representation hearing report PDU/2310/04 25 March 2010 Southall Gas Works Site (West Southall)

in the London Boroughs of Ealing and Hillingdon

planning application nos. P/2008/3981-S and 54814/APP/2009/430 Hybrid outline and full planning application Town & Country Planning Act 1990 (as amended); Greater London Authority Acts 1999 and 2007; Town & Country Planning (Mayor of London) Order 2008 (“the Order”)

The proposal Outline application

Demolition of 22 houses; the remediation of the land and the redevelopment of the site to deliver a large mixed use development including residential, non-food retail, food retail, restaurants, bars and cafes, hotel, conference and banqueting, cinema, health care facilities, education facilities, office/studio units, sports pavilion, an energy centre, multi-storey car park and associated car and cycle parking, landscaping, public realm, open space and children’s play space.

Full application

New access roads from the Hayes bypass and Southall centre to the application site for vehicle, cycle and pedestrian access, including drainage and a flood relief pond. Widening of South Road across the railway line, widening of South Road over the railway line for the creation of a bus lane and three new accesses onto Beaconsfield Road. Two new footbridges to provide central pedestrian and cycle access to the Minet Country Park, bridging over the canal and Yeading Brook and to Minet Country Park and Springfield Road.

The applicant The applicant is National Grid Property Ltd. and the architect is MAKE Architects. Drawing numbers and documents Application plans P1000/00; P1001/00; P1002/00; P1003/00; P1004/00; P1005/00; P1006/00; P1007/00; P1008/01; P1009/00; P/1010/00; P1011/01; P1012/00;P1013/00; P1014/00; P1015/00; 800E Rev A; 800VV Rev A; 368_A_100-F; 368_A_200-B; 368_A_300; 368_A_305; 368_A_306; 368_A_310-B; 368_A_315-A; 368_A_316; 4597-P-003; 4597-P-001; 4597-P-002; 4597P-002; 4597P-003; EX_02_site plan; PO_02_site plan; PO_02_plan; PO_04_13A; PO_04_13B; PO_04_13C; PO_04_13D; 4597-P-010; 4597-P-011; 4597-P-12; 52212/B/31 RevA; 52212/B/33; 52212/B/34 RevA; 4597-P-020; 4597-P-020; 4597-P-021; 4597-P-022; 4597-P-023; 4597-P- 024;52212/A/51/A; 52212/B/33/A; 52212/B/35 RevB; 52212/B/36; 4597-P-030; 4597-P-031; 4597-P-032; 4597-P-033; 4597-P-034; 4597-P-035; 4597-P-036; 52212/B/48; 52212/A/49; 52212/A/50; 52212/B/51; 52212/B/50; 52212/B/49; South Road/Uxbridge Road improvement option drawings: SK-SR1; SK-SR2 and SK- SR3. 4597-RT-01 Existing tree removal/clearance, retention and protection.

Submitted documents Planning Application Forms Environmental Statement and Non Technical Summary prepared by RPS Design and Access Statement prepared by Make Architects and Capital Lovejoy Development Statement prepared by RPS Planning Statement prepared by RPS

page 1 Transport Statement prepared by Savill Bird and Axon Framework Travel Plan prepared by Savill Bird and Axon Sustainability Strategy prepared by Beyond Green Energy Strategy prepared by White Young Green Health Impact Statement prepared by Hunt Dobson Stringer Retail Assessment prepared by RPS Regeneration Strategy prepared by RPS General Management Strategy prepared by Savills Statement of Community Involvement prepared by RPS Recommendation summary

That the Mayor:

1. Acting as local planning authority, grants permission, in respect of application reference numbers P/2008/3981-S and 54814/APP/2009/430 for Ealing Council and Hillingdon Councils conditional outline and full planning permission for the reasons set out in the reasons for approval section below subject to the prior completion of a section 106 legal agreement.

2. Delegates authority to the Assistant Director for Planning to:

i) Issue the planning permissions.

ii) Agree the final detailed wording of the conditions.

iii) Add any additional informatives as required.

iv) Negotiate, sign and execute the section 106 legal agreement.

3. Delegates authority to the Assistant Director for Planning to refuse planning permission if by 24 September 2010 the legal agreement has not been completed.

4. Agrees that reserved matters applications be submitted to Ealing Council.

5. Agrees that both Ealing and Hillingdon Councils will be responsible for enforcing the conditions attached to the applications.

Reasons for approval

1 The Mayor, acting as the local planning authority, has considered the particular circumstance of this application against national, regional and local planning policy, relevant supplementary planning guidance and any material planning considerations. He has also had regard to both the Ealing and Hillingdon Development Control Committee reports, of 4 November 2009 and 10 December 2009 respectively, and both sets of draft reasons for refusal. He has found this application acceptable in planning policy terms for the following reasons:

• The application proposes an acceptable quantum and mix of uses on a strategic underutilised brownfield site located in the Southall Opportunity Area that forms part of the wider Heathrow Opportunity Area. This application will facilitate significant regeneration of an area of deprivation in West London. The scheme accords with London Plan policies 2A.5, 2A.9, 5F.1 and 5F.2 and draft replacement London Plan policies 2.6, 2.7 and 2.13. At the local level the scheme accords with policies 2.2, 8.2 and 10.1 of Ealing Council’s saved UDP (2004), and policy 2.8 of Ealing’s Development Strategy 2026 Initial Proposals (2009).

page 2 • The application proposes a significant quantum of much needed new housing that will help achieve Ealing Council’s annual housing targets and the Mayor’s Londonwide annual housing targets during the proposed 15-year development programme. The scheme accords with London Plan policies 3A.1, 3A.2 and 3A.3 and draft replacement London Plan policies 3.3 and 3.4. At the local level the scheme accords with policy 2.8 of Ealing’s Development Strategy 2026 Initial Proposals (2009). • The application proposes a significant quantum of much needed affordable housing that will help achieve Ealing Council’s annual affordable housing targets and the Mayor’s Londonwide annual affordable housing targets during the proposed 15-year development programme. The scheme accords with London Plan policies 3A.9 and 3A.10 and draft replacement London Plan policies 3.12 and 3.13. At the local level the scheme accords with policy 5.2 of Ealing Council’s saved UDP (2004), and policy 2.8 of Ealing’s Development Strategy 2026 Initial Proposals (2009). • The application will generate a significant number of job opportunities for Londoners, particularly for those living in areas of economic deprivation, during the development build programme and within the proposed business, commercial and leisure uses as a result of development. The scheme accords with London Plan policies 2A.5, 3B.1, 3B.2, 3B.3, 3B.11, 3A.10, 5F.1 and 5F.2 and draft replacement London Plan policies 2.6, 2.7, 2.13, 4.1, 4.2 and 4.3. At the local level the scheme accords with policies 6.1 and 6.2 of Ealing Council’s saved UDP (2004), and policy 2.8 of Ealing’s Development Strategy 2026 Initial Proposals (2009). • The proposal includes an extension Southall town centre, which is identified as a Major centre in need of significant regeneration. The extension will significantly enhance the vitality and viability of Southall’s retail offer. The scheme accords with London Plan policies 2A.8, 3D.1, 3D.2, 3D.3, 5F.1 and 5F.2 and draft replacement London Plan policies 2.7 and 2.15. At the local level the scheme accords with policies 7.1, 7.2 and 7.3 of Ealing Council’s saved UDP (2004), and policy 2.8 of Ealing’s Development Strategy 2026 Initial Proposals (2009). • The application includes new cultural and leisure facilities in the form of a cinema and hotel that would benefit Southall’s existing and proposed residents and will help encourage tourism in an Outer London area. The scheme accords with London Plan policies 3D.4 and 3D.7 and draft replacement London Plan policies 4.5 and 4.6. At the local level the scheme accords with policy 6.2 of Ealing’s Development Strategy 2026 Initial Proposals (2009). • The application includes a range of health, education and community facilities that would benefit Southall’s existing and proposed residents. The scheme accords with London Plan policies 3A.17, 3A.18, 3A.20, 3A.21, 3A.23 and 3A.24 and draft replacement London Plan policies 3.1, 3.2, 3.17, 3.18 and 3.19. At the local level the scheme accords with policies 8.2, 8.6, 8.7 and 8.8 of Ealing Council’s saved UDP (2004), and policy 6.2 of Ealing’s Development Strategy 2026 Initial Proposals (2009). • The proposal includes significant areas of onsite green space encompassing public open space, children’s play space and sports facilities which will adequately serve prospective residents. The scheme accords with London Plan policies 3D.6, 3D.11, 3D.12 and 3D.13 and draft replacement London Plan policies 2.18, 3.6 and 3.20. At the local level the scheme accords with policies 3.4, 3.5 and 3.6 of Ealing Council’s saved UDP (2004), and policy 5.5 and 6.3 of Ealing’s Development Strategy 2026 Initial Proposals (2009). • The layout, scale and massing of the development would preserve the open character of nearby Green Belt land. The scheme accords with London Plan policy 3D.9 and draft replacement London Plan policies 7.16. At the local level the scheme accords with policies 3.4, 3.5 and 3.6 of Ealing Council’s saved UDP (2004), policy 5.1 of Ealing’s Development

page 3 Strategy 2026 Initial Proposals (2009) and policy OL5 of Hillingdon Council’s saved UDP (1998). • The proposal would enhance access to nature in an identified area of deficiency, whilst not materially harming any biodiversity. The scheme accords with London Plan policy 3D.14 and 3D.17 and draft replacement London Plan policies 7.18 and 7.19. At the local level the scheme accords with policy 3.8 of Ealing Council’s saved UDP (2004), policy 5.4 of Ealing’s Development Strategy 2026 Initial Proposals (2009) and policies EC1 and EC3 of Hillingdon Council’s saved UDP (1998). • The application proposes all public realm and buildings to be fully accessible with 100% Lifetime homes, sufficient wheelchair accessible homes and hotel rooms, and blue badge car parking all to be secured by conditions. The inclusive design and access arrangements for this application accord with London Plan policies 3A.5 and 3D.7 and draft replacement London Plan policies 3.1, 3.8 and 7.2. At the local level the scheme accords with policies 4.3 and 5.3 of Ealing Council’s saved UDP (2004), and policy 2.8 and 6.1 of Ealing’s Development Strategy 2026 Initial Proposals (2009). • The development would result in minor adverse impact upon daylight and sunlight to some surrounding residential neighbours and the Grand Union canal during winter months only, which is expected following development of an open site in an urban context. The scheme complies with London Plan policy 4B.10 and draft replacement London Plan policies 3.1 and 3.8. At the local level the scheme accords with policy 4.1 of Ealing Council’s saved UDP (2004) and is in line with the guidance set out in the Building Research Establishment (BRE) handbook ‘Site Layout Planning for Daylight and Sunlight – A guide for good practice, 1991’. • The energy and sustainability strategies for this application have been prepared in line with the Mayor’s energy hierarchy, London Plan policies 4A.1 to 4A.19 and draft replacement London Plan policies 5.1 – 5.15. At the local level the scheme accords with policies 2.1 and 2.9 of Ealing Council’s saved UDP (2004). • The development would positively bring contaminated land into beneficial use through appropriate remediation measures in compliance with London Plan policy 4A.33 and draft replacement London Plan policy 5.21. At the local level the scheme accords with policy 2.7 of Ealing Council’s saved UDP (2004). • Contributions have been secured towards the provision of services and facilities related to the development including: transport infrastructure improvements; education, community and health facilities; open space and public realm improvements and access to employment for local people in line with Government Circular 05/05, London Plan policy 6A.4 and draft replacement London Plan policy 8.2. At the local level the scheme accords with policy 1.10 of Ealing Council’s saved UDP (2004) and policy R17 of Hillingdon Council’s saved UDP (1998). • The proposed master plan of the site would achieve a high quality design with a legible layout. The scale parameters of the buildings would create different character areas with a human scale reflecting the different site contexts that would respect the existing buildings that surround the site. The detailed design of the buildings would be appropriately conditioned and considered at various reserved matters stages. The master plan accords with the design policies set out within chapter 4B of the London Plan and draft replacement London Plan chapter 7. At the local level the scheme accords with policies 4.3 and 5.3 of Ealing Council’s saved UDP (2004), and policy 2.8 and 6.1 of Ealing’s Development Strategy 2026 Initial Proposals (2009).

page 4 • The proposed layout and scale of new buildings would enhance the existing poor setting of the grade II listed Water Tower at the eastern end of the site. This accords with London Plan policies 4B.11, 4B.1 2 and 4B.13 and draft replacement London Plan policies 7.8 and 7.9. At the local level the scheme accords with policy 4.1 of Ealing Council’s saved UDP (2004). • The proposed development would enhance the character and appearance of the Grand Union Canal Conservation Area, with acceptable set back and separation of the new canal side buildings respecting the canal’s openness. This accords with London Plan policies 4B.11, 4B.1 2 and 4B.13 and draft replacement London Plan policies 7.8 and 7.9. At the local level the scheme accords with policy 4.8 of Ealing Council’s saved UDP (2004) and policies BE32 and BE34 of Hillingdon Council’s saved UDP (1998). • The proposed development would increase infrastructure, facilities and activities that support the use and enjoyment of the Blue Ribbon Network with increased access alongside the canal as part of a development in an Opportunity Area. This accords with London Plan policies 4C.10, 4C.11 and 4C.12 and draft replacement London Plan policies 7.27 and 7.28. At the local level the scheme accords with policy 3.2 of Ealing Council’s saved UDP (2004). • Significant financial contributions have been secured, through a section 106 agreement, towards the provision of transport infrastructure improvements, education and health facilities, open space and public realm improvements, biodiversity and ecological management, access to employment for local people in line with Government Circular 05/05, London Plan policy 6A.4, draft replacement London Plan policies 8.2, Ealing Council’s saved UDP (2004) policy 1.10 and Hillingdon Council’s saved UDP (1998) policy R17, which all seek to secure contributions toward infrastructure and services required to facilitate the proposed development and acceptably mitigate any impacts. • The proposed development would help deliver the widening of the South Road Bridge, secured by Grampian condition and through a section 106 agreement. This fundamental transport mitigation measure would help relieve traffic congestion caused by the mix of uses on the application site, to ensure traffic movement on South Road and Beaconsfield Road would remain acceptable. This transport mitigation measure accords with London Plan policies 3C.1 and 3C.2, draft replacement London Plan policy 6.1, 6.3 and 6.12 and Ealing Council’s saved UDP (2004) policies 9.1 and 9.9. • The Environmental Impacts of the application have been assessed and there are no, or insufficient, grounds to withhold consent on the basis of the policies considered and other material planning considerations. Recommendation

2 That the Mayor, acting as local planning authority, grant planning permission, in respect of application references P/2008/3981-S and 54814/APP/2009/430, for the reasons set out above, subject to conditions and the prior completion of the legal agreement.

3 Planning application permissions - P/2008/3981-S and 54814/APP/2009/430

Legal agreement

4 The prior completion of a legal agreement to secure the following planning obligations:

page 5 London Borough of Ealing: P/2008/3981-S • Affordable Housing totalling 30% of all residential units/floorspace comprising 50% rent, 50% intermediate tenure mix. • 2,550 sq.m health facility. • 3,450 sq.m, two form entry, junior school and nursery. • £4,310,338 towards the improvement of local secondary education provision. • £60,000 towards the for refurbishment and provision of additional play equipment on the Spencer Street open space • £100,000 towards the provision of allotments • £262,000 towards the provision and maintenance of street trees on the Spine Road • £400,000 towards the provision of additional burial space at Greenford Cemetery • £975,000 towards pooled funding for the provision of a swimming pool • £678,000 towards employment and training provision • On-site employment skills training program and a commitment to a Local Labour Scheme • £360,000 towards provision of a shopmobility scheme • £596,000 towards implementation of public realm improvements • £664,000 towards the implementation of a low emissions strategy and air quality monitoring • £50,000 towards three years part funding of a Contaminated Land Officer post • 200 sq.m unit within the retail centre for operation as a Metropolitan Police Authority Community Policing Station • £6,600,000 towards funding for diversion of bus routes into and through the site • Permanent public access to the public realm • Permanent public access to the open space and recreation facilities • £50,000 towards implementation of VMS/Signage • £100,000 towards Southall town centre car parking • £100,000 towards review of adjoining Controlled Parking Zones • Provision of fifty car club parking spaces on the site • Restriction of parking permits • £3,550,000 towards the formation of a Transport Fund

London Borough of Hillingdon: 54814/APP/2009/430

• £1,840,000 towards implementation of mitigation measures and capacity enhancements to Minet Country Park • £821,118 towards the improvement of local secondary education provision • On-site employment skills training program and a commitment to a Local Labour Scheme

page 6 • £50,000 towards the implementation of air quality monitoring

5 That the Assistant Director for Planning be delegated authority to negotiate, sign and execute the legal agreement containing obligations securing the above.

Conditions

6 That the Assistant Director for Planning be delegated the authority to issue the planning permissions and agree the final wording of the conditions (and informatives) to secure the following matters:

London Borough of Ealing P/2008/3981-S

• Development commencement • Details of each reserved matter to be submitted • Compliance with approved drawings • Proposed use of Plot HS20 • Detailed design of all bridges to be constructed • Facing materials of all development • Maximum floor space areas of each approved use • Site Wide Strategy compliance • Construction Phasing Programme details and compliance • Construction Management Scheme details and compliance • Construction Management Scheme and Code of Practice detailed approval • Grand Union Canal study for transporting construction materials feasibility study • Grand Union Canal strategy submission • Urban Design Statement to accompany each reserved matter • Completion of Pump Lance access • Completion of Beaconsfield Road accesses • Eastern access works • South Road / Merrick Road junction improvement works • South Road / A4020 Uxbridge Road signalised junction works • Bulls Bridge signalised junction works • South Road northbound bus lane works • Merrick Road and the Eastern Access shall be constructed and brought into use before commencement of the widening of the South Road Bridge • M4 Junction 3 signalised junction works • Bulls Bridge signalised junction works completed before commencement M4 Junction 3 signalise

page 7 • No more than 1750 Development Units shall be occupied prior to the bringing into use for general traffic of the Pump Lane Access works d junction works • Pump Lane access not open to general traffic until Bulls Bridge and M4 Junction 3 signalised junction works are completed • Access to retained airport parking via Pump Lane access when open to general traffic • Closure of Brent Road to vehicular traffic with 4 weeks • Minet Country Park pedestrian/cycle bridge construction • Springfield Road pedestrian/cycle bridge construction • Eastern Access details in relation to access ways to Southall Station • Details of works within Crossrail safeguarded land • Remediation Strategy works • Finding of new types of contamination during remediation works • Validation report of completed remediation works to be submitted • Full details of foundation design • Full details of storage facilities for oils, fuels or chemicals • Connection of roof water down pipes to drainage system • No soakaways constructed in contaminated ground • No sewage or trade effluent discharged to the surface water system • All sewage or trade effluent discharged to the foul sewer • No infiltration of surface water drainage into ground • Full details of method statement for Japanese Knotweed, Giant Hogweed and Himalayan Balsam removal • Code for Sustainable Homes level 4 • BREEAM excellent rating • Full details of water efficiency statement • Living roof details • Water butt and rainwater harvesting technology details • Full details of a Energy Strategy • Commitment to a site wide heat and power network • New buildings to connect to the site wide heat and power network from first occupation • Energy Centre shall be installed and operational prior to occupation of 800th apartment • If Blue NG energy used: Energy Centre operational prior to occupation of 500th apartment • If Blue NG energy not used: Prior to the occupation of the 1000th new apartment on the development, the Energy Centre should contain gas combined heat and power (CHP) plant of at least 500 kilowatts

page 8 • Prior to the occupation of the 2500th dwelling the Energy Centre should contain a gas CHP plant of at least 1,000 kilowatts • Full details of a landscaping and maintenance scheme • Full details of children’s play spaces • Trees for podium planting • Retention and protection trees • Replacement of dead or damaged trees within 9 months • Any trees or shrubs that die within a period of 5 years from the date of planting replaced • Trees inspected for bats • Submission of an Ecological Management Plan • Appointment of an Ecological Clerk of Works • Undertaking of biodiversity surveys • Full details of a Bird Hazard Management Plan • Full details of the surface water drainage methods • Eastern Access shall not begin until the detailed design of the surface water drainage scheme is submitted • Full details of how foul water will be disposed of, to accord with the Site Wide Strategy • Full details of refuse and recycling strategy and storage • Full details of the Lifetimes Homes standards • Full details of 10% of all dwellings to be constructed as ‘wheelchair accessible’ • Full details of 10% hotel bedrooms to be constructed as ‘wheelchair accessible’ • Full details of car parking bays suitable for wheelchair users • Full details of Access Statements • Full details of an alternative wheelchair access to the Springbridge Road pedestrian bridge • South Road bridge widening scheme details • Full details of a dedicated taxi rank for the hotel and conference facility • Full details of all proposed car parking • Full details of the Home Zones within each residential part • Full details of traffic calming measures • Full details for the parking and manoeuvring of commercial vehicles • Full details of the proposed cycle and pedestrian routes • Full details of cycle space provision for all residential units • Full details of cycle space provision for non-residential uses • Full details of canalside moorings

page 9 • Full details of archaeological investigations • Full daylight and sunlight assessments • Full details of each unit meeting minimum floorspace standards • Full details of noise attenuation measures for protecting residential units from noise from the road or railway or aeroplane • Standard internal noise insulation for residential living rooms and bedrooms • Full details of proposed plant systems for commercial units • Full details of sound limiting devices to control the output from amplification systems • Full details of the green wall acoustic barrier • Full details of developments impact on the wind environment • Full details of lighting and external illumination • External lighting approval from CAA and Local Authority • Full details of a design strategy for all shopping frontages • A technical assessment of any potential effects of the development upon radio and/or electromagnetic signals, navigational and communication aids at Heathrow Airport • Full details of proposed extract ventilation systems • Full details of hours of operation including time of receiving deliveries or servicing of all commercial uses • Full details of security arrangements including the potential to link to the CCTV network • Full details of the noise level emitted from any proposed external plant and machinery • Demonstrate that the development complies The Hazardous Substances Consent • The Southall to Richmond high pressure, natural gas pipeline (HSE Ref No. 8021) has been re-routed • Removal of permitted development rights for dwellings

London Borough of Hillingdon 54814/APP/2009/430

• 7-year time limit for development commencement • Compliance with approved drawings • Detailed design of all bridges to be constructed • Full details of facing materials including samples • Strategy compliance • Construction Phasing Programme details and compliance • Construction Management Scheme details and compliance • Completion of Pump Lance access • Bulls Bridge signalised junction works • M4 Junction 3 signalised junction works

page 10 • Bulls Bridge signalised junction works completed before commencement M4 Junction 3 signalised junction works • Pump Lane access opening to general traffic (non-construction traffic) • Pump Lane access not open to general traffic until Bulls Bridge and M4 Junction 3 signalised junction works are completed • The Pump Lane / Bilton Way junction improvements works • Pump Lane access width restriction works • Plans and details of construction and surfacing of the Pump Lane link road • Minet Country Park pedestrian/cycle bridge construction • Springfield Road pedestrian/cycle bridge construction • Remediation scheme • Finding of new types of contamination during remediation works • Validation report of completed remediation works to be submitted • Full details of foundation design • Full details of the construction of storage facilities for oils, fuels or chemicals • Full details of method statement for Japanese Knotweed, Giant Hogweed and Himalayan Balsam removal • Full details of a landscaping and maintenance scheme • Retention and protection trees • Replacement of dead or damaged trees within 9 months • Any trees or shrubs that die within a period of 5 years from the date of planting replaced • Trees inspected for bats • Submission of an Ecological Management Plan • Appointment of an Ecological Clerk of Works • Undertaking of biodiversity surveys • Full details of a Bird Hazard Management Plan • Full detailed design of the river realignment scheme • Pump Lane Link Road bridge shall not begin until the detailed design of the surface water drainage pond is submitted • Full details of an alternative wheelchair access to the Springbridge Road pedestrian bridge • Full details of archaeological investigations • Full details of lighting and external illumination of bridges • External lighting approval from CAA and Local Authority • Full details of facing materials including samples • Full details of security arrangements including the potential to link to the CCTV network

page 11 • Risk Assessment and Method Statement outlining all works to be carried out adjacent to the Grand Union Canal

7 The detailed wordings of the above conditions with reasons are set out in the draft decision notice appended to this report.

8 That the Mayor directs that reserved matters planning applications be submitted and approved by Ealing Council under section 2C of the 1990 Town and Country Planning Act (as amended).

9 That the Mayor agrees that Ealing and Hillingdon Council’s are responsible for the enforcement of the conditions attached to the respective planning permissions.

10 That the Mayor confirms that his reasons for granting planning permission are as set out in this report in the Reasons for Approval section, as required by Article 22(1) of the Town and Country Planning (General Development Procedure) Order 1995 (as amended).

Informatives

• Under the terms of the Water Resources Act 1991, and the Thames Region Land Drainage Byelaws 1981, the prior written consent of the Environment Agency is required for any proposed works or structures, in, under, over or within 8 metres of the top of the bank of the Yeading Brook, designated a ‘main river’. • Under the terms of the Land Drainage Act 1991, the prior written consent of the Environment Agency is required for proposed works or structures which will affect the flow of the, designated an ‘ordinary watercourse’. • The Sustainability Report has highlighted the need to adopt water efficiency measures. This is welcomed as the Thames Region (which includes all the London Borough's) has been identified as an area of 'serious water stress under our published document 'identifying Areas of Water Stress'. • All landscaping areas (including private gardens) should be planted with drought tolerant plants, trees and grasses to minimise water requirements. • Prior to the commencement of details of the design of works to be undertaken within the vicinity of the railway, the applicant is recommended to contact Network Rail to ensure their proposals satisfy the requirements of Network Rail, in particular: a) Drainage - additional and increased flows of surface water should not be discharged into Network Rail land culverts or drains. b) Safety - No work should be undertaken that may endanger the safe operation of the railway or Network Rail's structures and adjoining land The demolition of buildings or other structures must be carried out in accordance with an agreed method statement. c) Ground levels - Network Rail need to be consulted on any alterations to ground levels, with no excavations near railway embankments, retaining walls or bridges. d) Support - Proposals should not cause surcharging of cutting slopes or retaining walls. Network Rail can accept no liability to maintain support to adjoining land other than for its existing use. e) Site layout - it is recommended all buildings be sited at least 2 metres from the boundary fence to allow construction and any future maintenance work be carried out without involving entry to Network Rail's infrastructure. Where trees exist on Network Rail land the

page 12 design of the foundations close to the boundary must take into account the effects of root penetration in accordance with the Building Research Establishment's Guidelines. f) Environmental issues - Design and siting of buildings should take into account the possible effects of noise and vibration and the generation of airborne dust resulting from the operation of the railway. g) Lighting - Any external lighting may conflict with Network Rail's signalling system. You will be required to obtain Network Rail's approval of the detailed lighting proposals. • The development of this site is likely to damage archaeological remains. The applicant should therefore submit detailed proposals in the form of an archaeological project design. This design should be in accordance with the appropriate English Heritage guidelines. • The historic building(s) is/are of intrinsic archaeological interest and any alteration or demolition of the historic structure(s) should be recorded before it/they are damaged or destroyed by the development hereby permitted. • Construction and demolition works, audible beyond the boundary of the site shall only be carried out between the hours of 0800 and 1800 hours Mondays to Fridays and 0800 and 1300 hours on Saturdays and not at all on Sundays and Public Holidays. The maximum permitted noise levels are: - Not greater than 72 dB L Aeq.10 hr Mondays to Fridays. - Not greater than 72 dB L Aeq.5 hr Saturdays. • Vibration from demolition, breaking of concrete and piling etc. as measured in the vertical direction on any floor in surrounding noise sensitive buildings shall not exceed an overall peak particle velocity level of 1mm/s • Prior to commencement of development of construction and demolition works, details of noise/vibration and dust mitigation measures shall be submitted to the Environmental Health section for approval. • Prior to commencement of development, of any site works, all sensitive properties surrounding the site shall be notified in writing of the nature and duration of the works to be undertaken and the name and address of a responsible person to whom enquiries and complaints should be directed. • No bonfires should be lit on site. • Any stone crushing plant proposed on site during the demolition process may require authorisation under the Environmental Protection Act (Prescribed Processes and Substances) Regulations 1991, SI 472. Contact the LBE Environmental Health Section on 20088258111. • Any property operating as a café or restaurant or handling food may be required to register with the Council as a food business and to comply with the requirements of the Food Safety (General Food Hygiene) Regulations 1995 and the Food Safety Act 1990. For further details contact Environmental Health and Trading Standards on 0208 825 6666. • The commercial units may be required to comply with the Health and Safety at Work Etc Act 1974 (Staff Amenities, Sanitary Accommodation, and Ventilation). For further details contact Environmental Health and Trading Standards on 020 8825 6666 or Health and Safety Executive on Tel 0845 345 0055 or www.hse.gov.uk 11 The Assistant Director for Planning be delegated the authority to include additional informatives as required.

page 13 Site description

12 The 44.7 hectare site is broadly triangular in shape and is bounded by Victorian housing to the north extending off Beaconsfield Road, Southall town centre to the east and north, the Great Western Mainline Railway to the south and the Grand Union Canal to the west with Yeading Brook and Minet Country Park beyond. The majority of the site is located in the London Borough of Ealing with the Grand Union Canal acting as the borough boundary with the London Borough of Hillingdon. The site traverses the borough boundary into Hillingdon in three places to accommodate two footbridges leading to Minet Country Park and Springfield Road, and a new vehicular access of Pump Lane.

