North Planning Committee
Meeting date: THURSDAY 4TH NOVEMBER 2004
Time: 6.30PM
Venue: BISHOP RAMSEY UPPER SCHOOL, HUME WAY, RUISLIP
To Members on the Planning Committee
Councillors Conservation Area Advisory Panel Members Scott Seaman-Digby (Chairman) Michael Platts (Eastcote) Margaret Grant (Vice-Chairman) Clive Pigram (Ruislip) Bruce Baker David Horne John Ross (Harefield) John Hensley Peter Curling Michael Hurst (Canal Locks) Tony Burles Pamela Jeffreys (Ickenham) Substitute Councillors Anne Banks Geoff Courtenay Dave Allam Norman Nunn-Price David Bishop Mary O’Connor Janet Duncan Peter Ryerson George Cooper Roshan Ghei Paramjit Sethi Josephine Barrett Paul Harmsworth
Further information
For information about the planning applications please telephone 01895 250401.
This agenda was published on 27th October 2004. If you would like further information about the meeting please call Gill Brice in Hillingdon’s Cabinet Office on 01895 250693, email [email protected] or visit the Council’s website www.hillingdon.gov.uk
Involving the Public in the way we do business…
The Public have a right to petition and speak at this committee, but must notify the Cabinet Office beforehand on 01895 250693.
Members of the Public and Press are very welcome to attend this meeting.
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This agenda is available in large print
Agenda
1. Apologies for Absence
2. Declarations of Interest in matters coming before this meeting
3. Matters that have been notified in advance or urgent.
4. To confirm that the items of business marked Part I will be considered in Public and that the items marked Part 2 will be considered in private.
5. Consideration of the reports from the Head of Planning & Transportation
Reports - Part 1 – Members, Public and the Press Items are normally marked in the order that they will be considered, though the Chairman may vary this. Reports are split into ‘major’ and ‘minor’ applications. The name of the local ward area is also given in addition to the address of the premises or land concerned.
Major Application
Address Ward Description & Recommendation Page 1 RAF Eastcote Eastcote & Redevelopment of the site for 1 Lime Grove East Ruislip residential purposes at a density of Ruislip up to 50 dwellings per hectare, including affordable housing, live- work units, a community facility and open space (Outline Application)
Recommendation : Refusal
A Item No. Report of the Head of Planning and Transportation
Address: RAF EASTCOTE, LIME GROVE, RUISLIP
Development: REDEVELOPMENT FOR RESIDENTIAL PURPOSES AT A DENSITY OF UP TO 50 DWELLINGS PER HECTARE, INCLUDING AFFORDABLE HOUSING, LIVE-WORK UNITS, A COMMUNITY FACILITY AND OPEN SPACE (OUTLINE APPLICATION)
LBH Ref Nos: 10189/APP/2004/1781
Drawing Nos: Planning Application Boundary (Dwg 07312-L44, Aboricultural Survey (Dwg 07312-L30a), Lime Grove Traffic Management Measures (Dwg 5006067/012 RevA, Sheets 1 to 4), Eastcote Road signals (Dwg 5006067/005 Rev B), Illustrative Layout (Dwg 07312-L38 illustrative only)
Date of receipt: 14/06/2004 Date(s) of Amendment(s): None
1.0 SUMMARY
1.1 This planning application is an outline application for the redevelopment of a 7.7 hectare site known as RAF Eastcote. The application seeks approval for the principle of residential development at a density of up to 50 dwellings per hectare including affordable housing and live-work units, a community facility, open space and means of access. All other matters, namely the siting, external appearance and design of buildings, landscaping and the internal road network are reserved for subsequent approval.
1.2 The site is owned by the Ministry of Defence, and has been used for a variety of military and government purposes since 1946 and comprises 28,000m2 of predominantly administration/office floor space. Some land around the site boundaries is leased by the MoD to neighbouring properties whom use this land for garden space. While the site presently has two driveways to Eastcote Road, this access was closed by the MoD some years ago for safety reasons. As a result, the site is currently serviced solely via a driveway to Lime Grove. The Crown does not currently require planning consent to use their property.
1.3 There has been significant public interest and objections raised to this planning application. These issues have included traffic impacts and concerns that the density proposed is too high resulting in unacceptable impacts on built form, traffic and community facilities and services.
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1.4 The density of the development, being up to 50 dwellings per hectare, is consistent with the guidelines in the London Plan. The illustrative scheme has not been submitted for approval as design and siting is a reserved matter. The Council’s Urban Design and Conservation Officer supports the provision of a mix of 2 and 3 storey buildings on the site. Such a building height should be able to accommodate the maximum density envisaged. However, as detailed design has not been provided, if the Council were minded to grant planning approval, a condition would be placed on the outline consent that a density of up to 50 dwellings per hectare and up to 200 habitable rooms per hectare is approved. The impact of the development on local services and facilities such as doctors and schools is proposed to be addressed via a planning obligation, as is the case for all residential developments in the Borough.
1.5 In terms of traffic impacts, the Council’s Highways Engineer has advised that the applicant has failed to demonstrate that the right turn movement from Eastcote Road into Fore Street will not obstruct the free flow of traffic. This would result in inconvenience to road users and highway and pedestrian safety conflicts. Therefore the application is recommended for refusal.
2.0 RECOMMENDATION: REFUSAL, for the following reasons:
1. The applicant has failed to demonstrate that the right turn movement from Eastcote Road into Fore Street will not obstruct the free flow of traffic resulting in inconvenience to road users and highway and pedestrian safety conflicts. As such, the development is inconsistent with Policy AM7 of the Unitary Development Plan.
3.0 CONSIDERATIONS
Site and Locality
3.1 The site is 7.7 hectares in area and is dissected into a ‘northern’ and ‘southern’ area by an existing public footpath. An internal private road links the northern and southern areas. The northern portion is 4.2 hectares and houses a US Navy facility, which is virtually vacated. The land in this area is undulating, and becomes lower towards the northwestern boundaries. The southern portion of the site is 3.5 hectares, is generally flat, and comprises a number of vacant buildings. Many mature trees adjoin the property boundary. The total existing floorspace for the entire site is approximately 28,000 m2 of which 22,500m2 is administration space and 5,500m2 are barracks (for 200 personnel).
3.2 The site has three driveway entrances, two to B466 Eastcote Road and one driveway to Lime Grove which is a single carriageway road with footpaths on both sides and on street parking. The MoD closed the two driveways to Eastcote Road some years ago due to safety concerns. The
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site currently has 246 marked parking spaces and 169 unmarked parking spaces.
3.3 The eastern pedestrian access from the site (near The Sigers) is located some 560 metres from the Primary Shopping Area within the Eastcote Town Centre. This eastern pedestrian entrance is located approximately 950m from the Eastcote Underground Station which is a suitable walking or cycling distance. The site is also served by the H13 bus service which runs along Eastcote Road and the 282 bus service which runs along Field End Road to the East. There are no designated cycle ways within the area, though a facility is proposed to run along Elm Avenue south of the site, which will link Eastcote to the National Cycle Network.
3.4 Council officers requested that Transport for London recalculate the Public Transport Accessibility Level (PTAL) of the site for this application. It has been advised that the site has an average PTAL score of 1b, which is a low score within a possible range of 1 to 6.
Scheme
3.5 Outline planning permission is sought for approval of the principle of residential development at a density of up to 50 dwellings per hectare including affordable housing and live-work units, a community facility, open space and means of access. Each component of this outline scheme is discussed briefly below:
3.6 Residential Density – The application is for a density of ‘up to’ 50 dwellings per hectare. A habitable room density of 250 habitable room per has been indicated in the ‘development brief’ submitted with the planning application. However, the applicant is not specifically making application for 250 h.r.p.h as this is not part of the development’s description. The precise density that would occur on the site is unknown until a reserved matters application is submitted and approved for the siting and design of buildings. That being said, if the Council was minded to approve this outline application, the Council can include consent conditions stipulating a maximum acceptable density if this is necessary for planning purposes.
3.7 Affordable Housing – The applicant has advised that they are willing to enter into a Section 299 agreement to provide 35% of dwellings as affordable housing.
3.8 Live-work Units – Live-work units can be defined as follows:- "The genuine and permanent integration of living and working accommodation within a single self contained unit, with a greater proportion of the unit comprising working floor space and where the principal occupier both lives at and works from the property" In similar large scale schemes the Council has controlled such live-work units by including conditions on planning consents to control: the number, size and occupancy of such units.
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3.9 A Community Facility – An indicative site layout plan submitted with the application indicates a 170m2 2 storey community facility. The location and scale of this facility is indicative only because the application reserves siting and design details. The application does not indicate what type of community facility is envisaged. If the Council was minded to approve this outline application, any approval could include consent conditions stipulating what community uses (for example: nursery, health centre, community hall, etc) are acceptable on the site.
3.10 Open Space – An indicative site layout plan submitted with the application indicates 0.73 hectares of open space, of which some 0.4 hectares is provided in the centre of the site. The location of open space is indicative only because the application reserves siting and design details.
3.11 Means of Access – The means of access is the only matter that is not ‘reserved’ by this outline application. The application proposes to provide a signalised intersection to Eastcote Road (requiring other ancillary signals in the vicinity of Fore Street) and a driveway to Lime Grove. It is proposed to formalise a shuttle system in Lime Grove via the use of waiting restrictions (yellow lines). The applicant has indicated that it is not intended to provide a public vehicle link between the northern (4.2hectare) and the southern (3.5 hectare) portions of the site. In terms of how many dwellings would be ‘linked’ to each access the indicative scheme suggests 186 to Eastcote Road and 189 to Lime Grove. However, the transport assessment included a sensitivity test concluding that the proposed signals at Eastcote Road could accommodate 225 or 275 dwellings thereby reducing the number of dwellings using the southern (Lime Grove) access to 150 or only 100 dwellings. The precise dwelling split north-v-south that would occur on the site is unknown until a reserved matters application is submitted. That being said, if the Council was minded to approve this outline application, the Council can include consent conditions stipulating the maximum number of dwellings that can be served from Lime Grove if this is necessary for planning purposes.
3.12 All other details including the layout of the site, position of buildings, the detailed design and external appearance of those buildings, the layout of open areas including, amenity areas, the details of landscaping and all other details relating to car parking areas are not part of this application and are, therefore not for consideration as part of this assessment. However, an indicative site layout has been provided to illustrate to the Council how development could occur, as summarised in the following:
Northern Area: • Community Facility- 170sqm • 78 Apartments- 50-100sqm, 3 storey, 1.5 parking spaces per unit • 108 houses- 80-180sqm, 2 storey, 2 spaces per house • 0.42 ha open space
Southern Area:
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• 108 Apartments- 50-100sqm, 3 storey, 1.5 parking spaces per unit • 81 houses- 80-180sqm, 2 storey, 2 spaces per house • 0.31 ha open space
3.13 The applicant has also submitted a series of detailed technical papers and supporting information that assess the impact of the proposal. These are summarised below:
• Transport Assessment
This report considers the proposed use of site as residential and considers the impact of the proposal in the context of traffic flows from the residential development. Public transport, cycle and pedestrian links have also been considered. As discussed above, the transport assessment included a sensitivity test concluding that the proposed signals at Eastcote Road could accommodate up to 275 dwellings thereby reducing the number of dwellings using the southern (Lime Grove) access to 100 dwellings.
• Air Quality Assessment
This report considers the key issues relating to air quality in relation to the proposed development and impacts from traffic emissions generated as a result of traffic accessing the new residential properties. The report concluded that the impact is likely to be negligible.
• Ecological Appraisal
In 2003 the Council adopted a screening opinion confirming that the redevelopment proposal for the RAF Eastcote site did not require an Environmental Impact Assessment (EIA). The report assessed the ecological values of the site in relation to the proposed development and any likely impacts. It was concluded that the site offered little ecological value and that the redevelopment would not have a detrimental effect on ecology.
• Arboricultural Survey
Includes a survey of 192 trees on and in the vicinity of the site.
