste management. Again this is a major improvement on the existing situation where refuse collection is haphazard.
7.92 Access to the lower level storage area and the pontoon entrance is provided via stairs and also a platform lift, the latter enabling heavier items and refuse to be easily moved to the car park level (with this also suitable for a wheelchair).
(iii) Thames Path
7.93 Watermans Park includes a section of the Thames Path, with this pedestrian route being an important link in the green infrastructure network that adjoins the river. As detailed above the proposals would enhance Watermans Park and improve pathways throughout. There would be a minor diversion to accommodate the car park building, however the pathway already detours around adjacent private land at this point and the through route would remain legible with new signage installed.
8. Sustainable design
7.94 The broad aim of sustainable development is to ensure that the quality of social, economic and ecological environments are improved and maintained for future generations. The London Plan and Local Plan encourage sustainable development through many policies including promoting the use of energy efficient building design and materials, re-use of previously developed land and existing buildings, and location of development in or close to town centres and areas with good public transport. Sustainability is also a clear thread running through the NPPF.
7.95 London Plan Policy 5.2 (Minimising carbon dioxide emissions) requires developments
to make the fullest practicable contribution to minimising CO2 emissions following this energy hierarchy:
1. Be Lean: use less energy 2. Be Clean: supply energy efficiently 3. Be Green: use renewable energy
7.96 Policy EQ1 (Energy and carbon reduction) of the Local Plan says all development should meet the carbon dioxide emission reduction requirements of the London Plan, and major developments over 1,000sqm in floor area or with a site area of over 1 hectare (the site area directly involved in some aspect of the development) should seek consider additional energy reduction measures. Local Plan policy EQ2 (Sustainable Design and Construction) says new build non-residential development over 500sqm in floor area should be assessed against BREEAM to assess and certify the sustainable design of the building. Although being a ‘major’ application, as the application site area exceeds 1 hectare, an Energy Statement was not submitted with the application. This is acceptable in this instance as the proposed car park building has a floor area of 261sqm, and it is to be used primarily for storage, with two rooms for plant/ utilities. As such it is not an inhabited space and does not require artificial heating and cooling, and it would be naturally ventilated meaning it would not result in high energy use. Additionally much of the work within the site area is landscaping for which planning permission is not needed. Use of on-site renewable energy production is unlikely to be practical or desirable due to limited space available for infrastructure as the top level is used for parking, and additions such as solar panels or wind turbines would draw undue attention to the structure in conflict with the riverside character of the site.
7.97 To accord with the London Plan the development must demonstrate that it would achieve a minimum 40% reduction in carbon dioxide emissions beyond those required by the 2010 Building Regulations. A condition in this regard has been recommended. Energy use of moored boats is more difficult to regulate given their size and characteristics are presently unknown, though inherently they would be likely to use less energy than other dwellings as they are smaller and have fewer appliances.
7.98 Policy EQ2 also aims to promote the highest standards of sustainable design and construction in development including water efficiency, sustainable drainage (SuDS), green roofs and urban greening.
7.99 The development would be consistent with the objectives of this policy, as additional planting including trees helps offsets the additional building footprint, the new work is to include SuDS, whilst the provision of proper servicing and utilities reduces use of inefficient and air polluting generators, and associated fuel deliveries. Surface water would be discharged to the river as at present, with runoff rates to be limited to greenfield levels, with attenuation provided underground.
7.100 Conditions are recommended requiring further details of the sustainable design and construction of the development with these to encourage the use of recycled materials (e.g. recycled aggregates) and energy saving measures such as motion-censored LED lighting systems and provision of 20% (active and passive) electrical charging points in the car park to encourage use of electric and hybrid vehicles.
8.0 PLANNING OBLIGATIONS
8.1 A payment or other benefit offered in a section 106 agreement is not material to a decision to grant planning permission and cannot be required unless it complies with the provisions of the Community Infrastructure Levy (CIL) Regulations 2010 (regulation 122), which provide that the planning obligation must be:
(a) necessary to make the development acceptable in planning terms; (b) directly related to the development; and (c) fairly and reasonably related in scale and kind to the development.
8.2 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.