13 The site was historically used for a range of heavy industrial uses including gas manufacture that ceased in the early 1970s. Two redundant and decommissioned gasholder structures occupy the central site area, but the site surrounds a compound containing a fully operational gasholder located midway along the southern boundary next to the railway line. A grade II listed Water Tower, which has been converted into residential flats, is located the application site’s eastern corner. There are large areas of car parking, associated with Heathrow airport users, currently occupying the site. This car parking is accessed via Brent Road on the southern boundary, and vehicle-servicing workshops occupy the site’s western corner. The Crescent and Beaconsfield Road provide two other site accesses from the site’s eastern and northern boundaries respectively.

14 The site is predominantly flat and characterised with extensive areas of hardstanding, comprising concrete or loose gravel, used for car parking. Vegetation within the site is sparse comprising poplars and scrub along the canal edge and northern boundary.

15 The scrubland, sandwiched between the Canal and Minet Country Park, is owned by British Waterways is contaminated land. A narrower piece of scrubland, directly north and opposite Yeading Football Club is own by Hillingdon Council and is commonly known as Minet Tip. This land is also contaminated. Along with the Minet Country Park, the scrubland is designated as Green Belt. The southern area of Minet Park, including the contaminated scrubland and Canal, is designated a Nature Conservation site of Metropolitan Importance. The Canal also forms part of the London Plan’s Blue Ribbon Network. The eastern edge of the Canal, located in Ealing, is part of the Grand Union Canal Conservation Area and the towpath is promoted as a recreational route, forming part of the Grand Union Walk and the Hillingdon Trail. The application site is also designated as an opportunity area by the London Plan and is identified as having deficient access to nature.

Image 1: Location map for application site (Source: MAKE Design and Access statement)

16 Approximately 240 metres west of the Grand Union Canal is the A312 The Parkway / Hayes Bypass, to which a new western access link road is proposed from the development site via Pump

page 14 Lane. This road would be primarily constructed in the southern area of Minet Country Park on land that is safeguarded for road construction by policy AM4 of Hillingdon Council’s UDP. Additionally there was an historic outline planning consent for construction of a link road in this location (see history section) that has now expired.

17 The closest part of the Transport for London Road Network (TLRN) is the A312 Parkway/Hayes Bypass, which is directly to the west of the development and in Hillingdon. The closest part of the Strategic Road Network is Uxbridge Road A4020, which is directly to the north of the site. Both roads will provide access to the site. The surrounding network consists of local distributor, primary and national roads managed by Ealing Council, TfL and the Highways Agency. As with many town centres in London the highway network currently operates at or near capacity and there are limited opportunities to increase or extend the network within the highway boundaries, in particular on South Road between the A4020 and Tentelow Road.

18 The site currently has a public transport accessibility level (PTAL) of between 1 in the west and 4 around Southall station however this does not fully reflect the high frequency of bus and train services available. The PTAL will increase [to between 3 and 5] upon completion of the development, [when bus services penetrate the site and with the introduction of new rail services], including and the site will also benefit from Crossrail from 2017. It should be noted these benefits were not reported in the transport assessment because Crossrail was not committed at the time the assessment was undertaken. Seven bus routes are accessible in close proximity to the site.

Details of the proposal

19 The hybrid part outline/part full application seeks outline planning permission, with matters of layout, scale, appearance and landscaping reserved, for the remediation of the existing contamination and comprehensive redevelopment of the site to provide a mix of commercial, community and residential uses along with areas of public realm and public open space and an internal network of roads within the site. Full consent is sought for the proposed site accesses in recognition of the necessity of securing these accesses to enable redevelopment of the constrained site.

20 All the built development would be located within Ealing with the exception of three proposed access ways from the west as well as a flood water storage area that are located in Hillingdon. These are detailed below.

• A bridge located of the northwest corner of the site over the Canal would provide cycle and pedestrian access to and from the site to Springfield Road.

• A Minet Country Park bridge over the Canal and Yeading Brook would be located centrally on the western boundary to provide pedestrian and cycle access to the Minet Country Park.

• A new road extension of Pump Lane to link to the Hayes by-pass would continue through the south area of Minet Country Park bridging over Yeading Brook and the Canal to provide for vehicle, cycle and pedestrian access to the site from it’s south-western corner.

• Alterations to and expansion of the existing drainage and flood relief area adjacent to Pump Lane.

page 15 21 In addition to the above the application proposes the demolition of several residential properties in Beaconsfield Road to facilitate three vehicular site accesses from the north, and demolition of properties in The Crescent and Randolph Road to facilitate a new vehicular access from the east leading of South Road. These accesses and properties are located within Ealing.

Use Maximum Floorspace (square metres) Residental 320,000 (up to 3750 units) Retail 20,050 Cafe/restaurant/pub 1,750 Hotel 9,650 Conference/banqueting suite 3,000 Leisure (cinema) 4,700 Heath care facility 2,550 Education (junior school) 3,450 Office 3,500 Sports pavillion 390 Public/communal open space 181,000 Energy centre 1,885 Multi storey public car park 24,450

Table 1: Proposed floorspace breakdown and mix of uses

22 Although the majority of the application is in outline form, a Development Specification document and a series of parameter plans have been submitted in line with Circular 01/2006 ‘Guidance on changes to the Development Control system’, which provide further detail of the proposals that provide a structure of elements and requirements that an outline approval could be conditioned against. The Development Specification includes maximum floorspace areas, and the parameter plans specify the proposed upper and lower building scale limits, internal road layout and areas of private and public realm. The Development Specification document has been used to assess the environmental impact of the development in accordance with EIA regulations.

23 An indicative master plan has also been submitted, which provides detail of the proposed development layout and overall development strategy. A central ‘spine’ road would run diagonally through the middle of the site, connecting the proposed eastern and western accesses with a network of secondary and tertiary roads extending northward and southward from this spine road, providing access to the remainder of the site. An open ‘Town Square’ would be located to the north of the neighbouring site’s operational gasholder, to act as a hub for commercial and community uses. These uses generally contained to the eastern half of the site. Additional cafe, restaurant and bar uses would be provided in a contained area opening onto the Grand Union Canal to the west. A large open space would be provided to the immediate west of the retained gasholder, with a wetland area extending further westward from this park. Higher density housing would be provided at the eastern end of the site and lower density housing at the western end, reflecting the relative distance to the proposed commercial uses on the site and the main transport link of Southall station.

page 16

Image 2: Master Plan with uses across the site (Source: MAKE Design and Access statement)

24 Residential car parking would be provided at an average ratio of 0.7 spaces per residential unit (between 2380 and 2625 spaces dependant on the eventual residential mix). This car parking would be provided through a combination of on and off street provision, in a combination of surface parking adjacent buildings, basement parking levels, and allocation within the town centre multi storey car park as dictated by the detailed design.

25 Commercial car parking would primarily be provided within a proposed multi storey car park that would be located at the southern extent of the town centre area. Additional car parking would be provided to the cinema, supermarket and hotel uses, incorporated into the building designs. A maximum of 950 non-residential car parking spaces are proposed, of which, up to 120 would be related to the hotel.

26 Eight coach spaces would be provided in an area adjacent to the town centre. Fifty car club spaces are proposed, which would be available for commercial and residential occupiers of the site and surrounding area. A minimum provision of 1 cycle parking space per residential unit would be provided, and up to 4000 cycle parking spaces would be provided for the commercial uses. Planning history of the site

Ealing Council

27 On 2 September 2009 Ealing Planning Committee resolved to refuse construction of a combined heat and intelligent power plant (CHiP) adjacent to the existing gasholder, on the adjoining site, to generate renewable energy. The applicant has lodged an appeal against this refusal. This application was referred to the Mayor (PDU/0119d).

28 On 23 July 2008 temporary planning consent for the continuation of the use of the main site for airport car parking was granted until 31 July 2010.

29 On 26 June 2007 an outline application for the demolition of existing buildings and comprehensive redevelopment of site for mixed uses comprising residential, employment, retail, leisure, community uses, new roads and points of access, and landscaping, was withdrawn. (Directly linked to the four full applications refused by Hillingdon on 29 November 2005). This application was referred to the Mayor (PDU/0119b).

page 17 30 On 15 December 2005 temporary consent for continued use of the site for the storage, preparation and parking of motor vehicles including retention of existing ancillary structures was granted.

31 On 23 August 2004 change of use from car workshop and body shop to scrap vehicle- processing centre (Permission sought for temporary period to 2008) was refused.

32 On 15 December 2001 temporary consent for continued use of site for storage, preparation and parking of motor vehicles and retention of existing structures was granted.

33 On 18 September 1997 temporary consent for continued use of site for storage, preparation and parking of motor vehicles and retention of existing structures was granted.

34 On 27 April 1995 temporary consent for continued use of site as storage for vehicles with ancillary workshop, offices, loading and unloading facilities with boundary fencing was granted.

35 On 4 March 1993 construction of new link road and roundabout with cycle ways, footways and landscaping, linking Gas Works site and Hayes By-Pass was granted.

36 On 29 May 1991 redevelopment of Gas Works site to create business estate (outline) was granted.

37 On 29 May 1991 redevelopment of Gas Works site to create a residential estate and park (outline) was granted.

38 On 1 May 1991 temporary consent for continued use of site as storage for vehicles with ancillary workshop, offices, loading and unloading facilities, 7 security towers and boundary fencing was granted.

39 On 19 July 1990 construction of new link road and roundabout with cycle ways, footways and landscaping, linking Gas Works site and Hayes By-Pass was granted.

40 On 26 April 1990 temporary consent for continued use of site as storage for vehicles with ancillary workshop, offices, loading and unloading facilities, 7 security towers and boundary fencing was granted.

41 On 23 November 1983 erection of two-storey blocks each comprising six residential units, one three-storey block comprising two units, and one three-storey block comprising six units, with parking provision (outline) was granted.

42 On 15 June 1983 consent for preparation and storage of motor vehicles and other storage purposes, and erection of two ancillary industrial and office buildings was refused.

43 On 18 May 1983 part use of land as travellers’ caravan site was granted.

44 On 16 March 1983 erection of two-storey blocks each comprising six residential units, one three-storey block comprising two units, and one three-storey block comprising six units, with parking provision (outline) was granted.

45 On 16 March 1983 use of land for storage of motor vehicles with ancillary industrial and office buildings was refused.

page 18 46 On 16 March 1983 layout of access road and erection of one block of six houses, one block of four houses, and one block of four houses and eight residential units, with parking provision (outline) was granted.

Hillingdon Council

47 On 29 November 2005 a proposed new link road between Pump Lane on the Hayes by-pass (A312) and the former Southall Gas Works with associated embankment and culverts over the flood relief channel and bridges over the Yeading Brook and Grand Union Canal was refused and a consequent appeal withdrawn. This application was referred to the Mayor (PDU/1309).

48 On 6 February 2006 a proposed new link road between Springfield Road/Beaconsfield Road and the former Southall Gas Works with associated embankment and bridges over the Yeading Brook and Grand Union Canal was refused and a consequent appeal withdrawn. This application was referred to the Mayor (PDU/1310).

49 On 29 November 2005 a proposed new footbridge over the Yeading Brook and the Grand Union Canal to link the Minet Country Park with proposed development on the former Southall gas works was refused and a consequent appeal withdrawn. This application was referred to the Mayor (PDU/1311).

50 On 29 November 2005 a construction of compensatory flood storage lagoon was refused and a consequent appeal withdrawn.

51 On 29 November 2005 reserved matters (details of siting, design, external appearance and landscaping) in compliance with condition 1 of outline planning permission ref. 33350/w/96/0079 dated 31 July 1996 for the construction of a link road to join the former Southall Gas Works site to Hayes bypass was refused and a consequent appeal withdrawn.

52 On 20 April 1990 outline planning permission was granted on appeal for the construction of a link road between the former Southall Gas Works site and the Hayes By-pass (A312) (Planning Inspectorate Ref: T/APP/R5510/A/88/084332/P3). Applications to extend the period for the submission of reserved matters were subsequently approved on 3 March 1993 (Ref: 33350/S/92/1362) and 31 July 1996 (Ref. 33350/W/96/0079). History of current planning applications

53 Following the withdrawal of the previous outline application the applicant started afresh with the new master planning team MAKE Architects. On 17 September 2007 a pre-planning application meeting was chaired by GLA case officers to discuss the proposed master plan.

54 The application was received Ealing Council on 9 October 2008 and the Council referred to the Mayor on 30 October 2008. Hillingdon Council also received the exact same application on 9 October 2008 but the Council did not refer to the Mayor.

55 The application was referable to the Mayor under Categories 1A, 1B 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 outside Central London and with a total floorspace of more than 15,000 square metres.”

page 19 • “Development for a use, other than residential use, which includes the provision of more than 200 car parking spaces in connection with that use”.

56 On 9 December 2008 the Mayor considered the referral application from Ealing Council and provided a statement of general compliance with the London Plan. At that time strategic issues outstanding included affordable housing, climate change, inclusive design and transport. (PDU/2310/01).

57 On 16 April 2009, the Head of Planning Decisions at the GLA wrote to Hillingdon Council advising it of the Mayor’s full consideration of the application on 9 December 2008 and provided a copy of the report.

58 The applicant proceeded to address the Mayor’s initial strategic concerns and on 23 September 2009 and updated stage I report was considered by the Mayor. By this time the only issues, which remained outstanding, were affordable housing and transport.

59 On 4 November 2009, Ealing Council considered an officer-level recommendation to grant planning permission, but the planning committee resolved to refuse permission for the following reason:

• The proposal, by reason of traffic generation from the mixed uses on site, would add to local road congestion, harming traffic movement on South Road and Beaconsfield Road.

60 On 10 December 2009 Hillingdon Council considered an officer-level recommendation to refuse planning permission and subsequently resolved to refuse permission for four reasons:

• The proposal, by virtue of the height, size and siting of buildings proposed adjacent to Green Belt land to the west of the site (Minet Country Park), would injure the visual amenities of the Green Belt, Yeading Brook and Grand Union Canal. In particular, the limited setback provided for between the canal edge and the development restricts the potential to successfully integrate the scale of this development into its surroundings.

• The proposal, by virtue of the inadequate timing and scope of the ecological surveys (including surveys of birds, reptiles, bats and invertebrates), and lack of adequate measures to mitigate habitat loss and fragmentation caused by the scheme would be unacceptably detrimental to the ecological value of Minet Country Park (a Site of Metropolitan or Borough (Grade I) Importance for Nature Conservation) the Grand Union Canal and Yeading Brook.

• The applicant has failed to provide, through an appropriate legal agreement an adequate provision of, or contributions towards the improvement of services and facilities as a consequence of demands created by the proposed development.

• The application fails to demonstrate that the scheme would not result in adverse impacts on the Highway network, in particular: (i) The additional 6% increase in saturation levels on the A312 South PM peak, with the resultant increase in queuing lengths, is at odds with the applicant's assertion that the development will have nil detriment. It is considered that this increase in queue length will have an adverse impact on the highway network; and (ii) The Applicant has failed to satisfy the Local planning Authority that the development will not result in adverse traffic conditions on the wider surrounding highway network.

page 20 61 Both Councils referred the application back to the Mayor in accordance with the requirements of the Mayor of London Order. On 22 December 2009 the Mayor considered the referred applications at stage II against the policy tests set out in the 2008 Mayor of London Order and concluded that… ‘Having regard to the details of the application, the matters set out in the committee reports, the Council’s draft decision notices and the fact that the policy tests set out in Article 7 of the Order have been met in that the development has a significant impact on the implementation of the London Plan and there are sound planning reasons for the Mayor to intervene in this particular case, the proposals in respect of the Southall Gas Works site warrant the issuing of a direction to take over the application and any connected application’.

62 In this regard, under the provisions of Article 5 of the Town & Country Planning (Mayor of London) Order 2008, the Mayor issued a direction under Article 7 that he was to act as the local planning authority for the purpose of determining the application and any connected application.

63 The Mayor carried out a site visit of the application site on 10 March 2010.

Relevant policies and guidance

64 In determining this application, the Mayor must have consideration to planning policy at the national, regional and local levels. The relevant issues and corresponding policies are as follows:

• National

Draft PPS ‘Planning for a Natural and Healthy Environment’ Draft PPS ‘Planning for a Low Carbon Future in a Changing Climate’ PPS1 ‘Delivering Sustainable Development’ Supplement to PPS 1 ‘Planning & Climate Change’ PPG2 ‘Green Belt’ PPS3 ‘Housing’ PPS4 ‘Planning for Sustainable Economic Development’ PPG 13 ‘Transport’ PPG 14 ‘Development on Unstable Land’ PPG 15 ‘Planning & the Historic Environment’ Draft PPS15 ‘Planning for the Historic Environment’ PPG 16 ‘Archaeology’ PPG 17 ‘Planning for Sport and Recreation’ PPS 22 ‘Renewable Energy’ PPS 23 ‘Planning & Pollution Control’ PPG 24 ‘Planning & Noise’ PPS25 ‘Development & Flood Risk’

• London Plan February 2008

2A.8 Town Centres 2A.9 The Suburbs: Supporting sustainable communities 3A.1 Increasing London’s supply of housing 3A.2 Borough housing targets 3A.3 Maximising the potential of sites 3A.5 Housing choice 3A.6 Quality of new housing provision 3A.7 Large residential developments 3A.8 Definition of affordable housing 3A.9 Affordable housing targets

page 21 3A.10 Negotiating affordable housing 3A.11 Affordable housing thresholds 3A.17 Addressing the needs of London’s diverse population 3A.21 Locations for health care 3A.24 Education facilities 3B.1 Developing London’s economy 3B.3 Mixed use development 3C.1 Integrating transport and development 3C.3 Sustainable Transport in London 3C.4 Land for transport 3C.12 New Cross-London Rail Links 3C.16 Road scheme proposals 3C.17 Tackling congestion and reducing traffic 3C.19 Local Transport and Public Realm Improvements 3C.23 Parking Strategy 3C.24 Parking in Town Centres 3D.1 Supporting Town Centres 3D.2 Town Centre Developments 3D.7 Visitor Accommodation 3D.8 Realising the value of open space and green infrastructure 3D.9 Green Belt 3D.11 Open space provision in DPDs 3D.12 Open space strategies 3D.13 Children and young people’s play and informal recreation strategies 3D.14 Biodiversity and nature conservation 3D.15 Trees and woodland 4A Climate change and London’s metabolism: mitigation of and adaptation to climate change and using and managing natural resources 4B Designs on London 4C.1 The strategic importance of the Blue Ribbon Network 4C.11 Increasing access alongside the Blue Ribbon Network 4C.14 Structures over and into the Blue Ribbon Network 4C.20 Development adjacent canals 5F.1 The strategic priorities for West London 5F.2 Opportunity areas in West London 6A.1 The Mayor’s own powers and resources 6A.4 Priorities in planning obligations 6A.5 Planning obligations

‘London Housing Strategy’ 2010 SPG ‘Housing’ Draft SPG ‘Housing’ SPG ‘Providing for Children and Young People's Play and Informal Recreation’ SPG ‘Accessible London: Achieving an Inclusive Environment’ SPG ‘Sustainable Design and Construction’ SPG ‘Land for Transport Functions’ SPG ‘Planning for equality and diversity in London’

page 22 • London Plan Consultation draft replacement plan October 2009

2.6 Outer London: vision and strategy 2.7 Outer London: economy 2.8 Outer London: transport 2.13 Opportunity Areas and Intensification Areas 2.14 Areas for regeneration 2.15 Town Centres 3.2 Addressing health inequalities 3.3 Increasing housing supply 3.4 Optimising housing potential 3.5 Quality and design of housing developments 3.6 Children and young people’s play and informal recreation facilities 3.7 Large residential developments 3.8 Housing choice 3.10 Mixed and balanced communities 3.11 Definition of affordable housing 3.12 Affordable housing targets 3.13 Negotiating affordable housing on individual private residential and mixed use schemes 3.14 Affordable housing thresholds 3.17 Protection and enhancement of social infrastructure 3.18 Healthcare facilities 3.19 Education facilities 3.20 Sports facilities 4.1 Developing London’s economy 4.5 London’s visitor infrastructure 4.7 Retail and town centre development 4.8 Supporting a successful and diverse retail sector 5 Climate change 6.1 Strategic approach 6.2 Providing transport capacity and safeguarding land for transport 6.3 Assessing transport capacity 6.4 Enhancing London’s transport connectivity 6.7 Buses, bus transits, trams 6.8 Coaches 6.9 Cycling 6.10 Walking 6.11 Smoothing traffic flow and tackling congestion 6.12 Road network capacity 6.13 Parking 7 Living spaces and places 8.2 Planning obligations

• Ealing Unitary Development Plan 2004 (as saved September 2007)

1.10 Legal Agreements and Partnerships 2.1 Environmental and other Sustainability Impacts 2.2 Regeneration of Special Opportunity Sites 2.5 Water Drainage Flood Prevention and Environment 2.6 Air Pollution and Quality 2.7 Contaminated Land

page 23 2.9 Energy 2.10 Waste Minimisation and Management 3.2 Green Corridors and the Waterway network 3.4 Public and Community Open Space 3.5 Land for Sports, Children’s Play and Informal Recreation 3.6 Allotments 3.8 Biodiversity and Nature Conservation 4.1 Design of Development 4.2 Mixed Use 4.3 Inclusive Design – Access for all 4.4 Community Safety 4.5 Landscaping, Tree Protection and Planting 4.7 Locally Listed Buildings, Buildings with Façade Value, and Incidental Features 4.8 Conservation Areas 4.10 Commercial Frontages and Advertising Signs 4.11 Noise and Vibration 4.12 Light Pollution 5.2 Affordable Housing 5.3 Lifetime Homes and Wheelchair Housing 5.4 Range of Dwelling Sizes and Types 5.5 Residential Design 5.6 Small Dwellings and Flats 6.1 Supply of Land and Property for Business Use 6.2 Proposals for Office Development 7.1 Promoting and Enhancing a Network of Centres and Promoting Key Sites 7.2 New Shopping Development and the Sequential Approach 7.3 Designated Shopping Frontages 7.6 Eating, Drinking and Entertainment 8.1 Existing Community Facilities 8.2 Major Developments and Community Facilities 8.6 Facilities for Young Children 8.7 Education Facilities 8.8 Health and Care Facilities 9.1 Development, Access and Parking 9.2 Stations and Public Transport Interchanges 9.3 Major Transport Projects 9.4 Buses 9.5 Walking and Streetscape 9.6 Cycling 9.7 Accessible Transport 9.8 Low Car Housing 9.9 Highways and Traffic Management 10.1 Strategic Sites and Areas 10.2 Green Corridors 10.8 View Points and Landmarks 10.11 Buildings of Facade or Group Value 10.12 Conservation Areas 10.16 Designated Shopping Frontages 10.18 Zones for Parking Standards 10.19 Transport Projects 10.20 Road Hierarchy

page 24 10.21 Development Sites

SPG1 Sustainability Checklist SPG2 Water, Drainage and Flooding SPG3 Air Quality SPG4 Refuse and Recycling Facilities SPG5 How to prepare an urban design statement SPG6 Plot Ratio SPG7 Accessible Ealing SPG8 Safer Ealing SPG9 Trees and Development Guidelines SPG10 Noise and Vibration SPG13 Garden Space SPG14 Indoor Living Space SPG18 Places for Eating Drinking and Entertainment SPG20 Sustainable Transport: Transport Assessments SPG21 Sustainable Transport: Green Travel Plans SPD1 Affordable Housing SPD2 Community Facilities SPD3 Low Car Housing in Controlled Parking Zones SPD7 Car Clubs SPD9 Legal Agreements (DRAFT) SPD Conservation Areas and Listed Buildings (DRAFT)

LDF Ealing’s Development Strategy 2026 Initial Proposals (2009)

• Hillingdon Unitary Development Plan 1998 (as saved September 2007)

Pt1.4 To safeguard a network of Green Chains from built development to provide a visual and physical break in the built-up area and opportunities for recreation and corridors for wildlife. Pt1.6 To safeguard the nature conservation value of Sites of Special Scientific Interest, Sites of Metropolitan Importance for Nature Conservation, designated Local Nature Reserves or other Nature Reserves, or sites proposed by English Nature or the Local Authority for such designations. Pt1.7 To promote the conservation, protection and enhancement of the archaeological heritage of the Borough Pt1.10 To seek to ensure that new development will not adversely affect the amenity and character of the Borough’s residential areas. Pt1.12 To avoid any unacceptable risk of flooding to new development in areas already liable to flood, or increased severity of flooding elsewhere. Pt1.16 To seek to ensure enough of new residential units are designed to wheelchair and mobility standards. Pt1.17 To seek to ensure the highest acceptable number of new dwellings are provided in the form of affordable housing. Pt1.18 To maintain, enhance and promote town centres as the principal areas for shopping, employment and community and cultural activities in the Borough. Pt1.19 To maintain a hierarchy of shopping centres which maximises accessibility to shops and to encourage retail development in existing centres or local parades which is appropriate to their scale and function and not likely to harm the viability and vitality of town or local centres. Pt1.30 To promote and improve opportunities for everyone in Hillingdon, including in particular women, elderly people, people with disabilities and ethnic minorities.

page 25 Pt1.34 To maintain the road hierarchy set out in this Plan and accordingly seek to segregate different types of traffic by the function of the various tiers of the hierarchy through traffic management schemes, road signing and planning control over development and redevelopment schemes. Pt1.35 To accord priority to pedestrians in the design and implementation of road construction and traffic management schemes, and to seek to provide a network of cycle routes through the Borough to promote safer cycling and better conditions for cyclists. Pt1.39 To seek, where appropriate, planning obligations to achieve benefits to the community related to the scale and type of development proposed. OL1 Green Belt - acceptable open land uses and restrictions on new development OL2 Green Belt -landscaping improvements OL5 Green Belt – development adjacent or conspicuous from the Green Belt EC1 Protection of sites of special scientific interest, nature conservation importance and nature reserves EC2 Nature conservation considerations and ecological assessments EC3 Potential effects of development on sites of nature conservation importance EC5 Retention of ecological features and creation of new habitats BE13 Layout and appearance of new development BE18 Design considerations - pedestrian security and safety BE31 Facilities for the recreational use of the canal BE32 Development proposals adjacent to or affecting the Grand Union Canal BE38 Retention of topographical and landscape features, and provision of new planting and landscaping in developments proposals OE1 Protection of the character and amenities of surrounding properties and the local area OE7 Development in areas likely to flooding - requirement for flood protection measures H4 Mix of housing units R17 Use of planning obligations to supplement the provision of recreation, leisure and community facilities AM1 Developments which serve or draw upon more than a walking distance based catchment area - public transport accessibility and capacity considerations AM2 Development proposals – assessment of traffic generation, impact on congestion and public transport availability and capacity AM4 Safeguard land for new road link between Hayes by-pass and former Southall gasworks AM7 Consideration of traffic generated by proposed developments AM8 Priority consideration to pedestrians in the design and implementation of road construction and traffic management schemes AM9 Provision of cycle routes, consideration of cyclists’ needs in design of highway improvement schemes, provision of cycle parking facilities AM10 Incorporation in new developments of additions to the proposed cycle network AM12 Priority to Bus Lanes AM13 Increasing the ease of movement for frail and elderly people and people with disabilities in development schemes through (where appropriate):- (i) Dial-a-ride and mobility bus services (ii) Shopmobility schemes (iii) Convenient parking spaces (iv) Design of road, footway, parking and pedestrian and street furniture schemes AM18 Developments adjoining the Grand Union Canal – securing facilities for canal borne freight

page 26

LDF Revised Core Strategy Preferred Options 2007

Responses to consultation

65 In assessing this planning application, Ealing and Hillingdon Council’s have carried out a consultation process, consulting all relevant departments within their respective Councils, statutory bodies and the local public.

