planning report PDU/2527/02 14 December 2011 RAF Uxbridge, Hillingdon Road, Uxbridge in the London Borough of Hillingdon planning application no. 585/APP/2009/2752 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 – hybrid planning application Outline approval is sought for a residential-led mixed-use redevelopment of an existing RAF base to provide: up to 1,296 residential units (two to six storeys), 77 one bed assisted living retirement units (two storeys), a primary school (two storeys), a 90-bedroom hotel (five storeys), a 1,200-seat theatre with ancillary facilities, a town centre extension with new local centre to contain 2,850 sq.m. retail, 13,860 sq.m. office space, together with GP surgery, an energy centre, district park, car parking, landscaping and servicing. All matters are reserved, with the exception of access. Full planning permission is sought for the change of use of an existing cinema building to community use, the change of use and alterations to the grade-II listed Hillingdon House to provide restaurant and office space together with 44 residential units. The applicant The applicant is VSM Estates, and the architect is Sheppard Robson. Strategic issues The land use principle to provide a large mixed-use residential led development to include a town centre extension, community uses, and commercial floor space is in accordance with strategic planning policies. Appropriate uses for the Green Belt are proposed. The housing mix, density and accommodation quality are acceptable and appropriate conditions have been included on the decision notice. A minimum of 15% affordable housing would be provided on-site and a review mechanism is included in the section 106 agreement which will provide for additional section 106 requirements in the event of the scheme becoming more viable in the future. The strategic issues relating to urban design, climate change and transport issues that were raised at Stage I have been satisfactorily resolved. As such the application is in accordance with strategic planning policies within the London Plan. The Council’s decision page 1 In this instance Hillingdon Council has resolved to grant permission. Recommendation That Hillingdon 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 or direct that he is to be the local planning authority. Context 1 On 23 December 2009 the Mayor of London received documents from Hillingdon 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 Categories 1A, 1B, 3C, 3D and 3F of the Schedule to the Order 2008: “Development which comprises or includes the provision of more than 150 houses, flats, or houses and flats”; “Development (other than development which only comprises the provision of houses, flats, or houses and flats) which comprises or includes the erection of a building or buildings—(c) outside Central London and with a total floorspace of more than 15,000 square metres”; “Development which is likely to prejudice the use as a playing field of more than 2 hectares of land which— (a) is used as a playing field at the time the relevant application for planning permission is made; or (b) has at any time in the five years before the making of the application been used as a playing field”; “Development—(a) on land allocated as Green Belt or Metropolitan Open Land in the development plan, in proposals for such a plan, or in proposals for the alteration or replacement of such a plan; and (b) which would involve the construction of a building with a floorspace of more than 1,000”; and “Development for a use, other than residential use, which includes the provision of more than 200 car parking spaces in connection with that use.” 2 On 2 February 2010 the Mayor considered planning report PDU/2527/01, and subsequently advised Hillingdon Council that the application did not comply with the London Plan, for the reasons set out in paragraph 153 of the above-mentioned report; but that the possible remedies set out in paragraph 155 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. On 24 January 2011 Hillingdon Council decided that it was minded to grant planning permission, and following a period of negotiations regarding the section 106 legal agreement, on 1 December 2011 it formally 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, direct Hillingdon Council under Article 6 to refuse the application or issue a direction to Hillingdon Council under Article 7 that he is to act as the Local Planning Authority for the purposes of determining the application and any connected application. The Mayor has until 14 December 2011 to notify the Council of his decision and to issue any direction. 4 The environmental information for the purposes of the Town and Country Planning (Environmental Impact Assessment) (England and Wales) Regulations 1999 has been taken into account in the consideration of this case. page 2 5 The decision on this case, and the reasons will be made available on the GLA’s website www.london.gov.uk. 6 The London Plan has been published since the Mayor’s initial consideration of this scheme and the Council’s determination, and it is now part of the statutory development plan. Update 7 At the consultation stage, Hillingdon Council was advised that whilst the application was broadly acceptable in strategic planning terms, the scheme was not fully compliant with the London Plan in relation to a number of issues, relating to the scheme viability and affordable housing, urban design, energy, transport and noise. The applicant and Hillingdon Council have subsequently provided further information and clarification on these matters. Addressing each of these points in turn, the following is noted: Affordable housing and viability 8 The scheme proposes 1,340 units of which 15% would be affordable, based on habitable rooms. Of this there would be a 53:47 split between social housing and intermediate rent. At the time of writing the Stage I report in January 2010 the applicant’s affordable housing toolkit had not been independently appraised, and as such it was not possible to confirm if the scheme was providing the maximum reasonable amount of affordable housing. 9 This was in the context of the other large section 106 obligations, including a primary school, district park, roundabout improvements and land for a theatre, and it was necessary to understand the requirements for each of the elements and how these costs would impact upon the affordable housing offer. Extensive discussions have taken place subsequently, between the applicant, Hillingdon Council and the GLA regarding these obligations and the associated costs and the impact that this has upon the provision of affordable housing. In particular, there has been discussion about the Council’s commitment to securing a theatre in this town centre location, and other community uses such as a school, given the shortage of school places in the borough. These competing objectives are accepted, given the scale of development, its location adjacent to the town centre, and the benefits these would bring. 10 The circumstances of this site are that it is surplus to MoD requirements, and forms part of a wider project that involves the consolidation of six London bases onto RAF Northolt. The applicant, VSM would be responsible for delivering the entire project through funding and project managing the construction requirements, the relocation of units and the disposal of the surplus sites. Under normal valuation criteria the value of the development would be no more then the development site value however, guidelines from the GLA viability toolkit explain that if a planning applicant can demonstrate that in order to make the site available for development there is a need to relocate the existing uses elsewhere, these costs can be taken into account when assessing viability. 11 In this case, the cost of building the new facilities at RAF Northolt is being funded by the disposal of the six surplus sites and the development values generated on these sites. In the case of RAF Uxbridge, in excess of £80.5 million is required from the sale of the land to fund the relocation works at Northolt and secure the release of RAF Uxbridge for redevelopment. As such the cost of the relocation of the military facilities to RAF Northolt have been factored into the viability appraisal. 12 Consequently it is only viable for the application to provide 15% affordable housing on-site which will be split 53% social rented units and 44% intermediate units. An independent review of the viability information has confirmed that this is the maximum reasonable amount of affordable housing that can be provided at this point in time. The Council’s independent consultant has carried out a sensitivity assessment and considers that, subject to values increasing and costs page 3 decreasing, that additional sums could be generated by the development. As such, given the phasing of the development and length of the project, a viability review mechanism is proposed in the Section 106 agreement which will provide for additional section 106 requirements, known as “crossover obligations” which would prioritise transport contributions and additional affordable housing.