• Development Brief
Submitted with the planning application is a Development Brief. This has been submitted to provide a “planning framework” for the redevelopment of RAF Eastcote for housing. It includes an “outline concept” plan and an “illustrative sketch” layout plan. It was prepared in March 2003, prior to the publication of the London Plan.
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as will the site access. However, all matters in the outline application are reserved for the determination at the detailed planning stage.”
Therefore, the contents of the Brief, which have not gone through any formal separate statutory consultation procedures are for illustrative purposes only, it remaining the case that all matters of detail, namely siting, design, external appearance and landscaping are reserved for subsequent approval.
Planning History
3.14 During World War II, the buildings at RAF Eastcote were constructed for use as a hospital, however the land was never used for this purpose. From 1946 the Government Communications Headquarters (GCHQ) moved into the premises, with the buildings housing cryptography machines (bombes). Up until 1977 various communications and security agencies were accommodated on the site. Since that time, the site has been used for a variety of military uses, most recently operating as a US Navy administrative centre and for the housing of military personnel.
3.15 A planning application to redevelop the site for residential purposes was submitted to the Council in June 2003, (Ref: 10189/APP/2003/1438). A report was prepared by Council officers for the Planning Committee meeting of 16th February 2004 which recommended refusal. The application was withdrawn shortly before the Committee meeting and therefore was not determined by the Council. In summary, the two principle reasons recommended for refusal for the previous application were: • The impact of increased traffic volumes along Lime Grove on residential amenity and traffic conflicts. • The redevelopment of this site was entirely for residential purposes. In this regard, the application was considered to be contrary to the Draft London Plan, PPG1 and PPG3 which seeks the provision of mixed use development.
3.16 In response to the above, the current application (2004/1781) altered the earlier application documents to: • Propose live-work units and a community facility; • Propose traffic management measures along Lime Grove (yellow lines to formalise a shuttle system); • Provide documentation on the link-capacity of Lime Grove; • Make clear that the application incorporates signals on Eastcote Road (as the exhibited plan in the Transport Assessment of 2003/1048 included an unsignalised T-junction with Eastcote Road); • Provide a sensitivity analysis to illustrate that more of the dwellings can be accessed via a proposed signalised intersection at Eastcote Road rather than via Lime Grove.
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Planning Policies and Standards
The London Plan, RPG3 (Regional Guidance for London), PPG 1 (Planning Policy Guidance) “General Principles”, PPG3 (Planning Policy Guidance) “Housing”, PPG 13 (Planning Policy Guidance), “Transport”, PPG24 (Planning Policy Guidance) “Planning and Noise”. Circular 6/98 Planning and Affordable Housing is also relevant.
UDP Designation: Developed Area Adjacent to Local Distributor Road (B466 Eastcote Road) Adjacent to Nature Reserve Site of Borough Grade II Importance Adjacent to Conservation Area
The following UDP polices are considered relevant to the application:-
Part 1 Policies:
Pt1.10 , Pt1.17, Pt1.21, Pt1.35, Pt1.38, Pt1.39
Part 2 Policies:
ECOLOGY AND NATURE CONSERVATION EC1 Protection of sites of special scientific interest, nature conservation importance and nature reserves (Highgrove Eastcote) 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
BUILT ENVIRONMENT BE4 New development within or on the fringes of conservation areas BE13 Layout and appearance of new development BE19 New development within residential areas
OTHER ENVIRONMENTAL CONSIDERATIONS OE1 Character of surrounding properties OE2 Environmental Assessments OE3 Buildings or uses likely to cause noise annoyance OE6 Proposals likely to result in pollution OE10 Phasing of development in areas of potential flooding or inadequate sewerage capacity OE11 Development involving hazardous substances and contaminated land - requirement for ameliorative measures OE12 Energy conservation and new development OE13 Recycling facilities in major developments and other appropriate sites
HOUSING
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H4 Mix of housing units H5 Dwellings suitable for large families H6 Density H8 Change of use from non-residential activity to residential H9 Housing for people with disabilities H11 Affordable Housing
RECREATION, LEISURE AND COMMUNITY FACILITIES R1 Recreational open space R10 Proposals for new meeting halls and buildings for education, social, community and health services R16 Accessibility for elderly people, people with disabilities, women and children R17 Recreation Open space planning obligations
THE LOCAL ECONOMY LE1 Proposals for industry, warehousing and business development LE5 Small scale business activities within the developed area LE7 Provision of planning benefits from industry, warehousing and business development
ACCESSIBILITY AND MOVEMENT AM1 Development and the public transport system AM2 Which assesses development against their contribution to traffic congestion and on public transport availability 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 AM11 Improvement in facilities and promotion of safety and security at bus and rail interchanges; use of planning agreements to secure improvement in public transport services
Consultations
The application was advertised under Article 8 of the Town and Country Planning Act (1990) as major development. A sign was erected on the site and a public notice was placed in local paper on 14th July 2004. Some 375 resident households were directly notified via letter and local resident groups were notified including: South Ruislip Residents’ Association, Eastcote Residents’ Association, Ruislip Residents’ Association and Eastcote Village Conservation Panel. A total of 155 letters of objection have been received from residents. Please note that there were a number of residents who wrote in twice, such as a ‘holding’ objection via the email
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and then a detailed submission. In such circumstances, one objection has been recorded to arrive at the total of 155 reported above, however issues raised in all correspondence has been considered. In addition, 6 petitions have been submitted, with a total of 31, 39, 68, 176, 27 and 48 signatures.
In addition to the above, a public meeting was held on 1st September 2004. In total 127 residents provided an RSVP to the Council, representing 117 households. The key concerns or objections raised at this meeting, as summarised by the Chair, is reproduced below:
(i) Traffic – along Lime Grove, and rat-runs through Myrtle, Acacia, Hawthorn. (ii) Traffic – Eastcote Road and Fore Street (iii) Density – consistency with UDP (iv) Schools and Medical Facilities (v) 3 Storey buildings –3 families rather than 1 family in a building (vi) Parking provision – does not look adequate on illustrative plan (vii) Preserve the character of the environment and conservation area (viii) Live-work units – traffic and parking generated
A more detailed summary of the issues raised by resident submissions and petitions to this application is provided as an attachment to this report.
Elected Representatives
Hillingdon Four members of the Liberal Democrat Group, Cllr Carey, Liberal Cllr Webb, Cllr Cox and Cllr Gettleson, wrote to register their Democrat formal objection to the planning application. In summary, Group the following concerns were raised:
Eastcote Road Access – This access is not of concern unless there is a through route linking the two proposed access points. Needs to be a physical barrier between the two.
Lime Grove Access – This is a major concern due to increased traffic and parking restrictions in this quiet residential road. Traffic counts illustrate an existing rat-run problem off Lime Grove. Concerned that the development’s additional traffic will seek to avoid the Lime Grove/ Elm Avenue Junction and rat run through streets such as Acacia and Myrtle. Rat-run a problem due to schools/ safety.
Transport Report – The traffic data includes reference to 30 properties in Kent Gardens whereas there are 50. We suspect that a bus link through the site has been considered in estimating traffic flows. A bus route along Lime Grove is unacceptable.
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Social Facilities – Existing problems with access to a general practitioner, dentist, and deficiencies in primary and secondary school places will be worsened. Utilities may not cope eg sewerage, drainage.
Other – More residents should have been notified by letter.
Please note that all objections to the application are provided on file and are available for public viewing.
John Wrote 2 cover letters enclosing copies of correspondence Wilkinson MP from constituents, which had been received by LBH. The MP requested that the concerns of his constituents be taken into account in the Council’s consideration of the application and that residents be included in the consultation process, such as Myrtle Avenue.
External Consultees
Greater The Planning Decisions Unit advised that the application London does not appear to be one classed as strategic by the Town Authority and Country Planning (Mayor of London) Order 2000. Accordingly, the planning decisions unit will not be commenting on the application however they have passed this to the Bio-diversity Team in case they wish to comment.
The Biodiversity Team provided an officer view of the application. It does not constitute a formal response. The Ecological Appraisal ignores the potential increase in visitor pressure on the Highgrove Nature Reserve from residents of the new development. The nature reserve will be a valuable amenity for these residents, and it is reasonable to expect the applicant to contribute to the enhancement of the reserve. In particular, works to improve the pond and ditch would be valuable. This should aim to restore the water bodies to a state in which they could support crested newts if there is still a population of this protected species in the area. Removal of tipped rubbish would also be valuable, and would help to discourage further tipping. Provision of new interpretive materials and the establishment of a fund for ongoing routine maintenance could also be considered. These improvements to the nature reserve could be secured through a Section 106 Agreement. There are concerns over the thoroughness of the protected species survey for crested newts. However, as the application site appears to lack any suitable terrestrial habitat for newts, it is unlikely that there would be any impact even if crested newts still breed in the adjacent nature reserve.
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English English Nature can confirm that the proposals will not affect Nature any statutory sites (eg Sites of Special Scientific Interest). We note that surveys undertaken by Defence Estates show no records of protected species. However the application site is near the High Grove Nature Reserve that has been identified as a ‘Site of Borough Importance Grade 2’ and we therefore recommend that you fully consult with the Greater London Authority Biodiversity Unit. We strongly support measures to enhance the ecological value of the application site and measures, outlined in the submission, to protect and enhance the wildlife value of the nearby High Grove Nature Reserve.
The Wildlife It appears that a full survey of Great Crested Newts (a Trusts legally protected species) on the adjoining Nature Reserve was not carried out. We strongly recommend a qualified licence holder undertake this survey, and if found to exist, that a terrestrial habitat be provided for them as part of the proposals. Also have concerns about the thoroughness of the bat survey. If the application were approved, would like to see greater commitment to enhance the adjoining Nature Reserve, which will act as a valuable resource for the residents. Conservation works should include trimming back trees around the pond and ditch outside the bird nesting season to let in light, removing rubbish and consideration of methods to discourage future fly tipping in the site. Also upgrading of site interpretation such as signs and a long- term maintenance budget is highly recommended.
Primary Care The Primary Care Trust have already provided detailed Trust support for the previous application, 10189/APP/2003/1438, seeking a contribution toward the provision of additional GP services and the expansion of existing GP facilities in order to accommodate the increased demand likely to be generated by the proposed development. As discussed at that time, the existing primary care facilities in this area are already stretched and could not sustain the influx of up to 900 new residents. Depending on the future population mix of this site, it may be necessary to increase provision of both health visitor and district nursing staff. Consideration should also be given to the special needs of both the elderly and families with young children in accessing appropriate healthcare facilities. The development should include the provision of health and community facilities and that planning obligations would need to include scope for a contribution towards the expansion of health facilities in the area.
While the PCT indicated during the previous application that
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it would seek the erection of healthcare services on the subject site, this is no longer the case. Rather the PCT have requested a financial contribution of £147.30 per resident, based on the Draft Supplementary Planning Guidance for Health Facilities, which would equate to around £150,000 depending on the final dwelling density and mix.
Transport for The developer has produced a Transport Assessment but it London does not extend as far as the A40 Polish War Memorial Roundabout which is the TFL’s main area of concern as this junction is already operating at capacity during peak periods. In response to this comment, the applicant provided additional advice. This additional information advised that negligible increased flows are predicated at the A40 roundabout as a result of the development and far more increase in traffic could occur through simple daily variation in base flow. TFL subsequently advised that the response provided by the applicant was acceptable and that TFL had no further comment to make.
In response to queries from Council officers regarding public transport TFL further advised that the level of development proposed would be very unlikely to result in capacity problems on Bus Route H13 (Eastcote Road) and that no sustainable service enhancements are likely to be proposed in relation to this development.
Environment No objection, subject to a condition relating to surface water Agency control.