66 Summary of Ealing Council internal comments

Noise and vibration: No objection subject to proposed conditions.

Air quality: No objection subject to the financial contributions agreed for a low emissions strategy and air quality monitoring in addition to attached air quality conditions.

Contaminated Land: No objection subject to a Risk Assessment, at the various stages of development that would enable a Remediation Strategy to be developed.

Access: No objection subject to suitable conditions to ensure that future occupiers would benefit from inclusive design. The details of which would be fully developed at reserved matters stage.

Transport: Recognises that the traffic generated by the proposal will have negative consequences on some major junctions, but to some extent this will be offset by proposed highway improvement measures secured by condition and s106. On balance the regeneration benefit of the scheme significantly outweighs some negative impact on the highways.

Housing: The increase from 20% to 30% affordable housing with a 50:50 rent to intermediate tenure mix is supported following consideration of scheme viability.

Design: The master plan including layout and scale parameters is broadly supported. Detail design on appearance and internal layout would be considered at reserved matters stage.

Education: Supports the provision of a school on the site to address the junior school needs arising from the proposed development and the financial contribution to address the demand for senior school places arising from the development.

Economic Regeneration: Very supportive, in particular proposed retail mix will complement the existing ‘ethnic niche’ retail offer in Southall town centre rather than competing with it.

Parks and Countryside: Welcome provision of local parks containing local equipped areas of play (LEAPs) and neighbourhood equipped areas of play (NEAPS) within the site so that they would be within 400m of all residential properties. However, financial contribution is required for cemeteries, allotments, street trees and sports facilities.

Crime Prevention Design: No objection, but further detailed design to address crime prevention and anti terrorism measures at reserved matters stage.

67 Summary of statutory body comments for Ealing

page 27 CABE: Offer broad support for the masterplan, the disposition of the uses, and routes across the site. Recognises careful conditioning is required to ensure that future reserved matters applications abide by these principles so that the development reaches its full potential

LB Hillingdon: Strong objection to proposal, and recommended refusal for four reasons.

LB Hounslow: No objection subject to further consideration of transport, health and education impact on the borough.

Health and Safety Executive: Advised that there are sufficient reasons, on safety grounds, to refuse planning permission, unless Grampian conditions were attached to update the hazard listing for the site following removal of redundant gas infrastructure and new pipeline constructed.

British Waterways: No objection subject to conditions and s106 requirements.

Defence Estates Safeguarding: No objection given proposed building height does not exceed 94.5 metres above ground level.

National Air Traffic Services: No objection.

West London Health Estates and Facilities Management: The PCT is supportive in principle with the proviso that there should be continuing dialogue with the local NHS and communities to ensure that health impacts are optimised during construction and operational phases.

Metropolitan Police Authority: No objection subject to the provision of a 200 sq.m unit in an appropriately visible and accessible location within the site to be secured by s106.

London Fire and Emergency Planning Authority: No objection subject to compliance with layout and specification standards that are based on Building Regulations.

Natural England: Generally supportive and recommend that the applicant produces an Ecological Management Plan.

Thames Water: No objection subject to a Grampian condition requesting submission of a strategy detailing any on and/or off site drainage works. No discharge of foul or surface water from the site would be accepted into the public system until a scheme had been approved, to ensure that sufficient capacity is made available to cope with the new development.

Environment Agency: No objection subject to conditions and Flood Risk Assessments are acceptable.

Highways Agency: Strongly supports the proposed bus measures and travel plan requirements and recommends conditions in accordance with the final position of the Transport Working Group.

Cross London Rail Links Limited: No objection subject to conditions should be applied requiring further detail of railway boundary treatment and detailed design and construction method statements.

English Heritage: This application should be determined in accordance with national and local policy guidance, and on the basis of the Council’s own conservation advice.

page 28 English Heritage (Archaeology): No objection subject to a condition being attached to secure the recording and analysis of the two gasholders to be removed. Additionally, each individual development phase should submit an archaeological strategy, specific to each phase yet also demonstrating how the Written Scheme of Investigation condition, attached to the outline consent, will be applied, as part of each detailed planning application.

Greater London Authority Stage I response: • Regeneration: The principle of this residential led mixed-use development on this large challenging brownfield site in an opportunity area is supported. • Retail: Given the complementary nature of the proposed development to the existing centre and the fact that the retail impact assessment has identified that there is a need for the development, the impact of the development would be acceptable, the scale of development is appropriate and there is no suitable, viable alternative town centre site it can be concluded that the retail element of the application complies with the London Plan. • Green Belt: The Pump Lane link road is safeguarded in Hillingdon’s UDP and is essential to unlock the potential of this significant site for provision of much needed housing. The pedestrian bridges do not constitute inappropriate development and increase access to the Green Belt. The application complies with the London Plan in this regard. • Biodiversity: Given that the application increases access to the Minet Country Park from an area that is currently deficient in accessible wildlife sites, and these accesses minimise impact through good design, the proposal complies with the London Plan in this regard. Consideration should be given to the provision of a contribution towards the maintenance of Minet Country Park and all recommendations for ecological mitigation and enhancements contained in the Environmental Statement should be made fully enforceable as conditions. • Blue Ribbon Network: the application broadly complies with London Plan policy in this regard however, the flood risk assessment, the impact of the bridges on the Blue Ribbon Network and the adequacy of the flood storage areas have yet to be assessed. · • Housing and affordable housing: the affordable housing mix proposed broadly complies with the London Plan however an affordable housing toolkit has yet to be submitted and as such it is not possible to assess whether the application is compliant with the London Plan with regard to affordable housing and housing mix. Currently wheelchair accessible units are only provided in the affordable sector and as such the application does not comply with the London Plan. • Children’s play space: The development provides a large amount of dedicated playspace however, given that the dwelling mix has not been fixed it is not possible to calculate the child yield in order to assess if the development complies with the London Plan target of 10 sq.m. per child. • Office, leisure, hotel and community uses: the land uses are broadly compliant with the London Plan. The hotel use is welcomed however the provision of 10% of accessible hotel rooms should be considered to ensure compliance with the London Plan. • Urban design: Overall this is one of the most humane and well thought through masterplans for a large site that has been referred to the GLA and as such the application complies with the London Plan in design terms. • Climate change mitigation: the applicant has proposed two alternative energy strategies- one that relies on CHP only and one that relies on gas pressure reduction and bio-fuel CHP. Whilst the second option is innovative the approach that fits best within the London Plan hierarchy is the CHP only option. However, significant further information is needed on both options before it can be concluded if either is compliant with London Plan policy.

page 29 • Climate change adaptation: The target for 50% of all roofs to be green or brown is welcomed. The applicant should commit to the maximum water use target for residential development. The surface water run-off arrangements have yet to be assessed. • Transport: TfL has no objection in principle to the proposed development however, significant further work is needed on a number of aspects before it can be concluded that the application complies with the London Plan in this regard.

Stage 1 update response: • Climate change: The further information requested in terms of energy has been provided and demonstrates consistency with the energy hierarchy, subject to the agreement of suitable section 106 clauses to deliver the proposed strategy. • Design: Further information has been provided in respect of children’s play space and an appropriate solution has been found to make the eastern access as accessible as possible given the level change. • Housing: The applicant should reconsider its provision of affordable housing, either in terms of an increased guaranteed percentage to prevent harm to strategic and local targets, whilst retaining an incentive to develop, or by capturing more accurately the financial performance of the scheme through full review of viability at appropriate stages to ensure that the maximum reasonable amount of affordable housing is delivered. • Transport: Continue discussions with Transport for London to ensure that the delivery and implementation of suitable transport measures is secured.

Local representations in Ealing

68 A total of 13,000 neighbouring properties were notified about the application and in excess of 40 site notices were displayed in the vicinity of the site. A total of 66 letters of objection were received along with a further letter of objection accompanied by a petition containing 278 signatures. Two letters of support were also received.

Support reasons

• Widening of South Road Bridge. • The scheme would be an improvement to the appearance and facilities of the area. • Modern buildings would be welcomed. • This is a prime site for redevelopment, particularly given the use as largely derelict brownfield land.

Objection reasons

69 A total of 27 separate planning matters of objection were identified in the 66 letters that were received on the following issues:

• The proposed Eastern Gateway access, which would become a traffic island as a result of the development to the detriment of the residents of the Water Tower (20 responses) • Proposed CHP Plant - as the production of bio fuels is environmentally unsustainable and results in the generation of greenhouse gasses and a consequent deterioration in air quality (18 responses) • The effect on the local infrastructure that would result from the development of 3,750 residential units and the additional pressure on the local road system that more car users would have (11 responses) • Increase in traffic congestion and the worsening of on street parking in an area that already suffers from such problems (17 responses)

page 30 • Overdevelopment of the site and the high residential density of the proposed development (12 responses) • Decline in air quality and the increase in respiratory diseases that would be a consequence of the increase in the local population, the increase in car use and the added pressure on emergency services such as hospitals and doctor’s surgeries that would arise (5 responses) • Loss of open space/children’s play area at The Crescent as it would be bounded by the proposed access road to the south. This would be contrary to Ealing UDP Policy 3.5 (Land for Sport, Recreation and Children’s Play Space) (1 response) • Rear service road for refuse collection vehicles for the recently built block of flats and retail units at 4-7 The Crescent would be blocked if the proposed development is allowed (1 response) • The site is contaminated land and would be hazardous for future occupiers and neighbours (7 Responses) • The proposed mix of uses, none of which are needed, as there is already adequate provision that is within easy reach of the area (1 response) • Inadequate and insufficient information that has been provided by the applicant in the Design and Access Statement and in the range of technical statements that have been submitted (1 response) • Discrepancies in the notification procedure, e.g. Failure to notify statutory and local emergency services, e.g. the Health and safety Executive and the Police and Fire Services. (1 response) • Proposed access - more thought should be given to the creation of a spur road off Merrick Road to continue under the roundabout at the southern end of the bridge to alleviate traffic congestion and link old Southall to the new development (1 response) • The development will cause existing properties in the area to become devalued (1 response) • Alternative forms of transport such as cycling, will be ineffective because the local road system is too congested and dangerous (1 response) • The proposed supermarket would destroy the diversity and choice that is a characteristic of the existing shopping centre (1 response) • The Environmental Statement is inadequate as it is technically unsound and open to question in sustainability terms (1 response) • The housing element of the proposed development may not be built to acceptable standards of habitation, in which case it should be called in by the Mayor (1 response) • The notification procedure was only printed in English and not in community languages. This is discriminatory, particularly as Southall has a high ethnic composition in its population and many people have therefore been excluded from the consultation process. (1 response) • Other concerns with consultation (1 response) • The design of the proposed buildings is poor and badly conceived. This is particularly true of the design of civic spaces in the proposal, which has little regard for issues relating to designing out crime in development. Furthermore, no thought has been given to vital issues such as the insulation of the proposed dwellings or energy efficiency (1 response) • The Retail Impact Assessment is out of date as its terms of reference are based on a West London Retail Needs Strategy that was compiled by a cluster of Council’s in 2006, before the credit crunch and the economic downturn emerged (1 response) • The housing element of the proposed development will be obliged to be high density to offset the costs of the additional infrastructure costs that will be required. This will mean that the design and building quality of the residential buildings will suffer (1 response)

70 The following interest groups and resident associations responded.

page 31 Commercial Boat Operators Association (CBOA): No objection but suggests that construction material could be transported into the site from other wharves locally at Bulls Bridge or further a field, reducing local road traffic in Southall.

The Inland Waterways Association: No objection in principle to the redevelopment of the site. Noted that much of the development is remote from, and would not have a visual impact on, the Paddington Arm of the Grand Union Canal.

Save Our Southall: Concern that the proposed sustainable transport strategy for the site will not work, and the scheme will not be pedestrian friendly; concern regarding transporting of contaminated material from the site; poor public transport links; inadequate incorporation of Canal into proposals; the area suffers from significant traffic congestion, and this proposal will worsen conditions; the eastern access will become overloaded; concern that car parking restrictions on the site will result in overspill to surrounding areas; the proposed flatted accommodation is inconsistent with local needs; concern regarding the proposed remediation strategy.

Ealing Friends of the Earth: Consider energy proposals ‘immature’ given approach of two potential systems and no details provided within the submission; if approved seek condition that an acceptable bio fuel scheme is submitted/implemented; concern over options (including solar panels) have not been identified as a means of delivering renewable target – and as a minimum solar panels should be provided and should only be accepted if their inclusion were conditioned; seek inclusion of CHP, due to better conversation of energy rate and details of heating arrangements be set out; seek greater than 10% energy requirements to be met by renewables; concern over the level of car parking – in terms of air pollution and its consequential impacts.

Ealing Civic Society: Express general support for the concept of the proposed development, but express concern with the following issues: Site isolation and access to adequate public transport; absence of leisure and community facilities within the scheme; further local parks and outdoor sports facilities are needed to accompany the development; adequate depth of remediation for substantial planting; underestimation of population yield; building heights along the Canal will dominate this area and the Green Belt beyond; the Southall gas holder should be painted as art work to as this will be a dominant feature within the scheme; townhouses in the south west part of the site will be affected by rail noise.

Planning and the Community Group: If the retail development is to be acceptable, it must be regarded as part of the town centre, and not a competitor to the town centre or an out of centre mall; this means reconfiguring the town centre so that people arriving at the new retail area can move around the town centre as a whole, and will regard their trip as being to the ‘town centre’. The implication of this is that there are good, easy bus services to and from the new retail area around the town centre as a whole. A mix of community facilities is needed within the retail area, consistent with the town centre status of the area, and serving wider Southall. Restriction of community facilities to dual use of school sites is not sufficient. Remediation of the land contamination is vital - future residents must be absolutely secure in the knowledge that there is no danger to their health or the health of their children. The mix of housing must reflect the demographic and social needs of the people of Southall - the range of unit sizes approved should be justified on this basis. It is suspected that there might be a shift to fewer but larger units on the basis of this approach, reflecting the nature of Southall’s communities. The Group is not persuaded that access to and from the site is sufficient to cope with the transport impacts the proposed development - given the increased population and envisaged commercial traffic expected. The group is particularly concerned about road access from the east.

Friends of Minet Country Park: In general, the group objects to the proposed development in its proposed form, scale, composition and extent on the gas works site, including the accesses from

page 32 the western part of the site. The development would be disruptive and detrimental to Minet Country Park and would introduce additional users that would place additional demand on the park. The group seeks further ecological assessment of the Park, and states concern about the loss of areas of ecological value, and the impact that additional users would have on these areas. The group also object to the development on the basis of traffic congestion and associated adverse environmental impacts on the Park.

Southall History Society: Object as there is insufficient roadway infrastructure to cater to this scale of development.

Ealing Shopping Centre Partnership: The proposed retail provision exceeds that envisaged by the Sub-Regional Development Framework for West London, and as a result may draw existing trade from the Ealing town centre. Specific objection is made on the following grounds: the scale of proposed retail exceeds that envisaged by the London Plan; the stated 0.25%/£1.7M trading impact on Ealing town centre is likely to be under-estimated; the scale of retail development proposed is inappropriate to the role and function of Southall Major centre, within the retail hierarchy.

Norwood Green Resident Association: Objection to inadequate access to the Grand Union Canal, and the scheme would contribute congestion to the local area; proposed demolition of dwellings on Randolph Road and The Crescent; and finally air pollution.

Avenue Road and Villiers Road Residents’ Association: Concern regarding the address of the application site on notification; adverse impact on residential property through the formation of the eastern access; Beaconsfield access proposals will lead to congestion; western access to Minet Country Park is merely a measure to overcome on site amenity space deficiency.

71 Summary of Hillingdon Council internal comments

Highways: The Council’s Highways Engineer has confirmed that the applicant has undertaken substantive further highways mitigation work to address most of the Officer's original concerns. However, the additional traffic levels on the A312 AM peak are not considered to be acceptable and not in line with the nil detriment. Therefore, objection is raised on Highways grounds.

Policy - Retail: The retail assessment has considered current conditions and estimates of impact are considered accurate. It is considered that there is a need for the proposed retail space, the impact of the development would be acceptable, the scale of development is appropriate and there is no suitable, viable alternative town centre site. Officers have further considered the potential impact of the scheme on Hayes Town Centre, and are satisfied that while there will be some likely trade draw, this is not considered to harm the viability of the town centre and that there should also be some benefit from the development for the town centre. There is no objection to the cinema and hotel and conference centre.

Policy - Housing: No objection to housing density, mix or affordable provision and tenure split proposed.

Policy – Open Space: Provided the scheme meets much of its basic recreation needs according to GLA Playspace provision standards there would be no policy objection to this aspect of the proposal.

Policy – Social infrastructure: It is probable that Hillingdon’s facilities would be used by the new residents and visitors. Appropriate mitigation should be sought to ensure that Hillingdon facilities are adequate to cope with such a major development in accordance with London Plan Policy.

page 33

Environment Protection Unit – Contamination: No objection subject to provision of a ‘Strategy for the Management of Earthworks Contamination’, assurance from the applicant that remediation measures or other mitigation measures (such as fencing and signage) can be put in place to prevent any access to the contaminated areas in Hillingdon, a management plan setting out how traffic leaving site (including vehicles transporting contaminated waste) are to be managed to prevent any contaminants from entering the environment and a condition to ensure that adequate monitoring of dust, vapours and odours is undertaken during the remediation works..

Environment Protection Unit – Air quality: No objection subject to a planning obligation to cover the cost of additional air quality monitoring made necessary by the development.

Trees and landscape: There are no trees protected by Tree Protection Order (TPO) or Conservation Area designation within the London Borough of Hillingdon part of the site. The Canal side residential blocks will be set back from the canal by only 8.5m, with ‘fingers’ of development extending towards the Canal. Significant concern is raised in relation to the potential for harm to be caused to the visual amenities of the Green Belt. The loading capacity of the roof gardens should be designed to support ‘intensive green roofs’, capable of supporting structural landscaping (with trees) and recreational uses. The Pump Lane access will cause an inevitable loss of habitat and shadows cast over the watercourse, however the mitigation measures are accepted to reduce adverse impacts during and after construction.

Green Space: Objects to the inappropriate timing of the wildlife surveys, the location of the mammal tunnel, lack of management details have been provided for areas that will be isolated by the road development and the associated shift of the flood relief channel, measures proposed to mitigate habitat loss and fragmentation are considered inadequate and the EIA does not address the impact that the raised banked road will have on species movement.

Projects and Implementation Team: The application would result in a significant number of impacts within the London Borough of Hillingdon, which would need to be mitigated through use of planning obligations.

Urban Design: The proposed courtyard developments are all of similar concept and scale, with only a limited number of typologies extensively repeated throughout which is likely to result in a monotonous urban site with a lack of distinctiveness and poor legibility, both internally and when viewed from the neighbouring Minet Country Park. The western access approach would benefit from further design work in order to emphasise this key gateway to the site.

Access: No objection subject to suitable conditions being imposed on any permission to ensure that future occupiers would benefit from inclusive design. The details of which would be fully developed at reserved matters stage.

Leisure services: The new Botwell Leisure Centre, which includes swimming and sports hall provision, opened in February 2010 would adequately accommodate any additional demand placed on facilities by new residents living in the scheme. With the introduction of the Hillingdon First card scheme into the Leisure Centres at this time, this would also ensure that local Hillingdon residents are not disadvantaged by Ealing residents using the facilities.

72 Summary of statutory body comments for Hillingdon

London Borough of Ealing: Confirmation that the Planning Committee overturned the officer recommendation to grant permission and resolved to refuse for a single transport reason.

page 34 Network Rail: No objection subject to requests that fencing is required to prevent access to railway land; drainage should not discharge onto railway land; demolition method statements will be required; no excavations should occur near railway land; buildings should be set at least 2m from railway land; siting of and design of building should take account of noise from the railway; all scaffolding and cranes should be such that it can not fall onto the railway.

British Aviation Authority Airports: No objection subject to the imposition of conditions on any consent requiring: a Bird Hazard Management Plan; a landscape plan; cranes to be limited in height so as not to endanger aircraft.

For summary comments from the Greater London Authority, the London Borough of Hounslow, the Health and Safety Executive, CABE, Natural England, Thames Water, British Waterways, the Environment Agency, the Highways Agency, CTRL Limited, English Heritage (Archaeology), Defence estates Safeguarding, NATS NERL Safeguarding and the London Fire and Emergency Planning Authority see paragraph 67 above as these comments are duplicated for both Councils.

Local representations in Hillingdon

73 A total of 5,328 neighbouring properties were notified about the application and site notices were displayed in the vicinity of the site. Additionally a public notice was placed in the local press on 8 April 2009, application was published on the Council’s website and a file for public viewing was had at the Civic Centre’s reception.

74 A total of nine letters of objection were received and raised the following issues:

• The development will place considerable strain of social and community infrastructure (e.g. health and educational facilities) • The application will generate significant amounts of traffic, which will cause unacceptable congestion • Proposed buildings are too high and there is not enough green space proposed • The scheme will result in significant additional usage of Minet Country Park • Capacity enhancements to the Park will be necessary and are not proposed • There would be a loss of wildlife habitat in Minet Country Park and other negative impacts on the ecological values of the park • The applicant has stated that the scheme is not financially viable if made to meet planning obligations, however the lack of supporting financial information makes it impossible to confirm this • The energy strategy is inadequate • The scheme will worsen air quality • The proposals do not comply with disabled access requirements • The scheme may result in harmful impact to existing retail areas • Construction impacts may cause damage to existing homes and the historic Water Tower on the site • Some of the buildings proposed to be demolished to create access-ways into the site from the north are worthy of retention • Consultation was not carried out correctly and notification letters were in English, which is inappropriate because many persons in the area of the site do not speak English • The application was accompanied by so much information it was not possible to adequately consider it all within the consultation time frame • The site may be bound by a covenant which may prevent the development, additionally, the applicant may not own the land

page 35 • The determination of the scheme should not occur until the London Borough of Hillingdon Local Development Framework has been finalised • The Developer does not have the skill set necessary to undertake the development

75 The following interest groups and resident associations responded.

Hayes Town Partnership: The retail proposed in the scheme will compete with and impact upon existing retailers in the area and echoed the majority of residents concerns above.

Hillingdon Slipstreamers: Object on grounds that the cycle circuit would also be more heavily used and contributions should be sought to cover the cost of capacity enhancements needed at the cycle circuit in order to cope with additional usage; greater numbers of people using Minet Country Park and surrounding roads would increase the risk of people colliding with cyclists; the increase in population in the area may lead to elevated levels of antisocial behaviour and criminal activity. Security measures and additional way finding signage will be required in the general area and within Minet Country Park.

Saint George’s Church: The proposal would involve loss of wildlife habitat in Minet Country Park; Capacity enhancements will be needed in the park in order to cope with additional usage; the greater number of persons using the park would increase the chance of someone gaining access to the contaminated land.

Bovis Residents Association: The scheme will result in a significant increase in traffic generation and congestion; additional persons living in the scheme would place additional pressure of infrastructure (including community/social infrastructure such as schools and health care facilities).

For Friends of Minet Country Park, Save Our Southall, CBOA and the Inland Waterways Association comments refer to paragraph 70 above.

76 Representations made to the Mayor

77 The Mayor has directly received 20 representations from members of the public and organisations. These representations have broadly raised similar planning concerns to those already received following the public consultation exercises carried out by both Ealing and Hillingdon Councils. The issue regarding traffic congestion in Southall was referred to most frequently in the representation letters.

78 A further common objection, in the representations received by the Mayor, related to the democratic process, whereby elected members of both Council’s have already resolved to refuse the application and therefore the Mayor should not interfere in their democratic decisions.

79 John Randall M.P and Councillor Gurcharan Singh, both wrote objection letters to the Mayor highlighting similar planning concerns to those already received following the public consultation exercises carried out by both Ealing and Hillingdon Councils.

Material planning considerations

80 The main planning issues raised by these applications that the Mayor must consider are: (The report page number included in bold type for ease of reference):

1. Land use principle page 37 2. Housing page 45

page 36 3. Residential standards page 48 4. Neighbouring amenity page 49 5. Transport page 50 6. Green Belt page 61 7. Blue Ribbon network page 63 8. Biodiversity, ecology and nature conservation page 64 9. Trees page 66 10. Contamination and human health page 67 11. Gas infrastructure page 69 12. Urban design – masterplan page 69 13. Heritage and archaeology page 72 14. Secured by Design page 74 15. Open space page 75 16. Access and inclusive design page 76 17. Air quality page 77 18. Noise and vibration page 78 19. Climate change mitigation page 79 20. Climate change adaptation page 81 21. Flood risk page 82 22. Phasing and construction page 82 23. Community infrastructure page 84

Land use principle

81 The application proposes a mix of uses across the site as set out table 1and illustrated in image 2. The site is specifically identified (site 43) in Schedule 10.21 of Part 2 of Ealing’s UDP 2004 as being suitable for a mixed-use redevelopment scheme. Additionally the London plan has identified the site as part of an opportunity area in which mixed-use developments are promoted.

Employment uses

82 London Plan policy 3B.1 recognises and supports London’s role as a world city and identifies the need to facilitate London’s continued attractiveness to international business through the supply of appropriate floorspace.

83 The site forms a significant element of the Heathrow Opportunity Area, as identified in London Plan policy 2A.5. The strategic importance of the application site has been has been reinforced further in the draft replacement London Plan October 2009, which contains emerging policy 2.13 and Map 2.4 ‘Opportunity and Intensification Areas’ that identifies Southall as an opportunity area in its own right. London Plan table 5F.1 indicates that the Heathrow Opportunity Area has the capacity to provide 11,000 jobs by 2026, whilst table A1.1 of the draft London Plan indicates that the Southall Opportunity Area site has an employment capacity of 2000 new jobs. The draft London Plan also includes emerging policy 2.7 ‘Outer London: Economy’, which covers the application site area. This proposed strategic policy seeks to address the constraints on economic growth of Outer London boroughs such as Ealing.

84 The Ealing UDP 2004 identifies the site as a ‘Special opportunity site’ important for borough wide regeneration objectives and UDP policy 6.1 seeks a wider range of employment uses including offices in shopping centres and at transport nodes. UDP policy 6.2 seeks to locate new office development in or on the edge of town centres including Southall. This application proposes 3,500 sq.m of office space and a significant quantum of other employment generating floorspace including retail, leisure and community uses (see table 1). These employment-generating uses

page 37 would create a significant number of jobs for existing and proposed residents and, which supported by local and regional policy designations for the site.

Hotel, conference and banqueting use

85 The application proposes up to 9,560 sq.m of hotel floorspace and London Plan and draft London Plan policies 3D.7 and 4.5 respectively identify the need to provide 40,000 net additional hotel bedrooms across London by 2031. Associated with the hotel, the application proposes up to 3,000 sq.m of conference and banqueting floorspace to be accommodated within the same building.

