APPENDIX 8 – BRENTFORD FC PLANNING COMMITTEE REPORT Agenda Item 5

PLANNING COMMITTEE 5 December 2013

References: P/2013/1811 00703/A/P11

Address: Land at Lionel Road South, Brentford, TW8 9QR

Proposal:

Full Planning Permission for the demolition of all existing buildings and the erection of a stadium with ancillary accommodation (D2 Use Class), associated infrastructure including a new vehicular and pedestrian bridge from the eastern corner of the site into Capital Interchange Way, reopening of an existing pedestrian underpass from Kew Bridge Station beneath Lionel Road South and the construction of a new covered, open sided link from that underpass to the stadium external concourse, vehicular and pedestrian circulation areas, public realm improvements, 60 car parking spaces, 400 cycle parking spaces and landscaping; and

Outline Planning Permission for the demolition of all existing buildings and erection of associated enabling development, comprising up to 910 residential units (C3 Use Class), up to 1,200sqm retail/other floorspace (A1, A2, A3, A4, A5, D1 and D2 Use Classes), a hotel of up to 160 bedrooms (C1 Use Class), vehicular and pedestrian circulation areas, up to 775 car parking spaces, cycle parking, associated hard and soft landscaping and public and private amenity spaces (all matters reserved).

This application has been referred to Planning Committee as a planning application subject to an Environmental Impact Assessment, which departs from the Development Plan, and would require a legal deed if approved.

Application received: 3 June 2013

1.0 SUMMARY

1.1 The application proposes a new stadium for Brentford Football Club (BFC), moving its home ground to Lionel Road South. The proposal also includes housing on surrounding land, with this helping to fund the stadium. Other associated transport, public realm improvements, car parking and commercial development, including a hotel are proposed.

1.2 The two main elements of the application are:

(i) A 20,000 seat football stadium with ancillary and community uses. (ii) Housing development on adjoining and surrounding land to provide funding for the stadium comprising up to 910 dwellings, commercial uses and a 160 room hotel.

1.3 Full planning permission is sought for the football stadium and associated uses including hospitality and function space, club management, training facilities, car parking, public realm improvements and accommodation for community uses with an association with the club, these being the Brentford FC Community Sports Trust, the Learning Zone and the Hounslow Interim Education Centre.

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1.4 Outline planning permission is sought for the housing and hotel development with car parking. These uses would be located around the stadium, with all matters (layout, scale, appearance, access, and landscaping) relating to the buildings being reserved at this stage. Twelve tower blocks ranging from 7 to 17 storeys are proposed.

1.5 The application has been submitted with an Environmental Statement, and it has been advertised as a departure from the Council’s Development Plan.

1.6 The development would be phased over ten years, with obligations requiring the stadium to be completed prior to the housing. The club would retain ownership of the stadium but sell the housing sites to fund the stadium’s construction.

1.7 Owing to the current viability of the development, no affordable housing is proposed, and the ability to fund other planning obligations is reduced. As a phased scheme, an obligation is proposed requiring viability to be retested over different stages of its delivery, to ensure that if viability improves to a level that would enable affordable housing and other community contributions to be provided, that these can be secured.

1.8 A major proposal of this nature raises numerous issues relating to both the stadium and the housing, with the scheme attracting much public interest with large numbers of submissions for and against it. Various statutory consultees and local amenity groups have also commented.

1.9 This assessment takes into account relevant Development Plan policies, the National Planning Policy Framework, information in an Environmental Statement and other environmental information including that submitted in accordance with Regulation 22 of the EIA Regulations 2011, and considers the three elements of sustainable development, the economic, social and environmental impacts.

1.10 The proposal would assist in the regeneration of the area through optimising use of brownfield sites and enhancing the local economy. Importantly it would be an opportunity to improve the financial sustainability of BFC, retaining its home in the Borough, which will maintain its heritage and identity and help secure and expand its existing wide ranging community and sporting role in the region. New housing, commercial uses and environmental improvements would add to this regeneration and provide housing choice and spur local economic activity.

1.11 The provision of a large spectator venue and high density housing will have significant implications for future residents and impacts on the character and amenity of the surrounding area and local transport network, with this including concerns about impacts on the townscape including views from neighbouring conservation areas and views from the World Heritage listed Royal Botanic Gardens at Kew, the living conditions of neighbours, noise and disruption, pressure on local infrastructure and parking, as well as traffic and public transport congestion.

1.12 Given these impacts, and the nature and scale of the scheme and its uses, significant mitigation through conditions and obligations under a s106 deed would be

11 necessary if the application was approved, in order to secure high quality architecture and minimum housing quality standards, and so that the wider regeneration and community benefits of the proposal are achieved. This would also ensure harm is minimised in respect of match-day activity and general transport effects.

1.13 Ultimately where harmful impacts from the development remain as is the case for some effects, it is necessary for Members to balance these against other material planning considerations, in particular the public benefits of the scheme, to consider if these outweigh the harm.

1.14 Taking all these matters into account, and balancing the benefits of the development against the harm, approval is recommended, owing to the overall positive social, economic and environmental impacts. This approval is subject to conditions recommended to safeguard the details of the development, secure mitigation measures and to restrict the proposals to the parameters assessed in the environmental impact assessment and planning application. A legal deed is also required to secure delivery of the stadium and its community benefits and other mitigation, including community infrastructure.

1.15 Following a resolution by the Committee, the application must be referred to the Mayor of London for him to determine whether he is content for the Council to determine the application, direct its refusal, or if he wishes to determine it himself.

2.0 SITE

2.1 The application site has an area of 4.7 hectares and is comprised of three plots of land adjoined by railway lines, Lionel Road South and Capital Interchange Way. Lionel Road South is a one-way north to south route linking Chiswick High Road (just to the north of Kew Bridge) to the Great West Road (A4) and the elevated M4 motorway to the north (N.B. the first 50m at northern end is two way). Kew Bridge railway station adjoins the southern end of the site.

2.2 The central area of the site (“the Central site”) is a roughly triangular shaped plot bounded by railway lines to the northwest and east, with Lionel Road South running along its southern and southwest side. This site has a variety of industrial type uses, and is principally used for waste transfer with construction waste being sorted and recycled . Other uses include vehicle repair, car hire, construction hire and engineering. Much of the site is unsurfaced, with stockpiles of various waste materials amongst a number of pre-fabricated buildings. A two-storey brick building c1870s adjoins Lionel Road. This site is owned by the applicant.

2.3 The second plot is a smaller triangular shaped site to the southwest of Lionel Road. This site is also bounded by railway lines on two sides. It is occupied by a builder’s yard and has a number of two-storey buildings and sheds. This site is owned by Duffy Group PLC/ (“the Duffy site”).

2.4 The third and final plot is an irregular shaped plot to the east of the main site, which has railway lines to the west and Capital Interchange Way to the east. It has a four- storey office building, Capital Court, which is one of a pair of 1980s office buildings,

12 the other building having recently been converted to a secondary school (“the Capital Court site”). This site is under contract of sale to the applicant.

2.5 The Duffy site is shown on the proposals map of the Unitary Development Plan (UDP) and the Brentford Area Action Plan (BAAP) for ‘waste management’. A small area of footpath at the far southern end of the site, is within Kew Bridge Conservation Area. The site has no other specific designations in the UDP. The Central site is referred to in the BAAP as a site for a new stadium for BFC with associated mixed use development.

2.6 Owing to its location between railway lines and the low lying nature of the land, the site is relatively isolated and self-contained from the surrounding environment. The character of the surrounding areas differ significantly with these displaying diverse uses, and varying urban grain, building scale and form.

2.7 The adjoining areas to the north and west form part of the A4/M4 corridor and contain the elevated motorway and large commercial buildings, which are largely replacements of earlier industrial development. Buildings here range in height between 39m to 62m AOD (above ordnance datum).Further north is Gunnersbury Park, a large area of open space that is designated as Metropolitan Open Land, a conservation area, Grade II* listed park and garden and a Site of Local Nature Conservation Importance.

2.8 To the southwest, beyond the Brentford Fountain Leisure Centre and mixed use shopping parade along Chiswick High Road are residential areas, comprised largely of two and three-storey terraced and semi-detached housing with some flats, the latter includes Rivers House, a 9-storey converted residential building (37m AOD). These residential localities are of high townscape value and much of the area is designated within either Wellesley Road or Strand on the Green Conservation Areas, the riverside containing many listed buildings.

2.9 To the immediate south, on the opposite side of railway lines is Kew Bridge Station, which has a Grade II station building, as well as residential development of houses and flats on Kew Bridge Road and off Green Dragon Lane. Kew Steam Museum, a group of listed buildings (Grade I and II) is a key feature of this area, with its distinctive tall standpipe tower (campanile) being a prominent landmark as it rises to 67m AOD. Further beyond this and fronting the Thames, is a new mixed use scheme adjacent to Kew Bridge. This scheme is partially complete and has buildings up to 9- storeys (34m AOD) with it adjoining a similar height building (Regatta Point). Part of this area is designated as Kew Bridge Conservation Area.

2.10 West and southwest are the six Brentford Towers, 23 storey residential blocks (72m AOD). These buildings are of a uniform design and are prominent in the skyline of the area. A new development under construction, known as Kew Bridge West, lies adjacent to these towers and the Steam Museum. Phase 1 has nine buildings ranging from 8 to 16-storeys (up to 64m AOD) and Phase II three buildings of 4 to 7- storeys (up to 32m AOD)

2.11 Kew Bridge, itself a Grade II Listed Building, crosses the Thames to the south of the site. It provides a long axis for a north-south view that terminates at the Vantage

13 West office building (62m AOD) that is directly north of the site. Across the Thames and into the London Borough of Richmond upon Thames are Kew Green and the Royal Botanic Gardens, both of which are designated as conservation areas. Additionally Kew Gardens is a World Heritage Site and area designated Grade I on the Register of Parks and Gardens of Special Historic Interest. It has many Listed Buildings including Kew Palace. The Garden’s World Heritage Buffer Zone incorporates Kew Green and extends to the Brentford side of the Thames.

Image 1: Location

3.0 BACKGROUND TO PROPOSAL

3.1 BFC was founded in 1889 in the Oxford and Cambridge Public House which was near to Kew Bridge. The club moved to their existing home ground at Griffin Park in 1904. They presently play in the third tier of football (League One).

3.2 The club’s supporter base is drawn from the local region including the London Boroughs of Hounslow, Ealing, Hillingdon and Richmond, with others spread around London and southeast England, particularly nearby areas to the southwest of London.

3.3 The applicant states the proposed stadium is key to the club’s aspiration to be more financial sustainable and eventually more successful. Its financial statements demonstrate continued losses, whilst the existing ground at Griffin Park provides

14 limited opportunities for expansion or improvement of facilities to increase revenue, pressuring the financial sustainability of the club.

3.4 For more than a decade the club has sought to ensure its financial security and long term prospects through a move to a new stadium where additional income from sponsorship, commercial activity, corporate hospitality and enhanced catering facilities, and increased attendances may be achievable. BFC considers in addition to helping secure the future of the club a new stadium will provide other benefits as it will:

• Provide a social focal point with a buzz of activity; • Enable the Brentford FC Community Sports Trust to provide a range of activities that will attract all age groups from all sections of the local communities; • Promote sport, health, education, employment and training, social enterprise and social inclusion; and • Assist in the regeneration of the area and build close links with local businesses and residents.

3.5 Outline planning permission (00143/A/P42) was granted in 2002 for the redevelopment of their existing home ground at Griffin Park for housing and open space, with an obligation that the development can only be implemented once a new stadium for the club has been constructed. This permission was extended in 2006 (P45) and 2012 (P50).

3.6 Relocation of the club has been previously investigated with the Lionel Road site being considered along with other sites including at Osterley Park, Western International Market (Cranford), Hounslow West, Feltham Arenas, Bedfont Lakes and Hanworth. In 2001 a previous owner proffered a ground-share scheme at Woking, Surrey, owing to the unsustainable finances of the current ground.

3.7 In 2002 the Lionel Road site, then known as the ‘Brentford Diamond’, and adjoining land, was announced as the club’s preferred location for a new stadium. In 2008 a prospective scheme for a new stadium with enabling housing development to fund it was prepared. This scheme comprised a partnership between BFC and Barratt Homes, as well as involvement from LB Hounslow through inclusion of the nearby Brentford Fountain Leisure Centre which was to be rebuilt and its site redeveloped with new housing. The scheme included a 20,000 seat stadium with a mix of uses around the stadium, with 1,282 dwellings and buildings ranging up to 28 storeys (100m+ AOD). The scheme failed to progress to a planning application owing to the financial crisis of 2008 with Barratt (who had bought the site in 2008) deferring the project before eventually withdrawing from it in 2011.

3.8 In 2006 BFC was sold with a majority share being held by Bees United, a supporters group. Since then the club was bought by a wealthy individual supporter (Matthew Benham), who also subsequently purchased the main Lionel Road site in 2012. Bees United retain a ‘golden share’ that allows any sale of Griffin park to be vetoed unless it is in the best interest of the club. With the financial backing of the new owner, the relocation of the club has been able to be progressed to the current planning application.

15 4.0 SITE HISTORY

4.1 The area was used for market gardening until arrival of railways in the mid-19 th century. The main part of the site was then a goods yard with numerous railheads, whilst the area to the east, comprising Capital Interchange Way, was formerly Brentford Market. The goods yard, which was owned by British Rail, ceased operating in the 1970s following which the site has been used for a variety of industrial and related activities including waste transfer, vehicle recovery, vehicle repairs, skip hire, engineering workshops, tyre fitting and storage.

4.2 Brentford Market also closed in the 1970s and the site was redeveloped with the Fountain Leisure Centre and offices, the latter including the offices on Capital Interchange Way that form part of the application site. The Duffy site also once comprised railway land but has been used for a long period as a builder’s yard.

4.3 The recent history relates to outline applications (ref. 00703/A/P9 and P10) to redevelop the main site with a mixed use development comprising motor related uses, waste transfer, (B1) offices and light industrial,(B2) general industrial and (B8) warehouse and distribution uses, which were made in 1999. Neither application was determined with both eventually being withdrawn.

4.4 Since then there have been various applications for Certificates of Lawful Use for use of much of the main site as a waste transfer, with that use having commenced in the early 1980s.

5.0 PRE-APPLICATION PROCESS & CONSULTATION

5.1 Planning Performance Agreement

5.2 The Council and applicant signed a Planning Performance Agreement (PPA) on 4 December 2012. The purpose of the agreement was to provide pre-application advice to assist the preparation of an application and establish key issues and procedural requirements. The process did not involve an assessment of any detailed drawings and comments made were without prejudice to formal consideration of any planning application. A number of meetings between officers and the applicant have been held since that time, covering a broad range of planning topics.

5.3 The PPA meetings identified the main issues to be considered, including the high density and scale of the enabling housing development, transport and parking, community benefits, affordable housing and housing quality, infrastructure, and impacts on surrounding residents and businesses. The applicant also consulted the Mayor of London during this process.

5.4 Pre-application consultation

5.5 The PPA confirmed that the development would require an Environmental Impact Assessment, and the Council issued a formal Scoping Opinion on the applicant’s Scoping Report on 22 February 2013.

16 5.6 The Scoping Opinion commented on the content and extent of information to be submitted in an Environmental Statement to accompany a planning application for the development, identifying the types of environmental impacts to be investigated and reported, taking into account the specific characteristics of the development. In particular it identified matters omitted or to be addressed so that these can be included in further detail.

5.7 Community consultation

5.8 BFC has undertaken pre-application consultation comprising public exhibitions, leaflet drops and meetings with local stakeholders, the latter including local resident and amenity groups such as:

• Strand on the Green • Griffin Park Residents Association • Friends of Stile Hall Garden • West Chiswick and • Green Dragon Lane Gunnersbury Society Cooperative • The Kew Society • Temeraire Place Residents • Wellesley Residents

5.9 The club has held regular meetings with local stakeholders through the Lionel Road Liaison Group (LRLG). This group, which had first formed during the previous Barratt scheme, was restarted in 2012. Meetings to discuss the scheme and concerns with the applicant’s project team and club officials were held on the following dates:

• 1st October 2012 • 3rd December 2012 • 21st January 2013 • 18th March 2013 • 22 April 2013 • 29 April 2013

5.10 Members of the LRLG were provided with application documents on request.

5.11 Separate consultation has been carried out directly with:

• Greater London Authority including Transport for London • Royal Botanic Gardens, Kew • Kew Palace (Royal Palaces)

5.12 BFC also held three public exhibitions. Consultation letters in respect of the exhibitions were sent to over 10,000 addresses in Brentford and Chiswick with details also sent to local community websites and LRLG. The exhibitions were attended by the general public with the project team for the proposal answering questions as required. Information about the exhibitions is given in more detail in the applicant’s Statement of Community Involvement, with a summary given below:

1st Exhibition: 17, 18 and 19 January 2013

5.13 Held at Griffin Park. Over 300 people attended with approximately 40% of people completing questionnaires.

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2nd Exhibition: 21, 22 and 23 March 2013

5.14 Held at Griffin Park and Brentford Fountain Leisure Centre. Over 240 people attended with approximately 59% of people completing questionnaires.

3rd Exhibition: 31 May and 1 June 2013

5.15 Held at Brentford Fountain Leisure Centre. Over 170 people attended included local amenity groups. Approximately 40% of people completed questionnaires.

5.16 In addition to these activities the club has publicised a website: http://www.brentfordcommunitystadium.com, which has given details of the evolving proposal, whilst information has also been given on local websites ChiswickW4.com and BrentfordTW8.com.

5.17 Local Area Forums

5.18 A representative from the club has presented the details of proposal and answered questions at the Isleworth and Brentford Area Forum (31 January 2013) and the Chiswick Area Forum (22 January and 19 March 2013). Comments from these meetings are listed below.

(i) IBAF comments: None (at either meeting)

(ii) CAF comments 22 January:

Councillor Lee: • Impact on Chiswick of match day transport and Chiswick tube stations. • No mention of use of spur lines by the site. • Noise pollution. • What methods might be used to pay for the development? • Commercial units on site and possible inclusion of a night club. • Exhibition held in Brentford with nothing in Chiswick.

Councillor Todd: • Thanked club for youth and education work. • Understood that there would be tower blocks and was disappointed the original scheme had not gone ahead as this included redevelopment of the Leisure Centre. • Noted rugby mentioned. • Noted current attendance was around 8,000 but the aspiration was 20,000. • Asked what the project might do in respect of S106 obligations. • Noted Club was previously owned by the supporters but was now owned by one person and sought assurance that this individual was not a property developer. • Noted that the Club still owed the borough £500,000.

Councillor Oulds (Chair): • Noted mention of conferences and banqueting. • Had club ruled out concerts?

Councillor Davies:

18 • Noted applicant would not rule out concert use. • Transport provision was overflowing in the area. • With regard to Gunnersbury Station, members had been told that it was not possible to improve the station as it was full from the number of people travelling to and from the business parks. • This was in the morning rush hour and 5-6 p.m. in the evenings. People tended to spill out of the station into the High Road to catch a bus. • Trains via Kew Bridge station were unreliable. • Would like more detail about the transport proposals.

Councillor Hearn: • Stressed that would be important to absorb the detail. • No doubt it would cause a huge change to the character of the neighbourhood. • Would impact on Brentford, on Riverside and Turnham Green wards • Asked whether a 20,000 capacity stadium was the final aspiration of Club. • What might happen if more success and capacity was not sufficient? • Were there were any plans beyond the medium term for the stadium and whether it was considered that this might not be a permanent home. • Asked whether the Club should look for a site which would allow for expansion.

Councillor McGregor: • This was a brown field site and the stadium would displace office and warehousing. • Sought confirmation of the number of residential units.

(ii) CAF comments 19 March:

• Councillor Lee: • Not enough consultation of Chiswick residents, were there any plans to do more? • Would be a massive development. • Pressure on transport would increase for the local community. • Gunnersbury Station would now be much closer so expected that fans would use Gunnersbury or Kew Bridge stations. • Gunnersbury Station was no longer fit for purpose. • Those arriving for night time matches around 6.30 to 7.00 p.m. would hit the rush hour from the Business Park. • At Kew Bridge there were two extra platforms there with the loop line and the line was still in situ. • Did not take account of less frequent trains at weekends. • Suggested that Chiswick residents felt that they were faced with a fait accompli. • How noisy would it be and how would it be controlled? • Attendance figures would increase as the Club progressed up the league. • Concerns especially true for residents in Stile Hall Gardens who were very close to the site across the High Road. • Normally for major development residents would expect and exhibition in Chiswick Town Hall and advertisement on the ChiswickW4 website.

Councillor Oulds (Chair): • Pointed out that the service (Kew Bridge) on Sunday was one train per hour.

Councillor McGregor:

19 • Raised concern about the cycle super highway proposals and the need to be watchful of the TfL proposals and was not confident that the programme was managed properly. • When would the Club would liaise with the police and consider police support for the new stadium?

Councillor Todd: • Asked whether there were proposals to hold musical events in the stadium? • Did not believe that there was evidence of financial viability. • Noted the Club was owned by one individual and asked what discretion this gave?

Councillor Hearn: • Asked what residents associations were saying as people speaking to him were not overwhelmingly in favour. • The prospect of 900 extra units with families and children posed the question of where was the new school and health centre.

Councillor Davies: • Rail network would be inadequate, especially with the proposed increase in the number of local residents. • Had there been consideration of an increase in bus services or whether it was expected all would walk from the tube. • Suggested that extra bus services would enable access to South Ealing, Acton Town, Ealing Broadway and Richmond station for the south west. • Without an increase in bus services, the neighbouring stations would become dangerous and considered that Gunnersbury Station was already dangerous. • Assumed that there was a need for TfL agreement.

5.19 Public Meetings

5.20 A public meeting for Chiswick residents chaired by the local Member of Parliament, Mary Macleod MP and organised by Chiswick Area Councillors was held on 7 th September in Grove Park, Chiswick. The meeting was attended by over 150 people from the local area, with the majority of attendees speaking in opposition.

5.21 A public meeting for Kew residents chaired and organised by the Member of Parliament for the Kew area, Zac Goldsmith MP was held on 30 September in Kew. The meeting was attended by over 300 people from the local area. Most attendees opposed the housing development, though the principle of the stadium was largely accepted.

6.0 DETAILS OF THE PROPOSAL

6.1 The football club is proposing to move their home ground from Griffin Park to the site, with the scheme including new housing to help fund a 20,000 seat stadium. A hotel and car parking are also proposed, along with works to Lionel Road, access to Kew Bridge station and a new bridge over railway lines from Capital Interchange Way.

20 6.2 The application is a ‘hybrid’ application, with two parts, the first is the football stadium, its associated facilities, the new bridge and car parking, for which full planning permission is sought.

6.3 The second part is in outline only and covers the housing development which is proposed to part fund the stadium, a hotel, plus some commercial uses and parking. Some areas of the application overlap including the access to Kew Bridge Station and areas of public realm.

6.4 In summary the proposal is for:

- A 20,000 seat football stadium with associated public realm works to provide a stadium concourse area - Opening of a pedestrian underpass beneath Lionel Road South from the site to the eastbound platform of Kew Bridge Station - A pedestrian link from Kew Bridge Station to the stadium concourse - Improvements to Lionel Road South - A new pedestrian and vehicular bridge over the railway line to the east linking the stadium to Capital Interchange Way - Up to 910 dwellings over four parts of the site (phased over 10 years) - A hotel of up to 160 rooms - Other related uses including retail, café, education uses - Parking for up to 835 cars (210 for the football club, 585 for residential development and 40 for the hotel) - 400 cycle spaces for the stadium

6.5 Maximum floor areas for the proposed uses are shown in the table below.

Land Use Area sqm (GIA*) Residential (C3) 81,900 Retail, Leisure (shops, 1,200 restaurant etc) (A1, A2, A3, A4, A5, D1, D2) Hotel (C1) 4,700 Stadium (D2) 37,841

Table 1: Proposed Uses *Gross Internal Area

6.6 The stadium is at the heart of the development. The masterplan for the scheme utilises Lionel Road South as the primary axis for the development, with the main public spaces and stadium entrance to be located off this road. Improvements to Lionel Road and the access to Kew Bridge Station would direct activity to a hub at the entrance to the stadium, where a public concourse is provided.

6.7 Commercial uses such as retail and restaurants, including a club shop are envisaged around this key hub. Beyond the stadium, residential development with active uses to the street level are proposed. Concourse areas and pathways extend around the stadium to link it with the new bridge over the railway to Capital Interchange Way

21 and to the residential development there. Fuller details of each element of the proposal are described below.

6.8 New Football Stadium

6.9 The proposed stadium is located on the triangular shaped central area of the site between Lionel Road South and railway lines. It has stands to all four sides of the football pitch. The stadium would include: • Accommodation for a total of 20,000 spectators • A covered single and two tier arena • Stand to stand dimensions of 120m x 80m for football (FIFA compliant pitch) • Hospitality for 1,500 spectators in lounges, bars and hospitality boxes, also capable of being used for conference and banqueting events on non-match days • Provision of space for 171 disabled spectators with access • Parking for 210 spaces for match day and non-match day uses (with the majority of these (150) located within parking area of the building on Capital Court site) • Indoor recreation facilities, and a climbing wall • Accommodation for the Club’s management functions • Accommodation for the Brentford FC Community Sports Trust, Learning Zone and Hounslow Interim Education Centre 6.10 Size

6.11 At its greatest extent it is approximately 180m long and 145m wide. It covers much of the central part of the site, with it having a continuous bowl design but with distinctive folded forms to the roofs of each side. Its maximum height ranges from around 14.5m up to 26.5m, which is the equivalent of a 4 to 7-storey residential building.

6.12 The South stand is the largest and has the main hospitality areas and 6,000 seats. It has two tiers, a large lower tier, with a hospitality tier above, split by a level containing hospitality boxes.

6.13 The North stand is the smallest of the four stands with 4,000 seats in a single tier. Its design is constrained by its proximity to the adjacent railway. It would be sited 1m from the site boundary to enable maintenance.

6.14 The East and West stands are of similar design and each has 5,000 seats, with facilities for the ground floor and single tier stands. The concourse next to the East stand provides the location for both non-match day parking and a match day television broadcast area.

6.15 Uses

6.16 Apart from the football pitch and spectator seating, the stadium has a range of related uses. The floor area located underneath the seating tiers would house club offices, changing rooms, medical treatment areas, and accommodation for community uses.

6.17 The table below provides a comparison between the uses of the proposed stadium with the club’s existing home ground.

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Use Griffin Park Lionel Road Capacity 12,300 20,000 Hospitality boxes 0 15 Disabled seating 10 171 Disabled parking 0 22 Disabled toilets 2 17 Other parking Match Days – 0 on site but 210 – (60 on main site and 72 off site; Non-Match 150 provided within Days – 15 on site. podium area of Capital Court) Club shop 142 sqm 365 sqm Club hospitality 396 sqm 2,075 sqm and bars etc Club offices 150 sqm 360 sqm Learning Zone 90 sqm 310 sqm Interim Education 72s sqm 150 sqm Centre Brentford FC 0* sqm 360 sqm Community Sports Trust Table 2: Comparison of uses * Presently accommodated at premises elsewhere in Brentford.

6.18 Hospitality – Various refreshment kiosks are found throughout the stadium for home and away supporters, with hospitality boxes, a club bar and dining areas also being provided in the main South stand.

6.19 Brentford FC Community Sports Trust – Offices for the trust are provided on the second floor of the South stand.

6.20 Interim Education Centre – Three classrooms and associated access/ facilities are provided on the first floor of the East stand (with lift access).

6.21 Learning Zone – Floor space is provided on the second floor of the South Stand. This area would also double as a media room on match days.

6.22 Rugby

6.23 The applicant has expressed a desire to eventually agree an arrangement for the use of the stadium by a professional rugby team. However no such agreement is in place and supporting documents have not fully considered such a use. Therefore the application only proposes use of the stadium by the football club. Any approval would include a condition limiting the use of the stadium to prohibit rugby use, with this to enable the potential impacts to be assessed and appropriately controlled when a specific and sufficiently detailed proposal is put forward. Should approval be given, a separate consent would be required for rugby.

23 6.24 Access

6.25 The main entrance area is from the south west corner from the proposed stadium concourse area off Lionel Road South. This would serve the South stand. Other parts of the stadium are accessed by further entrances off Lionel Road South for the West and part of the North Stand, and from the new bridge off Capital Interchange Way for the rest of the North stand and the East stand.

6.26 The site layout allows for public access around the stadium to the east, south and west sides, with the proposed bridge link allowing visitors to access the pedestrian and transport routes available around the site.

6.27 Accessible toilets and access is provided to the main facilities throughout the stadium by ramps or lifts.

6.28 Design

6.29 The stadium encloses the four sides of the football pitch. Owing to the siting and size of the surrounding buildings that are proposed, there would not be wide views of the full elevations of the stadium. The design has sought to provide a distinctive roof form that distinguishes it from other stadiums with it comprised of sections that form ‘folded’ shapes.

6.30 The main outer elevations of the stands are predominantly finished in textured fibre cement cladding with a neutral tone, with this material to be separated from the roof by a band of translucent panels. At lower levels blockwork is used to provide a smaller scale.

6.31 The main stadium elevations open up in the south west corner to include a glass curtain wall with louvres to Lionel Road South which signposts the main stadium entrance with this area also having a large, angular projection that overhangs the public concourse below.

6.32 The concourse areas that extend around the outside of the stadium to its west, south and east are designed to be durable and capable of accommodating large crowds, and are relatively free of street furniture. Patterns and textures will be used in paving to provide interest, with groups of street trees sited to add greenery. These would be accessible to the public at all times. A public park is shown on the southwest side of Lionel Road.

6.33 Residential Development

6.34 A maximum of up to 910 dwellings with associated parking and amenity space are proposed on four sites around the stadium as follows.

Site Maximum No. of Dwellings Central Southern 240 Central Eastern 190 Capital Court 205 Duffy’s 275

24 Total 910 Table 3: Maximum no. of dwellings

6.35 The housing is in the form of blocks of flats. An illustrative mix with 40% one- bedroom, 40% two-bedroom and 20% three-bedroom is given. With this mix the total number of new residents is likely to be 2,410 by 2023 when the last phase is completed. The layout, scale, appearance, access, and landscaping of this part of the development would be reserved for subsequent assessment (at each phase) if permission was granted, however the application has essential information for consideration at the outline stage, which includes: • Use – the proposed uses for the development and distinct development zones within the site; • Amount of development – the amount of development proposed for each use; • Indicative layout – an indicative layout of proposed building footprints, public realm and semi-private amenity space for residents; • Scale parameters –the upper and lower limits for height, width and length of each building within the site boundary; and • Indicative access points –areas in which the access point or points to the site will be situated.

6.36 Therefore the application seeks to establish the maximum amount of residential accommodation for the site. The maximum floor areas that would be delivered within defined building footprints and envelopes are given along with drawings showing the maximum parameters for each building. Footprints are defined by parameters, which the development cannot exceed. Floor space areas for each block are derived from a likely footprint within each parameter and a maximum number of storeys of accommodation within a volumetric envelope as illustrated in submitted drawings.

6.37 Housing is proposed to help provide funding for the stadium, as although the club will fund a significant proportion of this cost, through the financial support of its benefactor and development at Griffin Park, residential development to generate capital receipts is a key component of the proposal.

6.38 The following table lists the accommodation schedule proposed by the applicant.

Block 1 Bedroom 2 Bedroom 3 Bedroom Total A 37 37 19 93 B 31 31 15 77 C 42 42 21 105 E 29 29 14 72 F 67 67 34 168 G 38 38 19 95 H 38 38 19 95 I 30 30 14 74 J 33 33 18 84 K 19 19 9 47

25 TOTAL 364 364 182 910

Table 4: Proposed schedule of accommodation

6.39 The site plan below shows the position of the footprints for proposed buildings on the site, excluding the podium parking below (also see Appendix 1).

Image 3: Location of proposed blocks (footprint)

6.40 Duffy Site

6.41 This is a triangular shaped plot on the western side of the site. It has three blocks of flats, labelled A, B and C. The blocks would be located on a podium that meets the street level of Lionel Road at its northern end before being raised towards the south. Commercial uses and residential entrances would be provided at street level. The three blocks are arranged around a central area of open space, with one level of parking below for 170 cars. They would have the following maximum parameters:

Block A (15-storey): Envelope from 42.0m AOD at west stepping up to 55.0m AOD. Block B (17-storey): Envelope from 49.0m AOD at west stepping up to 61.0m AOD. Block C (12-storey): Envelope from 34.0m AOD near Lionel Road to 46.0m AOD.

6.42 Central Southern Site

6.43 This is a triangular shaped plot occupying the southern end of the site. It has two blocks of flats, labelled E and F. The blocks form three masses that step down from north to south. There are two levels of parking below for 160 cars. Commercial uses

26 and residential entrances would be provided at street level. An area of open space for residents is provided between the blocks. The blocks would have the following maximum parameters:

Block E (14-storey): Envelope from 42.0m AOD stepping up to 54.0m AOD. Block F (7 to16-storey): Envelope from 33.0m AOD at the front of the site stepping up to 43.0 AOD and then 60m AOD.