English The RAF base lies to the immediate south of the medieval Heritage settlement of Eastcote, which is known to have been established in at least the 13th century. As this was a non- nucleated settlement, farmsteads and houses may have extended over a considerable area. The proposed development is for a large residential scheme that will clearly involve a considerable amount of construction and ground disturbance. The proposed development may therefore, affect remains of archaeological importance, depending on previous truncation. It is not considered that further work need to be undertaken prior to determination of this planning application but that the archaeological position should be reserved by attaching a condition to any consent granted under this application. It is also recommended that an archaeological desk based assessment be submitted in support any details application.
Metropolitan No objections subject to appropriate conditions. All reserved Police matters applications are to have regard for the Council’s
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(CPDA) Supplementary Planning Guidance on Community Safety by Design. All social housing and ideally the whole estate should be designed to Secured by Design standards. The Police are particularly concerned about establishing clear circulation patterns through the development. They do not want excessive permeability. Furthermore, adequate barriers/ fencing will be required to separate public and private space to minimise the potential for crime. Good quality lighting is required for public areas, such as footpaths, the central garden and internal road network. The community facility should have a defined and secure boundary and appropriate security including CCTV. Care needs to be taken that soft landscaping does not interfer with natural surveillance of the public domain.
Sports The proposal could involve the construction of up to 380 England new dwellings which would produce a population increase of some 900 people. Sport England considers that residential development of this scale will generate additional demand for sports facilities and physical activity which should be addressed as an integral part of building sustainable communities.
I note that L.B. Hillingdon has supplementary planning guidance that supports seeking developer contributions for community facilities, including open space and indoor leisure and recreation.
The applicant’s development brief refers to a minimum of 0.7ha of new open space being incorporated to meet the NPFA standards for the provision of informal open space and children’s play areas. However, the NPFA full standard would also indicate an additional 1.4ha should be provided for outdoor sport for this level of population. While this may not be entirely realistic in this case, it does point to the desirability of accommodating active outdoor sports uses in some form. Sport England suggests that there is scope for including one or two multi-use games areas (standard size 40m x 33m for two court area) within the development and that this should be considered to help meet community needs, particularly of young people for outdoor sport.
Subject to the above matters receiving further consideration, Sport England does not raise an objection to the application.
Thames The ability of local sewers to dispose of foul and surface Water water will need to be determined. If investigations find that insufficient capacity is available, Thames Water will provide the additional capacity as soon as practicable. To ensure
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that Thames Water has sufficient lead-in-time to provide such additional services, Grampian condition requiring adequate site drainage is necessary. In addition, it is recommended that Petrol/Oil interceptors be fitted in all car maintenance/parking/washing facilities.
Transco Forwarded plans of those pipes in the vicinity of the site owned by Transco in its role as a licensed gas transporter. These plans indicate that there are a number of gas mains that run through the site which will need to be taken into account at the construction stage.
EDF Energy No comments received.
London Fire Requires that the development comply with Part B of the and Building Regulations. The authority also provided a copy of Emergency a guidance note similar to B5 of the Regulations. Planning Authority
Ruislip Traffic Residents The development is likely to attract more vehicles to the site Association than the allocated parking spaces and this will result in a substantial number of movements each day, particularly at peak hours. Both Eastcote Road and Elm Avenue are important distributor roads and already carry a relatively high volume of traffic. The proposed width restriction in Elm Avenue at the junction with Lime Grove and Oak Grove, whilst beneficial to the development, is likely to impede the traffic flow on this road. Similarly the provision of traffic lights on Eastcote Road will also affect the flow of traffic on this road. We would be interested to know whether consideration has been given to combining the site access with that of Highgrove House. At this point better visibility would be available from all directions. Myrtle Ave and adjacent roads to the west are already used as an alternative route by traffic travelling to and from Eastcote. The use of this route will increase as a result of the development and consideration needs to be given the effect this will have on these roads.
Education We understand there is already a need for additional primary and secondary school places in the area and note that the applicant is prepared to fund additional places generated by this proposal. To ensure these additional places are available when required consideration needs to be given now to their provision.
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Medical We support the Primary Care Trust request for an expansion of GP, health and social services provision on the site. It is not clear whether the proposed 170 sq metre building would be adequate for all of these requirements.
Leisure Apart from expanding facilities at Highgrove Swimming Pool, provision needs to be made on site for dual purpose accommodation for social activities such as a local playgroup, youth club etc. This would help to avoid some of the social problems experienced on new developments.
Layout and Design We would suggest that any housing designed for elderly residents should be located as close as possible to local facilities and bus routes. We trust the principles set out in the ‘SPG Community Safety by Design’ will be adopted.
Internal Consultees
Highways Northern Access (Eastcote Road): Engineer Three options were considered by the developer’s consultant: 1. Priority junction together with a mini-roundabout at the junction of Fore Street / Eastcote Road in order to reduce the speed of traffic on Eastcote Road if deemed appropriate. 2. Priority junction together with the option of a speed table at the junction of Fore Street and Eastcote Road 3. Signalisation of the site access and the Fore Street / Eastcote Road junction.
The results of the analysis show that the formation of a mini-roundabout will result in significant queuing on Eastcote Road and this option is therefore unacceptable.
Speed tables are suggested in order to slow traffic on Eastcote Road if deemed appropriate. Eastcote Road is a classified road (B466) and is busy main route linking Ruislip with Pinner and Northwood Hills. It is also a bus route. A speed table is not recommended for this road, central islands where they can be accommodated would be more appropriate. A speed survey conducted during the period 28 Sept 04 to 11 Oct 04 indicates 85th percentile wet weather speeds of 35.5 southbound and 33.5 northbound at a location south of Highgrove Way.
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The traffic assessment shows that a priority junction will accommodate the predicted traffic. However, the signalisation option provides opportunity to find solutions in terms of safety and would overcome any deficiencies in visibility requirements. It could also provide an improvement to the capacity of Fore Street and benefits pedestrians wishing to cross Eastcote Road.
The proposed access into the site off Eastcote Road involves the creation of a signalised junction. As part of the signalisation, traffic coming south down Eastcote Road will still be able to turn right into Fore Street. Because of the width of the highway in the vicinity of Fore Street, it is not possible to accommodate a right hand turn land should it be deemed necessary.
Modelling by the applicants that has been carried out to date shows that even with vehicles turning right into Fore Street, that the highway movements will not be prejudicial to the free flow of traffic. However comments from Transport For London (TFL) point to inconsistencies in the way the right hand movement have been modelled. Therefore with both existing and proposed traffic levels it has not been demonstrated that vehicles turning right into Fore Street at the levels likely to arise will not be detrimental to both highway and pedestrian safety and the free flow of traffic.
Accidents-There were 4 accidents in the 3 years to October 2002, three slight and one serious. The serious accident involved a motorcyclist who lost control on a bend and hit street furniture. There were three accidents in the three years to April 2004, one at the frontage of the site and two at the Fore Street junction.
Southern Access (Lime Grove): This access is intended to serve up to 189 (previously 225) proposed dwellings. Lime Grove has a width of approx 7.3 to 7.6 metres, which gives it a link capacity of 1300 vehicles per hour in the busiest direction. This capacity is based on a road type with unrestricted parking. The predicted flows on Lime Grove in 2005, with the development traffic are AM peak – 173 vehicles/hour southbound (3 vehicles per min) and 144 vehicles / hour northbound. PM peak – 128 vehicles / hour southbound and 199 vehicles / hour northbound (3.3 vehicles/min). The analysis also shows that the Lime Grove / Elm Avenue junction will work within capacity. Currently two-way traffic in Lime Grove is impaired due to parked cars and there is
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an ad hoc shuttle working.
This is to be regularised by the introduction of waiting restrictions at predetermined stretches of the highway. In order to further reduce the impact on Lime Grove the number of dwellings accessed from Lime Grove could be restricted to 150.
Accidents- There were 4 recorded accidents in the three years to October 2002, all of them ‘slight’. Two were at the Lime Grove / Elm Avenue junction. In the three years to April 2004 there have been 5 accidents in Elm Avenue, none at Lime Grove / Elm Avenue junction.
Policy and Principle of Redevelopment: The loss of the existing Environmental uses, as part of the comprehensive redevelopment of the Planning site, does not conflict with any UDP policy objectives. RAF Eastcote is used primarily as office and residential accommodation by the US Military in supporting the largely administrative function of this site. The site does not, however, form part of any Industrial Business Area (IBA) as shown on the UDP proposals map and the administrative function of RAF Eastcote means that any loss of employment would fall outside of the remit of Policies LE2 and LE4 respectively. Nevertheless, it is noted that existing personnel would largely be located to the nearby RAF Uxbridge and so there would no noticeable impact on employment in the area.
Density: Residential redevelopment across a significant proportion of the site would represent an appropriate use of previously developed land within a largely residential area – in accordance with local, regional and national planning objectives. Nevertheless, the density of development should reflect the location of the site and its level of public transport accessibility. Whilst residential density on the site should accord with the provisions of Policy H6 and paragraphs 7.13 and 7.14 of the UDP, regard should also be had to both the (ODPM) Residential Density Direction (2002) which requires development to exceed 30dph (to avoid government call-in) and in particular, Policy 4B.3/Table 4B.1 of the London Plan. Both are material considerations.
Given the site has a PTAL score of 1 (taken from all egress points on the site) – the lowest possible score - residential development will be expected to take place at a density of between 30-50 dwellings to the hectare and 150-200 hrph, in accordance with Table 4B.1 of the
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London Plan. The proposed redevelopment will provide up to 50 dwellings to the hectare, leading to a density approaching 250hrph – implying a greater number of larger units than the site may be capable of accommodating. If the site cannot satisfactorily accommodate development at 250 hrph, it is suggested that the density be reduced to approximately 230 hrph, reflecting the London Plan average unit size for PTAL 1 areas of 4.6 hr/unit.
Given the present character of the site and surrounding density, development in excess of 250hrh/50u/a is unlikely to be achievable.
Mix of uses: As discussed in relation to the previous application 10189/APP/2003/1438, it is considered appropriate to seek a mix of uses across a modest part of the site, in line with government guidance (PPG1, PPG3) that seeks a mix of uses where possible on larger sites. The current application now proposes a community use at the front of the site and the provision of live work units. These inclusions should ensure that a modest amount of mixed use development occurs on the site in line with government guidance. In respect of the community uses, it is suggested that the range of acceptable D1 community uses (eg. healthcare, crèche, nursery, community hall) be prescribed as a condition. In respect of live-work units, it is suggested that 3% of all units be provided on a live-work basis.
Whilst exceptionally large residential schemes might be expected to have full regard to the provision (on-site) of land for school places, the redevelopment of RAF Eastcote is not considered to fall within this category; the Mayor of London does not specifically require referral on schemes of less than 500 dwellings, whilst 1,000 dwellings is recognised to be the threshold to constitute EIA development. Notwithstanding the need to seek funding for school places, the issue of land availability for education provision is not considered to be the responsibility of the developer on a scheme of this size.
Given the need to provide a greater mix of uses on the site, whilst keeping residential density below 250 hrph, it may become necessary to reduce the residential land area and number of dwellings from the present level of 375 dwellings.
Affordable Housing: The applicants have indicated a
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willingness to provide affordable housing on-site. Given the size of the site, in excess of the Policy H11 threshold, this should all be provided on-site and agreed as part of the outline proposals. Notwithstanding the provisions of Policy H11, regard should be had to Policy 3A.8 of the London Plan which seeks a 70:30 split out of the overall 35% target for residential/mixed use schemes – equating to 25% social rented and 10% intermediate (key worker) housing. It is noted, however, that the Examination in Public (EIP) Panel report recommends that the 35% target for Hillingdon be deleted to provide Hillingdon (as with all boroughs) “greater flexibility” to negotiate on individual sites. Nevertheless, given that the Mayor’s provisional 25% social rented provision simply equates to the level sought in Policy H11, it is considered appropriate to seek 25% social rented on the site, along with a further 10% in the form of intermediate housing.