86 London Plan paragraph 3.292 states that ‘To reduce pressures on central London… increase London’s tourism attractions and contribute to broader regeneration and sustainability objectives, other locations should in future play a much greater role in provision for visitors. Town Centres and Opportunity Areas with good public transport access will be especially important’.

87 This building would be appropriately located within an opportunity area and at the edge of the proposed town centre area in a location that would be served by good access to the proposed bus routes diverted to run through the site. Additionally the location is within easy walking distance to the Southall railway station that will be further enhanced as part of the Crossrail works scheduled for completion in 2017. A hotel, conference and banqueting uses on this part of the site are welcomed and would address a deficiency of such uses in the Southall area.

Retail and restaurant uses

88 Southall Town Centre is designated as a Major Centre in the London Plan and Ealing’s UDP 2004, and is the only Major Centre in the Borough. It forms a ‘T’ shape, including the active length along The Broadway and High Street and extending down South Road, over the railway tracks, to just south of Norwood Road.

89 Ealing’s UDP policy 7.1 recognises the town centre as providing a specialist, and regionally significant, Asian based retail offer, of both Asian comparison and convenience goods. Significant characteristics include the distinct absence of major national retailers, the scarcity of modern retail units, with the buildings predominantly dating from the 1930’s or earlier and the significant ‘leakage’ of spending from the surrounding catchment population to other town centre areas for both mainstream comparison goods retail and convenience retail. While the specialist ethnic retail offer provided in the centre is operating strongly, the town centre is not providing the full range of retail offer to meet the needs of the surrounding catchment population.

90 The application proposes up to 20,050 sq.m. of retail, broken down into 5,850 sq.m. of convenience goods floorspace (single supermarket) and 14,200 sq.m. of comparison goods floorspace. Additionally 1,750 sq.m of restaurants, cafes, drinking establishments and hot food takeaway are proposed. The majority of these uses would be located in the eastern area of the application site close to the edge of Southall town centre.

91 PPS4, London Plan policy 3D.1 and draft London Plan policy 2.15 encourages retail, leisure and other related town centre uses to be located within existing town centres and discourages them outside of town centre. Additionally, London Plan policy 3D.2 states that the scale of the proposed retail, commercial and leisure development should relate to the size and role of the centre.

92 Although this application proposes the retail and leisure uses to be located at ‘edge of centre’ the strategic importance of the site is clarified by table A1.1 of the draft London Plan which states that ‘there is great scope to enhance the local environment and complement Southall’s

page 38 current strengths, including its ethnic identity and links with South Asia, by introducing a more diverse retail offer… The imperative to deliver genuine linkages between the Southall Gasworks site and the existing Southall town centre must be secured’. The London Plan and Ealing’s UDP policies recognise that the application site provides a unique opportunity whereby an ‘edge of centre’ retail development could serve to enhance the vitality and viability of Southall town centre.

93 Additionally, Ealing Council has recently published the consultation document ‘Development Strategy 2026 (Initial proposals)’ which proposes to extend the Southall town centre boundary, to enable any major retail development on the application site to be incorporated within Southall town centre. This consultation document therefore signals the Council’s support for the provision of retail on the application site and its intention to incorporate this area within future policy for Southall’s town centre boundary.

94 Notwithstanding the Council’s future policy aspirations for an amended Southall town centre boundary and the London Plan recognition to provide town centre uses on the opportunity site, the principle of this ‘edge of centre’ development can only be accepted if the tests of PPS4 are met.

95 The application was submitted to and considered by both Council’s prior to the publication of PPS4 and was therefore assessed against PPS6. The PPS6 tests are considered individually below, as they do help inform the consideration of PPS4 (which is set out in paragraphs 104-121). a) The quantitative and qualitative need

London Plan policy 5F.1 seeks to enhance the attractiveness of town centres and paragraph 5.168 expands on this stating that ‘West London is expected to experience significant growth in consumer expenditure, which could generate demand for 145,000 to 227,000 sq.m of extra comparison goods floorspace up to 2016. Strategically designated town centres in the sub-region, (shown on Map 5F.1), should be considered opportunities for more intensive development’. Southall is strategically designated as a Major centre and the London Plan designates the Gas Works site in an opportunity area recognising its potential to accommodate a significant proportion of West London’s quantitative need for comparison goods floorspace. This quantitative need is further justified given the estimated population yield of the development would be approximately 12,000 people.

In addition to policy justification, further retail needs data for West London is provided in the West London Retail Needs Study (WLRNS) 2006. In relation to Southall the study confirmed that there is a significant leakage of trade from its population catchment to other town centres. This loss is directly linked to qualitative shortcomings that are readily apparent in the town centre. Due to the specialist ethnic retail function of the centre, it currently fails to provide a sufficiently varied retail offer to cater to the needs of the whole catchment population including persons not seeking the specialist offer. This effectively results in the catchment population being deprived of an acceptable consumer choice of mainstream retail that a designated Major centre should offer. Hence the catchment population has to unsustainably travel to further distant centres to fulfil their individual qualitative retail needs. Accordingly, there is an identified quantitative and qualitative need in line with PPS6, to support an ‘edge of centre’ development of this nature. b) The development is of an appropriate scale

Paragraph 2.41 of PPS6 establishes that the scale of a development should relate to the role and function of the centre within the wider hierarchy and the catchment served. Southall Major centre competes alongside the Major centres of Hounslow, Chiswick and Fulham within West London and although the quantum of floorspace for Southall (including the proposals) would be greater than those competing West London Major centres, it is recognised that Southall significantly under

page 39 performs relative to its role in the West London retail hierarchy. For example the predicted 2011 turnover of retail floorspace in Southall (£35M) is extremely low, compared to Hammersmith (£295M); Chiswick (£114M); and Fulham (£128M) (Source: WLRNS Table 26). Even Fulham, which has 28% less retail floorspace than Southall, has a £93M high turnover.

In order to trade successfully against competing centres in West London, the proposed retail element at Southall needs to be of a certain scale to achieve the right critical mass. The scale proposed has been carefully considered to ensure that it would trade well against other Major centres, but would not elevate Southall above its position in the retail hierarchy. A significantly reduced quantum of floorspace at Southall, than what is proposed, would not achieve this critical mass and the scheme would not be commercially viable. The type and scale of development proposed is therefore consistent with Southall’s position in the retail hierarchy. In fact, it would ensure Southall fulfils its role as a Major Centre and would stop it declining further in relative terms. c) Applying the sequential approach to site selection

The number of vacant units in Southall town centre is well below the national average. Moreover, the majority of these vacant units comprise small unit shops (140-160 sq.m), which are appropriate to attract small independent retailers that already predominate in the centre, but are not suitable for the type of mainstream retailers that are sought for the Southall Gas Works site for the quantitative and qualitative reasons already explained above. Furthermore, there are no other suitable, viable or available alternative development sites in Southall town centre that could accommodate a building to meet the needs of modern retailers. A more diverse retail need for Southall has been identified and this can only be considered acceptable, both in practical and viable terms, on the edge of the existing centre. d) There are no unacceptable impacts on existing centres

Paragraph 3.21 of PPS6 states that, in assessing sites, local planning authorities should consider the impact of the proposal on the vitality and viability of existing centres within the catchment area of the proposed development. The development would enhance the vitality and viability of the existing Southall centre rather than compete with the existing specialist retail offer, which is recognised by Ealing Council by their policy aspiration to extend the existing town centre boundary to include this area of the Gasworks site.

The greatest predicted impact would be on the Hayes district town centre located in Hillingdon. The applicant’s Retail Assessment predicts a 4.3% reduction in trade from this centre, however the assessment concludes that the Hayes centre performs well as a shopping destination, offering a predominantly independent retail offer. It is considered that Hayes centre is strong enough to withstand the trade draw of 4.3%. Moreover, Hillingdon Policy officers comments concluded considered that the proposal would have some benefit for Hayes and Hillingdon Council’s Planning Committee accepted this fact. e) That locations are accessible

In this case, accessibility of this part of the site would be significantly improved through the introduction of bus routes through the site, and the proximity to Southall train station, which will be significantly enhanced as a Crossrail station.

96 In addition to meeting these tests, PPS6 also advises that additional benefits of regeneration and employment may be material considerations in the site selection process, and that the weight afforded to such factors would depend on local circumstances. As outlined in other sections of this report, the proposed development would deliver substantial regeneration

page 40 benefits to the local area. The proposed retail element must not be considered as a stand-alone ‘edge of centre’ development but considered in holistic terms forming part of a large sustainable mixed-use regeneration scheme.

97 The proposed retail element of the scheme would be effective in linking with the existing retail area and the distinctly mainstream retail offer proposed on the site would contrast with, and therefore strengthen, the specialist retail offer of the existing centre. Subsequently this would increase Southall centre’s market share of the surrounding catchment, and would assist in providing long-term consolidation of the Major centre position within the shopping hierarchy.

98 Furthermore, it is likely that if the application is approved, the Council will progress proposed alterations to the Southall town centre boundary, to replace the existing ‘T’ shape form of the town centre with a ‘J‘ shape that would incorporate the application site.

Leisure use

99 4,700 sq.m of leisure floorspace is proposed as a multi-screen cinema, which is a town centre use for the purposes of PPS6 and it is therefore appropriate to assess this element of the scheme in the context of that policy guidance.

100 There is an existing three screen cinema within Southall town centre, The Himalaya Palace, but this only shows Bollywood films and therefore residents of Southall are forced to travel to the to Ealing and Feltham should they wish to view a mainstream/Hollywood film. This gap in provision is self evident from the ‘Cinema Gap Analysis’ that forms an appendix to the WLRNS 2006.

101 Given the existing cinema within Southall town centre is a specialist cinema, the proposed cinema would complement rather than compete therefore having no detrimental impact on the existing town centre facility. In fact, it would have a positive impact on Southall by retaining leisure expenditure that is currently lost to competing centres in West London, hence further improve Southall’s overall offer and reduce existing unsustainable travel patterns. Accordingly, the proposed ‘edge of centre’ cinema is supported within the development.

Education facility

102 The application proposes up to 3,450 sq.m of education facilities for a two-form entry junior school and a nursery for 50 infants. Ealing’s UDP 2004 policy 8.7 states that the Council will work with educational facilities to achieve provision. The reasoned justification to the policy recognises that new development generally increases demand on existing education facilities, and states that the supply of additional facilities will be based on demographic needs of the local area. London Plan and draft London Plan policies 3A.24 and 3.19 respectively state that Boroughs should identify additional schools particularly where major new housing development is planned and in areas of regeneration. Accordingly the proposed education facilities are supported.

Health facilities

103 The application proposes up to 2,550 sq.m of health care facilities provided as a health centre with capacity for up to eight General Practitioners. This health centre would be located on the upper floors of a building shared with the proposed school, on the periphery of the proposed commercial area. Ealing’s UDP 2004 policy 8.4 provides guidance on the location of new community facilities, directing them firstly to established town centre locations and then to areas with suitable public transport accessibility. London Plan and draft London Plan policies 3A.21 and 3.18 respectively state health care facilities in appropriate locations accessible by public transport. Accordingly the proposed education facilities are supported.

page 41 PPS4 ‘Planning for Sustainable Economic Growth’ appraisal

104 Although the applicant’s retail assessment was produced before PPS4 was adopted, under the national guidance of PPS6, it is now necessary to consider how the application does comply with PPS4. PPS4 replaces PPG4, PPG5, PPS6 and parts of PPS7 and PPG13. It sets out the Government’s national policies for all economic development (whether urban or rural) and defines economic development to include: “Use Classes, public and community uses and main town centre uses.”

105 PPS4 includes both Plan Making Policies (Policies EC2 to EC8) and Development Management Policies (EC10 to EC19). The latter group of policies are to “be applied directly by the decision maker when determining planning applications”.

Policy EC10 – Determining Planning Applications for Economic Development

106 This policy is applicable to all applications for economic development. The starting point of Policy EC10 (EC10.1) is to look favourably on planning applications for economic development. Where proposals secure “sustainable economic growth” they should be treated favourably. This proposal has always been supported in relation to securing economic growth, both by Ealing Council and the Mayor. A development, which achieves economic growth, is required on the site in order to fully comply with existing Ealing UDP and London Plan policies, especially as site is part of an opportunity area whereby economic growth is strongly encouraged. The proposals are, as such, wholly consistent with the guiding principles of Policy EC10 and, consistent with Government advice, should be looked upon favourably.

107 The second part of Policy EC10 establishes five general impact considerations against which all proposals for economic development should be assessed. These are considered individually. a) Whether the proposal has been planned over the lifetime of the development to limit carbon emissions, and minimise vulnerability and provide resilience to, climate change.

The scheme includes various measures to address climate change adaptation and mitigation. In terms of energy efficiency an overall carbon saving of approximately 14% beyond the baseline emission has been estimated. The scheme has been designed over its lifetime to ensure that carbon emissions are minimised and the scheme is resilient to climate change. b) The accessibility of the proposal by a choice of means of transport including walking, cycling, public transport and the car, the effect on local traffic levels and congestion (especially to the trunk road network) after public transport and traffic management measures have been secured.

The site is in close proximity to Southall railway station and new bus services will be provided through the development site. Furthermore, dedicated cycle and pedestrian ways permeate throughout the development providing good accessibility both within the development itself and to the adjacent areas including, notably, Southall Town Centre. The development as a whole and, in particular, the proposed main town centre uses will be accessible by a range of means of travel.

(c) Whether the proposal secures a high quality and inclusive design which takes the opportunities available for improving the character and quality of the area and the way it functions.

Ealing Council, the GLA and CABE have all recognised that the proposed outline masterplan would secure a high quality and inclusive design. The finer details of the design would be fully considered at reserved matters stage and there are appropriate conditions included to ensure the highest quality would be achieved.

page 42 (d) The impact on economic and physical regeneration in the area including the impact on deprived areas and social inclusion objectives.

In terms of physical regeneration the proposals would bring forward a large, under utilised site within an urban area for redevelopment. This would include full remediation and the creation of new accesses to the highly constrained site. In terms of socio-economic regeneration objectives the development would provide new range of housing options for Southall’s residents, including a significant element of affordable housing, a modern, attractive retail offer that would complement the role of Southall Town Centre, significant employment opportunities for locals, community and recreation facilities and significant open space available for future occupiers of the site as well as the wider Southall community, improved access into and throughout the site, notably across the canal and brook into Minet Country Park to address the site’s current status as deficient in access to nature.

(e) The impact on local employment.

The construction period would create approximately 820 Full Time Equivalent (FTE) jobs to improve the local employment and the economy. Additionally, approximately 1,320 FTE jobs will be provided on-site when the scheme is completed; the majority of which will be in retail. Retail jobs are particularly important for local employment with jobs offered across a broad spectrum of skills. Retail also tends to employ people more locally than in other employment sectors.

108 The subsequent Development Management Policies are then split in to those relevant to main town centre uses and those that are not main town centre uses. The non-housing elements of the proposal principally comprise main town centres uses as defined by the PPS (retail, leisure, hotel and offices). As such, policies EC14 to EC17 are all relevant for this application.

109 Policy EC14 explains what evidence would be necessary to submit in support of planning applications for main town centre uses, and establishes size thresholds of when such evidence will be required. In the contest of the application site, policy EC14 requires a sequential assessment to be undertaken and an assessment of the impacts set out in policy EC16.1.

110 The evidence submitted in the retail assessment in support of the proposal includes both a full sequential assessment and a retail impact assessment. This evidence has already been considered acceptable, under PPS6, and as such the evidential requirements of EC14 are met.

111 Policy EC15 expands on policy EC14 to detail how a sequential assessment should be undertaken to support any application for a main town centre use that is not located not in a recognised centre (or in accordance with an up-to-date development plan). The guidance in EC15 essentially draws together and refines the previous advice of PPS6 on the sequential approach and therefore the existing sequential assessment is compliant with PPS4.

112 The application proposals are supported by a thorough and robust sequential assessment that considered a wide range of sites both within Southall Town Centre and beyond. In the context of EC15, the assessment considered sites in terms of their availability, suitability and viability, looked at all ‘in centre’ options first, considered the question of flexibility in terms of the scale of development, scope for disaggregation and format. In the absence of any genuinely available in centre sites, that could accommodate the identified need, and deliver the ‘seed change’ in shopping habits that Southall requires and established policy seeks, it was concluded that the applicant site, being edge-of-centre, was the next best alterative. This situation has not changed since PPS4 adoption and is therefore consistent with Policy EC15.1(c).

page 43 113 Ealing Council has already accepted that the sequential approach had been satisfied. There remains no sequentially preferable sites within Southall Town Centre that could deliver the consolidated retail centre that is needed. As such, the requirements of policy EC15 are met.

114 Policy EC16 is concerned with assessing impact. Again, retail impact has been addressed in the retail assessment that accompanies the planning application. It considers the impact of the proposals on a range of centres across the catchment area and concludes the main impact would fall on Hayes Town Centre. However, Hillingdon Policy officer’s comments have concluded that the proposal would have some benefit for Hayes, and Hillingdon Council’s Planning Committee accepted this fact.

115 Notwithstanding the earlier PPS6 conclusions on impact, the following comments in relation to the individual criteria of Policy EC16 are an important consideration.

116 The proposal would not result in any unacceptable loss of public or private investment, whether existing, committed or planned in the adjacent centre or any other centre. On the contrary, the proposal results in very significant private sector investment on a site adjacent to Southall Town Centre, which will deliver economic regeneration and enhance Southall as a shopping destination consistent with its position within the established retail hierarchy.

117 Detailed evidence accompanying the planning application was submitted to demonstrate that the proposal would not unacceptably impact on the vitality and viability of any established centres and that position remains unaltered since PPS4 adoption.

118 The proposal would not have any impact on the prospects of other allocated town centre sites beyond Southall Town Centre coming forward for development.

119 The proposal would have an overall positive impact on in centre trade within Southall Town Centre. It will do this by retaining shoppers within the catchment area who are currently choosing to shop elsewhere, including beyond the catchment area, for their shopping needs. Southall currently under performs in terms of its position in the shopping hierarchy. These proposals will restore Southall to its rightful position as a Major centre and therein boost trade for existing retailers in the town centre through increasing shopper retention rates. There is no conflict with this criterion of the policy.

120 The site is located in an edge-of-centre position. As confirmed in the Report to Committee, the proposal is of an appropriate scale given Southall’s defined Major centre role in the shopping hierarchy. The proposal is not out of scale and again the criterion is met.

121 The final PPS4 policy of relevance of is EC17. This is the overarching policy against which all proposals for main town centre uses, not in a defined centre or in accordance with an up-to- date development plan, should be judged. It establishes a staged approach to the consideration of such proposals. First, the sequential approach has to be followed (which it has) and secondly, it must be shown that the proposal would not result in any significant impact as defined in policies EC10.2 and EC16.1 (there would be no such significant impact). If a proposal fails either of these two tests, it should be refused consent. The proposal does not fail these tests as evidenced in the information supporting the planning application and was accepted by both Local Planning Authorities and the GLA. Accordingly, consistent with policy EC17, the proposals would then have to be weighed against their overall positive and negative impacts, again, defined by Policies EC10.2 and EC16.1. When that exercise is undertaken the balance in terms of impact falls very heavily in favour of granting consent. The application is therefore compliant with PPS4.

page 44

Housing

122 London Plan Policy 3A.10 requires 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 70% of housing should be social and 30% 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. Policy 3.13 of the consultation draft replacement London Plan echoes the principles of policy 3A.10. However, draft policy 3.12 seeks to ensure that 60% is social and 40% intermediate.

123 Policy 3A.10 is supported by paragraph 3.52, which urges 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 results of a toolkit appraisal would need to be independently verified.

124 Policy 5.2 of Ealing’s UDP seeks the provision of 50% of units on site as affordable housing. The policy also states that less than 50% may be justified where there will be particular costs associated with the development that would mean a scheme involving affordable housing would not be viable, or would prejudice the realisation of other planning objectives that need to be given priority.

Affordable provision

125 The applicant has submitted a GLA Affordable Housing Development Control Toolkit with the application that provides an overview of the wider financial viability assessment of the scheme. The appraisal is based on a development scenario of 3,475 residential units and provides a summary of the £276.8m exceptional development costs of up-front investment to facilitate the site’s development. In response to the current economic climate, the residential valuation figures within the appraisal are based on January 2008 property values. The Toolkit concludes that the scheme could viably provide a maximum of 20% of the units as affordable housing, which would equate to 694 residential units.

126 The Valuation Office was jointly commissioned by the GLA and Ealing Council to undertake an independent assessment of the toolkit. The Valuation Office independent assessment report provides two significant conclusions. Firstly, potential cost savings suggest that a greater percentage of affordable housing could be provided than the proposed 20%. Secondly, the wide range of variables and assumptions, contained within the toolkit, do not robustly justify a proposed departure from Ealing’s UDP 50% affordable housing target of for the potential 20 year duration of the development, during which time scheme viability would likely improve.

127 In recognition that development would be constructed over a long period of years in ‘phases’ the applicant was told that the fixed 20% affordable offer was not acceptable and was requested to deliver affordable housing through the security of a review mechanism. This mechanism would secure reassessments of scheme viability prior to each phase of development resulting in the affordable housing contribution to more closely reflect likely costs and values at

page 45 that future time, hence achieving the maximum reasonable amount of affordable housing at that time. However, to deliver a scheme of this scale, on a highly constrained and contaminated site, significant up-front investment would be required for remediation, construction of new roads and utilities, and the assembly of land outside the developer’s ownership to enable the development.

128 The applicant stressed that a review mechanism would result in the distribution of affordable housing at much later phases because the up-front costs prior to each development phase would demonstrate that early affordable provision as unviable. This point was considered reasonable, however the independent assessment of the applicant’s financial toolkit still proved that the alternative offer of a fixed 20% was not enough. Following extensive discussion, this fixed offer was increased to 30%, which could result in 1,042 affordable housing units on the site if developed to 3,475 units.

129 There is clear choice between the certainty of the applicant’s preferred approach to deliver 1,042 affordable housing units, and the alternative review mechanism approach for certainty that the maximum reasonable amount of affordable housing being delivered over the lifetime of the scheme at each phase. It is important to recognise that one approach is not necessarily certain to provide more affordable housing than the other and therefore both approaches are valid in principle.

130 It is accepted that the provision of a fixed figure of 30% affordable housing would strike a reasonable balance between allowing long term certainty for Ealing Council and the applicant, and uncertain future change of variables, that could in fact result in a lower delivery of affordable housing in the long term if a review mechanism was implemented. Additionally, this site can be seen as a unique example requiring significant up-front enabling costs where there is a real need to encourage rather than residential development on an identified opportunity site. For these reasons the 30% offer is only acceptable given the special circumstances uniquely related to this particular development site and proposal.

Tenure split

131 London Plan policy 3A.9 states that Council’s affordable housing targets should be based on an assessment of regional and local housing need and a realistic assessment of supply, and should also take account of the London Plan strategic target that 70% of housing should be social and 30% intermediate provision, and of the promotion of mixed and balanced communities. Policy 3.12 of the consultation draft replacement London Plan demands a 60:40 split in favour of social.

132 The 30% affordable housing provision would be split 50:50 between social rent and intermediate tenures, which is 521 units each. Although this tenure split is contrary to the aspiration of draft London Plan policy 3.12, Ealing Council’s Housing team has fully assessed the proposal considering the social composition of the area and conclude the split as acceptable to help create a mixed and balanced community in Southall.

Mix of units

133 London Plan Policy 3A.5 requires new development to offer a range of housing choices in terms of the mix of housing sizes and types, taking into account of the housing requirements of different groups. In support of this policy, the London Plan Housing Supplementary Planning Guidance (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. Recent guidance is also set out in the London Housing Strategy, adopted February 2010, and draft replacement London Plan policy 3.8.

page 46 134 The proposal would provide a broadly acceptable mix of unit sizes across all tenures; particularly positive would be the provision of 104 four-bed+ units as affordable. Policy 1.1C of the London Housing Strategy seeks more family sized homes with 42% of social rented and 16% of intermediate housing to have three bedrooms or more. This scheme would provide 41% three and four-bed units for social rent and 40% for intermediate, in this regard the proposal would practically meet the Mayor’s target for family sized social rent and would significantly exceed the intermediate target. In total there would be a provision of 1221 larger three/four bedroom units, including 200 single-family dwellings, which is very positive. The mix is supported and would provide a range of housing for all social groups in accordance with policy 3A.5 and emerging policy 3.8.

135 However, given that development will be phased over a 20 year build programme there is potential for housing needs to change, therefore any approval would require a degree of flexibility to enable the approved development to respond to such changes. Hence it would not be appropriate to fix a specific housing mix by condition to any outline approval, rather an overall housing mix strategy should be required by condition with an incorporated review mechanism, with subsequent phases of development to accord with this strategy. This would allow for future flexibility in unit mix, but would also provide adequate assurance that an appropriate mix would be provided in the development.

Density

136 London Plan Policy 3A.3 outlines the need for all development proposals to achieve the highest possible intensity of use compatible with local context, the design principles of the compact city (policy 4B.1), and with public transport accessibility. Table 3A.2 ‘density matrix’ of the London Plan provides guidelines on density in support of policy 3A.3.

137 The Development Specification document submitted with the application advises that the building plots with a CPS or CPN reference would be below 90 units per hectare and that building plots with a HS reference would be above 90 units per hectare. No further upper or lower density limits are specified.

138 The HS building plots are located on the eastern half of the site, and along the northern site boundary. The CPS and CPN building plots are generally located on the western half of the site. This is consistent with the overall strategy to create a mixed use town centre area at the eastern end of the site, including higher density flatted development above retail uses, consistent with the intended character of this area. The eastern end of the site would also benefit from a better public transport accessibility level due to the proximity to Southall Rail Station, which will be further enhanced as part of the Crossrail works.

139 The public transport accessibility levels (PTAL) are not yet available for the development, as these will be subject to the completion of bus route proposals, however it is likely that the town centre character area at the eastern end of the site would be consistent with a central area character of medium PTAL. Density levels in excess of 90 units per hectare would be appropriate in this area. The remainder of the site would likely be characterised as an urban setting with a low to medium PTAL value. Residential development below 90 units per hectare on this central/western part of the site would be similarly consistent with the London Plan density matrix.

140 The main site area, excluding the wider site areas related to the access proposals, is approximately 33 hectares. The 320,000 sq.m of residential floorspace represents approximately 86% of the proposed floorspace, resulting in a relative site area of 28.5 hectares. The provision of 3750 residential units on the site would result in an overall density across the site of 131 units per hectare. On the basis of the mixed approach to the residential provision across the site, with

page 47 higher and lower density areas, it is considered that an average of 131 units per hectare would maximise the potential of the site in an opportunity area. Residential standards

141 London Plan Policy 3A.6 seeks that residential development design takes the safety and security of residents into account and this policy is reinforced by draft London Plan policy 3.5 which seeks housing developments to be of the highest quality internally, externally and in relation to their context. Ealing’s UDP 2004 policy 5.5 requires new residential development to provide good living conditions for residents and good architectural quality, that it should relate well to its setting, and should incorporate sustainability principles. Residential development should (i) provide an attractive outlook and a sense of privacy for new residents and their neighbours, (ii) provide adequate indoor living space, and garden space well related to the accommodation, (iii) ensure adequate sunlight and daylight and (iv) provide adequate play space for children.

142 Although the residential element of the outline application is for access only, the masterplan includes parameter plans of the housing block layout across the site and how they relate to their closest neighbours. This indicative layout provides the required 21-metre separation distance between the facades of residential buildings for acceptable residential privacy and outlook, however the final layout would be subject to detailed design at reserved matters stage. In terms of indoor living space the exact size of each unit would require consideration at reserved matters, however the applicant has committed through a condition to ensure that all the residential units would meet the minimum floorspace standards outlined in table 3.3 of the draft London Plan. This is welcomed.

