RAF Uxbridge, Hillingdon Road, Uxbridge

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

“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. The review mechanism will be undertaken on a phase by phase basis using an agreed review toolkit, and will apply to profits generated over and above an initial rate of return of 15%. As part of the negotiations, it has also been agreed that the profits will be split – with 40% to the developer and 60% to the Council to incentivise the developer to increase profits. The review mechanism sets out that a maximum of 50% affordable housing would be provided in each phase and overall, but that it cannot fall below 15%.

13 Fundamental to the acceptability of the affordable housing offer, and as required by London Plan policy 3.13, is that the scheme would deliver the maximum reasonable amount of affordable housing over the life of the scheme, with appropriate review mechanisms secured in the section 106 agreement. London Plan policy 8.2 establishes the strategic priorities for planning obligations and states affordable housing and transport should generally be given the highest importance. In addition to the affordable housing requirement, the scheme would also provide for upgrading of the St Andrew’s Roundabout (to improve links to the town centre), as well as highways mitigation works, a transport fund, sustainable travel plan initiatives. There are other obligations such as a gift of land and contribution to build a new two-form entry primary school, the laying out of a new district park and contribution towards a theatre that place a financial obligation on the developer. In line with Hillingdon Council, it is considered that the proposed planning obligations are pragmatic and realistic, offering a guaranteed minimum amount of affordable housing and significant regeneration benefit for the edge of the town centre.

Urban design

14 At the initial consultation stage, it was acknowledged that the masterplan principles were well considered in terms of height and massing and responding to the Green Belt location. The density across the site varies, responding to the different locations, and is acceptable in principle. There were some queries about connections to the town centre and plot sizes, and a commitment to achieving the design codes would be expected at detailed design stage.

15 The application is accompanied by an illustrative masterplan, parameter plans, a landscape and open space strategy and a design code. The Council notes that the scheme would be subject to further consideration in terms of appearance at reserved matters stage and through the discharge of conditions.

16 In terms of residential quality, it is acknowledged that the scheme is largely outline, and as such it will be important that at detailed design stage, a satisfactory standard of accommodation is secured. The Council notes that the scheme would exceed its own minimum floor space standards, however, it is noted that since the Stage 1 consideration of the scheme, the London Plan (2011) has been adopted and this sets out minimum standards for residential development, which exceed the minimum standards set by the Council. The applicant has produced an accommodation schedule that shows that, except for three units the development would meet the London Plan minimum standards. The Council has also agreed to impose a condition requiring that all units are built to comply with these standards. On this basis, the scheme is in accordance with London Plan policy 3.5.

Energy and climate change

17 A number of queries were raised at the initial consultation stage in relation to the proposed energy strategy. This included remodelling of the baseline carbon emissions, investigation into district heating and providing details in relation to renewable energy.

page 4 18 The applicant has subsequently provided further clarification and commitments in relation to its energy strategy. In particular, the applicant has confirmed its commitment to connecting the buildings within the mixed use zone to the district heating network. Given the constraints highlighted in relation to connecting other buildings outside the mixed use zone, it is accepted that the district heating would not initially extend beyond this zone. A section 106 obligation has been secured, which defines the district heating network as connecting the hotel, theatre, cinema, offices and every apartment in the Mixed Use Urban Zone. A trigger point that requires the CHP to be operational by the time 60% of the domestic properties is proposed within the section 106 agreement, and this is acceptable.

19 The applicant is also proposing to install photovoltaic panels, with a minimum area of 8,000 sq.m. to achieve a 15% reduction in emissions. This is also secured in the section 106 agreement, ensuring a renewable technology that is compatable with the overall energy strategy, including the heat network infrastructure supplied by CHP, and there is sufficient amount of it.

20 The scheme would be constructed to Code for Sustainable Homes Level 4 (with some up to 6) and BREEAM excellent, and conditions are proposed to secure these commitments. On this basis, outstanding issues raised at the initial consultation stage have been sufficiently addressed and the scheme is considered to be in accordance with London Plan climate change policies.

Transport

21 At the initial consultation stage, a number of issues were raised that needed to be addressed in order to make the development acceptable in transport terms. In particular, further highway assessment, details on junction design and information on how the pedestrian environment would be improved was required. Mitigation towards enhanced bus capacity and infrastructure, further work with regard to pedestrian and cycle links, cycle parking and the travel plan was also required. TfL also requested a reduction in the level of car parking proposed. Since the initial consultation stage, a substantial amount of work and negotiation has taken place in order to resolve the outstanding transport issues.

22 A package of transport related Grampian style obligations have been secured:

 £1,620,000 contribution to be paid to the Council towards St Andrew’s roundabout.  £500,000 transport contribution fund, for unforeseen highway mitigation.  £350,000, to be paid to the Council for travel planning measures.  £120,000 to be paid to the Council towards bus infrastructure improvements.  £45,000 towards a Parking Management Study.

23 In addition contributions for other non-specific highway works to improve safety and accessibility have been secured. A comprehensive package of highway and pedestrian improvements on the local network, have been secured through the section 106 and will be delivered by the developer via s278 agreements. This is welcomed by TfL.

24 The residential parking level has not been reduced and remains at approximately 1.2 spaces per unit. This is broadly in line with London Plan standards given the location and accessibility of the site and mix of larger three and four bed units within the development. Given the proximity to Uxbridge town centre and a range of public transport links however, it is requested that a parking target be included in the section 106 agreement. The car parking management plan should be the mechanism used to achieve this target and should also be secured through the section 106 agreement. This document will include monitoring car ownership and car use, local highway issues parking controls and viability on a phased basis, and on this basis, it is requested that TfL be consulted prior to approval of the car parking management plan, which in turn should be approved prior to commencement of development. Subject to addressing the outstanding issues through the section 106 agreement, the application is in conformity with London Plan policy 6.13.

page 5 25 The commercial car parking has been reduced slightly by 74 spaces and is acceptable to TfL. A minimum of 6 car club vehicles across the site will be provided and electric vehicle charging points have been secured in the section 106 agreement, in line with London Plan standards. TfL also welcomes the planning condition that ensures occupants of the development will not be eligible to apply for parking permits in any future controlled parking zone in the vicinity of the site. Furthermore 10% of all parking on site would be for disabled users and appropriate taxi rank and coach parking facilities have been secured by condition.

26 Following further assessment TfL concluded that given the site’s position adjacent to a high-frequency bus corridor, that it would not be necessary to run buses through the site. The bus infrastructure improvements that have been secured will ensure high quality and accessible bus provision for future occupiers of the site.

27 The framework travel plan is acceptable and has been secured via the section 106 agreement. A travel plan contribution of £250 per unit (or a total of £350,000) to be paid to the Council for travel plan initiatives has been secured in the section 106 agreement. This ensures conformity with London Plan policy 6.3. A delivery and servicing plan and construction logistics plan have been secured by condition; this is welcomed by TfL and ensures conformity with relevant elements of London Plan policies 6.3 and 6.14.

28 Overall, the additional work undertaken, the package of transport obligations and planning conditions mean that the development is acceptable in transport terms and complies with London Plan transport policies. Response to consultation

29 The application was advertised by site and press notices and consultation letters, which were sent to approximately 3475 neighbouring properties on two occasions.

30 A total of 17 responses were received as a result of the initial consultation process, with 14 objections and three petitions following the second round of consultation. Concerns were raised in relation to the following:

 Overdominance of buildings – building heights should be no greater than 2-3 storeys.  Density of the scheme, resulting in overpopulation.  Loss of light.  Impact on privacy.  Impact upon biodiversity, including bats and  Transport impact, in terms of volume of traffic, parking levels, connectivity, traffic controls, pedestrian and cycle routes.  Other uses such as hospital, bus depot, community centre, museum should be considered.  Uses such as retail, hotel and theatre are questions.  Concern over the loss of the sports stadium.  Pollution during construction stage, and need for restrictions on construction hours.

31 Letters of support were received from two parties, stating that the mix of uses is appropriate and the open space provision is welcomed.

32 The petitions raise issues in relation to traffic, wildlife protection, St Andrew’s Roundabout, and how the scheme extends the town centre.

33 A response was received from an MP, expressing support for a museum on the site.

34 Matters relating to the amenity impact, loss of light, privacy, pollution crime, and local amenities are not in this instance strategic planning matters and have been assessed by Hillingdon

page 6 Council in the committee report. In relation to the objections from local residents raising strategic matters about the use of the site, design, density, transport, noise and air quality these have been dealt with in this and the previous report.

35 Other statutory consultees responded as follows:

 English Heritage: Objections have been raised in relation to the loss of heritage assets, namely barrack blocks and the NAAFI building. Support is offered in relation to the change of use of the cinema but there are concerns about the impact of the new buildings on its setting. The changes to Hillingdon House are welcomed.

 Environment Agency: Conditions are recommended in relation to flood risk, contamination, ground water infiltration, piling, buffer to the River Pinn, and management for flood storage. Appropriately worded conditions have been imposed by the Council.

 London Fire Brigade: Fire fighting provision is to be addressed by existing fire hydrants in-situ, or additional hydrants to conform to British Building standards.

