planning report PDU/0291b/02 1 August 2012 Bedfont Lakes Development, Land at Clockhouse Lane, Feltham in the London Borough of Hounslow planning application no.00287/K/P1

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

The proposal Erection of a storage and distribution warehouse (Class B8) with ancillary offices including associated access and car parking.

The applicant The applicant is The City Hotel Management LTD, and the architect is Buchanan Associates Architects LTD.

Strategic issues Outstanding issues related to design, sustainable development, noise, employment and training, and transport are resolved satisfactorily.

The Council’s decision

In this instance Hounslow Council has resolved to grant permission but giving delegated authority for officers to refuse permission if the Section 106 agreement is not signed within a specified date. Recommendation That Hounslow Council be advised that the Mayor is content for it to determine the case itself, subject to any action that the Secretary of State may take, and does not therefore wish to direct refusal.

Context

1 On 8 May 2012 the Mayor of London received documents from Hounslow Council notifying him of a planning application of potential strategic importance to develop the above site for the above uses. This was referred to the Mayor under Category 3E of the Schedule to the Order 2008:”Development – (a) which does not accord with one or more provisions of the development plan in force in the area in which the application site is situated; and (b) comprises or includes the

page 1 provision of more than 2,500 sq.m. of floorspace for a use falling within any of the following classes in the Use Classes Order -… (viii) Class B8 (storage and distribution).”

2 On 6 June 2012 the Mayor considered planning report PDU/0291b/01, and subsequently advised Hounslow Council that the application did not comply with the London Plan, for the reasons set out in paragraph 87 of the above-mentioned report; but that the possible remedies set out in paragraph 89 of that report could address these deficiencies.

3 A copy of the above-mentioned report is attached. The essentials of the case with regard to the proposal, the site, case history, strategic planning issues and relevant policies and guidance are as set out therein, unless otherwise stated in this report. Since then, the application has been revised in response to the Mayor’s concerns (see below). On 5 July 2012 Hounslow Council decided that it was minded to grant planning permission but giving delegated authority for officers to refuse permission if the Section 106 agreement is not signed within a specified date, for the revised application, and on 23 July 2012 it advised the Mayor of this decision. Under the provisions of Article 5 of the Town & Country Planning (Mayor of London) Order 2008 the Mayor may allow the draft decision to proceed unchanged or direct Council under Article 6 to refuse the application. The Mayor has until 5 August 2012 to notify the Council of his decision and to issue any direction.

4 The decision on this case, and the reasons will be made available on the GLA’s website www.london.gov.uk.

Update

5 At the consultation stage Hounslow Council was advised that the application did not comply with the London Plan, for the reasons set out in paragraph 87 of the above-mentioned report; but that the possible remedies set out in paragraph 89 of that report could address these deficiencies:

 Design: Provide further clarifications and justifications.  Sustainable development: Confirm the savings as required in the report above.  Noise: Provide further clarifications.  Employment and training: Submit a strategy in regard to this.

 Transport: Address concerns raised. Design

6 The Stage I report raised some local design issues and the applicant was asked to provide additional information and justification. It is disappointing that this additional information and justification has not been provided. Given that these are local issues and the Council is content with the development this is, on balance, acceptable. Sustainable development

7 A revised energy strategy has been submitted for the industrial units. The outstanding issues raised at Stage 1 (i.e. carbon savings and modelling based on electric heating) have been satisfactorily addressed and resolved.

Noise

page 2 8 The applicant has provided further clarifications on the noise impact of the development but did not submit a noise mitigation strategy.

9 That said, it is noted that the proposed building would be positioned in the context of other warehouse uses adjoining the site (less than 50m to the west). The nearest residential units are over 500m away, thus the proposal would not harm neighbours living conditions.

10 As such, it is considered that there would not be any impact on adjoining properties with regard to noise, odour or air pollution. Therefore there are no outstanding issues. Employment & training

11 The section 106 agreement includes provision for employment and job brokerage for local people (£100,000 – based on an expected job creation of 40 full-time staff) and a construction training programme for local people (£17,120 – based on construction costs of £6.848M) which is welcomed. Transport for London’s comments

12 At stage 1 TfL requested clarification be provided on the number of goods vehicles and public transport trips likely to be generated by the proposed development; these have now been provided and TfL is satisfied that there would be no significant impact to the highway and public transport network resulting from the proposal; hence no mitigation measures are required. TfL also welcomes that the local authority will be securing a new pedestrian/ cycleway improvement via the section106 agreement.