8.3 Local Plan policy IMP3 seeks to ensure that development proposals fully mitigate the impacts of the development on the area through a Section 106 agreement, where necessary or appropriate, having regard to supplementary planning document and provide the CIL payments required by any charging scheduled, including the Mayor of London’s CIL. 8.4 In this instance there are no planning obligations recommended, as adequate mitigation and details, including an Operational Management Plan for the moorings, would be secured by conditions.
9.0 EQUALITIES DUTIES IMPLICATIONS
9.1 Existing boats moored without consent would need to move from the site to accommodate the proposed development. Existing occupiers would be able to apply to moor at the redeveloped site whilst other sites in the area offering permanent residential moorings presently have vacancies or boats may use the river for temporary moorings.
9.2 To the extent that this proposal may be considered to interfere with the right to property as protected by the Human Rights Act 1998, such interference is considered to be necessary and proportionate in order to protect the wider public interest.
9.3 The Council has to give due regard to its Equalities Duties and in particular with respect to its duties arising pursuant to the Equality Act 2010, section 149. It is considered that there will be no specific implications with regard 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.
10.0 COMMUNITY INFRASTRUCTURE LEVY
10.1 Some new developments granted planning permission will be liable to pay Community Infrastructure Levy (CIL) to the Mayor of London and Hounslow.
10.2 CIL is payable on m2 of new floor space or where a new dwelling is created or the net floor area increase exceeds 100m2.
Mayors £35 per m2
Hounslow: Housing: Supermarkets, Health care, All other superstores and education and 2 2 uses: £20m East £200m retail emergency warehousing: services 2 Central £110m 2 £155 m facilities: £0 2 West £70m
10.3 This proposal would be liable to pay Community Infrastructure Levy (£9,135 Mayor & £5,220 Hounslow).
11.0 CONCLUSION
11.1 The proposal would provide new permanent moorings where boats can be appropriately managed and maintained, with adequate servicing, and with controls to ensure boats are fit for navigation without undue disrupt[tion of the local open space at Watermans Park.
11.2 The development would not adversely affect safe navigation, biodiversity, or the living conditions of nearby residents, and would help animate the waterway and add positively to the riverside character of the site and Brentford. Accordingly, it concluded that it would have been recommended that planning permission be granted, subject to conditions
12.0 RECOMMENDATION: GRANT planning permission subject to the following conditions:
12.1 Conditions and Reasons
1. 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. 2. Detailed Applications
The proposed development shall be carried out in all respects in accordance with the proposals contained in the application and the plans submitted
521560-A-001 (Site Location Plan)
521560-A-055 Rev. PL3 (Existing Site Plan – Showing Moorings)
521560-A-056 Rev. PL3 (Proposed Site Plan)
521560-A-140 Rev. PL2 (L0 Car Park Plan)
521560-A-146 Rev. P1 (L1 Car Park Plan with Visibility Splays Shown)
521560-A-060 Rev. PL1 (Existing Longitudinal Site Section)
521560-A-221 Rev. PL1 (Proposed Sections A-A and B-B)
521560-A-300 Rev. PL1 (Proposed Elevations, South East, South West, North East)
521560-A-057 Rev. PL2 (Existing Site Plan, Tree Removal Plan)
Flood Risk Assessment by Frankham dated 28 May 2015 and Appendix Report to Flood Risk Assessment by Frankham dated November 2015
589-L-01 Rev. E (Landscape Proposals)
Existing and Proposed Sections and Elevations Sheet 1 Rev. PL1
Existing and Proposed Sections and Elevations Sheet 2 Rev. PL1
Ecological Improvements General Arrangement Rev. PL1 Ecological Improvements Sections and Details Rev. PL1
Proposed Layout of the Foul Drainage Rev. PL1
Section Through Proposed Steps Rev. PL1
Arboricultural Survey (Ref. PJC/3414/14)
Navigational Risk Assessment by Frankham (Ref. 521560-FCG-C-NAVREPORT-FIN- VER1.0)
River Impact Assessment by HR Wallingford (Ref. DDM7742-RT001-R02-00) 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 is used.