 Thames Water: No objections raised in relation to waste or water, subject to a drainage strategy being secured. The Council has secured such a condition.

 Metropolitan Police: No objections, subject to appropriately worded conditions being secured in relation to CCTV, Secure by Design, details of cycle parking, car parking, boundary treatments. Such conditions have been imposed.

 Sport England: Following clarification from the Council, concerns raised in relation to replacement facilities at RAF Northolt and securing in-kind provision of facilities at RAF Uxbridge have been addressed. This is subject to a robust obligation that has been secured in the section 106 agreement in relation to school facilities and district park that are being provided.

 London Wildlife Trust: No objection is raised, subject to the implementation of management plans for the district park and the River Pinn. Conditions are proposed in relation to biodiversity management.

 Theatres Trust: No objections raised to the the change of use of the cinema, and the theatre is welcomed.

 Natural England: No objections to the proposal, and the provision of open spaces and landscaping, and brown/green roofs is welcomed. Any protected species should be protected, and opportunities for biodiversity enhancement should be included. A condition has been included by the Council securing details of ecological enhancement works and landscaping.

 BAA Safeguarding: Suggests conditions in relation to bird hazard management, landscaping, and renewable energy. Suitably worded conditions are proposed.

 Hillingdon PCT: Would prefer a financial contribution over the provision of a facility on site. In response, the Council notes that the provision for health facilities in the town centre extension is in accordance with he RAF Uxbridge SPD.

page 7  London Cycling Campaign: Cycle improvements to St Andrews Roundabout and links to the north are suggested. Conditions and section 106 obligations have been imposed in relation to prioritising walking and cycling.

 Adjoining boroughs/councils: No objections raised by Ealing, Harrow, or Hounslow Councils, Fulmer Parish Council, or Surrey County Council. Buckinghamshire County Council has made comments in relation to traffic modelling, congestion, and the validity of data provided. South Bucks Council is concerned about traffic impact and the impacts upon infrastructure. Chorleywood Parish Council states that the Air Defence Museum should be retained and raises concerns about the road systems. It is noted that the Battle of Britain Bunker and curtilage would remain in situ, and the transport statement addresses issues in relation to traffic.

 Garden History Society: No objections, although concerns raised regarding the history landscape and contribution made by the RAF period, and that there should be more inclusion of RAF landscape features into the scheme.

36 The following provided either no objection, no comment or no response: Highways Agency, NATS, Civil Aviation Authority, EDF Energy, Scottish and Southern Electrict, Crossrail, Network Rail, Ministry of Defence, British Waterways, BAA Heathrow, LAMAS, Health and Safety Executive

37 In relation to the points raised by English Heritage and the heritage of the site, the Council notes that the masterplanning process has been informed by comprehensive studies of the buildings worthy of protection, and which are being retained as part of the proposals. The barrack blocks and parade ground are not listed and as such, their loss is not considered to key to the site’s heritage. With the retention of one barrack block and the cinema, and the works to Hillingdon House and its setting, on balance, there are no objections to the proposed works. Article 7: Direction that the Mayor is to be the local planning authority

38 Under Article 7 of the Order the Mayor could take over this application provided the policy tests set out in that Article are met. In this instance the Council has resolved to grant permission with conditions and a planning obligation, which satisfactorily addresses the matters raised at stage I, therefore there is no sound planning reason for the Mayor to take over this application. Legal considerations

39 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. He also has the power to issue a direction under Article 7 that he is to act as the local planning authority for the purpose of determining the application and any connected application. 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. If the Mayor decides to direct that he is to be the local planning authority, he must have regard to the matters set out in Article 7(3) and set out his reasons in the direction. The Mayor must also have regard to the guidance set out in GOL circular 1/2008 when deciding whether or not to issue a direction under Articles 6 or 7.

page 8 Financial considerations

40 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.

41 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.

42 Should the Mayor take over the application he would be responsible for holding a representation hearing and negotiating any planning obligation. He would also be responsible for determining any reserved matters applications (unless he directs the council to do so) and determining any approval of details (unless the council agrees to do so). Conclusion

43 Having regard to the details of the application, the matters set out in Hillingdon Council’s committee report and its draft decision notice, this scheme is acceptable in strategic planning terms. Further information has been provided, which together with conditions (and planning obligations) imposed by Hillingdon Council, address all the outstanding issues that were raised at Stage 1. A further condition is proposed to secure minimum space standards for dwellings in accordance with the London Plan. On this basis, there are no sound reasons for the Mayor to intervene in this particular case.

page 9

planning report PDU/2527/01 2 February 2010 RAF Uxbridge, Hillingdon Road, Uxbridge

in the London Borough of Hillingdon Planning application no. 585/APP/2009/2752

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 This is a hybrid application seeking part outline and part full planning permission.

Outline approval is sought for a residential-led mixed-use redevelopment of an existing RAF base to provide a community of 1,425 new homes, 77 one bed assisted living retirement units, a primary school, a 90-bedroom hotel, a 1,200-seat theatre with ancillary facilities, a town centre extension and a new local centre with retail, office and medical facilities, and an energy centre. There will also be improvements to the local transport network, and a network of streets and open spaces throughout the site, including a new district park. 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 a restaurant and office space together with the creation of new housing, as well as the change of use of other buildings around the site to provide additional dwellings.

The applicant The applicant is VSM Estates, and the architect is Sheppard Robson.

Strategic issues Strategic issues for consideration are the principle of the proposed mixed use development; the loss of playing fields and the impact on the green belt; justification for, and acceptability of, the proposed quantum of retail, office and leisure uses; the requirement for affordable housing and the proposed mix of housing units; residential quality; and the provision of children’s play space.

Also for consideration are the transport requirements of the scheme; urban design, including the setting of the retained listed buildings, the design of the public realm; the need for new social and community infrastructure; climate change mitigation and adaptation; biodiversity; and flood risk.

page 10 Recommendation That Hillingdon Council be advised that while the application is generally acceptable in strategic planning terms, the application does not comply with the London Plan, for the reasons set out in paragraph 153 of this report; but that the possible remedies set out in paragraph 155 of this report could address these deficiencies.

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. Under the provisions of The Town & Country Planning (Mayor of London) Order 2008 the Mayor has until 2 February 2010 to provide the Council with a statement setting out whether he considers that the application complies with the London Plan, and his reasons for taking that view. The Mayor may also provide other comments. This report sets out information for the Mayor’s use in deciding what decision to make.

2 The application is referable under 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 for a use, other than residential use, which includes the provision of more than 200 car parking spaces in connection with that use.”

3 Once Hillingdon 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; take it over for his own determination; or allow the Council to determine it itself.

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

page 11 Site description

6 The proposals concern a 44.6 ha Royal Air Force Base located next to Uxbridge Town Centre. The site contains a number of buildings that reflect its military use including offices, barracks, accommodation blocks, mess facilities, recreational buildings and stores. The site also contains Hillingdon House, a Grade II listed mansion dating to 1844, and a Grade 1 listed bunker. There are also outdoor facilities including a rifle range, sports pitches and an athletic track.

7 The eastern portion of the site sits within the Green Belt, and within this is the River Pinn flood plain corridor, which runs north south. There are a number of groupings of trees around the site including on the avenues around the parade ground, along the River Pinn and along the western boundary.

8 The site is bounded to the west by Hillingdon Road and Park Road, with Honeycroft Hill to the north and St Andrew’s Road running through the middle of the site from west to east. To the south is Hillingdon Golf Course and to the south-west and north-west is low-density defence personnel housing.

Figure 1: Aerial photograph of the existing parade ground and surrounding area, looking east with the route of the River Pinn running through the centre of the photo (Green Belt Land) and the Grade II listed Hillingdon house at top left (Source: Design and Access Statement)

9 The majority of the site is within walking distance of the seven bus routes along Hillingdon Road, whilst only the northern part of the site is considered to be within an acceptable walking distance to Uxbridge Underground / bus station. The public transport accessibility level (PTAL) varies between 2 and 5 across the site given its size and associated variations in the walking distances to services. The majority of the site has a rating of 2 and 3.

10 The plan overleaf shows the site layout, which has been dictated by Hillingdon’s adopted supplementary planning document for the site.

page 12

Figure 2: RAF Uxbridge Quarters (Source: RAF Uxbridge Supplementary Planning Document

Details of the proposal

11 Outline consent is sought for redevelopment of RAF Uxbridge site (with all matters reserved, except for access) for the following:

 1,303 dwellings of between two and six storeys;  77 one bed assisted living retirement apartments;  1,200 seat theatre with ancillary cafe;  13,860 sqm office development;  2,850 sqm retail development (use class A1, A2, A3, A4, A5);  Four storey 90 bed hotel (use class C1);

page 13  Two storey primary school (three form entry);  local centre to provide 150 sqm of retail (use class A1, A2) and 225 sqm GP surgery (use class D1)  associated car parking (2,156 spaces);improvements to pedestrian linkages to town centre; open space including a district park; landscaping and servicing.