13 The applicant also confirmed that a total of 25 car parking spaces, including two blue badge bays, will be provided on site; along with eight lorry bays and 20 cycle parking spaces. There will also be provision of five active and three passive electric vehicle charging points. TfL considers that this provision is compliant with London Plan Policy 6.13 – Parking.

14 TfL is therefore satisfied that the strategic transport issues raised at consultation stage are dealt satisfactorily with by conditions or through the section 106 agreements such as car and cycle parking, travel plan, service and delivery plan and construction logistics plan. Response to consultation

15 Neighbour notifications: 12 neighbouring owners/occupiers were consulted. A site notice was displayed on the 09/05/2012 and a press notice on the 04/05/2012. No comments were received from the residents.

16 Statutory Consultees:

 The British Airports Authority (BAA) commented that it has no aerodrome safeguarding objection to the proposal, but requested that a number of conditions be included with any planning permission (Condition 22).

 The Environment Agency (EA) has no objection but recommended a number of conditions which have been conditioned (Conditions 23-26).

 Thames Water commented that with regard to sewerage infrastructure it would not have any objection to the planning application. The Council has conditioned the proposed flood management and mitigation measures as detailed in the Flood Risk Assessment and in regard to SuDS (Conditions 17, 24 and 26).

page 3  Spelthorne Borough Council raises no objection to the proposal subject to the conditions recommended in regard to contamination and air quality issues (conditions 20 and 21), and dust control (Condition 18).

17 All the recommended conditions are included in the draft decision notice. Legal considerations

18 Under the arrangements set out in Article 5 of the Town and Country Planning (Mayor of London) Order 2008 the Mayor has the power under Article 6 to direct the local planning authority to refuse permission for a planning application referred to him under Article 4 of the Order. The Mayor may also leave the decision to the local authority. In directing refusal the Mayor must have regard to the matters set out in Article 6(2) of the Order, including the principal purposes of the Greater London Authority, the effect on health and sustainable development, national policies and international obligations, regional planning guidance, and the use of the River Thames. The Mayor may direct refusal if he considers that to grant permission would be contrary to good strategic planning in Greater London. If he decides to direct refusal, the Mayor must set out his reasons, and the local planning authority must issue these with the refusal notice. Financial considerations

19 Should the Mayor direct refusal, he would be the principal party at any subsequent appeal hearing or public inquiry. Government guidance in Circular 03/2009 (‘Costs Awards in Appeals and Other Planning Proceedings’) emphasises that parties usually pay their own expenses arising from an appeal.

20 Following an inquiry caused by a direction to refuse, costs may be awarded against the Mayor if he has either directed refusal unreasonably; handled a referral from a planning authority unreasonably; or behaved unreasonably during the appeal. A major factor in deciding whether the Mayor has acted unreasonably will be the extent to which he has taken account of established planning policy. Conclusion

21 As such all the outstanding issues have been resolved and the Mayor is content for the Council to determine the case itself, subject to any action that the Secretary of State may take, and does not therefore wish to direct refusal.

for further information, contact Planning Decisions Unit: Colin Wilson, Senior Manager – Planning Decisions 020 7983 4783 email [email protected] Justin Carr, Strategic Planning Manager (Development Decisions) 020 7983 4895 email [email protected] Tefera Tibebe, Case Officer 020 7983 4312 email [email protected]

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planning report PDU/0291b/01 6 June 2012 Bedfont Lakes Development, Land at Clockhouse Lane, Feltham in the London Borough of Hounslow planning application no. 00287/K/P1

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

The proposal Erection of a storage and distribution warehouse (Class B8) with ancillary offices including associated access and car parking.

The applicant The applicant is The City Hotel Management LTD, and the architect is Buchanan Associates Architects LTD.

Strategic issues Principle of use/employment, Green Belt, urban design, access, sustainable development, biodiversity, flood risk management, transport and community infrastructure levy (CIL), employment and training are the key strategic issues considered.

Recommendation That Hounslow Council be advised that the application does not comply with the London Plan, for the reasons set out in paragraph 87 of this report; but that the possible remedies set out in paragraph 89 of this report could address these deficiencies. The application does not need to be referred back to the Mayor if the Council resolves to refuse permission, but it must be referred back if the Council resolves to grant permission.

Context

1 On 8 May 2012 the Mayor of London received documents from Hounslow Council notifying him of a planning application of potential strategic importance to develop the above site for the above uses. Under the provisions of The Town & Country Planning (Mayor of London) Order 2008 the Mayor has until 18 June 2012 to provide the Council with a statement setting out whether he considers that the application complies with the London Plan, and his reasons for

page 5 taking that view. The Mayor may also provide other comments. This report sets out information for the Mayor’s use in deciding what decision to make.