6.44 Central Eastern Site

6.45 This is a triangular shaped plot occupying the north east corner of the main part of the site. It has two blocks of flats, labelled G and H. The blocks have two levels of parking and an outdoor broadcasting space below, with parking for 120 cars. They would be accessed by the new bridge from Capital Interchange Way. An area of open space for residents is provided between the blocks. The blocks would have the following maximum parameters:

Block G (15-storey): Envelope from 48.5m AOD stepping up to 60.5m AOD from west to east. Block H (14-storey): Envelope from 45.5m AOD site stepping up to 57.5m AOD from east to west.

6.46 Capital Court Site

6.47 This has three blocks, I, J and K, located on Capital Interchange Way, with the proposed bridge adjacent to the north. The two lower floors of the blocks form a podium that has two levels of parking for 135 residential spaces and 150 spaces for BFC, residential entrances and commercial units. An area of open space for residents is provided between the blocks. The blocks would have the following maximum parameters:

Block I (13-storey): Envelope to 50.0m AOD. Block J (14-storey): Envelope from 43.0m AOD to east and west sides rising to 53.0m AOD at centre. Block K (9-storey): Envelope to 38.0m AOD.

6.48 Design Code

6.49 The outline housing elements are accompanied by a Design Code document, which aims to control and guide the subsequent detailed design of reserved matters to ensure a high quality and comprehensive scheme for the whole site is achieved. The code seeks to emphasise key environmental and architectural requirements for future designers, though is not excessively prescriptive so as to avoid limiting creativity.

6.50 The Design Code includes commentary on internal layout, massing, proportions, materials, windows and balconies, access, open space, form, colour, character and key fundamentals that should inform a detailed design rationale.

6.51 Hotel

27 6.52 Block D is a proposed 160-room hotel. It is sited adjacent to the western stand of the stadium, fronting Lionel Road. It has 11-storeys with a maximum height of 45.5m AOD, which lowers to 31.6m AOD as it approaches the northern site boundary and floor area of 4,700sqm. Parking for up to 40 cars is envisaged.

6.53 Phasing

6.54 The application details an indicative phasing plan, with the stadium to be built to open in mid-2016 and the housing to be provided over a ten year period up to 2023. Given the long implementation time and future input from a development partner the phasing may change, with this to be controlled by conditions and a legal deed.

6.55 Environmental Impact Assessment

6.56 Owing to the nature of the proposal development, an Environmental Impact Assessment was required. Before determining the application the Council must consider the environmental information contained in the Environmental Statement (ES), including the further information submitted, as well as representations from consultees about the environmental effects of the development.

6.57 The ES assesses likely environmental impacts from the development including its construction and operation, including cumulative impacts from other ongoing developments. The ES identifies the existing (baseline) environmental conditions, and the likely environmental impacts (including magnitude, duration, and significance) and also identifies measures to mitigate any adverse impacts. A summary of potential positive and negative residual effects remaining after mitigation measures is also given. The residential development is an outline proposal so the ES has considered the parameters of the proposed blocks including building heights, envelopes and floor spaces, which are maximums and therefore ‘worst case’.

6.58 The ES itself does not necessarily consider compliance with planning policies and so planning permission does not have to be granted or refused based on its findings, but these are material considerations. Where significant adverse effects are found, consideration will need to be given to mitigation proposed and then ultimately to whether the remaining impact warrants refusal or if such harm is outweighed by other benefits.

6.59 The ES contains analysis of impacts for the following topics:

• Demolition and Construction • Planning Policy and Land Use • Transportation • Air Quality • Noise and Vibration • Townscape and Visual • Archaeology and Cultural Heritage • Soil Conditions, Groundwater and Contamination of Water Resources • Microclimate • Socio-economic • Sustainability

28 • Cumulative Impacts • Rugby Club

6.60 Further information supplementing the ES was received on 24 September pursuant to Regulation 22 of the EIA Regulations. This information related to transport, noise and air quality and townscape views in respect of Kew Gardens.

6.61 This followed a request from the Council on 14 August. It provided further information on ecology, townscape, transport, noise and air quality. Separately the applicant also provided additional information in the form of a Clarification Report and an updated Design Report to address responses from consultees. Officers are satisfied that the ES (taken together with the further information received pursuant to regulation 22) has adequately considered the potential environmental impacts of the development.

7.0 CONSULTATION

7.1 The application is accompanied with an Environmental Statement, with publicity and consultation being carried out in accordance with the Town and Country Planning (Environmental Impact Assessment) Regulations 2011 and Planning (Conservation and Listed Buildings) Act 1990.

7.2 Eight site notices and a press notice advertised the application, and copies of the Environmental Statement and other application documents were made available at the Hounslow Civic Centre and Brentford and Chiswick libraries, as well as the Council’s website. There were also separate site and press notices for the development in respect of the Planning (Listed Buildings and Conservation Areas) Act 1990 requirements.

7.3 Consultation letters were sent to statutory consultees, neighbouring boroughs and local amenity societies, and to 11,195 properties within Brentford and Chiswick.

7.4 Information about the proposal was included in the Borough’s newsletter, Hounslow Matters (summer 2013 edition), which is sent to all residents. The LB of Richmond was consulted and it posted site notices and placed information on its website.

7.5 Following receipt of further information, all persons originally consulted, and those that had made submissions in response to the first consultation were re-consulted by letter on 2 October, with new site notices also posted and the information added to the website and made available at local libraries.

7.6 The application was included on the Pending Decisions List (Week 33, 16-23 August 2013) sent to ward members of Chiswick and Isleworth and Brentford and to a number of amenity societies and posted on the Council’s website for information.

7.7 Responses

7.8 Owing to the nature and scale of the development proposal, wide consultation and activity by the club, there has been much interest in the application, with over 3,000 responses received from individuals as well as many amenity societies. Responses have been received from nearby residents as well as supporters of the club, the

29 latter including many local residents but also people from the wider region, other parts of England and even overseas.

7.9 Given the large number of submissions it is not possible to quote every submission in detail, but the following summary provides details of the issues raised those for and against by individuals and residents’ groups/ amenity societies. Responses from statutory authorities, institutions and other bodies are detailed separately below.

7.10 Members will note that consultation is not a referendum and the tally of those for and against is not a determining factor when making a decision though the range of topics and the geographic origin of responses may be useful to consider. A summary of individual responses is given below.

7.11 Objections – In total 1,168 individual responses objecting to the proposal were received, with these being overwhelmingly from nearby areas of Chiswick (W4) and Kew (TW9), with some also from nearby residential areas of Brentford (TW8). A further 102 repeat objections were received (giving total submissions as 1,270). Objections from some residents (49) were in the form of a generic leaflet cut-off. A petition with 276 signatures was also received objecting to the loss of the stable block building on the Central site (on Lionel Road).

7.12 Support – In total 1,967 individual responses in support of the proposal were received, with these being from a wide area, including locally adjoining areas, across the Borough and neighbouring boroughs of Ealing, Richmond, Hillingdon and Spelthorne. As noted many responses were also received from across England. A further 327 repeat submissions in support were received. In addition to emails and letters, the responses in support also include 3,179 postcards distributed by Brentford supporters, with standard text stating:

“I support Brentford FC’s planning application for a new community stadium and the associated development at Lionel Road South. I urge Hounslow Council to approve Brentford FC’s planning application ”.

7.13 The majority of these postcard responses had additional comments providing reasons of support, and these are included in the summary of responses below. A further 16 unintelligible post cards were received.

7.14 Source of responses – The table below collates all the individual responses in geographic areas, with a separate table given for the supporting post cards.

7.15 Individual emails and letters

Table A: Total submissions in objection

W4 TW8 Other TW9 Other No address Total Hounslow (incl. W3) 683 53 27 390 24 93 1,270

Table B: Total submissions in support

30 Hounslow Richmond Ealing Hillingdon Other Other No Foreign Total London England address 428 155 176 100 223 1,095 62 55 2,294

Table C: Breakdown of submissions in support by LB Hounslow addresses

W3 W4 W5 TW3 TW4 TW5 TW7 TW8 TW13 TW14 Total 2 94 4 45 11 4 80 130 40 18 428

7.16 Post cards

Table D: Post cards in support

Hounslow Richmond Ealing Hillingdon Other Other Foreign Total London England 656 223 302 280 308 1,385 25 3,179

Table E: Breakdown of post cards in support by LB Hounslow addresses

W3 W4 W5 TW3 TW4 TW5 TW7 TW8 TW13 TW14 Total 4 49 7 74 53 34 106 187 69 73 656

7.16 Summary of individual responses

7.17 Issues raised in objections

Design, Townscape and Heritage • Development breaches national, regional and local guidance including policies on design, density and tall buildings, the Thames and conservation areas from NPPF, London Plan, UDP, Thames Landscape Strategy • Excessive density, which is 3 times the relevant density range • Development is too intense • Harm to character and appearance and views of Strand on the Green, Wellesley Road, Gunnersbury Park, Kew Bridge, Grove Park, Thorney Hedge and Kew Green Conservation Areas due to height and bulk of proposed buildings • Harm to listed buildings of Kew Gardens • Harm to listed buildings at Kew Steam Museum • Harm to Kew Bridge station listed building • Harms views from Royal Botanic Gardens, Kew, World Heritage Site • Harm to views from the Thames • Harm to view of Stand on the Green from across river • High rise buildings are out of keeping with scale of surrounding areas • Would be detrimental to the streetscene of the area • Unsightly appearance of tower blocks • High rise does not fit in West London skyline • Will spoil views • Architecture has no local pride or civic identity • Destroys low urban grain of Chiswick

31 • Need to protect heritage for future generations • Stadium is too large • Stadium lacks quality design • Stadium design compromised by size of site and proximity of housing and is not worthy of the club • Stadium is grotesque • Area will become like an Asian city • With other development on M4 will look like Chicago • Should be low rise housing • Should be no higher than 7-storeys • Should be 4-storeys as previously recommended • Would block views of Vantage West building from Kew Bridge • Loss of non-designated heritage item – stable block • Stable block should be retained and used as an energy centre • Stable block should be incorporated into the stadium design • Demolition of stable block in not necessary • Site is too small for the development • Not a suitable site for housing • Should be a detailed application • Outline parameters would be pushed higher once approval is given • Opportunity to improve area not grasped • Need masterplan for wider area

Quality of Housing • Poor quality design and cramped accommodation • Too many units • Inadequate and poor quality amenity space • Noise and air pollution would adversely affect residents • Lack of children’s play space of facilities • Units too close to football stadium and would have poor amenity • Tower blocks not suitable for families as leads to squalor and people feeling isolated

Affordable Housing and Community Infrastructure • No affordable housing • Should look at market rent options • Future affordable housing impractical • Need to consider future affordable housing provision in the design having regards to management of mixed tenure blocks, costs, service charges • Lack of family housing • No housing for elderly • New residents would add to demand for health services that are already inadequate • No health contributions • Increased demands on West Middlesex hospital • New residents would add to demand for school places that are already inadequate

32 • No education contributions • Will adversely affect local school children • Where would the Council spend the New Homes bonus? • New residents would use riverside paths and public spaces which cannot cope with more people • Football spectators would use riverside paths, public spaces and public houses which cannot cope with more people • Must have new schools, shopping areas etc • No investment in Brentford Fountain Leisure Centre • Policing the area and energy services access inadequate

Impacts on environment and living conditions of surrounding residents • Excessive noise from football crowds would affect surrounding residents and spaces • Overshadowing of neighbouring homes and open space • Loss of privacy from overlooking • Air quality would get worse • Floodlights would result in light pollution to neighbours • Disruption to use of local public transport • Loss of parking • Non-football goers cannot use railway stations • Would ruin quality of life • What about local peoples right to a peaceful life? • Families would need to move from the area • Spectators will use local pubs and open spaces • Anti-social behaviour will increase, with poor behaviour from fights, swearing, vandalism, overcrowding, public urination. • Crime would more than likely rise, theft, break-ins, rape, assaults etc. • Football supporters will be in residential streets • Who will clean up streets after matches? • Experience of Fulham match days shows verbal and physical abuse • People of Fulham, Tottenham and Highbury will attest to overwhelming impact of large football grounds • Crowds will be intimidating for young mothers • No guarantee visiting club’s supporters will be well behaved • Wellesley Road would be used as a route to Gunnersbury Station trapping residents in their homes • Will disrupt visitors to Kew Gardens and Kew Steam Museum • Would bring area into decline • Loss of village atmosphere of Strand on the Green • Would harm village type feeling of Kew • Need to preserve the area for tourists • Noise from rock and pop concerts • Rugby use would mean used all the time, with traffic, parking and noise implications. • Sewage and water infrastructure cannot cope

33 • Kew, the nearest area of shops, schools and other necessities is too small to cope with the erection of small town less than a mile away • Thames river would be polluted • Kew residents already suffer from aircraft noise • 12,000 new residents is an enormous local increase • Local wildlife will suffer • Adverse effects of construction work would block roads, dust and have HGVs

Transport • Match day traffic generation would cause grid lock on already congested roads • Spectators driving would search for free spaces denying local residents spaces • Traffic generation from housing would cause grid lock on already congested roads • Inappropriate site for stadium as it is next to busy roads that are heavily congested • No new roads proposed or reworking of traffic flows • Site has a poor PTAL for stadium • Lack of parking for stadium • Too much parking for stadium • On-street parking from match goers would cause congestion and disruption of local streets • Inappropriate site for housing as it is next to busy roads that are heavily congested with long delays already experienced on local roads • Would block traffic on main roads including Chiswick Roundabout, Kew Bridge, Kew Bridge Road, A4/M4 and Chiswick High Road (North Circular) amongst busiest in London and an area of bottlenecks • Already long queues of traffic in the area at all times • Would block traffic on local roads including Wellesley Road and Strand on the Green • Kew is already clogged with cars visiting Kew Gardens and on match days this will be made worse • 5,000 visitors in cars would seek to park in Kew which is already saturated with residents • Would affect the cycle superhighway • Need more work to model the impact of increased traffic and pedestrian flows • Transport Assessment inadequate and inaccurate • Transport Assessment underestimates impacts on roads and public transport • Lack of parking for hotel • Lack of parking for 910 residential units • Too much parking for residential units • There will be fatalities on roads and railways • Residents parking is inadequate and would lead to overspill parking on nearby streets • Residents would have more than 1 car per unit • Traffic gridlock created would affect ability to get to work, emergency access, and businesses • Harm to existing businesses in locality due to increased traffic congestion and possible CPZ

34 • Areas have no CPZ controls so will suffer from overspill parking • Richmond Council will be forced to introduce CPZ s in North Kew adding costs to local households • Public transport is inadequate • Underground is already at capacity day and night • Residents are already blocked from accessing the platform at Gunnersbury Station during peak hours due to employees of local offices • Trains are already at capacity • Buses are already at capacity • Kew Bridge station has no disabled access and large gap to trains • Kew Bridge station needs modernisation • Chiswick Roundabout crossings are dangerous for pedestrians • Gunnersbury Station is inadequate for proposed use • No lifts at Gunnersbury Station • Gunnersbury Station is dangerous and safety will worsen • Unrealistic for stewards to control crowds at Gunnersbury Station, which will have to be closed to prevent overcrowding as happens at other stations (Highbury & Islington, Fulham Broadway) when events are on depriving residents and businesses access • Saw adverse impacts at Chelsea when everything must stop • Passengers would need to be managed in queues of up to 320 people for ¾ of an hour to be admitted safely to Gunnersbury Station • Conflict between spectators and commuters at Gunnersbury Station during peak hour • Traffic would affect elderly community facility in area (Chiswick Age Concern) • Should build a second entrance from Wellesley Road to Gunnersbury Station • Kew Gardens station is inadequate to handle likely passenger flows • Worsened traffic jams would result in increase road rage and injuries to cyclists from motorists • Traffic from rugby at Twickenham is already bad

Need and Business Case • No need for a stadium • No need for new housing at the Council meets annual quota for new dwellings • Enough hotels in the area • Size of stadium excessive given existing BFC crowds are much lower and latent support is not there • Club will not be promoted • If club cannot support itself and goes under there are other teams in the area • No room for expansion if more successful • Failure to audit and approve the economic model • The case for larger stadium to accelerate financial viability of club is flawed and merely aspirational as clubs already in Championship with larger attendances make higher losses • No proof increased capacity would increase financial health of club • What would happen if club failed? • Club owner will make large profit and is a developer • Club supporters and owner should fund development

35 • Local community is financing the development • Scheme is a housing development with a stadium rather than other way round • High density owing to viability which is not a good argument • Scale of enabling development is unreasonably great and disproportionate • If paid too much for the site they applicant should not be able to compensate for that by increasing the enabling element at to the detriment of the community • No details of viability • Enabling development is for a profit • Failure to audit and approve the economic model • Motive is profit • Too many luxury flats

Other • Should build higher density at Griffin Park • Cumulatively with other development in Brentford the development is too much for the area • Lack of consultation • Need public meeting • Supporters don’t live in area • A stadium without housing would be supported • Would affect business if CPZ introduced • Realignment of Lionel Road further west would allow retention of stable block • Realignment of Lionel Road could be funded by energy savings from site wide energy centre with common utilities trunking, delivered through a bond issue and managed by an Energy Savings Company (ESCO) • Government funding would finance the up-front costs for an ESCO • Site is suitable for centralised energy system • Energy efficiency merely meets updated Building Regulations and should do more • Housing would be for foreigners • Misrepresented sight lines • Council has an interest as loaned club £500,000 • Kew Bridge scheme was bad enough • Should be determined by the Mayor • Should be located in Brentford and not Chiswick • Should find an unused area preferably close to a retail or industrial park in Brentford • Use for football is against developer’s stated intentions to include rugby

Community benefits • No community benefits • No benefits for local residents • Claimed benefits are not significant

7.18 Issues raised in support

Regeneration and economic growth

36 • The development will regenerate the existing site, which is previously developed and detracts from the amenity of the area • The area is currently used for waste transfer and is an eyesore • The use is a very beneficial use of backland between the M4 and the South Circular and a far better location for the football club than the present site • It will act as catalyst for regeneration of other surrounding sites. • It will help regenerate the run down end of Chiswick High Road • It would make the area more vibrant • Relocation is supported by the BAAP • It will lead to greater investment and infrastructure in Brentford • Will aid Brentford’s renaissance • Significant short term investment and employment during construction and from stadium, hotel and businesses (200 construction jobs) • Major long term positive impact on economy from new stadium, housing and businesses (650 full and part time jobs) • It will help to stimulate the local and national economy, vital at this time • Increased attendances will boost local trade in shops, pubs and restaurants, helping the local economy • On average spectators spend £17 in the local economy on match days, which would inject £340,000 into the local economy on match day if a crowd of 20,000 • Current match day spending in a season exceeds £2.69m, which will significantly increase with larger stadium • The identity of the area will be enhanced with a progressive high profile football club • The development would bring in an extra £2.5million to the local economy • Previous considerations for the site have been waste or warehousing uses which would not regenerate the area like the proposal would • The most recent demise of Coventry City FC demonstrates the effect of not relocating within the heart of the community

Housing

• 910 dwellings will help address housing shortage • The residential accommodation is highly attractive and a bonus to the area • Enabling development vital to scheme

Need

• The new stadium is vital to the long term financial security of the club • Without a new stadium the future of the club is in doubt • Club loses around £5m a season which is unsustainable • Current ground has no corporate facilities and inadequate hospitality areas • Improved facilities will increase attendances and revenues for the club • New stadiums are shown to significantly boost attendances, supporting the club’s Business Plan • Cannot extend current ground which is 100 years old • Current capacity not adequate for Championship level • Recently sold out ground on a number of occasions • There are no suitable alternative sites in the Borough

37 • Cannot accommodate away fans from large clubs • The current Stadium does not meet current standards, for example the toilets • Family and friends have stopped going to BFC because of poor facilities. • Increasingly difficult to attract new supporter as ground has inadequate and old facilities that do not meet expectations of what fans expect from football stadia • This is a once in a generation opportunity • Over the years there have been many changes to Griffin Park, most of which have culminated in reduced capacity for supporters and a general decline in facilities. • The most recent demise of Coventry City FC demonstrates the effect of not relocating within the heart of the community • Do not want club to fold or move away like Wimbledon

Residential Amenity

• The Local Area Management Plan would protect amenity of neighbours • Despite our proximity to the ground we do not remember any adverse fan related issues in all the time we have lived there • Incidents of hooliganism are negligible. • Local residents should have no fear of anti-social behaviour, as there is simply a miniscule amount associated with Brentford • The residential accommodation is highly attractive and a bonus to the area, comparing especially favourably to the Green Dragon Lane tower blocks • Public realm would be improved • The possible impacts on traffic, transport, noise pollution, climate, water and soil issues are all being addressed • Existing uses generate HGV traffic and pollution • Clubs like Arsenal which have crowds of 60,000 have managed to move within a large city and remain close to their original plot

Transport

• Many supporters would use public transport to get to the ground • The station improvements proposed as part of the development will enable crowds to arrive and be dispersed safely and quickly • Any traffic, both pedestrian and vehicular, would be adequately covered by the proposed arrangements • There are more than adequate modes of transport to cover any increase in crowd numbers caused by promotion • There are no unsolvable transport issues that would prevent the granting of permission • Traffic impacts are not excessive • Moving the stadium half a mile does not create unmanageable traffic problems • There are not many families that come to the existing ground, due to the poor facilities for children and women, so if a male fan starts to bring his family you may get more people in the cars, but not more cars • At almost all London grounds it is impractical to use a car as a mode of transport. • Football supporters are used to using public transport and there is no reason to think otherwise in respect of this proposed development

38 • I will continue to walk or take public transport to matches and do not foresee a sudden change in the way the majority of fans travel to matches • Brentford used to attract crowds of over 30,000 and the area coped and in times when traffic and transport infrastructure was much poorer • Due to the new location’s better public transport links there would be a reduction in fans using cars • There would no longer be dumper trucks delivering waste to the site and clogging up junctions • Would improve road safety • Presently no provision for cyclists • May stimulate improvements to stations near the ground

Community Benefits and Heritage

• BFC has been in Brentford for 124 years and is part of its heritage • BFC is at the heart of the community • One of the few places these days where I feel a strong community spirit and pride in the Borough • Brentford has seen loss of its courts, Firestone Building, Beecham House, Brentford Market and many of its much missed public houses so do not want to lose club • The club would help to create a stronger community • Great asset for the Borough to have a professional football club • Should stay in the area for reasons of local pride and to reap the community benefits • There is no similar type facility with similar capacity within the local area • The BFC Community Sports Trust would benefit greatly from the improved facility and therefore their contribution to the community would be increased. • Bringing the Trust and Club back together in the new stadium will enable the trust to expand its work and with improved facilities • Improved facilities for Learning Zone and Interim Education Centre • BFC Community Sports Trust is an award winning charity • BFC’s wide-ranging support for schools includes work with over 50 local schools delivering sports and social inclusion programs and the new stadium would increase this significantly • BFC’s involvement in the community would be secured • A football ground is no longer just a place to play football, as evidenced by the BFC Community Sports Trust, who have won many awards • Creates a strong sports and recreational cluster and will help promote sport, health, education, employment, training, social enterprise and social inclusion • In the event that the scheme does not go ahead the various community benefits would be lost • Will become a focal point for the community to visit and not just on match days • Advantageous to the community, particularly young people • Would provide better facilities for children • Would provide better facilities for disabled people • Would benefit elderly groups (Hounslow Aged Concern) • Gives young people the opportunity to access sport activity, education, health benefits , empowering them to reach their full potential in life

39 • The club offers affordable children’s season tickets • Opportunities for volunteering would be increased • The club was only the second to offer free entry and commentary to non-sighted users and has influenced others, leading the way in this and other regards • Hounslow is not blessed as one of the richer London Boroughs and any opportunity to provide benefits for the whole community must not be lost • The effects of community programmes such as BFC’s on reducing crime should not be underestimated • At a time of large government cuts it is fantastic having someone else willing to offer such opportunities to young people in the area. • The work they is vital in keeping young people off the streets and helping them think positively and have pride in their borough. • The work they do promoting health and fitness can only help to reduce costs for local NHS services • Olympics has shown how sport can spur on a nation to be more active but it comes down to the opportunities at the local level

Design and townscape

• New buildings will enhance the character and appearance of the area. • Some views of the area will be impacted, dependant on your viewpoint, but not too drastically • The development will provide a enhanced link between Gunnersbury Park and the River Thames, which is presently blighted by industrial businesses • Do not believe the height of the buildings is an issue as the immediate area already has similar sized buildings and which contribute to the character of the area • Concerns regarding adverse impacts on Kew Gardens are unwarranted • If construction was not allowed to take place near any of the UK’s World Heritage Sites the City of Westminster and the area surrounding the Tower of London would not be surrounded by the beautiful and modern architecture which they are today • The cultural heritage of the area will be added to • The existing stadium does not fit in with the new look Brentford • The design of the development ensures it will not be an eyesore and will not block views • You would not be able to see the development from inside Kew Gardens • High density is appropriate next to a railway station. • It is difficult to object to high-rise development next to the elevated section of the motorway and the existing office blocks • The club has already agreed to reduce the size of enabling development in accordance with the views of the community

Other

• The club has already agreed to reduce the size of enabling development in accordance with the views of the community • The present ground has not caused any unreasonable pressure on upon transport or the environment so fail to see why a new adjacent one would

40 • The sustainable, long-term benefits of the project would far outweigh any short- term inconvenience

7.19 Responses from statutory bodies

1. LB Ealing (28/10/13) and (1/8/2013) No objection • The Council has worked in partnership with the BFC Sports Trust to offer a range of sports and community focussed initiatives • Using sport as a catalyst, the Trust has been successful in engaging young people in Ealing with a range of abilities through delivery of football and other activities • Joint projects have had a significant positive impact on Ealing residents that have enriched the lives of young people. • The Trust in partnership with Pro Active West London and 5 boroughs delivers a programme designed to increase the number of disabled young people over 14 that regularly take part in sport. • The stadium will provide a long term home of the Trust, as well as providing purpose built, modern facilities from which schemes engaging young people can be delivered to promote not only sporting benefit, but also healthy living, education, employment and career opportunities, all incredibly important at a time when young people need help and support to fulfil their potential. • The new facilities and stadium will provide the Trust with the opportunity to build on past success and widen its service delivery to all ages from all sections of the community. 2. LB Richmond upon Thames (21/11/13) Objection • Objects to the visual impact of the proposed enabling development on the appearance and character of the Kew Green Conservation Area and the Royal Botanic Gardens World Heritage Site area, particular with respect to the setting of Kew Green, but also with respect to views from the Thames embankment and across Kew Bridge. • In the absence of adequate illustrative material to demonstrate otherwise, there are also strong concerns about a damaging impact of the enabling development on the setting of the Grade 1 listed Palm House building in the Royal Botanic Gardens. • The enabling development would also be harmful to the setting and character of the River Thames. • The scheme would therefore be in conflict with Policies DM OS4, DM OS11, DM HD1, DM HD2, DM HD5 and DM DC3 in the LB Richmond upon Thames LDF Development Management Plan: November 2011 and Policies CP7 and CP11 in the London Borough of Richmond upon Thames LDF Core Strategy: April 2009, and the Royal Botanic Gardens World Heritage Site Management Plan 2011. • Objects due to the failure to adequately assess the impact of additional traffic and overspill parking from the development on existing roads south of Kew Bridge, both on match days and at times when these coincide with other major events in Richmond borough. • Objects due to the failure to adequately demonstrate the affect of additional vehicles from the development on the traffic flow of the A205 South Circular Road on match days and at times when these coincide with other major events in Richmond borough. • Objects due to the failure to adequately assess increased traffic generated by the residential development, and the impact of this on the A205 South Circular Road.

41 • The proposal would therefore be in conflict with Policies DM TP1, DM TP2 and DM TP8 in the LB Richmond upon Thames LDF Development Management Plan: November 2011. Informative: In the event of planning permission being granted, LB Hounslow is advised that section 106 monies should be secured towards funding a review and implementation of changes to Controlled Parking Zone(s) in Kew. 3. Greater London Authority (Mayor) (30/7/2013) Neither • Stage 1 Response: • The Deputy Mayor considers that the application does not comply with the London Plan, for the reasons set out in paragraph 138 of the above-mentioned report; but that the potential remedies also set out in that paragraph of the report could address those deficiencies. • Whilst recognising the potential contribution of the enabling residential development to deliver the full scheme, the Deputy Mayor remained concerned that no affordable housing would be provided in such a large quantum (910 units) of accommodation and that a financial viability appraisal had not been included in the electronic or hard copies of the documents submitted in support of the referral. He was also concerned that insufficient attention had been paid to the potential impact of the proposed tall buildings on the World Heritage Site at Kew and requested that a full visual impact assessment be submitted for strategic consideration, prior to any further referral of this case back to the Mayor. • London Plan policies on waste capacity, loss of employment, sports facilities, regeneration, housing, mixed-use developments, transport, urban design, inclusive access, energy, ambient noise and air quality are relevant to this application. Whilst the application is broadly acceptable in strategic planning terms, it does not yet fully comply with the London Plan. • The following changes might, however, remedy its deficiencies and could lead to the application becoming compliant with the London Plan (paragraph 138). • Waste capacity: The applicant Club or waste transfer operator (Quattro) should confirm the company’s current annual throughput (in tonnes) and specify the location and capacity (also in tonnes) of its alternative sites, to enable GLA officers to ensure that there is sufficient land and capacity sites to meet the demand for waste transfer operations. Hounslow Council needs to safeguard all existing waste sites, or if a good case can be put forward for losing a site, allocate and safeguard alternative site provision. Officer Response: Tonnage information was stated as being commercially sensitive and not provided. In any event, adequate alternative waste facility sites area available in West London, including proposed site at Western International Market. • Affordable housing: Hounslow Council is requested to share the conclusions independently reviewed financial viability appraisal to ascertain that the scheme cannot support any affordable housing and a robustly drafted review mechanism in the legal agreement to secure some affordable housing if there is a significant improvement in financial circumstances and subsequent viability of the development. Officer Response: A financial viability report has been assessed by an independent consultant on the Council’s behalf. It confirms that no affordable housing is presently viable. An obligation applying a deferred contribution review mechanism, to secure affordable housing/ affordable housing contributions should the viability position improve

42 as the development proceeds has been recommended. • Housing mix: In view of the low proportion (20%) of family-sized housing within the scheme, Hounslow Council is requested to confirm whether the proportion of three- bedroom units adequately reflects the housing need for that location. Officer Response: The proposed mix is appropriate given the scheme’s location and the higher density nature of the development. • Children’s play space : The applicant should ensure that at the very least, the London Plan and SPG play space requirement for children aged five and under, is provided on site. Officer Response: Children’s’ play space for under 5s and 5-11 year olds will be provided on site, in accordance with the London Plan and Play and Informal Space SPG play space requirements. This would be secured by condition and reserved matters. • Social infrastructure : The scale of residential development is likely to increase demand for and pressure on local social infrastructure, such as school places and health facilities. The Council is requested to raise this issue with the Club to secure appropriate provision or a contribution towards such provision, in order to avoid any acute deficiencies in essential services. Officer Response: An obligation requiring a contribution towards funding of school places is recommended. In respect of health, the ES has demonstrated existing services are adequate for the developments impacts and it is noted the scheme secures and enhances operations of the BFC Community Sports Trust, which has extensive preventative health, sporting participation and education benefits that would enhance the health and well-being of many people in the region. • Transport: The applicant should work with TfL and Hounslow Council to improve access to the site for both match days and non-match days. Similarly, the car parking strategy for match day and car parking levels for non-match day should be reviewed. Further assessment of the impact on public transport should be undertaken, especially for the rail and underground network. Currently, highway modelling is inadequate and should be resubmitted in discussion with TfL. Match day and non-match day mitigation will be required. Officer Response: Further information was submitted in respect of TfL’s comments regarding site access, car parking, public transport impacts and highway modelling. The further information demonstrates that the transport impacts from the development are not of such significance that refusal is warranted, though they will be disruptive on occasions and would result in minor increased delays on the road traffic network. Conditions and planning obligations are proposed to secure match-day and non-match day mitigation and minimise impacts. • Urban design: The urban design section highlights a number of shortcomings in the design, layout, typology and legibility of the development, some of which derive from the outline nature of much of the scheme. Some suggestions are made to resolve these issues, which the applicant is requested to consider and address before a decision is made on this application. In particular, the applicant should submit a visual impact assessment of the development on strategic views, including the World Heritage Site at Kew. Officer Response: The applicant submitted a design clarification document that sought to respond to the GLA queries, demonstrating satisfactory accommodation that would meet relevant Housing SPG standards could be provided. This included an analysis of an alternative ‘perimeter block’ layout, which was found to be inferior to the proposed