12 Full permission is also being sought for change of use and alterations to various individual buildings on the site, including Lawrence House, the Sick Quarters, the barrack block, cinema, and Hillingdon House.

13 Associated listed building consent is also sought.

Case history

14 There is no relevant history of a strategic nature, although the applicant engaged in pre- application discussions with GLA officers in November 2009. Strategic planning issues and relevant policies and guidance

15 The relevant issues and corresponding policies are as follows:

 Green Belt/MOL London Plan; PPG2  Town centre uses London Plan; PPS4  Employment London Plan; PPS4; Industrial Capacity SPG  Housing London Plan; PPS3; Housing SPG; Providing for Children and Young People’s Play and Informal Recreation SPG, draft Housing Strategy; draft revised interim Housing SPG  Affordable housing London Plan; PPS3; Housing SPG, draft Housing Strategy; draft revised interim Housing SPG  Density London Plan; PPS3;  Playing fields London Plan; PPG17  Urban design London Plan; PPS1  Access London Plan; PPS1; Accessible London: achieving an inclusive environment SPG; Planning and Access for Disabled People: a good practice guide (ODPM)  Transport London Plan; the Mayor’s Transport Strategy; PPG13;  Parking London Plan; the Mayor’s Transport Strategy; PPG13  Sustainable development London Plan; PPS1, PPS Planning and Climate Change Supplement to PPS1; PPS3; PPG13; PPS22; the Mayor’s Energy Strategy; Sustainable Design and Construction SPG  Biodiversity London Plan; the Mayor’s Biodiversity Strategy; PPS9  River Thames/flooding London Plan; Mayor’s draft Water Strategy; PPS25, RPG3B

16 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 1998 Hillingdon Unitary Development Plan (Saved Policies) and the 2004 London Plan (Consolidated with Alterations since 2004).

17 The Hillingdon Core Strategy Preferred Options, the site supplementary planning document as well as the draft replacement London Plan are also relevant material considerations.

page 14 Principle of development on Green Belt

18 Part of the site to the west is designated as Green Belt in the Hillingdon Unitary Development Plan 1998. As such, the proposal must be considered against Planning Policy Guidance Note 2: Green Belts. Paragraph 3.2 of PPG2 states that “Very special circumstances to justify inappropriate development will not exist unless the harm by reason of inappropriateness, and any other harm, is clearly outweighed by other considerations”. Policy 3D.9 of the London Plan states that “There is general presumption against inappropriate development in the Green Belt, and such development should not be approved except in very special circumstances”. Draft replacement London Plan policy 7.16 reiterates this position. This approach is consistent with PPG2.

19 PPG2 establishes five purposes of including land in Green Belts:

 to check the unrestricted sprawl of large built-up areas;  to prevent neighbouring towns from 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.

20 There is a no loss of Green Belt land resulting from the encroachment of buildings and access routes. Additionally, several buildings presently located on Green Belt land will be demolished. The major issue to consider is whether the quantum and form of development will harm the setting and character of the Green Belt land. Given the mostly suburban and low-rise character of the proposal, this is unlikely, although the medium density proposals close to the extended town centre will have a greater impact.

21 The consideration of negative effects on the Green Belt land must be scaled with the proposed benefits. The proposal opens up the land to wider public access, creating new routes though the previously closed site to enable existing residents to access the land. New facilities, such as sport pitches and improvements to walking routes will be undertaken. The development will provide opportunities for the management of biodiversity and flood risk. This balance will provide greater opportunities for both new and existing residents with regards to both use and access to the Green Belt land, with minimal negative effects, and as such this aspect of the proposal is supported.

22 PPG2 states that the conversion of buildings on Green Belt land, such as Hillingdon House, is not inappropriate providing that they do not have a material detrimental impact on the character of the Green Belt. The conversion of the existing buildings will not have a major impact on character and their internal layout and landscaping is appropriate to the context. London Plan policies accord with PPG2 and as this development respects the setting and character of the Green Belt by reusing the existing listed building, the development is acceptable. Town centre uses

23 The mix of uses is appropriate in its support of a new neighbourhood, comprising both mixed-use development, in accordance with PPS1 principles of sustainable development, and new physical and social infrastructure. The provision of non-housing uses is considered within this section of the report; housing issues are considered in detail within the next section.

page 15 Retail

24 London Plan policy 3D.1 seeks to strengthen the role of London’s town centres and secure a sustainable pattern of retail provision by encouraging retail, leisure and other related uses in town centres and discouraging them outside town centres. London’s strategic town centre network is illustrated on map 3D.1 and in Annex 1. Policy 3D.2 states that the scale of retail, commercial and leisure development should be related to the size and role of a centre and its catchment, and that retail and other service provision should be managed in line with the sequential approach, seeking to reduce car dependency and traffic generation and to improve public transport access to promote more sustainable forms of development. These principles are reflected in draft replacement London Plan policy 4.7 Retail and town centre development. The CAZ policies set out in paragraph 36 of the policy are also relevant.

25 National planning policy guidance for retail, leisure, entertainment and other main town centre uses is provided by Planning Policy Statement 4 (PPS4) Planning for Sustainable Economic Growth. This was published in December 2009 and replaced PPG4 (1992), PPG5 (1992) and PPS6 (2005). The key change from PPS6 to PPS4 is the replacement of the need test with a wider ranging six-point impact test. The sequential test remains, as does the scale test, which has been incorporated into the new impact test alongside accessibility by a choice of means of transport. PPS4’s main objectives include promoting the vitality and viability of town and other centres as important places for communities, delivering more sustainable patterns of development, reducing the need to travel, especially by car, and responding to climate change.

26 When considering proposals for retail development, the London Plan is concerned with the likely impact of development on the vitality and viability of existing town centres, including the evening economy (para 3.273). Impacts traditionally consider trade diversion, but it is also essential to consider the health of nearby town centres and the likely effect of the new proposal on planned investments in those centres. The applicant has submitted a retail assessment that discusses the impact and other implications of the new floorspace.

27 The scheme proposes an extension to town centre, which is acceptable in strategic policy terms. There will also be local convenience retail uses elsewhere in the scheme. The scale of the increase in retail floorspace is relatively minor, with the floorspace proposed to cater to the needs of the local community and new employment floorspace, rather than act as a destination that will compete with the existing town centre shops. Therefore impact on existing facilities will be limited, while the occupiers of the site will gain local facilities that contribute to the sustainability of the new neighbourhood.

Hotel

28 London Plan policy 3D.7 recognises a need for 40,000 additional hotel bedrooms by 2026. In the draft replacement plan, the requirement is for 40,000 new hotel rooms of which at least 10% should be wheelchair accessible. Outside of Central London, the expectation is that hotels be located in town centres and other locations, such as Opportunity Areas, with good public transport access to Central London and national and international transport termini. This development would help to meet the demand – being located in a town centre and within a reasonable travel distance to Heathrow Airport – and help meet Mayoral objectives to diversify and increase tourism provision across the capital in accordance with the London Plan and draft replacement London Plan.

page 16 Offices

29 The applicant has used the 2009 Hillingdon Employment Land Study, which foresees a need for additional employment space capacity to be accommodated in areas such as Uxbridge, Hayes, Stockley Park and Heathrow. The applicant’s assessment concludes that the proposed floorspace will have no impact on other provision within the catchment area, and that the growth will contribute to the vitality of the town centre. The provision of employment uses in town centres are supported by the London Plan, and the level of provision appears to be justified by the expected demand.

Theatre

30 The principle of the theatre use is welcomed. Such uses contribute to the overall mix and health of town centres, and provide a useful role in supporting the night-time economy. They also support creative professions and can be useful providers of niche employment training, as well as acting as identifiable features of communities in design terms.

31 Nonetheless, officers have concerns regarding the size of the proposed theatre. The theatre is proposed to have a capacity for an audience of 1,200 for regular performances. By way of comparison, the capacity of other suburban regional London theatres are given within the following list:

 Churchill Theatre, Bromley: 785  Fairfield Halls, Croydon: 800 (Ashcroft Theatre, although the additional concert hall has a capacity of nearly 2,000)  Broadway Theatre, Catford: 800 (plus smaller 80 seat space)  New Wimbledon Theatre: 1,700  Theatre Royal, Stratford East: 460  Hackney Empire: 1,275

32 The size of the theatre is clearly regional, given that it compares with the Hackney Empire and is larger than theatres in town centres of similar importance as Uxbridge, such as Croydon and Bromley. At the same time it should be remembered that Uxbridge is designated as a metropolitan town centre within the London Plan and the draft replacement London Plan, and as such may be suitable for a venue of this scale. This is likely to be the ‘borough’ theatre for Hillingdon.

33 The applicant’s theatre assessment, submitted as part of the application, makes a suitable case for the provision of a theatre of this size. However officers seek further clarification on the cost of providing this theatre, with regard to any cross-subsidy that would affect the provision of other facilities or uses on the site. Specifically, officers require more information on the cost of the land to provide the theatre, whether this value is affected by the proposed capacity, and whether any changes in this figure would affect the provision of affordable housing throughout the site. Officers therefore require further information on the deliverability of the theatre. The issue is discussed further within the affordable housing commentary within this report.