2 The application is referable under Category 3E of the Schedule to the Order 2008: ”Development – (a) which does not accord with one or more provisions of the development plan in force in the area in which the application site is situated; and (b) comprises or includes the provision of more than 2,500 sq.m. of floorspace for a use falling within any of the following classes in the Use Classes Order -… (viii) Class B8 (storage and distribution).”

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

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

5 The site is a wedge of land approximately 1.45ha in size situated between the western and south-western arms of Clockhouse Roundabout in the London Borough of Hounslow. It is bounded on the north by the dual-carriageway of the A30 Staines Road, on the east by an Esso Petrol filling station, on the south by Clockhouse Lane and by neighbouring Green Belt on the west.

Figure 1: Aerial photo of the application site – Source: applicant’s design and access statement

6 The wider surrounding area includes the ‘New Square’ and ‘Lakeshore’ office developments, the Bedfont Lakes, Ascot Road Industrial Trading Estate and extensive areas of open Green Belt, including Mayfield farm to the north of Staines Road. The nearest residential area is on the north eastern side of Clockhouse Roundabout.

7 In addition to Route 116, this site is also served by Route H26. These routes operate from three bus stops on the A30 Staines Road, all are within walking distance to the site. Heathrow Terminal 4 Underground and rail station, and Ashford Station are also the nearest stations to the

page 6 site. It is estimated that the proposed development would have a public transport accessibility rating of 1B which represents very poor accessibility level (PTAL).

Details of the proposal

8 The planning application is for a warehouse designed for a use class of B8 - Storage or Distribution centre. The proposed building contains one large warehouse with a floor space of 3,900 sq.m, including a plant room and auxiliary office with a floor space of 430 sq.m. A service yard and car parking are also incorporated in the scheme. Case history

9 An outline application for hotel development was approved in January 2001, and subsequently detailed planning application was lodged on 22nd June 2001 by Bondcare (Heathrow) Ltd (albeit RMC (UK) Ltd, RMC Properties Ltd and Hanover Property Unit Trust continued to have an interest in the site), for “Erection of a 400 bedroom hotel with associated new access, basement car parking and landscaping.” The application was presented at committee on the 28th February 2002 and was approved subject to the completion of a section 106 Agreement which it is understood has not been signed. In 2004 an application for the variation of Condition 2 (attached to Outline Consent Reference 287/J/P29) time limit to extend the permission to end 17th January 2007.

History of the wider site

10 The first gravel extractions on site were carried out in the mid 1860s and involved a small quarry at what is now the northern end of North Lake, adjacent to Clockhouse Lane. The only remaining feature of this extraction site is Finger Island next to Black Hide, which formed the southern boundary. It was later turned into a fish pond. From the 1930s to the 1950s the site was worked for sand and gravel extraction to provide raw materials for the housing expansion of London and to increase the road network.

11 For the next two decades the abandoned gravel workings were used as a landfill site for both domestic and industrial refuse. At this time there were not the regulations in place concerning the safe disposal of refuse in landfill sites that we have today, and subsequently this caused problems later on in the site’s history. It was reported that at the time it was the largest pile of rubbish in Europe. The landfill site activity ceased in 1973, leaving a legacy of polluted lakes, derelict buildings, and abandoned machinery.

12 In 1988 the Council granted planning permission for the surrounding industrial developments and negotiated that the developers create the Country Park as well. Bedfont Lakes Country Park opened in July 1995 and was the second largest open space to be created in London in the 20th century. The actual application site, currently is vacant, i.e. not part of the Country Park. Strategic planning issues and relevant policies and guidance

13 The relevant issues and corresponding policies are as follows:

 Employment London Plan; Industrial Capacity SPG; draft Land for Industry and Transport SPG  Green Belt London Plan

page 7  Biodiversity/Geodiversity London Plan; the Mayor’s Biodiversity Strategy; draft Tree and Woodland Strategies; London’s Foundations (Geodiversity) SPG  Urban design London Plan;  Access London Plan; Accessible London: achieving an inclusive environment SPG; Planning and Access for Disabled People: a good practice guide (ODPM)  Sustainable development London Plan; Sustainable Design and Construction SPG; Mayor’s Climate Change Adaptation Strategy; Mayor’s Climate Change Mitigation and Energy Strategy; Mayor’s Water Strategy  Flooding London plan;  Ambient noise London Plan; the Mayor’s Ambient Noise Strategy;  Air quality London Plan; draft Early Minor Alteration to the London Plan; the Mayor’s Air Quality Strategy;  Transport/parking London Plan; the Mayor’s Transport Strategy; Land for Transport Functions SPG, draft Land for Industry and Transport  Crossrail London Plan; Mayoral Community Infrastructure Levy; Crossrail SPG

14 For the purposes of Section 38(6) of the Planning and Compulsory Purchase Act 2004, the development plan in force for the area is the 2003 Hounslow Unitary Development Plan and the 2011 London Plan.