Section 106 Financial Contributions: The applicants should be made aware of the approximate sum that will be sought in respect of funding for school places, in accordance with the Supplementary Planning Guidance (SPG). It may also be appropriate to seek a financial contribution to assist in the improvement/maintenance of Highgrove Nature Reserve, given the increased numbers living in the area following any redevelopment of RAF Eastcote and the greater volume of people wishing to use Highgrove.
Access and Parking: The redevelopment of the site, at a significantly greater density and intensity of use than the present occupiers, will generate increased trip movements. Access into the site will need to be assessed in accordance with the provisions of Policy AM7. Whilst parking provision is due to be considered as a reserved matter, the level of parking is likely to influence the layout and density of development. The 2nd Deposit Draft standards, approved for DC purposes, seek a maximum of 1.5 spaces/unit for communal parking and 2 spaces/unit for curtilage parking. Given the poor public transport accessibility of the site, parking provision close to or at the maximum is likely to be needed. Detailed advice on the ability and capacity of surrounding roads to accommodate the development should be sought from the Traffic DC section.
Conclusion: PEP support, in principle, for the proposed redevelopment of the site for a predominantly residential scheme up to a density of 230-250 hrph. Nevertheless,
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there may need to be a modest reduction in the number of dwellings, in order to accommodate a mix of uses across part of the site.
Urban Design No conservation designations apply to the actual site itself. and The existing buildings are of no special architectural or Conservation historic interest. The area is situated on the boundary of Officer the Eastcote Village Conservation Area, to the north west of the site.
The site is divided in two parts, of quite different character. The northern part has a more dramatic and interesting topography, while the south area is flat. One of the greatest qualities of the site is the substantial tree belt which surrounds the site, which provides a pleasant backdrop and a valuable framework to the site. The existing vegetation gives the site character and some climatic shelter. Every possible effort must be made to retain the existing tree belt, and the few mature trees/tree groups which are found within the actual area. From a conservation point of view, it should be noted that there are two adjacent listed buildings situated in the conservation area to the north of the site, along High Road Eastcote. It is vitally important that the setting of these listed buildings is retained intact.
The detailed design of the new access and alterations at Fore Street, including new traffic lights, needs to be studied in detail in the forthcoming design process in order to retain the character and appearance of the adjacent Eastcote Village Conservation Area (Policy BE4 BE13) and listed buildings (Policy BE10, PPG15).
From an urban design point of view, the principle of residential redevelopment is supported. In terms of scale, a combination of two to three storey buildings would be appropriate on this site.
Chief One of the Governments key objectives is to sustain and Executive’s enhance the vitality and viability of town centres. The key Office to making the town centre sustainable is to ensure that it is attractive, safe and accessible to local residents and that the facilities available are used by local people.
There is growing awareness within the Council that this concept should not just be applied to the major centres such as Hayes and Uxbridge but that efforts need to be made to sustain and develop the smaller town centres such as Ruislip, Northwood, Eastcote and West Drayton.
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No one development will be able to provide the level of funding required to support the initiatives in each of the centres, but by securing contributions from a number of developments a range of projects, which support the viability of local centre can be pursued. The size of the development on the RAF Eastcote site will have an impact on the local town centre in terms of the number of people it will potentially bring into the town centre.
Ideally Eastcote and the other smaller town centres would each have their own Town Centre manager and supporting strategy. This is the objective we need to be striving to achieve. Consideration is now been given to establishing a town centre initiative for Eastcote.
Based on the example of Hayes it costs in the region of £85,000 per annum to run a Town Centre initiative. Uxbridge has a budget of £100,000. This includes staff, promotional activity and environmental improvements.
Securing £17,000 towards town centre initiatives from the Eastcote development seems a reasonable contribution given the size and potential impact of the scheme.
Housing Housing Services supports in principle the redevelopment Directorate of this site to provide new homes. However we are concerned about what we consider to be a potential missed opportunity to provide much needed affordable housing in the borough.
The London Borough Of Hillingdon 2001 Housing Needs Survey, using techniques recommended as good practice, estimates there is an annual shortfall of 2,872 affordable homes in Hillingdon for the five year period 2002-2006. The Council’s Housing Strategy estimates there will be a shortfall of 5,698 affordable homes for priority housing needs for the period 2002-2007.
In the period April 2002 to March 2003 the Council accepted 958 households as homeless. Only 549 of these households were provided permanent affordable housing in either council or housing association homes. The balance of 409 households accepted as homeless in 2002/03 were placed in temporary accommodation paid for by the Council. This trend of more homeless acceptances than discharges has been the norm for a number of years and has resulted in a steady annual increase in the number of households in temporary accommodation.
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I would suggest that the Council could seek a provision of 50% affordable housing rather than the proposed 35%. This should be made up of 35% affordable rented accommodation and 15% intermediate housing (low cost home ownership options for key workers and other households unable to afford market housing).
The requirement for 50% affordable housing is now supported by the London Plan published in February 2004. In addition, the Greater London Authority’s (GLA) comments on recent residential planning applications like the Honeywell Site, Trout Lane and RAF Porters Way (pre application comments), where they have suggested that larger developments can accommodate a 50% affordable housing requirement, suggests the GLA would direct the Council to seek 50% affordable on the RAF Eastcote site.
The GLA suggest in its draft Affordable Housing Supplementary Planning Guidance (July 2004) that a financial appraisal of the proposed development has to be carried out before any planning decision is made. This is because the presumption now is that the applicant has to prove to the local planning authority a requirement for public subsidy, if any is required, to fund the provision of affordable housing.
As a general rule of thumb, the GLA suggests 35% affordable housing should not require any public subsidy and 50% affordable housing would require some public subsidy to make a development viable.
It is very important to establish exactly how much subsidy is required to deliver the affordable housing because public subsidy cannot be guaranteed and affordable housing requires a significant amount of subsidy, particularly for affordable rented homes. The Council needs to decide whether to require 35% or 50% affordable housing and then carry out with the applicant a financial appraisal to determine how much, if any, public subsidy would be required to deliver the affordable housing. This issue is set out in more detail in the annex to the draft London Plan Affordable Housing SPG.
Youth and Facilities that have been identified as needing expansion Leisure or improvements to accommodate the increase in population are discussed below:
Highgrove Pool and Leisure Centre: As discussed for
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the previous planning application 10189/APP/2003/1438, the nearest leisure centre to the proposed development is Highgrove pool and leisure centre, which is approximately 300 metres away and there is already a waiting list for swimming lessons and associated classes. This close proximity suggests that we would attract a significant amount of users from the housing proposal. This potential increase would create a saturation problem at certain times (school holidays, public holidays etc) pushing the capacity of the pool beyond its limit. In addition to the capacity of the pool tank there are issues around providing additional changing rooms, parking and swimming lessons for the increased custom predicted. All of the above would be a minimum requirement to allow the pool to function effectively but there are some additional activities that could be designed into the pool building, this would reduce the pressure on the swimming side and provide a more diverse range of activities for the local community.
Youth Club Facilities: The development of 375 units in the Eastcote area is expected to produce 938 additional residents of which there is likely to be an increase of 100 young people in the ward. The standard requirement for the number of Youth Service contacts per 1000 of population within the 13-19 target age range is 25%, and the standard requirement for the number of individuals involved at least 4 times a month is 15%. The 2001 Census figures for Eastcote show that there is a population of 1197 10-19 year olds. If this figure is used then the additional 100 young people referred to above is equal to 8.35% increase in population. The estimated cost of providing a Youth Centre building is £150,000. The Service is therefore requesting that the applicant contribute to the cost of funding Youth Centre Facility improvements in Eastcote in the order to £12,500.
Green Spaces The Green Spaces Team has no objection to the proposed Division development but supports a Section 106 agreement to seek funds to compensate the fact that the new development will directly create a need for new, additional and/or enhanced facilities and community infrastructure pertaining to open space facilities and recreational provision.
The area surrounding the development site does not have a play facility for children within easy walking distance i.e. within 400 metres. The closest playground is only a small housing site, containing only enough suitable equipment to reach a Local Area for Play (LAP) standard playground.
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Therefore, because of the legitimate increase of usage directly created by the proposed development, Green Spaces would stipulate that on-site facilities need to be incorporated, “related in scale and kind” (Supplementary Planning Guidance for Planning Obligations). This would require a children’s play area: a minimum of an National Playing Field Association (NPFA) recommended Local Equipped Area for Play (LEAP) standard, implemented to LBH council standards. There will also be a need to maintain this new playground, with repairs to inevitably damaged equipment (minimised by adhering to the council’s standards) and monthly inspections (bi-monthly in the summer months). Thus a commuted sum would be a prerequisite. Indeed, should the developer desire to dedicate the space to the Council; the Council would agree to accept the space, subject to a commuted sum for 20 years maintenance, which will need to be paid to the Council prior to handover occurring.
The Green Spaces Team has also considered the provision of recreational open space, since the proposed development will not have a suitable sized on-site provision. The outdoor sport/recreation areas surrounding the site are at full capacity, since all pitches are fully utilised (leased to local clubs). It is therefore deemed that without providing any extra facilities/sites, “strain [would be] placed on the existing local infrastructure to the detriment of the existing local community and public resources would be placed under greater pressure”(SPGPO). Green Spaces would therefore stipulate that adequate financial provision is made to provide outdoor/recreation spaces on sites surrounding the development area, in order to “safeguard the local environment”(SPGPO) from the increased use, and provide the new development with such spaces off-site. A commuted sum would be a prerequisite.
Environmental Should the application be successful, the permission Protection Unit should be granted subject to the following conditions: (a) A scheme to minimise pollution - The scheme may include such measures as set out below. • Energy efficient building design • Car parking restrictions in accordance with the Council’s adopted parking standards. • Green Travel plans that aim to minimise the use of cars and encourage the use of public transport and other alternative means of transport. • Construction works management control measures
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– dust noise, complaints procedure (b) Hours of Operation for non-residential uses – 8am to 6pm Monday to Friday and 8am to 1pm Saturday (c) Delivery/loading hour restrictions - 8am to 7pm Monday to Friday and 8am to 4pm Saturday (d) Informatives on – bonfires, construction site noise
Social Services Social Services would like to be able to bid for some Supported Housing provision within this development, in collaboration with Housing colleagues. This will need to be worked up but Social Services are currently proceeding with a modernisation programme for our clients with learning disabilities living is large residential hostels (including Bourne Lodge, South Ruislip). Future residential requirements for this client group will primarily be procured through registered social landlords.
Trees and Existing Situation: The application includes information Landscape about the existing trees in the form of a tree survey. The tree survey report indicates that most of the 192 trees on the site are in good condition, none are over-mature and that a large proportion (about 70) of the trees are 10-20m+ tall. At the present time public views of the trees are limited to the road frontage, but the visibility of the trees would increase significantly if the site were to be redeveloped for housing, roads and open space. In terms of policy BE38, the tree masses close to the boundary and footpath merit retention as part of and therefore constrain the redevelopment of the site.
The Illustrative Layout: One of the design principles in the development brief contained in the planning statement is the enhancement of the landscape of the site. New landscaping should be used to integrate the development into the surrounding area and provide a high quality landscape setting. The ‘Illustrative Layout’ suggests the retention of the key individual and groups of trees supplemented by new tree planting and landscaping to provide a landscape setting to the residential development and the open spaces, and to enhance the High Road frontage. In some areas of the illustrative layout the buildings (houses and blocks of apartments) would be too close to the retained trees. The layout of the site should be designed to secure the long-term retention of the trees, taking account of their growth potential. This will be a complex process, which will need to take account of
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several interrelated site factors, including levels, hydrology and surroundings.
Tree Protection: The protection of the trees at this stage of the process, while the site is Crown land owned by the MOD, is complicated particularly as this is an outline application. The various options to secure the long-term retention and management of the trees should be carefully considered. It is not expedient to make a tree preservation order at this stage, but to require and secure the retention of the trees (until such time as a full permission is granted and/or an order is made) by a planning obligation.
A number of conditions should be applied to any planning consent including Conditions TL1, TL2, TL3, TL4, TL6, TL7 (5 years) and 31 (Circular 11/95) (reason similar to TL7, but long-term).