School/Community uses

34 New community uses will include a two-form entry primary school, health facilities (a GP surgery with space for two practitioners, within the local centre in the site’s proposed ‘southern quarter’), and a community facility within the retained former cinema building facing the new town square. The provision of such facilities on a local scale is supported and will support the new population while not detrimentally affecting the vitality of the town centre.

page 17 Housing

35 The new-build housing component of the scheme comprises 1,348 dwellings. Additionally there will be 77 beds provided within the proposed assisted living facility. More than 50% of new homes will be provided in the town centre extension zone, with the areas with a more suburban character providing most of the remainder. Approximately 30 homes will be provided within the vicinity of Hillingdon House, with a small number in other retained buildings. There is no traditional existing housing on the site, although the accommodation formerly provided as part of the barracks is no longer required as a result of the redundancy of the former RAF use.

36 Homes will be a mix of one- to three-bedroom flats, and three-, four- and five-bedroom houses. The dwelling mix of the scheme is set out in the following table, which does not include the assisted living units:

Number of bedrooms Flats Houses % of total dwellings

One bedroom 245 - 18%

Two bedrooms 545 - 40%

Three bedroom 42 270 23% (3% flats, 20% houses)

Four bedroom - 228 17%

Five bedroom - 18 1%

Total 832 516 (1348 dwellings)

37 It can be calculated from the table that 41% of dwellings would be family-sized accommodation with three or more bedrooms per unit; whilst the majority of those remaining would be two-bedroom units rather than one-bedroom flats. The level of family accommodation provided would be 55% based on a habitable rooms calculation. The mix is acceptable from a strategic policy perspective.

Affordable housing

38 London Plan Policy 3A.10 requires borough councils to seek the maximum reasonable amount of affordable housing when negotiating on individual private residential and mix-use schemes. In doing so, each council should have regard to its own overall target for the amount of affordable housing provision. Policy 3A.9 states that such targets should be based on an assessment of regional and local housing need and a realistic assessment of supply, and should take account of the London Plan strategic target that 35% of housing should be social and 15% intermediate provision, and of the promotion of mixed and balanced communities. In addition, Policy 3A.10 encourages councils to have regard to the need to encourage rather than restrain residential development, and to the individual circumstances of the site. Targets should be applied flexibly, taking account of individual site costs, the availability of public subsidy and other scheme requirements.

39 Policy 3A.10 is supported by paragraph 3.52, which urges borough councils to take account of economic viability when estimating the appropriate amount of affordable provision. The ‘Three Dragons’ development control toolkit is recommended for this purpose. The ‘Three Dragons’ development control toolkit is recommended for this purpose. The results of a toolkit appraisal might need to be independently verified.

page 18 40 The Council’s UDP does not specify an affordable housing target and, in any event, the Secretary of State did not save policy H.11 on affordable housing in the September 2007 review. In such instances, where borough councils have not yet set overall targets as required by policy 3A.9, they are required to have regard to the overall London Plan targets.

41 Core Policy 28 of the Council’s Affordable Housing SPD (May 2006) follows the London Plan objective to negotiate the maximum reasonable provision of affordable housing on a site by site basis and will seek to ensure 50% affordable housing provision between 1997 and 2016, on the basis of 70% social rent housing and a minimum 30% intermediate housing (including various options for shared ownership) from all residential and mixed-use developments with an element of housing.

42 Hillingdon Council has a Local Area Agreement with the government to deliver 465 affordable housing units between 2008 and 2011, and has also agreed a target of 598 affordable homes with the Mayor over the same period.

43 The scheme proposes 25% of the units as affordable housing, of which 53% would be social rent and 47% intermediate tenure. This has yet to be independently verified, so as it currently stands, it is not possible to confirm compliance with the London Plan. The mix of affordable housing mix is defined in the following table.

Type of dwelling Total number Social rented Intermediate Affordable housing total

One bedroom flat 245 15 36 51 (20% of one-bedroom flats)

Two bedroom flat 545 48 70 118 (21% of two-bedroom flats)

Three bedroom flat 42 0 0 0

Three bedroom house 270 54 30 84 (31% of three-bedroom houses)

Four/five bed. house 246 62 22 84 (34% of four/five bed. houses)

Total 1348 179 158 337 (25% of housing provision)

44 The London Plan Housing SPG seeks to secure family accommodation within residential schemes, particularly within the social rented sector, and sets strategic guidance for councils in assessing their local needs. The mix of units across tenures is even; the applicant states that this has been developed in response to local need and the Council’s planning framework for the site. GLA officers will engage in discussions with the Council to confirm that this provision is appropriate to meet local need.

45 As advised at pre-application stage, there are a number of other potentially large section 106 requirements arising from the scheme (e.g. primary school provision, land for a new theatre and improvements to the pedestrian subway). It is essential that a reasonable and realistic approach is taken to balancing these objectives against the need to deliver the maximum reasonable amount of affordable housing and bearing in mind the priority given to the delivery of affordable housing set out in policy 6A.4 of the London Plan. It is also important to note that the development should not be expected to meet Hillingdon’s existing statutory duties, e.g. primary school places for existing nearby residents. The full costs of providing elements such as the theatre, improved subway etc, with different options if appropriate, need to be clearly understood so that an informed decision can be made about competing objectives. The requirements of each of these elements is also important to understand – for example the size and provision of the

page 19 theatre may have an effect on the level of affordable housing provision, but the link has not yet been made explicit. The toolkit appraisal should run different scenarios based upon various combinations to the s106 package.

46 Review mechanisms for delivery of the planning obligations will be required given the timeframe for delivery and the phased nature of this large scheme.

Density

47 London Plan Policy 3A.3 outlines the need for development proposals to achieve the highest possible intensity of use compatible with local context, the design principles of the compact city, and with public transport accessibility. Table 3A.2 of the London Plan provides guidelines on density in support of policy 3A.3. The corresponding figures are set out in Table 3.2 of the draft replacement London Plan.

48 The residential density of the scheme is 205 habitable rooms per hectare (or 61.5 units per hectare), which is close to the upper end of the range i.e. 150-200 hr/ha (40-65 u/ha) indicated in the London Plan density matrix for a development on a suburban site with a public transport accessibility level of less than 2 and an average dwelling size of 3.34 habitable rooms.

49 In these respects, the proposed density accords with London Plan policy 3A.3, which seeks to optimise the development potential of sites to an extent that is compatible with local context, public transport accessibility and the design principles set out in policy 4B.1. It is also in line with the expectation (600 to 800 dwellings) stated in the Council’s planning brief for the development of the site.

50 The applicant has indicated that the development will include over 1,200 residential units, with a table submitted indicating density (dwellings per hectare). In assessing the appropriateness of the proposed density, it is vital that the development accords with the design principles of the London Plan, that the residential units are of a high standard, that sufficient play provision and residential amenity space is provided, that there is sufficient community, health and education provision in the immediate area, and that the development is compatible with the local context and public transport accessibility.

51 Having reviewed the densities, it is noted that the number of units per hectare falls below PPS3 guidelines in some cases, and are generally low compared to the London Plan density matrix. Whilst this might be acceptable near the Green Belt, further justification is required for the chosen approach, particularly in the more urban town centre location. This is discussed further in the urban design section below.

Housing quality

52 London Plan policy 3A.6 and draft replacement policy 3.5 seek to secure housing of the highest quality. Draft replacement policy 3.5 sets down minimum space standards for new development, with Table 3.3 setting out essential internal areas.

53 The majority of new housing is covered by the outline application; therefore it is not possible to undertake a detailed assessment of internal layout and other indicators of quality. However the applicant has developed a series of design codes to outline the future development of various types of housing, which will regulate factors such as plot layout, overall housing footprints and similar factors. The codes are discussed within the urban design section of this report. However, factors that can be assessed at this stage – such as the outline building parameters, indicative street layout and housing orientation, coupled with other factors such as proximity to

page 20 green space – suggest that the quality of the residential environment will be satisfactory, provided that the detailed phases remain aligned to the outline principles.

54 The provision of new homes within the full planning application component – those within retained converted buildings and around Hillingdon House – will be undertaken to a decent quality and officers are satisfied that these will provide a pleasant living environment for future occupants.

Children’s play space

55 Policy 3D.13 of the London Plan sets out that “the Mayor will and the boroughs should ensure developments that include housing make provision for play and informal recreation, based on the expected child population generated by the scheme and an assessment of future needs.” The guidance sets a benchmark of 10 sq.m. of useable child playspace to be provided per child, with under-5 child playspace to be provided on-site as a minimum. The corresponding policy in the draft replacement is policy 3.6, which cross-references to the Mayor’s Supplementary Planning Guidance (SPG) ‘Providing for Children and Young People’s Play and Informal Recreation’.