Reason: To ensure the development is carried out in accordance with the planning permission. 3. Details of samples/materials
Details of the materials (including paint finishes, colours and materials samples where appropriate) to be used for the external surfaces of the development hereby approved (including details of the service bollards and pontoons) shall be submitted to and approved in writing by the Local Planning Authority in consultation with Network Rail before any part of the development is commenced, and this condition shall apply notwithstanding any indications to these matters which have been given in this application. The development shall be carried out in accordance with the approved details. Reason: In order to safeguard the visual amenity of the area and building in particular and to satisfy the requirements of policies CC1 and CC2 of the adopted Local Plan. 4. Hours of work
No demolition or construction work shall take place during the bird breeding season for Heron (March – mid May) and none shall take place on the site except between the hours of 8am to 6pm on Mondays to Fridays and 8am to 1pm on Saturdays, with the timing of piling works to coincide with either the middle of the day or during low tide. No demolition or construction work shall take place on Sundays and public holidays without the prior written approval of the Local Planning Authority. Reason: In order to safeguard the amenities of the adjoining residents and to mitigate construction disturbance impacts on birds.
5. Refuse and Recycling Storage
Prior to the commencement of development, details of the arrangements for storage and collection of refuse and recycling, shall be submitted to and approved in writing by the Local Planning Authority. The development shall be completed in accordance with the approved details prior to occupation, and shall be maintained permanently thereafter. Reason: To ensure adequate provision is made for storage and management of refuse and recycling.
6. Construction Environment Management Plan
A Construction Environmental Management Plan for the development shall be submitted to and approved in writing by the Local Planning Authority prior to the implementation of development. The plan shall identifies all aspects of construction that could have an environmental impact and provide management controls to eliminate and/or minimise those identified impacts, with impacts to be addressed including but not being limited to traffic, construction dust and noise and any disturbance to vegetation. The plan shall also include details of the arrangements for the temporary use and/or management (as appropriate) of those parts of the sites awaiting redevelopment. The construction of the proposed development shall then be carried out in accordance with the details set out within the approved Construction Environmental Management Plan.
Reason: In the interests of the amenity of park users and adjoining residents and to minimise highway and traffic impact during the course of construction.
7. Environmental Sustainability
The development hereby permitted shall not commence until a finalised Energy Strategy (demonstrating how the targets for carbon dioxide emissions reduction are to be met in line with the Mayor of London’s energy hierarchy), and details of sustainable design measures including use of recycled materials (e.g. recycled aggregates) and energy saving measures such as motion-censored LED lighting systems has been submitted to and approved in writing by the Local planning Authority.
The development shall be implemented in accordance with the approved Energy Strategy and shall not commence above ground until full Design Stage calculations under the National Calculation Method have been submitted to and approved in writing by the Local planning Authority to show that the development will be constructed in accordance with the approved Energy Strategy, and any subsequent approved revisions.
Prior to first occupation of the building evidence (e.g. photographs, installation contracts and As-Built certificates under the National Calculation Method) should be submitted to the Local Planning Authority and approved in writing to show that the development has been constructed in accordance with the approved Energy Strategy, and any subsequent approved revisions.
Reason: To ensure that the development makes the fullest contribution to minimising carbon dioxide emissions in accordance with London Plan Policy 5.2 and the London Borough of Hounslow Local Plan Policy EQ1.
8. Hazardous waste and sewage
No boats shall be moored until a scheme for the removal, storage and disposal of liquid and/or hazardous wastes (including fuels, oils and general residential boat effluent/ sewage) has been submitted to and approved in writing by the Local Planning Authority and the approved scheme shall then be managed as approved unless otherwise approved in writing by the Local Planning Authority.