15 The following are also relevant material considerations:  The National Planning Policy Framework and Technical Guide to the National Planning Policy Framework  The Hounslow Core Strategy DPD (Preferred Options Stage)  The Hounslow Employment DPD (Adopted November 2008)

 The draft SPG Land for Industry and Transport (2012)

 The Early Minor Alteration to the London Plan

Principle of land use/employment

16 The application site is undesignated on the Hounslow UDP proposals map. The site was previously allocated as Employment Sites but has not been included within Hounslow Employment DPD Adopted in November 2008.

17 However, EP5 'Location of New Industrial/ Warehousing and Related Uses' of the plan states that “Proposals for new industrial/warehousing and related development will be directed to the Borough’s ‘Preferred Industrial Locations’ (PIL), ‘Industrial Business Parks’ (IBP), ‘Locally Significant Industrial Sites’ (LSIS) (refer to Annex 1 and Proposals map) and other existing industrial sites subject to being compatible with uses surrounding the proposal”.

18 EP5 reiterates this further by stating “Where proposals for new development are proposed outside these locations, the Council will make an assessment against the following criteria:

 Compatibility with uses in the area surrounding the proposal and potential impacts on those uses;

page 8  Capacity and impact on the road network and access by sustainable modes of transport.”

19 The draft SPG Land for Industry and Transport (2012) states that “Efficient logistics systems and supporting infrastructure to distribute goods to, from and within London are essential to the competitive offer of almost all London’s economic sectors and to sustain future economic and demographic growth. London will need to accommodate a projected 15 per cent increase in Light Goods Vehicle demand by 2031 (on a 2006 baseline) with stabilizing levels of Heavy Goods Vehicle movement. Directly and indirectly logistics and supporting infrastructure also have implications for Londoner’s quality of life. They are an essential component in the London economy, bringing goods from manufacturers and wholesalers to other businesses, retailers and ultimately customers.”

20 The draft SPG reiterates further that “Research has identified six principal property market areas (see diagram in Annex 4) for industry and logistics in London including:

 Thames Gateway – extending through Newham, Barking and Dagenham and Havering and into Essex on the north side of the Thames, and from Greenwich/Charlton to Belvedere/ Erith and into Kent on the south side;

 Lee Valley – including parts of the Lower Lee, Haringey, Waltham Forest and Enfield;

 Park Royal/A40/M4/A4 corridors – including parts of Brent, Ealing, Hammersmith and Fulham, Hillingdon and Hounslow;

 Heathrow – around the airport and overlapping with the Park Royal/A40/M4/A4 corridor market;

 Wandle Valley – including Wandsworth, Merton, Sutton and Croydon;

 Around the Central Activities Zone – including parts of Camden, Islington, Hackney, Tower Hamlets, Lewisham, Southwark, Lambeth, Wandsworth and Hammersmith and Fulham.”

21 The London Plan in Table 2.1 'Potential strategic outer London development centres', in its strategic function(s) of greater than sub-regional importance under the sub-heading 'logistics' designates Hounslow as one of the potential outer London development centres.

22 The London Plan sets out that the Heathrow Opportunity Area has an indicative employment capacity of 12,000 and sets out that there is capacity to develop Hounslow’s strategically important industrial areas.

23 Having considered the surrounding existing industrial estates and its proximity to the dual- carriageway of the A30 Staines Road and Heathrow airport, the proposed development for the industrial storage and distribution warehouse and ancillary office use is considered acceptable in terms of land use facilitating the above logistics functions and job creation. As such, the proposed development is in keeping with the neighbouring land uses and will enhance the industrial provision within the Heathrow Opportunity Area. Green Belt

24 National Planning Policy Framework states that the Government attaches great importance to Green Belts. The fundamental aim of Green Belt policy is to prevent urban sprawl by keeping land permanently open; the essential characteristics of Green Belts are their openness and their permanence.

page 9 25 Green Belt serves five purposes:

 to check the unrestricted sprawl of large built-up areas;

 to prevent neighbouring towns merging into one another;

 to assist in safeguarding the countryside from encroachment;

 to preserve the setting and special character of historic towns; and

 to assist in urban regeneration, by encouraging the recycling of derelict and other urban land.