56 Using the quantitative method outlined in the SPG, the development could be expected to accommodate 1040 children. This would result in a need for slightly more than one hectare dedicated to play space. There would be a range of equipped and other play spaces provided in close proximity to homes throughout the site; nonetheless provision would be only around three- quarters of the requirement. However this is offset by the availability of other open land, such as the improved green belt district park in the centre of the site, the out-of-hours availability of the school play area, the provision of back gardens to houses, and other managed community facilities to be provided as part of the development. As such it is considered that the level of play space to be provided is acceptable. Playing fields

57 There will be a loss of existing pitches used by RAF personnel, or other sections of the community (for whom access to the pitches is restricted unless they gain express approval). Generally though, these areas are not currently available to the general public. The on-site military population is to relocate to RAF Northolt, where a replacement provision equivalent facilities will be made available to meet their recreational needs. The proposal will allow for the provision of 0.8ha of new sports pitches that, although managed, will be available to the general public.

58 Policy 3.20 of the draft replacement London Plan states that proposals that result in a net loss of sports and recreation fields, including playing fields, should be resisted. The area of the existing RAF pitches have not been provided, although using measurements taken from the submitted plans there appears to be a slight loss in the level of provision. The new sports areas and the out-of-hours availability of the school recreational areas provide an increase in the availability of facilities to the public, and alternative facilities will be required where needed for serving personnel. Officers support the provision of new these new facilities and consider that these will be appropriate to serve the community. Urban design

59 Good design is central to all objectives of the London Plan and is specifically promoted by the policies contained within Chapter 4B which address both general design principles and specific design issues. London Plan Policy 4B.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, views, and the Blue Ribbon

page 21 Network. The draft replacement London Plan reinforces these principles, with new development required to have regard to its context, and reinforce or enhance the character, legibility and permeability of the neighbourhood (policy 7.1).

60 The principles of the scheme are sound and the design is generally of a high standard. Although this is an outline scheme, the applicant has prepared a set of design codes to be applied to the various character areas and types of development. Additionally the proposed scheme remains largely unchanged following officers’ comments offered within pre-application discussions, and many of the issues discussed continue to be relevant. Although officers mostly support the design aspects of the scheme, these issues would improve the quality of the spaces and experiences for residents and other users, and are examined within the following sections.

General layout and principles

61 The masterplan is informed by two main factors: the integration of the Green Belt within the urban fabric, and the transition between the different types of existing development, and the Green Belt. This approach is supported and the masterplan and supporting design codes demonstrate this in several ways: with a well-considered height and massing strategy, incorporating views of green space as being central to the basic layout, and ensuring that Green Belt land is retained and improved, with the potential for its extension into the new urban area. Additionally, the retention of existing historic building and landscape features, and their improvement through sensitively designed additions and new uses, are welcomed.

62 The mix of uses is supported, as are the extension of the town centre and the creation of a smaller, secondary centre to support local needs. The proposal would provide areas of medium- to high-density residential development around the proposed town centre extension, and areas of medium- and low-density residential provision to the south, all within higher ground away from the flooding corridor in the centre of the site. Several of these individual blocks have densities that are lower than PPS3 density guidelines, although this is not the case when taken across the character areas and it is understood that the local context is one of predominantly low-density residential development. At the pre-application meeting, officers believed that some areas of the site have the capacity for a greater density of dwellings, given the edge-of-town centre location of the development, and could be applied in areas such as south of the town centre extension. The additional information provided within the design codes provide a well-reasoned justification to these comments and partially alleviate officers’ concerns.

63 The road hierarchy is appropriate, and entrances are clearly marked through differentiation in building heights. Further information has been provided to alleviate officers’ concerns on the layout of some streets, and differentiation of similar streets within the same character areas, which will have public art and varied landscaping. In a development of this size it is difficult to avoid north-facing units, but the design codes prescribe features to maximise light, such as height variations and use of additional glazing on north-facing facades.

64 The settings of the listed buildings are well thought-out and in the case of Hillingdon House, uses the gradients and existing structures to cleverly create new development that does not detract from the original. Likewise, the retention of significant trees is appreciated and will help the development to have a defined character from the outset.

65 The use of design codes is welcomed. These are fairly thorough but will allow some flexibility to developers of individual phases in terms of building interpretation within the set parameters. Officers encourage Hillingdon Council to ensure the design codes form part of the approved documents, should the application be approved, or set within the section 106 agreement.

page 22 66 It is disappointing that the phasing plan proposes the development of most of the town centre extension as the final stage of the development, and although there will be some buildings, such as the theatre, proposed to be delivered earlier, officers will need to be assured that residents of the southern parts of the site will be encouraged to walk or cycle to Uxbridge town centre along attractive and usable links during the construction of the northern parts, and will not develop less sustainable patterns involving car use that will become entrenched over time.

Edges

67 The provision of an effective route across St Andrew’s roundabout to the town centre will be absolutely central to the function and success of the new town centre square. Without an effective and simple crossing that follows the line of site from the existing town centre as closely as possible, pedestrians within the high street will be discouraged from ‘crossing the bridge’ of the roundabout to explore the new area. When the proposed theatre is established along with the surrounding retail uses, an activity node is likely to form in this area, and it would be far more desirable to have this as a functional ‘endcap’ to the town centre rather than acting independently.

68 The access into the green belt is welcomed, although a direct ‘green’ route from the town centre square would help link the desire to bring the green belt into the urban area. The building ’teeth’ in this area are also welcomed, and contrast with the more formal but lower density edge arrangement to the south.

69 Beyond the town centre, block 2.1 will have a density that would result in a jarring change compared with the town centre extension, and is a departure from the densities normally expected within town centres with good accessibility and access to facilities. The GLA would normally consider the potential for such areas to have a higher density if the design demands, thereby making the most effective use of the land. The same could also be said for block 2.2, which will be low-rise in nature (presumably to aid the ‘parade ground’ character of this area). It was mentioned at the pre-application meeting that a theme of the masterplan is ‘transition’, but this marked change in density in such a location does not seem an appropriate transition between the town centre and the lower density residential development to the south. Further work or justification should be produced.

70 A point was raised at the pre-application meeting regarding the location of the care home. It was mentioned that there could be a future development of the land to the north, in the area around Jackson Road. The care home would be on a large block with an open, green space (presumably private) edge. The siting and layout of this facility should not preclude future permeability between the town centre and new square and the site to the north; nor should it give rise to conflict between potentially noise-generating town centre uses and the facility.

71 Elsewhere around the site boundaries, the transition between the existing homes and the new layout is acceptable and will help to knit the old and new. The higher density forms facing Hillingdon Road are welcomed and these blocks have the opportunity to act as lead-in for the town centre, which should be reflected in the quality of the buildings in this location.

Within the scheme

72 The scheme’s design presents natural divisions into character areas. The design codes are prescriptive in their coding to ensure sufficient parameters that set the character of each area, and also cover the streets and the ways in which these can be differentiated to aid legibility.

73 The block structure has clear delineations between private and public places. The design codes offer clear guidance on dwelling types but are less prescriptive on coverage ratios. Although the proposed houses will have back gardens, some of the low-density housing blocks will be

page 23 shallow. The applicant is encouraged to offer a minimum back garden size or depth within the code to ensure that a sufficient level of private open space will be available to occupants of the houses.

74 Parking layouts appear to be appropriate. Courtyards, where used in the southern portion of the site, will be gated and overlooked from the homes served. Parking within shared surface areas will be delineated by landscaping. Hillingdon Council is asked to consider the width of integrated garages during the detailed design phases, to ensure that residents are encouraged to use them rather than park on the street.

75 The green strategy throughout the site is supported, as are the various opportunities for smaller green spaces and ‘green views’ along streets and corridors. The proposed local square has a large scale, although the additional information supplied within the application provides examples of squares with similar dimensions and enclosure, suggesting that the space will be appropriately sized. The existing roundabout leading to Uxbridge town centre will be renewed to remove high walls and provide new landscaping, and at-grade crossings added. The provision of a sustainable urban drainage scheme (SUDS) is appreciated, and will help to address the site’s drainage issues. The design of the SUDS swale channels is such that they are an integrated and attractive part of the urban landscape.

76 The Mayor’s draft Housing Design Guide provides the design principles which he will expect new development to have regard to, and includes advice on factors such as north-facing plots, room sizes and provision of private gardens. The GLA wishes to ensure that the principles of the Guide are imbued within the scheme. As the majority of the scheme is an outline application, Hillingdon Council is urged to adopt the principles of the guide within the reserved matters development stages. Inclusive design

77 London Plan Policy 3A.5 (draft replacement London Plan policy 3.8) states that all new housing should be built to Lifetime Homes standards and that 10% should be wheelchair accessible, or easily adaptable for residents who are wheelchair users. The applicant has indicated that these standards will be achieved, but will be required to demonstrate on plan accordance with this policy requirement at the detailed planning stage.

78 Inclusive design principles have been incorporated into the landscape and public realm. Gradients have been planned to eliminate steep streets and the design codes provide materials guidelines, which will be important for inclusivity in crossing points and shared surface streets. The location of disabled parking bays throughout the scheme should be provided in accordance with the comments in the following section.