Corporate The following comments are provided on behalf of the Property Council as an adjoining property owner. Strategy Group 1. The Scheme is primarily for a high density residential development which is likely to put pressure on many existing services including education, social services and health. The development should, therefore, provide means of meeting the additional pressures on these services created by the development.
2. The development will be accessed from Eastcote Road directly and from Elm Avenue via Lime Grove. Both Eastcote Road and Elm Avenue are busy distributor roads which are particularly heavily trafficked at peak hours. The residential development of the site is likely to generate significant additional traffic from people travelling to work or on school trips particularly during peak hours. This is likely to lead to traffic congestion around the accesses to the site and Lime Grove/Elm Avenue junction which will be detrimental to the amenity of local residents particularly in Lime Grove and particularly at the densities proposed.
3. The junction onto Eastcote Road as designed is likely to be dangerous as it will be close to bends in Eastcote Road in both directions. An attempt has been made to alleviate this by introducing signalised junctions both on entry to the site and at Eascote Road/Fore Street junction. However, due to the position of the proposed access to the site this is still unlikely to fully resolve the potential danger in addition to which congestion is likely to develop in traffic moving along Eastcote Road in peak hours. One possible
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solution would be to move this proposed junction further to the west to link it with the access to and from Highgrove House. This would place the junction on the outside radius of one bend in Eastcote Road and further away from the other and therefore greatly improve visibility and safety.
Education The site is within an area that is experiencing pressure for Directorate nursery, primary and secondary school places and, as such, a contribution is necessary. To address this, it is proposed that the applicants be required to enter into a S106 Agreement that obligates them to provide a financial contribution towards nursery, primary and secondary school places in the Ruislip and Eastcote Area commensurate with the estimated child yield of the development as calculated in the formula prescribed in the Supplementary Planning Guidance to the Hillingdon Unitary Development Plan entitled 'Seeking Funding for School Places from Residential Development' adopted in October 2003. Current estimate, based on predicted impacts (details of total number of habitable rooms not known at outline application stage) is that a monetary figure of around £2.6m would be required for the proposed 375 dwellings.
Main Planning Issues
3.17 The main issues are considered to be:
(i) Principle of the use (ii) Density and building scale (iii) Accessibility and traffic impacts (iv) Impact on the Environment and Conservation Area (v) Impact on Residential Amenity (vi) Impact on Local Services and Facilities (vii) Planning Obligations
(i) Principle of the use
3.18 The site remains undesignated under the Hillingdon adopted Unitary Development Plan. It does not form part of an Industrial Business Area (IBA). Policy H8 provides for the change of use from non-residential to residential land use provided a satisfactory residential environment can be achieved, the existing use is unlikely to meet a demand for such and the proposal is consistent with the other objectives of the plan.
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3.19 The RAF Eastcote site has been identified for disposal as part of a Ministry of Defence rationalisation programme for London, known as Project MoDEL. The application documents advise that if RAF Eastcote is not disposed of, this will have implications for their rationalisation programme and that “RAF Eastcote will continue to make inefficient use of land.” (pg9). It is evident that RAF Eastcote has been under utilised for some time, with many of the site’s 28000m2 of buildings being vacant. Furthermore, the disposal of RAF Eastcote will not result in a noticeable impact on employment in the area as the applicant’s planning report advises that RAF Uxbridge is to serve as a core site for the US Navy. The under utilisation of RAF Eastcote provides justification for the site’s redevelopment to residential purposes in compliance with Policy H8 of the UDP.
3.20 The site falls within the definition of previously developed land as per PPG3: Housing. Development of a predominantly residential development across the site will represent an appropriate use of previously developed land within a largely residential area in compliance with local, regional and national planning objectives. The site is well located in proximity to Eastcote Village, and a variety of local services and facilities, and transport infrastructure. A satisfactory residential environment can be achieved as required by Policy H8 of the UDP.
3.21 The application proposes to incorporate some live-work units on the site and a community facility. The Council’s Policy and Environmental Planning Manager has indicated that a mix of uses across a modest part of the site, is supported and is in line with Government Guidance (PPG1 and PPG3).
(ii) Density and Building Scale
3.22 As discussed at 3.6 of this report, the application is for a density of up to 50 dwellings per hectare (some 375 dwellings). The applicant’s Development Brief indicates a principle of locating 3 storey apartment buildings near the eastern boundaries of the site to assist in achieving this density. The applicant has submitted an illustrative layout with a total ground floor building footprint of some 16,000m2 of which 30% is 3 storey apartment buildings (186 units), with the balance being mostly 2 storey houses (189 houses). The precise density that would occur on the site is unknown until a reserved matters application is submitted and approved for the siting and design of buildings.
3.23 The three key planning policy documents that the Local Planning Authority needs to take into account when assessing residential density are the Hillingdon UDP, PPG 3, and the London Plan.
3.24 Policy H6 of the Hillingdon UDP states that the density of development depends on a balance between the full and effective use of available housing land and the building’s compatibility with its context. As a guide, new housing is expected to be in the range of 100-200 habitable rooms per hectare (h.r.p.h). Applications with densities above 150 h.r.p.h need to
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demonstrate that the layout and design of the schemes are of a quality that produce good environmental conditions and that harmonise with the surroundings.
3.25 PPG3: Housing encourages more intensive housing development. It advised that Local Planning Authorities should: • avoid developments with a density of less than 30 dwellings per hectare; • encourage housing development which makes more efficient use of land (between 30 and 50 dwellings per hectare); and • seek greater intensity of development at places with good public transport accessibility such as city, town, district and local centres or around major nodes along good quality public transport corridors.
3.26 The London Plan provides more recent guidance on density and is a significant policy document since it has recently formed part of the Development Plan for the Borough. Policy 4B.3 advises that boroughs should ensure that development proposals achieve the highest possible intensity of use compatible with: local context, the design principles in Policy 4B.1 and with public transport capacity. Table 4B.1 provides some guidance in this regard recommending densities of 30 to 50 units per hectare for a PTAL 1 suburban locations, up to a high density of 240 to 435 units per hectare for a PTAL 4 to 6 in a large town centre location.
3.27 The site’s Public Transport Accessibility Level (PTAL) score has been recalculated by Transport for London since the assessment of the previous planning application. The previous report to committee on Application 10189/APP/2003/1438 reported that the site had a PTAL of 2 which equates to a density guideline of 50-80 units per hectare. As a result the previous report supported a density of 50 units per hectare and up to 250 habitable rooms per hectare. However, it has now been confirmed that the site has a PTAL of 1b which equates to a recommended density in the London Plan of 30-50 units per hectare and 150-200 habitable rooms per hectare.
3.28 Policy and Environmental Planning support a density of up to 50 dwellings per hectare on this site. However they have advised that a density approaching 250 habitable rooms per hectare may not be able to be accommodated as this requires an above average unit size. PEP have suggested that the density be reduced to approximately 230 hrph, reflecting the London Plan average unit size for PTAL 1 areas of 4.6 hr/unit. The inclusion of live-work units may result in a decrease in the number of dwellings provided below the 375 currently proposed.
3.29 Many of the residents submissions have raised concerns with the density of the application, including that: (a) It is inconsistent with UDP guidance that new housing is expected to be in the range of 100-200 habitable rooms per hectare; (b) It is incompatible with the density in the surrounding area;
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(c) The illustrative layout fails to demonstrate how a density in excess of 150 habitable rooms can be satisfactorily accommodated on-site and harmonise with the surroundings; (d) Unacceptable external transport and service impacts of this density.
3.30 The following provides a planning response to issues (a) to (c) above. The issues raised at (d) are discussed elsewhere in this report – goto (iii) and (iv).
(a) Inconsistency with UDP Guidance on habitable rooms
3.31 The description of the development makes application for 50 units per hectare rather than habitable rooms. While paragraph 7.13 suggests that new housing is expected to be in the range of 100-200 habitable rooms per hectare, these figures are guidance rather than incorporated into the wording of Policy H6 itself. Furthermore, the London Plan supersedes this guidance. A density of up to 50 dwellings per hectare complies with the London Plan. In order to ensure that any redevelopment on this site complies with the spirit of the UDP and the London Plan density table, it is recommended that a condition be placed on any planning consent that dwelling density is not to exceed 200 habitable rooms per hectare.
(b) Incompatibility with Density in the Surrounds
3.32 At the public meeting of 1st September 2004 the applicant advised that the existing residential density in the surrounding area ranged as follows: South – 25 dwellings per hectare (due to large gardens) East – 40 dwellings per hectare North – 40 dwellings per hectare West – 60+ dwellings per hectare (Campbell Close area)
3.33 A number of submissions have argued that the proposed density should be reduced. Suggestions have ranged from a maximum of 200 dwellings (26 dw/ha) to 308 dwellings (40 dw/ha). However there is no planning requirement that applications must mirror the dwelling density in an adjoining area, therefore there is no planning basis to recommend refusal on that basis. Rather the total overall density needs to be ascertained when design and layout details are submitted with the application. For that reason, there is no objection in principle to a density of up to 50 dwellings per hectare being approved as part of the outline application. Furthermore, given the size of the land and its location adjoining the rear gardens of existing dwellings it can successfully establish its own identity. If the Council were minded to grant approval, it would be recommended that a condition be included on the consent to make clear that the density of up to 50 dwellings per hectare acts as a maximum. Council will still maintain control over the built form on the site via any reserved matters application, in the event the application was to be favourably recommended.
(c) No evidence that 150 hrph can be accommodated on-site
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3.34 Policy H6 of the UDP advises that applicants will be expected to submit sufficient details to demonstrate that the layout and design of the scheme will produce good environmental conditions and harmonise with the surroundings.
3.35 Many resident submissions have argued that the illustrative layout submitted does not achieve the above because: 3 storey apartments adjoin 3 storey townhouses 3 storey apartments adjoin 2 storey houses Buildings are too close to the boundary Privacy concerns Overshadowing concerns Impact on private views enjoyed over-site Impact on existing boundary trees Not enough open space on-site
3.36 The impact of the development’s building bulk on the character of the area and adjacent residential amenity will depend on the number of houses proposed as compared to flats and the size of those dwellings. It is understood that many residents fundamentally oppose 3 storey flat buildings on the site. However given the size of the site, at least part of the land is capable of accommodating 3 storey buildings. The principle of a mixed building height of 2 and 3 storeys is supported by the Council’s Urban Design and Conservation Officer. Concerns regarding overlooking, overshadowing, tree removal and over domination from flat buildings relate to siting and design which are reserved matters. Impact on private views is not a planning matter. The illustrative scheme anticipates some 30% of the footprint as being 3 storey apartment buildings, so there is clearly scope to either relocate these buildings if necessary or alternatively increase the proportion of units (as opposed to houses) to decrease the total extent of building bulk.
3.37 If the illustrative layout was implemented, then there would be some unacceptable impacts. For example, the apartment buildings are setback some 6 to 26metres from the property boundaries and 14 to 35metres from neighbouring dwellings. Some of these setbacks are contrary to the Council’s Design Guide on Residential Layouts and House Design, which recommends a 21 metre vision splay to achieve an acceptable level of privacy and 15metre separation to neighbouring gardens to minimise over domination. However, as discussed above, the illustrative plan does not form part of the application because siting and design are reserved matters.
3.38 As with (b) discussed above, it is recommended that a condition be included on the consent establish a maximum density of up to 200 habitable rooms per hectare.
(iii) Accessibility and Traffic Impacts
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3.39 The primary accessibility and movement policies that apply to the development from the Unitary Development Plan are Policies AM1, AM2, AM6, AM7, AM8, AM9 and AM10. These policies relate to traffic generation impacts, access to public transport and cycle facilities. The development’s performance against each of these key policies is discussed below.