26 The NPPF reiterates that when considering any planning application, local planning authorities should ensure that substantial weight is given to any harm to the Green Belt. ‘Very special circumstances’ will not exist unless the potential harm to the Green Belt by reason of inappropriateness, and any other harm, is clearly outweighed by other considerations.

27 The site itself is not a designated Green Belt but is bounded on the east by neighbouring Green Belt. Thus that the applicant does not need to demonstrate ‘very special circumstances’. Provided that the green landscaped buffer around the site is clarified and justified (see detailed comments in the design section below), it is considered that the scale, massing and height of the proposed development will not have a detrimental impact on the neighbouring Green Belt. Biodiversity

28 The site is not designated as having any strategic ecological importance and Bedfont Lakes (SINC) is approximately 0.6miles away, but as the site is currently open land the Council should ensure the impacts of the development are mitigated.

29 It is understood that a 1.8m welded mesh fence would be erected along the western and northern boundaries of the site. Works for construction would include dewatering and infilling of the excavation and levelling of the ground and construction of the surfaces and buildings. Infill may be obtained from levelling of the proposed development site off Ascot Road, in the western part of the adjacent restored land.

30 These proposals would result in the loss of a recently formed area of standing open water with an associated narrow strip of marginal vegetation, along with dense willow scrub and areas of semi-improved grassland. The groups of trees on the north western, north eastern and southern boundaries of the site would be retained, and the fence along the southern boundary would be retained. It is thought unlikely that noise from construction or operation of the site would affect nearby sites of nature conservation importance due to its position between two fairly busy roads (A30 and Clockhouse Lane). In the absence of mitigation, construction and subsequent operation of the industrial unit may result in disturbance to any wildfowl using the adjacent restored land immediately to the west and contiguous with the site.

31 The mitigation measures proposed include:

 Removal of trees and scrub should be undertaken outside the breeding bird season (March to September), or following a check for nesting birds. If nesting birds are recorded, the nest should be left intact until nestlings have fledged. The timing of de-watering/infilling of the flooded excavation should be informed by the further survey, and the construction works should follow a wildlife construction plan.

page 10  Where possible, bird boxes, including those suitable for house and tree sparrow, should be attached to the western and northern sides of the warehouse and to the larger retained trees in this area. The dead birch tree should be retained as standing dead wood if possible, or felled and the dead wood used to create log piles to benefit invertebrates in the adjacent area of restored land. The trees to be retained around the periphery of the site should be protected during construction.

 On account of its proximity to the development site, Japanese knotweed in the northern part of the adjacent restored land should be fenced off and treated to reduce the risk of it spreading more widely, including inadvertently (Appendix III). Buddleia and goat’s-rue would be removed from the site as part of site clearance works and, as invasive species, should not be planted as part of the landscape scheme.

32 Provided that the above and all the proposed mitigation measures in the ecological report are conditioned, maintained and managed the detrimental impact on biodiversity is considered to be minimal.

Urban design

33 Good design is central to all objectives of the London Plan (2011) and is specifically promoted by the policies contained within chapter seven which address both general design principles and specific design issues. London Plan Policy 7.1 sets out a series of overarching design principles for development in London. Other design polices in this chapter and elsewhere in the London Plan include specific design requirements relating to maximising the potential of sites, the quality of new housing provision, tall and large-scale buildings, built heritage and World Heritage Sites, views, the public realm and the Blue Ribbon Network. New development is also required to have regard to its context, and make a positive contribution to local character within its neighbourhood (policy 7.4).

34 The proposed development sits on a triangular site with its northern edge fronting on to Staines Road, its eastern edge facing a green open space and the remaining edge along Clockhouse Lane. The scheme is made up of a large 11.3m high shed with a footprint of 97 x 51 metres clad in two tones of grey Kinspan Wall Panels. An area of a similar footprint is covered in hard surfacing to be used as car parking and servicing to the southern side of the shed. A strip of landscaped greenery is located along the eastern and northern edges of the site.

Figure 2: An artist impression (3D view from Clockhouse Lane) – Source: applicant’s design and access statement

35 Whilst the site presents no significant strategic opportunities for improving the quality or permeability of the area and spaces around it, it is disappointing that the information provided does not indicate any clear intentions for the design of the development or a clear strategy to how it relates to the surrounding area which is disappointing.

page 11 36 The green landscaped buffer around the sides of the site does not appear to contribute to the quality of the scheme or of the surrounding area and needs further justification, in particular the reasoning for the green buffer along the northern boundary with Staines Road.