79 Hillingdon Council is encouraged to work closely with the GLA’s access officer and the local access forum to ensure that inclusive design principles continue to be incorporated into all aspects of the scheme at the detailed approval stage. Transport for London’s comments

80 Existing walking routes suffer from the barrier of Hillingdon Road and Park Road, in particular at the St Andrew’s roundabout where a sub-standard and unattractive subway is the only facility for pedestrians to cross for access into the town centre, which provides access to the Underground and bus station.

page 24 81 The application is supported by a transport assessment (TA) produced by Halcrow. A formal Transport for London (TfL) pre-application meeting was held on 1 December 2009 with a follow up letter of advice sent to the applicant on 15 December. The pre-application meeting was attended by highways and planning officers from the Council.

82 The total number of residential units will need to be fixed. Paragraph 5.2.1 of the TA states that the proposal is for 1265 units but Table 5.1 states 1425 units. Paragraph 5.2.3 states that the assessment includes additional land, with a total residential development of 1736 units. In addition consented (and planned) developments in the vicinity of the site should be considered in the cumulative impact assessment.

83 The proposal to introduce town centre uses in the north-western part of the site with residential uses focussed primarily along the western part of the site is considered to be suitable in transport planning terms, given the location of the Underground station to the northwest of the site and the bus corridor along Hillingdon Road. However, the approach to town centre uses should apply a restrained car parking strategy given the proximity to public transport.

Pedestrian links

84 The pedestrian links between the site and Uxbridge station via the High Street are important to the success of the development, particularly given the aspiration to extend the town centre into the site.

85 The High Street offers the most direct and attractive pedestrian link from the Underground / bus station and town centre facilities. The pedestrian route via the High Street through St Andrew’s roundabout is key to the success of the site. At present, Hillingdon Road and the existing subways under the roundabout represent a significant barrier. TfL generally supports as a policy objective removal of subways and the introduction of surface crossings but this has to be considered against achievement of multimodal objectives.

86 The provision of at-grade pedestrian crossings on the Hillingdon Road south and west arms of the St Andrew’s roundabout are welcomed. The improvements to the subways are also welcomed but further information should be provided to illustrate how the subway will look and function including drawings and images. The safety of all users will be essential to any decision to keep the subway open and compliance with accessibility guidance together with details of lighting is essential.

87 The secondary walking route to the town centre and Underground via Chippendale Waye and alongside the railway lines is not considered to be a desirable route. Discussions between the Borough and TfL will be important to determine the best way forward for achieving good quality pedestrian links across the site as a whole.

88 A site wide PERS assessment should be undertaken to assess the general routes to the local bus stops and to the town centre and Underground / bus station and to other nearby destinations such as Brunel University. Any deficiencies such as lack of signage, dropped kerbs, tactile paving or appropriate pedestrian crossing facilities at junctions should be highlighted so that an appropriate contribution can be agreed with TfL and the council to address the deficiencies that are identified.

89 Shared surfaces within the development site are accepted in principle for the secondary road network, however, there must be appropriate information such as tactile delineation for vulnerable users. The tertiary streets within the site will need 2m wide footways on both sides.

page 25 90 A scheme of pedestrian signage and wayfinding both within the site and on external routes to bus stops, the town centre and station and Brunel University will need to be developed in consultation with TfL using the principles of the Legible London system.

page 26 Highways impact

91 The traffic modelling to assess the effect of the proposed development has been assessed through use of VISSIM, which is accepted in principle as the appropriate tool, with the use of LINSIG, ARCADY and PICADY for validation.

92 A technical audit has been undertaken through the use of the DTO’s VMAP process and a number of technical points require explanation and justification prior to agreement of the modelling approach. The applicant has considered the weekday morning and evening peak hours. Given the sensitive town centre location and the size of the site, the applicant must consider the weekday inter peak and Saturday peak periods.

93 Background traffic growth will need to be added for the future year assessment scenario to ensure that the effect of cumulative impacts of other developments is assessed. The use of the SATURN model is accepted in principle for the basis of the distribution of traffic on the highway network. All of the site access junction designs will need to be considered and agreed in detail with the Borough Highways Officer in consultation with TfL.

94 Each junction has been considered in turn by TfL and detailed comments have been supplied to the council. In summary there is a considerable amount of further work required to address the following: Northern site access / Chimes roundabout; St Andrews roundabout; Main site access junction; and Southern site access / Greenway Junction. It is not appropriate to go into detail in this report. However, the concerns relate to operation of buses and ease of movement for pedestrians. In some case there will be modal conflicts which must be resolved in order to help meet the objective of smoothing traffic flow and equal allocation of road space. All junctions will be subject to Stage 1 Safety Audits. Further work is required before TfL can support the proposed highway work.

95 TfL will require financial contributions through the s106 agreement to fund any necessary alterations to the bus network or additional running costs. In addition land within the development will also be required to meet operational requirements. These sums are still to be negotiated with the applicant.

Car parking

96 The level of car parking proposed is one space per unit for flats and 1.5 spaces per unit for houses. Whilst this is in general conformity with the London Plan maximum standards it does not meet the aims to reduce car parking and demonstrate restraint in accessible of town centre/ edge of centre locations. TfL advises the applicant to reduce parking to less than the 2001 census data for the local ward. On this basis, it is considered that parking should be provided at 0.5 spaces per unit for flats and 1 space per house. The restraint based parking regime should be in tandem with travel planning measures including a car club, to be secured through the s106 agreement.

97 For a scheme of this size and nature, a number of car club bays should be reserved in three or more locations across the site. The travel plan should incorporate an arrangement with the car club operator with annual membership paid for upon first occupation of any units without an assigned car parking space or with a single assigned space. This should be secured, monitored and funded through the s106 agreement.

98 Disabled parking, to fully accessible specifications, for the residential component of the development is required at a ratio of 10% of spaces. These should be provided in convenient locations to provide ease of access.

page 27 99 To ensure that the parking is controlled and enforced, a controlled parking zone should be considered by Hillingdon Council. A car parking management plan linked with the operation of the travel plan should also be prepared. These measures should be secured by planning condition or obligation in the s106.

100 The proposals suggest a shared parking approach for the commercial uses; this is accepted in principle. The TA states that a multi storey car park of 361 spaces will serve the commercial uses but also states that additional parking is provided across the site in Table 5.3, with a total non- residential parking provision of 504 spaces. TfL does not support the proposal to provide a multi storey car park in the location. Clarification is also sought on what parking is attributable to which land uses and relevant drawings provided to illustrate this.

101 In policy terms, the car parking provision will need to be in accordance with the London Plan standards and the Borough’s standards for uses not within the London Plan. The level of parking provided should be restrained given the aspirations for extending the town centre into the site. The proposed 504 spaces including a multi storey car park of 361 spaces is not considered to be justified and is not in accordance with the Adopted London Plan Policies 3C.23 Parking strategy and 3C.24 Parking in town centre or the draft revised London Plan Policy 6.13 Parking, in that it provides an over-provision of parking.

102 The applicant has calculated the peak predicted demand for the land uses and subtracted 20% to take account of linkages between the land uses. TfL requests that the level of parking is calculated based upon a more restrained approach with a full consideration of how the parking demand will vary throughout the day for the different land uses so that a more appropriate level of parking can be agreed to ensure compliance with London Plan Policies. The reduced parking provision should be linked with the proposals in the travel plan. Parking charges will also need to be in place to manage car parking use.

103 Disabled parking at a ratio of 5% of spaces will be required in safe and convenient locations to provide ease of access between the parking area and the building entrances in accordance with DDA requirements.

104 Electric charging points are required for 20% of the car parking spaces in line with the Mayor’s Guidance, London Plan Consultation Draft Replacement (October 2009) and the Mayor’s guidance on electric vehicles.

105 Coach parking should be provided for at one space per 50 rooms of the hotel, it is recognised that a shared coach parking facility to serve the commercial uses in the town centre extension would be suitable.

106 A taxi rank must be provided at a suitable location to serve the needs of the hotel and other commercial uses.

Cycle parking

107 A full breakdown of the cycle parking should be provided as part of the TA and should be in line with TfL’s cycle parking standards as set out in the draft replacement London Plan. For the residential units, this equates to one space per flat and one two bedroom houses, and two spaces for any homes with three or more bedrooms. The B1 office use requires one space per 250sq.m of floor space, which equates to 54 spaces. Provision for the leisure use and health centre will need to be established as they are based on the number of staff and expected visitors. The requirement for retail is either 1/350sq.m. for food retail or 1/500sq.m. for non-food retail.

page 28 108 All cycle parking should be secure, sheltered, easily accessible and covered by CCTV as an additional security measure. Showering and changing facilities should also be provided for employees cycling to the site. Cycle parking to be provided for visitors to the residential element of the development and recommend that this be in the range of 1 space per 10 units.

Cycle routes

109 An analysis of the existing cycle routes and facilities in the vicinity of the site should be included within the transport assessment with any deficiencies identified and a commitment to make improvements as necessary. For example, a route east –west should be defined from the main site access over the River Pinn to Vine Lane and north-south cycle facilities along the main spine route through the site.

110 TfL would expect that measures such as offering a bicycle voucher to residents including purchase and repair as part of Travel Plan to assist mode shift away from car use.