43 layout. The ES included an assessment of key views from Kew Gardens WHS. A further view was assessed following comments made. The verified views show that the impact on the character and appearance, and Outstanding Universal Value of the gardens is not significantly harmful, with limited changes to existing views. • Inclusive access: The main obstacles to free movement to, through and from the development for people with disabilities are identified in the inclusive design and access section of this report and should be resolved before any future referral of this application back to the Mayor . Officer Response: The applicant submitted a response to these comments, and appointed an advisor on accessibility matters with a Stadium Access Strategy developed. The advisor’s recommendations and clarification demonstrate that the stadium and enabling development would inclusive, with details of accessibility to be secured by conditions. • Energy: The energy section identifies a series of actions and clarifications required from the applicant to ensure that the proposed energy strategy is robust and compliant with the energy policies of the London Plan. Officer Response: Further discussion of this matter has been undertaken with the Council’s Sustainability Officer, with the use of centralised heating network explored. It has been accepted that such a system is not viable for the initial phase of the development, but that the scheme would be designed in a manner capable of utilising or joining such a system should this develop. Otherwise the overall scheme meets the relevant polices of the London Plan in respect of carbon dioxide emission reductions and energy efficiency, with a shortfall for the stadium itself to be offset through an obligation requiring a carbon offset contribution. • Ambient noise: Inadequate information has been provided to enable a proper assessment of the noise implications of the proposed development. The relevant deficiencies are identified in the ambient noise section of this report and should be fully addressed if Hounslow Council is minded to grant permission for the development. Officer Response: Further information was submitted in response to the GLA’s comments, with these demonstrating that with appropriate mitigation where necessary, a satisfactory noise environment would be provided for both future occupants of the development and to neighbours and nearby open spaces. • Air quality: Additional information and clarifications are required to allow a full assessment of the air quality issues raised by this proposal and to ensure full compliance with the air quality policies of the London Plan. Officer Response: Further information was submitted in response to the GLA’s comments, with these demonstrating that with appropriate mitigation where necessary and measures to maximise sustainable modes of transport by residents and visitors to the site, impacts on air pollution would be minimised, and the air quality for future occupants of the dwellings would be satisfactory. 4. Transport for London (12/7/13) Neither • As with all major land uses that attract the assembly of large crowds, the proposed stadium development raises a wide range of strategic transport issues that need to be addressed prior to commencement and operation of the scheme. Site access strategy • To maximise access to the site, pedestrian, vehicle and cycle links are proposed from

44 various locations including Lionel Road South and Capital Interchange Way. • New bridge is essential part of the access strategy so must be secured by condition or legal agreement that this link will be constructed and opened prior to the first occupation of the stadium or housing within the north eastern section of the site. • Should the bridge link and access not be adopted as part of the public highway, a s106 obligation should also ensure that it remains available for public vehicle, pedestrian and cycle access on a 24-hour basis. • Proposed reopening of pedestrian underpass beneath Lionel Road South to create a direct link to the stadium concourse should be secured through a section 106 agreement. • The capacity of Lionel Road South would also be improved through the installation of a 2m wide footway on the south side. As the increased footway width will be necessary to accommodate match day spectator flows, they should be completed prior to the first occupation of the stadium and that they are delivered by the applicant through the s278 agreement. • Pedestrian crowd flow modelling indicates that on match days, local road closures would also be necessary, especially for the post match period. • Forecast pedestrian and cycle movement suggests that demand would be greatest at Chiswick High Road, east of Lionel Road South. As Lionel Road South is one of the main links to the A4/M4, even limited closures would increase delays at Chiswick Roundabout. Should consider whether addition links should be created to the stadium area. For example, the installation of a pedestrian link to Green Dragon Way could help to dissipate the crowd and avoid the relatively narrow footpath on Kew Bridge Road and Chiswick High Road. Car and cycle parkin g • Should have a restraint based approach to parking in accordance with London Plan • Should justify the level of on-site operational car parking, particularly as it is noted that only 22 blue badge spaces are highlighted as being available for match day use. • Need a stadium car parking management plan, secured by s106 agreement to minimise traffic congestion on match days. • Need further details of proposed procurement and management of 1,000 off site match day car parking spaces along the A4/M4 corridor, and if agreed secured through a s106 agreement and promoted through the travel plan. • The assessment should also consider the quantum and availability of other on and off site car parking within a reasonable walking distance of the proposed stadium. • On-street parking should be discouraged through match day CPZ to minimise vehicular congestion in the local area. • Need further details of actual spectator parking. • Given the level of congestion that already exists on the local and strategic road network, the applicant should reduce provision of residential parking to the minimum necessary to support any family or wheelchair accessible dwellings. • Capped parking levels should be supported by CPZs within a nearby existing residential area (subject to consultation) to address potential overspill. • The level of parking that is currently proposed within such a large development could generate high levels of vehicular trips resulting in peak hour congestion and would be

45 inconsistent with the Hounslow Council’s proposals to boost cycling levels and the use of other sustainable modes, and may compromise any TfL proposals to improve cycle safety on the nearby sections of the TLRN. • For the level of residential parking that is ultimately agreed, recommends that it will be supported by a management plan to control and minimise their impact, including details of any allocation and phased roll out. • Should have electric vehicle charging points and 10% of all spaces to be disabled spaces. • Cycle parking to be in accordance with revised standards. Transport assessment • Although most location points within the site are expected to achieve a PTAL of at least 3, this should be verified • Transport assessment for the stadium considers the impact of a football club only, it is noted that the stadium will be designed to cover football and rugby as well as match day and non-match day hospitality, banqueting and other events so impact of these alternative scenarios should also be examined. • Although a 20,000 capacity football stadium may be expected to represent a ‘worst case’ scenario, the match day operation is highly managed, supported by various strategies including a ‘Local Area Management Plan’. Furthermore, the travel patterns associated with frequent spectators are unlikely to be representative of an ad hoc visitor. Should the applicant fail to assess the impact of other match day and non-match day uses, recommends that Hounslow Council restrict the use of the stadium accordingly. • Should assess a mid-week fixture. • The level of highway modelling is not adequate. A validated base model with be required along with an area based model that compares the current network with the proposed development and take account of other committed developments will be necessary. • Sceptical that the applicant’s proposal to optimise signals would satisfactorily mitigate the impact as there is unlikely to be any spare capacity within this section of the TLRN.

22/10/13 – Further comments made in response to additional information submitted. • Remains concerned about the impact of the closure of Lionel Road South for up to 30 minutes in the post match period. Given the significant affect on the operation of the TLRN at Chiswick Roundabout. • Extra pedestrian traffic heading north to planned off-street car parks will require public realm improvements and/or control through the stadium management plan. • Coach parking on Capital Interchange Way to commence only once necessary arrangements are in place. • Clarify hotel coach parking and taxi pick up areas with these to be secured. • The undertaking of further match day travel surveys is welcomed. Clarification of parking impacts necessary. Notwithstanding that, it appears that 2,719 potential on spaces have been identified and a further 1000 ‘club controlled’ spaces. • Forecast pedestrian movements would, post match, dissipate very quickly across the network, large numbers will affect comfort levels and could be a safety issue, which

46 should be mitigated through public realm improvements And impact of pedestrian flows should also be managed through the LAMP and improved wayfinding. • Clarification of rail usage numbers • Queuing times at Kew Bridge station are expected to increase from 60 to 67 minutes. Whilst this not considered materially greater, this reinforces the need to secure a stadium retention strategy through the travel plan, as well stewarding to manage the queues, secured through the LAMP. • Contribution of £175,000 required towards an additional peak hour service, pooled between these two developments (£175,000 each) is therefore requested. • The applicant should clarify the extent of the area where is it is expected that spectators and other users of Gunnersbury station would queue. It should also be noted that marshals have no legal powers to contain queuing and if spectators become unruly by being made to queue there would be no mechanism of redress. • Recommends supplementary highway assessment • Regardless of the outcome of VISSIM modelling, TfL appreciates that there are no easy solutions in terms of mitigating the impact of additional traffic in this area. • The applicant’s current proposed optimisation of the LINSIG model delivers an unrealistic prediction of the benefits that can be gained from signal timing alterations. In reality, Chiswick Roundabout already operates close to capacity • TfL emphasises however, that the capacity of the network in relation to proposed development traffic should be determined with micro simulation modelling in order to provide the decision maker with a level of confidence about the impact of these proposals . Officer Response: The applicant has liaised with both TfL and the local authority to provide clarification on the above matters with agreement that a number of issues would be addressed through the Stadium Management Plan, plus other obligations requiring contributions for buses, public realm improvements, and travel plans. The applicant also complemented there revised traffic modelling, through meeting direct with TfL to utilise their own resources, with this confirming the earlier conclusions that there would be additional delays to journey times on the adjoining road network, and although not ideal, this would not be so severe to warrant refusal. It is noted that the validation and checking of the model has not yet been completed by TfL and therefore the supplementary results are subject to their final sign off. 5. Thames Water (28/6/13) No objection • Waste (sewerage infrastructure) – no objection. • Water (supply) - The existing water supply infrastructure has insufficient capacity to meet the additional demands for the proposed development. Thames Water therefore recommend the following condition be imposed: Development should not be commenced until: Impact studies of the existing water supply infrastructure have been submitted to, and approved in writing by, the local planning authority (in consultation with Thames Water). The studies should determine the magnitude of any new additional capacity required in the system and a suitable connection point. Reason: To ensure that the water supply infrastructure has sufficient capacity to cope with the/this additional demand.

47 6. Heathrow Airport (8/10/13) No objection • The proposed full planning part of the development has been examined from an aerodrome safeguarding perspective and does not conflict with safeguarding criteria. • The proposed outline planning part of the development has been examined from an aerodrome safeguarding perspective and could conflict with safeguarding criteria unless any planning permission granted is subject to a condition regarding bird hazard management . 7. Metropolitan Police (14/11/13) No objection • Happy for the application to proceed to next stage, with conditions in respect of liaison with Police in incorporating Secure by Design elements, crowd management and provision of real time information systems (showing train and queue times) 8. Environment Agency (22/10/13) No objection • No objection. 9. Sport England (17/6/13) Neither • Consultation acknowledged. 10. English Heritage (Archaeology) (27/11/13) No objection • Based on archaeological ‘Written Scheme of Investigation: Method Statement for Archaeological Investigation Works’ - Accords with relevant standards and guidance and that it is in compliance with the GLAAS recommendation for a staged approach to archaeological mitigation here predetermination of the planning application (conditions recommended). 11. English Heritage (22/7/13) Objection • The development site is in low intensity industrial use, and contains no designated assets of historic or architectural significance. • Recognise the new stadium in this locality will bring cultural and social benefits to the local and wider community. • Whilst the stadium itself is broadly acceptable, the height, scale and massing of aspects of the outline enabling elements are harmful to the setting of a number of designated heritage assets, particularly the scale of the south eastern element. • The scale would harm the setting of designated heritage assets in the immediate and wider locality, including the Grade II listed Kew Bridge Station, the Grade I listed Pump House Tower and Great Engine House of Kew Bridge Pumping Station, and its associated complex of Grade II buildings, and the Grade II listed Kew Bridge. • In addition, the wider settings of other designated assets in LB Richmond potentially harmed include the listed buildings within the Kew Green Conservation Area and views from and within the Royal Botanic Gardens Kew World Heritage Site, listed Grade I on the Register of Historic Parks and Gardens of Special Historic interest in England. 12. ICOMOS – UK (1/8/13) Objection • Strongly object owing to significant visual effect on key points in the WHS and setting, because the high-rise structures of the development will be visible from various key points in the WHS and essential setting. 13. The Georgian Group (25/9/13) Objection

48 • The proposed development will have a significant impact on heritage assets that fall within The Group's remit. • Royal Botanical Gardens, which contains fine Georgian structures. • Kew Green Conservation Area designated due to its character as an historic open space, associated high quality of mostly C18th development and its superior riverside. • Gunnersbury Park will also be affected. • Understands demand for new stadium and has no objections in this location in principle, however, has objections to the "enabling development" of 12 residential/commercial tower blocks, up to 16 storeys high, all within 400m of the aforementioned heritage assets and "protected view" from Kew Gardens. • The impact of the mid-late 20th century tall buildings developed west of the application demonstrate the impact of the proposal, as they be detrimental to the setting of the heritage assets above by infilling the skyline and creating a sense of advancing urban development. • The character of these assets is dependent upon retaining a sense of "escape" from the surrounding metropolis and the proposed development will take a significant step towards eroding this character. • Supports English Heritage and the Kew Society that the proposed development should be refused on the grounds that the erosion of the existing skyline will be damaging to the setting of the heritage assets. • The NPPF states: "Significance can be harmed or lost through alteration or destruction of the heritage asset or development within its setting. As heritage assets are irreplaceable, any harm or loss should require clear and convincing justification." (Para.132 ) • In this case the justification is enabling development, i.e. that the development is not financially viable without the proposed ancillary residential development. If this is the case The Group recommends that the applicants seek additional development off-site or consider an alternative type of development as the current development cannot be considered to enhance or preserve the setting of features of special architectural or historic interest, as required by statute. 14. Victorian Society (12/11/13) Objection • The Victorian Society has been made aware of this application to demolish the former Stable Block, and I now write to convey our objections to the proposal. • The building is handsome in appearance and monumental in its massing. It speaks of a working past with its wide openings to the ground floor, and surviving hoists above the first storey doors. It is finished with fine details such as the polychromatic brickwork and cogged bricked cornice, which mark it as an understated but accomplished building. • The former Stable Block is an un-designated heritage asset of note. Paragraph 135 of the National Planning Policy Framework instituted a degree of statutory protection to undesignated heritage assets, which makes the building’s demolition a material consideration in planning terms. • The demolition of the building is unnecessary. It is in a good condition, and its fairly large size means it would lend itself to a number of uses that could be easily incorporated into the proposed development. Stable blocks have shown themselves to be well disposed to adaptation, as the building in question has already demonstrated by its current use as a classic car repair shop.

49 • The building is also a surviving fragment of the area’s rich nineteenth century heritage and character, which includes the Grade I listed steam museum. Its demolition would therefore erode the areas historic interest. • If your council is minded to accept the application, we advise that the plans are amended to retain and incorporate the stable block.

7.20 Non-statutory responses from interested parties

15. Football League (22/7/13) Support • Support ambition to improve stadium facilities for supporters & local community. • With an excellent reputation for its community work, including twice being recent winners of our Community Club of the Year Award, The League is convinced that the development of such excellent new facilities would further enhance this work, & the club’s standing as a whole. • Clubs should remain at the heart of, and play an integral role within, their communities. As such, while aspects of the move will need to comply with our regulations, at this stage The League fully supports the club in its application. 16. Chase Bridge Primary, Twickenham Support (18/7/13) • Worked with club and BFC Community Sports Trust for a number of years, with them delivering PE lessons and a wide range of after school and lunchtime clubs. • We are extremely pleased with the quality of provision and professionalism shown by the trust, including the high quality of lessons delivered by coaching staff. • BFC and Community Sports Trust are real community assets and we fully support them remaining within the local community in Brentford • With the benefits experienced first hand, as well as the obvious economic and social benefits for the wider community, we support the club’s development. 17. Trafalgar Infants (Twickenham) (16/7/13) Support • BFC and the BFC Community Sports Trust have always been community focussed and supportive. This development will enable them to improve their work with: • More capacity to offer more support to after school football club. • More capacity for links to PTA – providing tickets to local families at affordable prices. • More facilities to help Junior Bees teams for local children. • New opportunities through the Trust to provide sporting experiences to children. • Improved facilities to encourage local families to make BFC their club to support. • Opportunity to have a local venue for conferences and seminars for our school cluster. 18. Three Bridges Primary, Southall (22/7/13) Support • Last season we took over 200 children, parents and staff on 3 occasions to watch BFC. • These occasions has a huge impact on all concerned in raising awareness and participation in sporting, social and community events. • Children benefit from expert coaching. • It is very important that our local area continues to have a thriving professional football

50 club, especially a club that has the wider community at its heart. 19. Marjory Kinnon School, Hounslow (16/7/13) Support • A special school that has benefited for many yeas from BFC community work. • The Community Sports Trust has provided excellent sport, health, and education projects within the school and Griffin Park. • Have always encouraged the inclusion of our special education needs students. • The club’s plan will only benefit the community even further. 20. Brentside High, Hanwell (16/7/13) Support • Believe the club to be an asset to the local community. • The club supports events at local high schools giving time and effort to support youngsters in the community. 21. The Heathland School, Hounslow (17/7/13) Support • Largest secondary school in Hounslow (1,800+ pupils). • Our sports staff has regular contact with the Brentford Community team and they have invariably been ambitious to support initiatives in schools. • A new stadium in this area will raise the motivation & enthusiasm for healthy sports amongst boys and girls in this area. • They have a broad vision for expanding interest in sporting activity and such a development would raise the profile of Brentford and Hounslow. • In the past we have booked venue in hotels in Twickenham for staff/ student functions and would appreciate expanding our range of options for conferences and social functions that the new stadium would enable. • This is an imaginative and forward looking plan for re-generating a major community club in this area. 22. Greenford High, Southall (9/7/17) Support • The club is extremely supportive of the school. • We are a large comprehensive in Ealing near to the club and LB Hounslow, with 1,800 students and 200 staff. • BFC have supported us though a literacy project to promote reading amongst boys, through sporting opportunities for our youngsters, through work experience and by offering support and development for a particularly troubled and challenging young man whom they took on a coaching programme. • Believe that BFC has demonstrated to us its commitment to the local community and local schools and we would like to support it in securing its future. 23. Together We Create (23/8/13) Support • Charity has worked with the club and Griffin Park Learning Zone for number of years and see the dynamic impact it has on young people. • Provision of safe interactive, alternative space for children to learn is vital in west London and in particular LB Hounslow • New stadium will bring educational benefits and a new Learning Zone is a positive way to enhance learning locally

51 24. Bees United (10/9/13) Support • Represent over 2,000 members • Presence of club helps to maintain profile of Brentford nationally • Award winning community work one of only 40 UK companies awarded a BITC community mark • Larger more modern stadium will meet needs demands of contemporary sports audience putting club on significantly more stable financial footing • Will secure club’s position in long term and allow BFC Community Sports Trust to expand • BFC Community Sports Trust has won Football League Community Club of the Year 4 times and delivers 7,500 sessions annually across 27 sports in 4 boroughs • Stadium will be a true community hub, providing links with local leisure, education, health and community facilities throughout Hounslow and neighbouring boroughs • Will deliver much needed housing 25. Brentford Lifeline Society (19/8/13) Support • Witnessed amazing energy and work ethic from all involved, whether players, staff, supporters of the Club and members of the Community Sports Trust, in encompassing the whole local community into everything that it does. • An integral part of the community and planned Community Stadium will be of continuing benefit of all concerned, including Hounslow community and neighbouring areas. 26. Supporters Direct (15/8/13) Support • Promote sustainable spectator sports clubs based on supporters involvement and community ownership. • Through research we have found that football clubs have a vital role in helping the cohesion of their communities, and by integrating the community into club life there is a chance to realise social value. • Through the involvement of Bees United, the community is well placed to make the most of the development. • The provision of a ‘golden share’ to protect the sale of the ground at Lionel Road means the supporters’ interests are enshrined and the benefits should be sustained for future generations. 27. Brentford Independent Association of Support Supporters (BIAS) (16/10/2003) • Represents membership of over 600. • Brentford FC is a part the local community. • Believe the development will breathe new life into an area in need of revitalisation. • Many BIAS members are from the local Brentford area and as such BIAS has taken a keen interest in the impact of the new development on the surrounding area. • Impressed with the inclusion of a footbridge from Kew Bridge on matchdays. • New development will be better served by the bus routes and is easily accessible from a greater number of train stations than is currently the case. • Impressed with the work done by the club to reduce the height of the developments to reduce their visual impact on the surrounding area.

52 • Many visitors contribute significantly to the local economy on matchdays, and a stadium with greater capacity and better facilities would increase this spend. • Club has a long and proud tradition as being community focused and working to make a positive difference for local residents. • Of particular success is the Brentford FC Community Sports Trust which is truly of benefit to the community. The new stadium would give it more facilities and scope to give back to the community. • The plan for a new stadium in Lionel Road South is essential for the sustainability of the club, but Brentford’s plans put the community at their heart. • A new Brentford FC in Lionel Road South would be a great step forward for Brentford’s community. • Brentford FC has just celebrated its 124th birthday and a new stadium will rejuvenate not only Football Club but the whole area. 28. Sporting Equals (23/7/13) Support • A national charity that promotes diversity in sport and physical activity. Has worked with BFC Sports Trust for over 6 years and noted the club’s commitment to the local community and to improving opportunities through their Trust. • The current facilities are detrimental to the club’s ability to deliver the best opportunities to local people of all ages and backgrounds. • With an increasingly diverse population in the borough the facilities will assist in driving up standards and opportunities for local residents, with positive impact on health, education and leisure. • New modern facilities will reduce some of the known barriers to many ethnic groups engaging in sport and other activities. • With new facilities, Sporting Equals, and other partners would direct residents in the area to the range of sporting, leisure, volunteering and other opportunities at the site, helping to increase visits and supporting the local economy. • Support promotion of increased travel by cycling 29. ABeeC political party (31/8/13) Support • A once in a generation of opportunity to transform BFC as a business can only further the club’s ability to continue its excellent work in the local community. • Griffin Park is more than 100 years old and not fit for purpose. • The stadium will offer other much needed facilities that will benefit the community through the BFC Community Sports Trust and Learning Zone. • The benefits contrast with the current use of the site as a recycling yard with there no longer being large trucks delivering waste to the site. • By encouraging supporters to use public transport it is likely this will lead to an improvement in traffic coming off Kew Bridge Road. • It will be a win for the supporter base who will enjoy facilities for the modern age and a win for the community who will benefit from the local amenities of the stadium. 30. Stephen Pound MP Ealing North (8/13/2103) Support • Move to a purpose built stadium will be beneficial to the club and local community. • There have been some concerns over scale and design of residential development, including level of affordable housing, as well as traffic and transport but hopefully

53 negotiations can continue and an accommodation can be reached on the issues. • In principle, an excellent proposal which will ensure future of BFC and provide a new home for BFC Football Community Sports Trust. • Will help regenerate this part of Brentford. 31. Brentford Chamber of Commerce (1/8/13) Support • Believe the development is a real community asset and will kick start the much-needed economic vitality that Brentford has been lacking in recent years. This will further result in new business prospects and ultimately increase revenue into Brentford. • Established local businesses will be enhanced, initially through contract procurement opportunities generated from the initial build process, and into the future of the new development and its associated buildings surrounding the stadium. • The new stadium complex will also encourage new business development and provide local employment, which will benefit Brentford and its impending vast regeneration over the coming years. • The stadium itself will be an iconic landmark for Brentford’s future, and keep Brentford firmly on the map. 32. Hounslow Chamber of Commerce (11/7/13) Support • Appreciate that the football club brings a significant amount of business income into the local economy and this will substantially increase in the new stadium. • Strongly believe that the project will stimulate regeneration and economic growth in Hounslow. • In addition to increased visitor numbers and income for local businesses, new homes, 200 new construction jobs and creating and safeguarding 650 new and existing long term jobs will be immensely appreciated by Hounslow Chamber Of Commerce. 33. West London Business (4/7/2013) Support • West London Business, the Chamber of Commerce and Economic Development Agency for West London, representing over 800 businesses, promoting it as a business location and investment destination. • BFC is one of our longstanding and active members. • Express strong support for the BFC stadium development. • The expansion is necessary for the continuing commercial health of a community sports club that brings added value to the local community. • The new 20,000 capacity stadium will enable the club to enjoy a sustainable future with expanded facilities attracting more business and revenues. • The existing spending of fans in the local area (£2.7m each year) can be increased significantly. • In terms of regeneration the advantages include 200 construction jobs in the short term, 650 jobs created or safeguarded, and a lively new community and social centre on what is now a semi-derelict brownfield site. • Development would provide 910 new apartments along with bar, café and restaurant facilities. • New stadium will have strong links with local health, education and leisure facilities • It will enable the BFC Community Sports Trust to thrive, with this award winning

54 charitable body bring much valued support to local youngsters through its Learning Zone and other activities. • New stadium will play a major role in revitalising Brentford, attracting enhanced income and investment interest and thereby generating much needed economic growth, which will benefit the local as well as broader West London, economies. 34. Royal Botanic Gardens, Kew (26/7/13) Objection • Stadium has potential to bring significant economic and social benefits to Brentford and wider area. However the associated residential development would have significant negative visual impacts. • Enabling development would have harmful impact on the Kew World Heritage Site and its setting, in particular Kew Green, and on the setting of listed buildings, particularly the Grade I listed Palm House. • This will be a significant change from the existing scene, particularly with the towers breaching the tree canopy to the detriment of the Kew Green conservation area, contrary to adopted policies. • At present the Vantage West office block on the M4 appears behind the Palm House seen along the Palm House vista. The stadium also aligns with the Palm House vista but is closer with the enabling development at approximately the same height and is likely to be seen behind the Palm House further intruding on the backdrop. • No safeguard to prevent a future developer from applying to build taller buildings. • Would compromise the Kew’s Outstanding Universal Value and associated attributes, contrary to the aims and objectives of the WHS Management Plan. • Use of Kew Bridge Station on match days and proposals for car parking, with the possibility of overspill parking on Kew Green and in the Kew car park itself, conflicting with our own interests. • Seek assurance that visitors leaving Kew Gardens on match days will not be caught within the football crowd, with some form of separate routing and priority access for Kew visitors (and others such as local residents) to be agreed. • Disappointing no plans to make both station platforms accessible, or improve Kew Bridge Road and Kew Bridge approach. • No objection in principle to the stadium itself which, with appropriate safeguards and conditions, could be a great asset to the area. Rather our objection concerns the way in which the stadium is financed by residential development which would compromise the Outstanding Universal Values of Kew Gardens which we seek to protect. (25/11/13) – In response to additional photographs requested: • Acknowledge that no visual impact on the Palm House in summer view. Image received on 15 November shows most trees along Pagoda Vista still in leaf. On this basis cannot be sure there will not be an adverse impact on the setting of the Palm House in the winter months. Request deferral of application until early 2014. 35. Brentford Community Council (15/7/13) Objection Supports the principle of the development but recommends refusal owing to: • Potentially harmful visual impact on adjacent and distant areas, during the phased construction and on completion. • Potentially adverse impact of crowd movement on the local community and on traffic movement from stadium use.

55 • Potentially adverse impact on the townscape, on tall building policy, and on other development near the Great West Road. • Potentially significant impact on the social support of Brentford, such as education, health and transport facilities, particularly in the light of the other major schemes in the planning process and the existing lack of infrastructure. • Poor quality of the design of the stadium, hotel and residential development, including concern at the poor quality and amount of amenity space for residents. Would welcome a scheme which: • Reduced the maximum height to 21m (equivalent to 7 floors), or about 35m AOD to have regard to surrounds. • Includes conditions to ensure residents, visitors to Kew Gardens and the river and others were not inconvenienced on occasions when the stadium is used. • Is not approved until increased demands on Brentford’s support infrastructure are met. • Conforms to development plan standards, including environmental quality and amenity for residential development. 11/11/13 – Further submission made providing an appraisal of development values claiming that the development would generate a profit of £95m. 36. Chiswick High Road Action Group (12/7/13) Objection • Scale, height and massing of the 9 high rise residential towers of up to 17 storeys impacts negatively on the surrounding areas and overshadows area. • Increase in population with no provision for additional social facilities or outside space. • Architecture is inappropriate and characterless with no local pride or civic identity. • Traffic impact is enormous and entirely negative, both on roads and on public transport. • Impact on local residential areas and the riverside, both of which are integral to the character and context of our area, are substantial and negative. 37. Strand on the Green Association (9/7/13) Objection • Implications for the local infrastructure and environment are not acceptable. • Size and bulk of the enabling development would have serious and adverse impacts on local residential areas, many of which are conservation areas, and threaten the World Heritage listing of Kew gardens. • The proposed buildings harm the domestic scale of surrounding conservation areas, which have been designated to protect them against inappropriate development and it will harm views travelling north on Kew Bridge. • The Grade 1 campanile of the Steam Museum would lose much of its appeal when viewed against a backdrop of high-rise apartment blocks. • Recommend buildings be no taller than 21m (7 storeys) • The density of 525 units per hectare is twice the limit of the range set by the Mayor. • The small parcels of land designated for the enabling developments would result in unacceptably high densities and allow very little amenity land for new residents. • Football supporters should be kept well clear of areas used by other members of the public. Sceptical as to whether proposed management plans will be effective. • Kew and Gunnersbury stations would be inadequate for the proposed uses. • Inadequate parking and unacceptable impacts on traffic conditions and safety.

56 • An over-arching master plan is needed to ensure that infrastructure needs are met. • The understandable desire to relocate the BFC stadium should not be justification for a development which would be harshly and permanently detrimental to its neighbours. • The current application flies in the face of many of the policies of Planning Policy. 38. Friends of Stile Hall Gardens (8/7/13) Objection • Enabling development and stadium too high and dense to be in keeping with the local area, blighting views from Kew Bridge, Strand on the Green, Wellesley Road and Stile Hall Gardens including conservation areas and World Heritage site. • Light pollution to nearby residential streets from floodlights. • Adjacent roads are congested and cannot cope with the extra traffic predicted. • Increased queues of traffic on Stile Hall Gardens and Wellesley Road will lead to further air pollution and is a safety risk for emergency vehicles. • Inadequate car parking would lead to on street parking on surrounding streets. • Extra residential parking schemes will be needed, and these should be funded by BFC. • Kew Bridge and Gunnersbury Stations cannot cope with extra demands of the large numbers of visitors and there will be impacts on non-football users of the stations. A contribution to improvements to both stations is recommended. • No affordable housing. • Risks of disturbance from noise and litter to the local residents of Wellesley Road and Stile Hall Gardens. If approved, a condition should that walking routes to the stadium are away from residential streets and be strictly marshalled and streets cleaned. • Quality of this accommodation does not meet UDP standards given the density of the development and the lack of outside space for its inhabitants, including children’s play. • Additional demand on education and health facilities. • The influx of fans will swamp the riverside walks and impair their use by local residents. 39. The Kew Society (30/7/13) Objection • The proposal is inconsistent with planning policies. • The “enabling” development will result in overdevelopment of poor quality housing with no amenity space. • The developer has not evidenced that all potential funding avenues have been explored and incorporated in financial appraisals. • Lack of infrastructure contributions e.g. schooling, affordable housing, CIL etc. • Visual impact on Kew Green Conservation Area, Kew Bridge Pumping Station Water Tower etc. of, in particular, towering residential developments. • Impact on Royal Botanic Gardens, Kew in terms of setting, views from and match day access including potential use of their Ferry Lane car park by those attending a match. • Implications for street parking in north Kew, potential need to extend CPZ to all streets. • The club’s proposals for providing adequate short-term parking (nearly 3,000 cars are expected) are not fully evidenced or proven and their long-term availability insecure. • The application is currently only for football use which is contrary to the developer’s stated intentions. Rugby and entertainment uses will have significantly different impacts which should be addressed as part of the current application. • Impact on public transport: bus, tube and train and road users generally. Proposed mitigation measures to train and tube railway stations are inadequate.

57 • Lionel Road access to the M4 would be closed for some time on match days so exacerbating traffic congestion on the North/South Circular Road. • The applicant’s Transport assessment contains a number of flaws and inconsistencies together with un-evidenced assumptions. 40. Kew Residents Association (4/7/2013) Objection • Seriously detrimental visual impact on Kew Green Conservation Area. • Negative impact on Royal Botanic Gardens in terms of setting, views from and match day access including potential use of Ferry Lane car park. • Enabling development will result in overdevelopment of poor quality housing with no amenity space, lack of infrastructure e.g. schooling. • Implications for street parking in north Kew, potential need to extend CPZ to all streets. • Proposals for providing adequate short-term parking not fully evidenced or proven. • Possible Rugby and entertainment uses will have significantly different impacts which should be addressed as part of the current application. • Negative impact on public transport: bus, tube and train (evening match supporters conflict with commuters) and road users generally. Lionel Road access to the M4 would be closed for some time on match days so exacerbating traffic congestion on the South Circular. 41. Kew Bridge Owners’ Association (4/7/2013) Objection • Density of occupation. • Impact of high rise tower blocks on landscape. • Impact on traffic flows is obvious with existing congestion. • Parking in the area which is already limited. • Transport issues exacerbated further by football matches and other events. • Facilities at this new location do not match the amenities available at Griffin Park. • Impact on the infrastructure generally; school places and medical facilities etc. 42. Kew Bridge Engines Trust (7/10/2013) Objection • Harm to setting of Steam Museum’s Grade 1 and 2 listed buildings due to massive high rise tower on the south side of the proposed development, which will overbear on the whole historic riverside setting. • Recommend significant reduction in height and massing on the south side of the proposed development, to minimise visual impact, and review stadium design to break up its current massing and allow a more transparent appearance. • Harm to operation of the Museum - with visitors or guests unable to reach the Museum because of match traffic, or because of overloading of and delays to public transport, including possible station closures, the future of the Museum will be jeopardised. • Should consult the Museum on arrangements and restrictions to be included in any agreement, to minimise the number of occasions on which the stadium is used, and should provide an endowment to the Museum under s106, to be held as a reserve fund to generate income to compensate for any loss of business incurred by the Museum as a result of the operation of the stadium. 43. Isleworth Society (22/10/2013) Objection • Harm to visual links to Kew, and built and natural local environment of Thames.