143 The apartment blocks would have central courtyards to provide amenity space for the residents, including doorstep play space. All the single-family dwellings would be provided with a private rear garden, which is welcomed. These communal spaces, along with private gardens would total 4.6 hectares. The communal courtyards would ensure good outlook to upper floor flats overlooking the internal courtyards, moreover this active surveillance of the spaces would ensure good security and ownership for residents. These courtyard amenity areas would be further supplemented by a number of publicly accessible parks across the site totalling 13.5 hectares. The proposal would provide a good level of onsite outdoor amenity for all prospective residents, which would be further enhanced by two new pedestrian bridges to Minet Country Park across the canal.

144 The internal layout of the residential units have not been provided, however the block layout could accommodate flat cluster and corner apartments to maximise dual aspect. However, it is recognised that there would also be a proportion single aspect unit but this number should be minimised, especially those directly facing north or south. With regard to each habitable room receiving adequate daylight and sunlight a condition is included to ensure the submission of a daylight and sunlight assessment for all internal habitable rooms facing north or at lower levels of the internal courtyards for each residential phase. Overall the outline submission provides assurance that a good standard of living could be achieved subject to conditions.

Children’s play space

145 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.” Using the methodology within the Mayor’s supplementary planning guidance ‘Providing for Children and Young People’s Play and Informal Recreation’ it is anticipated that there will be approximately 1,390 children within the development. As such the development should make provision for 13,900 sq.m, or 1.39 hectares, of dedicated play space throughout the site.

page 48 146 The development provides 2.62 hectares of playspace including 24 doorstep playable spaces, five local playable spaces, four neighbourhood playable spaces and three youth spaces. This figure exceeds the required provision by 1.23 hectares, which is welcomed and is secured by condition. Neighbouring amenity

147 Given that the site is largely vacant at present, neighbouring residents will have become accustomed to its relatively benign impacts. However, the site’s previous uses as a gas works and for other heavy manufacture would have had significant adverse impact on these residential neighbours. The proposed development will inevitably have some impact upon the amenities of neighbouring residential buildings that adjoin the northern boundary of the site and in the Water Tower.

148 In recognition of this sensitive relationship all the proposed terraces of townhouses would be no higher that four storeys with the exception of block HS.01 which could rise to five storeys. In addition to this appropriate maximum height, a separation distance in excess of 21 metres would be retained between the elevations of existing and proposed terrace housing. The neighbouring properties on Beaconsfield Road would therefore retain an acceptable level of natural light, privacy and outlook. Townhouse block HS.17 would adjoin the end of neighbouring terrace on Randolph Road, and would be no more than three storeys high to protect both neighbouring amenity and respect the scale of this terrace.

149 Two other blocks, HS.06 and HS.07, located close to the northern boundary, would be for mixed-use purposes. The eastern arm of block HS.06 would adjoin the end of neighbouring terrace on Grange Road, and would be no more than three storeys to protect both neighbouring amenity and respect the scale of this neighbouring terrace. Block HS.07 would be located close to the rear gardens of properties on Grange Road and Lewis Road, and its maximum height would be three storeys to protect the amenities of these neighbours.

150 The supporting text of policy 4.1 of Ealing’s UDP notes that proposals are expected to allow sufficient daylight and sunlight into buildings and land, and that the Council will apply the recommendations of the Building Research Establishment’s (BRE) ‘Site layout planning for daylight and sunlight’ guidance. Additionally, London Plan policy 4B.10 states that large-scale buildings should show sensitivity to their impact on microclimate including sun and overshadowing. To confirm that the indicative siting and maximum heights, of the blocks described above, would not adversely impact up neighbours the north, the applicant has provided a solar shading assessment in line with BRE guidance. The assessment confirms that the neighbouring residential properties would still receive excellent solar access throughout the day for spring, summer and autumn; however, solar access would be reduced during the winter. Overall the effect of this reduction on the amenity of existing properties is considered to be minor.

151 With regards to the residential Water Tower, the closest building within the development site would be sited approximately 60 metres away and would be single storey. In this regard the BRE assessment confirms that good solar access would be enjoyed year round and these neighbours would not suffer a significant loss of amenity.

152 Overall, it is accepted that during the winter months, the scheme would result in some detrimental solar shading impact on neighbouring residential development to the north of the site. However, the scale of this impact is not excessive; particularly as it is largely limited to the winter months and in an urban context like this it is not unusual for neighbouring amenity to be impacted upon to some extent by development on vacant sites.

page 49 153 Appropriate landscaping would be necessary to the western side of the eastern access route, to prevent overlooking of the rear elevation of neighbouring Randolph Road properties. This is indicated in the Design and Access Statement, and further details will be required at the reserved matters stage. Transport

154 The principle of residential led mixed-use development on the Southall Gas Works site is established through the Ealing UDP and is referred to under Heathrow in the London Plan Policy 5F.2 (Table 5F.1) Opportunity Areas in West London (2004). The draft revised London Plan (2009) refers more specifically to Southall Gas Works and sets an indicative employment capacity of 2,000 jobs and a minimum target in the region of 4,000 new homes. The current application is for 3,750 homes, which has been shown in the transport assessment to be deliverable. In employment terms the planning application seeks to provide mixed-use development that will contribute towards achieving approximately 2,000 jobs on site and this has also been assessed within the transport assessment.

155 In order to ensure compliance with London Plan policies 3C.1 Integrating transport and development, 3C.2 Matching development to transport capacity, 5F.2 Opportunity Areas in West London and draft replacement London Plan policies 6.1 Strategic approach and 6.3 Assessing transport capacity, Transport for London (TfL) requires the proposed development, which includes an enhanced town centre and associated uses, to be supported by a high level of public transport accessibility together with appropriate increases in capacity to mitigate the impact of the development. In particular, TfL requires a considerable mode shift away from reliance on the private car to use of more sustainable public transport, walking and cycling.

156 The planning application and transport assessment has been prepared in accordance with a committed phasing plan and construction programme. The transport impacts have been assessed in 5-year periods between 2005 and 2020 and the mitigation measures proposed accordingly. The phasing plan (Appendix 10A of the transport assessment) will be fixed by the planning permission and as a result the development will be comprehensively delivered unless agreed with the local planning authority and TfL and any deviation from this would require variation of the planning application through section 73 of the Town and Country Planning Act or a revised planning application.

157 The development would be constructed in 13 phases and is due to be completed by 2020 with all transport infrastructure and mitigation in place. The development will be phased from east to west including two new gateway accesses linked by a spine road. Construction traffic will arrive from the western access (‘haul road’) from phase 1 (2011/12). Works to the eastern access (South Road) will also begin during phase 1 (2011/12). It is noted that there is a complex set of overlapping works at the eastern access that will require careful construction management and mitigation. Crossrail will be operational from 2017 with works starting after 2012.

158 Both Ealing and Hillingdon Councils resolved to refuse this planning application. The steps that have subsequently been taken by the applicant to address these grounds and concerns are set out within this report.

Policy 3C.1: Integrating transport and development

159 Both the Councils considered that the application did not comply with London Plan policy 3C.1, The policy states: The Mayor will work with TfL, the government, boroughs and other partners to ensure the integration of transport and development by:

page 50 • Encouraging patterns and forms of development that reduce the need to travel, especially by car

• Seeking to improve public transport, walking and cycling capacity and accessibility where it is needed, for areas of greatest demand and areas designated for development and regeneration, including the Thames Gateway, Central Activities Zone, Opportunity Areas, Areas for Intensification and town centres and other parts of suburban London in which access is needed

• In general, supporting high trip generating development only at locations with both high levels of public transport accessibility and capacity, sufficient to meet the transport requirements of the development. Parking provision should reflect levels of public transport accessibility (see Annex 4 on Parking Standards)

• Encouraging integration of the major transport infrastructure plans with improvements to the public realm, particularly in key areas around major rail and Underground stations and interchanges, using land assembly powers where necessary

160 TfL raised a number of concerns on transport grounds within the Stage one and two reports and these issues are addressed in this Stage Three report together with a consideration of how they have been resolved in accordance with the London Plan.

S106 phasing and delivery mechanisms

161 Since the Councils resolutions and referral of this application to the Mayor, the section 106 agreement and planning conditions (including the timing of infrastructure triggers) have been worked up in more detail in order to give TfL (and the Mayor, should he wish to approve the application) confidence that the development will be adequately mitigated, including the timing of infrastructure triggers. The applicant has agreed to covenant with both Councils and where appropriate TfL to undertake the additional measures, make contributions and deliver various infrastructure works.

162 TfL also requested that it must be a signatory to the section 106 agreement in order to have ongoing involvement in approvals relating to the scheme and measures to enable TfL to enforce obligations therein. This has been agreed by the applicant and is now proposed in the agreed heads of terms. As a signatory TfL will work closely with other parties to ensure that the agreement provides the necessary mitigation when it is needed. The agreement secures various post outline planning requirements including the area wide walking and cycling study, South Road corridor study, South Road bus priority scheme, South Road Bridge widening scheme, framework travel plan, public transport strategy, and construction management plan. These controls will enable the Councils and TfL to monitor and manage the development as it is implemented using up to date interim assessments.

163 These objectives must be met to ensure compliance with London Plan policies 3C.1 Integrating transport and development and 3C.2 Matching development to transport capacity and draft revised London Plan policies 6.1 Strategic approach and 6.3 Assessing transport capacity.

Transport Management Fund

164 TfL raised concerns at Stage one and two about the content and adequacy of the proposed Transport Management Fund.

165 The applicant has since provided a breakdown of costs to show how the £3.55 million has arrived at and the works it is envisaged the fund would cover (dependent on the outcome of the

page 51 various studies and monitoring reports). It should be noted that the overall fund figure has reduced slightly from the figure cited in the committee reports to Ealing and Hillingdon Council. However, this is due to the fact that certain works in Hillingdon (which the applicant was previously proposing should be funded from the Transport Management Fund) are now secured by way of condition and will now definitely be delivered by the applicant by the relevant triggers regardless of cost. The applicant has stated that the there is no more funding available from the scheme and Ealing Council satisfied that the proposed £3,550,000 is sufficient to mitigate the impacts of the development.

166 TfL expects the fund to include a ring-fenced Supplementary Mitigation Fund for any unforeseen measures as appropriate identified through the Area Wide Walking and Cycling Study and South Road Corridor Study and to address any unforeseen traffic management measures in Ealing (and Hillingdon) as they should arise. This will be capped at £550,000. The Transport Management Fund will be finalised through the section 106 agreement and will amongst other things fund the cost South Road Bus Priory Scheme and all off site green travel planning measures.

167 The draft framework travel plan provided by the applicant secures a number of measures/facilities to be provided within the development in order to encourage and ensure a mode shift away from the private car. Whilst these proposed measures are to be welcomed, TfL has requested that the applicant provides more on site travel planning measures than those currently proposed given the scale and importance of this development. Therefore TfL will, under any section 106 agreement, require additional measures from the applicant, such as a cycle club, bicycle vouchers, Oyster Card vouchers and a greater commitment to fund the car club to ensure a considerable mode shift away from reliance on the private car to an emphasis on public transport, walking and cycling. Discussions in this regard are ongoing in the context of the overall section 106 agreement negotiations.

168 The section 106 agreement will also include a clause, which states that any unspent transport contributions (including where appropriate non transport related contributions) will be paid into the transport management fund to cover supplementary mitigation and travel planning measures.

169 These issues will be addressed through the s106 agreement to ensure compliance with London Plan policies 3C.1 Integrating transport and development and 3C.2 Matching development to transport capacity and draft revised London Plan policies 6.1 Strategic approach and 6.3 Assessing transport capacity.

Transport review group

170 TfL raised concerns at Stage One and Two in respect of the constitution of the proposed transport review group (TRG). The terms of reference for the TRG will be agreed by all parties prior to completion of the section 106 agreement, and formed prior to implementation of the development. The TRG will be constituted in a fair and reasonable manner and aims to ensure that decisions as to possible additional transport mitigation or the most appropriate travel plan measures are made collaboratively and on an informed basis. Priority measures upon which the transport management fund will be spent will be agreed through the TRG having regard to the South Road corridor study analysis and other sensitivity testing to be carried out by the applicants at various stages of the development. TfL will however retain complete discretion on matters relating to the bus network and bus infrastructure issues.

171 TfL also will have joint approval with the Councils of the framework travel plan, South Road corridor study, South Road Railway Bridge widening scheme, site wide car and cycle parking management strategy, area wide walking and cycling study and construction management strategy.

page 52 Trip generation

172 The trip generation methodology was agreed by TfL and the Councils prior to undertaking the baseline assessment. The applicant has provided a detailed breakdown of trips for 5-year periods. The trips arising from the development are summarised in the transport assessment.

173 A background growth factor has been applied to the development, which relates to traffic on the network not attributed to the development. This was important in assessing the full effects of the development together with wider growth on the network. This was welcomed by TfL and was particularly important in ensuring sufficient highway mitigation was provided on the A312 Parkway/Hayes Bypass.

174 The trip generation is considered to be broadly acceptable to TfL subject to the set phasing and triggers. However, TfL has agreed with the Council that due to some local constraints on the network there is a need to provide mitigation earlier than has been assumed in the transport assessment. This has been accepted by the applicant.

175 The applicant has committed to monitoring the impact of the development cumulatively through further interim assessments and sensitivity testing on the South Road corridor. The applicant has also agreed to monitor construction traffic and bus journey time. These measures will be secured through the s106 agreement in order to augment the development triggers.

Mode split

176 TfL requested at Stage 2 that the applicant should provide further information on mode shift progression as the development proceeds.

177 The transport assessment. identifies a final end state residential mode split target of 37.8% by car and 46.5% for retail. The mode shift will be monitored and kept under review using monitoring data and updated periodically in the travel plan.

178 It should be noted that the Crossrail scheme was not accounted for in the transport assessment. and as a result it is expected that more trips by public transport than anticipated in the transport assessment should be possible. As a result the applicant should be aiming to exceed the end state target.

179 Green travel planning measures and expenditure of the Transport Management Fund will contribute towards exceeding this target.

180 The mode shift will be at the very least achieved to ensure compliance with London Plan policies 3C.1 Integrating transport and development and 3C.2 Matching development to transport capacity and draft revised London Plan policies 6.1 Strategic approach and 6.3 Assessing transport capacity

Highway Impact: Ealing

181 Ealing Council’s reason for refusal is stated above. To enable the Council and TfL to be satisfied that these concerns have been addressed, the applicant has agreed to make some changes to the application.

182 The approach to the transport assessment was agreed with TfL and the Highways Agency. However, proposed development triggers had not been previously calibrated based on cumulative highway and construction impact. Therefore, TfL and the Council has requested that the timing of development triggers be changed and that further interim assessment and monitoring is

page 53 undertaken to review performance of the highway network at gateway junctions and along the South Road corridor. Specific concerns were also raised in respect of the buses and the South Road Bridge widening scheme.

183 Since the committee meeting Ealing Council has provided further clarification of its specific highway concerns which can be summarised as follows:

(1) Capacity and performance at the South Road/A4020 Uxbridge Road junction

(2) Capacity and performance at the South Road/Beaconsfield Road junction

(3) Capacity and performance at the South Road/Merrick Road junction

(4) Design and implementation of the South Road bus corridor and bridge widening

(5) Traffic management between Beaconsfield Road and A4020 (rat running through the residential area)

184 Linkages between the design, capacity and construction of these junctions and improvements in relation to the whole South Road corridor need to be considered. Ealing and TfL have requested that junction improvements at the three listed junctions (which are to be secured by agreed development thresholds pursuant to the conditions on the planning permission) must be provided in advance of the South Road Railway Bridge widening in order to ease any congestion that may be caused by the construction of the bridge works, subject to ongoing monitoring through a South Road Corridor Study. The impact and integration of Crossrail works will also be considered in accordance with the planning conditions. This has led to a revision of the proposed phasing of infrastructure improvements which were assessed in the TA, the phasing will be as follows:

Limit on Development Units Infrastructure Indicative timing 400 Eastern Access + Beaconsfield 1-2 years (2010/11) Road 800 South Road/Merrick Road 2-3 years (2012/13) N/A Crossrail works begin (2013/2014) tbc 1250 South Road/Uxbridge Road 4-5 years (2014/15) junction 1350 Bulls Bridge Junction (A312) 4-5 years (2014/15) 1500 M4 Junction 3 5-6 years (2015/16) 1500 South Road Bus Lane 5-6 years (2015/16) N/A Crossrail station works completed (2016/17) tbc 1750 Pump Lane Access open to all 6-7 years (2016/17) traffic 2500 Rail Bridge Widening 9-10 years (2019/20) Note: The numbers of development units are included as Grampian conditions, however the timing is indicative. The full cost of the works will be borne by the developer and will not affect any other s106 contributions.

185 TfL is broadly satisfied with this as a general approach as it provides further highway capacity and traffic management earlier in the development phasing. The applicant has agreed through a South Road Corridor Study mechanism in the s106 agreement to monitor and assess the impact of the development on a concurrent and cumulative basis so that the proposed and amended triggers and phasing (as illustrated above) can be fully assessed.

page 54 186 These provisions will be met to ensure compliance with London Plan policies 3C.1 Integrating transport and development and 3C.2 Matching development to transport capacity and draft revised London Plan policies 6.1 Strategic approach and 6.3 Assessing transport capacity

South Road Corridor Study

187 South Road is a sensitive part of the highway network and as such needs to be carefully managed and properly assessed. The relationship between buses and general traffic will also need to be addressed.

188 In order to overcome the specific highway concerns which have been raised by the Council and TfL the applicant has agreed to undertake regular multi-modal assessment and sensitivity testing through preparation of a South Road Corridor Study. The study will be secured through the s106 agreement with the detailed scope to be agreed between Ealing Council and TfL. The study will assess the cumulative impact of highway improvements relating to South Road and the eastern gateway and identify any unforeseen mitigation measures to be funded by the applicant from the proposed Transport Management Fund.

189 The study will specifically assess impacts on bus journey times, construction traffic and pedestrians and cycle routes on the highway network, it will have full regard to any works pertaining to Crossrail. Importantly the study will inform delivery of the South Road Railway Bridge Widening Scheme and the South Road Bus Priority Scheme. Where appropriate the study will also help inform any recommendations to draw down money from the Transport Management Fund.

South Road Railway Bridge Widening Scheme

190 As stated above Ealing Council has cited local highway capacity and congestion on the South Road corridor as one of the key reasons why the application was refused and in particular the relationship between buses and general traffic on the South Road Bridge. As a result TfL has seen it necessary to consider in more detail the proposed development trigger to enable the South Road Railway Bridge widening scheme to provide additional capacity relief to traffic and public transport.

191 The Council and the applicant have each raised concerns about existing highway conditions on the bridge and have suggested the bridge widening is required now. It should be noted in response to this that conditions in Southall are similar to those that one would expect in a strategically important town centre location. The development will clearly contribute to the worsening of these conditions (for example in relation to the impacts of construction).

192 TfL has accepted that the proposed mitigation is in principle sufficient subject to appropriate controls to make the development acceptable but is of the view that given the existing conditions in the area and the likely impact of the development the timely delivery of the mitigations works is essential. Consequently TfL has required, and the applicant has agreed through the s106 Agreement/conditions to commit to the following:

a) A Grampian Condition (see associated planning conditions) limiting development to 2,500 development units until such time as the bridge widening works have been completed;

b) A ‘reasonable endeavours’ clause to gain all ‘Necessary Consents’ and deliver the works earlier than the Grampian Condition;

c) A review mechanism (through the South Road Corridor Study) prior to implementation and every 2 years including prior to occupation of 1,500 dev units to assess and monitor impacts cumulatively;

page 55 d) An in lieu payment only on the basis that either the bridge can be delivered in a timely fashion by Ealing Council or that Alternative Mitigation Measures have been identified and will be delivered; and

e) Setting up of a ‘Bridge Task Force’ to help oversee the process

193 The reason for the reference to an in lieu payment or Alternative Mitigation Measures is that delivery of the South Road Railway Bridge works is reliant on a third party, Network Rail. There are no reasons to believe that this will frustrate the ultimate delivery of the bridge widening works, new bridges are common throughout London (for example the recently completed bridge linking Westfield Stratford with Stratford town centre, which spans Stratford Station). However it has therefore been agreed that if for reasons outside the applicants control the bridge cannot be delivered then Ealing Council and TfL will have the discretion to allow the applicant to instead make a payment (of an equivalent amount to the cost of providing the bridge) to Ealing Council or provide alternative measures but only if both the Council and TfL (having regard to the sensitivity testing the South Road corridor study and any measures proposed) are satisfied that any such payment/measures will enable suitable and sufficient mitigation to be put in place.

194 To help facilitate the process of designing the bridge and seeking to obtain the necessary consents from Network Rail, the applicant will convene, and where appropriate fund, the setting up of a South Road Railway Bridge widening scheme task force consisting of members from TfL/GLA/Ealing and the applicant and importantly Network Rail and Crossrail. The task force will seek to assist in the delivery of the bridge widening with the aim of mitigating the development and to ensure that the scheme is integrated with any Crossrail works.

195 The South Road bridge widening works will carried out in accordance with the above to ensure compliance with London Plan policies 3C.1 Integrating transport and development and 3C.2 Matching development to transport capacity and draft revised London Plan policies 6.1 Strategic approach and 6.3 Assessing transport capacity.

196 The additional junction works at South Road/Uxbridge Road, triggered delivery of three junction improvements along South Road prior to the bridge widening and required delivery of the South Road bridge widening have been negotiated since Ealing Council made its decision and are considered to satisfactorily address the Council’s reason for refusal.

Highway Impact: Hillingdon

197 Hillingdon Council raised concerns about highway impact on the A312 Hayes Bypass in particular the saturation level southbound in the PM peak and general adverse traffic conditions on the surrounding highway network. TfL note that the applicant has incorrectly stated that there will be nil detriment on the highway network. Despite this TfL is satisfied that the additional traffic impact generated by the development on the A312 is within acceptable levels when considered against the proposed highway improvements, which will adequately mitigate the impact of the development.

198 Therefore TfL considers that it would not be appropriate to re-open discussions on this part of the highway network and is not convinced that a corridor study similar to that which TfL is proposing at the eastern gateway would add benefit to the development proposals. TfL therefore concludes that highway impact on the A312 Hayes Bypass can be addressed through detailed section 278 design and negotiations, acknowledging at this stage that the principal highway works are acceptable for the purpose of granting outline planning permission.

199 Monitoring of construction impact, traffic management and the Area Wide Walking and Cycling Study together with and proposed mitigation must be undertaken and will be secured by

page 56 planning conditions and obligations in the section 106. Hillingdon Council will have the opportunity to make representations upon production of monitoring reports and construction management measures through its involvement in the TRG and expenditure of the transport management fund.

200 TfL is satisfied that the application does comply with London Plan policies 3C.1 Integrating transport and development and 3C.2 Matching development to transport capacity and draft revised London Plan policies 6.1 Strategic approach and 6.3 Assessing transport capacity.

Construction Impact

201 TfL requested at Stage 2 that a more detailed construction programme and impact assessment be provided, but in doing so accepted that this could be more robustly assessed in the future but prior to implementation of the development and key transport infrastructure and development impact being felt on the network.

202 The applicant has included in the transport assessment an assumption for construction traffic by applying 10% uplift in peak hour spreading. This is considered a reasonable starting point but does not provide for potential peaks and troughs in construction traffic throughout the construction period. In order to manage these impacts the applicant will jointly covenant with TfL and the Council in preparing and agreeing construction impacts and mitigation through a construction management plan. The plan will include rigid controls requiring trips to be off peak and limits on peak hour trips, it will include further construction impact assessment and a mechanism to agree construction routes and trip generation and distribution. An on-site construction consolidation centre will also be vital in limiting construction impact.

Car parking

203 The level of car parking for residential and non-residential and employment uses has been the subject of continuous debate between TfL and the Council(s) and has been raised in both Stage One and Two reports.

204 The parking ratios are set out in the planning conditions. The residential parking ratio is considered to be high for a proposed Opportunity Area and TfL is disappointed that the ratio is not below a maximum of 0.7 spaces per unit particularly with the high levels of congestion in the area. However, TfL will on this occasion accept this ratio on the basis that there is strong local pressure to provide parking due to current ownership and demand in the area. The applicant has also prepared a viability assessment that demonstrates that the development would not be viable with a lower residential car-parking ratio.

205 For retail parking, TfL raised concerns about the number of car parking spaces. Southall town centre currently has a shortage of car parking spaces and the draft revised London Plan accepts that in some cases parking will be necessary to support future retail growth. An additional 830 spaces will be provided for the retail, cinema and office uses and 122 spaces for the hotel and conference centre.

206 In order to manage these impacts the applicant will jointly covenant with TfL and the Council in preparing and agreeing car parking through a site wide car and cycle parking strategy. The strategy would include monitoring of car ownership and car usage based on the existing users and new users of the site. The strategy must allow for a parking review mechanism based on ongoing monitoring of the highway network; where conditions are worse than those predicted in the transport assessment it must be accepted that lower car parking or car free development will be appropriate. Accordingly the planning conditions include an appropriate caveat to allow for lower parking numbers.

page 57 207 A car club of 50 spaces will also be secured in the s106 agreement and will be funded at the cost of the developer, because the car club represents ‘on site travel planning measures’ the cost will not be drawn down from the transport management fund. TfL will have a role in approving details of the car club. This is welcomed by TfL.

208 Subject to the above matters being satisfactorily resolved through the s106 agreement this will ensure conformity with London Plan policies 3C.23 Parking strategy (inc Annex 5) and 3C.24 Parking in town centres and draft revised London Plan policy 6.3 Parking.

Electric Vehicles

209 The applicant has agreed to provide electric vehicle charging points and parking in accordance with the Mayor’s objectives having regard to the London Plan. This level of provision will be secured in the s106 agreement. Electric vehicle charging points will be provided at the cost of the developer and not from the transport management fund.

210 Electric vehicle charging points have been secured in the s106 agreement in line with the Mayor’s Electric Vehicle Delivery Plan and draft revised London Plan policy 6.3 Parking. This is welcomed by TfL.

Cycle parking

211 The applicant has agreed to provide cycle parking in accordance with TfL (and the Mayor’s) cycle parking standards as referred to in the London Plan and draft revised London Plan. This is secured in the planning conditions. All details relating to cycle parking must be in accordance with the provisions to be approved under the section 106 agreement and site wide car and cycle Parking management strategy.

212 The applicant must also procure and fund a cycle club to be managed on site, which would at some point in the future allow for the Mayor to use as part of the Mayor’s cycle hire scheme. This is welcomed by TfL.

213 All details relating to the design and location of cycling facilities will be agreed by the council in consultation with TfL. This is secured in the planning conditions.

214 Subject to the above the application is in general compliance with policy 3C.23 Improving conditions for cycling and draft revised London Plan policy 6.9 Cycling. This is welcomed by TfL

Walking and Cycling

215 At Stage 1 and 2 TfL reported that insufficient work had been done in relation to walking and cycling. While it was accepted that the site itself would provide high quality links and access, the wider networks had not been audited.

216 In particular TfL wishes to see a review of the predominant walking and cycling routes up to 1km from the site boundary. This will include condition of routes using the PERS methodology, for example condition, security, DDA compliance, wayfinding, widths and materials will all be considered.

217 In order to address this concern the applicant has agreed to an obligation in the s106 agreement which requires an ‘area wide walking and cycling study’ to be prepared prior to implementation, the scope of which must be agreed with TfL and the Council(s). The applicant has agreed to fund appropriate mitigation as identified in the study.

page 58 218 This has ensured general conformity with London Plan policies 3C.22 Improving conditions for walking and 3C.23 Improving conditions for cycling draft revised London Plan policy 6.9 Cycling and 6.10 Walking.

Buses

219 At Stage 2 TfL reported that the bus network improvements proposed by the developer were acceptable and had been robustly assessed and agreed with all parties. The detailed bus triggers and requirements will be included in the s106 agreement.

220 A ring-fenced contribution of £6,600,000 (index linked) has been secured to pump prime the bus network. The applicant will make this payment in instalments to TfL who will in consultation with the relevant Council be able to spend the monies on routes and bus services serving the development as felt appropriate. Further details will be confirmed through completion of the s106 agreement. This is welcomed by TfL.