37 No explanation has been given as to why the two chosen shades of grey are particularly appropriate for the cladding of the shed or the rationale for the particular articulation of the office block. Further justification for this is required as well as illustrations showing the alternatives that have been considered.

38 In summary, whilst the issues outlined above are considered to be locally rather than strategically important the applicant is asked to provide a clearer outline of the design intentions and justifications for the scheme. Access arrangement

39 London Plan Policy 7.2 seeks to ensure all future development meets the highest standards of accessibility and inclusion, and requires design and access statements submitted with planning applications to explain how the principles of inclusive design, including the specific needs of disabled people, have been integrated into the proposed development.

40 The design and access statement demonstrates that the scheme is designed in accordance with Part M of the Building Regulations. All entrance and perimeter paths are to be firm, durable and slip resistant with a minimum width of 1800mm. Access to the building is designed to provide safe passage for people with disabilities. There is a step free access into the building via 1:20 ramp. Powered entrance door, passenger lift and one unisex wheelchair accessible toilet are provided on ground floor.

41 Two disabled car parking spaces for wheelchair users are provided in compliance with section 1 (part M), close to the entrance with dropped kerb access.

42 The access arrangement incorporates inclusive design. This is welcomed and supported. Sustainable development

43 London Plan policies 5.2, 5.6 and 5.7 focus on mitigation of climate change and require a reduction in a development’s carbon dioxide emissions through the use of passive design, energy efficiency and renewable energy measures. The London Plan requires developments to make the fullest contribution to tackling climate change by minimising carbon dioxide emissions, adopting sustainable design and construction measures and prioritising decentralised energy, including renewables.

Overview of proposals

44 The applicant has broadly followed the energy hierarchy. Sufficient information has been provided to understand the proposals as a whole. Further revisions and information is required before the proposals can be considered acceptable and the carbon dioxide savings verified.

Climate change mitigation

BE LEAN

Energy efficiency standards

page 12 45 A range of passive design features and demand reduction measures are proposed to reduce the carbon emissions of the proposed development. Both air permeability and heat loss parameters will be improved beyond the minimum backstop values required by building regulations. Other features include energy efficiency, lighting and mechanical ventilation with heat recovery. The demand for cooling will be minimised through the use of high performance glazing and solar shading.

46 Based on the information provided, the proposed developments do not appear to achieve any carbon savings from energy efficiency alone compared to a 2010 Building Regulations compliant development (BER higher than TER). The applicant should model additional energy efficiency measures and commit to the developments to exceed 2010 Building Regulations compliance through energy efficiency alone.

47 From the information submitted in the energy strategy it appears that the modelling compared the energy reductions of the building based on electrical space heating and gas fired boilers for hot water generation to ascertain the improvement due to fabric enhancements and various active measures.

48 In line with the GLA energy assessment guidance, September 2011, the applicant should note that the target emission rate should be calculated assuming the building is heated from a gas boiler only (for all tiers of the energy hierarchy.) With this in mind and for clarity, using Table 1 & 2 in the GLA energy assessment guidance, September 2011, the applicant should update the regulated carbon dioxide savings from energy efficiency alone expressed in tonnes of carbon dioxide per annum and in percentage terms for the development.

BE CLEAN

District heating

49 The applicant has carried out an investigation and there are no existing or planned district heating networks within the vicinity of the proposed development. The applicant should however, provide a commitment to ensuring that both buildings are designed to allow future connection to a district heating network should one become available.

50 The applicant should investigate linking both the Ascot Road and Clockhouse lane buildings via an onsite heat network served from a single energy centre. Any constraints to doing so should be clearly summarised and evidenced.

Combined Heat and Power (CHP)

51 The applicant has investigated and discounted the use of CHP. Given the type of development and potential intermittent heat loads, this is accepted in this instance.

BE GREEN

Renewable energy technologies

52 The applicant has investigated the feasibility of a range of renewable energy technologies and is proposing to install air source heat pumps to provide the buildings heating and cooling requirements.

53 The applicant states that at the final stages of modelling the fuel source was changed to ASHP, and hence the notional figure (TER) also changed.

page 13 54 As mentioned in the energy efficiency section, in line with the GLA energy assessment guidance, September 2011, the applicant should note that the target emission rate should be calculated assuming the building is heated from a gas boiler (for all tiers of the energy hierarchy.)

55 With this in mind and for clarity, using Table 1 & 2 in the GLA energy assessment guidance, September 2011 the applicant should provide the absolute regulated carbon dioxide savings from this tier of the hierarchy expressed in tonnes of carbon dioxide per annum and in percentage terms.