58 • Exceeds density of London Plan. • Will compromise the quality of life of existing residents. • No affordable housing. • No provision for health, schooling, infrastructure facilities. • Does not meet housing needs for family accommodation. • Will exacerbate existing road traffic gridlock in the vicinity. • Minimal improvements to Kew Bridge station. • Compromise the orientation of the stadium/pitch to permit over-dense accommodation. • Only modest employment opportunities off-set by loss of existing employment. • No community benefits over and above those already carried out by the Club. • Inadequate amenity space for residents. • Inadequate parking arrangements for the stadium. • Inadequate proposals for crowd management. 44. London Parks and Gardens Trust (1/8/13) Objection • High buildings in corners of the site would intrude unacceptably into and from the Royal Botanic Gardens and Kew Green and will have a detrimental effect on the character, appearance and setting of the grade 1 registered landscape, Kew conservation area and World Heritage Site. • Need to consider effect on the character, appearance and setting of Gunnersbury Park, which is a conservation area and grade II* listed garden of special historic interest, and of the Strand on the Green conservation area, especially as seen from the Kew bank of the Thames, and the Thames Landscape Strategy. In all those considerations the scheme will be damaging or very damaging. • Proposals are an excessive over-development and contrary to national and local planning policy, and any perceived benefits do not outweigh the concomitant damage to the historic environment, which is of metropolitan, national and international significant. • Should refuse consent for the proposals, which need to be re-considered from first principles rather than simply re-submitted with a storey or two removed. 45. Thames Landscape Strategy (2/7/13) Neither • Ask that particular attention be paid to TLS local and strategic guidance including requirements that: • ‘New development and initiatives within the Strategy area should be judged against the paramount aim of conserving and enhancing the unique character of the Thames Landscape as defined by the Strategy’. • Enhance the river as the central feature in the landscape, conserving its bends, islands and open spaces to define the distinct communities along its banks and promoting the water and towpaths as a linear link between the separate villages. • Conserve and where appropriate re-instate the exceptional network of visual connections which has evolved over the last four centuries. • Identify, conserve and reveal the main landmarks of the area, with particular concern for the frame and backdrop to the view. Where appropriate new development should contribute fresh landmarks and foci to work with the existing urban pattern. • Local Guidance (Thames Landscape Strategy Review 2012) • Conserve the industrial character and scale of the Grand Union Canal and

59 • Brentford Waterfront, contrasting with the thick trees of the aits and the Royal Botanic Gardens • Protect the visual links between: * Kew Palace and the Grand Union Canal entrance * Kew towpath and St George’s Church *Kew towpath and the Steam Museum tower * Kew /Syon Reach and St George’s Church • To carefully consider the effects of scale and bulk of regeneration schemes to avoid visual intrusion into the massing of Brentford Waterfront. Prevent any further flat roofed, high rise buildings from intruding into the Brentford waterfront massing. 46. West Chiswick & Gunnersbury Society Objection (15/7/13) • Do not object to the principle of BFC building a new stadium with some enabling development. • However cannot justify inflicting irreversible and significant harm on the built and natural environment and compromising the quality of life of existing residential communities and of those who might live in the new development, nor overriding national, regional and local planning policy. • Would have severe adverse impacts on the amenity of local residential communities and cause significant harm to the setting of heritage assets of local, national and international importance which would outweigh any benefits arising from the scheme, contrary to local, regional and national planning policies that all emphasise the importance of responding to local character and history and of protecting heritage and natural features. • Stadium would have a dominant and negative visual impact on the surrounding area; the large south stand especially would appear alien and out of character with the historic townscape. • Addition of intrusive impact of floodlighting on both the occupants of the proposed residential development as well as the wider community, the. Large the local townscape character and would impact negatively on the surrounding historic parklands in terms of their natural assets and biodiversity. • Proposed enabling residential development is totally out of character with the surrounding area in terms of scale, height, massing and density, harming the setting of the River Thames and its associated heritage landscapes and buildings, to the World Heritage Site at the Royal Botanic Gardens Kew and to the historic residential townscapes, listed buildings, Gunnersbury Park and Conservation Areas, including a hugely detrimental impact on the visual amenity and quality of life of residents living within the Wellesley Road Conservation Area. • The night time appearance of these tall buildings would impact on all the surrounding area, compounded by lighting of the stadium and floodlighting during matches. • Adjacent 4-storey school would be engulfed and dwarfed by the residential blocks of the Central Southern site and of the Capital Court site. • Loss of daylight would be an additional negative impact on the school and on some of the properties in Green Dragon Lane. The ES indicates that of the 318 windows assessed, 50% showed an adverse effect, including 18% for which the impact was

60 medium and 18% high. • Will Local Area Management Plan to control pedestrian routes and access to local stations by football supporters ensure that Wellesley Road, Stile Hall Gardens, other residential streets and the riverside walkways are not subjected to disturbance from large crowds? • How will the impact on residents and businesses of queues outside Gunnersbury station be mitigated? • Has the impact on users of the Brentford Leisure Centre been considered? • How would other users of train services (residents including those of any new development and people visiting Kew Gardens, the Steam Museum and other local attractions) enter or leave the key stations at peak football supporter times? • Kew Bridge Station has excessive difference in height between the eastbound platform and the train doors which is particularly problematic for elderly and dis abled passengers. Presumably no step free access will be available to or from the westbound platform. • Gunnersbury Station has severe access/capacity/safety problems with the present situation resulting in residents having severe difficulty or being unable to access the platform at times during the morning peak. • What will happen as fans arrive for an evening match as workers at the Chiswick Business Park are travelling home? • Gunnersbury Station and Chiswick Park has no disabled access • Local bus services and stops are likely to require improvement to cope with additional demand on match days and during major events. • The residential development would add to the existing pressure on rail services and highlight the inadequacies of local stations • Local bus services and stops are likely to require improvement to cope with additional demand from the residential development. • Serious concerns about the extra stress on the local highway network resulting from both the stadium (match-day traffic) a hotel and a residential development. Chiswick Roundabout and the Kew Bridge junction are already severely congested at peak times and at weekends, with long queues on the approach roads. The inability of the network to cope results in delayed journeys for local and through traffic. Moreover it contributes significantly to poor air quality and high noise levels. • Closure of Lionel Road South to through traffic in order to provide pedestrians with the widest possible area of public realm would be welcomed. • Existing residential streets within the vicinity exhibit a high level of parking stress, especially Wellesley Road, Clarence Road and Stile Hall Gardens. • Future occupants would suffer in terms of visual amenity, daylight, sunlight, privacy, overlooking, wind effects and noise and air pollution with very limited private or communal spaces of the residential buildings would set up a conflict between football supporters and residents and would provide neither with an appropriate sense of place. • Serious open/play space deficit would be detrimental to the health and well-being of residents and would compound the existing deficit in the area. • Match-day noise and that from other events (such as concerts) would impact negatively

61 on existing communities, attractions and on the residents of the new apartments. • Sensitive controls are needed on the level of amplified noise and live or amplified music audible in both new and existing residential properties. • A much larger capacity stadium with the expectation of attracting much larger numbers of spectators, including increased numbers of away-fans who do not necessarily share the ethos of Brentford supporters. • The development does not provide affordable housing or housing suitable for families or for the elderly. High levels of private, rented, 1- or 2- bed apartments tend to result in more transient populations and loss of community cohesion. • The residential development will add significantly to the recognized, existing lack of appropriate infrastructure in terms of education, health, cultural and community facilities • .suggestion that it should be excused from providing any financial contribution to remedy these serious infrastructure deficits on grounds of viability of its scheme and the wider community benefits it provides is totally unacceptable. • The entire scheme if far removed from the “vibrant and mixed-use community hub” envisaged in the BAAP. • The overall burden adds up to a massive cumulative negative impact on the surrounding area and its communities compounded by the impact of other developments under construction or with consent in the area • Business case is based heavily on some very questionable assumptions, request that they start with a smaller capacity stadium (say 15,000) designed with the potential to expand. • If build a stadium but no screening residential development there is a danger of empty and un-landscaped plots providing a poor setting for a stadium. • High rise, high density residential development without a functioning stadium and no community benefits if the Club goes bust or is not able to deliver/meet conditions relating to operating the stadium is a risk. • Pressure for even higher rise, higher density residential development than in outline permission on central sites (if Club fails to secure additional sites or seeks future increase in enabling receipts). • Even worse traffic and parking problems if Club fails to negotiate parking in private business car parks on A4. • The response also includes lists if suggested conditions and planning obligations if approved 31/10/13 – A further response adding concerns as follows: • Dispute the claimed benefits owing to lack of affordable housing, limited employment creation, minimal additional work by the BFC Community Sports Trust. • Too many single aspect flats. • Flats are likely to be bought for investment. • High-rise development is unresponsive to local needs and is likely to weaken Stadium will harm the supporters experience owing to the design of the development. • The current community and supporter benefits and the future of Club itself could be

62 placed in jeopardy by the risks associated with the current business plan. • Benefits associated with the new stadium are completely outweighed by the severe and lasting negative impacts that the currently proposed hybrid scheme would inflict. • Further concerns about the adequacy of Gunnersbury Station, pedestrian impacts and parking. 47. Thornton-Mayfield Residents Association Objection (28/10/13) • Proposal is totally out of proportion to the surroundings and is completely out of place. • It will be an aesthetic disaster and destroy the view from Kew Bridge • No infrastructure which will be able to cope with this mega-building on this spot • The roads all around the area, and backing up into Chiswick, will be paralysed by the traffic for this venue. • This will overspill and destroy the unique character of the area, and of Chiswick • This is not the right location for such a venue. 48. Cunnane Town Planning on behalf of Objection Temeraire Places Residents Management Company Ltd (4/7/13) • Inadequate justification for the non provision of affordable housing or s106 contributions are proposed, wholly contrary to Planning Obligations SPD, unlike other recent development in the area which has made financial contributions to affordable housing, education, health facilities, amenity space, play space, public realm and transport improvements. • Unreasonable to emphasise Mayoral CIL payment of over £1m as this must be paid by all development in London and has no local benefit. • Stadium is for professional sports with a limited amount of accommodation for occasional use for community benefits and is no different to other stadiums developed in recent years without residential development. • If the club’s wish to redevelop the site is only financially viable if delivered with no or much reduced financial contributions for mitigation then it is not the correct site for a professional sports stadium. • Whilst in planning terms there is no such thing as precedent, if Hounslow were to approve the application it would undermine the Council’s credibility, harming future negotiations with any developers. • Community benefits justification would fall woefully short of the lack of financial contributions for infrastructure and public realm improvements normally expected (e.g. for health facilities). • No objection in principle to the site being redeveloped for a stadium, providing planning benefits commensurate to the scale of the proposals are provided given existing public transport and traffic network is heavily used and congested, for which the cumulative impacts would be severe so the application should be refused. • The tower blocks will have a severely detrimental impact on residential units of Temeraire Place in terms of loss of light reaching habitable rooms and adversely affecting balconies. • Increased noise and disturbance from the new stadium and associated enabling development, from use of Kew Bridge station (platform adjacent), will cause significant

63 and unacceptable harm to residential properties. • The enabling development in terms of scale, massing, form and density, is entirely out of keeping with the character and appearance of its surroundings, which include several conservation areas. • Although appreciate the club’s desire to relocate it cannot be allowed to overrule relevant, local, regional and national planning policies. 49. Green Dragon Lane Housing Cooperative Objection (30/6/13) • Overshadowing from large, high-rise housing. • Overlooking from flats. • Cumulative impact noting other developments nearby. • Object to size and height of development. 50. Rapleys Town Planning Consultancy on Objection behalf of LaSalle Investment Management owners of No. 27 Great West Road (5/7/13) • No. 27 GWR is a 7-storey office building • Does not object in principle to redevelopment of the site but raises concerns about unacceptable impacts • No consultation of owner prior to the application being submitted. • Density of 360 u/ha is well above maximum threshold of London Plan. • Overdevelopment of site with overly dense, tall buildings, detrimental to character of the area including from key views and heritage assets, including views from River Thames, Kew Gardens WHS, Grade I/II listed buildings at Kew Pumping Station and the nearby Grade II* Registered Gunnersbury Park and Garden. • Detrimental impact on daylight and sunlight to occupiers of offices and does not assess Average Daylight Factor (ADF) impact • Detrimental impact on the amenity and outlook of current and future occupiers owing to the bulk and scale of the buildings and lack of detail to the stadium elevations. • Floodlights could impact on occupiers of the building through additional glare and lightspill.

7.21 Chiswick Area Forum – 19 November 2013

Cllr Oulds (Chair): • Explained the Forum had no decision to make, but that the item was on the agenda to allow Councillors and members of the public to express their views.

Councillor Thompson: • Had asked for the item to be considered by the forum because of significant impact on residents of Chiswick. • Applauded benefits which BFC Community Sports Trust brought to the borough. • However many elements of significant concern. • Design of the development, the enabling residential blocks, lack of affordable housing, lack of parking, and visual impact of the development on key sites. • Also significant concern about the impact on local transport which was very busy.

64 • An additional 910 residential flats, as well as a hotel, and sports fans, would overburden an already stretched system. • Wanted councillors and residents to use the forum to express their views.

Councillor Lynch: • Asked about changes to the size and shape of the enabling development and whether this had affected viability.

Councillor Lee: • Opposed to this scheme from the start, five or more years ago. • Transport infrastructure insufficient to serve the development, and proposed management of stations by stewards made it intolerable, as stations were for the use of local community. • Noise impact on matchdays would be significant, and unacceptable, in, for example, Stile Hall Gardens. Noted he could hear faint noise from Griffin Park at home in Princes Ave • Overdevelopment, and would have a huge impact on Chiswick, not just visually, but also in terms of schools, health services, buses, and the like. • No consultation held in Chiswick Town Hall, and only the efforts of Councillor Oulds, and Mary Macleod MP, had given residents of Chiswick the chance to air their views. • Brentford got all of the benefits of this scheme, whilst residents of Chiswick, especially those living in Gunnersbury and Strand on the Green, shouldered the burden. • Far more could be done, for example providing more trains from Kew Bridge station, if Brentford FC were genuine about their desire to improve the local area. • Hoped that the Planning Committee would reject the application.

Councillor Todd: • Asked whether 910 new flats were needed to make the scheme viable. • Sought more information on affordable housing • Asked whether the stadium would be used for rugby games.

Councillor Hearn: • Wished Brentford FC well; however was concerned about the development. • Lack of affordable housing would be damaging to the local community. • Enabling development would impact significantly on Chiswick, and wondered whether the enabling development would be granted permission without the stadium.

Councillor Davies: • Asked whether there was a guarantee that the stadium would be used only for sporting events and not rock concerts. • Asked what guarantee there would be that the flats would not simply be sold to foreign investors who would not live in them. • Concerned that no-one would buy properties to live in without a parking space. • Asked what lobbying of TfL Brentford FC had done.

• Other comments in opposition were made by the West Chiswick and Gunnersbury Society and the Strand on the Green Association, and by a member

65 of the public regarding the stable block, whilst there were also comment made in support from a member of the public.

8.0 POLICY

8.1 Determining applications for full or outline planning permission 8.2 When determining applications for planning permission, the authority is required to have regard to (a) the development plan, so far as is material, (b) any local finance considerations, so far as is material, and (c) to any other material considerations. Local finance considerations means the Community Infrastructure Levy, or a grant or other financial assistance that has been, or will or could be, provided to a relevant authority (such as the Council, the Mayor of London, the Homes and Communities Agency, etc.) by a Minister of the Crown.

8.3 In addition, the determination must be made in accordance with the development plan unless material considerations indicate otherwise.

8.4 The National Planning Policy Framework 8.5 The National Planning Policy Framework (NPPF) came into force on 27 March 2012 and has replaced national policies and guidance formerly contained in Planning Policy Statements and Planning Policy Guidance notes and some other documents. The Local Planning Authority (LPA) considers that, where pertinent, the NPPF is a material consideration and as such, it will be taken into account in decision-making as appropriate.

8.6 The Development Plan 8.7 The Development Plan for the Borough comprises the Council's Unitary Development Plan (other than those policies that are wholly inconsistent with the National Planning Policy Framework), Employment Development Plan Document, Brentford Area Action Plan and the London Plan 2011 and Revised Early Minor Alterations to the London Plan 2013.

8.8 The emerging Local Plan 8.9 On the 4th June 2013 the Council's Cabinet approved that the “Policy Options for Local Plan" should go out to consultation and this was carried out in June and July 2013. Subsequently the “Revised Site Allocations for the Local Plan” went for consultation in October. As emerging policy, the Local Planning Authority (LPA) considers that the emerging Local Plan is capable of being a material consideration. Given that the emerging Local Plan is still in the consultation stages (most recent October 2013) the LPA considers that in general limited weight can be given to it at this stage.

8.10 Determining applications for conservation area consent 8.11 In considering whether to grant planning permission with respect to any buildings or other land in a conservation area, special attention shall be paid to the desirability of preserving or enhancing the character or appearance of the conservation area.

8.12 Determining applications in respect of listed buildings

66 8.13 In considering whether to grant planning permission for development which affects a listed building or its setting, the authority shall have special regard to the desirability of preserving the building or its setting or any features of special architectural or historic interest which it possesses.

8.14 Development Plan policies and other guidance – see Appendix 3.

9.0 ASSSESSMENT

9.1 The application is a major development, which is the subject of an Environmental Impact Assessment and is also a departure from the Development Plan owing to the existing designation of part of the site (Duffy site) in the Unitary Development Plan (UDP) for a proposed waste management use. Arguably other elements of the scheme could also be considered as departures as the housing is provided in tall buildings that harm some sensitive views, including from conservation areas, contrary to polices of the UDP and London Plan (LP). Although these townscape issues may be addressed through conditions and obligations and the design mitigation proposed in the application documents, where there is residual harm this would be considered contrary to the Development Plan. The adopted Brentford Area Action Plan (BAAP) includes objectives supporting the relocation of the club to the application site.

9.2 Members should note that their decision must take into account the environmental information submitted with the application, and that departures from the policies of the Development Plan should normally be refused, unless there are other material considerations that would justify an exception.

9.3 The key planning issues are considered to be as follows:

A. Regeneration and the principle of the proposed uses

1. Regeneration of the area (i) Regeneration and sustainable development (ii) Loss of existing uses and employment (iii) Proposed uses (iv) Employment and economic activity

2. Football stadium (i) Need (ii) Location (iii) Alternative locations

3. New Housing (i) Enabling development (ii) Suitability of the site for housing (iii) Housing need and amount

4. Commercial and Hotel Uses (i) Size and location

5. Conclusion

B. Housing Quality

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1. Unit Design and Layout (i) Mix (ii) Access and servicing (iii) Unit sizes (iv) Daylight and outlook (v) Privacy

2. Open Space (i) Private and communal amenity space (ii) Children’s play space

3. Conclusion

C. Affordable housing

1. Viability appraisal

2. Conclusion

D. Urban Design and Impacts on the Townscape

1. Design context

(i) Urban design (ii) Design and Access Statement and Design Code (iii) Methodology

2. Design assessment and impacts

(i) The stadium (ii) The public realm (iii) The housing (iv) Impacts on the character of the site itself (v) Impacts on the character of surrounding areas (vi) World Heritage Site (vii) Mitigation

3. Conclusion

E. Archaeology and other heritage

1. Archaeological investigation

2. Non-designated heritage

(i) Listing (ii) Retention (iii) Relocation (iv) Reuse

3. Conclusion

F. Stadium Operation and Impacts

1. Matchday Use

(i) Safety

68 (ii) Access (iii) Noise (iv) Crime and anti-social behaviour

2. Stadium Management Plan

3. Non-match days

4. Conclusion

G. Traffic and Parking

1. Transport Assessment

2. Match days

(i) Pedestrians (ii) Rail (iii) Buses (iv) Cycling (v) Coaches and taxis (vi) Parking and traffic impacts (vii) Cumulative impacts

3. Match day mitigation

4. Conclusion (match days)

5. Non-match days

(i) Non-residential uses (ii) Housing (iii) Parking, traffic and transport impacts

6. Non-match day mitigation

(i) Travel Plan (ii) CPZ (iii) Conclusion

7. Construction impacts

8. Conclusion

H. Impacts on Neighbours

(i) Outlook and privacy (ii) Daylight and sunlight (iii) Noise and other disturbance (iv) Conclusion

I. Other Environmental Matters

(i) Air quality (ii) Contamination (iii) Flooding (iv) Noise and vibration (v) Ecology

69 (vi) Conclusion

J. Community Benefit

1. Cultural and Social Value

2. Community Benefit

(i) Aims and objectives (ii) Brentford FC Community Sports Trust (iii) BFC objectives and enhanced community benefits (iv) Current and proposed provision (v) Value (vi) Securing the benefits

3. Conclusion

K. Sustainability

1. Sustainable Design

2. Sustainability Assessment

3. Conclusion

L. Equalities and Accessibility

1. Equalities

2 Accessibility

3 Conclusion

A. Regeneration and the principle of the proposed uses

1. Regeneration of the area

(i) Regeneration and sustainable development

9.4 The National Planning Policy Framework (NPPF) emphasises three elements to sustainable development: economic, social and environmental, with new development to make a positive contribution to each.

9.5 The Unitary Development Plan (UDP) seeks sustainable development and regeneration to meet the primary objectives of the plan which include:

IMP.1: To encourage a pattern of land use and provision of transport which minimises harm to the environment and reduces the need to travel, especially by car, whilst maximising development opportunities in the Borough. This will be achieved by encouraging the reuse of existing buildings and previously developed land as a first priority, consistent with the principles of sustainable development whilst maintaining environmental quality and providing opportunity and equity for all. IMP.3: To promote area regeneration, particularly in areas of the Borough which require physical improvement, and the enhancement of the quality of life, housing and employment opportunities for local people.

70 IMP.4: To attract new economic development, encourage economic diversity, and direct it to appropriate areas. Concentrating development and promoting competitiveness in regeneration, whilst stimulating economic activity and improving the environment, within the capacity of labour availability, transport and the environment. IMP.5: To promote a good quality of natural and built environment specifically in relation to high quality of building and urban design, the improvement of the Green Belt, and enhancing the riverside environment of the Thames. IMP.6: To encourage the provision of appropriate planning obligations in association with new development. IMP.7: To have regard to the relationship of UDP policies, proposals and objectives with other London Boroughs, adjoining districts and counties.

9.6 This site is an area of Brentford that historically accommodated commercial and industrial activity on the Great West Road and near the Thames, but is continuing to undergo substantial transformation, with major redevelopment schemes comprising housing and commercial uses completed or underway. It has been identified for regeneration in a number of iterations of the Borough’s Local Plan over time and it is a major site for future redevelopment in the Borough.

9.7 Although the main aim of the scheme is to develop a new football stadium which would help secure the presence of BFC in the Borough, the overall mixed-use scheme creates an opportunity to reuse previously developed land to secure wider economic, social and environmental benefits through providing employment and economic activity, new housing, and improvements to the public realm and character of the area with enhanced links to surrounding areas, including recreational and cultural features such as Gunnersbury Park, the Thames, Kew Bridge Steam Museum, the Musical Museum and the Royal Botanic Gardens. It would also provide accommodation for community uses associated with the club.

9.8 The quality of the townscape here is much lower than some of the attractive, historic residential areas nearby such as Strand on the Green and Kew Green, and the site detracts from the local environment owing to its main use for waste transfer which is unsightly and generates heavy lorry traffic. Being bound by railways and severed from other areas to the north by the elevated M4, it is relatively isolated and lacks good connections to its surrounds. Lionel Road is a hostile pedestrian route, with a narrow footpath and high enclosing fencing creating a poor public realm. Nearby Kew Bridge station building, long in poor condition, has recently been refurbished externally though it remains disused, whilst its adjoining shopping parade has vacant shops and a rundown appearance. Further afield the shopping parade on Chiswick High Road opposite Capital Interchange Way suffers from limited footfall and heavy traffic and lacks vibrancy. New development would provide an opportunity to enhance the townscape and its links to adjoining areas.

9.9 The process of regeneration in Brentford is assisted by the Brentford Area Action Plan (BAAP), which provides a spatial strategy and detailed policies and proposals for the area and includes designation of development sites. The BAAP emphasises the importance of quality urban design and sustainable development, as well as the pressures on community infrastructure from increased development in the area, and

71 makes reference to the importance of the Royal Botanic Gardens World Heritage Site at Kew and the Thames Landscape Strategy.

9.10 The BAAP (and UDP) designate the Duffy site for ‘Waste Management’. The draft Local Plan (2013), which will replace the UDP/ BAAP, but is not adopted yet, and so has limited statutory weight, identifies the site for a mixed use development including a football stadium, with it to form a significant part of the future housing land supply for the Borough.

9.11 The BAAP recognises the existing role that BFC has in the community identifying it as a large scale community and leisure facility that has the potential to make a significant contribution to local area regeneration, creating opportunities for people to share a sense of pride in where they live, as well as delivering initiatives that support community cohesion and facilitate greater social inclusion.

9.12 The BAAP states that the role of BFC within the community is highly valued and supported by the Council as its continued operation in the area and the prospect of enhancing their activities through relocation to Lionel Road. Objectives of the BAAP (3 and 9) provide support for the principle of a new stadium and community hub at the application site and the club’s plan to develop a community stadium hub linking a range of sports, health, education, leisure and business support facilities. London Plan (LP) policy 4.6 provides support for the continued success of professional sporting enterprises and the cultural, social and economic benefits that they offer to residents, workers and visitors.

9.13 Therefore the proposed mixed use development is a significant opportunity for economic, social and environmental improvements that can help achieve the broad goals of sustainable development and also help in the wider regeneration of the area but any scheme needs to given satisfactory account to the environment including built heritage, the natural landscape, neighbouring residents and infrastructure.

(ii) Loss of existing uses and employment

9.14 There is a range of existing uses on the site, which has been used historically for noisy and unsightly industrial type activities such as waste transfer, storage, skip hire, vehicle repairs and engineering. Offices are located on Capital Court site. Consideration needs to be given to the loss of these existing uses and employment.

9.15 Waste facility – The Duffy Site is designated in the UDP for ‘waste management’. Policy ENV-P.2.3 of the UDP says the Council will seek to protect waste management facilities and sites identified on the proposals map.

9.16 This site is not used for waste management as it is a builder’s yard, plant hire and office. However as its current UDP designation is for Waste Management, redevelopment of that part of the site with housing is a departure from the current Development Plan. Further, LP policy 5.17 requires London boroughs to make adequate provision for waste processing capacity and says when preparing plans they must allocate sufficient land for waste management. The policy also says where an existing waste management facility is lost a compensatory site will be required. The supporting text of the BAAP also says that compensatory provision will be made

72 for the existing waste management facilities on the site in accordance with LP policies, though as noted there is no such use at the site.

9.17 A separate part of the site is used for waste transfer, with a large area of the stadium site used by Quattro, with construction waste delivered to the site for sorting before being transferred elsewhere. This use is classified as ‘waste transfer’ and is distinct from a ‘waste management’ site which is a site for the disposal, recycling, composting or recovery of waste.

9.18 With no existing waste management facility to be lost; the key issue in considering the acceptability of the departure from the UDP is the loss of the part of the site designated for a proposed waste management use, whilst the impacts of the proposed uses detailed elsewhere in this report are also material considerations.

9.19 Officers consider the proposed redevelopment of the Duffy Site is acceptable in the context of its role in funding the stadium and the wider regeneration scheme as the site is not used for waste management and its designation has not been carried forward in the draft Local Plan (2013), albeit this only carries limited weight as the plan is not adopted. The waste transfer operations on the Quattro site are not protected and the operator also has another site (Park Royal) that may accommodate the displaced use. Inclusion of this site is integral to the regenerative benefits of the scheme, as it would complement public realm improvements and enhancement of the character of Lionel Road.

9.20 In any event the Duffy Site was not identified as an existing waste management site in the draft West London Waste Plan (2011) which includes Hounslow, and neither it nor the Quattro site were considered as appropriate and suitable for such a use. Although this plan is a draft and is not adopted, it provides useful information about waste management sites in West London. The draft plan identifies that 22.4 hectares of land is required to develop waste management capacity by 2026. In order to meet this land allocation, eight existing waste transfer sites (accounting for 19.4 hectares) have been identified as suitable and available for reorientation into waste management sites. An additional 8.2 hectares was identified as potentially deliverable from new sites in West London with the application site not being one of these. The draft plan estimates that within West London there is 27.6 hectares of land potentially available for waste treatment, which exceeds the land allocation required to meet the LP. The Council’s recent draft Local Plan (October 2013) also identifies a site at Western International Market (Cranford) in the revised sites allocation as the possible location of a waste facility. Therefore taking this into account, the redevelopment of the site would not adversely affect the capacity for waste management in the region.

9.21 Offices – The application site includes a 1980s office block on Capital Interchange Way. There are also smaller areas of office space ancillary to other primary uses on the site. Policy EP4 of the Employment Development Plan Document (EDPD) relates to change of use of an office outside of town centres and key office locations. It says a change of use is acceptable if:

A. the existing use of the site for offices is detrimental to amenity of the surrounding area, OR

73 B. evidence is provided of the active marketing of the site for offices for a period of at least one year; AND C. the proposed use is compatible with the amenity of the surrounding area.

9.22 The existing office use has no adverse impacts on the amenity of the surrounding area as it adjoins other commercial premises and a secondary school. Therefore part B of the policy applies. The main offices are part vacant (only 25% leased, though occupancy is lower and the building will soon be vacant as leases end) and despite marketing, no demand has been identified, either from new tenants or purchasers of the premises as an office investment. The club’s owners have been negotiating the purchase of the office building site for the last 12 months to incorporate into the development with the sale presently nearing completion. A similar marketing process was undertaken for an adjoining office building, which was marketed without success for a number of years before being granted permission to change to a private school in 2013.

9.23 Therefore the loss of offices is satisfactory owing to the lack of demand for offices at the location, whilst the replacement uses (residential and commercial) are compatible with surrounding uses (school, car showroom, leisure centre).

9.24 Other employment – Other parts of the site, including the Duffy site and the Central site have a range of industrial and commercial uses. The Duffy site would not be developed in the early phases of the scheme, however the occupier has indicated that viable alternative sites would be available for relocation (and relocation would be necessary in any event if the current UDP designation of the site for waste management were fulfilled). Other existing employment on the central site is small scale and none of the site is designated in either the LP as a Strategic Industrial Location or in the BAAP as a Locally Significant Industrial Site.

9.25 LP policy 4.4 and EDPD policy EP8 relate to loss of industrial land, allowing the managed release of surplus land in order to meet strategic and local planning objectives. Policy EP8 says a change of use from industrial, warehousing and related uses on a site not identified as a Preferred Industrial Location, Industrial Business Park or Local Significant Industrial Site will be acceptable subject to the following criteria:

A. The existing use of the site for industrial/ warehousing uses is detrimental to the amenity of the surrounding area; OR B. evidence is provided of the active marketing of the site for industrial and warehousing uses for a period of at least one year; the site does not contribute significantly to industrial supply and economic diversity, either individually or cumulatively; and surrounding industrial sites are not undermined for industrial uses.

9.26 The policy goes on to state that housing, education and/or community uses will be considered as alternative uses, provided the above criteria are met.

9.27 Loss of the industrial use of the site is acceptable as the existing use of the main site for waste transfer is unsightly and generates lorry traffic that is detrimental to the amenity of the area, and which conflicts with the improvements being made to the local environment where derelict and surplus industrial land is being regenerated. It

74 is also noted that the land had no special designation with the land not a significant part of the Borough’s industrial reserve, whilst the mixed use scheme will provide substantial employment at the site. An obligation requiring endeavours to assist existing businesses to relocate is recommended.

(iii) Proposed uses

9.28 The proposed mixed-used scheme would provide a football stadium, housing and commercial uses. In principle these uses are consistent with the three elements of sustainable development with them capable of making a significant contribution to the economy, social life and environment of the local area.

9.29 In accordance with paragraph 69 of the NPPF the stadium would play an important role in facilitating social interaction and with its associated sports activity work with children would help create a healthy, inclusive community. The mix of uses proposed is consistent with paragraph 70 of the NPPF, which says that to deliver the social, recreational and cultural facilities and services the community needs, planning policies and decisions should:

• plan positively for the provision and use of shared space, community facilities (local shops, meeting places, sports venues, public houses) and other local services to enhance the sustainability of communities and residential environments; • ensure an integrated approach to considering the location of housing, economic uses and community facilities and services.

9.30 Paragraph 73 of the NPPF says opportunities for sport and recreation can make an important contribution to the health and well-being of communities. LP policies 3.16 and 3.19 provide support for enhancement of sports and recreation facilities, as these are important parts of the social infrastructure, providing a range of social and health benefits for communities. Policy 4.6 of the LP gives support for the continued success of professional sporting enterprises and the cultural, social and economic benefits that they offer to residents, workers and visitors.

9.31 New housing on other parts of the site is proposed to help fund the stadium. More detailed consideration of the housing and its role in funding the stadium is discussed below but in terms of land use, residential development would be acceptable if the housing quality was satisfactory.

9.32 The commercial uses proposed are ancillary to the stadium and housing, enhancing the viability and sustainability of both by concentrating supporting activity and providing opportunity for local services for residents, which adds to the regeneration benefits of the scheme.

(iv) Employment and economic activity

9.33 One of the core planning principles of the NPPF is to proactively drive and support sustainable economic development to deliver the homes, business and industrial units, infrastructure and thriving local places that the country needs. The NNPF also states that significant weight should be placed on the need to support economic growth through the planning system.

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9.34 Redevelopment of the site, which is brownfield industrial land with low-intensity industrial uses, with a mixed use scheme of over 910 homes, a football stadium, hotel and commercial uses provides a major opportunity to enhance economic activity and employment for both the construction and operational phases of the development.

9.35 The construction phase is expected to provide the equivalent of 200 full time jobs annually for the duration of the 10 year construction programme as well as investment of over £200 million for construction costs alone. If approved, obligations to secure construction training and job brokerage to enhance skills and opportunities for local people would be recommended. Additional employment gains from construction procurement and spending has been calculated at 75 full time jobs during the construction phase.