3.39 Policy AM1 advises that developments which serve or draw the majority of its employees, potential customers and visitors from beyond a walking distance catchment will only be approved if it is accessible by public transport and public transport has sufficient capacity to absorb the additional journeys. The inclusion of live-work units within the development has the potential to draw potential customers in particular from beyond a walking based catchment and possibly employees. The site is served by public transport. Transport for London has confirmed that there is spare capacity within the existing bus service to cater for this development. At the reserved matters stage it will be necessary to ensure that all live-work units are appropriately located on this large site to facilitate access to public transport.
3.40 Policy AM2 advises that all proposals will be assessed against their contribution to traffic generation and their impact on congestion, particularly on the principal road network and the potential of public transport to satisfy additional demands generated. The traffic generation and impact of the development has been assessed as discussed under Policy AM7 below. Transport for London has confirmed that there is spare capacity within the existing bus service to cater for this development.
3.41 Policy AM6 advises that the Council will take appropriate measures to discourage the use of local distributor and access roads by through traffic having no need for local access. A number of residents have raised concerns that the development will result in rat-runs, namely along roads to the west off Lime Grove (Myrtle, Acacia) and encourage rat-runs through Fore Street. The Council’s Highways Officer has not advised that traffic calming measures on these sides roads are necessary.
3.42 Policy AM7 advises that the LPA will consider whether the traffic generated by proposed developments is acceptable in terms of the capacity of principal roads only. Principle roads are defined at 14.14 of the UDP as including strategic routes and London Distributor Roads. The only principle road in proximity to the site is the A4180 (West End Road). Transport for London raised concerns about the capacity of the Polish War Memorial round-a-bout to accommodate the development. In response the applicant provided additional advice concluding that negligible increased flows are predicated at the A40 roundabout as a result of the development and far more increase in traffic could occur through simple daily variation in base flow. TFL subsequently advised that the response provided by the
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applicant was acceptable. Therefore it is considered that the development is acceptable in terms of this part of Policy AM7.
3.43 In addition, Policy AM7 requires that the LPA will not grant planning permission for developments whose traffic generation is likely to:- (a) Unacceptably increase demand along roads or through junctions which are already used to capacity, especially if part of the strategic london road network, or (b) Prejudice the free flow of traffic or conditions of general highway or pedestrian safety, or (c) Diminish materially the environmental benefits brought about by new or improved roads, or (d) Infiltrate streets classed as local roads in the Borough Road Heirarchy unless satisfactory traffic calming measures can be installed
3.44 The development’s consistency with the above part of UDP Policy AM7 is discussed below: (a) Transport for London have accepted that the development will not unacceptably increase demand at the Polish War Memorial roundabout, which was their key concern. (b) The Council’s Highways Engineer has advised that Lime Grove has adequate capacity. The applicant has failed to demonstrate that the right turn movement from Eastcote Road to Fore Street will not obstruct traffic flows on Eastcote Road. This will impact on the free flow of traffic and potential highway safety conflicts which is inconsistent with Policy AM7. (c) Issue © above does not apply (d) Concern is raised by residents that the development’s traffic from Lime Grove will infiltrate adjacent streets, such as Myrtle and Acacia. See discussion at 3.41 regarding traffic calming measures.
3.45 Policy AM8 requires the Council to accord priority to the needs of pedestrians in the design of roads and traffic managements schemes. The objective of this policy would be achieved with the inclusion of a pedestrian phase in the signals at Eastcote Road. It could also be required via a legal agreement that the applicant provide a pedestrian crossing over Elm Avenue as a number of residents have identified that it is currently difficult to cross this road which will be exacerbated with the new development. In this manner, pedestrian facilities both for future residents and existing residents will be achieved.
3.46 Policy AM9 and AM10 requires the Council to take into account the needs of cyclists and incorporate additions to the cycle network shown in the UDP where appropriate. In the event that the application were recommended for approval, the applicant would be required to contribute to the cycle network via a Section 299 agreement to upgrade the pedestrian link from Eastcote Road to The Sigers and contribute to the costs of implementing the London Cycle Network in the area.
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(iv) Impact on the Environment
3.47 The Councils Environmental Protection Unit has assessed the proposed re- development of the site and raises no objections provided that conditions relating to: a scheme to minimise pollution; construction works management measures; and restricted hours of operation for the live-work units and community facility. In addition, given that the site has been used for military purposes, it may have been used for contaminative purposes before its current administrative and residential use. A contaminated land condition would therefore be necessary in the event of a favourable recommendation of the scheme.
3.48 The site is located adjacent to Highgrove Reserve which is a nature conservation site of Borough Grade II importance. The GLA Biodiversity Group advised that there are concerns over the thoroughness of the protected species survey for crested newts, however they also advised that as the application site appears to lack any suitable terrestrial habitat for newts, it is unlikely that there would be any impact even if crested newts still breed in the adjacent nature reserve. The Wildlife Trust also raised concerns about the thoroughness of the bat survey, however this was not raised by the GLA Biodiversity Group. A daytime and nocturnal bat survey was conducted on 29 July 2002, which is a time of year when all native bats would be active. This survey inspected all mature trees and buildings at the site and did not find any evidence of bat activity. The ecological surveys were undertaken by a qualified licence holder with English Nature. As neither the GLA Biodiversity Group nor English Nature have requested any additional ecological surveys nor objected to the development on the basis of impacts on protected species, the development is considered consistent with Policy EC1 and EC2 of the UDP. In the event that the application were recommended for approval, it would be necessary for a suitable planning obligation to be provided to contribute to the enhancement of the reserve which is consistent with Policy EC5 of the UDP.
3.49 Whilst investigations into the ecological values of the site has revealed few ecological features of significance, the site does contain a number of mature trees and hedgerows, primarily around the perimeter of the site, that will be worthy of retention. A tree survey has been undertaken. The Trees and Landscape Section has indicated that should the application be approved then any approval should include a mechanism to secure the long-term retention of the significant trees.
3.50 The north-western corner of the site adjoins the Eastcote Conservation Area. Policy BE4 of the UDP advises that new development within or on the fringes of the conservation area will be expected to preserve or enhance those features which contribute to their special architectural qualities. The Council’s Urban Design and Conservation Officer has advised that the setting of listed buildings needs to be retained and a combination of two and three storey buildings would be appropriate on this
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site. These are obviously reserved matter issues. The Urban Design and Conservation Officer has also advised that the detailed design of the new access and alterations at Fore Street, including new traffic lights, needs to be studied in detail in the forthcoming design process in order to retain the character and appearance of the adjacent conservation area and listed buildings. Accordingly, the inclusion of traffic lights is not inconsistent with the character of the conservation area, subject to detailed design.
(v) Impact on Residential Amenity
3.51 Policy BE19 advises that the Local Planning Authority will seek to ensure that new development within residential areas complements or improves the amenity and character of the area.
3.52 Amenities is defined in the UDP as follows: “The pleasant qualities of the environment. Amenities are those facilities which can make the internal and external environment more agreeable. In a domestic context basic amenities include fixed bath or shower in bathroom, wash/hand basin, sink, hot and cold water supply at these points, and an inside w.c. if practicable or a readily accessible outside w.c. Externally, amenities include garden areas, play areas, parks, open spaces, streetside greenness, etc.
3.53 A number of residents have objected to this application on the basis that the style of housing, namely 3 storey apartment buildings, does not fit in with the character of the area. The Council’s Urban Design and Conservation Officer has advised that a mix of 2 and 3 storey buildings are acceptable on the site. The precise location of where any 3 storey buildings should be located is to be addressed by the reserved matters application. It is understood that some residents are concerned that 3 storey apartments will not provide them with an adequate level of privacy. However the Council has controls on privacy in its Design Guide Residential Layouts and House design which would apply to the reserved matters application. There is no planning basis to recommend refusal to the application on amenity grounds because of a difference in tenure of the proposed buildings as compared to neighbouring houses.
3.54 The redevelopment of the RAF site would be required to incorporate adequate amenity space on-site to protect the character of the area (eg. retain trees), provide adequate informal recreation space on-site, and ensure adequate building separation. The provision of informal recreation and amenity space would be addressed by the reserved matters application. In the event that the scheme was recommended for approval, it would be necessary to ensure the provision of a children’s play space on- site and require the applicant to contribute to other leisure and recreational facilities in the locality by way of a legal agreement.
3.55 Many residents have also objected to the application on the basis that the additional traffic generated by the development would unacceptably impact on the amenity of the area. The Council’s Highways Engineers has
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advised that the applicant has failed to demonstrate that the right turn movement from Eastcote Road to Fore Street will not result in unacceptable impacts on traffic flows. Residents have raised concerns about noise and pollution from cars however the Council’s Environmental Protection Unit officers do not object to this application. The transport assessment and indicative scheme envisage a total of 186 dwellings on the northern portion (4.52ha) served via Eastcote Road and 189 dwellings on the southern portion (3.5ha) served via Lime Grove. Therefore the indicative scheme envisages Lime Grove accommodating proportionally more dwellings than Eastcote Road. The additional traffic represents a 4to5% increase in traffic on Eastcote Road and a c.55% increase in traffic on Lime Grove. The applicant has provided a sensitivity test demonstrating that Eastcote Road can accommodate up to 275 dwellings via the new signals. The Council’s Highways Engineer has recommended that in order to reduce the impact on Lime Grove the number of dwellings accessed from this road be reduced to 150 dwellings. If the Council were minded to grant approval, a condition could be included on any planning consent limiting the number of dwellings that can access the site via Lime Grove.
(vi) Impact on Local Services and Facilities
3.56 Concerns have been raised by residents that the development will result in unacceptable impacts on a variety of services and facilities. These have include: general practitioners, dentists, hospitals, school places, public transport, police resources, parks, gas, water, sewerage, surface water discharge, and waste services.
3.57 Policy R17 of the UDP advises that the Council will seek to supplement the provision of recreation open space and other community, social and education facilities through planning obligations in conjunction with development proposals. The Council has developed Supplementary Planning Guidance on Planning Obligations to address this issue. These policies apply to all planning applications and specifically address Primary Care Trust requirements, education requirements and leisure and recreational facilities. In terms of planning assessment and legal obligations, an applicant is usually required to provide funding to expand local facilities to cater for the new development, such as funding to build additional classrooms to house any additional children. Planning legislation does not address operational costs such as the employment of doctors or police officers as this is funded elsewhere. In addition, planning obligations are not to be used to address any existing deficiencies. IN the event that the scheme was to be recommended favourably, it would be necessary for the applicant to enter into a legal agreement for planning obligations in accordance with Policy R17.
3.58 The Council advises service utility providers that planning applications have been submitted. These service providers are required under their legislation to provide a service to all their customers (new and old) to statutory standards. Of the statutory service providers, only Thames Water
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requires a condition to be placed on the consent requiring detailed plans on storm water and sewerage design.
(vii) Planning Obligations
3.59 The proposed development represents a significant increase in population that will result in a wide range of impacts on the local community within which it is located. In order to address and in some cases mitigate this impact wherever possible, the applicant would in the event of a favourable recommendation be required to enter into an agreement under Section 299a (Crown Land) of the Town and Country Planning Act 1990 (as amended). Issues which a legal agreement should cover are as follows:
(a) Education – The applicant provides a financial contribution towards nursery, primary and secondary school places in the Ruislip and Eastcote Area commensurate with the estimated child yield of the development as calculated in the formula prescribed in the Supplementary Planning Guidance to the Hillingdon Unitary Development Plan entitled 'Seeking Funding for School Places from Residential Development' adopted in October 2003 or any subsequently approved amendments to this guidance.
(b) Health - The applicant provides a financial contribution of £147.30 per resident towards the provision of primary health care facilities in the Eastcote area.
(c) Affordable Housing – That at least 35% of the residential units constructed on the land shall be reserved for the provision of affordable housing by or on behalf of a registered social landlord.
(d) Leisure, Youth and Cultural Services - The applicant provides a financial contribution of £650 per residential unit towards improvements in leisure, youth and cultural services in the locality.