OVERALL CARBON SAVINGS

56 Taking into account the comments above and using Table 1 & 2 in the GLA energy assessment guidance, September 2011 the applicant should confirm the absolute overall value of regulated carbon dioxide savings as well as savings at each tier of the energy hierarchy expressed in tonnes of carbon dioxide per annum and in percentage terms for the buildings.

57 Further revisions and information is required before the proposals can be considered acceptable and the carbon dioxide savings verified.

Climate change adaptation

58 London Plan policy 5.3 Sustainable Design and Construction seeks to ensure future developments meet the highest standards of sustainable design and construction. Specific policies relate to overheating (5.9), green roofs (5.11), urban greening (5.10), flood risk (5.12) and sustainable drainage (5.13), water (5.14 and 5.15) and waste (5.17). Further guidance is provided in the London Plan Sustainable Design and Construction SPG.

59 Although some measures are identified in the FRA including green roofs further information should be provided. Flooding management

60 A flood risk assessment (FRA) has been submitted and it states that the site is located within Flood Zone 1, and that that all development types are compatible with this location, provided necessary flood risk mitigation measures and maintenance are appropriately implemented.

61 The FRA report demonstrates that the risk of flooding from nearby rivers, lakes, groundwater, and sewers are minimal. However, The King George V1 and Staines Reservoirs which are raised storage facilities, that lie approx. 1,700m west of the site, could be a source of potential flooding in the event of a failure. But due to the distance and ongoing maintenance of the structures it is not considered that they pose a serious flood risk.

Flooding management

62 The FRA concludes that subject to further investigation it should be possible to provide a drainage system for the site utilising a combination of techniques that include living roofs, basins and ponds, filter strips and ponds, infiltration devices, permeable paving and tanked systems.

63 Whilst this is welcomed, the proposed flooding management and mitigation measures should be conditioned and implemented in consultation with the Environment Agency and Thames Water. Noise

page 14 64 The Environmental Noise Survey Report supporting the planning application was prepared by Hann Tucker Associates, and dated 29th March 2012. The noise survey was carried out by the deployment of two unmanned noise monitors for 24 hours.

65 The report presents the measured background noise levels in terms of LA90. However, no assessment is made of the noise impact due to the proposed development, such as vehicular movements and fixed plant installation.

66 A noise impact assessment is required in order to assess the impact of the development. Air quality

67 A qualitative assessment of dust assessment of dust levels associated with the construction of the proposed development at land off Clockhouse Lane in Hounslow shows that, although dust is likely to occur from site activities, this can be reduced through appropriate mitigation measures. Some degree of dust impact is possible at these properties if the dust is not properly mitigated.

68 Acceptable mitigation measures are proposed by the applicant and these should be conditioned.

69 The air quality assessment is sound and the proposed mitigation measures are acceptable. They should be secured via appropriate conditions. Employment and training

70 Continued investment in the skills of London's current workforce will ensure that skills and training provision is tailored to meet current employer demand. The GLA is committed to develop the skills that London needs to sustain economic growth, improving individual's employability skills in order to create a positive impact on the skills levels within all of London's communities.

71 Consequently, and in accordance with London Plan 2011 Policy 4.12 ‘Improving opportunities for all‘, the applicant should confirm that the proposals will deliver a number of employment opportunities for local residents as required by the London Plan policy. The proposed scheme should incorporate construction training. This should also be secured as part of the s106 agreement. Transport for London’s comments

72 The proposed main vehicular access to the site is by a single point of vehicular access directly from Clockhouse Lane, a borough road, further south of the existing vehicular access to New Square Business Park. It is proposed that the vehicular access will take the form of a priority controlled junction. This level of provision is considered acceptable as it allows for 2 large articulated vehicles to simultaneously make use of the proposed access without encroaching on either vehicle.

73 It is proposed that the development will provide 6 lorry parking bays and 29 car parking spaces; this is also considered to be within the standards set out in the London Plan and is therefore acceptable. However, it also remains unclear how many disabled spaces will be provided; and this should be clarified in order to ensure compliance with the London Plan.

74 The applicant should also clarify the actual number of spaces that will be equipped with electric vehicle charging points and should ensure that they are in line with the London Plan standards.

page 15 75 It is proposed that 19 cycle parking spaces will be provided. This is also in accordance with the standards set out in London Plan and is welcomed. The applicant should also confirm that the facilities will be provided in a secured and safe location; along with adequate changing and shower facilities to be provided on site to encourage staff to cycle to work; this is to comply with the London Plan Policy 6.9 Cycling.