9.36 Once complete the stadium and commercial uses would provide a substantial increase in employment for the area, with this creating new economic activity which also has a multiplier effect that adds further to growth and employment prospects. West London Business and the Hounslow and Brentford Chambers of Commerce support the proposal. Redevelopment of Griffin Park would also create construction activity, new housing and increase the population of that area adding to economic activity, minimising any effects from displacement of crowds to the new ground, though the latter is around 900m from the current ground so some supporters may choose to maintain existing pre-match activities such as use of pubs and shops.

9.37 The existing businesses on the application site and BFC’s Griffin Park and the Community Sports Trust provide employment for 444 people (142 Full Time and 302 Part Time). The proposed scheme would increase this to 720 people (190 FT and 520 PT). In addition the new business plan facilitated by the development includes an aim to raise the number of BFC employees off site (training ground at Osterley and academy) by 15 FT and 37 PT jobs, whilst the stadium floor area when fully fitted out has the potential to eventually provide for another 130 FT jobs.

9.38 The football stadium, with its 20,000 capacity and much enhanced hospitality facilities creates opportunities for increased spectator spending and procurement of goods and services by the football club and interaction between businesses using corporate hospitality all of which would add to economic activity. Football related spending by supporters has been shown to be at a ratio of 37% in stadium and 63% out of stadium in local pubs, cafes etc. The current estimated spend of spectators visiting the existing ground is over £2.7m through spending at local pubs, restaurants, shops and transport, with this economic activity set to expand with the likely increase in attendances to £4.29m (based on 9,350 supporters), and help create 6 FT equivalent (FTE) jobs. Such activity would be likely to assist in improving the vitality and viability of nearby shopping parades on Kew Bridge Road and Chiswick High Road, thereby bringing wider regeneration benefits.

9.39 Additionally, the new housing would eventually accommodate an estimated 2,410 residents, with their estimated total spend being £17.23m a year, of which £11.28m is expected to remain in the Borough, creating an additional 141 FTE jobs. Cumulatively the development would therefore create nearly 200 new full time jobs

76 (48 from the site, and 147 from additional spectator and residents spending) which is a major positive impact for economic activity and employment in the Borough.

2. Football stadium

(i) Need

9.40 BFC states the need for a new stadium is driven by the inadequacies of their existing stadium, with the proposed stadium key to the club’s aim to be more financially sustainable and eventually more successful. Its financial statements demonstrate continued losses, whilst the existing ground at Griffin Park provides extremely limited scope for expansion or improvement of facilities to increase revenue, pressuring the financial sustainability of the club and ultimately its survival.

9.41 These pressures are familiar issues for professional football clubs, where replacement of old, outdated grounds with poor facilities and prospects for improvement have led to many new stadiums being built in the last decade as competition and costs have intensified and spectator expectations risen.

9.42 Griffin Park has been the club’s home ground since 1904 and it is closely surrounded by terrace housing which prohibits substantial and worthwhile extension. The club lists Griffin Park’s deficiencies as follows:

• Virtually no accommodation for match day hospitality, for individuals and corporate entertainment; • Inadequate and poor toilet and concourse facilities; • An ability to accommodate only 1,800 away fans; • A lack of attractive facilities and space for non-match day activities; • Inadequate club and ground management accommodation; and • Inadequate facilities to accommodate the Club’s community activities, including the BFC Community Sports Trust.

9.43 The existing stadium is in poor condition, lacking modern facilities, with very limited hospitality areas. Access and facilities for disabled spectators is also poor. When combined these factors would detract from the matchday experience with the stadium comparing badly with other contemporary leisure and recreation facilities including other football stadiums of larger teams in London, limiting opportunities to attract new supporters and retain existing ones. It also has poorer public transport links compared to the application site.

9.44 Despite having crowds close to the average for League One, turnover for BFC is significantly below the average with it being £3.7m compared to the League One average which is around 50% higher at £5.5m, reflecting the lack of non match-day income and the poor facilities at Griffin Park. The proposed stadium would give opportunities to ensure greater financial security through generating additional income from sponsorship, commercial activity, sale of premium seats, corporate hospitality and enhanced catering facilities, as well as potentially increased attendances. A new stadium cannot guarantee either financial or sporting success, but the continued existence of the football club is currently reliant on funding from its present owner and such an arrangement not sustainable financially in the long run.

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9.45 Additionally, footballing authorities have introduced regulations to ensure fairer competition and avoid insolvencies that may lead to loss of clubs, with penalties for clubs that are not financially prudent, leading to a need to maximise both match-day and non-match day revenue in order to reduce both losses and reliance upon debt.

9.46 A new stadium would also provide a home and enhance the capacity and quality of the community work carried out by the club and the associated BFC Community Sports Trust, the latter of which is presently unable to be accommodated at Griffin Park owing to its limited facilities.

9.47 In respect of the proposed 20,000 capacity, the applicant submitted a Business Plan that analyses League One and Championship attendances, and impacts from new stadiums on attendances to justify the increase in capacity of 7,700. This is important as the average attendance at Griffin Park is well below 20,000, being only 6,317 in 2012/13, though the applicant notes that last season it twice sold out the ground, took 23,000 supporters to a Wembley final, and the average from 1 January to the end of the season was 7,260 indicating greater underlying support.

9.48 The capacity of Griffin Park is 12,300 but this includes terracing for standing. Significantly current regulations require all clubs that are promoted to the Championship to convert to all-seater stadia within three years. If BFC were promoted to the Championship as is their aim, it would need to become seating only, reducing the capacity to 11,000. Such promotion is a realistic prospect as the club lost in a play-off final for promotion at the end of last season.

9.49 The average stadium capacity in League One is currently 14,700 and in the Championship it is 27,660. The average attendance in the Championship last season (2012/13) was 17,558 1. If BFC were to achieve promotion to the Championship, its current ground would be third smallest in the current Championship, ahead of only newly promoted Yeovil (9,000) and Bournemouth (10,700). Apart from the other promoted team, Doncaster (15,231), the next smallest grounds are Blackpool (17,338) and Watford (17,477) (both all seating), which would mean a 20,000 seat stadium is at the lower end of the capacity range for the division of 24 teams.

9.50 The improved facilities and matchday experience offered by a new stadium would be likely to see increased attendances. The Business Plan notes uplift in football attendances from new stadiums as detailed in the following table that shows increases in attendances in the first year following opening of a new stadium (excluding teams promoted or relegated in first season after opening).

Club Year Opened % Increase Leicester 2002 47% Hull 2002 77% Manchester City 2003 35% Swansea 2005 67%

1 Football League.

78 Arsenal 2006 57% Milton Keynes 2007 57% Cardiff 2009 15% Chesterfield 2010 76% Table 5: Effect of new stadiums on attendance

9.51 On average there is a 55% increase in attendance, which if replicated at Brentford would increase the average BFC attendance to over 9,700, with any promotion very likely to increase this further noting the average attendance for matches in the Championship is 17,558 as there are larger teams with more travelling fans. The club’s longer term business model aims for it to reach the Championship division. Its plans show that an attendance average of 15,000 would significantly reduce operating losses, and 20,000 would mean a small profit, compared to the current unsustainable losses of around £5m per year.

9.52 In addition to having better facilities and opportunities to generate match-day income, sustained spectator growth would depend on sporting success to which a more financially sustainable club would be better placed to achieve. It is reasonable to consider some scope for growth on attendances that may come with success. Without a new ground the club will continue to struggle to match its competitors and attract new spectators noting its lower turnover and poor quality facilities respectively, though longer term success will be significant in meeting the objectives of the Business Plan as a new ground alone would not sustain this in the long term.

9.53 Provision of a smaller stadium with later expansion was considered and the phased provision of parts of stands to reduce initial capacity could help viability through reducing early construction costs. However permission for a lower capacity stadium would not adequately meet the projected needs of the club, in particular its aim to be financially sustainable. Further, costs of future construction, physical logistical difficulties in construction noting the site constraints and the need for funds from development on all housing sites even for a 15,000 seat stadium (and therefore bridging of the railway), as well as potential disruption for new residents of the housing blocks, would realistically limit the feasibility of a later extension.

9.54 Therefore in principle the 20,000 seat stadium proposed is considered a reasonable size and although ambitious, not overly so, given the characteristics of attendances for teams in the Championship and League One and the uplift in attendances observed with new stadia. The proposed capacity falls below the average stadium capacity of all clubs from both divisions (which is 21,180) and would accommodate the average Championship crowd of 17,558 with a modest buffer for larger crowds that may arise for more important games. The stadium would significantly enhance the facilities available to spectators, which is likely to attract substantially more supporters as the increase in crowds accompanying other new stadia shows, whilst there should be some allowance for the club’s realistic prospects for greater financial sustainability and growth associated with potential sporting success. Detailed assessment of the impacts from the stadium and whether these are acceptable follows further in the report.

79 (ii) Location

9.55 As noted above in paragraph 9.12 the BAAP supports the principle of the relocation of the football club to Lionel Road, with Objective 3 including an aim to support BFC’s plan to develop a Community Stadium hub linking a range of sports, health, education, leisure and business support facilities within the ‘Brentford Diamond’) and Objective 9 stating:

“The Council will continue to work in partnership with Brentford Football Club to explore the possibilities of delivering an exemplary sustainable sports stadium and community hub, supported by a variety of mixed uses in the East of Brentford, on a site now known as ‘The Brentford Diamond”.

9.56 The planning permission for redevelopment of the club’s existing home ground for residential use includes a planning obligation that says the permission cannot be implemented until arrangements are in place for the construction of a new stadium in the Borough or the London Boroughs of Ealing, Hammersmith and Fulham, or Richmond. At present this obligation allows Griffin Park to be redeveloped as long as contracts for construction of a new stadium within two years are in place. This could potentially see BFC play elsewhere for two years and although the club has indicated it has no plans to do this, it is recommended Members require this this legal deed is varied to tighten the provision to ensure that development at Griffin Park cannot commence until the club has relocated to Lionel Road.

(iii) Alternative locations

9.57 The NPPF, policy 4.6 of the LP and policy C.5.1A of the UDP all require a sequential approach to be taken to the development of new stadia with objectives being to location such facilities in the most accessible locations. LP policy 4.6 supports new sports facilities where they are located on sites with good public transport, are accessible to all including disabled and older people, and where they address deficiencies in facilities and provide a cultural focus to foster more sustainable communities.

9.58 UDP policy C.5.1A has criteria to be taken into account when considering applications for large scale, all seater stadia as listed below. Further assessment of how the application meets the criteria is discussed in detail throughout the report, however the site has been selected in the BAAP as the location for BFC’s new stadium and its siting accords with the Development Plan. This selection followed appraisal of alternative sites in the region, with its accessibility to public transport an important factor.

9.59 There are considerable constraints in finding a suitable location for a stadium in Brentford given it is an urban area with land being relatively expensive compared to other regions, with very few sites capable of accommodating a stadium in West London let alone the Borough, and even fewer having no policy protection, for example for office or industrial development. Possible sites in other parts of the Borough or neighbouring boroughs are also constrained by being outside built up areas such as on Green Belt or Metropolitan Open Land, where public transport is also poorer.

80 9.60 Possible sites previously considered have included Osterley Park, Gunnersbury Park, Feltham Arenas, Western International Market (Cranford) and land in Bedfont, Hanworth and Hounslow West. Details of past investigations of alternatives are described in the Environmental Statement (ES). However none of these sites are preferable to Lionel Road owing to factors including:

• Green Belt/ Metropolitan Open Land/ Local Open Space designation • Poor access public transport • Unacceptable displacement of existing uses

9.61 Weight should also be given to the retention of the club in Brentford as this is where it was established and has maintained its home and heritage, providing an important element to the cultural history and identity of the area for over 120 years, as referred to in many submissions in support.

9.62 In general terms the proposal has considered the criteria of policy C.5.1A of the UDP, as follows:

(i) the stadium is in a suitable location where the proposed activities and the large number of visitors would not conflict with the local environment, amenity and neighbouring uses ; 9.63 The site occupies commercial land that has been previously developed. It has direct access to a number of modes of public transport which will reduce impacts on the local area, with car parking being limited. Impacts from people travelling to other nearby public transport, particularly Kew Bridge and Gunnersbury Station, as well as possible limited closure of Lionel Road shortly before and after matches will potentially be disruptive albeit temporarily, and such impacts would be mitigated through a local management plan to minimise disruption. Otherwise the use would complement local service and recreational uses.

(ii) the site is highly accessible by public transport, other non-car modes and appropriate provision is made for coach parking; 9.64 The site has a medium to good PTAL (ranging from 3-4), which is higher than Griffin Park or the alternative stadium locations previously considered. It is next to Kew Bridge Station whilst bus and Underground transport is within walking distance. The site is close to the proposed route of a new Cycle Superhighway and 400 cycle parking spaces are proposed. Coach parking will be managed in Capital Interchange Way.

(iii) the impact of the proposed stadium on trip generation, highway safety and movement; 9.65 The Transport Assessment considers these impacts with the conclusion being that with appropriate management, the impacts would be tolerable.

(iv) the effect of the proposed stadium on residential amenity; 9.66 This is addressed in the ES, which considers Transport, Air Quality, Noise and Vibration, Microclimate and Socio-Economic impacts, but the impacts overall are minor with adverse impacts to be mitigated through design and conditions.

(v) the provision of safe, well-lit pedestrian access;

81 9.67 The scheme includes public realm improvements along Lionel Road, the main pedestrian access route to the stadium, whilst an audit of other routes indicates they are safe and adequately lit.

(vi) provision of appropriate access for people with impaired mobility;

9.68 The stadium and its facilities are fully accessible, and designed to meet Part M of the Building Regulations, and disabled car parking is provided. This would substantially improve accessibility compared to the club’s current ground.

(vii) high quality design to incorporate safe entry and exit for a large number of visitors, comfort, safety and public order; 9.69 The safety of spectators is integral to the design and it has been designed to achieve relevant safety standards for crowd movements, including emergencies. Various safety certificates and licences would need to be obtained under separate non- planning regulations prior to the stadium being used.

(viii) provision of appropriate on-site amenities for visitors; 9.70 This is a key objective of the new stadium, with it to provide much improved facilities for visitors through kiosks, bars, catering and hospitality areas as well as seating and toilets that meet contemporary standards.

(ix) assessment of the implications of any multiple use and non-sporting activities to the environment and community; and 9.71 As noted the full implications of possible dual use with rugby and other special events have not been assessed and therefore the stadium is for football use only. Non-matchday uses have been given consideration in the ES and the impacts from these are satisfactory. Other community uses and there benefits are discussed separately below.

(x) the use of high quality design and materials. 9.72 The stadium design is discussed in detail later, but overall its bespoke design would ensure it is distinctive and worthy of its prominent position and it would become a recognisable landmark in the area.

9.73 In conclusion the proposed stadium is justified at this location, given it would be likely to improve the club’s longer term financial position and its ability to compete, attract spectators, and links to local residents, providing enhanced facilities and accessibility for all in a location with good public transport links. The site is referred to in the BAAP as the site for a new stadium, with no preferable alternative sites available. Alternatives such as expansion of Griffin Park is not practical and doing nothing could threaten the long term survival of the club, whilst its retention in the Borough and Brentford is a major positive outcome given historic and cultural links with the local community. Therefore the principle of the new stadium is acceptable.

3. New Housing

(i) Enabling Development

82 9.74 In addition to the stadium, the scheme proposes up to 910 dwellings on surrounding land. This housing would help fund the construction of the stadium and associated works, and is labelled ‘enabling development’, as the delivery of the new stadium is enabled in part by the funds generated by the housing development which would otherwise not be viable. With the housing and stadium being at the same site, the two elements have a fundamental connection, and section 106 planning obligations and planning conditions would ensure the stadium is delivered prior to the housing.

9.75 Enabling development is referred to in the NPPF, but in the context of heritage items, as it is a term typically applied to development used to fund conservation and repair in the interest of heritage conservation. Broadly however it can be applied to other proposals and in this wider context it is essentially development that cross- subsidises another element of a scheme. Sometimes the ‘enabling development’ is contrary to planning policy, but is permitted because it brings public benefits which outweigh the harm that would be caused (for example housing to fund repair of a listed building). The applicant does not apply this term in this sense as they contend the development is acceptable in planning terms.

9.76 From its finances it is clear that BFC cannot fund the very significant up front capital cost of the stadium’s construction and related infrastructure. Therefore, alternative sources of capital must be found to fund the stadium. Obtaining necessary funds from the government or charities is not feasible given the estimated cost is of the stadium construction alone is over £71m. BFC’s current owner can through private wealth underwrite a proportion of the cost and has made very substantial investments in the proposal to date with this expected to reach £35m, which on the present expectations of viability would not be recovered from the development, hence the need for enabling housing development to help deliver the stadium. Such an arrangement is not unusual when considering new stadiums, with examples of new or extended stadiums being approved with enabling housing and commercial development being found throughout the country including for Chelsea, Arsenal and Tottenham football clubs.

9.77 The club’s detailed financial plans and the viability of the scheme are commercially sensitive and confidential. However BFC has made a less detailed Business Plan publically available and allowed its finances and the scheme’s viability to be independently assessed by a consultant property surveyor on behalf on the Council. This appraisal is on an ‘open book’ basis and this and other financial information from the club and its owner give details of the anticipated costs and revenues for the whole development to determine its viability. Such appraisals are based on best estimates, and represent a snapshot in time as costs and revenues will fluctuate with time and changes in the economy but the appraisal is considered to reflect realistic and reasonable assumptions.

9.78 The applicant’s viability assessment demonstrates how the sale of the proposed housing will enable the delivery of the stadium and also identifies the level of funding shortfall that may exist. Its key findings are that the scheme is only viable with the amount of housing proposed, and with no affordable housing and reduced s106 contributions.

83 9.79 An assessment by the Council’s consultant of financial information and the viability assessment confirms the significant cost of the scheme and that revenue from the sale housing would be necessary to help cover the funding shortfall. Additionally, the consultant confirms the viability assessment shows that the amount of housing proposed is necessary to fund delivery of the stadium, and that no affordable housing, and reduced s106 contributions are also necessary to make the scheme viable. Consideration has been given to the ability of the Council to capture any improvement in viability generated in the future through rising house prices etc. and obligations in this regard are recommended.

9.80 Notably, the earlier 2008 Barratt scheme, which included affordable housing, proposed much taller buildings than the current scheme in order to be viable. Members will need to consider the applicant’s assertion that inclusion of affordable housing would only be possible if the buildings were taller to provide more units, which has implications for the townscape.

9.81 The current scheme has no affordable housing owing to this reducing viability to a level that would affect the deliverability of the stadium. Nevertheless the housing is at a very high density, and has tall buildings, and the ES finds there are some adverse impacts on the townscape, including effects on conservation areas, which is a breach of planning policy. Ultimately these impacts can potentially be mitigated through careful design which would follow with reserved matters, but given its characteristics and noting the townscape concerns associated with the blocks, Members will need to consider that the amount of housing proposed is crucial to the delivery of the stadium and its benefits and weigh this up against any resultant harm and its degree.

9.82 In coming to such a judgement, the Council is entitled take the financial viability of the development into account as a material consideration. The financial dependency of part of a composite development on another part is relevant where this finances other planning benefits, which in this case the proposed housing would fund the stadium. Additionally, off-site benefits which are related to the development, such as the wider community benefits of the stadium and football club are material. However for all these considerations it is up to Members to determine what weight to give them. Townscape impacts and community benefits are considered in detail below.

9.83 Related to this issue are comments from some objectors that make reference to English Heritage guidance in respect of enabling development. This application does not involve heritage development so such guidance need not be followed, and each case must be considered on its own merits and particulars. Nevertheless it and previous planning decisions usefully set out a framework of factors to consider in decisions about enabling development applications and officers recommend Members consider these issues noting concerns about density, tall buildings and impacts on the townscape.

9.84 Key issues to consider raised by the objectors are:

(i) Is a new stadium is necessary? (ii) Is the enabling housing the only reasonable way of securing the stadium? (iii) Is housing the least harmful, financially viable way of funding stadium?

84 (iv) Is there certainty that the stadium will be delivered and is economically sustainable in the long term? (v) Do the public benefits secured through the enabling development decisively outweigh the disbenefits of breaching other planning policies?

9.85 Is a new stadium necessary?

9.86 The justification for the new stadium, including its 20,000 capacity is given above in paragraphs 9.40 to 9.55. The club currently loses around £5m per annum, with these losses being unsustainable. Doing nothing would ultimately put at risk the economic, social and community value of the club.

9.87 Is the enabling housing the only reasonable way of securing a new stadium?

9.88 BFC cannot fully fund the stadium itself, with the club making annual losses, whilst its owner cannot cover the whole cost he is providing very substantial investment in the project. Other sources of funding such as from government are not available for such projects. Other much larger football clubs such as Arsenal and Tottenham have taken the enabling development route whereby other uses have been approved alongside the stadium in order to help generate funding. The use of housing to help fund the stadium is the only feasible way identified that would generate funds to sufficiently contribute towards a new stadium and help secure the club’s future and the community benefits associated with it. No feasible alternatives have been suggested.

9.89 Is housing the least harmful, financially viable way of funding the stadium ?

9.90 The extent of the planning impacts, including harm, resulting from the proposed development is discussed in detail below. However, it is important to consider whether the housing is the only viable way of generating the necessary funds to enable a new stadium to be constructed. The proposed housing development is likely to have some adverse impacts on the townscape, and so other possibly less harmful uses should be ruled out before considering the planning merits of the proposal.

9.91 For this site, which is brownfield land surrounded by a mix of uses and with an awkward shape that after provision of a stadium does not lend itself to large industrial or commercial buildings, residential use would achieve the highest values (as proven by sales figures from nearby schemes). It also assists in the sustainable regeneration of the area through creating a mixed-use development. Other uses such as industrial, retail or offices, would not be feasible given the size of the land, would not achieve the same values, or would be inappropriate outside of a town centre at a scale that would provide any significant funding. Further, the demand for housing is such that the new housing units are likely to be sold unlike office development for which demand is more uncertain. Therefore housing is considered to be the most suitable, feasible and viable enabling development.

9.92 Is there certainty that the stadium will be delivered and is economically sustainable in the long term?

9.93 The planning permission would ensure that there would not be a situation where the residential units have been constructed but the stadium is not built. Obligations

85 secured by a legal deed would be recommended with restrictions on occupation of housing before the stadium and other necessary infrastructure such as the new bridge are completed. Further obligations in respect of delivery of community benefits and phasing of the development are also recommended. Therefore these restrictions would provide certainty that should the development be implemented the stadium would be delivered first, ensuring that there is no housing without the benefits of the stadium being secured, which should be the key concern regarding the enabling argument. BFC’s Business Plan shows that its provision would be likely to enhance the long term financial stability and prospects of the club through increasing revenue, and significantly reduce its operating losses, and if fully utilised achieve a position above break even, with this being one of the key factors for the plan for a new stadium.

9.94 More broadly as a development project itself, no guarantee can ever be given that a project will ever commence as the granting of planning permission does not oblige the scheme to be implemented. Further, no prospective scheme is risk free from future changes to the economy. In this instance the housing sites would be sold on with planning permission if it were granted, but developers have not signed contracts in this regard, although this prospect is moving closer, as are arrangements for compilation of the site. Detailed consideration has been given by the Council’s independent consultant to costs, funding and cashflow projections, as well as logistical issues involved in constructing the various phases of the development. Although negotiations in respect of land acquisition for the development site are still in progress, these have advanced positively. The Council’s independent consultant concludes that taking into account the viability assessment and information in respect of negotiations with landowners and potential delivery partners, there is a realistic prospect of this scheme coming forward, though there are risks noting existing land holdings and the sensitivity of the viability.

9.95 Do the public benefits secured through the enabling development decisively outweigh the disbenefits of breaching other planning policies?

9.96 The economic, environmental, and social impacts of the development are discussed in detail throughout the report, and there are major positive impacts in respect of community uses, public realm and transport improvements, provision of a new stadium, housing and business opportunities, and growth in employment and economic activity. Harmful impacts in respect of the townscape, transport and neighbours are largely able to be mitigated through conditions and planning obligations, though where there is residual harm, Members must make a balanced judgement of the overall benefits of the scheme that the housing would help fund.

(ii) Suitability of the site for housing

9.97 In considering the principle of housing on the site there are no concerns regarding loss of existing uses, but the new housing must also be appropriately located to ensure satisfactory living conditions for residents with account given to any environmental constraints. Additionally, although housing is satisfactory in principle, the need for housing and the amount proposed must be assessed.

9.98 Information submitted with the ES has considered environmental constraints that may affect the suitability of the site for housing. Possible constraints including

86 flooding, contamination of land from previous uses, poor air quality from traffic in the locality and noise and vibration from adjacent roads and railway lines, as well as from the use of the stadium itself. More detailed analysis of environmental considerations and impacts relating to the whole development are given separately in the report, but the ES concludes that subject to appropriate mitigation, there are no significant constraints that would preclude housing on the site.

(iii) Housing need and amount

9.99 Supply – The NPFF and the housing policies of the LP and UDP support new housing on previously developed sites such as this. Brentford is identified in the draft Hounslow Local Plan as one of two housing growth areas in the Borough.

9.100 In accordance with paragraph 47 of the NPPF, the Borough has a good supply of deliverable housing and presently exceeds its annual minimum housing target of 470 dwellings per year from the LP 2011. As of April 2013 the Borough meets its five year housing supply requirement (5 year target of 2,468 including a 5% buffer) as there are 4,025 dwellings deliverable, though this target is likely to be increased soon to approximately 822 dwellings per year following a review of the Greater London Authority’s Strategic Housing Land Availability Assessment in 2013. The revised housing targets are reflected in the current draft Local Plan that underwent consultation in October 2013 (“Revised Site Allocations for the Local Plan”).

9.101 Both Griffin Park and the application site are referred to in the draft Local Plan and are allocated for mixed uses with housing, and together they are expected to form a significant proportion of the Borough’s future housing delivery sites up to 2025. Given the scheduled increase in local housing targets, which are expected to be adopted with revisions to the London Plan in early 2014, the Council will be seeking to achieve a big increase in housing provision and to make efficient use of underused brownfield sites with better accessibility such as this.

9.102 These housing targets are not maximums and local authorities are encouraged to exceed them subject to adequate infrastructure being available and impacts being acceptable or adequately mitigated in order to provide greater housing choice and availability as demand is increasing with rising population growth and household formation in London. Notably the draft Local Plan estimates that the population of the Borough will increase by 12% over the next 20 years amounting to 30,000 new residents and an annual average increase of 1,749 households to 2021 indicating a significant need for additional housing which the scheme would help meet.

9.103 Density – LP policy 3.4 seeks to optimise housing potential, taking into account local context and character, the design principles set out elsewhere in the plan, and public transport capacity. Development should optimise housing output for different types of location within relevant density ranges. Proposals that compromise this policy should be resisted, but the density matrix should not be applied mechanistically as density is a fairly crude tool for measuring scale and massing.

9.104 The site is in an urban area and has a PTAL ranging from 3 at the northern end of the site to 4 from its midpoint south. This results in the density range varying from between 70-170 units per hectare (u/ha) for the area with a PTAL of 3 and 70-260 u/ha for the area with a PTAL of 4.

87

9.105 Calculating density for this mixed use scheme, which includes a large stadium, with a varied PTAL, in way that most accurately reflects the character of the development is difficult. Using LP guidance, which accounts for non-residential floor space in mixed use schemes, a proposed density of 296 u/ha, was calculated, with this a figure given in the GLA’s Stage 1 response. Using this measure the density is between 1.1 to 1.7 times the maximum of the LP density ranges.

9.106 However leaving out the stadium footprint as well as the football pitch area, as although the latter is a large area of open space, it is not publically accessible, and excluding the hotel site and Lionel Road itself, the density would be 379 u/ha, and officers consider this gives the true picture. Using this figure the proposed density is between 1.6 to 2.2 times the maximum LP density range, indicating the scheme is very high density.

9.107 Some objectors suggest the density should only consider the outline residential areas, giving a density of over 500 u/ha. However the LP states that residential density is to be based on net site area, which relates to the ‘red line’ planning application site boundary which includes the proposed homes, non-residential uses in mixed use buildings, ancillary uses, car and cycle parking areas, proposed internal access, proposed on-site open spaces (including publicly accessible spaces), and children’s play areas. This scheme, which is a hybrid application, is a single planning application that covers a range of development and falls across PTAL 3 and 4. The development also includes overlapping areas, with the Central East and Capital Court sites including stadium related space (car parking) and the Central Southern having an underpass. Officers consider it appropriate to include the new internal road (the bridge providing access to the Central East housing site) and the new public spaces created elsewhere including new public realm along Lionel Road and the concourse (which is a new east-west route open at all times).

9.108 What it is evident is that the proposed density, whether at 296 or 379 u/ha is much higher than the range of the LP and the density proposed is therefore more in keeping with a central setting deemed most appropriate in a town centre or central London. Given the tall buildings and number of dwellings proposed and the awkward shape of the housing sites, this is not a surprise.

9.109 Very high density does not always indicate poor design, though it can indicate overdevelopment. Traditionally high densities are found at centres of activity, focused on transport nodes, and points of convergence. High densities can sometimes have benefits such as encouraging greater interaction between residents, enhancement of the economic viability, support for public transport use, energy efficiency, and reducing overall demand for development land and urban sprawl. Successful higher density also depends on a range of factors including location, management, occupancy and tenure.

9.110 Conversely high densities can make provision of good quality housing difficult, creating issues such as overshadowing, lack of privacy, noise and servicing issues, as well as putting pressure on local services. Additionally, high densities often result in tall buildings that can be seen from wide areas, affecting the townscape, which is

88 highly relevant for this scheme given the nearby conservation areas, Listed Buildings and World Heritage Area.

9.111 For this application the high density proposed is fundamental to the financial viability of the scheme and ultimately the delivery of the new stadium and its associated community benefits. Nevertheless such a high density scheme must still provide good liveability having regard to dwelling mix and quality, with satisfactory access to services, long term management of communal areas.

9.112 When considering the proposed density and local context and character, the large area of the site and its nature, which is largely self-contained and not adjacent to other dense areas and which has good public transport links, should be acknowledged, as it provides some opportunity for flexibility to create its own character that may differ from the surrounds. However this opportunity needs to be balanced against the sensitivity of surrounding areas where the impacts in terms of massing, scale and character on views are important considerations.

9.113 Ultimately a qualitative assessment must be made on these issues and it would be expected that new development has satisfactory impacts on local environmental conditions and that minimum standards from the Mayor’s Supplementary Planning Guidance for Housing (Housing SPG) are met. Where such tests are failed or there is some environmental harm including to townscape views, Members may consider the enabling argument in respect of the amount of housing proposed and whether the benefits of the wider scheme outweigh that harm.

4. Commercial and Hotel Uses

(i) Size and location

9.114 The scheme includes a 160 room hotel, a retail shop for the club, hospitality areas and kiosks, and up to 1,200sqm of commercial floor space (the latter proposed within ground floors of the residential blocks). The club shop and commercial space associated with the stadium would be integral to the stadium use, for which the acceptability of the principle has been established above. The other commercial floor space (which may be used for A1, A2, A3, A4, A5, D1 or D2 uses) is intended to be ancillary to the housing in order to provide a comprehensive mixed use scheme that provides adequate local shops and services for residents and activity to the site.

9.115 Paragraph 24 of the NPPF requires application of a sequential test to planning applications for main town centre uses such as hotels and retail units not in an existing centre, as is the case for this site. This sequential approach requires applications for main town centre uses to be located in centres, then in edge of centre locations and only if suitable sites are not available should out of centre sites be considered. When considering edge of centre and out of centre proposals, preference should be given to accessible sites that are well connected to the town centre.

9.116 Additionally where such development is 2,500sqm in floor area the NPPF requires an impact assessment to consider impacts on existing centres.

89 9.117 This site is outside of a town centre and the hotel floor and cumulative commercial floor space both exceed 2,500sqm and each therefore a sequential test and impact assessment in respect of them being located outside a town centre is required.

9.118 The sequential approach from the NPPF is also applied by LP policies 4.5 and 4.7. The LP recognises the need for additional visitor accommodation and says it may be appropriate to locate visitor accommodation outside preferred areas where it is related to major visitor attraction of sub-regional or greater significance but only where it can be shown that no suitable site on other locations existing and that there is a clear link in scale, nature and location (particularly demonstrating sufficient proximity to minimise overall need to travel and maximise walking and cycling) between the accommodation and the attraction.

9.119 Similarly policy EP10 of the Council’s EDPD relating to new visitor accommodation and conference facilities seeks to direct such to town centres in the first instance, followed by edge of centre locations. Otherwise, the policy advises that it will need to be demonstrated that there are no sites available in the town centres, followed by edge of centre locations, and that the site is accessible by sustainable modes of transport.

9.120 A sequential test and impact assessment of the proposed uses was submitted with the application. In respect of the hotel it demonstrates that there are no available, sequentially preferable hotel sites and that the impact of such a development will be acceptable with there being demand for more hotel accommodation in this area of Brentford.

9.121 Apart from the stadium, which would serve spectators and players, the hotel is also well located in respect of other national and regional visitor attractions such as Kew Gardens, Kew Place, Gunnersbury Park, Musical Museum, Kew Steam Museum, Chiswick House, Boston Manor House and the Thames are all within walking or cycling distance, whilst it has good public transport links to London from Kew Bridge Station, and is near major transport routes such as the M4/A4 and North Circular road. Inclusion of a hotel with conference facilities complements the main stadium use, ensuring activity on non-match days, which may only be once every 2 weeks during the football season.