Trip generation and distribution

111 The calculation of residential trip rates using first principles is an acceptable way forward, however the calculations and assumptions are still unclear and a check should be carried out using TRAVL/TRICS. The sites selected from TRAVL for commercial trip rates should meet the requirements of the TA best practice guidance of not being more than 5 years old and use of any older sites should be justified.

112 With reference to the residential retail and leisure trip internalisation, clarification of the 50% of internalised trips set out in 6.5.12 will need to be provided. In addition clarification is required for the assumptions set out in section 6.5.16 in relation to the assumption on the retail trips. The document “Trip Attraction Rates of Development with Multiple Retail and Leisure Trips (JMP 2005) needs to be provided for review by TfL.

Travel plan

113 The framework travel plan has failed its ATTrBuTE evaluation and a number of key changes need to be made before it is considered acceptable. Primarily, the respective roles of the framework travel plan versus the full travel plans need to clarified. The role of a framework travel plan is to set out how sustainable travel will be supported on a site with multiple land uses and/or occupiers, including site-wide management, marketing, measures and monitoring. Within this, the individual occupiers develop full travel plans as they become known, outlining their individual commitment to the site-wide framework travel plan and detailing what specific measures they will implement within their organisation. The framework travel plan should set out guidelines for how full travel plans will be developed amongst occupiers, including setting thresholds for the sizes of organisations that would be responsible for developing these travel plans with contingencies set for organisations that fall below the threshold.

114 This framework travel plan should clearly commit to objectives for the site, around which the site-wide targets and measures should be based. The framework travel plan must include details of a site-wide marketing plan, detailing what will be done and not just what will be considered. The travel plan must commit to the introduction of site-wide ‘soft’ measures as well as infrastructure measures, as was detailed in the pre-application advice. These should include walking, cycling and public transport use as well as reducing the need to travel. While the introduction of a car club was mentioned for consideration, a firmer commitment should be outlined, as was detailed in the pre-application advice. For such a site, the package of measures must be robust, relating directly to the travel plan objectives and targets.

page 29 115 For a large, mixed-use development with a long build-out period, the phasing needs to be taken into account throughout the development of the framework travel plan, especially within the setting of targets and within the monitoring programme. While the individual occupiers will need to commit to standard five-year monitoring programmes, a longer monitoring programme must be implemented for the site-wide monitoring to take into account the build-out period. The proposed targets should also clearly state how and when the baseline will be measured in terms of this phasing, with several interim targets set throughout the build-out period.

116 Further work on the travel plan is required in respect of measures, monitoring, targets and implementation to ensure general compliance with London Plan Policies 3C.1, 3C.2 and 3C.3.

Additional documents

117 A delivery and servicing plan and construction logistics plan should be referred to in the transport assessment, and secured by planning condition or through the S106 agreement. These documents should be prepared in line with TfL guidance.

Impact mitigation and planning obligations

118 The development will result in a significant increase in trips by public transport and an increase in walking and cycling, which will require mitigation in the form of additional infrastructure and financial contributions.

119 TfL will be seeking appropriate mitigation to cover the costs of improvements to the local transport network, in particular buses, which will include not only an accurate assessment of trips created by the development but also the cumulative impact of other schemes in the area. Further contributions and compensation may also be required where the development proposes amendments to the existing public transport network.

120 For bus infrastructure the developer will make financial contributions at the appropriate time, usually upon occupation of the 1st unit and in consultation with TfL either through an agreed sponsored route agreement or paid directly to TfL.

121 Where appropriate the developer will need to enter into an agreement with TfL under Section 278 of the Highways Act 1980 (as amended by Section 23 of the New Roads and Street Works Act 1991). All design and construction costs associated with impact mitigation off-site will be borne by the developer.

Compliance with the London Plan

122 There are several elements of the development proposals and assessment that require alteration or additional work before the application can be considered acceptable. The additional work will ensure general compliance with the following London Plan policies; 3C.2 Matching development to transport capacity, 3C.20 Improving conditions for buses, 3C.22 Improving conditions for cycling, 3C.21 Improving conditions for walking, 3C.23 Parking Strategy, 3C.25 Freight strategy and draft revised London Plan policy 6.3 Assessing transport capacity, 6.7 Buses, bus transits, trams, 6.9 Cycling, 6.10 Walking, 6.13 Parking, 6.14 Freight. Subject to the above being satisfactorily addressed TfL would be happy to support the development in transport terms. Climate change

123 The London Plan climate change policies as set out in chapter 4A collectively require developments to make the fullest contribution to tackling climate change by minimising carbon dioxide emissions, adopting sustainable design and construction measures, prioritising

page 30 decentralised energy supply, and incorporating renewable energy technologies with a target of 20% carbon reductions from on-site renewable energy. The policies set out ways in which developers must address mitigation of, and adaptation to, the effects of climate change.

124 The corresponding policies in the draft replacement London Plan are set out in Chapter 5. These policies follow the same general approach with respect to the energy hierarchy and places greater emphasis on minimising carbon dioxide emissions and making use of decentralised energy systems and networks.

Mitigation

125 Policies 4A.2 to 4A.8 of the London Plan focus specifically on how to mitigate climate change, and the carbon dioxide emissions reduction targets that are necessary across London to achieve this. Developments are required to make the fullest contribution to tackling climate change by minimising carbon dioxide emissions (be lean), adopting sustainable design and construction measures and prioritising decentralised energy (be clean), including renewables (be green).

126 The applicant has broadly followed the energy hierarchy in Policy 4A.1. Sufficient information has been provided to understand the proposals as a whole and to verify carbon dioxide savings in principle. Further information is required to fully assess the application.

Baseline carbon emissions

127 Baseline emissions have been calculated using benchmarks and all energy usages have been considered and estimated to be 21,260 Tonnes CO2 per year for a building regulations 2006 part L compliant development. However, the benchmarks do not directly relate to building regulations 2006 part L compliant development. Hence the applicant should use approved modelling, due to the lack of details considering this being an outline planning application representative modelling results for similar developments should be used, unless justification could be provided why this is not possible.

Energy efficient standards

128 Energy efficiency and conservation measures are applied beyond that normally incorporated into a 2006 Building Regulations compliant design. This incorporates measures such as passive designs, enhanced thermal performance of the building fabric such as U-values, energy efficient lighting with occupancy control, ‘A-rated’ electrical equipment etc. These measures would reduce the baseline emissions by 31%. Although it is not clear how these actually relate to building regulations 2006 part L, it is clear that the measures proposed would in fact provide good performance of the new development. This is acceptable.

District heating

129 The mixed-use urban zone offices, retail and residential apartments as well as community buildings, assisted living apartments and hotel will use a district heating system to deliver space heating and domestic hot water to all buildings within the zone from the energy centre. There is also a district heating system loop serving the code level 6 houses and the adjacent apartment block with bio-mass-fuelled low water for space heating and domestic hot water purposes.

130 For the apartment zone to the east, no network is proposed. The applicant should investigate further how these apartment blocks could be added on the network. To this end an indicative network should be shown showing the additional length of pipework required to connect

page 31 these blocks. The applicant should confirm that systems springing from the same energy centre could be linked in the future.

131 It is acknowledged that connecting the proposed houses to a network does not present itself as a viable alternative. Nonetheless applicant is encouraged to estimate the heat losses associated with the proposed biomass system for the code level 6 homes, as these may be higher than anticipated and affect the carbon intensity of the heat delivered.

132 The detailed planning strategies for the refurbishment works are acceptable.

Combined Heat and Power, Cooling

133 The proposal includes application of combined heat and power with the capacity of 1.8 MW electrical output with the possible addition of cooling linked through absorption chillers, to deliver further energy efficiencies from a natural gas supply. This approach is appropriate only when there is sufficient base load throughout the year and will be supplied via a thermal buffer store. These measures would reduce the baseline emissions by 8%.

Cooling

134 Main measures to minimise the need for active cooling systems include:

 Increased use of daylight through larger windows, rooflights, atria and light tubes.

 Natural ventilation using operable windows where acoustic characteristics allow.

 Orientation of buildings and glazed elevations to gain solar input while avoiding overheating. 50% cooling demand for offices is expected as a result of adopting these passive measures.

135 For buildings requiring cooling input (in the mixed use urban zone), each will house an absorption chiller linked to the district heating system and will run a cooling network internal to each building

Renewable energy

136 The applicant estimates that renewables will approximately contribute to a 15% carbon reduction comprised of:

 Solar thermal water heating sufficient for 50% of hot water demand.

 8,000sq.m. of PV array area with an assumed array of 13%.

 Biomass boiler – 500kW woodchip boiler within the energy centre serving 29 Code level 6 houses and adjacent apartment block.

 Ground source heat pump – installed for the school and Hillingdon House. Curtilage areas to make use of open space for slinky arrays. A single 20kW Gazelle wind turbine.

137 To support the photovoltaic panel proposal the applicant should provide roof plans to show that enough roof space is available.