(e) Children’s Play Space – Require the applicant to provide one equipped children’s play space on-site for the use of the new residents which has an area of at least 3600m2, including a landscaped buffer around the activity zone. This play space is to be in the form of a Local Equipped Area for Play (LEAP) as described in the National Playing Fields Association Guidelines. The playground facilities are to be provided to Council’s standards. A management plan for the space shall be submitted to and approved by the local planning authority prior to implementation. The space shall either be maintained in perpetuity by the developer, or, should the developer desire to dedicate the space to Council and Council agree to accept the space a commuted sum for maintenance will need to be paid to Council prior to handover occurring.
(f) Informal Recreational Open Space – Require the applicant to provide a management plan for all informal recreational open space required on-
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site to service the development. The space shall either be maintained in perpetuity by the developer, or, should the developer desire to dedicate the space to Council and Council agree to accept the space a commuted sum for maintenance will need to be paid to Council prior to handover occurring.
(g) Outdoor Sport Facilities –The applicant is to provide a financial contribution of £84 per resident to cover the capital costs of providing or improving pitch sport facilities off-site. A commuted sum is to be provided for maintenance.
(h) Highway Works – Require the applicant to cover all costs associated with the consultation, approval and installation of: traffic signals at Eastcote Road and Fore street including associated civil engineering works and waiting restrictions; waiting restrictions along Lime Grove; waiting restrictions and works at and adjacent to the intersection of Lime Grove and Elm Avenue; and two central islands and a speed activated sign in Eastcote Road. This is to also include a commuted sum for maintenance of the traffic signals as required by Transport for London.
(i) Cycle and Pedestrian Network –
• The applicant is to upgrade the existing pedestrian link that extends from Eastcote Road to the Sigers, to details to be approved by the Council. Upgrade works are to provide adequate lighting and surfacing and ensure that both pedestrians and cyclists can use the link. • The applicant provides a financial contribution of £17.47 per residential unit towards improvements to the London Cycle network in the locality. • Require the applicant to agree to cover all costs associated with the approval and installation of a pedestrian crossing over Elm Avenue.
(j) Protection of Trees - Require the applicant to agree not to fell any trees on-site without the prior approval of the Council until such time as a reserved matters application is approved and/or a Tree Preservation Order is made. Any non compliance will attract a financial penalty and the requirement to plant an advanced tree specimen in close proximity to the tree removed.
(k) Highgrove Nature Reserve - Require the applicant to provide a financial contribution of £4,350 to improve the habitat of Highgrove Nature reserve and a financial contribution of £21,000 to upgrade the path network through the reserve linking to the Highgrove Leisure centre.
(l) Public Consultation – Require the applicant/developer to undertake public consultation prior to the submission of any reserved matters application for the site. This shall include pre-application consultation with the public, and a forum to provide feedback from the public and a
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report from the developers to explain how such consultation has informed the development, having regard to the terms of the outline planning permission.
(m) Construction Management - Require the applicant/developer to provide and adhere to a responsible constructor scheme.
(n) That the applicant meets the Councils reasonable costs in the preparation of the Section 299 agreement and any abortive work as a result of the agreement not being completed.
(o) That the applicant meets Council's project management and administration costs as set out in the Planning Obligations Strategy SPG.
It is relevant to note that there are some areas where planning obligations have been requested by various officers or residents however are not included in the range of measures above. These are discussed below:
• Affordable Housing
3.60 The applicant has offered to provide 35% affordable housing on-site. Council’s Housing Officer has requested the provision of 50% affordable housing. The Council’s Planning and Environmental Planning Manager has advised that the provision of 35% affordable housing is acceptable. On the basis of PEP’s advice, it is not recommended that the application be refused on the basis of inadequate affordable housing. It should be noted that PEP have recommended that 25% be provided as social rented housing and 10% in the form of intermediate housing in accordance with the Council’s housing needs assessment and the London Plan.
• Town Centre Enhancement
3.61 Council officers have requested a contribution to enhance the Eastcote Town Centre. The applicant has not agreed to this request. It is not recommended that the application be refused on this basis, taking into account the Council’s SPG guidance that improvements in the town centre, such as improving public areas, generally relate to non-residential uses. The population increase in the Town Centre catchment would, on balance, increase rather than decrease the sustainability of the centre by providing more customers.
Comments on Public Consultations
3.62 At the time of writing this report, 155 objections have been received against the application and 6 petitions with a total of 31, 39, 68, 176, 27 and 48 signatures. Most of the key planning objections have been addressed in the main body of this report. The planning issues raised in submissions
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concerning density, siting and design will be addressed at the time applications for reserved matters are submitted. A more detailed summary of resident objections is provided as an attachment to the report.
4.0 Observations of the Borough Solicitor
4.1 When making their decision, Members must have regard to all relevant planning legislation, regulations, guidance and circulars and also, the provisions of the Human Rights Act 1998. Further, Members must make their decision on the basis of relevant planning considerations and must not take any irrelevant considerations into account.
5.0 Observations of the Director of Finance
5.1 The officer recommendations are based upon planning considerations only and therefore, if agreed by the Planning Committee, they should reduce the risk of a successful challenge being made at a later stage. Hence, adopting the recommendations will reduce the possibility of unbudgeted calls upon the Council’s financial resources, and the associated financial risk to the Environmental Services Group and the wider Council.
6.0 CONCLUSION
6.1 This is an outline planning application for the redevelopment of RAF Eastcote. The application seeks approval of the principle of residential use of the site and means of access and a maximum density. All other matters are reserved.
6.2 The principle of residential use with some mixed-use component in the form of live-work units and a community facility is considered acceptable. The density of the development is consistent with the London Plan. The Council still maintains control over the built form to be erected on the site by requiring a reserved matters application. The Council’s Highways Engineer has raised concerns that the applicant has failed to demonstrate that the right turn movement from Eastcote Road into Fore Street at the proposed signalised junction, will not obstruct the free flow of traffic. On that basis, the application is recommended for refusal.
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Reference Documents:
(a) The London Plan (b) Policy Planning Guidance No. 3 – Housing (b) Policy Planning Guidance 13 - Transport (c) Unitary Development Plan (d) Revised Parking Polices and Standards (2001) (e) Letters of objection
Contact Officer: DEBORAH KRZEMINSKI Telephone No: 01895 556 767
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Attachment 1 Summary of Objections to the Planning Application
Responses to Traffic Issues at (A) and (B) below are to be provided by the Council’s Highways Engineer
(A) Traffic Impacts
(a) Traffic Generally in the Area
• There is insufficient capacity on the road network generally in Eastcote to accommodate a development of this scale. Roads and intersections identified as having insufficient capacity include: Eastcote Road/ High Road, Lime Grove, Elm Avenue, Park Way; Acacia, Myrtle, Hawthorn, Morford Way, Field End Road. • Junctions in the locality have no spare capacity, including: round-a-bout at top of Field End Road; round-a-bout at the bottom of Fore Street.
(b) Impact of Access at Eastcote Road
• Development should not be increasing traffic on a B road. Eastcote Road is already at capacity. • The traffic lights on Eastcote Road will cause traffic jams • The siting of the proposed traffic lights is not safe. • Impact on Pedestrian Safety of extra traffic given poor crossing facilities in the area and the number of schools. • It is currently very difficult to turn right out of Spring Drive, Acacia Avenue, Flag Walk to High Road Eastcote. The development will make this worse. • The development’s traffic that accesses via Eastcote Road will have difficulty turning right, as we do in Spring Drive. • Existing residents on Eastcote Road have difficulty accessing the road. This will be made worse with the extra traffic. In addition, the location of signals and associated islands means that some residents will have difficulty accessing Eastcote Road – for example some residents will not be able to turn right. • The traffic lights will be removing parking in Fore Street • Traffic signals will shine into resident’s homes. • One resident has done their own modelling exercise for Eastcote Road. They advised that assuming a 4:1 time ratio in favour of Eastcote Road (40 secs: 10 secs with 5 secs changeover) is employed, this would significantly delay traffic along Eastcote Road at peak periods. This cycle, when applied to single line traffic, would allow 20 cars per cycle. At peak times, traffic flows along Eastcote Road at 24 cars per minute on a continual basis. Therefore it would not take long for this deficit to cause grid lock on each of them. • Fore Street has been used as a ratrun for many years. This problem has reduced in recent years due to the difficulty turning into Eastcote Road.
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The signalisation of Fore Street will therefore bring more cars to this intersection than existing due to the improved level of access. This extra traffic will decrease safety for children going to school in the local area (4 schools in Fore Street). • Traffic emerging from Fore Street at off-peak times during the week is very low. Figures of 0 cars per minute are recorded near midday. At such times, it is totally unnecessary to stop traffic along Eastcote Road, with resulting delays and added pollution. • Fore Street access will not improve as the intersection design only allows for 6 cars to queue turning right.
(c) Impact of Access to Lime Grove
• Lime Grove does not have the capacity for extra traffic – for example it is a narrow road, cars have to do 3 point turns blocking traffic. Many residents said that it is a quiet no through road whilst others said that it is already too busy. • The intersection of Lime and Elm does not have the capacity to cater for the extra traffic. • Because the intersection at Lime and Elm Avenue is poor, cars currently use Myrtle and other streets as a rat-run between Elm and Eastcote Road (avoiding the shops) or avoiding traffic lights at the junction of Windmill Hill/ Pembroke/ Park. The rat-run traffic comprises rush hour and school trip traffic. The development would result in more traffic using this rat-run with unacceptable impacts on amenity and safety. • Queuing to access the Lime and Elm junction will block driveways. • The proposed width restriction on Elm would reduce the capacity of the road. • The change to the road geometry at the junction of Lime and Elm will cause safety problems. • Traffic volumes and queuing on Lime Grove will make it difficult for Acacia Avenue residents to exit into Lime. • Yellow lines will move parked cars into other residential streets. Competition for spaces will increase further if Council introduces a resident parking spaces in streets near the station (due to commuter parking) • Yellow lines will mean greater competition for parking spaces on Lime Grove so that residents can not park outside their homes. Particular concern at northern end of Lime near maisonettes. • Impact on Pedestrian Safety of extra traffic given poor crossing facilities in the area and the number of schools. Roads of concern include: Elm Avenue; Myrtle; • Lime Grove and Myrtle Avenue currently have many pot holes. The development will make this worse. The developer should be required to resurface these roads as they will further deteriorate with the extra traffic. • Foundations of buildings will be affected by heavy traffic during the construction phase. • Traffic calming required for Lime Grove.
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(d) Other Traffic and Parking Issues
• Parking rates proposed inadequate (assume reference to rates in Development Brief?) • The development will result in overspill parking into surrounding streets. • Lime Grove is too narrow for a bus route. • Investigate vehicle access via Azalea Walk • Traffic claming required for Myrtle, Acacia,
(B) Inaccuracies in Traffic Study
• Traffic counts done before yellow lines in Elm and alterations to traffic phasing at intersection Field End Road and Elm Avenue. • The report references 30 houses in Kent Gardens whereas there are 50+ dwellings. • Suspect that the report has considered a bus service through the site in reducing estimated traffic flows from the development. • The stated accidents at the junction of Lime/Elm does not reflect the many accidents that go unreported. • The study does not consider impact on all local roads such as the Warrender rat-run • Traffic study should have assessed impact on The Sigers and Azalea Walk • The study does not consider the traffic load from people driving to the shops and station and the like. • The summary of predicted flow changes is grossly underestimated. Are trip generation rates appropriate as they are unduly weighted to non London comparisons. • Refute the accuracy of the Parking Assessment on 30/3/04. School was closed. • Commuters are parking all-day in Lime Grove and Acacia Avenue. This has reduced the road width to one vehicle along Lime Grove, extending from the junction with Elm back to at least Acacia, and often beyond. As a result traffic piles up waiting to turn from Elm into Lime. • Some residents (live-work units) may own commercial vehicles which is not considered in the traffic assessment. • The assumed growth rate in traffic of 2.1% fails to consider the impact of the enlargement of the M25. • The traffic queue surveys are incapable of conveying traffic dangers along Eastcote Road. • No Transyt analysis included for Lime/Elm junction • Traffic worse on Eastcote Road compared to 2002 survey
(C) Density and Design Issues
(1) 3 storeys incompatible with existing context and will have unacceptable impacts on amenity. Concerns raised include: (a) impact on character of adjacent conservation area
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(b) height is inconsistent with predominant 2 storey suburban character – particular concern for Deane Way and The Sigers; (c) 3 storey flats shown 7metres from people’s back gardens. Is there a minimum distance between the new development and adjoining houses? (d) Overlooking into dwellings and gardens (e) loss of sunlight (f) loss of outlook (g) noise (h) inadequate open space Comment: Building design is a reserved matter, notwithstanding the Council’s Urban Design and Conservation officer supports the principle of a mix of 2 and 3 storey buildings on-site. See discussion at (ii) and (v) of the report.