9.122 Much of the commercial floor space proposed is within the stadium and is ancillary to its use. The 1,200sqm (600 sqm Central site, 300sqm Capital Court, and 300 sqm Duffy site) provided elsewhere in the scheme is below the 2,500sqm threshold and would provide for small businesses that complement the housing with it envisaged this would be cafes, local retail shops and the like. The sequential test and impact assessment for these uses also demonstrates the acceptability of the scheme, with there being no adverse impacts on nearby town centres as the non-stadium provision is local in scale, and will serve the increased demand from occupants of the new housing and not compete with existing centres, and who are expected to actually boost consumer expenditure in and activity at nearby centres.

5. Conclusion

90 9.123 The development is a prime opportunity for regeneration of an underutilised brownfield site, which would secure a major sporting facility and new housing for the Borough, with this having significant economic benefits during both construction and operation. The stadium is appropriately located and has a satisfactory size, which would assist in securing the long term financial security of BFC and consolidate and enhance its presence in the Borough.

9.124 It has the potential to create a significant number of new jobs and secure existing ones, despite the need for displacement and relocation of some smaller businesses. The scale of investment and size of the developments are such that there would be likely to be significant wider effects to the surrounding area leading to a potential catalyst for further regeneration, whilst the specific commercial uses would not harm the vitality and viability of other commercial uses in Brentford or other centres. The proposed housing, which is high density, is key to the viability of the development and the delivery of the stadium, with the viability assessment also confirming justification for the proposal’s lack of affordable housing and suggestion of reduced s106 contributions. Further consideration of the impacts of the housing and stadium on the environment is given below.

B. Housing Quality

9.125 A core planning principle of the NPPF is to seek to secure high quality design and a good standard of amenity for all existing and future occupants of land and buildings. The government also seeks to ensure delivery of a wide choice of high quality homes.

9.126 LP policy 3.5 says the design of all new housing developments should enhance the quality of local places. The associated Housing Supplementary Planning Guidance (SPG) (2012) has minimum standards that set a baseline for quality and design that new homes should aim to meet including for particular needs for older people, children, amenity space and Lifetime Homes and wheelchair housing as well as in relation to the liveability and operation of the site, and interaction with surrounding development. The guidance also provides ‘good practice’ standards that are likely to lead to exemplary design. The standards must be read in relation to other strategic objectives of the LP with there being a need to give consideration to viability and the need to ensure an appropriate level of housing supply alongside the effects design has on the living conditions of occupants. The standards are consistent with the aims of the Council’s own older guidelines (UDP policy H.4.1 and UDP SPG) for form and design, daylight and sunlight, privacy and spacing between buildings, private amenity space, roads, parking and noise.

9.127 As the proposed housing is in outline, with full design details to follow with reserved matters if the application was approved, the details of proposed units are illustrative only. However, to ensure good quality design and that minimum standards can be met, the applicant has provided indicative floor plans for units in each block to demonstrate key standards can be met in a future design within the parameters proposed. The Housing SPG states that extent to which proposed developments depart from this baseline should be taken into account in planning decisions. Those which depart significantly, either in terms of failure to meet with a number of baseline

91 standards or the extent of failure to meet particular baseline standards, are unlikely to be acceptable.

9.128 If approved, specific design principles and minimum standards would be secured through conditions and the Design Code, which would inform future reserved matters applications. A fully detailed design is likely to be able to secure many ‘good practice’ standards but in the absence of a detailed scheme it is important to ensure minimum housing standards are secured through ensuring maximum compliance with key Housing SPG baseline standards.

1. Unit Design and Layout

(i) Mix

9.129 LP policy 3.8 says development proposals should aim to meet local needs by providing an adequate mix of dwelling sizes and mix of tenures to reflect local and strategic demand, with all dwellings to meet Lifetime Homes standards.

9.130 The Council’s strategic housing objectives given in the draft Local Plan (Policy SC3 Housing mix) seeks a Borough wide preferred housing mix of 30% one-bed, 40% two-bed, and 40% three-bed dwellings. The proposed housing is in units, and being an outline scheme an illustrative mix has been submitted, with this showing 40% one-bed, 40% two-bed and 20% three-bed units. This mix is predominantly for smaller units, which differs from the preferred mix, but is appropriate in this instance given the high density and lower car parking provision proposed, though there is still a good number (up to 182) of larger family sized units.

9.131 The units would meet Lifetime Home standards and are all private tenure as no affordable housing is proposed (see discussion below). The site has no immediate residential neighbours but in the wider area there are large numbers of social housing units nearby to the west, whilst housing to the south and east is largely private and high value, meaning the development would in broader terms sit within socially mixed community.

(ii) Access and servicing

9.132 High density unit design should carefully consider internal access and circulation arrangements to the housing blocks and within building cores, with an aim of ensuring they are accessible to all and that internal building corridors are safe and well managed. The illustrative material shows approaches and access to each building and all units would be able to be fully accessible meeting Lifetime Homes and Part M of Building Regulations requirements (disabled access) and the baseline standards of the Housing SPG.

9.133 The illustrative material also shows that all buildings would meet the baseline standards for shared circulation spaces, with their design meeting the minimum circulation dimensions, having audio-visual verification control systems for entrances, and adequate numbers of lifts and wheelchair access to all buildings. The lowest floor of the residential units would be accessed from street level as well as ramps and stairs owing to variation in the ground levels of the site. Taxi drop off areas are

92 illustrated for the blocks whilst secure cycle storage and refuse and recycling areas would be able to be provided within secure basement areas and forecourts.

(iii) Unit sizes

9.134 The illustrative floor plans show all units would meet the minimum internal floor area baseline standard for each unit type from the Housing SPG, with the plans demonstrating that the units would satisfactorily accommodate furniture, access, circulation, storage, working from home and activity space requirements.

(iv) Daylight and outlook

9.135 In addition to adequate floor areas, units should have good quality outlook and natural light, ideally being dual aspect, as this can provide better daylight and sunlight, cross-ventilation, mitigation of air and noise pollution, and offer a choice of views and more flexible use of rooms. The Housing SPG recommends that where possible the provision of dual aspect dwellings should be maximised and that visual and acoustic privacy should be provided.

9.136 The proposed scheme, which has awkwardly shaped plots, a high density, and tall blocks of flats with central cores for access inevitably includes some north facing units.

9.137 The Housing SPG has a baseline standard for dual aspect housing, stating “Developments should avoid single aspect dwellings that are north facing, exposed to noise levels above which significant adverse effects on health and quality of life occur, or contain three or more bedrooms”.

9.138 There are no detailed floor plans as the scheme is outline. The illustrative scheme shows that 55% of the units, for the typical floors (2 nd floor) are likely to be single aspect and that overall 7% of the total number of units are predominantly north facing and single aspect. All of these north facing single aspect units would be one- bedroom, and an illustrative floor plan has been produced to mitigate against the north aspect with the inclusion of bay windows or glazing to two directions as shown in the image below. This would maximise daylight to rooms.

93

Image 5: Illustrative floor plan for single aspect north facing unit

9.139 Having regard to the baseline standard, no two and three-bed units would be single aspect north facing, and mitigation for noise pollution is provided for all units. The illustrative layout has sought to minimise the number of north facing single aspect units through specifying zones for building cores and arranging layouts to limit their number, but as noted even with this considered design, 7% of the units would be single aspect and north facing. This is not ideal, though full compliance would be difficult to achieve given the high density and layout of the scheme. The Design Code includes criteria that would minimise the number of north facing single aspect to no more than 10% of all dwellings with these to be one-bedroom and to include the design features of the illustrative floor plan that would maximise light and outlook.

9.140 More generally the layout and illustrative floor plans show many flats would have outlooks towards open space to the north and the river to the south, or open views to the east and west. Some flats to lower levels would look towards adjacent railway lines or the stadium, though the railway lines are at a lower level as they run in cuttings. Many units would look in part towards other new buildings, which are tall and potentially dominant features, but although corners of some buildings are close,

94 the footprints of the blocks are offset from each other allowing the primary outlook from windows and balconies to be orientated towards spaces between blocks and to open aspects. The relatively self-contained nature of the site between railway lines means built development on neighbouring land is well spaced from the site opening up the outlook even for lower level units. At the northern end of the Central South site the corners of the building footprints are opposite each other at a minimum distance of 7.5m. In this section the layout has the potential to affect the outlook from units as they would be close to other buildings. To demonstrate satisfactory outlook is achievable the applicant has prepared illustrative floor plans that show where the units are opposite each other and within 21m, the primary outlook for each unit can be offset through use of inset balconies and careful window placement. Additionally, the footprints are at an angle and are none of the units in question are north facing single aspect units, with this allowing for some flexibility in window placement and design, ensuring they would still have a reasonable outlook and adequate daylight, though in a dense environment. The units of the Central South site closest to the stadium have triple aspects ensuring outlook would not be overbearing.

9.141 With this layout, plus use of quality finishes and materials, and careful window design and placement, it is considered that all units would be able to be designed with a satisfactory aspect that is not oppressive and that would receive adequate daylight.

(v) Privacy

9.142 The UDP SPG recommends a minimum distance of 21m between opposing windows of habitable rooms. The more recently adopted Housing SPG is more flexible than the UDP SPG with it recognising that older planning guidance for privacy sought to achieve visual separation between dwellings by setting minimum distances of between 18-21m between habitable rooms, with these distances being useful yardsticks for privacy. However it also says that adhering rigidly to these measures can limit the variety of urban space and housing types, and sometimes unnecessarily restrict density. The Housing SPG requires each dwelling to be provided with an adequate level of privacy in relation to neighbouring property, the street and other public spaces.

9.143 The proposed layout has buildings sited within 21m of each other. The footprints of some blocks are very close with some building envelopes (worst case) between 5 to 8.5m apart, but this is at corners where no windows would be designed with the layout being able to provide primary and secondary (flank) outlooks to units in these situations.

9.144 Overall the blocks are positioned in a manner that would enable windows and balconies to be placed so as to avoid undue overlooking, with the main outlook from windows in units being illustrated as facing open aspects or offset from other units. As noted already the blocks on the Capital Court site and in particular the northern end of the Central Southern site are more closely arranged than other sites and some units would suffer from reduced privacy even with dual aspect and windows offset as the closest blocks illustrated have windows just over 12m apart albeit at an angle, though this is a minority. The lowest level units to all blocks would also need screens and landscaping to ensure adequate privacy and security from adjoining communal open space. The lowest level units are also positioned at least one-storey

95 above the adjoining concourse areas for the stadium, providing security and privacy from crowds when events are held.

9.145 The Design Code guides future solutions to this issue through detailing illustrative unit locations and window and balcony zones. Careful design will be required towards the ends of buildings and where units adjoin each other, and in some instances inset balconies and window treatments (such as angled or high level windows) may be required. However as with daylight and outlook, the proposed layout of the blocks and shape of their footprints creates opportunities to offset windows and balconies between units where they are closer than 18-21m apart. Overall it is considered an adequate level of privacy between units will be possible, though for some units this will be more akin to city living which, reflects the density of the scheme.

2. Open Space

9.146 Being a large residential scheme the proposal should consider open space and landscaping strategically to consider the full range of possible provision, including outdoor sport and play facilities, local parks and other public spaces in accordance with LP policy 3.7. The Housing SPG recognises that provision of public, communal and open spaces also makes a key contribution to residents’ quality of life, and there is a particular need to take account of the requirements of children, older and disabled people. It has baseline standards for private and communal amenity space and further recommendations are made in the SPG on Providing for Children and Young People’s Informal Recreation. The Council’s UDP SPG has older numerical standards, which have been superseded by the LP, but still has qualitative guidance with amenity areas to be secure, accessible, have good sunlight and of a size and shape that makes them functional for both passive and active recreation as appropriate.

9.147 The maximum parameters show the footprint of buildings and along with the illustrative drawings, these indicate that open space would be provided in the form of communal amenity space between the blocks on each housing site as well as new public realm from the stadium concourse and a public park adjacent to Lionel Road.

(i) Private and communal amenity space

9.148 Amenity space in the form of private balconies to each unit and communal amenity space for the housing blocks is proposed. The illustrative material shows that private balconies could be provided to all units to meet the minimum Housing SPG baseline standard of 5sqm for 1-2 person dwellings and an extra 1sqm for each additional occupant, with the scheme to provide a minimum of 5,224 sqm of private amenity space from balconies, with provision in accordance with the baseline standard to be secured by condition. The Housing SPG says enclosing the balconies as glazed winter gardens is considered an acceptable alternative to open balconies and recommends this for dwellings with high noise exposure to high noise. This may be option for the detailed design of some units, but a noise assessment undertaken concludes this would not be strictly necessary given matchday noise is irregular and temporary in duration.

96 9.149 There is also communal open space areas for the units, with these sited at the same level of the lowest residential floors for all blocks, with level access provided to all spaces. For the illustrated unit mix proposed, the UDP SPG 1997 recommends a total of 23,480sqm of amenity space, though as noted earlier the more recent LP (2011) sets a minimum standard which is lower.

9.150 The layout shows that the space available for communal amenity areas has a total area of 5,595sqm. When combined with the private balconies, the total amenity space provision exceeds 10,000sqm. This meets the LP requirements for the development and would provide satisfactory amenity space for residents.

(ii) Children’s play space

9.151 LP policy 3.6 seeks to ensure that all children and young people have safe access to good quality amenity space. The Mayor’s Shaping Neighbourhoods: Play and Informal Recreation SPG gives guidance recommends a minimum of 10sqm of play space for each child that is likely reside in the development.

9.152 The Play SPG says larger developments should incorporate play space on site, however if there is existing provision within an acceptable distance of a proposed development, financial contributions toward off-site play space as an alternative to new provision may be considered, though play space for under-fives must be on-site. The guidance states that the play space for older children must be within reasonable and safe walking distance of new housing, with it recommended that the maximum walking distance for 5 to 11 year olds is 400m, and for the 12+children 800m.

9.153 The proposed development shows play space for under-fives and 5 to 11 year olds on site, with children aged 12+ able to use Gunnersbury Park. Five notional play areas for under 5’s are highlighted on the site within the communal amenity space areas. These play areas have a total area of 570sqm and meet the baseline standard for the child yield based on the illustrative unit mix. An area of 380sqm is shown for children aged 5-11 within the public park provided adjacent to the Duffy Site. Compliance with the baseline standards for children’s play space will be secured by condition. Older children (12+) would be able to use the communal amenity areas. The older children could also cross the A4 at traffic lights to reach Gunnersbury Park, which is 550m walk from the furthest units on the site. Plus children could make use of the new public realm throughout the site and proposed climbing wall. The Fountain Leisure centre which has a swimming pool and indoor courts is across the road from the Capital Court site. Additionally, Carville Park is also around 500m from the centre of the site, and the wider regeneration of the area will soon see new public spaces created on nearby sites which include a paved square and a landscaped park next to Kew Bridge (250m south) and the Steam Museum (400m west) respectively.

9.154 Therefore the development would be capable of making adequate provision for children’s play with older children to utilise off-site areas, with a detailed play strategy to be required by condition to be submitted with reserved matters applications for each development phase to ensure this is secured.

3. Conclusion

97 9.155 Subject to careful detailed design to follow with reserved matters, and adherence to design measures given in the Design Code, which would be secured by conditions, the proposal is capable of providing a good standard of residential accommodation that would meet key minimum baseline standards for housing quality as recommended in the Housing SPG, with these being consistent with the Council’s own guidelines. The supporting illustrative material shows that a scheme can be built within the maximum parameters that would see all dwellings meet the minimum size standards, have good access and security, an appropriate mix, meet Lifetime Homes requirements and in general have good outlook, privacy and access to light, as well as adequate provision of children’s play within an enhanced public realm.

9.156 There a some single aspect north facing units (7% of overall units), but where these cannot be avoided they will be limited to one-bedroom units and designed to maximise opportunities for light and outlook. Elsewhere the layout and maximum parameters, which include tall buildings at a high density, will create challenges for detailed design so as to ensure living standards with respect of privacy, natural light and outlook are satisfactory. Whilst the separation of buildings, spaces and the windows of habitable rooms may in some instance vary from the guidance of the UDP SPG and Appendix 1 of the UDP, officers are satisfied that with careful planning and mitigation, the resulting development, particularly in terms of building layouts and their juxtaposition, would provide satisfactory living conditions for future occupants in terms of privacy, outlook and daylight and open space.

C. Affordable housing

9.157 The NPPF and LP emphasise the importance of providing affordable housing and this is a priority for the local authority. Policy 3.13 of the LP requires developments of 10 or more dwellings to include affordable housing and this is a key objective of the Council.

9.158 The Council seeks the maximum proportion of affordable housing achievable on-site in accordance with the LP in order to contribute towards the Mayor's target of at least 13,200 more affordable homes per year in London over the term of the Plan. In Hounslow this equates to approximately 41% of all new housing provision whilst the Council has also committed to delivering 2,500 affordable homes to rent or buy by 2015, as set out in Pledge 3 of the Council’s Corporate Priorities. Within this is an objective to achieve 60% of the affordable housing provision for social rent and 40% for intermediate tenures.

1. Viability appraisal

9.159 Policy 3.12 of the LP states that in negotiating affordable housing in private schemes, boroughs should seek the maximum reasonable amount of affordable housing having regard to their affordable housing targets, the need to encourage rather than restrain residential development and the individual circumstances of the site. Targets should be applied flexibly, taking account of individual site costs, the availability of public subsidy, the implications of phased development including provision for re-appraisal and other scheme requirements.

9.160 The application proposes no affordable housing, with the applicant submitting that its provision would make the scheme unviable and would reduce the funding available

98 to subsidise the stadium, prohibiting its delivery. This lack of provision would be highly unusual given the strategic and local need for affordable housing, however in considering the individual circumstance of the site and application must be considered. In this regard the applicant’s viability assessment has been independently reviewed by a consultant on the Council’s behalf.

9.161 This review accepts that in the current circumstances no affordable housing is viable if the stadium is to be funded and delivered. However, the appraisal represents a snapshot in time and so the figures involved are subject to change. Therefore it is appropriate to require a viability to be reviewed during the various phases of the development. The applicant has agreed to a review mechanism and this would be included in a section 106 agreement where if viability increases to an agreed level then affordable housing contributions will be made.

2. Conclusion

9.162 Affordable housing would typically be expected for a scheme that includes the proposed number of dwellings, though this is not a typical development given the development costs include the football stadium. In this case it has been demonstrated through independent assessment that the current overall viability of the development cannot support affordable housing without adversely affecting the deliverability of the stadium. A review mechanism is recommended to ensure that should viability improve to an extent that affordable housing can be provided, that this is secured. Additionally it must be highlighted that the provision of the stadium is the key aim of the project and the housing would help fund it, Members should consider the lack of affordable housing against the strategic benefits of the stadium.

D. Urban Design and Impacts on the Townscape

1. Design context

(i) Urban design

9.163 The NPPF states good quality design is an integral part of sustainable development and that decision takers should always seek high quality design. It states that achieving good design is about creating places, buildings or spaces that work well for everyone, look good, will last well, and adapt for the needs of future generations, with good design responding in a practical and creative way to both the function and identity of a place, putting land, water, drainage, energy, community, economic, infrastructure and other such resources to the best possible use.

9.164 The NPPF also says permission should be refused for development of poor design that fails to take the opportunities available for improving the character and quality of an area and the way it functions. It is proper to seek to promote or reinforce local distinctiveness. However planning permission should not be refused for buildings and infrastructure that promote high levels of sustainability because of concern about incompatibility with an existing townscape, if mitigated by good design (unless the concern relates to a designated heritage asset and the impact would cause material harm to the asset or its setting which is not outweighed by the proposal’s economic, social and environmental benefits).

99 9.165 Policy ENV-B.1.1 of the UDP promotes high quality design that enhances the overall environmental quality and townscape. Section 9.0 of the UDP SPG has guidance for the design and layout of developments to enable them to be compatible with, and make a positive contribution to the locality. The BAAP also includes policies requiring high quality design and identifies character areas that assist design of developments. Policy BAAP2 Urban Design requires the high quality development of all proposal sites in order to enrich existing areas of distinctive local character, rejuvenate those areas that lack a positive identity and improve the overall quality of Brentford’s urban form.

9.166 The LP has similar policies. LP policy 7.1 says development should be designed so that the layout, tenure and uses interface with the surrounding land and improves people’s access to social and community infrastructure (including green spaces). New buildings and spaces should help reinforce or enhance the character, legibility, permeability and accessibility of the neighbourhood.

9.167 LP policy 7.4 says development should have regard to the pattern and grain of existing streets in orientation, scale, proportion and mass, and other policies including 7.5 and 7.6 also emphasise design quality and ensuring development relates well to its surrounds.

9.168 Both UDP policies ENV-B.1.2 and ENV-B.1.3, and the LP recognise that in sensitive areas, buildings which are much higher than their surrounds are generally inappropriate, with the objective being to limit harmful impacts on existing character from the scale, mass or bulk of a tall or large buildings.

9.169 The LP provides further guidance, with LP policy 7.7 on the location and design of tall and large buildings, recognising they can have detrimental impacts on local character, including over a wide area. It says that tall and large buildings should:

• generally be limited to sites in the Central Activity Zone, opportunity areas, areas of intensification or town centres with good access to public transport; • only be considered in areas whose character would not be affected adversely by the scale, mass or bulk of a tall or large building; • relate well to the form, proportion, composition, scale and character of surrounding buildings, urban grain and public realm, particularly at street level; • improve the legibility of an area, by emphasising a point of civic or visual significance where appropriate, and enhance the skyline and image of London; • incorporate the highest standards of architecture and materials, including sustainable design and construction practices; • have ground floor activities that provide a positive relationship to the surrounding streets; • contribute to improving the permeability of the site and wider area; • incorporate publicly accessible areas on upper floors, where appropriate; and • make a significant contribution to local regeneration.

9.170 And tall buildings should:

• not affect their surroundings adversely in terms of microclimate, wind turbulence,

100 overshadowing, noise, reflected glare, aviation, navigation and telecommunication interference; and • not adversely impact local strategic views.

9.171 This policy also recognises that the impact of tall buildings in sensitive locations such as conservation areas, the setting of listed buildings and World Heritage sites needs particular consideration, with there being further policies in both the UDP and LP in respect of development affecting these areas.

9.172 In principle, subject to detailed design of the building and impact of access on this area the Borough has supported the aspiration for the football club to stay in Brentford, and a new stadium to be sited at Lionel Road, for more than 10 years. Through site allocations in policy and land transfer the borough has actively assisted this move. The primary concern is therefore the impact of the tall and dense enabling development in this congested and visible site on its surroundings.

(ii) Design and Access Statement and Design Code

9.173 The applicant’s Design and Access Statement (D and A) provides information about the evolution of the design and the factors taken into consideration when preparing the scheme, which includes the above policies. These documents cover both the stadium and the other buildings.

9.174 The D and A identifies site constraints and opportunities and details how the scheme meets the development requirements and aims to maximise the quality of the design and minimise its negative impacts. Connections with the surrounding areas, transport and the context of the wider area are discussed. Both the stadium design and the housing blocks are the result of considerable analysis. The housing plots follow from the stadium itself, which has taken precedence in the layout. The housing analysis has balanced viability against massing and scale impacts, and has also been the subject of significant view testing to limit impacts on sensitive views from neighbouring conservation areas, listed buildings and the Royal Botanic Gardens World Heritage site in particular.

9.175 The nature of the development, which includes a large stadium set within a largely self-contained site, is unique in the Borough. The stadium has had to retain sufficient space to function, but has been squeezed to provide space for housing development, which also needed an enlargement of the original site area. The proposed amount of housing is driven by the viability of the development and this has led to the large numbers and a high density scheme to make the delivery of the stadium viable.

9.176 The stadium design is fully detailed with architectural drawings and elevations. The outline elements (housing and hotel) are described in maximum parameter drawings with their detailed architectural design not the subject of this application. Despite all matters for these buildings being reserved, outline details that identify building plots, key vehicular and pedestrian routes and building height and envelopes have been submitted to enable assessment and guide future reserved matters.

101 9.177 Supporting statements (D and A statement and Design Code) illustrate the likely scale and massing of the completed development, indicating the maximum extent and potential impact of the buildings, as well as setting out the design objectives and rules required to be addressed when the detailed design for each development plot comes forward. Given the sensitivity of some views towards the site, and noting the high density and tall buildings proposed, the Design Code is particularly important in ensuring exemplary design can be achieved and a high benchmark for architectural quality is set.

9.178 The housing massing, stadium with integral ancillary accommodation and the particular need of access to all of these have been sited to gain the best overall compromise for the restricted site itself, given the desired amount of funding accommodation.

(iii) Methodology

9.179 The ES assesses potential townscape impacts of the development against a standard methodology. The ES includes assessment from agreed viewpoints that were selected in consultation with officers, and Kew Gardens and English Heritage. The original assessment was supplemented by an additional view to address comments in respect of impacts on a particular view from Kew Gardens.

9.180 Verified views provided in AVRs (accurate visual representations) showing how the proposed development could look from different locations, accurately merging the scheme into photos of the townscape, have been submitted.

9.181 The ES considers the visual implications of the changes from these selected viewpoints, taking into account their sensitivity and the magnitude of impact, before concluding what the extent and significance of the impact is for both the construction and operation phases of the development.

9.182 The significance of effects on townscape character is derived from the interaction between the sensitivity of the townscape, and the nature of the change it is likely to experience as a result of the development. The sensitivity of a townscape reflects its value together with its ability to accommodate change without fundamentally affecting its character; or if so affected in what way. Townscape sensitivity is increased by the presence of designations such as conservation areas or listed buildings; by proximity to open spaces or water bodies (which create viewing opportunities); and where built form is predominantly low-rise. Sensitivity tends to decrease as urban density and/or building heights increase, since viewing opportunities are reduced and the townscape becomes more robust to change.

9.183 Officers concur that all important views have been considered and the methodology followed is correct, though it must be noted that such representations are static and the way the development would be perceived will vary as one moves around the site, and conclusions on impacts are subjective. It is also noted that the illustrative images from the AVRs give a representation and are not the final design. The applicant acknowledges the outline elements and comments that the assessment of impacts is therefore limited to the location and mass of buildings. Experience shows that high quality design and appropriate choice of materials are likely to reduce impacts on townscape character and visual amenity. The applicant contends that residential

102 towers on the Central South Site could provide a visual landmark from Kew Bridge and the south bank of the River Thames. Additionally, the use of lighter materials such as glazing as shown to upper levels in the images can underestimate the impact should a more solid massing be used, even if this may be less contextual, so officers have noted this when undertaking the assessment.

9.184 The impacts of the proposal on the townscape, taking into account the findings from the ES are described in detail in following sections. In summary there are some views from where there will be significant impacts on the townscape, and some of these will be ‘major adverse’ in their magnitude compared to the existing situation. This is the case for both construction and operational impacts, though the former will be temporary (albeit for some years). Where harm is found this is to be addressed through detailed, quality design but such mitigation is not likely to fully address all harmful impacts from height and bulk. Where this is the case Members will need to consider whether these are offset or outweighed by other beneficial aspects of the whole development, in particular the creation of a new townscape comprising provision of a new stadium with its associated community benefits and a significant amount of residential accommodation also related to the viability of the development.

2. Design assessment and impacts

(i) The stadium

9.185 The stadium itself is a very large structure, the equivalent of between four to seven domestic- storeys in height. It will be a long-roofed building seen from north and south, with angular roof elements at the sides and entry corners, enclosing the stands. Ancillary accommodation is contained within the overall mass and influences the appearance and silhouette. It will lie at the heart of a cluster of tall buildings and these, together with floodlighting and glimpse views of the stadium will be very visible, particularly from the elevated M4. Policies in the BAAP support redevelopment of the site for a stadium, which even on its own would be a significant building, and so current Development Plan policy envisages a large building on the site. The design of the stadium also involves its function, use and character.

9.186 The surrounding residential buildings and hotel will be more prominent as a group and interrupt views of the full stadium elevations. This layout has advantages and disadvantages. The location of the stadium amongst new buildings in a tight site avoids the blandness and starkness associated with many new stadium developments that often sit in large open areas surrounded by car parking, with little activity except for match days. It won’t be isolated because the routes will be used for permeability generally. However these surrounding buildings, in relation to the sensitivities of the context, reduce opportunities to provide a single prominent, highly legible entrance. The position of the main access route, and triangular shape of the site, further constrain the shape and extent of the adjoining concourse areas.

9.187 There would be some views of the stadium from the south near Kew Bridge, i.e. from opposite the grade 2 listed station building and on the adjacent railway bridge. These would be behind or between the proposed taller residential blocks and are secondary or within the context of other larger existing buildings along the M4. From Kew Bridge the stadium would barely show except for flood-lighting. From the north, east

103 and west views of the stadium building will be more intermittent due to the bulk of the residential and other buildings.

9.188 The most significant views of the stadium are from its southern approach on Lionel Road South, towards the main stand, entrance and public concourse, which is within and to be the ‘hub’ of the development; and from Kew Bridge Road to the southwest of the site, where the southwest corner will be seen as the backdrop to the Kew Steam Museum’s cluster of listed buildings.

9.189 The north-facing view up Lionel Road South is important as this is the main approach for most users of the stadium and is its ‘public face’. It needs to be of a very high quality, creating a legible entrance and marking its importance to the route. The siting of the main entrance and interaction of the ground floor activities (club bar, shop, turnstiles) with the other commercial uses proposed to the ground floor of the residential buildings is appropriate, as these uses and the new public space between them, will provide a liveliness and sense of place that would help create an identity for the development. The maximum design-parameters for the residential blocks of the Central Southern site need to ensure that space for views towards the main entrance can be accommodated to aid legibility for pedestrians. Conditions are recommended to ensure that the lower levels be undercut or setback adequately from Lionel Road to ensure a vista is provided.

9.190 The currently proposed materials, which include fibre cement cladding to the most walls of the stadium, provide more detailed interest than typically found on new stadiums which often feature just a single material for cladding and are usually very functional and uniform in appearance. A condition requiring samples of external finishes to be submitted for approval is recommended, in particular because of the impact on the setting of the steam museum. The applicant has sought to revise the Design Code to address these issues but it is recommended both the materials and detail of finishes to the stadium and the concourse level floor/s setback of Block E on Central Southern site (adjacent to Lionel Road) be the subject of conditions.

9.191 As noted, views of the stadium from a stretch of Kew Bridge Road southwest of the site will be possible. The southwest corner is seen as a distant background to the Steam Museum (the stadium being 185m away from the museum) and around 300m from the viewpoint. The stadium itself will blur the silhouette and fill the sky place immediately behind the main buildings which although industrial in use are symmetrical and classically roofed. The residential towers will rise well above the roofs of the main buildings and form a large mass behind the standpipe tower “campanile” which is Grade 1 listed and a local landmark. Officers and English Heritage, as well as objectors, have raised concerns about the impact of the new backdrop of the stadium on the integrity of the Steam Museum cluster, for which special regard to the desirability of preserving the building or its setting or any features of special architectural or historic interest which it possesses must be given.

9.192 The stadium elevation although lower than the other proposed buildings has the potential to either blur the skyline of the listed buildings or unduly clash with them. Officers have suggested that the visible elements should be more sympathetic in this view, designed to create a more visibly distinctive symmetrical form – e.g. sides angled to get narrower towards the top - with appropriate cladding to act as a main

104 but neutral feature. This would help to reduce the impact and make subordinate by masking and containing the upper storeys of adjacent accommodation. The feature shape should have some depth or mass; and a more natural integrity, such as an industrial colour such as copper or bronze combined with a seamed cladding or the like is advised. The aspiration is to provide a neater shape, less intrusive and forming a less ‘active’ elevation in this view. In addition the more obtrusive elements should be shielded by being orientated to and more firmly focussed on the southern approach from Lionel Road. The design of the Lionel Road approach and the visibility from that direction is therefore also important.

9.193 The applicant has been receptive to these suggestions and has undertaken to amend the detailed elevation. A condition requiring further details of this element of the stadium design in line with suggested comments is to be submitted for approval.

9.194 Overall the stadium building would have an acceptable design that would add a distinctive structure to the area although with surrounding buildings limiting significant views. Apart from the effect as the Steam Museum backdrop, and subject to the recommended conditions it would not adversely affect the character of the surrounding area. Officers are content the condition would ensure that the impact is sufficiently mitigated, though if unsatisfactory details were submitted pursuant to this condition consent would be able to be withheld until they were acceptable.

9.195 Ancillary uses within the stadium are found throughout each stand but are focussed in the main southern stand. This is primarily owing to the constraints of the site, but is logical given this side is closest to the main concourse and public transport links to the site. The new stands, concourse, spectator and player facilities have all been designed to meet the latest safety and sporting standards and are fully accessible, and will provide a high quality sport facility.

9.196 Therefore subject to the safeguarding conditions recommended to ensure high quality finishes and minimise harm to views over the Steam Museum, the stadium which by its very nature is large and must be functional, is considered to have a satisfactory appearance and capable of achieving high quality, locally distinctive design.

(ii) The public realm

9.197 LP policy 7.5 seeks to develop and enhance the public realm, creating safe, legible and attractive spaces. Other LP policies including 6.9 and 6.10 in respect of encouraging cycling and walking also support public realm improvements. The spaces surrounding the stadium and housing are very important in creating character and ensuring the layout is integrated with surrounding uses, is permeable and enhances access to public transport, green infrastructure and local communities as recommended by LP policy 7.1 and policy ENV-B.1.1 of the UDP.