Reason: To protect the water environment from pollution. 9. Archaeology
No demolition or development shall commence until a written scheme of investigation (WSI) has been submitted to an approved by the local planning authority in writing. For land that is included within the WSI, no demolition or development shall take place other than in accordance with the agreed WSI, which shall include a statement of significance and research objectives, and A. The programme and methodology of site investigation and recording and the nomination of a competent person(s) or organisation to undertake the agreed works. B. The programme for post-investigation assessment and subsequent analysis, publication and dissemination and deposition of resulting material. This part of the condition shall not be discharged until these elements have been fulfilled in accordance with the programme set out in the WSI. Reason: To protect significant heritage items in accordance with policy CC4 (Heritage) of the Local Plan. 10. Cycle Parking
No development shall commence until full details of cycle parking for the moorings has been submitted to and approved in writing by the Local Planning Authority. Car parking shall be provided in accordance with the approval details prior to first occupation of the moorings and maintained permanently thereafter. Reason: To encourage sustainable modes of transport policy EC2 (Developing a sustainable local transport network) of the Local Plan. 11. Car Parking
No development shall commenced until a car parking plan showing at least accessible car spaces suitable for disabled drivers, a communal delivery space, and 20% of spaces with access/ future access to electric vehicle charging points has been submitted to and approved in writing by the Local Planning Authority. Car parking shall be provided in accordance with the approval details prior to first occupation of the moorings and maintained permanently thereafter. Reason: In the interests of highway safety and to encourage sustainable modes of transport policy EC2 (Developing a sustainable local transport network) of the Local Plan. 12. Visibility Splay
No development shall commence until details of a visibility splay of 2.4m x 43m has been provided in accordance with Manual for Streets guidance to the new vehicular access and arrangements for relocation of the existing bus shelter if necessary have been submitted for approval in writing by the Local Planning Authority. Access shall be provided in accordance with the approval details prior to first occupation of the moorings and maintained permanently thereafter. Reason: In the interests of highway safety. 13. Operational Management Plan
No development shall commence until an Operational Management Plan (OMP) for the moorings and associated infrastructure hereby approved has been submitted to and approved by the Local Planning Authority. The moorings and associated infrastructure shall be operated at all times in accordance with the approved OMP.
The OMP shall set out procedures for the ongoing management of the operation of the moorings and associated infrastructure and mitigation of environmental impacts.
The OMP shall include but not be limited to the following areas:
Health and safety
Safety policy and procedures Life saving equipment Fire control and prevention Access, use and maintenance of pontoons
Vessels and users
Vessels must be able to arrive and depart under their own power Vessels must be able to ground Vessels must be designed and capable of speeds up to 8kts Vessels must include own sanitary facilities Vessels must not exceed maximum height, beam and length standards (30 metre houseboats at berths 1-14 and 25 metre houseboats at berths 15-26). Users must be able to demonstrate they are capable of manoeuvring the vessel
Administration
Payment Notice boards and information Control of nuisance and disturbance
Utilities
Service bollards Minimum facilities to include electricity, water, sewage and foul water, phone
Parking and access
Deliveries Disabled spaces Cycle storage Car parking
Environment and Pollution
Prevention of discharges to river Inspection of foul water systems Storage of waste and recycling prohibition on maintenance involving possible discharge of dangerous or polluting substances including but not limited to painting, engine maintenance and anti- fouling work Procedures for accidental spills Controls in respect of noisy activities including use of audio equipment, radios, televisions, operating engines, generators, power tools, alarms and anti-social behaviours
Reason: In the interests of the amenity of park users and adjoining residents and to minimise environmental impacts from the operation of the development. 14. External Lighting
No development shall commence until details of external lighting to be provided for users of the moorings hereby approved have been submitted to and approved in writing by the Local Planning Authority development. External lighting shall be provided in accordance with the approved details prior to first use of the moorings and maintained permanently thereafter. Reason: In the interests of the safety and amenity of future users and occupiers of the site, to prevent excessive light disturbance to the adjacent river, in accordance with policies CC1, CC2 and EQ6 of the adopted Local Plan. 15. Life Saving Equipment
No development shall commence until details of life saving equipment to be provided for users of the moorings hereby approved have been submitted to and approved in writing by the Local Planning Authority development. Life saving equipment shall be provided in accordance with the approved details prior to first use of the moorings and maintained permanently thereafter. Reason: In the interests of the safety and amenity of future users and occupiers of the site, to prevent excessive light disturbance to the adjacent river, in accordance with policies CC1, CC2 and EQ6 of the adopted Local Plan. 16. Construction Method Statement
No development shall commence until a Construction Method Statement for moorings hereby approved, Including for piling and timber grid works and demolition of the existing timber walkway, has been submitted to and approved in writing by the Local Planning Authority. Work shall be carried out in accordance with the approved statement unless otherwise agreed in writing by the Local Planning Authority. Reason: In the interests of the safety and amenity of future users and occupiers of the site, to prevent excessive light disturbance to the adjacent river, in accordance with policies CC1, CC2 and EQ6 of the adopted Local Plan. 17. Hard and Soft Landscaping
No development shall take place until full details of hard, soft and water landscaping works have been submitted to and approved in writing by the local planning authority and these works shall be carried out as approved. These details shall include proposed finished levels or contours; means of enclosure; emergency vehicle and pedestrian access and circulation areas; hard surfacing material; minor artefacts and structures (e.g. furniture, play equipment, refuse or other storage units, signs, lighting etc); proposed and existing functional services above and below ground (e.g. drainage, power, communications cables, pipelines etc. indicating lines, manholes, supports etc); retained historic landscape features and proposals for restoration, and re-use of non-designated heritage assets location at the site, where relevant. Soft landscape works shall include (planting plans; written specifications (including cultivation and other operations associated with plant and grass establishment); schedules of plants, noting species, plant sizes and proposed numbers/densities where appropriate; implementation programme).The scheme shall be implemented as approved prior to first use of the moorings.