221 TfL will in consultation with Ealing and Hillingdon through the TRG have the final determining view on the routes and payment method. Further details will be confirmed through completion of the section 106 agreement.

222 In addition, the developer will fund the cost of the South Road bus priority scheme, through funds drawn down from the transport management fund the cost of these works will deliver best value and any unspent monies will be returned to the transport management fund.

223 A strategy for buses and payment of bus contributions will require ongoing engagement to ensure compliance with London Plan policies 3C.4 Land for transport and 3C.14 Enhanced bus priority, tram and busway schemes and draft revised London Plan policies 6.2 Providing public transport capacity and safeguarding land for transport and policies 6.7 Buses, bus transits, trams.

Crossrail

224 At Stage 2 TfL reported that the application would need to have full regard to the Crossrail project to ensure that the Gas Works site and works associated with Crossrail would complement each other. Appropriate planning conditions have been included and agreed with TfL which provide adequate controls. Crossrail will provide additional capacity relief to existing services which suffer from congestion during peak periods.

225 TfL also reported that the site was within 960m of a Crossrail station, which under the Crossrail SPD (and associated London Plan Alteration), would give rise to a Crossrail contribution. The requirement to provide a contribution is triggered by office development and following the Examination in Public Panel report, retail and hotel uses have been added. This would give rise to a contribution, however, at Stage 2 TfL and the GLA did not consider that it would be appropriate to request a Crossrail contribution on the basis that the application had been determined by the local authorities in November 2009 and the matter had not been raised by the Mayor at Stage One and Two.

226 Because of the position stated above it is not considered that draft revised London Plan policy 6.5: Funding Crossrail and any other strategically important transport infrastructure or the emerging Supplementary Planning Guidance: Use of planning obligations in the funding of Crossrail, are relevant to this application.

Servicing and delivery strategy

page 59 227 The Stage 2 report requested further information on servicing and delivery of the site and the need to prepare a comprehensive site wide strategy.

228 Since then the applicant has added a servicing and delivery section to the framework travel plan (FTP). The applicant will provide appropriate measures to manage and consolidate deliveries to the site through implementation of the FTP and individual travel plans. This is welcomed by TfL who will have joint approval of the FTP.

Travel Plan

229 The applicant has prepared a Framework Travel Plan (FTP) which required some further work before being considered to be acceptable. As a result a revised document was prepared in February 2010, however this will still need to be further revised and agreed with TfL and the Council prior to occupation of the development through the section 106 agreement. For example, TfL will expect further review of the mode shift through ongoing monitoring.

230 To ensure the green travel plan measures are acceptable and appropriate for this development the FTP must be agreed jointly by TfL and the Council prior to implementation through the s106 agreement. The FTP will continue to operate beyond completion of the development. Measures must include subsidised travel for residents, travel centre, a cycle club, car club and other monitoring and marketing initiatives. This will require funding to be made available by the applicant. The applicant must fund all on site FTP measures outside of the proposed Transport Management Fund, with all external measures being drawn down from the fund. This will be secured through the section 106 agreement.

231 FTP measures will also be discussed through the transport review group (TRG).

232 These objectives must be met to ensure compliance with London Plan policies 3C.1 Integrating transport and development and 3C.2 Matching development to transport capacity and draft revised London Plan policies 6.1 Strategic approach and 6.3 Assessing transport capacity.

Public Transport Strategy

233 The applicant has covenanted with TfL and the Council through the s106 agreement to prepare a multi-modal public transport strategy including separate provisions for rail, buses, cyclists, pedestrians. This is welcomed by TfL and will provide the overarching strategy for implementation of the scheme. The applicant will review and update the strategy on a regular basis and will agree the scope with TfL and the council.

234 These objectives must be met to ensure compliance with London Plan policies 3C.1 Integrating transport and development and 3C.2 Matching development to transport capacity and draft revised London Plan policies 6.1 Strategic approach and 6.3 Assessing transport capacity.

Summary

235 Transport for London has considered carefully the reasons for refusal cited by Ealing and Hillingdon Councils and in collaboration with the two local planning authorities has proposed a number of changes to the application as submitted, which were deemed necessary to make the application comply with the London Plan, in particular policies 3C.1 Integrating transport and development and 3C.2 Matching development to transport capacity and draft revised London Plan policies 6.1 Strategic approach and 6.3 Assessing transport capacity.

page 60 236 The proposed development will be constructed and occupied over a number of years and in order to ensure that TfL has an ongoing role in reviewing and ensuring that the developer is committed to provide mitigation in advance of or concurrently with development, the council and the applicant have agreed to make TfL a signatory to the Section 106 agreement. As a result TfL has requested that it has a joint role in preparation of a number of key studies and strategies including public transport, walking and cycling, construction management, car and cycle parking and future monitoring.

237 TfL is now satisfied that the developer has proposed appropriate and timely mitigation measures having agreed to build new junctions and make necessary improvements to existing parts of the network. In particular, TfL has identified that South Road will need to be the subject of ongoing monitoring which may give rise to additional traffic management measures and mitigation or changes to the timing of key infrastructure. The developer has now agreed to a Grampian condition restricting development beyond 2,500 development units until the South Road railway bridge widening has been completed. £6.6m will be invested into the bus network and the site will benefit from Crossrail from 2017. In addition, a transport management fund of £3.55m will be provided including a contingency transport fund to pay for supplementary mitigation measures and to fund the South Road bus priority scheme. The developer has also committed to a number of green travel planning measures which include car clubs and cycling facilities which will funded outside of the s106.

238 TfL is now satisfied that all the issues raised in the Mayor’s Stage One and Two Reports have now been resolved and no longer objects to the planning application on transport grounds. TfL will work closely with the Council(s) and TfL in completing and implementing the Section 106 agreement and will have an ongoing role in future reserved matters applications.

Green Belt

239 The part of the application site located in the London Borough of Hillingdon is designated Green Belt and therefore national government guidance in ‘Planning Policy Guidance 2: Green Belts’ (PPG2) is relevant. Paragraph 3.12 of PPG2 outlines that engineering and other operations, and the making of any material change in the use of land are inappropriate development unless they maintain openness and do not conflict with the purposes of including land in the Green Belt.

240 Policy OL1 of Hillingdon’s UDP reiterates PPG2 guidance and in addition to the above, London Plan policy 3D.9 ‘Green Belt’ states that “There is a general presumption against inappropriate development in the green belt, and such development should not be approved except in very special circumstances”.

241 This proposal for new road and bridges on Green Belt is therefore an inappropriate development, and in such cases there needs to ‘very special circumstances’ to justify inappropriate development. PPG2 paragraph 3.2 states “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”. Firstly, the new Pump Lane road extension, linking Pump Lane and the Hayes Bypass, would be a principal access road that is key for the constrained application site being brought forward for development. Without this access the proposed development on this identified opportunity site would not be possible, and the regeneration benefits including affordable housing of sub-regional importance would be lost. The strategic importance of this new access through the Green Belt has been strengthened further by policy AM4 of Hillingdon’s UDP 2004, which safeguards this land for new road link between Hayes by- pass and the application site. This policy was saved following Examination in Public in 2007 and is material consideration of significant weight. In this regard a clear very special circumstance does

page 61 exist. Additionally, the historic permission for a new link, following an appeal, for the road is also a material consideration.

242 With regard to the two pedestrian and cycle bridges, namely Springfield Road and Minet Country Park bridges, these would traverse the canal and Yeading Brook within the Green Belt. Hillingdon Council have always recognised that these two bridges are also key to the delivery of the site and sought the future creation of such bridges within the original proposals in creating Minet Country Park in 2001. The application site and surrounding area is identified as having deficient access to nature and hence there is a very special circumstance to provide good access to the biodiversity value of Minet Country Park for the future residents of the proposal and wider Southall area in compliance with draft London policy 7.18.

243 Notwithstanding the identified very special circumstances and acceptability of the new road and bridges within the Green Belt, the impact of the new buildings next to the Canal upon the visual amenities of the Green Belt must also be considered. PPG2 states that the visual amenities of the Green Belt should not be injured by proposals for development within or conspicuous from the Green Belt which, although they would not prejudice the purposes of including land in Green Belts, might be visually detrimental by reason of their siting, materials or design. Hillingdon’s UDP policy OL5 echoes the PPG2. The proposed buildings along the western boundary of the site, overlooking the Canal, are closest to the Green Belt therefore may create potential harm. The outline nature of this application means that details relating to building heights and footprints are specified in maximum and minimum ranges. The residential and mixed-use buildings proposed adjacent to the canal could rise to between four to eight stories in height, and the proposed layout, at its closest point, sets the new buildings back from the eastern edge of Grand Union Canal by 8.5 metres.

244 The footprints of the Canal side residential blocks have been designed so only ‘fingers’ of the development would extend towards the canal. The residential courtyard gardens between these fingers are in effect, roof gardens over underground parking areas. The fingers could range between 13.5 and 16.5 metres in width and the courtyard space between each finger could range between 24 and 103 metres. Therefore the projecting fingers total only a small percentage of built elevations closest to the Canal. In contrast the deeply recessed and much wider courtyard elevations, in between each finger, would be further set back from the Green Belt and hence less visible and would not harm the visual amenity of the Green Belt. This recessing of the courtyard elevations significantly reduces the overall bulk of these buildings located in this sensitive part of the site.

245 In addition to careful building design to reduce bulk, the applicant also proposes significant landscaping with tree planting along the Canal towpath and within the recessed courtyards to act as a landscape buffer zone between the new buildings and the canal side environment and Green Belt beyond. The success of this landscaping is crucial and therefore there are conditions attached to ensure that these areas will be managed correctly and that all trees will be of good health and adequate size. It is not intended that the landscaping should completely screen the development but instead soften its appearance; as to completely screen it would miss this excellent opportunity to enliven the canal frontage with the creation of views across the canal into the Green Belt and vice versa. This relationship between new buildings and canal would provide excellent outlook and passive surveillance that would be a positive design outcome and help the creation of a secure and overlooked canalside environment.

246 Where landscaping is proposed above the parking decks, it is important to ensure that these are deigned to accommodate suitable structural planting. The material submitted with the application shows that this can be achieved and a condition is imposed to secure this.

page 62 247 To summarise it is recognised that the new development would be visible from persons using Minet Country Park, however this juxtaposition of buildings overlooking Green Belt or Metropolitan Open Land (MOL) in such an urban context like this is commonplace throughout London and the impact depends in part on the scale of the buildings, the quality of their design and the existing context that surrounds the Green Belt. This area of Green Belt is not physically connected to the wider Green Belt that surrounds London and has a distinctly different character because of its urban setting. A number of tall buildings and other buildings of varying design quality are already visible from the Green Belt including the Guru Nanak School to the north and the three 13 storey residential tower blocks of Glenister House, Fitzgerald House and Welling House located west across the Hayes Bypass. These tall buildings are very close and clearly visible from the Green Belt. Therefore the proposed height and massing of the development next the Canal and the quality of the design sought through the outline consent would not harm the existing character of the Green Belt subject to the landscape conditions attached, but would instead enhance the views to the Canal from within the suite and views from the Canal towards the site. Blue Ribbon network

248 Policy BE32 of Hillingdon’s UDP states that when considering proposals for development adjacent to or having a visual effect on the Grand Union Canal, the Council will among other things:

• Ensure that buildings are of a design, which complements the visual qualities of the Canal in terms of scale, bulk, layout and materials; • Take the opportunity to enhance or create views through and from the development, from and towards the watercourse; and • Secure and where possible enhance the role of the canal and its immediate surrounds as a wildlife corridor

249 Hillingdon UDP policy BE34 states that when considering proposals for development adjacent to or having a visual effect on rivers the local planning authority will, where appropriate, seek to enhance views from and towards the watercourse. The London Plan contains a chapter on the Blue Ribbon Network, however policies 4C.1, 4C.3, 4C.4, 4C.11, 4C.12 and 4C.14 are most relevant.

250 As already discussed with the Green Belt paragraphs above, the proposed buildings next to the Canal have been sensitively designed in terms of scale, layout and bulk as to complement the visual qualities of the canal. A landscape strategy will also act as an appropriate buffer between the new buildings and the canal, whilst also improving access along the canal frontage. The design would enhance views from the development across the canal and the proposed canal plaza would create a vibrant waterfront to enhance facilities and activities in the Blue Ribbon Network. A 4- metre wide wildlife corridor is also proposed along the canal and a mammal tunnel would supplement this. The canal side development would therefore enhance the character of the Blue Ribbon Network.

page 63 Biodiversity, ecology and nature conservation

251 The development would impact upon the ecological value of two Sites of Importance for Nature Conservation (SINC), both located in Hillingdon. One SINC is Yeading Brook Meadows (Metropolitan SINC), which is an extensive mosaic of unimproved meadow and pasture within the former flood plain of the Yeading Brook. This is the land located between the Canal and the Brook as described in detail under paragraph 277. It supports many breeding and over wintering bird species as well as breeding populations of great crested newt, and other important species. Part of this SINC is a Local Nature Reserve. The second SINC is Minet Country Park (Borough Grade I SINC), which is a large site containing mixed grassland habitats on former derelict land. The site is important for birds and bird watching and is known to support reptiles, amphibians, and an invertebrate fauna including five nationally scarce water beetle species.

Image 3: Hillingdon Council’s UDP proposals map showing the SINCs (denoted by black dots)

252 Policy EC1 of Hillingdon’s UDP make it clear that permission will not be given to development that would be unacceptably detrimental to sites of Metropolitan, or Borough (Grade I) Importance For Nature Conservation. This policy requires that applicants wishing to develop in or near ‘Nature Conservation Sites of Metropolitan or Borough Grade l Importance’ submit an ecological assessment to demonstrate that the proposed development will not have unacceptable ecological effects. Hillingdon UDP policy EC3 requires that proposals for development in the vicinity of sites of nature conservation importance to have regard to the potential environmental effects which may arise from the development. London Plan policy 3D.14 states that the ‘planning of new development and regeneration should have regard to nature conservation and biodiversity’, and this is reinforced by draft London Plan policy 7.19.

Ecological surveys

253 The applicant undertook bat surveys during September and October in 2004 and 2007, during weather conditions that were suitable for bat survey. Natural England has specific responsibility in England for nationally and internationally important nature conservation resources, including all native species of bat, and it has no objection to this development proposal in respect

page 64 of bats. However, to ensure bat activity is protected during and following development, an appropriate condition is attached.

254 With regards to birds there is no specific policy requirement to undertake bird surveys as part of an Environmental Statement although, where information is required to assess likely effects of the proposals, it may be beneficial. In this case, effects on breeding birds would only occur during construction works, therefore no further bird surveys should be necessary to determine the application. Nonetheless, the applicant has committed to undertake further surveys prior to any vegetation clearance during periods when birds are likely to breed. This is welcomed and will be specified within the Code of Construction Practice (as a responsibility to be managed by the Ecological Clerk of Works), and therefore conditioned.

255 In terms of reptiles, it is known that some grass snakes do occupy the site, although the applicant’s survey did not find any. Therefore further measures to be identified within an Ecological Management Plan are requested. The measures include the briefing of site personnel concerning identification of grass snake, legal obligations in respect of this species, and actions to be taken in the event of it being present and that the Ecological Clerk of Works undertakes regular checks for grass snake in areas prior to disturbance by construction workers or activities so as to ensure that incidental killing of grass snakes does not occur during the course of works.

256 The 2007 survey of water voles is considered appropriate, however as water voles are a species highly prone to move into and away from areas, it is requested that a repeat survey be undertaken of this area to confirm the continuing absence of this species from affected areas. This survey is secured by condition and managed by the Ecological Clerk of Works.

257 An assessment of invertebrate potential was undertaken in October 2004 and repeated in 2007, and the applicant has committed to additional monitoring for invertebrates, which will be conditioned.

Mitigation measures

258 Approximately 6.4 hectares of land will be required to create the Pump Lane extension, including connection to the Hayes bypass and a floodwater holding area and two pedestrian and cycle bridges over the canal. This development will have the effect of reducing and fragmenting wildlife habitat, however the Environmental Statement proposes mitigation measures to offset the loss of habitat and these include:

• A 4 metre wide buffer along much of the length of the eastern side of the canal; • A single mammal tunnel beneath the proposed Pump Lane extension; • Bat roosting boxes on bridge abutments; • Floodwater holding area serving as a wetland habitat; • Enhancements to Yeading Brook.

259 The 4-metre buffer strip represents a smaller habitat area than that which would be removed, but with appropriate management it can achieve greater long-term ecological value than what existed previously. It is recommended that a detailed Ecological Management Plan, with provisions to ensure that appropriate management and monitoring occurs in the longer term, is provided by the applicant to the satisfaction of the relevant nature conservation bodies prior to commencement of any construction works. This Ecological Management Plan is secured by condition.

260 The proposed mammal tunnel would not be essential to facilitate wildlife movement as the Pump Lane extension bridge abutments would be set back 5 metres from the watercourse edges of

page 65 both Yeading Brook and the Grand Union canal and would provide at least a 2.7 metre ground clearance. It is considered that mammals would continue to use the waterside routes connected to the buffer strip for movement. However the incorporation of the mammal tunnel is still recognised a positive addition as an alternative route.

261 The existing flood relief channel would be diverted, as part of works for the Pump Lane extension, to enter into a larger brook channel to the east of its existing channel. Both ground and surface waters would be largely protected from the effects of reduced quality road surface run-off by in-built design features such as storm drains with reed beds. The drainage design will channel surface waters from the road into a retention feature (hydro-brake) and then into a petrol interceptor to remove gross contamination before discharge to surface waters. These measures will be conditioned and will help reduce pollutants from road runoff and within the greater context of surface water flow regimes the overall effect will be negligible.

262 The proposed diversion of the relief channel positively avoids the need for culverting of Yeading Brook, with the channel diversion to replace the 225 metres of existing, highly engineered low biodiversity character concrete channel. The new channel will be diverted to the east of the existing channel into an open natural feature water course and that would converge with the brook just upstream of the Pump Lane link road. This would create a substantially beneficial effect on the water and ecological value of the local area. A commitment to management of these water features would be secured by condition within an Ecological Management Plan for the development.

Minet Country Park

263 Hillingdon Council confirm that significant improvements to the facilities in the park would be necessary to mitigate the impact of the proposal, including:

• Habitat creation and enhancement as compensation for wildlife habitat fragmented by bridges, the Pump Lane extension and altered and extended floodwater holding area; • Security measures; • Access ways, park furniture and facilities; • Maintenance and management; • Removal of waste and invasive species.

264 The Council requests a financial contribution from the applicant, through the section 106 agreement, to help implement the above mitigation measures. Considering that the Pump Lane extension would be built on land already safeguarded for road construction by Hillingdon Council, coupled with the ecological conditions secured, the applicant has offered a figure of £1,840,000 that is accepted as fair and reasonable for the improvement to the Park’s facilities and ecological mitigation. The impact of the development, in terms of increased footfall, on the park is discussed elsewhere in this report.

265 To summarise, the proposed ecological design features and Ecological Management Plan to be secured by conditions, coupled with the financial contributions towards Minet Country Park would ensure that the biodiversity impact of the development is minimised and mitigated as practically possible in compliance with draft London Plan policy 7.19. The two new cycle and footbridges, linking the development to the park, would reduce the Area of Deficiency in access to nature that affects the site, which is welcomed. The GLA biodiversity officers have reviewed the proposals and are satisfied that there would be no adverse impact on ecology or biodiversity. Trees

page 66 266 Ealing’s UDP policy 4.5 advises that landscaping schemes submitted with applications for development should ensure the identification and protection of existing vegetation of value. Policy 4.8 of the UDP provides protection of trees located within conservation areas. London Plan policy 3D.15 states the requirement that Boroughs should protect, maintain and enhance trees.

267 The existing trees on site are predominately located along the northern and southern boundaries. The trees along the northern site boundary, next to the canal within Ealing’s boundary are protected, as they are located within the Grand Union Canal Conservation Area. There are no protected trees within the Hillingdon site boundary.

268 The application proposes to retain all existing trees on site where practicable and proposes extensive replanting of the site as part of the landscape scheme, this planting will take the form of tree lined streets, boulevards, parks and along sections of the canal. Fifty-four trees are to be retained along the northern, southern and eastern site boundaries.

269 Neither Ealing nor Hillingdon Council’s has raised any objection to the loss of trees on the site and supports the extensive replanting proposed as part of the redevelopment of the site. However, Hillingdon Council has raised concern in relation whether trees could grow on the podium levels covering basement car parking next to the canal. In response the applicant has provided cross section drawings of these areas to illustrate how the trees could grow and a condition is attached to secure the management and health of these important structural trees. Additional conditions are recommended to ensure that the required tree protection measures are implemented and that details of the tree planting and management are secured.

Contamination and human health

270 PPS23 provides guidance on how the Government's policies for contaminated land are to be reflected in land use planning. Section 25 states that: “The remediation of land affected by contamination through the granting of planning permission (with the attachment of the necessary conditions) should secure the removal of unacceptable risk and make the site suitable for its new use.” London Plan Policy 4A.33 states that The Mayor will work with strategic partners to enhance remediation of contaminated sites and bring the land into beneficial use. Ealing UDP policy 2.7 requires assessment of land contamination when considering development proposals and, where necessary, requires satisfactory remediation of sites to address contamination.

271 The Environmental Statement addresses health and safety risks during construction, protection of quality of groundwater and removal of land gases. A Remediation Strategy has been developed in order to mitigate the identified risks posed by the presence of contamination at the site and would include controlled excavation of contaminated materials, on-site treatment of materials, removal and disposal of material and treatment of groundwater, as appropriate. It has been stated “further detailed studies would be completed prior to the commencement of the remediation, in order to assess the best and most appropriate on-site remediation treatment techniques”.

272 The Remediation Strategy would address both soil and groundwater contamination and the intention is to treat the majority of the contaminated material on the site with limited export of heavily contaminated material off site. The depth of remediation would vary throughout the site in response to the character of contamination, with excavation continuing until acceptable composition was achieved. Ground water remediation would concentrate on areas of significant contamination and would likely to be through steam injection with in-situ air sparging.

273 Air sparging is akin to blowing bubbles from a straw into a bowl of water. As the bubbles rise, the contaminants are removed from the groundwater by physical contact with the air (i.e.,

page 67 stripping) and are carried up into the unsaturated zone (i.e., soil). As the contaminants move into the soil, a soil vapour extraction system is usually used to remove vapours.

274 The main access to and from the site, including for vehicles removing the most heavily contaminated waste, will be via the new Pump Lane extension. Hillingdon Council’s Highways Engineer and Environmental Protection Unit have noted the other locations of the site’s access routes and taken account of concentrations of existing neighbouring residential development at these routes, and confirmed that the proposed use of Pump Lane as the main access to and from the site is most appropriate. However, conditions are imposed requiring the applicant to prepare a management plan setting out how traffic leaving site and travelling through the London Borough of Hillingdon, including vehicles transporting contaminated waste, are to be managed to prevent any contaminants from entering the environment. Further conditions are imposed to ensure the final Environmental Management and Monitoring Plan include measures to ensure the adequate monitoring of dust, vapours and odours is undertaken during the remediation works.

275 Ealing Council Environmental Health Officers are satisfied the remediation works can be completed subject to a condition to secure further detail and implementation of the proposed scheme of remediation. It is anticipated that the provision of such information could be in stages, as development of different areas of the site proceeds. Other heavily contaminated, former gas works sites in London, including Greenwich Village and Imperial Wharf (Fulham) have been successfully remediated to enable residential redevelopment.

276 To assist Ealing Council in overseeing the remediation process, as well as to offset public concerns associated with the development, the applicant has agreed to provision of £50,000 towards the part funding of an Environmental Health Officer post to monitor all remediation works to ensure best practise standards are met to protect human health.

277 The land between Yeading Brook and the Grand Union Canal has been excavated historically for gravels, and these soils were replaced with domestic and construction wastes, dredging and also gas works waste. Conditions are attached to ensure remediation works are carried out to clear the unsuitable soil for the bridge and road foundations to Hillingdon Council’s satisfaction.

Off-site contamination

278 The two proposed cycle and pedestrian bridges would traverse the contaminated land; commonly know as ‘Minet Tip’, between Yeading Brook and the Grand Union Canal, to allow direct access into Minet Country Park. Hillingdon Council contend that these new access ways would greatly increase the number of persons using Minet Country Park for recreational purposes, and consequently create significant health risk for users of the park to access heavily contaminated land. British Waterways, who own the majority of this contaminated land, have sought a £4 million planning obligation to ensure sufficient funding is secured to enable remediation of the contaminated Minet Tip land. Given the threat to human health posed by the contaminated land, the request from British Waterways is strongly supported by Hillingdon Council.

279 However, given that the park is already publicly accessible, then this contaminated land should be secured already to prevent those persons currently enjoying the park from entering the contaminated land. As the contaminated land is owned by British Waterways and located with Hillingdon it is therefore the responsibility of one of those parties to either securely fence or remediate the contaminated land, not the responsibility of applicant of the Southall Gas Works site. The £4 million planning obligation is therefore not necessary to make the proposed development acceptable in planning terms and not directly related to the proposed development, hence fails the policy test for seeking an obligation under Planning Circular 05/2005 Planning Obligations.

page 68 Gas infrastructure

280 London Plan policy 4A. 34 states that boroughs should take into account the presence of establishments where hazard substances are stored when determining applications. The Health and Safety Executive (HSE) is the statutory authority for development within consultation distances of major hazard installations. The operational gas works infrastructure on and adjoining the site, and both of the redundant gasholders on the application site, are listed as major hazards.

281 The ‘West Southall Masterplan; PADHI Report - October 2008’, produced for the applicant by Advantica assumes that HSE’s consultation distances around the Gas Works site and the Southall to Richmond pipeline should have changed because the two gasholders have been decommissioned and the pipeline is to be fully replaced. As a result, the report also assumed that the HSE would not object to the proposed development.

282 However, the HSE consultation response does object to the application because of the existing hazards listing for the site. This major hazard listing does not take into account the proposed upgrade of the Southall to Richmond gas pipeline into the site, or the removal of the two redundant gasholders. The HSE would require physical removal of the redundant gasholders and upgrade of the gas pipeline to be fully completed, and the major hazards listing then amended, before its statutory response could be reconsidered.

283 However, HSE’s preliminary assessment, based on the information contained in the Advantica report, confirms that it would not advise against the granting of planning permission were it consulted again over the proposed development when the changes to the hazards listing and the pipeline have been notified.

284 Considering that HSE would not object to the consultation distance if the hazard listing was updated, HSE have agreed in principle that Grampian planning conditions, requiring the applicant to satisfy the HSE requirements prior to first occupation of the development, would enable the development to progress, with the secured certainty of the developer undertaking the required work to amend the hazards listing for the site. This Grampian conditions ensures that the development complies with the HSE consultation distances of major hazard installations. Urban design

285 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 and views.

page 69 Image 4: Aerial view of proposed masterplan from the east (Source: MAKE Design and Access statement)

286 The site is flat and dominated by a listed Victorian Water Tower to the west and a large blue waterless gasholder at the centre of the site. The site is laid out to maximise views into and out of it from the existing town centre and from the Minet Country Park. The main high street is aligned on an axis with the Water Tower, which forms a focus in the view and makes the most of the most attractive heritage asset adjoining the site. A town square is located in the middle of the high street around which is located the hotel, conference/banqueting facility and the school. This area is of a similar size to Leicester Square and the courtyard of Somerset House.

287 The site plan is an extension of the Victorian Southall grid and this ensures that, as well as providing visual permeability, the site layout would be easy to understand and navigate and fits well with Southall’s existing urban grain.

288 New vehicular entrances are proposed to the east opposite the existing Southall train station and to the west across the Grand Union Canal linking with the Hayes Bypass. Two additional pedestrian footbridges would provide links from the site to the Minet Country Park and Springfield Road. These provide an access to nature, for both the proposed occupiers of the new development and those of existing communities to the east of the Canal who have to travel a considerable distance to access the country park at the moment.