9.198 The application proposes work to improve the public realm along the length of Lionel Road from its intersection with Chiswick High Road to the railway bridge at the northern end of the site. Other works to create the stadium concourse, and provide a bridge over railway lines to link the main site to Capital Interchange Way are also

105 proposed. The housing plots currently for outline consent stage also require improvements to the adjacent pedestrian environment and streetscape.

9.199 These works would significantly enhance the existing poor-quality environment along Lionel Road, and create new public realm around the stadium, the latter providing an east-west route across the site. In total an area of 6,395sqm is provided by new public realm and concourse areas, plus there is a further 2,763sqm of highway footpath and shared surfaces created through narrowing the carriageway and widening of footpaths next to Lionel Road and building the new bridge.

9.200 New paving, street tree planting, and lighting should help link the site to the places of interest to the north and south. These improvements would help make Lionel Road a link not only for vehicles but also for residents and visitors, joining Gunnersbury Park and residential areas to the north of the A4/M4, to Kew Bridge, the Thames and beyond to Kew Green, as well as complementing other improvements resulting from new buildings, activity and landscaping. In a wider context this, along with the new east-west route across the site provided by the bridge over railway lines to Capital Interchange Way, would enhance the permeability of the area. Alterations to the left turn into Lionel Road in the first (stadium) phase should make this intersection safer for pedestrians.

9.201 Permanent closure of Lionel Road South to through traffic was identified during pre- application discussions as a major opportunity to optimise the north-south link and the environment for residents, and in urban design terms is considered essential. As yet traffic modelling on such a full closure has not been undertaken by TfL with this to be the subject of future assessment in respect of the proposed Cycle Superhighway along Chiswick High Road and possible effects on traffic at Chiswick Roundabout.

9.202 A partially enclosed pathway from the main stadium concourse to a re-opened underpass that provides direct access to the London bound platform of Kew Bridge station is proposed. This pathway would ramp up from the underpass, extending alongside railway lines and underneath proposed buildings on the Central Southern site. The gradient of the ramp meets disabled access requirements and it would be partially open to the roof and all along the railway to provide natural light. The primary benefit of this space is its direct access to the Kew Bridge station which will facilitate crowd movement, though marshalling security features and satisfactory will be necessary. As this would be a permanent feature and with a shorter but stepped route will be available for wider use, the detailed design will be very important.

9.203 The stadium concourse areas and new east-west link, whilst although providing functional space for football crowds, gives an opportunity to create new public realm. These areas need to be both durable and attractive and the proposed Design Code and D & A show good quality landscaping is proposed. The proximity of the housing blocks to the stadium avoids sparse areas that would be stark and uninviting, but does add to the overall sense of being built up and high density, with the finer detail of the materials and planting being very important to provide some human scale and distinctiveness to avoid these spaces appearing overwhelmed by the adjacent buildings. Conditions requiring further details to secure details of public realm works are recommended.

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9.204 The GLA stage 1 response sought additional permeability, suggesting another east- west link, to join Lionel Road to Green Dragon Lane. This would help integrate the development with the surrounds and would be a positive improvement. However analysis of such a link shows that it would be impractical given private landholdings on the western side of the railway lines, whilst it would also add considerably to the cost of the development, for which viability is marginal.

9.205 In summary, the development will enhance and create new public realm, improving links between the site and its surrounds, helping to create areas of new neighbourhood and complementing the new community infrastructure. Despite the proposed tall buildings, Lionel Road would become a significantly more pleasant space with more greenery and activity proposed, contrasting with its present industrial nature and use predominantly as a vehicle thoroughfare. The potential remains that it could provide still better and more attractive access to Gunnersbury Park and its amenities.

9.206 Further details as discussed are needed to maximise the quality and legibility of the spaces, to help reinforce local character and accessibility, with these to be secured through the Design Code and conditions and will be the subject of reserved matters. The Design Code and Design and Access Statement provides comfort that these areas would be high quality and suitable for both match and non-match day use. In this regard the concourse areas and footpaths are illustrated with high quality, durable landscaping that has a good amount of detail and infrastructure without compromising the flow of large numbers of people when in full use. It is noted that the stadium design has fully accounted for crowd arrival and dispersal, with detailed arrangements covered in the various management and operational plans to be agreed with police oversight.

(iii) The housing

9.207 The proposed housing is provided in a series of tall blocks located around the stadium. As noted, the scheme has a high density, which exceeds the applicable density ranges from the LP, and it includes tall buildings that affect sensitive and other views from neighbouring areas, and the skyline.

9.208 The impact of the housing design on the quality of the scheme itself, the townscape of the immediate environs of the site, and how it appears from areas outside of the site are, in addition to ensuring good transport, infrastructure provision and acceptable impacts on neighbouring residents, key to determining whether the buildings are satisfactory.

9.209 UDP policy ENV-B.1.2 says that tall buildings, which are those that significantly exceed the height of their surroundings, will normally be refused where they would be in or result in significant harm to sensitive places including residential area, conservation areas, the setting of listed buildings, open spaces and the Thames Policy Area.

9.210 Policy ENV-B.1.3 of the UDP provides exceptions for tall buildings saying that in the remainder of the Borough permission for tall buildings will only be granted where

107 they carefully relate to their surrounds, the site is large enough include adequate space for landscaping and minimise impacts on neighbours, and the building is of a high quality design with acceptable impacts on microclimate and important views.

9.211 The site’s surrounds have some tall and large buildings, particularly to the north and west, with such buildings part of the townscape of Green Dragon Lane and the M4/ Great West Road corridor and intermittent skyline features viewed from Lionel Road South, Capital Interchange Way and both Kew Bridge and parts of Strand on the Green conservation areas, though these are not necessarily precedents to be followed. Many are over-clad buildings from the mid twentieth century. The more recent developments affecting views across the Thames have been carefully considered in materials, height-layering and articulation especially of the skyline. The proposed buildings are no higher than these other tall buildings and given the relatively self-contained nature of the site, medium tall buildings may be appropriate as this would optimise reuse of brownfield land. However, the site also bounds a number of different areas with varying townscapes and uses, with some parts of the scheme potentially affecting neighbouring residential areas, and views from conservation areas, the setting of listed buildings and a World Heritage area, whilst others adjoin commercial areas that are less sensitive. As such the objectives of both policies are relevant and very tall buildings are not appropriate.

9.212 Although some people admire tall buildings, many do not, and it is clear from the numerous objections received, that many local residents oppose the development due to the height and large scale of the proposed buildings on the skyline and their impact on the character of the surrounding areas. Tall and large scale high buildings will have significant impacts on the immediate and wider context of the environment. The extent of these impacts will be influenced by the quality and parameters of the design, but they can be overly dominant and adversely change the character of historic areas, intensify pressure on infrastructure, create adverse climatic effects, and be unduly disruptive during construction.

9.213 Owing to their height, scale and location, the proposed tall buildings would be seen from many vantage points. However, simply being able to see it does not make the design poor. Tall buildings in major redevelopment schemes can optimise the reuse of land and economic potential, as well as enabling the cross-subsidisation of other aspects of the development. They may also aid legibility of the townscape, acting as landmarks that help identify a point of civic or visual significance such as a football stadium, and promote regeneration or secure other planning gains. Additionally, character is about more than height, bulk and appearance, it is about distinctiveness, uses, people and communities and how places are connected. Character is also not static, it is dynamic, with change over time being a fundamental feature of the urban environment including this area.

9.214 There is considerable guidance in respect of design and tall buildings, with CABE/ English Heritage issuing policy to assist evaluation of tall building proposals with this referred to where pertinent below. Setting aside context, in general design guidance for tall buildings consistently identifies some important factors in ensuring their success, these being:

• Elevations to be varied and interesting.

108 • Tops to be well articulated with the most visible compositional elements. • Materials to be appropriate to their settings. • The surrounding public realm to be accessible to the public and capable of accommodating pedestrian movement. • Microclimate impacts to be within acceptable limits.

9.215 The proposed buildings are outline only, with their maximum parameters being for determination, though illustrative material, and in particular the Design Code, will guide future detailed design. A full application is always preferable in determining the possible impacts of a development, but the submitted material, including the ES and D and A, provides adequate information to conclusively determine whether there are harmful impacts from the height and scale of the proposed buildings. To provide further reassurance in respect of the quality of the future detailed design, the applicant asked for submission of suggested designs from prospective developers, with these to address the Design Code in order to demonstrate delivery of a high quality of design and architectural treatment at later detailed design stage is realistic should the application be approved.

9.216 More detailed design comments in respect of each element in the scheme is given below

(iv) Impacts on the character of the site itself

9.217 The site lies bounded within and adjacent to a triangle of land resulting historically from intersecting railway lines, which disrupted the agricultural land and earlier alignments and leaving a space useful for industry. The original station lay to the north and with the new Lionel Road led to the placing of the “medieval” gatehouse access into Gunnersbury Park. Within it is a mostly flat secretive area which itself is not sensitive, although the site had small vernacular buildings, relating to the railway itself and some still un-demolished stables for the gas works. Artificial hills and cuttings to allow crossing the lines create changes of level allowing uncelebrated views of the steam tower, seen when approaching from the north. It is not in a conservation area, is outside the Thames Policy area, outside the Kew Gardens World Heritage Buffer Zone, and has no designated heritage items. Other than Lionel Road there is no public access within the site and does not create a townscape. Although its low rise buildings ensure in a wider context its impacts are fairly benign, the open storage of recycling and mix of industrial uses is apparent from along Lionel Road and parts of the M4/ A4, with this detracting from the overall character.

9.218 The scheme includes twelve buildings ranging from 7 to 17 storeys. Owing to their number and extent, they would form appreciable and prominent groups of buildings. Sometimes clustering of tall buildings helps to limit wider impacts, focussing them to a particular area. However for this site the three clusters of buildings are spread around the lower stadium sited in the middle. This highlights the shape of the site and intentionally reduces the impact.

9.219 The magnitude of change to the built form will be high, as the proposal introduces buildings of a much greater scale, height and bulk than the existing development. This will sit within existing development to the north and immediate east of the site,

109 where the urban grain is characterised by large blocks. The height of the buildings is comparable with some of the tallest buildings in the immediate surroundings, such as the commercial Vantage West building, the focal tower of the residential Thames Water site development and the Brentford Towers. However towards the southern end the buildings become apparent in more sensitive views and some negative impacts result. A major concern of the design process was to avoid the additional tall buildings creating a continuous skyline, without redeeming breaks and undulations.

9.220 Within the site the environment is constrained by the railway lines and the new stadium, with the consequence that with the concourses as well the character will feel congested and very urban. Maximising the width of pedestrian areas and provision of street trees and greenery will be very important in creating a pleasant streetscene. Taking advantage of existing changes in ground level to provide much of the proposed car parking below street level will allow active frontages from entrances and shops next to footpaths, though further detail on relative levels to confirm a seamless transition between the pavement and ground floor is necessary to avoid awkward junctions. Correctly achieved these relationships will help create a sense of place and the activity will add vibrancy. The exception to this are the blocks on Capital Interchange Way, that sit completely on podiums containing two parking levels. The inclusion of commercial space and residential entrances to the ground floor would give some relief to what could be a blank wall to the street. Further mitigation such as green walls, recesses for planting and use of materials to provide articulation will be very important to the street elevations here.

9.221 Overall, and provided the public realm is finished with durable, attractive and finely detailed designs, the tight arrangement of buildings in the layout could help create distinctive precincts/ quarters within the site. At lower levels imaginative architecture may be expressed, and with the ground floor activity provide some human scale that would help offset the sheer scale of the stadium that sits at the heart of the site. At upper levels buildings’ mass should taper to reduce visual and environmental oppressiveness.

9.222 The layout includes communal open space between tall blocks, which would not be ideal, but the areas proposed are of a good size and they would be likely to receive adequate sunlight at various times throughout the day. The ES has considered wind microclimate impacts from the development and found impacts to be acceptable for users of the spaces adjoining the buildings (with this matter discussed in detail later). Semi-private spaces amongst the housing units should also provide areas where there can be quiet enjoyment contrasting with the stadium activity outside. This could be achieved, subject to management, by dedicating parts of the access floor which would have insufficient privacy to be a home.

9.223 LP policy 7.3 on designing out crime requires proposals to take account of the principles of Safer Places and Secured by Design and there are recommendations in this regard from the Housing SPG. The detailed design will need to clearly mark private and public spaces and incorporate appropriate security features and be well managed. A benefit of the scheme’s density is it will provide good natural surveillance of public spaces whilst the mix of uses will maximise activity during non- match days, reducing risk of crime and contributing to a sense of security.

110 9.224 Officers and the GLA have during both pre-application and post application discussions sought to minimise impacts and ensure high quality environments are created. Lowering overall building heights through reconfiguration of the layout and loss of units to the point the minimum viability threshold were achieved during the pre-application stage. The applicant was asked to consider alternative layouts that may potentially lower the height of the buildings and increase legibility by having perimeter blocks that align with adjoining roads, although the space for new streets is extremely limited.

9.225 The applicant responded to this matter by preparing a design with a perimeter block layout. This did in part reduce building heights, but also resulted in continuously long, slab-like buildings which still had an impact on the external views. In some areas these were likely to have poorer amenity to the lower levels and / or shade external space, which would result in lower quality accommodation and potentially affect the values which can be obtained at the lower floor levels, ultimately affecting funding for the stadium.

9.226 Taken as a whole, the proposed stadium and housing result will result in the intense use of the site and this is reflected in the density and built form of the proposal. However, within its a large, more or less self-contained site that is well connected to public transport, and noting that minimum housing quality standards are achievable, that a mix of uses is proposed to the street level, and there are significant public realm enhancements and additions with the potential to achieve more, the scheme has the opportunity to create its own character. With conditions and the Design Code to focus the final design in order to achieve high quality architecture and suitable accommodation, the scheme’s impacts on the site itself are acceptable.

(v) Impacts on the character of surrounding areas

9.227 As the policy framework discussed above sets out, the development cannot be considered in isolation. Despite the site itself not being sensitive, other than as a low- lying space, the height and siting of the buildings will mean they are visible from surrounding areas, some of which are sensitive. From a distance, the buildings will need to have some overriding rationale for their siting. Once detail of styles are produced, these could include elements of character or appearance related to a more industrial past, with significant use of brickwork and metal elements recommended, and large areas of glazing to be avoided. The upper parts of the buildings should taper in width to temper the apparent height and bulk but at the same time excessive stepping of the building form is discouraged as this may accentuate their bulk. This should be influenced by the design integrity and structural logic necessary to design buildings that look right over their full proposed height.

9.228 The extended shape of the site assists its impacts on surrounding areas to vary, whilst the sensitivity to change and the acceptability of such change of the surrounds also varies. The impacts of the proposed buildings on views from over 30 vantage points were considered in the ES. This assessment took account of designations such as conservation areas, listed buildings and gardens, Metropolitan Open Land and protected viewpoints and landmarks. Officers have considered these views as well as assessing impacts more generally throughout the surrounds.

111 9.229 Significantly, UDP policy ENV-B.1.2 regarding tall and large buildings, states that permission will normally be refused for the erection of such buildings in or where they would result in significant harm to Metropolitan Open Land, residential areas, conservation areas, Thames riverside, local parks and sites of nature conservation importance, and the settings of the listed buildings.

9.230 Conservation Areas – In respect of conservation areas, policy ENV-B.2.2 of the UDP says the any development within or affecting a conservation area should preserve or enhance the character and appearance of the conservation area and it should respect the character of existing architecture in scale, design and materials, and take account of specific guidelines for the area. Therefore special attention must be paid to the desirability of preserving and enhancing the character and appearance of such areas.

9.231 The proposed development would be apparent from the following nearby conservation areas:

• Gunnersbury Park and Surrounding Area – to the north beyond the M4. Comprising a large open space around listed buildings, the park is also designated as Metropolitan Open Land, a conservation area, Grade II* listed park and garden and a Site of Local Nature Conservation Importance. Its character is derived from the listed buildings and associated parkland and cemetery. The garden estate to the east is also within the conservation area but has shorter distance views. • Wellesley Road – to the southeast, on the eastern side of Chiswick High Road, has a variety of high quality Victorian buildings edging the streets. • Strand on the Green – to the southeast, alongside the Thames. It is an historic riverside settlement, ribbon development adding to a picturesque setting including many attractive early small-scale houses and listed buildings. • Kew Bridge – to the south, including Kew Bridge. It is focussed on the convergence of a number of important transport routes, and includes the grade II listed Kew Bridge and grade I and II listed buildings at the Kew Steam Museum. It recognises the industrial character created by the pumping station and its associations, and their high quality of architectural style. The bridge and standpipe are architectural landmarks, and Kew Bridge station, though currently vacant and its locally listed neighbours are in poor condition forms with them an architecturally attractive group. • Kew Green – to the south, on the opposite side of the Thames. Its value is as an historic open space (village green), along with associated high quality of 18 th and 19 th century buildings to the east of the green. This area is in the Kew Gardens World Heritage Site buffer zone. • Royal Botanic Gardens – to the south, (corresponding with the World Heritage site). Kew Gardens was made a World Heritage Site in 2003 in recognition of its contributions to botanical and environmental science, plant collections and influence landscape and garden design. The area is also designated Grade I on the Register of Parks and Gardens of Special Historic Interest. It also has many listed buildings including the Temperate House, the Palm House, Queen

112 Charlotte’s Cottage, and the Japanese Gateway as well as Kew Palace, which is also a Scheduled Ancient Monument.

9.232 There are other conservation areas such as Grove Park and Thorney Hedge, where some glimpsed views would be available but these are at long distances where mere visibility of the buildings in an urban context will not be harmful.

9.233 Each conservation area has an appraisal statement that identifies the attractiveness or interest of an area and what makes it special. These went to committee in 2006 and were approved as far as but not including pressures on the area and management guidelines. The earlier UDP SPG includes statements on Gunnersbury Park and Surrounding Area and Strand on the Green conservation areas. There are no UDP SPG entries for more recent designations, including Wellesley Road and Kew Bridge, however they went through public consultation and their full descriptions at the time of designation were the basis of the statements noted above.

9.234 Other designations – In respect of Gunnersbury Park, policy ENV-N.1.6 is relevant, as it states that development will not normally be permitted which would adversely affect the site, settings or views to and from historic parks and gardens.

9.235 UDP policy ENV-B.2.6 applies to buildings of Local Townscape Character, with protection given to them and their setting. The buildings at 56, 57, 58, 59 and 60 Kew Bridge Road are locally listed (also in Kew Bridge conservation area).

9.236 UDP policy ENV-B.2.8 relates to landmarks and key local views, it stating that the Council will seek to protect these from immediate obstruction from high buildings and any development should only be permitted if it does not affect the views and landmarks. These views include East-South-East and West-South-West vistas from Kew Bridge (not affected by the development) and a North-West view from Kew Gardens, which is towards the site. The Steam Museum is a landmark.

9.237 LB Richmond has similar policies in its Development Management Plan relating to protection of important views, heritage items and settings, and good design, with these considered in the ES.

9.238 The Thames Landscape Strategy (Hampton to Kew) is also relevant. This is guidance covering the environment of the Thames, which aims to conserve and enhance the riverside landscape. The relevant section highlights the contrast between the Surrey and Middlesex banks for the nearby stretch of the Thames, with Brentford having an industrial past as opposed to the green spaces of Kew and the Botanic Gardens. Its objectives correspond with policies protecting the character of the area as they relate to the riverside environment and its heritage and views. It specifically calls for no more flat-topped buildings dominating the view, a reference to Rivers House.

9.239 Listed Buildings – The proposed development would appear in the background of some listed buildings. Kew Bridge and Kew Bridge station, both Grade II listed, lie to the south. To the southwest is the Grade I and II listed cluster of building at Kew Steam Museum. Further away there are listed buildings on Kew Green and Strand on the Green, as well as inside Kew Gardens.

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9.240 Section 66 of the Planning (Listed Buildings and Conservation Areas) Act says that in considering whether to grant planning permission for development which affects a listed building or its setting, the authority shall have special regard to the desirability of preserving the building or its setting or any features of special architectural or historic interest which it possesses.

9.241 Construction impacts – Construction impacts on surrounding areas and on views is neutral or negligible for many areas as impacts are largely indirect as a result of partial views of construction activities from limited locations. Sites in closer proximity, including from within Kew Bridge conservation area, would be more affected as the works will be highly visible and impacts are minor to moderately negative. Elsewhere impacts on other conservation areas are less direct, though as some affected areas are conservation areas, such as Strand on the Green and Wellesley Road, or residential areas to the west, the impacts will be minor to moderately negative. These impacts will be temporary, with the main negative effects relating to the construction of the Central South Site (expected to take place from July 2014 to September 2016), with some effects from the stadium construction also expected (from November 2014 to April 2016).

9.242 Mitigation of the visual impacts would involve site management practices such as:

• Erection of hoardings around the site to screen construction activity • Control of lighting to minimise upward and outward light pollution • Control of construction hours • Locating compounds and stockpiles in the least visible locations within the site • Limiting movements of material between stockpiles

9.243 Floodlights – Policy ENV-P.1.7 of the UDP states that when considering proposals for floodlighting the Council will take account of the effect on the character and amenity of the surrounding area. Where lighting or floodlighting is permissible in principle, factors such as: the appearance of the installation when switched off; the effect of the lighting on residents when lit in terms of sky glow, glare and light trespass as well as the effects on wildlife, including on adjoining land; and the potential noise and disturbance from the associated use of the facilities being lit, will be taken into account.

9.244 The pitch would be floodlit for most football games in the late afternoon and evening. The floodlights would be designed and installed to concentrate light onto the ground but they would be able to be seen from some surrounding areas in particular to the residential areas to southwest, to the south around the end of Kew Bridge, along Kew Road, the Surrey bank of the Thames and Kew Gardens.

9.245 It is appreciated light pollution can be a major annoyance and should be considered carefully in the design. The lighting systems have been designed to ensure there is no lightspill and could be a feature of the roofscape. Apart from lightspill, glare is also considered to be a nuisance, particularly in intrinsically dark areas. This site is currently a “dark area” but sits amid a heavily built up area, with major roads and multi-storey office buildings adjacent; and impacts on the character of the area and wildlife from the intermittent use is considered negligible. The impact of light glow will

114 be greater to the north because the roof is lower on that side, but the lights themselves will face away and add to the skyglow of the M4. In respect of Kew Gardens, it is noted that the existing floodlights to Griffin Park are more prominently located, whilst the gardens close throughout the off season (27 Oct to 7 Feb) at 4:15pm. Kew Palace is closed from end of September to the end of March. As a result, use of the gardens does not correspond with the a large part of football season and the main period when floodlights would be in use (late afternoons and occasional evenings during winter), thereby reducing concerns over their visibility, which in any event would be at some distance and for temporary periods only.

9.246 Gunnersbury Park and Surrounding Area CA and environs to north – The impact of the development on the area to the north of the site, including Gunnersbury Park is acceptable subject to breaks and shapes forming a varied skyline. In the immediate area to the north, the townscape comprises mostly large scale buildings along the M4/ Great West Road corridor, with which the scale of the proposed buildings is consistent. At a lower level, south of the railway bridge the new public realm works will enhance the streetscene and pedestrian environment of Lionel Road which links to this area. Further away the impacts on character are more indirect as there are partial views of the new buildings with some upper levels breaking the tree line along the southern end of Gunnersbury Park and also the Kensington and Chelsea Cemetery, but these are also partly obscured by the trees and existing (and consented) commercial buildings. The openness of the MOL will not be affected. Impacts on views are cited as being of minor to moderate negative effect owing to their high sensitivity and their height contrasting with the natural character of the park. Where the buildings are apparent, they are of a similar scale to other existing buildings along the M4 corridor and so their impact on the character of these areas would not be significantly greater than that of existing development already apparent if an intermittent and undulating skyline can be achieved.

9.247 Wellesley Road CA and environs to east – The Wellesley Road CA would experience a low magnitude of change as views are partial and the majority of the area would not have any views of the site. Overall it is considered there is a minor negative effect, with impacts on the character and appearance of the conservation limited. The development would be seen along Chiswick High Road, but this would be in a context with what are currently considered large buildings along the road, Rivers House and the Kew Bridge development. Whilst these are shorter than almost all the proposed buildings, the proposed blocks will be set further from the road, the design code requiring a step down at that end. The Brentford Towers form the background, remaining the highest points. One view looking out from the conservation area would experience major adverse impact owing to the height and bulk of the proposed housing blocks being apparent at the end of the view along Wellesley Road, with this being out of scale with residential buildings in this view.

9.248 Change to Capital Interchange Way would be significant but this is not a sensitive area, and the design code anticipates a varied skyline. Although it brings taller buildings away from the main roads they would edge the stadium on the eastern side, and to the extent that much of the new access will be from Capital Interchange Way will assist legibility. There would be considerably more activity as a result of the new bridge, bring an opportunity to expand and improve the public realm and enhance the streetscene of the road itself.

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9.249 Strand on the Green CA – This area is highly sensitive to change owing to its many listed buildings and picturesque setting of many of the other buildings and the riverside edge. The change to the townscape, and overall character and appearance of the conservation is low however, as apart from the extreme northeast end of the designated area, there would be minimal views of the development as the ribbon development along the Thames and narrow streets elsewhere block views. Existing riverside views from the conservation area upstream and towards Brentford look towards a variety of large and tall buildings extending west from Kew Bridge, with the six Brentford Towers being very apparent.

9.250 The proposal would not therefore significantly affect the context or the character of, i.e. within, the conservation area. Nevertheless, it would result in major harm to a view out from the area that is north from the open space at the end of Strand on the Green. This will be significantly changed by the buildings on the Central Southern site and also the south elevation of the stadium, as from here they would appear out of scale with existing development.

9.251 Views into the conservation area, and therefore the setting, will be affected seen from across the river opposite Strand on the Green. This view which is from another conservation area would be adversely affected by the massing of the new buildings appearing above the tree/ ridge skyline from this direction. The effect of this would be similar to extending Rivers House, an existing building. This is an overclad building, already out of scale owing to its height and bulk, which although individually improved in appearance still has a very long silhouette and is accentuated by being painted white. This highlights the importance of the proposed buildings having colours and surface finishes which visually retreat, along with the need for breaking up of the mass and modelling, to reduce their bulk on the horizon.

9.252 Kew Bridge CA and environs to south and west – This is the most affected area given its proximity to the site and the long viewing distances, which means the proposed buildings will be highly visible from a number of locations, in particular from on the listed Kew Bridge. It is also of high sensitivity as the conservation area includes other listed and locally listed buildings. The setting of these heritage assets is partially compromised by existing buildings, outside the conservation area but affecting it through bulk and mass: notably the 6 Brentford Towers at 23 storeys, each sited on a small footprint into the former reservoirs of the waterworks. The northern edge of the conservation area culminates to the west in the enclave of the Steam Museum with two grade 1 buildings including the standpipe “campanile” tower, and several others at grade 2.

9.253 Other than the tower, this side is of consistently domestic scale, at the east end terminating in the elegant Kew Bridge station building, fully repaired externally but still “At Risk” through vacancy. On the south side of Kew Bridge Road the formerly disparate edge has been recently knitted into what is now a streetscape between the road and the Thames that is undoubtedly taller (average 5-7 storeys, over two small areas up to 9 storeys and near the river at 3) than before, whilst other tall accommodation is being constructed further west. To the east Rivers House (9 storeys) in Strand on the Green conservation area has already been described. At

116 street level the area suffers from the visually chaotic and poor quality public realm of the major road junction at Kew Bridge.

9.254 The impact on the character of the conservation area and settings of the listed buildings is indirect, i.e. a setting issue: with the development sited on rising ground and adding a greater mass on the horizon to the other larger buildings within the townscape. Even though there are higher buildings already out of scale in the scene, the proposal results in effects of minor to moderate negative effects owing to the sensitivity of the area. English Heritage objects to the impact of the development on the skyline behind the Steam Museum, stating it would erode the clarity (of the group and individual buildings). In such circumstances the authority shall have special regard to the desirability of preserving the building or its setting or any features of special architectural or historic interest which it possesses. As discussed earlier, use of appropriate forms and materials to the stadium elevation apparent in background views of the Steam Museum would help to minimise its impact on their townscape relationship with this secured by condition.

9.255 As described earlier, the final design of the proposed housing blocks needs to take cues from this area. This is partly to attempt to respect its setting and character and mitigate impacts. The character of the area includes its industrial uses and history. Overly domestic or modern architecture would not be appropriate, instead references to industrial heritage, with building elements to be expressively robust and use of brickwork and natural materials is recommended. At the same time, these materials and tonal values will help reduce reflectivity and visual obtrusiveness. The use of glass should be considered very carefully, as its apparent “lightness” and immateriality can appear very alien in this context.

9.256 Kew Green CA – From within the Green a low magnitude of change will occur as the impacts will be indirect, with partial views of upper parts of some buildings visible from the southern side of the Green. As the sensitivity to change is high, these would still have a “minor to moderate negative” effect. Existing development such as the Brentford Towers and the recent Kew Bridge development are also apparent from various parts of the Green. The impact is lessened when trees are in leaf and when this is the case impacts are reduced to “minor” negative. Given the distance from the site, the incursions to the skyline would not materially alter the character and appearance of the conservation area.

9.257 Kew Green in L B Richmond’s conservation area extends across Kew Road and views down (i.e. north along) Kew Road towards the site, from both next to Kew Green and approach to and in particular from the crest of Kew Bridge will be significantly affected by the development of the Central Southern site. This is a long distance, linear view that would provide a clear view of the development. There would be a high magnitude of change to this view as the top sections of residential towers on the Central Southern Site will form a new skyline that appears taller than existing buildings in the same line of view.

9.258 At present this vista terminates with a tall commercial building, known as ‘Vantage West’. This is a 1960s re-clad office building that is 62.0m high (AOD) and is finished with blue glass, which makes it a prominent. A second building, the ‘Big Yellow’ building used for self-storage, sits in front of it (37.0m AOD) and from the crest of

117 Kew Bridge is just visible over the current roof line of the locally listed buildings forming the front layer along Kew Bridge Road.

9.259 The height of the new blocks on the Central Southern site, at 54.0m and 60.0m AOD are lower than Vantage West, however these new blocks are closer to the viewing points and owing to foreshortening they will appear much larger in the view.

9.260 From the crest of Kew Bridge, the height and bulk of the Kew Bridge (St George) scheme and Rivers House, both at a maximum of nine-storeys, would frame the view, with the new buildings rising between them. The vista stop created by Vantage West is not an appropriate one because it represents a false legibility; i.e. it is not a direct route to that point. The new development would however alter and increase harm to the setting of the listed station building and adjacent locally listed buildings in this view although it is already affected by the Vantage West buildings visible above them, by bringing the height and bulk much closer. The views along the road are kinetic and set within an urban environment that includes traffic along the road itself, and with the site earmarked for re-development, some change is envisaged.

9.261 However the overall height and bulk of the group of buildings will transform the townscape. Owing to the sensitivity of the areas affected, this change is considered a major negative effect. The ES states the development could provide an opportunity to enhance the view: noting that Vantage West is of an incongruous style and so higher quality buildings at the end of the view could become a more appropriate landmark. There is some logic to this argument as the site sits at the middle of a major interchange of direction and character; and since the football club aims to represent the region and have a community role, will have a building/ use of more than local importance. However this role could be as effectively marked with lower buildings, which would be more appropriate given the sensitivity of areas affected by them.

9.262 Cumulative impacts – Other nearby sites presently undergoing development include the second phase of the Kew Bridge (St George) development next to Kew Bridge, and the Kew West (former Thames Water site) development to the south of the Brentford Towers. The former would screen most views of the proposed housing from the riverbank to the southwest of Kew Bridge, although there is some concern that careful skyline detailing could become blurred; whilst the latter includes buildings ranging from 7 to 16-storeys, adding to the mix of buildings in the townscape. A smaller housing scheme is currently being constructed in the original filter beds to the immediate west of the Steam Museum, which includes the temporarily 2 storey sales centre (to be a permanent single storey) seen in the foreground of the view of the steam museum enclave affected by the stadium. Other development to the north includes new car showrooms and potentially some very distinctive office buildings, but the latter have not commenced.

(vi) World Heritage Site

9.263 The Royal Botanic Gardens, Kew, is a World Heritage Site (WHS) and is of international importance. Policy 7.10 of the LP states that development should not cause adverse impacts on World Heritage Sites or their settings (including any buffer zone). In particular, it should not compromise a viewer’s ability to appreciate its Outstanding Universal Value (OUV), integrity, authenticity or significance.

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9.264 In considering planning applications, appropriate weight should be given to the provisions of World Heritage Management Plans. Paragraph 132 of the NPPF states that “when considering the impact of a proposed development on the significance of a designated heritage asset, great weight should be given to the asset’s conservation. The more important the asset, the greater the weight should be.” Paragraphs 133-135 further state that when a proposed development will lead to harm or loss, to the significance of a designated heritage asset, this harm should be weighed against the public benefits of the proposal.

9.265 The Royal Botanic Gardens, Kew World Heritage Site Management Plan 2011, although a draft, provides an update to the original management plan from 2002. It highlights the WHS buffer zone and important sightlines and views within, to and from Kew Gardens. The plan discusses the importance of vistas and visual envelopes extending outside the WHS buffer zone to the site’s OUV and the need for additional planning protection, as well as covering proposed improvements to the gardens. The BAAP recognises the sensitivity of the WHS and possible impacts from development in Brentford.