(2) The inclusion of any flats will change the 1930s character of the area. Comment: See comment above
(3) Extra traffic would change the character of Lime Grove which is a cul-de-sac. Comment: The Council’s Traffic Engineer has advised that Lime Grove has the capacity to accommodate this traffic and has recommended that a condition be included on any consent to specify a maximum of 150 dwellings are to be served from this exit.
(4) The high proportion of social rented accommodation with cause enormous environmental problems. Comment: The inclusion of affordable housing is a government requirement. All such housing is required to be designed as secure by design. Consent conditions would be included requiring adequate lighting and CCTV.
(5) Proposed parking provision is inadequate. The one car family no longer exists. Comment: The location and volume of parking would be addressed by the reserved matters application. Council’s parking standards would apply to such applications.
(6) 6 parking spaces for a Community Facility is inadequate Comment: See comment above
(7) In order for density to be compatible with the local context it should be 40dw/ha as that is what exists in most adjacent areas Comment: The above is not sufficient basis to condition the outline approval to the maximum density suggested by the resident. The density complies with the London Plan. A consent condition is included to prescribe a maximum density of 50 dwellings per hectare and 200 habitable rooms per hectare. The design of buildings will be required to be compatible with the local context, which would be addressed by the reserved matters application.
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(8) Any flats for elderly needs to be located close to local facilities and bus routes Comment: An access statement would be required by Condition.
(9) Community safety by design controls will be required. Comment: The Council’s Community Safety SPG would be taken into account when assessing reserved matters applications. An informative to this effect could be included in any planning approval.
(10) Indicative scheme does not show parking for 750 cars Comment: The location and volume of parking would be addressed by the reserved matters application. Council’s parking standards would apply to such applications. Adequate parking is essential – if it can not be provided at-grade then it could be provided in a basement.
(11) This is a high density development. The proposed density of 250 hrph is greatly inexcess of the UDP’s guidelines of 100-200hrph. Comment: If the council were minded to grant approval then it would be recommended that the approval be conditioned to prescribe a maximum density of 200 habitable rooms per hectare. The development is not high density in accordance with the London Plan’s density scales. This density is equivalent to a PTAL 1 – the lowest density range. The maximum density in the London Plan is a PTAL 4to6 town centre with a maximum of 435 dwellings per hectare or 1100 habitable rooms per hectare.
12)The additional population would result in an increase in crime, litter and other anti-social activities. Comment: The Council’s SPG on Community Safety by Design would apply. Any planning approval would include consent conditions as recommended by the Metropolitan Police.
(13) The character of the area would change and detract from the historical nature of Eastcote. Comment: The Council’s Urban Design and Conservation officer does not object to the outline application.
(14) The development is not within walking distance of any facilities – shops, station, medical centre. Eastcote does not have a full-range supermarket. Comment: The density of the development is consistent with the London Plan’s density guidelines which take into account the site’s access to public transport. As discussed in the background to the report, the site is within walking distance to a number of facilities.
(15) The site boundary is shown as touching our garage wall – how do we maintain? Comment: Planning legislation does not over-ride property rights. Party wall legislation applies where an owner builds on the property boundary.
(16) Altered source water for trees and amended surface water drainage may damage the foundations of our house.
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Comment: Details of the site’s drainage system is required to be submitted as a condition of planning consent, as recommended by Thames Water and the Environment Agency.
(17) The development does not fit in with the style of housing in the area. This reason was accepted by the Inspectorate in January 2004 against a decision to build 12 flats in Uxbridge. Comment: The Council’s Urban Design and Conservation Officer has advised that a mixed building height of 2 to 3 storeys would be appropriate. The details of where such buildings are to be located is a reserved matter.
(18) The proposed carparking areas adjacent to the boundary will result in noise and fumes day and night. Comment: The location of carparking is a reserved matter.
(19) Can we be assured that there is no bus-route through the site? Comment: A condition would be included on any planning consent that there is to be no link for traffic (other than emergency vehicles if necessary) from Eastcote Road to Lime Grove..
(20) How will traffic be prevented from rat-running through the estate? Comment: See comment above.
(21) A maximum density of say 200 or 275 dwellings would imply a more realistic Comment: See discussion at (7) above regarding density
(22) The plans propose to building 2 storey townhouses only 6metres (etc) from our boundary with resultant impacts. Comment: Building siting and design is a reserved matter. See discussion at (ii) in report on density and design.
(23) Providing a pedestrian link from the NE corner into Azalea Walk would result in safety problems. Comment: This link is not proposed at present. All reserved matters applications will be discussed with the Police in relation to safety.
(24) What boundary fencing is proposed? Comment: This is not part of the outline application. Details would be required to be submitted to the Council for approval.
(25) What is the future of the footpath at Farthings Close? Comment: This is not part of the outline application.
(26) Object to the location of the community facility Comment: This is not part of the outline application.
(D) Landuse Concerns
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(1) Impact of live-work units – increased noise levels, extra delivery and collection vehicles, industrial/commercial waste. Comment: Consent conditions would be recommended to ensure that live- work units have minimal external impacts, such as hours of operation and use. Live-work units are encouraged by the Policy and Environmental Planning Team to provide an element of mixed-use of the site.
(2) Live-work units are incompatible with the existing context Comment: Live-work units are compatible with government policy. Conditions would be included to ensure that such activities remain low-key with minimal impact on the environment. The site currently accommodates 28,000m2 of predominantly administration/office floor space therefore a small element of live-work units (3-5%) is not inconsistent with the existing activity on-site.
(3) Dangers of bringing problem families into the borough through affordable housing Comment: Affordable housing is a requirement consistent with government and Council policies.
(4) There is no justification why a single-use development is appropriate on this site. Not consistent with sustainable development objectives in PPG3. Comment: The development incorporates residential development as well as live-work units and a community facility. This mix of landuses is supported by PEP.
(5) It is considered that on-site community and leisure facilities should be provided as, without such, the development is not sustainable. Comment: Service providers have requested S299 funding from the applicant to provide for facilities off-site so that greater efficiency of provision can be achieved because the development is not large enough to sustain, for example, its own doctor, school or leisure centre. Upgrading of existing facilities is able to occur in the locality. The on-site provision of a children’s playground is required because guidance recommends that it needs to be very close to developments since it is serving young children.
(E) Impact on Public Services/ Infrastructure
(1) Schools. Consideration needs to be given now to the provision of extra school places. Comment: A planning obligation in accordance with the Council’s SPG would be requested, as is the case for all residential developments. Issues about when the Education department require the funding to be provided would be addressed in the legal agreement.
(2) GPs and other PCT uses - chiropody, health visiting, district nursing, dental care centres. Will 170m2 community centre be adequate to cater for this? Comment: The PCT has requesting funding to expand primary care services, which would be secured via a legal agreement. The community
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facility is not being required by the PCT. It is not the role of planning to obtain operational cost funding for facilities funded elsewhere such as nursing wages.
(3) Sewer. The existing sewer fails to carry the existing load and backs-up. The development will make this worse. Comment: A condition and informatives would be included in any planning approval as required by Thames Water.
(4) Water Supply. Mains pressure in the area is already below an acceptable standard. The development will make this worse. Comment: Separate legislation sets the acceptable level of water pressure required for existing and new customers. Three Valleys Water have a duty of care to met their statutory requirements.
(5) Drainage Comment: A condition and informatives would be included on sewerage design and drainage as required by Thames Water and the Environment Agency
(6) There are currently staffing problems for schools, GPs, hospitals, police etc. Extra residents will further stretch resources. Comment: It is not the role of planning to obtain operational cost funding for facilities funded elsewhere such as nursing wages.
(7) Social and Leisure Facilities. Apart from expanding Highgrove pool, provision needs to be made on-site for local playgroup, youth club etc to minimise impacts. Comment: Council’s SPG on Community Facilities advises that Council has identified a need for £650 per new unit to accommodate the impacts of residential development through the Borough on leisure, youth provision, adult education and libraries. The Council’s Youth and Leisure team have advised that they would prefer most of that funding to go towards Highgrove leisure centre.
(8) Carparking impacts in the Eastcote town centre and at the station. Comment: The eastern access to the site is within walking distance of the town centre and the station.
(9) Electricity. Some years ago when the base was fully active, electrical power surges caused problems to Lime Grove. Will this occur again with 375 dwellings? Comment: Service providers have statutory requirements to provide adequate services.
(10) Public transport – bus and rail congestion Comment: Transport for London has advised that there is spare capacity on the bus system to cater for the development.
(F) Vegetation/ Ecology
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(1) It is unacceptable that the Council have not put a Tree Preservation Order on the site’s existing trees. Comment: Because this is Crown land different rules apply. It is proposed to protect the trees via a legal agreement.
(2) A number of residents have advised that some large existing trees could not survive if the plans go ahead due to the proximity of houses to these trees. Comment: This issue has also been raised by the Council’s Trees and Landscape Officer. Since design and siting are reserved matters this would be addressed by the subsequent applications and is not grounds for refusal.
(3) Ecological survey flawed as considered summer month only Comment: See discussion at (iv) of the report
(4) Tree survey does not show tree/s near resident garden Comment: A detailed tree survey would be required by a condition of approval. The impact of the development on these boundary trees would be considered once siting and design details are submitted. A legal agreement would be recommended to protect the trees.
(G) Other
(1) What compensation will we receive for the destruction of our surroundings? Comment: Financial issues are not a planning matter.
(2) The standard of housing will be below that in the area bringing down property prices. Comment: Financial issues are not a planning matter.
(3) The location of the proposed traffic lights will have a detrimental effect on the value of my property, degrade the conservation area. Comment: Financial issues are not a planning matter. The Council’s Urban Design and Conservation Officer does not object to the outline application
(3) The application should be amended. Suggestions offered include: (a) Warden controlled homes for the elderly (b) Provision should be made for suitable accommodation for purchase by senior citizens. (c) Access only to Eastcote Road (d) Access only to Lime Grove (e) Access should be opened up to Azalea Walk (f) Move the Eastcote Road access to next to Highgrove House (g) A school – first, middle or college (h) A recreational facility for young people Comment: There is no policy requiring the land to be used for a certain purpose such as warden controlled homes. The planning authority needs to determine planning applications put before it. The Council can not fundamentally redesign a scheme but rather recommend approval or refusal on the basis of planning policy.
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(4) Impacts of the construction phase. Comment: If the application was to be approved, consent conditions would require a construction management plan and limit hours of work. In the event of a favourable recommendation It would also be proposed via a legal agreement that the developer adhere to a responsible constructor scheme where mechanisms are in place to address potential concerns.
(5) There is some doubt as to the correct boundary of our house which may be 3metres further from our house than previously thought. These residents advised that they have asked their surveyors to look into this matter. Comment: No advice has been subsequently provided indicating that the RAF property boundary is incorrect.
(6) Application is identical to last years except now traffic is worse with the addition of live-work units and a community facility. Comment: See planning background in report.
(7) The residents who have rented land from the MoD should be offered the option to purchase bits of land they have used as their garden. Comment: This is not a planning matter.
(8) Council does not have a mandate from residents to increase population Comment: The applicable planning controls, namely the UDP and the London Plan, envisage population growth in the Borough.
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