289 The main access point to the east is formed by the demolition of an existing crescent of locally listed late Victorian terraced housing in order to form the new access road. In addition part of an existing park is used. Without this work it would be impossible to access the main development site and unlock its potential. There has been extensive discussion with the applicant about the design of this part of the scheme and how it could be integrated with the existing Southall grid of streets and terraced houses and new Crossrail station works at Southall, to present a well considered transition between the existing town centre and the new development.

290 The current proposals include the refurbishment of the remainder of the existing park and the development of new houses adjacent to the new access road to make it feel more like a normal London street and to provide overlooking for the park and the pedestrian route to Southall town centre. A new public space would be formed opposite the Crossrail station and there are ongoing discussions as to how this would be used. Overall the eastern entrance is well considered given the

page 70 current constraints to access that exist and the demolition of the locally listed buildings is considered acceptable, given the quality of the proposed replacement layout that would be achieved.

Image 5: Proposed view of new access road from Pump Lane (Source: MAKE Design and Access statement)

291 There is a mix of housing types across the site. The edges of the site comprise terraced houses with front and rear gardens and to the north of the site these back onto existing terraced housing along Beaconsfield Road. This ensures the development is well integrated with the existing townscape and would respect the immediate scale and massing of existing residential terraced housing.

292 The western Canal area comprises ‘C’ shaped blocks of flats with part basement car parking and private amenity space on the podium decks. Larger family duplex units would be located at ground floor/ podium level giving access to private amenity space. A condition is attached to ensure mature podium tree planting of at least 8 metre high trees.

293 The sectional relationship between the blocks and the towpath has been carefully considered to ensure that overlooking is achieved to ensure a sense of passive surveillance, whilst the delineation of private and public space is made clear. The landscaping is also managed to ensure that the edge of the car parking venting does not dominate the towpath and conditions are attached to secure the best quality hard and soft landscaping in this sensitive area of the site.

294 The canalside blocks, and those along the main high street axis, would potentially rise to 8- storeys maximum, whilst the connecting arms of the ‘C’ shaped blocks would fall to 4-storeys to ensure good light penetration of the internal garden spaces. The scale of the largest blocks and of the spaces between them is similar to that of the mansion blocks of Maida Vale and the proposed high street is of a similar scale to the Victorian terraces of Paddington at Sussex Gardens and Westbourne Terrace. The latter are listed and within conservation areas, and although the architectural detail of the current proposals would be subject to further detailed applications, their overall scale and layout should provide the basis for a high quality mixed use environment, with comfortable human scaled urban spaces.

295 The centre of the site is dedicated to park space that includes a village green, cricket pitch, seven hard surface pitches to be shared with the proposed junior school, ornamental gardens, community gardens and a wetland area with boardwalks.

page 71 296 A landmark tall residential building of up to 13 storeys (plot HS.15) and landmark hotel building of 11 storeys (plot HS.02) are proposed to front onto the main town square. These tall buildings would provide a point of orientation in one of the key vistas within the site that lead you from the town centre past the listed Water Tower and into the heart of the development. The buildings would be visually lower than the existing blue gasholder and are of an appropriate scale and proportion to the town square and are located at the centre of the site away from the more sensitive edges to of the Minet Country Park and the existing residential communities. The buildings should provide an attractive landmark element within the development that complements the Water Tower to the east and the open spaces, in which it is located and visible from. The buildings meet the requirements of policy 4B.9 and 4B.10 of the London Plan Tall buildings location and tall buildings design and impact.

297 The car parking strategy for the site has been well considered with a mix of on street and off street parking, which ensures that street scene character would not be dominated by large areas of surface car parking, whilst ensuring that the streets appear as normal London streets.

298 The indicative flat layouts show a mix of dual and single aspect units with due north single aspects being generally avoided. Long internal corridor runs are also avoided with regular core spacing and front doors for flats that face onto streets. A good deal of care has gone into this aspect of the scheme, which is welcomed and forms a sound basis for discussion at the approval of details stage, when the Mayor’s new Housing SPG will have been fully adopted.

299 As this is an outline application many benchmarks have been secured in the supporting design strategy and the applicant has provided these in a clear and thorough way. As the various reserved matters applications come forward they will have a number of different architects working up details of individual blocks. This approach will ensure a rich variety of architectural approaches.

300 Overall this is one of the most humane and well thought through master plans for a large site that has been considered by the Mayor, especially given it’s current constraints. The application complies with the London Plan and Ealing Council’s UDP in design terms.

Heritage

301 PPG15, London Plan policies 4B.11 to 4B.13, draft London Plan policies 7.8 and 7.9, and Ealing Council’s UDP policies 4.6 and 4.8 all identify the need to protect or enhance London’s historic environment. In particular PPG15 identifies the need to pay ‘special attention to the desirability of preserving or enhancing the character or appearance of a Conservation Area’. Draft PPS15 also introduces the concept of heritage assets and designated assets and expresses desirability of enhancing the significance of heritage assets, respecting the setting and reinforcing the distinctiveness of the asset.

302 The Victorian Water Tower, which has been converted to residential use, is the only listed building on or within the immediate vicinity of the site. The setting of the listed building currently comprises the ends of the terraces of the Southall grid, the locally listed crescent buildings, the railway line and the unkempt scrubland adjoining immediately to the north and west. The locally listed crescent complements the setting of the listed water tower in terms of the scale age and character of the respective buildings. It is therefore important that any scheme which removes the crescent buildings is carefully designed to ensure that it doesn’t harm the setting of the retained listed building, and that any new buildings on the gas works site achieve a similar end.

303 The eastern boundary would be the point at which the eastern access road enters the site and the road, and associated open space, would be subject of a high quality landscaping to ensure that the access point is well integrated into the existing townscape grid and preserves the setting

page 72 of the listed Water Tower building. An east bound bus only lane would be created to the north of the building. The design of this part of the scheme has been the subject of extensive negotiation with the applicant, particularly around the demolition of the locally listed crescent. The proposals would open up views of the Water Tower from Southall station and although the crescent would be removed, the new road will be edged in part with new buildings to give the appearance of a street. This combined with the proposed tree planting and landscaping should provide a good quality townscape setting for the listed building, and is not considered to harm its setting.

304 A small-scale office/retail pavilion is proposed to the immediate west of the Water Tower to a maximum height of 9 metres and this would be in the form of a high quality pavilion structure. The other buildings closest to the Water Tower comprise the cinema and office retail units of 4 to 5 storeys. The pavilion and other building heights have been kept low to ensure that the Water Tower remains as a landmark feature when viewed from within the site, and subject to the submission of design details at a later stage it is considered that the setting of the listed building would be preserved. As such the Water Tower’s setting would not be harmed by the alterations to the road layout, the demolition of the locally listed terrace or the construction of the pavilion building and other buildings within the development.

305 The Grand Union Canal is designated as a conservation area in Ealing. Currently the site boundary with the Canal is comprised of an unattractive and imposing 2-metre high boundary structure, creating a physical and visual barrier between the canal and the site. This boundary barrier significantly harms the character and appearance of this section of the conservation area, particularly in terms of preventing views from the canal towards the site.

306 The proposed development would remove this barrier and instead introduce residential development of up to eight storeys in height fronting onto the Grand Union Canal. These buildings on a vacant site would inevitably result in a significant change in the character of this length of the Canal; however, a new more open and active canalside would be created between the residential buildings and the Canal with a minimum 8.5-metre separation distance found only at the building’s projecting fingers. The majority of the building lines to be significantly set back from the Canal’s edge by at least 16.5 metres.

307 In addition to the significant set back of these buildings, the canal side would also be appropriately landscaped; including the provision of a 4 metre wide ecological buffer for wildlife movements, to sensitively mitigate the new buildings impact on the conservation area. A proposed canalside recreation area towards the northern end of the site would provide a more open area with a greater set back up to 67.5 metes from the Canal, with cafe and restaurant uses to revitalise and activate the Canal’s frontage.

308 The development would present an active frontage to the Canal, and would provide pedestrian and cycle links onto the canal throughout the development. Currently the only public access to the canal at this point is via a narrow dogleg shaped footpath at the end of Beaconsfield Road, between the site and Blair Peach Primary School. The proposed pedestrian and cycle routes will provide a vastly improved access to the canal for both prospective residents of the development and existing residents to the north and south of the application site (the latter having no access at present). The separation between the buildings would provide eastward views from the canal and a visual link with the main development.

309 Overall, the development would provide a more attractive environment for users, with increased openness, permeability, connectivity and natural surveillance of the area. While the proposed development would result in significant change to the character of this part of the conservation area, it is considered that this a positive change that would enhance the character and appearance of this section of the canal.

page 73 Archaeology

310 The site contains no Scheduled Ancient Monuments, Registered Parks or Gardens and is not located within an Archaeological Interest Area. However PPG16, London Plan 4B.15 along with Ealing’s UDP policy 4.9 seek to ensure that development proposals do not have an adverse impact on archaeological remains. In this regard the Environmental Statement submitted presents the findings of an Archaeological Desk Based Assessment undertaken by the Museum of London Archaeological Services (MoLAS) in March 2008, a Ground Conditions Report (2000), a Remediation Strategy (2008) and an Archaeological Mitigation Strategy prepared by RPS in August 2008.

311 The archaeological evaluation methods suggested in these assessments include geo- archaeological boreholes and trial trench evaluation. The Remediation Strategy divides the site into 12 zones and suggests archaeological mitigation measures for each of these zones.

312 The English Heritage Archaeology Adviser does not consider that any further work needs to be undertaken prior to determination of the planning application, but that the archaeological position should be reserved by attaching a condition to any consent granted. The investigation and remediation strategies proposed are considered acceptable and it is recommended that these are adopted as initial archaeological works.

313 English Heritage request that the archaeological strategy should be tied in with the detailed Remediation Strategy, and that no remediation should take place until this has been agreed as part of the Written Scheme of Investigation. It is also recommended that a condition be attached to secure the recording and analysis of the two redundant gasholders and this has been included as part of the formal recommendation. These conditions would ensure that there will be no archaeological harm. Secured by Design

314 Ealing Council’s UDP policy 4.4 requires the design and layout of new development to be based on the promotion of a safe and secure environment. London Plan policy 4B.6 states development should be safe and secure taking account the objectives of ‘Secured by Design’, ‘Designing out Crime ’and ‘Safer Places.

315 As an outline application, only limited assessment of the safety of the scheme can be undertaken at this stage. However, the applicant has provided detail of the design approach to maximise the passive measures to design out opportunities for crime within the development. This is achieved through the organisation and connection of spaces within the development and the provision of extensive natural surveillance of public realm areas from residential windows.

316 Accompanying the crime prevention design measures, the Development Specification and General Management Strategy Document refers to a network of monitored CCTV throughout the site and the provision of site security patrols.

317 Ealing Council’s Metropolitan Police Crime Prevention Design Adviser (CPDA) reviewed the application scheme and confirmed that no significant issues arise from the proposal. Specific comments from the CPDA relate to the provision of a suitable CCTV on the site, and that this is linked to the Ealing Council’s CCTV control room to enable continuity of coverage (to enable targets to be followed within and outside the site), requirement for suitable lighting through the scheme. The CPDA also recommends that the school and car parking areas should conform to the specific police guidance for these uses. The CPDA is satisfied that assessment of the detailed design can be considered at various reserved matters stages to ensure that the emergency services

page 74 communications (airwave) network would function throughout the site, or identification of remedial measures to ensure coverage was provided would be necessary.

318 It is welcomed that the detailed design of the defined ‘crowded places’ within the development, such as the cinema, will be assessed against specific counter terrorism design measures. Furthermore, the passive surveillance along the canal from the new buildings that would overlook it would significant increase security. This would also be true for the Minet Country Park, which would be overlooked by residential windows.

319 To ensure that the scheme embraces advancing crime prevention design techniques and technology, it would be appropriate for the development to commit to compliance with the Metropolitan Police Secure by Design scheme of accreditation.

320 The Metropolitan Police Authority (MPA) have also responded to the application advising that development of the scale proposed would have significant implications on the resources of the MPA in seeking to ensure the provision of a safe and secure environment. On this basis, the MPA have sought provision of a safer neighbourhood team base (of approximately 200 sq.m), with a public contact counter point, positioned in an accessible and visible area within the development. The applicant has agreed to the provision of such a unit within the scheme for this purpose. This unit would have a value of approximately £350,000 and is secured by means of section 106 agreement.

Open space

321 Draft London Plan policy 7.18 seeks to ‘ensure that future open space needs are planned for in areas with the potential for substantial change such as Opportunity Areas’. This application site is within Southall Opportunity Area and hence a quantum of open space is proposed that would equate to 24.4 hectares. This would include 4.6 hectares as communal garden space and 13.5 hectares as public open space. An additional 2.5 hectares of children’s playspace would be provided on top of the open space provision. The largest area of open space, ‘central park’, would be located on the area of the redundant gasholders and infrastructure to be removed and would include a village green/cricket pitch, seven sports pitches, community gardens, an ornamental garden and a wetlands with board walks for inclusive access.

322 Unlike children’s play space there is no policy guidance for calculating the exact open space requirement for large residential proposals like this, however Ealing’s UDP policy 5.5 states that at least 75 sq.m of garden space should be provided for a group of five flats. If this site was developed with the maximum 3,750 units then crudely applying policy 5.5 would calculate 5.625 hectares of communal garden space being required across the site. The development’s provision of 4.6 hectares would fall only roughly 1 hectare short of the policy 5.5 requirement, however, if the additional 2.5 hectares of children’s play space and likely private balcony areas are added to the crude calculation, it is highly likely the proposed communal garden space would adequately serve all prospective residents within the boundary of the application site.

323 This quantum of communal garden space must also be considered alongside the 13.5 hectares of public space to be provided across the site, which would further cater for all the future residents amenity space needs within the site.

324 Furthermore, the new open spaces would also benefit the existing residents to the north of the site and those to the south of the railway line via significantly improved pedestrian and cycle subways at Brent Road and Dudley Passage.

325 Notwithstanding that the development would likely provide acceptable levels of open amenity space within the site, it is proposed to provide access between the development site and

page 75 the Minet Country Park, located in Hillingdon. Two proposed bridges, that would span the Canal and Yeading Brook, would facilitate pedestrian and cycle access to this area of Green Belt, which is designated as a District Park. London Plan policy 3D.11 describes such parks as having a ‘landscape setting with a variety of natural features providing for a wide range of activities’. Minet Country Park would therefore provide an alternative type of open space, with access to nature, to the open space that would be provided on the site.

326 The completed development is likely to result in extra people visiting the park in numbers and frequency comparable to the use by existing Hillingdon residents that live nearby, which is positive. However, given the schemes phased build out time of over 20 years, coupled with the onsite open space provision to accompany each phase; it is not likely that there would be a significant intensity of visitors from the applicant site to use Minet Country Park. Throughout the build out, visitor numbers would only incrementally increase in an appropriately sensitive way as to not harm the amenities of the park.

327 It is important to note that the Minet Country Park is not laid out and managed as a formal park (unlike Battersea Park or Victoria Park for example) and there is no reason to suggest that Minet Country Park would need to be laid out or managed as such as a result of the extra visitors from the gas works site, since all of their formal recreation will take place within the application site.

328 For this reason it is not envisaged that the facilities of the country park would require significant upgrade or improvement to achieve the ‘best practise quality standards’ that only a Metropolitan Park would require. Such an upgrade of facilities would change the character of the Minet Country Park’s current designation as a District Park and draft London Plan policy 7.48 clearly states ‘replacement of one type of open space with another is unacceptable unless an up to date needs assessment shows this would be appropriate’. Furthermore, Hillingdon Council would need to prepare an Open Space Strategy as part of the assessment to re-designate the park. To conclude, the District Park designation of Minet Country Park should not be affected by the proposed development, and should Hillingdon Council seek to upgrade the park to Metropolitan Park standard, the process must follow London Plan policy.

329 Considering the above, the developer has duly recognised that visitor numbers to the country park will increase as a result of the development and have offered Hillingdon Council £1,840,000 through a section 106 contribution to undertake any necessary ecological mitigation and facility improvements. However, the visitor increases would not be significant enough as to require an upgrade to a formal park and therefore this financial offer is seen as very positive and would maintain the health of Minet Country Park’s designation as a District Park, which is an important resource of alternative open space with access to nature for the local community. It must be noted that Hillingdon Council had secured no money for the park and therefore this generous offer is considered to satisfy all the Council’s concerns in relation to their asset. Access and inclusive design

330 Ealing’s UDP policy 4.3 requires new development to be designed to be accessible for all and policy 5.3 requires all new residential units to be constructed to Lifetime Homes standards, and for 10% of new units to be designed to wheelchair housing standard. These requirements are endorsed in London Plan Policy 3A.5 which, in addition, seeks to ensure that new developments offer a range of housing choices, in terms of the mix of housing sizes and types, taking account of the housing requirements of different groups. London Plan policy 3D.7 states that there is a shortfall in the supply of wheelchair accessible hotel rooms across London, which is an increasingly important issue to address in advance of the London 2012 Olympic and Paralympics Games. The policy goes on to state that Councils should support an increase, and improvements to, the quality

page 76 of fully accessible wheelchair hotel rooms. Draft replacement London Plan policy 4.5 states that a minimum of 10% of hotel rooms are required to be wheelchair accessible.

331 The Development Specification document advises that the residential component of the development would be designed to comply with as many of the Lifetimes Homes standards as practicable. A condition is attached to ensure all sixteen standards of Lifetimes Homes would be achieved for all residential units. Likewise a condition is attached for a minimum of 10% of all new residential units to be provided to wheelchair accessibility standard across all tenures and sizes.

332 The applicant has committed to provide 10% wheelchair accessible hotel rooms, which positively exceed the minimum 5% required by Building Regulation requirements. This 10% figure will be secured by condition.

333 In terms of car parking, Ealing’s UDP policy 9.7 requires new development to make a minimum provision of blue badge car parking spaces. For example Ealing’s current parking standards requires a minimum provision of one blue badge parking space per ten dwellings, which equates up to 375 designated spaces. These standards could change during the lifetime of the proposed development therefore a condition is attached to ensure an acceptable level of blue badge car parking is provided during each phase of development in compliance with the standards at the time of the reserved matter application. This will apply to all proposed land uses on the site.

334 The inclusive design of the all public realm and children’s play space within the site will be appropriately considered at detailed design stage, however Ealing Council’s Accessibility Officer identified requirement for an alternative wheelchair access to the Springbridge Road pedestrian and cycle bridge which is secured by condition. Detailed consideration was also given to the new eastern access onto South Road, given the significant level change. Various alternatives were discussed with the GLA’ access officer and the chose option is considered the best solution. Given the outline nature of the application limited detail on the inclusive design aspects of the public realm and buildings are provided, therefore an appropriate condition is attached to secure inclusive design strategies prior to each development phase.

335 To maximise accessibility opportunities for visitors to the town centre element of the proposal, the applicant has agreed to a Section 106 contribution of £360,000 towards the establishment and operation of a Shopmobility scheme for four years, which is supported. Air Quality

336 London Plan policy 4A.19, Ealing’s UDP policy 2.6 requires the potential impact of a development on air quality to be considered. The London Borough of Hillingdon is also designated an Air Quality Management Area.

337 There are two aspects to the consideration of the air quality impacts arising from the scheme; firstly the resulting air quality within the scheme and secondly the impact of the scheme on air quality beyond the site boundary. The most significant impacts on air quality would arise from the energy strategy implemented on the site and the traffic generation resulting from the development.

338 While the impact of decentralised energy production on the site was recognised as a significant potential source of air pollution, it is considered that adequate measures could be provided to minimise and mitigate this impact.

339 While specific measures could be applied to the identified air pollutant sources relating to the energy strategy, such measures would be more difficult to apply to the emissions from general traffic associated with the site. Consequently, the Environmental Statement concludes that there

page 77 will be a moderate to substantial adverse impact at a number of locations to the east of the development site arising from road traffic pollutant emissions.

340 However, in accepting these findings of the Environmental Statement, it is noted by Ealing Council’s Senior Scientist that air quality modelling prediction involves considerable uncertainty, and that this uncertainty increases with the extent of forward projection. Accordingly, the modelling could be based on overly optimistic back ground air quality assumptions for 2025, and that there could be substantially more affected receptors.

341 To mitigate the potential air quality impact, the applicant has proposed a contribution of £664,000 to Ealing Council towards the establishment of a Low Emissions Strategy for West Southall, coupled with wider measures including air quality monitoring. The applicant has also pledged £50,000 to Hillingdon Council for air quality monitoring.

342 A range of measures would be developed within the Low Emissions Strategy, with the overall aim of reducing motor vehicle emissions. The financial contribution would ensure that Ealing Council, as the regulator, was appropriately resourced to assist in the implementation of the strategy. This proposal is considered to be a very positive step towards mitigating the air quality impact of the development. In recognition of this, Ealing Council’s Senior Scientist has stated support for the proposed approach. The strategy would be fully secured by section 106 agreement.

343 The study concludes that during the construction phases, the development may have some adverse impacts in terms of dust emissions. This matter is controlled by a construction management scheme condition.

344 Ealing Council’s Senior Scientist concludes that this development is acceptable, subject to the Low Emissions Strategy, and is appropriate and does not raise any concerns. The Greater London Authority has no sound planning reason to disagree with this recommendation subject to the condition attached. Accordingly, on the basis of the proposed mitigation approach, the air quality impact of the proposed development is considered to be acceptable in principle.

Noise and vibration

345 Planning Policy Guidance 24 ‘Planning and Noise’ (PPG24) provides guidance on the assessment of noise and its potential impact on noise sensitive dwellings. The document advises that wherever practicable, noise sensitive developments should be separated from major sources of noise. When separation is not possible, local planning authorities should consider whether it is practicable to control or reduce noise levels or to mitigate the impact of noise through conditions.

346 London Plan policy 4A.20 seeks to reduce noise, by minimising the existing and potential adverse impacts of noise on, from, or in the vicinity of development proposals and separating new noise sensitive development from major noise sources. This is echoed in draft London Plan policy 7.15In addition Ealing’s UDP policy 4.1 requires development which either causes or is affected by excessive noise and vibration to be screened by landscaping, tree and shrub planting, banks, barrier fencing or landscaped walls, and for there to be an adequate distance between source and sensitive development. Ealing UDP policy 5.5 also requires new residential development to provide suitable living conditions for future occupiers.

347 The site is potentially affected by noise from trains and vehicular traffic on major roads, including the A312 Hayes bypass to the west. Heathrow Airport is also located approximately 5 kilometres to the southwest and presents further noise considerations for the site. Accordingly, a Noise and Vibration assessment forms part of the Environmental Statement submitted with the application. The noise sources taken into account include railway (including forecast Crossrail

page 78 trains), Parkway, South Road, Beaconsfield Road and The Broadway (with predicted traffic flows from the Transport Assessment) and the spine road within the development with predicted traffic flows from the Transport Assessment).

348 The noise assessment identifies the main part of the development site as falling within Noise Exposure Categories A and B, and noise sensitive development is supported in these categories. A green wall acoustic noise barrier would protect the amenity of residential blocks to be sited along the southern boundary of the site, which abuts the railway line. This wall would screen railway noise, however the height and detail of this green wall has not been finalised and therefore a condition is attached to ensure this wall would be fully constructed to Ealing Council’s satisfaction before these residential properties are first occupied.

349 Given the application is for outline only, a number of noise conditions are attached to ensure the future noise sensitive developments on the site would be acceptably protected and attenuated. These details would be considered at the reserved matters stage with further conditions attached as appropriate. Furthermore, conditions for a Construction Environmental Management Plan and appropriate phasing of the development would ensure that significant adverse noise and vibration effects would not arise during construction. Climate change mitigation

350 The London Plan requires developments to make the fullest contribution to the mitigation of, and adaptation to, climate change, and to minimise carbon dioxide emissions (Policy 4A.1).

351 Policies 4A.2 to 4A.8 of the London Plan focus on how to mitigate climate change and the carbon dioxide reduction targets that are necessary across London to achieve this. Developments are required to be adaptable to the climate they will face over their lifetime and address the five principles set out in policy 4A.9 of the London Plan.

352 Consistent with the scale of development proposed, a site wide heat and power distribution network would be provided. There are two alternative options for powering this network with strategy 1 based on multiple CHP units and strategy 2 based on a power generating turbine associated with the existing gas pressure reduction process on the operational gas works site.

353 Plot HS.16, to the immediate east of the retained gasholder, would be developed as an energy centre that would act as the main power plant for the network. From this energy centre, power and heat would be distributed to all of the buildings of the proposed development.

354 It is likely that an Energy Services Company would be established to manage the heat and power infrastructure and distribution. The provision of a decentralised system on the site would enable significant efficiency gains to be achieved over a convention power network, as losses incurred in transmission are minimised.

Be lean (London Plan Policy 4A.1 and 4A.3)

355 Through a combination of design measures, materials and other efficiency gains, the application proposes that the energy efficiency of the buildings within the development would be a minimum of 23% for the residential element and 16.7% for non domestic buildings, over the minimum required by Building Regulations.

356 However, it is recognised that the detailed design process could provide greater levels of energy efficiency than that predicted by the submitted strategy. It would also be reasonable to expect advances in building and material technology to be developed during the construction phases, potentially enabling greater efficiency improvement.

page 79 Be clean (Policy 4A.5 and 4A.6)

• Strategy option 1

357 The energy centre would be powered by a series of gas fired combined heat and power (CHP) units. An additional biomass boiler unit would also be provided to meet heat demand, and to accord with London Plan policy 4A.7 for the incorporation of renewable energy generation within the development.

358 Gas fired CHP units are considered to be a low carbon technology due to the significant efficiency gains over conventional power supply. Essentially, gas supplied to the CHP unit is combusted, creating heat that is first utilised to turn an electricity generating turbine and then to heat water. This significantly reduces the energy transmission losses that are experienced on conventional power distribution networks, and gains more utility from each energy unit entering the system as it is used to both generate power and to heat water.

359 Following revision to the original energy strategy, the capacity of the gas fired CHP units within this strategy has been maximised in compliance with London Plan policy 4A.6, and would provide 54% of the energy demand of the site. This is equivalent to an 8.4% reduction of the carbon dioxide demand of the development

360 The biomass boiler unit would contribute up to 13% towards the total energy demand of the scheme and a further 6.7% reduction of the carbon dioxide demand of the development.

361 The renewable energy contribution to the overall reduction in the carbon dioxide emissions of the development falls short of the London Plan policy 4A.7 target of 20%, however this is accepted in line with the Mayor’s climate change hierarchy, whereby maximising the use of CHP is prioritised before maximising the use of renewable technology.

• Strategy option 2

362 The second energy strategy option is based on power generation from a turbine associated with the operational function of the neighbouring gasworks site.

363 An existing gas pipeline carries gas at high pressure into the site, which then goes through a pressure reduction process before entering the storage holder. The pressure reduction process results in significant cooling of the gas, which requires the application of heat to prevent systems failing due to the low temperature. Currently this heat is provided through the combustion of gas and all the waste heat is lost to the atmosphere.

364 The second strategy would see the pressure reduction process shifted from the existing location within the operational gas works site to the energy centre plot HS.16 within the development. Biofuel would be utilised to heat the gas through the pressure reduction process, and instead of the waste heat being immediately lost to the atmosphere, it would be captured to turn an electricity-generating turbine for the electrical requirements of the proposed development. The thermal output from this scheme would also provide 96% of the total heat demand of the development.

365 As the system would utilise a heat source that is currently lost from an existing industrial process, it is considered to be an intelligent energy generation process. The proposed use of biofuel has the added benefit that the energy created from the process is then considered to be from a renewable source. The energy created from such a process is likely to be significantly greater than that demanded by the development scheme, with potential electricity for around 50,000 homes.

page 80 366 As the energy created from the process is considered to be renewable, as defined by London Plan policy 4A.7, this option would also yield a significant carbon dioxide reduction from renewable energy generation on the site.

367 Strategy option 2 is subject to a separate planning application that has been submitted by Blue NG. Ealing Council resolved to refuse planning permission for this scheme in September 2009 and Blue NG has lodged an appeal with the Secretary of State. The appeal process is ongoing and therefore it remains as a potential energy system for the Gas works redevelopment site should the Secretary of State allow Blue NG’s appeal.