Reason: In the interest of biodiversity, sustainability, and to ensure that a satisfactory standard of visual amenity is provided and maintained, in accordance with policy CC1, CC2 (New Development) of the adopted Local Plan. 18. Tree Protection
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 occupation of the building 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 it.
(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 biodiversity and visual amenity area and to accord with policies CC1, CC2 (New Development) and GB7 (Tree Preservation Orders) of the adopted Local Plan. 19. Arboricultural Method Statement
No development shall take place until an Arboricultural Method Statement has been submitted to and approved in writing by the Local Planning Authority. The statement must describe how demolition, excavation and construction activity is to be managed in order to protect the existing trees adjacent to the eastern boundary of the site. This statement shall include details and specifications, for protective fencing, foundations and structural plans, ground level changes, Tree Protection Zones, a timetable of works, material storage areas, supervision and schedule of work methods with regard to BS 5837:2012.
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 biodiversity and visual amenity area and to accord with policies CC1, CC2 (New Development) and GB7 (Tree Preservation Orders) of the adopted Local Plan. 20. Drainage (SuDS)
No development shall commence until details of a Sustainable Drainage System (SuDS) has been submitted to and approved in writing by the Local Planning Authority in respect of the site. Discharge shall be limited to the geenfield rate for the drained area @ 5.2 litres/sec.
Reason: In the interest of biodiversity, sustainability, and the quality of the river environment.
21. Contaminated Land
Before the development hereby permitted commences: a. A contaminated land Phase 1 desk study report shall be submitted to, and approved in writing by the Local Planning Authority. Should the Phase 1 report recommend that a Phase 2 site investigation is required, then this shall be carried out and submitted to, and approved in writing by the Local Planning Authority. The site shall be investigated by a competent person to identify the extent and nature of contamination. The report should include a tiered risk assessment of the contamination based on the proposed end use of the site. Additional investigation may be required where it is deemed necessary. b. If required, a scheme for decontamination of the site shall be submitted to the Local Planning Authority, for written approval. The scheme shall account for any comments made by the Local Planning Authority before the development hereby permitted is first occupied. During the course of the development: c. The Local Planning Authority shall be notified immediately if additional contamination is discovered during the course of the development. A competent person shall assess the additional contamination, and shall submit appropriate amendments to the scheme for decontamination in writing to the Local Planning Authority for approval before any work on that aspect of development continues. Before the development is first brought into use: d. The agreed scheme for decontamination referred to in clauses b) and c) above, including amendments, shall be fully implemented and a written validation (closure) report submitted to the Local Planning Authority for approval. Reason: Contamination is known or suspected on the site due to a former land use. The LPA therefore wishes to ensure that the development can be implemented and occupied with adequate regard for public and environmental safety. Supporting notes: a. An initial phase 1 desk study must be submitted with the original application and will include the aims and objectives, data collection, site reconnaissance (walk over survey), and development of the initial Conceptual Model (CM), which identifies all potential pollutant linkages on the site. The report should also make recommendations for the further gathering of information and or intrusive investigation. The full site investigation must include intrusive testing for soil and groundwater contamination, soil gasses, and leachate. The investigation shall be carried out at such points and at such depths as the LPA may stipulate. Risk assessments must adhere to current UK guidance and best practice. b. The scheme for decontamination shall provide details of how each potential pollutant linkage, as identified in the conceptual model, will be made safe. c. In some instances the LPA may require work on site to be ceased whilst the nature of additional contamination is investigated fully. d. The validation report shall revisit the site conceptual model, and provide evidence that each aspect of the decontamination scheme was carried out correctly and successfully. This report shall prove that the development is suitable for its new use. e. We request that site investigation reports or site plans be sent electronically to [email protected] or by post on a cd or dvd wherever possible.