76 As per the neighbouring site, it is estimated that the site will generate an additional 27 two-way trips and 29 respectively during the morning and afternoon peaks; confirmation should also be provided whether those figures include the movements of goods vehicles generated from the proposal.

77 Similarly a full modal split assessment is required to assess the trip generation impact for non-car based modes of transport; TfL may also be seeking for s106 contributions if deemed necessary as a result, particularly in relation to local bus services.

78 The A30 forms part of the Olympic Route Network (ORN). TfL welcomes that there is no proposed highway work on the A30 as part of these two applications. However, TfL requires further information to ascertain the extent of traffic impact on the TLRN, in particular the level of goods vehicle trips to be generated.

79 A travel plan was submitted as part of this application and failed the ATTrBuTE tool assessment due to lack of clarity on how they will be secured. In order to ensure conformity with London Plan Policy 6.3, TfL expects the travel plan to be updated and subsequently secured, monitored, reviewed, and implemented via the s106 agreement.

80 Given the site location and existing poor pedestrian environment, TfL would therefore recommend that provision of a pedestrian/cycle route through and to/from the site be further considered to improve accessibility to local bus services in line with London Plan policy 6.10- Walking.

81 A construction logistics plan (CLP) and a delivery servicing plan (DSP) should have been included with the TA, however TfL is content for these to be secured by planning condition.

82 In accordance with London Plan policy 8.3 ‘Community Infrastructure Levy’, the Mayor has agreed a CIL Charging Schedule which came into operation on 1 April 2012. It will be paid by most new development in Greater London. Boroughs are arranged into three charging bands with rates of £50 / £35 / £20 per square metre of net increase in floorspace respectively. The proposed development is in the Borough of Hounslow, where the charge is £35 per square metre.

83 In summary the following issues should be addressed:

 Confirmation on the goods vehicle trip generation;

 Undertaking of modal split assessment to ascertain trip generation for non car based modes of transport;

 Investigation of pedestrian/cycle routes through and to/from the site to improve accessibility to local bus stops

 The securing of CLP, DSP and travel plan via appropriate condition/obligation;

 Confirmation of disabled parking provision;

 Provision of electric vehicle charging facilities to comply with London Plan 2011 requirement;

page 16  Revision to travel plan and that the plan will be secured via appropriate planning obligations.

Local planning authority’s position

84 It is understood that Hounslow officers are in a position to recommend for approval. Legal considerations

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

86 There are no financial considerations at this stage. Conclusion

87 London Plan policies on principle of use and employment, Green Belt, urban design, access, sustainable development, biodiversity, flood risk management, transport and community infrastructure levy (CIL), employment and training are relevant to this application. The application complies with some of these policies but not with others, for the following reasons:

 Principle of land use/employment: The proposed development is acceptable in terms of land use and job creation.  Green Belt: There is no detrimental impact on the neighbouring Green Belt.  Biodiversity: There is no strategic concern, but the proposed mitigation measures should be conditioned.  Urban design: The applicant is required to provide further clarifications and justifications for the issues raised in the design section of this report.

 Access: The access arrangement is acceptable, but it should be conditioned.

 Sustainable development: The applicant should confirm the overall value of regulated carbon dioxide savings as well as savings at each tier of the energy hierarchy expressed in tonnes of carbon dioxide per annum and in percentage terms for the buildings.

 Flood risk management: The flood risk management is acceptable, but it should be conditioned. Consultation with the EA and Thames Water is highly recommended.

 Noise: Clarifications and further work is required, in particular related to the noise impact of the development such as vehicular movements and fixed plant installation.

 Air quality: The air quality assessment is sound and the proposed mitigation measures are acceptable. They should be secured via appropriate conditions.

page 17  Employment and training: The applicant should submit a strategy in regard to this and it should be secured as part of the s106 agreement.

 Transport: The applicant is required to address concerns raised in the transport section of this report.

88 On balance, the application does not comply with the London Plan.

89 The following changes might, however, remedy the above-mentioned deficiencies, and could possibly lead to the application becoming compliant with the London Plan:  Design: Provide further clarifications and justifications.  Sustainable development: Confirm the savings as required in the report above.  Noise: Provide further clarifications.  Employment and training: Submit a strategy in regard to this.  Transport: Address concerns raised.

for further information, contact Planning Decisions Unit: Colin Wilson, Senior Manager – Planning Decisions 020 7983 4783 email [email protected] Justin Carr, Strategic Planning Manager (Development Decisions) 020 7983 4895 email [email protected] Tefera Tibebe, Case Officer 020 7983 4312 email [email protected]

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