Be green (Policy 4A.7)

368 Strategy option 1 includes a biomass boiler unit that would contribute up to 13% towards the total energy demand of the scheme and a further 6.7% reduction of the carbon dioxide demand of the development. Strategy option 2 would utilise biofuel to heat the gas through the pressure reduction process, and instead of the waste heat being immediately lost to the atmosphere, it would be captured to turn an electricity-generating turbine for the electrical requirements of the development. The thermal output from this scheme would also provide 96% of the total heat demand of the development. Both strategies would achieve an acceptable percentage reduction in carbon dioxide emissions from on site renewable energy generation.

Summary

369 Both of the proposed energy strategies, described above, would provide acceptable solutions for the development and both comply with the climate change mitigation policies of the London Plan. The applicant has committed to a single heat and power network supplying all elements of the scheme, from plant located in a single energy centre. This shall be secured by condition.

370 To ensure that one of these proposals is carried forward, appropriate conditions are recommended. These conditions would either secure the development of the heat network and installation of CHP or connection to the Blue NG scheme, should the current appeal be allowed.

Climate change adaptation

371 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 contribution to heat island effects, minimise solar gain in summer, contribute to flood risk reductions, including applying sustainable drainage principles, minimising water use and protecting and enhancing green infrastructure. Specific policies cover overheating, living roofs and walls and water.

372 The Development Specification document outlines the sustainability commitments of the application. This document states that the developer would undertake to make reasonable efforts to ensure that all residential development would meet Level 4 of the Code for Sustainable Homes from the outset. A similar commitment is made in respect of the non-residential component of the scheme, with the Building Research Establishment Environmental Assessment Method (BREEAM) ‘excellent’ level to be achieved. Both these commitments will be conditioned with reasonable endeavour to obtaining higher levels in later parts of the development in accordance with future changes to Building Regulations.

373 The acoustic barrier to the southern site boundary (with the principal purpose of screening rail noise) would be provided as a green wall and 50% of the roofs within the scheme would be provided as brown or green roofs and this commitment is welcomed in line with London Plan policy 4A.11. The green wall and roofs would provide biodiversity enhancements and the roofs would

page 81 also act to reduce water run-off rates. The details of the living wall and roof are secured by condition.

374 The applicant has indicated that demand for water will be reduced through efficient fixtures and fittings and has committed to achieving the maximum target of 105 litres of water per person per day set out in London Plan policy 4A.16 by accepting a condition. The applicant has committed to rainwater harvesting for all homes with private out door space on-site, however, further details of the provision of rainwater harvesting and grey water recycling across the site and in all unit types and uses are secured by condition. Flood risk

375 PPS25 seeks to ensure flood risk is taken into account at all stages of the planning process in order to prevent in appropriate development within areas at risk of flooding and direct development away from areas that are at highest risk. London Plan policy 4A.12 requires the assessment of flood risk for development proposals within flood zones and policy 4A.14 seeks to ensure effective management of surface water run-off, promoting sustainable urban drainage systems and aims that new development should achieve green field run off rates. Ealing Council UDP 2.5 and Hillingdon Council UDP policy OE8 both seek appropriate flood risk assessments and flood protection where redevelopment is permitted in areas at risk of flooding.

376 The Yeading Brook and its floodplain, north of the main site are identified as being located within Flood Zone 3a and 3b (functional floodplain). Table D1 of PPS25 restricts appropriate uses within this flood zone (3b) to water compatible uses and essential infrastructure, and requires essential infrastructure to pass an exceptions test to comply with the PPS25 guidance. The three bridges over Yeading Brook and the Grand Union Canal are considered to be essential infrastructure as part of the development and are considered to be compliant with the exceptions test, as they provide wider community benefit and there are no alternative sites available.

377 The main site is not within an identified flood risk area as it is approximately 4 metres higher than that of the Yeading Brook. The Flood Risk Assessment states that proposed development on the main site would result in a reduction of impermeable area through removal of hardstanding and the introduction of landscaped areas in and around the development. As a result the flood risk elsewhere would be reduced.

378 Identified measures such as the provision of a compensatory storage area adjacent to the A312 Hayes Bypass, the replacement of an existing 225 metres of concrete channel with a new enhanced flood relief channel and the provision of enhanced buffer along the Yeading Brook margin outlined in the Flood Risk Assessment, demonstrates that the proposal would not exacerbate flood risk in the area.

379 Accordingly the Environment Agency, who has statutory powers on flood risk developments, have advised that they have no objection to the flood risk associated with the development and a number of conditions are attached to ensure future maintenance of all sustainable drainage systems.

Phasing and construction

380 The construction of the scheme would be undertaken over 13 phases plus two overlapping phases of remediation over a period of approximately 15 years from 2010 to an estimated completion date in 2025. The table below indicates the likely sequence of development, which is also described below. The construction phases have been split into 3 five-year intervals, however, these are approximate and subject to market forces present during this time span. Overall,

page 82 construction on site moves approximately westwards over the 15 year period, commencing in the northeast and completing in the far west, with the exception of the access routes which are to be constructed and upgraded as required to facilitate access for both construction areas and new residents and businesses.

381 The very initial and limited construction access to the site will be from the existing Eastern (South Road) Access, but as soon as is practicable, this will be transferred to Pump Lane Bridge as its construction progresses. Thereafter, the construction traffic access to the main site would be via the Pump Lane Bridge and during all subsequent phases of development. It is likely that the widening of South Road Bridge would take place in association with Crossrail Construction.

382 Remediation of the main site is programmed for two phases (North and West), each taking place ahead of the completion of the infrastructure, substructure and superstructure construction in those areas, but taking primary development requirements into account.

Years Phase Development on site Years Remediation of the northern area of the Site, demolition of the western gasholder plus the 2010 to Pump Lane Bridge and Eastern Access will be undertaken first, followed by the construction 2015 phases described below Phase 1 Construction of residential component (192 units) along the northern site boundary plus the Energy Centre and some limited retail development. The spine road across the Site and the Pump Lane Bridge will be constructed to facilitate this Site development and access. Phase 2 Construction of further residential units (82 units) in the northeastern area of the Site plus the cinema and further limited retail units Phase 3 Construction of residential units in the northernmost area of the site (370 units) and works to facilitate access routes into the Site including the widening of the South Road Bridge and the Hayes Bypass Junction improvement to the west of the Site. Phase 4 Construction of more of the residential component (180 units), the town square and retail units in the north of the Site plus construction of the Springfield Road Foot/Cycle Bridge from the north. Improvements to Junction 3 of the M4 will also be undertaken during this phase

Years Remediation of the remainder of the Site (‘Remediation West’) will be undertaken at the 2015 to start of this five year period around the time of Phases 6 to 7. Construction Phases 5 to 9 2020 are planned for the years 2015 to 2025 and are outlined below: Phase 5 Construction in this phase includes residential units (283 units), food, retail, studio units and parking in the eastern area of the Site. A temporary nursery will also be constructed in the southern area of this phase of works. Further works to complete the spine road will be undertaken plus off-site works on Bulls Bridge. Phase 6 Construction of residential development (395 units) and the hotel in the north of the Site to the east of the National Grid retained land. Phase 7 This phase of construction includes a large section of land in the central area of the Site and is for development of school, health centre, residential component (390 units) and the park. Phase 8 Construction in this phase is of the Minet Park Bridge and the land adjacent to its landing on-site which will incorporate 303 residential units. Phase 9 Construction of 430 residential units in the central area of the site adjacent to the spine road

Years The final 5 years of construction include development phases 10 to 13 with completion of 2020 to the Scheme, estimated for 2025. These final five years incorporate the remainder of the 2025 residential component on the Site and the development of the western area as outlined below:

page 83 Phase 10 Construction of 200 residential units Phase 11 Construction of 297 residential units Phase 12 Construction of 249 residential units Phase 13 Construction of 122 residential units in the far west point of the Site

Community infrastructure and planning obligations

383 Section 106 of the Town and Country Planning Act provides the ability to address externalities arising from development, that would otherwise be considered unacceptable, by means of commitments set out by the applicant and if necessary the Local Authority and any other concerned party, in a legal agreement.

384 Government Circular 05/2005 Planning Obligations (July 2005) provides guidance on the use of section 106 planning obligations. The Circular advises that section 106 agreements can be used to prescribe the nature of a development, to secure contribution from the developer to compensate for loss or damage arising from a development or to mitigate the impact of a development. The Circular states that a planning obligation must be:

(i) Relevant to planning; (ii) Necessary to make the proposed development acceptable in planning terms; (iii) Directly related to the proposed development; (iv) Fairly and reasonably related in scale and kind to the proposed development; and (v) Reasonable in all other respects. . 385 The Circular states that planning obligations should be derived from the requirements of development plan policies. The Circular recognises that, in some circumstances, it may not be feasible for a development to meet all of the requirements set out in development plan policies and still be economically viable, while at the same time approval of the development may still be desirable in the interests of meeting the aims of the development plan. In such cases, the Circular advises that the local authority (and other public sector agencies) can decide the level of contributions to be secured from the development and the balance that would be required to be made up through local or central taxation to address all of the externalities from the development.

386 Given that the application site is geographically located within two London Boroughs, Ealing and Hillingdon, both the Council’s would each receive separate planning obligations from the applicant to mitigate the relevant impacts of the development. The obligations to both Councils are disused separately below.

Ealing Council

Education Facilities

387 The application would yield a school age population that would impact on demand for local education facilities. To address part of this demand, a nursery and two-form entry junior school are proposed on the site. In the context of fluctuating population age structures, it is considered that this provision should largely address the demand for junior school places. On the basis of current school rolls, any additional places required could be provided in schools surrounding the site.

388 A financial contribution of £4,310,338 has been agreed by the applicant to address the demand for secondary school places. It is expected that additional secondary school place demand could in part be addressed by a proposed school in the north of the Borough, and an associated

page 84 ripple effect gradually displacing existing catchment areas further southward to accommodate a new catchment to the north.

Health Care facilities

389 The average General Practitioner list size within the study area (800-metre catchment from the site) is approximately 2100 patients per General Practitioner, which is higher than the Ealing Primary Care Trust (PCT) target list size of 1,900 patients per General Practitioner.

390 It is expected that the development would yield a resident population of approximately 12,000 persons. On the basis of the Ealing PCT target list size of 1,900, this would result in demand for an additional 6.3 General Practitioners.

391 Consistent with the strategic NHS direction towards the provision of polyclinics, the application proposes a health facility of up to 2,550sqm, which would provide capacity for 8 General Practitioners. The application proposes that this facility would be constructed and fitted out before being transferred to the Ealing PCT. The facility would be provided on the upper floors of a building shared with the proposed school. The combined value of the school and health centre is £16.4 million (including the land cost).

392 The Ealing PCT and West London Health Estates have confirmed that the provision of such a facility on the site would be considered to address the demand on health infrastructure arising from the scheme.

Parks

393 The landscape strategy for the site includes the provision of a large open space within the development. The use of this park would not be restricted to occupiers of the scheme and would be available for use by the wider community.

394 The development would also provide improved pedestrian and cycle access to the Minet Country Park for the wider community, through improved subway access into the site from the south, and providing access from the north, provision of access through the site and provision of bridges from the site into the Park.

395 In recognition of the increased use of surrounding parks, the applicant has agreed to a financial contribution of £60,000 that would be spent on refurbishment and provision of additional play equipment on the Spencer Street open space, to the south of the site, adjacent to the Dudley Street underpass.

396 Other parks related contributions would be made to the provision and maintenance of street trees on the spine road that would be adopted (£262,000) and a contribution to enable the provision of additional allotments in the area (£100,000).

Cemetery contribution

397 Ealing Council’s Cemetery Team state that there is limited burial space available in this part of the Borough and the additional population could not be accommodated in the existing cemetery capacity. A figure of £750,000 was requested from the applicant to develop existing land Greenford Cemetery for future burial. The Council recognises that this is an uncommon requirement and no formula for calculation exists within the Council’s SPD9 ‘Legal Agreements’. Furthermore, it would cost an Ealing resident £1,890 to be buried in Greenford Cemetery, money which could help develop the additional land for increased burial capacity. Therefore a figure of

page 85 £400,000 has been agreed with Ealing Council for a cemetery contribution with the £350,000 allocated to the Minet Country Park contribution.

Leisure

398 The application proposes a sports pavilion on site that would be provided in association with the large public park. Tennis courts and all weather pitches are also provided on site.

399 However, the local area is considered to suffer from a deficiency in access to swimming pools. In recognition of this need, Ealing Council has sought the provision of a contribution of £1,150,000 that would go towards pooled funding for a swimming pool in the site’s vicinity. At this early stage no potential sites for the swimming pool have been identified and therefore there is no level of comfort that the swimming pool would be delivered within Southall in the near future.

400 Additionally the £14 million Botwell Green Leisure complex has recently opened in Hayes in the London Borough of Hillingdon. This complex includes a 25 metre long, eight-lane swimming pool with viewing gallery and learner pool. This facility is considered to be within easy access of the development site, especially with new bus routes and pedestrian and cycle bridges proposed to link the site with Hayes. An excellent opportunity for cross-borough community activity therefore exists and Hillingdon Council Leisure Services advises that the leisure complex would adequately cope with the demand of the population on the application site. In this regard the future occupants of the site would have access to a modern swimming pool and therefore the £1,150,000 requested by Ealing should be reduced. A figure of £975,000 would be appropriate for new swimming pool in Southall with the remaining £150,000 allocated to the Minet Country Park contribution and £25,000 to Hillingdon Council for air quality monitoring.

Transport contributions

401 As detailed in the Transport section of this report, significant contributions are proposed towards the provision of bus services through the site (£6.6M), the formation of a Transport Fund for such aspects as traffic management measures and travel plan measures (£3.55M), a contribution towards town centre car parking (£100,000) and VMS signage (£50,000), contribution to CPZ review in the areas adjoining the site (£100,000) along with the costs involved in formation of the accesses and pedestrian linkages, and the necessary of-site highway works (£23,000,000)

402 In total £34,150,000 would be spent on highway work and transport measures related to the development.

South Road Bridge widening works

403 The bridge widening works will be secured through the s106 as the first priority mitigation measure, and a Grampian condition is also attached to this effect. However an in lieu payment or Alternative Mitigation Measures may also be agreed between the applicant and Ealing Council and TfL. Please refer to paragraphs 190-196 for the full details on this mitigation measure.

Other Required Planning Obligations

404 As detailed elsewhere in this report, the applicant has agreed to the following contributions that are considered necessary to mitigate the impact of the development:

• Shopmobility scheme- £360,000 • Provision of a 200 sq.m unit for a Police office on site (unit value £350,000) • Employment and training - £678,000 • Public realm improvements in the surrounding area - £596,000

page 86 • South Road / A4020 Uxbridge Road improvements - £525,000 • Low Emissions Strategy and Air Quality Management - £664,000 • Remediation (officer funding) - £50,000

Hillingdon Council

Minet Country Park

405 It is recognised that the future occupants of the development site may wish to use Minet Country Park for recreational purposes, especially as there would be two pedestrian and cycle bridges constructed as part of the proposals to provide easy access to the Park from the main site. As such, Hillingdon Council require capacity enhancements of the Park to facilitate the proposed increases in visitor numbers.

406 Hillingdon Council contends that there would be a significant short fall of public open space and amenity space provision on the main site and therefore the proposal would be heavily dependant on the utilisation of Minet Country Park to meet the open space and recreational demands of the development’s future occupiers and users. Consequently this would substantially increase the patronage of Minet Country Park and associated facilities within the London Borough of Hillingdon.

407 Hillingdon Council contends that Minet Country Park, in its current form, is not adequately served by infrastructure, facilities or maintenance arrangements to accommodate the additional patronage that would be caused by this development. Additionally there are no adequate provisions in place to secure the protection of biodiversity interests in the Park as suggested by Natural England. Accordingly Hillingdon Council seek a financial contribution to mitigate the following:

• Wider and additional footpaths and cycleway networks; • Additional lighting, security measures, seating, bins, way finding signage, toilets and other facilities; • Landscape capacity enhancements by remodelling and replacement; • Protection of areas of ecological importance.

408 Hillingdon Council calculated the proposed mitigation works to cost £2,752,520.94, which would include £200,000 for a DDA compliant toilet facility, £160,000 for lighting, £150,000 for CCTV, £160,000 for a Park Ranger’s office, £90,000 for a tool shed, £282,500 for ecological improvements, £212,000 for fencing and £300,000 for ongoing maintenance over a 20 year period.

409 As discussed under the ‘Open Space’ section of this report it is highly likely the proposed communal garden space and public open space would adequately serve all perspective residents within the boundary of the application site. For this reason it is not envisaged that the facilities of the Minet Country Park would require significant upgrade or improvement to achieve the ‘best practice quality standards’ that only a formal park would require.

410 Hillingdon Council seek facilities that only a formal park would require, not a Country park, and therefore the requested £2,752,520.94 is not fairly and reasonably related in scale and kind to the proposed development contrary to Government Circular 05/2005 Planning Obligations. The applicant instead offered a figure of £1,840,000, which is very reasonable and would adequately meet Hillingdon Council’s reasonable costs for ecological improvements, fencing, and pathways without changing the character of the country park.

Education

page 87 411 The applicant has agreed a financial contribution of £821,118 with Hillingdon Council. This represents the cost of additional secondary school aged children, and post 16 year old students who could reasonably be expected to reside in the proposed scheme, but attend educational institutions in the London Borough of Hillingdon. An analysis of school roles and the postcodes in which students live was undertaken, for the last five years, to establish the likely average number of students who could reasonably be expected to attend Hillingdon schools.

Air Quality Monitoring

412 The southern part of the borough surrounding Heathrow Airport has the second highest levels of air pollution in the UK. Road traffic emissions are recognised as a major contributor to this as the three main road corridors across this part of the borough (namely the M4, A4 and A40 and also the nearby M25) all generate high density traffic. Due to the prediction that national air quality objectives would be exceeded across parts of the borough, and in accordance with National Government guidelines, Hillingdon Council declared an Air Quality Management Area (AQMA) in the borough encompassing all identified areas of poor air quality. The AQMA extends to include the Southall Gas Works site.

413 The proposal would result in increased air pollution from increased traffic and potentially from any biomass boiler/CHP energy centre. In essence the impacts from the development put greater strain on the surrounding road network, especially the A312 Hayes Bypass. The Councils Planning Obligations SPD notes that in some cases, air quality monitoring will be required to ensure these standards can be met and maintained. A contribution of £50,000 towards the establishment and ongoing maintenance of an air quality monitoring station in Hayes close to the Bypass. This station would provide two years of data measurement, collection and validation.

British Waterways

414 Given the sites location next to the Grand Union Canal and the proposed access bridges to traverse the Canal and land owned by British Waterways, British Waterways have also sought planning obligations from the applicant for the following:

• Financial contribution towards a strategic master plan for the wider area: £20,000; • Financial contribution towards delivery and implementation of a Waterspace Strategy: £10,000; • Financial contribution towards remediation of land between Yeading Brook and the Grand Union canal (Minet Tip): £4,000,000; • Financial contribution to implement works to improve access along the canal from Uxbridge Road to Bulls Bridge: £660,000.

415 As already discussed in the ‘Land contamination and human health’ section of this report, it is not the responsibility of applicant to help remediate land between Yeading Brook and the Grand Union canal. The contaminated land is owned by British Waterways and located with the London Borough of Hillingdon and it is therefore the responsibility of one of those parties to either securely fence or remediate the contaminated land. The £4 million planning obligation is therefore not necessary to make the proposed development acceptable in planning terms and not directly related to the proposed development, hence fails the policy test for seeking an obligation under Planning Circular 05/2005 Planning Obligations.

413 The other contributions sought for a strategic masterplan and a Waterspace Strategy are also not necessary to make the proposed development acceptable in planning terms and not directly related to the proposed development. With regard to the £660,000 sought for access improvements along the canal from Uxbridge Road to Bulls Bridge, the applicant seeks to spend in

page 88 the region £500,000 to improve the access along the site’s boundary alone and this is reasonable. The applicant, not British Waterways, would spend this money to improve access along the canal.

Summary

416 A total of £22,530,000 is currently included in the proposed heads of terms. However, the total value of the overall package of work that the applicant would undertake along with the financial contributions increases the overall value of the Section 106 benefits to £62,094,066 for Councils, TfL and British Waterways.

417 In considering the community benefit, and taking account of Ealing Council’s UDP Policy 1.10, it is recognised that the figures proposed for different items of infrastructure in the heads of terms to mitigate the impacts of the proposed development are estimates, and could change before and over the period of development. Consequently provisions are proposed in the heads of terms for the section 106 agreement to incorporate flexibility to allow any re-allocation of any contributions within the overall amount agreed. This would enable any surplus to be used to meet any additional requirements.

Conclusion

418 The comprehensive section 106 package adequately mitigates against the impacts of the development and meets the tests of the circular 05/2005. In accordance with Government Office for London circular 1/2008 ‘Strategic Planning in London’ the Mayor has consulted with both Ealing and Hillingdon Councils on the section 106 package. It is anticipated that both Councils will be signatory to the section 106 agreement to avoid the Mayor having to distribute the agreed funds.

Legal considerations

419 Under the arrangements set out in Article 7 of the Order and the powers conferred by Section 2A of the Town and Country Planning Act 1990 the Mayor is acting as the Local Planning Authority (LPA) for the purposes of determining this planning application and the connected conservation area consent.

420 Section 35 of the Greater London Authority Act 2007 inserts section 2F into the Town and Country Planning Act 1990 a requirement that for applications the Mayor takes over, the Mayor must give the applicant and the LPA the opportunity to make oral representations at a hearing. He is also required to publish a document setting out:

• Who else may make oral representations • The procedures to be followed at the hearing • Arrangements for identifying information, which must be agreed by persons making representations

421 The details of the above are set out in the Mayor’s Procedure for Representation Hearings which reflects, as far as is practicable, current best practice for speaking at planning committee amongst borough councils.

422 In carrying out his duties in relation to the determination of this application, the Mayor must have regard to a number of statutory provisions. Listed below are some of the most important provisions for this application.

Statutory duties in relation to the Development Plan

page 89 423 In determining any planning application, the Mayor is required by section 38(6) of the Planning and Compensation Act 2004 to have regard to the provisions of the Development Plan (in this case Ealing and Hillingdon’s Unitary Development Plan and the London Plan (consolidated with alterations since 2004) so far as is material to the application and to any other material considerations. The Mayor must determine the application in accordance with the Development plan unless material considerations indicate otherwise. Central Government guidance will always be a very significant material consideration.

424 Other guidance, which has been formally adopted by Ealing and Hillingdon and the GLA (e.g. supplementary planning documents, conservation area statements, planning briefs), will all be material considerations of some weight (where relevant.) Those that are relevant to this application are detailed in this report.

The Human Rights Act 1998 (HRA)

425 When determining this planning application, the Mayor is under a duty to take account of the provisions of the HRA as they relate to the development proposal and the conflicting interests of the applicant and any third party affected by, or opposing, the application, in reaching his decision. These include the following:

(a) Article 6: Right to a fair trial 6(1) In the determination of his civil rights and obligations...... everyone is entitled to a fair and public hearing within a reasonable time by an independent and impartial tribunal established by law. (b) Article 8: Right to respect for private and family life Everyone has the right to respect for his private and family life, his home and his correspondence. (c) Article 1 of the First Protocol: Protection of property Every natural or legal person is entitled to the peaceful enjoyment of his possessions. No one shall be deprived of his possessions except in the public interest and subject to the conditions provided for by law and by the general principles of international law. (d) Article 14: Prohibition of discrimination The enjoyment of the rights and freedoms set forth in this Convention shall be secured without discrimination on any ground such as sex, race, colour, language, religion, political or other opinion, national or social origin, association with a national minority, property, birth, or other status.

426 It should be noted however, that most Convention rights are not absolute and set out circumstances when an interference with a person's rights is permitted.

Conclusion

427 Section 38(6) of the Planning and Compensation Act 2004 requires that if regard is to be had to the development plan for the purpose of a determination to be made under the Planning Acts, the determination must be made in accordance with the development plan unless material considerations indicate otherwise.

page 90 428 When assessing the planning application the Mayor is required to give full consideration to the provisions of the development plan and all other material considerations. He is also required to consider the likely significant environmental effects of the development and be satisfied that the importance of the predicted effects and the scope for reducing them, are perfectly understood.

429 In preparing this report Officers have taken into account the likely environmental impacts and effects of the development and identified appropriate mitigation action to be taken to reduce any adverse effects. In particular, careful consideration has been given to the proposed conditions and planning obligations which will have the effect of mitigating adverse impacts.

430 The proposed master plan positively realises an excellent opportunity to decontaminate and develop large constrained site and connect it to the strengths and opportunities of its surroundings. The mixed-use development would achieve a quantum and mix of uses that is supported in local and strategic planning policy terms. The regional importance of this key brownfield site has been recognised with it being designated as an Opportunity Area, and in such areas it is of fundamental importance that the maximum provision of new housing and employment is secured. This development would satisfy both of these principles, not only at local level, but Londonwide level. Particularly positive would be the quantum of affordable housing that would be delivered, to be in excess of 1,000 units.

431 The master plan has positively responded to the many opportunities and constraints of the site’s surroundings, in particular the development would improve the setting of the nearby listed Water Tower and preserve the character of the Grand Union Canal conservation area. Currently the site’s western boundary has turned its back on the Grand Union Canal and the master plan actively seeks to open up the site to the canal environment, which is supported by the Mayor’s Blue Ribbon Network policies. The proposed density ranges and mix of uses across the site would complement and strengthen the role Southall Major town centre to the east by locating commercial and leisure uses in the eastern area of the site to form an extension to Southall centre to be connected by new bus routes and pedestrian and cycle paths. The proposed permeability and connectivity of the site would ensure social inclusion of the wider Southall community. This would be achieved whist also creating a distinct character for the Gas works site through the proposed layout and design to create a high quality environment for on site residents and visitors alike. The master plan would create a strong sense of place that will lead to a strong sense of ownership and civic pride for residents. A generous provision of public open spaces are proposed throughout the site and in this regard the master plan would both maximise density in respect of surrounding context and achieve a green urban environment.

432 The master plan would also strengthen cross-borough partnerships by linking the site to the Minet Country Park across the Grand Union Canal by way of two pedestrian and cycle bridges. This would strengthen the role of this District Park whilst allowing existing and future Southall residents easy access to nature within an urban context. Significant financial contribution has been offered by the applicant to ensure that this District Park would be maintained and improved as its visitor numbers increase.

433 A range of social infrastructure facilities would form part of the development including new school, doctor’s surgery, cinema, cafe, restaurants, sports pavilion, allotments and Community Policing Station. In this regard the future population would be served adequately without putting stress on existing infrastructure surrounding the site, which would create a sustainable community.

434 The massing, height and siting of the buildings would also ensure that the daylight, sunlight, outlook and privacy of the nearby residential properties to the north would be protected. Additionally, the relationship between the new buildings within the site would ensure the amenity future residents would be appropriate, particularly positive is the applicant’s commitment to

page 91 achieving the Mayor’s minimum internal floor space standards. Further commitments to securing a single district heat and power network, green roofs and sustainable urban drainage would ensure the Mayor’s climate change policies are achieved.

435 TfL is now satisfied that the developer has satisfied both Councils transport refusal reasons as far as practically and reasonably possible and that all the issues that were raised in the Mayor’s previous Stage One and Two Reports have now been resolved and no longer objects to the planning application on transport grounds.

436 Accordingly the recommendations set out at the beginning of this report are proposed.

for further information, contact Planning Decisions Unit: Giles Dolphin, Assistant Director, Planning 020 7983 4271 email [email protected] Colin Wilson, Senior Manager (Planning) 020 7983 4783 email [email protected] Justin Carr, Strategic Planning Manager (Planning Decisions) 020 7983 4895 email [email protected] Conor McDonagh, Case Officer 020 7983 6536 email [email protected]

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