22. Ecological Works
No development shall commence until a detailed design for the ecological improvements (reed structure) including its design life, monitoring and maintenance measures, the specifications for the fill materials, timber materials and the planting specification, has been submitted to and approved in writing by the Local Planning Authority. All work must be carried out in accordance with the approved details. Reason: In the interest of biodiversity, sustainability, and the quality of the river environment.
23. Noise
Noise from any plant or utilities in the new building hereby approved shall not exceed 10dBA below the background noise level as measured at the nearest sensitive receptor (Victoria Steps Quays houseboats). Reason: In the interest of the amenity of neighbours.
24. River Wall
Prior to the construction of the development a comprehensive river wall survey, including, where required, intrusive investigative works of the existing river wall shall be undertaken to establish the following: The location, landward extent & condition of the buried element of the defence. The structural integrity and stability of the wall, including, if needed, intrusive investigation and or testing of the wall and any buried element. Works required to bring the defences up to the life expectancy of the development. A report detailing the findings of the survey shall be submitted to and approved in writing by the local planning authority. River wall works resulting from the scheme shall be fully implemented in accordance with the approved scheme prior to construction of the development.
Reason: To establish the condition of the existing and proposed river wall to both inform the assessment of needed remedial and or replacement works and the detailed design for any construction close to the flood defence. To reduce the risk and impact of flooding on the proposed development, future occupants and third parties in order to defend the site for the lifetime of the development. 25. Water Framework Directive
Prior to the commencement of the proposed enabling works a Water Framework Directive (WFD) assessment covering the chemical risks associated with the proposed enabling works must be submitted to and approved in writing by the Local Planning Authority. All work must be carried out in accordance with the approved assessment. Reason: To ensure the development is carried out in accordance with the objectives set out in the Water Framework Directive (WFD). 26. Water Framework Directive
Prior to the commencement of the construction works a Water Framework Directive (WFD) assessment covering the dredging/regrading activity must be submitted to and approved in writing by the Local Planning Authority. All work must be carried out in accordance with the approved assessment. To ensure the development is carried out in accordance with the objectives set out in the Water Framework Directive (WFD).
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. The footway, carriageway and bus stop on Brentford High Street must not be blocked during the construction and maintenance of the proposal. The erection of the signage should not at any point encroach on the clear space needed to maintain the safe and uninterrupted flow of road users and pedestrians.
3. The site of proposed signage is situated on Brentford High Street which forms part of the Strategic Road Network (SRN). TfL has a duty under the Traffic Management Act 2004 to ensure that any development does not have an adverse impact on the SRN.
4. Environmental Permit This development may require a permit under the Environmental Permitting (England and Wales) Regulations 2010 from the Environment Agency for any proposed works or structures, in, under, over or within eight metres of the top of the bank of the River Thames designated a ‘main river’. This was formerly called a Flood Defence Consent. Some activities are also now excluded or exempt. A permit is separate to and in addition to any planning permission granted. Further details and guidance are available on the GOV.UK website: https://www.gov.uk/guidance/flood-risk-activities-environmental-permits.
5. The written scheme of investigation will need to be prepared and implemented by a suitably qualified/ professionally accredited archaeological practice in accordance with Historic England’s Guidelines for Archaeological Projects in Greater London. This condition is exempt from deemed discharge under schedule 6 of the Town and Country Planning (Development Management Procedure)(England) Order 2015.
Background Papers:
The contents of planning file referenced on the front page of this report, save for exempt or confidential information as defined in the Local Government Act 1972, Sch. 12A Parts 1 and 2