138 The applicant should be aware, that the proposed scheme is within an Air Quality Management Area. Therefore, effects on local air quality related to the biomass boiler proposals

page 32 should be considered. If air quality prevents the installation of a biomass boiler, alternative renewable electricity generating technologies are likely to have to be adopted to contribute to the renewable target.

139 Where the use of biomass is proposed, the biomass boiler must be certified as an exempt appliance in accordance with the Clear Act 1993. A list of exempt appliances can be found at: http://www.uksmokecontrolareas.co.uk/appliances.php. Efforts should be made to ensure the biomass boiler be one of the lowest emitting models available on the Government’s Exempt Appliance list at the time of installation. The following information should also be provided:

 The make, model and thermal capacity of the biomass boiler and details of the additional abatement technology that has been investigated for fitment to reduce air pollution emissions. What reductions in emissions will this produce?

 The type, height and location of the chimney

 A breakdown of emissions factors for NOX, particulates and any other harmful from the biomass boiler.

 An assessment of the impact of the emissions to ground level concentrations and any additional impact to surrounding buildings/structures. It would be most helpful if the results of dispersion modelling were presented on a map

Adaptation

140 The London Plan promotes five principles in Policy 4A.9 to promote and support the most effective adaptation to climate change. These are to minimise overheating and contribute to heat island effects; minimise solar gain in summer; contribute to flood risk reduction, including applying sustainable drainage; minimising water use; and protect and enhance green infrastructure (the corresponding draft replacement London Plan policy is policy 5.3). There are specific policies covering overheating, living roofs and water. Further guidance on these policies is given in the Mayor’s SPG Sustainable Design and Construction. The applicant has submitted an assessment of the scheme against the essential and preferred standards within London Plan Policy 4A.3 and the Sustainable Design and Construction SPG.

141 Policy 4A.14 of the London Plan and Policy 5.13 of the draft replacement seek to ensure that surface water run-off is managed as close to its source as possible and sets out a hierarchy of preferred measures to achieve this. Policy 4A.16 of the London Plan and Policy 5.15 of the Draft Replacement seek to ensure that new development has proper regard to the impacts on water demand and existing capacity by minimising the use of treated water and maximising rainwater harvesting.

142 Policy 4A.11 seeks major developments to incorporate living roofs and walls where feasible (corresponding policy 5.11 within the draft replacement London Plan). The design code proposed the extensive use of green and brown roofs to be provided at the detailed design stage, and officers would welcome their inclusion.

143 The sustainable urban drainage system (SUDS) to be installed throughout the site, is welcomed. Other measures such as permeable paving, water butts and rainwater harvesting are also supported.

144 All homes in the site are intended achieve a code for sustainable homes level of 4, and a small number of homes would achieve level 6. All other buildings are intended to have a BREEAM

page 33 rating of ‘excellent’. These initiatives are strongly supported by officers and exceed the baseline guidelines provided within the London Plan. Biodiversity

145 Although there will be some disruption and loss of habitat as a result of construction and urban development, this will be mitigated with the creation of habitat areas within the proposed district park. Following construction the area of grassland available to species will have increased on the present provision. Additionally, trees will be felled on the site, but the urban structure has been designed to retain as many existing trees as possible, and new native species will be planted throughout the site. Retained trees will be protected from construction disturbance. These aspects of the proposal, along with the additional management of public areas, are considered by officers to have a long-term benefit to local biodiversity, and are in compliance with the London Plan.

146 The works will result in the loss of three existing bat (protected species) roosts. New habitats will be created within retained buildings, with appropriate timing of works, and it is noted that both the loss of the existing roosting areas and creation of new roosts will be subject to further approval by the Council and statutory authorities. Lighting within the development should take account of these locations. Other mitigation measures, such as exclusion zones, will be put in place to protect and improve the habitats of badgers, birds and stag beetles, all of which are present on within the existing Green Belt areas. Flood risk / Blue Ribbon Network

147 The River Pinn runs through the centre of the site and is identified in the UDP as being liable to flood. Site construction works may cause adverse impacts upon local water quality, but the Environmental Statement recommends that the applicant provide a construction environmental management plan to demonstrate how best environmental practice will be implemented and how adverse impacts to the surrounding environment and local community will be minimised.

148 The development proposals incorporate measures to minimise flood risk. These include the use of sustainable urban drainage systems and collection areas, and rainwater harvesting, and minimising water use. Further comments will be provided by the Environment Agency as part of Hillingdon Council’s consultation on the application.

149 The proposal will increase access to the River Pinn; access is currently restricted as a result of the closed nature of the site. The improvement of footpaths and routes will provide permeability through the green spaces and along and across the river, and is considered to be in accordance with the London Plan. Local planning authority’s position

150 Hillingdon Council’s view of the application is not known. Legal considerations

151 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

page 34 unchanged, or direct the Council under Article 6 of the Order to refuse the application, or issue a direction under Article 7 of the Order that he is to act as the local planning authority for the purpose of determining the application and any connected 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

152 There are no financial considerations at this stage.

Conclusion

153 London Plan policies on Green Belt, mix of uses, urban design, inclusive design and access, climate change adaptation and transport and parking are relevant to this application. The application complies with some of these policies but not with others, for the following reasons:

 Principle of development on Green Belt: There will be no loss of green belt land, and access to the land will be improved through the creation of new routes and a district park.

 Mix of uses: There is an appropriate mix of uses that are logically located throughout the site. These will contribute to the continuing vitality of the town centre and also create a sustainable new residential-based neighbourhood.

 Housing: Assessment of affordable housing provision is presently limited, and will need to be examined in more depth. Although this is only an outline application, the overall standard of housing appears to be high, incorporating a reasonable mix allowing for a range of housing needs, including family accommodation across all tenures. Density levels across the site as a whole are appropriate, but low in certain locations. Although the level of allocated play space is below the recommended level, the provision of alternative spaces ensures that there will a good level and mix of provision across the site.

 Playing fields: The provision of new facilities with better access will mitigate the loss of the soon-to-be redundant existing, specialised facilities.

 Urban design: The quality of the scheme is high, and the use of design codes is welcomed. There are minor issues that could be improved to ensure the optimum quality of life for future residents and users.

 Inclusive design: The scheme is compliant with the London Plan.

 Transport: There are a number of elements of the development proposals and assessment that require alteration or additional work before the application can be considered acceptable and compliant with the London Plan and draft replacement London Plan. In particular, further highway assessment and agreement to the proposed junction layout and designs, appropriate mitigation towards enhanced bus capacity and infrastructure, further works with regard to pedestrian and cycle links, cycle parking and the travel plan. Importantly, officers will expect to see a reduction in the level of car parking proposed, including a car parking management plan and accumulation/demand assessment.

page 35  Climate change: The proposal is acceptable in principle but further information is required to assess compliance with the London Plan.

 Biodiversity: The proposal will result in short-term detrimental conditions, but there will be an improvement in local conditions over the long term. There will be a loss of bat (protected species) routes, but these will be replaced by new habitats, with plans subject to further approval by statutory authorities.

 Flood risk / Blue Ribbon Network: The measures undertaken to minimise flood risk and improve access to the river are supported, although further comments will be provided by the Environment Agency.

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

155 The following changes might, however, remedy the above-mentioned deficiencies, and could possibly lead to the application becoming fully compliant with the London Plan and Draft Replacement London Plan:

 Mix of uses: The applicant is requested to provide more information on the cost of the land to provide the theatre, whether this value is affected by the proposed capacity, and whether any changes in this figure would affect the provision of affordable housing throughout the site.

 Housing: An assessment of the affordable housing viability to justify the proposed levels of affordable housing, to judge whether the proposal is in accordance with the London Plan, and if not, what measures would be required to ensure compliance. Further justification is required for the chosen density approach, particularly in the more urban town centre location.

 Urban design: The applicant should provide confirmation that the design codes would form part of the approved plans of section 106 agreement, should the application be recommended for approval. It should be demonstrated that residents would be encouraged to access Uxbridge town centre using attractive and convenient routes during construction of later phases, including the town centre extension. Officers request the addition of a minimum rear garden area or depth within the design codes, to ensure usable back garden space on shallower plots.

 Transport: Officers require confirmation of the total number of dwellings to gain an accurate view of the Transport Assessment. Further discussions and agreement on walking routes to the town centre are required, and a site-wide PERS assessment and cycle route analysis should be undertaken. Further work on junction design is required. Section 106 contribution levels for improved bus services will be negotiated. Further information is required regarding the number and location of car club, coach parking, electric charging, cycle and disabled parking bays, as well as the provision of a taxi rank, and a site wide parking strategy potentially incorporating a controlled parking zone should be considered. The provision of a multi-storey car park in the town centre extension is not supported, and negotiations would be welcomed. Further trip rate modelling is required, and revisions should be made to the draft travel plan in order to comply with the London Plan. Additional plans should also be provided regarding servicing and construction routes.

page 36  Climate change: Baseline carbon emission data should be remodelled using approved data/procedures. The wider use of district network heating should be investigated. Further minor details are required as described within the report.

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] Samantha Wells, Case Officer 020 7983 4266 email [email protected]

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