9.266 Outstanding Universal Value – The OUV of a WHS indicates its importance as a key material consideration to be taken into account by the relevant authorities in determining applications. The OUV of Kew Gardens comprises:

• a rich and diverse historic cultural landscape providing a palimpsest of landscape design; • an iconic architectural legacy; • globally important preserved and living plant collections; • a horticultural heritage of keynote species and collections; and • key contributions to developments in plant science and plant taxonomy

9.267 The World Heritage SPG 2012 also recognises that as well as visual impacts of the proposal there are other physical and experimental impacts that also affect the setting of the WHS and contributes to its significance, such as public realm, routes and accessibility.

9.268 The setting of a WHS is the area around it, including any buffer zone, in which change or development is capable of having an adverse impact, including an impact on views to or from the site.

9.269 Under the terms of the Town and Country Planning (Consultation) (England) Direction 2009, planning authorities are required to consult the Secretary of State for Communities and Local Government on applications to which English Heritage maintains an objection and which would have an adverse impact on the OUV, integrity, authenticity and significance of a WHS or its setting, including any buffer zone. The Secretary of State then has the discretion to call-in the application for his own determination if he considers it appropriate to do so.

9.270 Impact on views from inside Kew Gardens – The sensitivity of Kew Gardens is high with even minor impacts possibly being of significance. The proposed development will have an indirect effect on Kew Gardens as the site is outside of the

119 designated WHS and its buffer zone. The AVRs and site visits show there is likely to be glimpsed and partial views of enabling (funding) development and construction activities from a small number of locations on its northern boundary (adjacent to the Thames Path, but currently obscured by the boundary wall) and some specific locations within the Gardens (Viewpoints 21 ‘Kew Palace’, 23 ‘Kew Gardens 01’ and 24 ‘Kew Gardens 02’).

9.271 Kew Palace, within the grounds of Kew Gardens but owned by Historic Royal Palaces, is a Scheduled Ancient Monument, and so its sensitivity to change is also high. The magnitude of change is expected to be negligible as effects will be indirect, relating only to a view of enabling and construction activities from the third floor, which is largely obscured by trees within Kew Gardens in the foreground and built development beyond at Kew Bridge. Effects are therefore likely to be indirect, temporary and of negligible significance.

9.272 With the high sensitivity of the site, the partial glimpses of the upper parts of the proposed buildings from limited viewpoints within the Gardens will result in minor to moderate negative impacts on those views. The ES consider these impacts and notes that the viewpoints represent only a fraction of the landscape and architectural features at Kew Gardens with enabling and construction activities not visible from the majority of the Gardens as a result of its enclosed nature, considerable distance from the application site and intervening development and vegetation. Therefore the magnitude of change on the WHS designation is therefore expected to be negligible, resulting in effects of negligible significance.

9.273 Both English Heritage and Kew Gardens disagree and object to the development raising concerns about impacts on the OUV from effects on views inside the WHS and also its buffer zone (Kew Green). From inside the WHS, objection is raised to impacts on the ‘Palm House’ vista when viewed from outside the Temperate House. This is a very long view that extends from the Pagoda to the Palm House, the latter a Grade I listed building. Currently Vantage West is seen in the background above the Palm House in that view.

9.274 English Heritage and Kew Gardens are concerned the new buildings on the Central Southern site will “… erode the appreciation of the buildings distinctive silhouette and cause harm to the attributes of the Outstanding Universal Value of the Kew Gardens WHS, as set in World Heritage Site Management Plan (2011) which identifies the iconic glass house design as making a major contribution to the OUV ”.

9.275 This specific view was not identified during scoping of the EIA as likely to be affected and so no AVR was prepared and the comments without an AVR. However following the receipt of objections, an additional AVR was submitted (in accordance with Regulation 22). This view shows that the proposed buildings are positioned to either side of the Palm House vista and are screened by existing trees. It is noted that Kew Gardens has since acknowledged that there would be no harmful impact on the summer view, but state they cannot be certain there would not be an adverse impact when trees are not in leaf. However officers consider that when not in leaf, the separating distance of over 1.8km and density of trees would mean impact on this view from the development is negligible. As such officers do not agree with the objections raised in respect of degree of impacts on this view.

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9.276 Impacts on the WHS Buffer Zone – Objection was also raised to the impact on views from the WHS Buffer Zone, in particular from some vantage points on Kew Green. Possible impacts here correspond with those discussed above in respect of Kew Green conservation area and the commencement of Kew Bridge. There would be some partial views of the upper floors of some blocks from the southern side of the Green, but these are minor incursions to the skyline and with appropriate materials they would not unduly alter the overall character of the area. Further, most visitors to the Green and Gardens would appreciate that they sit more widely in an urban environment and so visibility of other buildings outside the buffer zone is not necessarily harmful, although the amount and scale of the increase would be considerable.

9.277 Therefore the development would not compromise a viewer’s ability to appreciate the OUV, integrity, authenticity or significance of the world heritage listed Gardens.

(vii) Mitigation

9.278 As the housing blocks are outline, full details of the scale, appearance and layout are to be submitted for approval. As a result it is not possible to know what the buildings will look like, other than their maximum heights and volume. The Design Code has assessed the parameters and will guide the detailed architectural form and treatment for the blocks. Conditions which are recommended in respect of external finishes, materials, hard and soft landscaping, and the public realm will assist in producing a high quality design and significantly reduce the final visual impact of the development.

9.279 The Design Code and future designs will be able and should be encouraged to mitigate height and bulk, through providing articulation and modelling to the buildings and incorporating materials that complement the character of the local townscape and are recessive rather than intrusive in effect. Given a near immovable volume of new development to be accommodated, officer review during the design process has included recommendations so that within the maximum parameters careful reductions in mass and shape are made to minimise impacts on views, in particular to avoid blurring of or reduce impact on the most important silhouettes and landmarks such as the Steam Museum engine house buildings and the landmark Steam tower. It is also important that surface treatments should be robust and reflective of the materials and former industrial character of the immediate environs.

3. Conclusion

9.280 From the above discussion and review of the ES it is clear that the development has positive and negative impacts on the existing townscape. Primarily the harmful elements relate to the blocks closest to the river owing to their sheer size and bulk, particularly in relation to the existing condition, and because perspective will make them appear taller in sensitive views. The other sites and blocks are more acceptable as they are generally offset from main vistas, and so are masked more by other buildings and are seen in a context that contains some tall and large buildings. Taken overall and with their high density and height, they would all together produce considerable and a more continuous mass as a skyline and do change views from sensitive areas.

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9.281 The development would enhance the appearance and function of Lionel Road, providing significant new areas of attractive public realm, assisting in connecting the site to its surrounds and improving permeability from areas to the north of the site to the river, as well as creating a new east-west route. Opportunities are created for further improvement to traffic management, and high quality architecture that would help to regenerate the site and enhance its townscape value. The stadium itself, although a large structure, would add a unique building to the area, which adds to local distinctiveness and character and cultural heritage of the area, though further details of some elements need review to minimise impacts on the Steam Museum cluster of listed buildings and ensure its legibility along Lionel Road.

9.282 The development would on the whole not significantly alter the overall character and appearance of surrounding conservation areas, though impacts on settings of Kew Bridge conservation area and its listed buildings are greater owing to its proximity to the new tall buildings that are out of scale. Some views out of the conservation areas towards the site are harmed, especially from certain vantage points in Wellesley Road, Strand on the Green, and Kew Green conservation areas, and settings are harmed in particular of Strand on the Green seen from the Richmond conservation areas. Paragraph 138 of the NPPF states that not all elements of a World Heritage Site or Conservation Area will necessarily contribute to its significance, and some impacts are negligible and this is noted. Nevertheless as a consequence of the harmful impacts found, the development is considered to breach policy ENV-B.2.2 relating to conservation areas as there would be some adverse impacts on nearby conservation areas. This in turn means the development would breach policies ENV- B.1.2 and ENV-B.1.3 in respect of tall buildings as there are harmful impacts on sensitive places (i.e. conservation areas) and similar policies of the LP (7.1, 7.4 and 7.7)

9.283 There is also some impact on the Royal Botanic Gardens WHS and its buffer zone, as the upper parts of some buildings are visible in certain views, however these infractions are minor and are not considered significantly harmful so they would not reduce the ability of visitors to appreciate the Outstanding Universal Value, integrity, authenticity or significance of the Gardens, thereby complying with policy 7.10 of the LP.

9.284 It is also worth noting that at this point paragraph 65 of the NPPF should be considered. It says that local planning authorities should not refuse planning permission for buildings or infrastructure which promote high levels of sustainability because of concerns about incompatibility with an existing townscape, if those concerns have been mitigated by good design (unless the concern relates to a designated heritage asset and the impact would cause material harm to the asset or its setting which is not outweighed by the proposal’s economic, social and environmental benefits).

9.285 At a broad level the development of housing on a brownfield site within an established urban area can be considered to be sustainable; however the buildings themselves do not promote a net benefit in terms of sustainability, although no doubt designed to “wash their own face”, and conditions would ensure the buildings would meet current standards in respect of energy efficient building requirements. Where

122 additional environmental features could be provided to increase the net benefit, this should be designed so that their additional impact, for example, in visibility or distracting appearance can be assessed.

9.286 In this instance the Design Code, use of quality materials and finishes and public realm works will reduce the identified harm, but owing to the significant height of the buildings and the sensitivity of certain views affected by them, there is likely to be some residual harm, some minor, but as identified above some would be significant.

9.287 The NPPF provides further advice for such situations, stating at paragraph 133 that: Where a proposed development will lead to substantial harm to significance of a designated heritage asset, local planning authorities should refuse consent, unless it can be demonstrated that the substantial harm or loss is necessary to achieve substantial public benefits that outweigh that harm.

9.288 And at paragraph 134: Where a development proposal will lead to less than substantial harm to the significance of a designated heritage asset, this harm should be weighed against the public benefits of the proposal.

9.289 As noted above there is some harm to the surrounding environment, with some being less than substantial such as to the WHS and some views from conservation areas, but other harm is substantial such as to Kew Bridge Conservation Area and other sensitive views identified. Given the above assessment, officers accept there are a number of departures from the policies of the Development Plan, though there are also many other policies in support of the development. Section 38(6) of the Planning and Compulsory Purchase Act says that if the development does not accord with the Development Plan then it should be refused, unless material considerations indicate otherwise. From this two questions arise: 1. Overall does the Development Plan support the application? 2. If it does not, are there other material considerations that would justify the proposal not being in accordance with the Development Plan? In other words do the benefits of the development outweigh the harm?

9.290 Given the cumulative nature of the breaches recognised, and that that some ‘major’ and therefore substantive harmful impacts would result, officers consider that on an overall basis the development is not in accordance with the Development Plan, and it is a departure from it. Consequently the assessment must take account of other material considerations including the wider public interest derived from economic, environmental and social benefits of the development, the latter relating primarily to community benefits associated with the stadium, to determine if these outweigh the harm. This assessment continues in later sections of the report.

E. Archaeology and other heritage 1. Archaeological investigations

9.291 The NPPF and LP (policy 7.8) emphasise that the conservation of archaeological interest is a material consideration in the planning process. Paragraph 128 of the

123 NPPF says that applicants should submit desk-based assessments, and where appropriate undertake field evaluation, to describe the significance of heritage assets and how they would be affected by the proposed development. If archaeological safeguards do prove necessary, these could involve design measures to preserve remains in situ or where that is not feasible archaeological investigation prior to development.

9.292 Much of the site forms part of the Archaeological Priority Area that recognises the prehistoric potential of the Thames flood plain at Kew Bridge and London Romano- British Road. In light of this the applicant completed an Archaeological and Cultural Heritage Desk Based Assessment, which has been submitted.

9.293 This assessment concluded that the application site has not been subject to any previous archaeological investigations and as such, the buried archaeological potential of the application site remains unknown.

9.294 In the absence of on-site archaeological investigations, the applicant initially used evidence from investigations and research in the wider locality to predict the archaeological potential of the application site. Archaeological investigations across the wider area indicate the potential for the recovery of archaeology from the prehistoric, Romano-British, and medieval to post-medieval period to be moderate.

9.295 Given the scale of the proposed scheme and the archaeological potential of the site good practice recommends a staged approach to archaeological mitigation with this having been agreed with English Heritage.

9.296 Geotechnical studies and field work has been carried out, with this to inform an archaeological watching brief that would oversee further investigations once the site is free of development and construction activity begins, with this work to be subject of conditions. The results from the trench investigations carried out to date show there is little evidence for pre-20th century activity on the site, however as these investigations cover only a small part of the site, the archaeological work would need to continue through to pre-commencement and the construction stages in accordance with a programme of works to be agreed by condition with English Heritage and the Council.

2. Non-designated heritage

9.297 Paragraph 135 of the NPPF states the effect of an application on the significance of a non-designated heritage asset should be taken into account in determining the application. In weighing applications that affect directly or indirectly non designated heritage assets, a balanced judgement will be required having regard to the scale of any harm or loss and the significance of the heritage asset.

9.298 Construction of the stadium requires demolition of the existing buildings on the Central site, whilst housing on the Duffy site would require demolition of a number of buildings. The only existing building of any architectural or historic merit is a former stable block adjacent to Lionel Road South. This building is two-storey and constructed with London brick and a slate roof. It has not been identified as having any heritage significance, and was not included within the recently designated Kew

124 Bridge Conservation Area (2004). Areas of cobblestones, some partly covered over are also found on the main site. The loss of these elements has been the subject of objections who consider these to be of significant heritage value, including a petition with 225 names.

9.299 Externally, the original building appears to have been altered with an extension to its northern side. Internally, the building is much changed and sits in a landscape that no longer resembles its original context, which was once a market garden and coal storage, whilst the cobbles are found in a much altered form, having been partially surfaced over.

9.300 The applicant considers that mitigation in the form of Historic Building Recording, including archaeological recording prior to demolition as a condition to the planning permission would help to mitigate its loss through detailed preservation by record. This is true, but it first must be fully assessed whether the building:

(i) Is worthy of listing? (ii) Can be retained? (iii) Can be relocated elsewhere? (iv) Can have its component parts used in the new development?

(i) Listing

9.301 Many buildings are interesting architecturally or historically, but, in order to be statutorily listed, a building must have “special” interest. Selection Guides for different building types are published on English Heritage’s website. These provide detailed technical information about each building type. The guide on Agricultural Buildings refers to stable buildings, stating that:

Free-standing stables began to be built from the sixteenth century. They are normally two-storey buildings with a hayloft above and the horses stalled across the building, with a central door between two windows along one side. The floors were cobbled, and later of brick, with drainage channels laid across the floors.

9.302 The building dates from the late 19 th Century (estimated c1870s) and likely served as stables for a nearby coal store/ gas works and possibly other uses such as the local market. Guidance on listing of buildings makes it clear that they must be assessed on their own merits, though certain features will make them more worthy of listing. In this case the stable block, though a fairly attractive building, has no special architectural or historic merit that would see it worthy of designation as a listed building.

9.303 In this regard, the building, although a surviving remnant of the past, has no extra claim to special interest on grounds of rarity especially noting the existing listed stables at nearby Gunnersbury Park, it does not demonstrate any specific vernacular architecture or have representative or distinct features such as an intact interior or examples of special farming practices. Additionally, greater discrimination is urged post 1840-1880, with only buildings dating from prior to 1830 being prime candidates for listing. The Victorian Society objects to its loss as being unnecessary, also stating it reflects area’s rich 19 th century heritage which includes the nearby Steam Museum buildings and it should be reused. Although a remnant building, it has no

125 architectural or historic associations making it worth listing, including any with the steam museum cluster of buildings. Therefore the loss of this item of heritage is not significant, whilst it is noted that the building is clearly within the proposed stadium’s footprint, so its demolition is necessary to build the stadium.

9.304 Therefore, while it has some aesthetic and historic value, the stables are not worthy of listing. Additionally, even if the building was considered potentially suitable for listing, its footprint is overlapped by the proposed stadium, which would compromise the delivery of the stadium, whilst moving or redesigning the stadium as suggested by the objector would still see any retained building’s value severely comprised by proximity to a much larger structure, devaluing its setting and worthiness for listing.

(ii) Retention

9.305 Retention of this building as existing would necessitate would impact on the stadium design with its access/ turnstile needing redesigning noting the stadium footprint overlaps with the stable block. It would also result in loss of the new public open space and cycle parking on the southwest side of the road. Given the conclusion of the previous section, this argument is not supported.

9.306 As a related issue an objector to the loss of the stable building has suggested this realignment of Lionel Road, to facilitate retention of the building. However this However this realignment of Lionel Road would not address the changes required to the stadium design noting their overlapping footprints. Such work would also be a very significant cost. The applicant states this cost could be funded by issue of bonds relating to potential energy savings resulting from energy efficient building practices and a centralised renewable energy and utilities system within the development. It is claimed this would generate financial returns for investors through bonds managed through an Energy Service Company (ESCO). The objector also states the building could be retained without compromising the stadium’s function as it could incorporate turnstiles, but it is also put forward that the building house the energy centre. Officers have noted this proposal, but do not consider it would justify retention of the building for a number of reasons. Firstly, the retention of the building is not proposed by the applicant, and thus the application must first be considered on this basis, with officers concluding that the building is not an item of heritage worthy of retention. Secondly, although a central or district heating/ energy network scheme is desirable and its inclusion needs to be considered within the development, a system in the manner suggested by the objector is not presently proposed in the application, with officer assessment to consider the submitted scheme on its own merits. Thirdly, the objector’s proposed bond arrangement is effectively a speculative financial instrument, which requires third party investment and would also necessitate up front capital costs for the scheme that are not included in the application and it is not clear who would guarantee the bond. It is suggested capital costs could be financed from government grants at that this be secured by condition, however a condition requiring reliance on a possible government grant for an item not proposed in the application lacks certainty for delivery and viability. Taking account of the implications for the function of the stadium and the costs associated with the retention of the building as suggested by objectors, the retention of the building is not justified, as this would potentially reduce the viability of the whole scheme, and ultimately affect the delivery of the stadium and its benefits.

126 (iii) Relocation

9.307 This is unlikely at the current time, as there are no local candidate sites.

(iv) Reuse

9.308 Reuse of the constituent parts of the stables, and the cobblestones, within the fabric of the new development has been discussed and agreed in principle with the applicant and would be secured by condition. The following measures are proposed:

• Prior to demolition, undertake an accurate measured and photographic survey as a record of its presence. • Carefully reclaim bricks from the existing building and re-use them in selected parts of the proposed stadium. • Carefully extract existing cobble sets and re-use them in the new public realm to outline the footprint of the stable block. • Provide a change of material in the west lower concourse to outline the footprint of the stable block. • Provide a permanent information board on the west elevation explaining the history of the stable block and the re-use of the materials around the stadium.

3. Conclusion

9.309 The application has provided an adequate plan of management for protection of possible archaeology on the site, whilst the loss of other non-designated heritage on the site is satisfactory as retention is not feasible with the current design and the loss of heritage is outweighed by the benefits of the development.

F. Stadium Operation and Impacts

9.310 Policy C.5.1A of the UDP applies to new stadia, and seeks to ensure impacts from the stadium’s operation, including access and egress are acceptable and safe, with disturbance of other uses and neighbours minimised.

9.311 The layout of the development includes housing in close proximity to the stadium, and potential routes to the stadium from various public transport modes would go through residential areas off Green Dragon Lane, along Kew Bridge Road, Chiswick High Road and in the Strand on the Green and Wellesley Road areas.

9.312 The stadium would be used for football for 26-28 games a year, with most taking place on Saturday afternoons (typically 3:00pm kick off), and up to six on a Tuesday evening (typically 7:45pm kick off). At other times it would accommodate the management offices of BFC, and also accommodate offices for the BFC Community Sports Trust, the Learning Zone, and the Interim Education Centre. On non-match days the stadium’s function rooms and hospitality facilities would be available for commercial use such as for conferences.

1. Matchday Use

9.313 Many objections raise concerns about the impacts of large crowds, including the influx of non-residents to the area and the associated potential for anti-social

127 behaviour, hooliganism, property crime, safety hazards, noise and general overcrowding. Disruption of access to other attractions such as Kew Gardens and Kew Steam Museum, and use of riverside walkways and pubs are also concerns. Other objections relating to rock concerts and rugby may be discounted as they are not currently proposed and would require a further planning application.

9.314 The proposal would significantly increase the capacity of BFC compared to its existing ground (extra 7,700), and would allow it to cater for larger numbers of away supporters. Consequently, if used to capacity, larger numbers of people would be coming and going in the area, with the relocation shifting activity to new areas not previously subject to significant impacts from a football stadium. This would create both real and perceived impacts on local residents, primarily through disruption on match-days from crowds using public transport such as trains and buses, using footpaths, and additional parking demand. Other impacts such as litter, noise, and use of outdoor areas and public houses are also likely.

9.315 Some impacts are inevitable with large crowds, and although the disruption would be limited to match days and temporary in nature, without satisfactory management they would potentially have negative effects on residents that do not presently experience such impacts. The major impacts expected are discussed below, though detailed traffic and transport effects are dealt with separately later in the report.

(i) Safety

9.316 Safe use of the stadium for spectators and people nearby is governed by a raft of non-planning requirements and legislation. BFC presently play football less than a mile away and are subject to various licensing, policing and management controls from the Football League, with stadium safety certified under the Safety of Sports Ground Act 1975 and spectator standards regulated under the Football Spectators Act 1989. A similar regulatory regime would apply to the new stadium, though being all-seater, it would be compliant with requirements for the Championship division, unlike Griffin Park, which includes an area of terracing which is presently not allowed in higher divisions. The local authority is responsible for issuing and enforcing a safety certificate.

9.317 A safety certificate would be issued following assessment of compliance with standards and guidance for capacity, management, circulation, seating, access, fire safety, communications, medical and first aid provision, services, media provision and other uses within the stadium. Other regulatory controls including Building Regulations and Fire Safety also apply. It is noted that the stadium design has been rigorously tested to demonstrate compliance with relevant standards. In any event the stadium cannot be used without the necessary certification and so safety is able to be satisfactorily addressed through other controls.

(ii) Access

9.318 At full capacity there will be 20,000 people on the site, with these people arriving from all directions and variety of modes of transport. Careful design and management is necessary to ensure efficient access and egress, and to minimise disruption to local transport networks and neighbouring residential areas. Turnstiles and entrances are provided at a number of points around the stadium, with these

128 areas linked via the stadium concourse. The new bridge over the railway from Capital Interchange Way is integral to the stadium proposal, as it provides access and egress to the East Stand which has a capacity of 5,000. Without this bridge the capacity of the stadium would need to be lowered to a maximum of 15,000 for safety reasons.

9.319 Fuller impacts on transport modes and routes are discussed below, but once people are at the site their movement would be satisfactory, with the concourse areas providing new public realm where people can move safely across the site, though temporary closure of Lionel Road South to through traffic may be necessary for approximately ½ an hour before and after games when crowds are at their greatest. Space for 400 cycles has been provided to encourage cycling. The concourse area would be landscaped robustly to cater for significant crowds, but also show sufficient quality and detail to make these spaces attractive. A key element in the access plans for the stadium is the opening of the underpass from Kew Bridge station and creation of a new ramped walkway direct from the station to the concourse. This will facilitate access to the stadium and crowd management and egress to the station, but marshalling will be required to maintain access for non-football users.

(iii) Noise

9.320 LP policy 7.14 seeks to minimise noise pollution. During football matches there would be likely to be some occasional crowd noise (cheering etc) and from the PA system that could be heard outside the stadium including at neighbouring residential areas and major outdoor spaces. This noise would be intermittent and would take place only on match-days (up to 26-28 days per year). It would not take place during early mornings or late evenings, and occurs in an area that has some other noise from road and aircraft traffic, as well as occasional outdoor events that generate noise (e.g. outdoor rock concerts at Kew Gardens (6 evenings a year)). It is noted that nearby Griffin Park is a similar distance to Kew Gardens. Conditions limiting the use and number of events are proposed to minimise impacts. Therefore this is not considered to be unduly harmful to the usability of outdoor spaces near the ground or the living conditions of residents in the locality. Griffin Park sits amongst terrace housing in closer proximity to any of the existing residential areas near the site and is able to operate without undue impacts on the living conditions of neighbours from noise and disturbance. The stadium design has attempted to maximise the amount of noise retained inside the stadium to enhance the atmosphere. Residents of the new dwellings would need to close windows during matches to meet relevant noise standards but the intermittent noise is not considered to significantly affect liveability of the flats and occupants of these flats would be choosing to live next to the stadium and the impacts are for a relatively short duration.

(iv) Crime and anti-social behaviour

9.321 In respect of football related crime, BFC operates at Griffin Park amicably alongside residential properties that adjoin all four sides of the ground. Crime statistics show that the area containing Griffin Park has no greater crime levels than other surrounding areas despite the presence of large numbers of football fans, with crime rates being lower than commercial areas such as Chiswick High Road. Overall in the 2012/13 football season there was an average of less than 1 arrest made per match inside and outside of stadia in England (Premier League 1.90, Championship 1.13,

129 League One 0.42, League Two 0.29). Notably there were only 4 arrests of Brentford supporters related to football games and associated activity (24 hours either side of games) in the 2012/13 season (2 at home and 2 away), and 3 arrests in 2011/12 (1 home and 2 away) indicating anti-social activity associated with the club is very low.2

9.322 Matches are discussed in advance with the Metropolitan Police and resources are deployed according to any risks identified. Although risk of crime appears to be low, large crowds can be intimidating and other disturbances from noise, littering and overcrowding is possible and so measures to manage such impact are necessary to ensure anti-social activities are minimised and to give comfort to people living or visiting the area that would be affected by spectator movements.

2. Stadium Management Plan

9.323 To ensure the stadium functions well, with efficient access and egress, and to minimise disruption to activities and living conditions of non-spectators and residents in the area, extensive management on match-days is proposed.

9.324 The application includes a Stadium Management Plan (SMP), a collection of related documents that will oversee the safe operation and management of impacts from the use of the stadium. The SMP would manage public safety, crime prevention and local traffic and parking management related to the use of the stadium. It has five elements as follows:

• Operations Plan – Led by the Metropolitan Police. Its purpose is to manage crowds and traffic movements outside the stadium. This plan will be prepared by the Police in consultation with BFC and organisations responsible for the transport network (LB Hounslow, TfL and Network Rail).

• Events Management Plan – Required prior to issue of a Safety Certificate it would need licensing approval from the Council and the Sports Ground Safety Authority.

• Local Area Management Plan (LAMP) – Led by BFC, but would be developed in consultation with LB Hounslow, neighbouring boroughs, Police, TfL, railway providers and local amenity groups. It aims to ensure public safety through defining the primary pedestrian network for movement to and from the stadium and managing its use. It would cover many functional issues such as post match litter collection and street cleaning, marshalling of supporters awaiting transport and along key access routes, match day signage, maintenance of access to transport etc for non-football users, communication with residents, liaison with local public houses, and information for stadium users. One key part of the LAMP would be a spectator retention strategy, which would aim to keep people inside the stadium after matches so as to allow crowds to disperse at a more regular rate. This could be achieved through promotions, interviews, hospitality and information on transport conditions. The current Lionel Road Liaison Group would be maintained to facilitate local input.

2 ‘Statistics on football-related arrests and banning orders Seasons 2012-13’ and ‘2011-12’, Home Office

130 • Stadium Travel Plan – Led by BFC, it aims to maximise use of sustainable transport to the stadium on match days, and would be secured through a s106 obligation.

• Monitoring Programme – This would monitor the outcomes of use of the stadium and evaluates how effect measures to minimise harmful impacts have been such as the levels of public transport use, complaints etc.

9.325 The Operations and Events Management Plans are required separately from the planning process. This SMP would be similar to arrangements for other sports stadia in built up areas. The LAMP and Stadium Travel Plan will be integral to managing general matchday impacts. Both plans would be dynamic and able to react to changing circumstances and feedback from events, including comments from local residents.

3. Non-match days

9.326 The stadium would be used on non-match days by BFC management and the associated community uses, these being the Learning Zone, offices of the BFC Community Sports Trust and the Interim Education Centre. These operations would ensure activity on non-match days, the uses operating during normal business hours. They are not expected to have significant effects on the environment.

9.327 Other possible non-match day uses for the stadium facilities include use of hospitality areas for functions and conferences in order to generate income for the club and make full use of the stadium. This use would be ancillary to the stadium’s football use and would not be of a scale likely to generate excessive impacts on the environment noting there is some parking for the stadium on site.

4. Conclusion

9.328 The provision of the stadium, with its capacity for 20,000 spectators, would be likely to result in some disturbance and disruption of the local area, including residents of nearby areas. Such impacts are however intermittent, with them occurring on match days only. BFC currently operate nearby within a tight urban environment, albeit at a smaller scale, without significant trouble. Comprehensive management of match day operations covering all aspects of the stadium’s use, including transport, safety, access, and policing will be necessary. The overarching Stadium Management Plan, which would be similar to similar arrangements for other stadia in urban areas such as Arsenal, Chelsea and Fulham is appropriate and would adequately control most impacts. However despite such measures to minimise concerns, there would be some unavoidable inconvenience and disruption from large crowds being introduced to areas that formerly did not experience such impacts. Where this is the case, the temporary, intermittent nature of the impacts should be balanced against overall benefits of the development and in this regard it is concluded retention of BFC in the area, and securing its long term survival is considered to be of wider benefit.

G. Traffic and Parking

1. Transport Assessment

131 9.329 The NPPF includes a core principle on the need to actively manage patterns of growth to make the fullest possible use of public transport, walking and cycling, and focus significant development in locations that can be made sustainable. It requires all developments that would generate significant levels of movement to be supported by a Transport Assessment and says that development should only be prevented or refused on transport grounds where the residual cumulative impacts of development are severe.

9.330 Paragraph 34 of the NPPF says that developments which generate significant movement should be located where the need to travel will be minimised and sustainable transport modes maximised.

9.331 The LP and UDP contain policies with similar objectives. UPD policies ENV-B.1.1, T.4.3 and T.4.4 aim to ensure traffic generated by development does not prejudice the free and safe movement of pedestrians, cyclists, public transport services or existing traffic. LP policy 6.3 requires assessment of cumulative impacts on transport capacity to be considered locally and over the wider network, whilst other policies such as 6.9 (Cycling), 6.10 (Walking), 6.12 (Road Network Capacity) and 6.13 (Parking) also provide guidance for transport assessment.

9.332 The Transport Assessment submitted addresses both match day and non-match day impacts, and accounts for cumulative impacts from other committed development schemes in the locality. In respect of the stadium, its location is consistent with objectives of the BAAP, and it is sequentially preferable to other possible locations given its higher PTAL than alternative sites.

9.333 The PTAL of the site ranges from 3-4, which is a moderate level of accessibility. Public transport services within a maximum walking distance of 640m for bus services and 960m for rail/ underground services include the 65, 237, 267, 391, 440 and H91 buses, London Overground and District Line Underground services from Gunnersbury Station, and Southwest Train services from Kew Bridge station.

9.334 The site sits amongst a network of busy major roads, with the A406/205 Kew Bridge Road/Chiswick High Road, which adjoins Lionel Road South at its eastern end. This road is part of the inner ring road of London (North/ South Circular). Other major roads include the M4 motorway and A4 (Great West Road), which extend east-west from Chiswick roundabout and are located 300 metres to the north, and the A315 which heads to Brentford to the southwest from Kew Bridge junction. Both Lionel Road South (one-way) and Capital Interchange Way, provide an alternative route to the A4 from the south, avoiding Chiswick Roundabout, though only the former is heavily used in this manner.

9.335 Existing traffic conditions are known to include congestion at various points, namely at the:

• Junction of Kew Road/ Kew Bridge Road where large queues occur on the southern approach to the junction of Kew Road and the eastern approach on Kew Bridge Road, in all time periods. • Junction of Kew Road/ Wellesley Road in an eastbound direction in all peak time periods, queues from the junction of Kew Road/ Kew Bridge Road block through

132 this junction towards Chiswick Roundabout. In the PM and Saturday peak periods the approach of Wellesley Road experiences blocking due to the queuing of traffic downstream from Kew Road/ Kew Bridge Road. • Junction of Lionel Road South/ Great West Road at certain points within each of the peak periods traffic queuing does so in two lanes at the stop line on Lionel Road South. Additionally on the approach of Lionel Road South, in conditions where moderate queuing occurs, traffic queues over the mini roundabout directly to the south of the approach. Traffic at this junction is blocked downstream by queuing traffic in the AM peak. • Chiswick Roundabout in the Saturday peak large amount of queuing occurs on Gunnersbury Avenue. Internal queuing occurs on the internal links of the roundabout in all peak periods. This internal queuing affects the movement of traffic through the junction. On occasion traffic queues back through and from the junction of Kew Bridge Road / Wellesley Road and onto Chiswick Roundabout, this causes some blocking to occur on Chiswick Roundabout.

9.336 Access to the site would be from Lionel Road and Capital Interchange Way. The latter would be the site of a new bridge over railway lines, providing access for pedestrians and vehicles to the East Stand of the stadium, and the Central Eastern housing plot. This bridge is therefore essential to the scheme and so if approved a condition requiring its completion prior to use of the stadium and occupation of any dwellings is recommended. Servicing for the stadium and associated facilities is from a dedicated service yard located within the southern stand, east of the main entrance, with the access off Lionel Road South. An emergency vehicle connection route is provided between Lionel Road South and Capital Interchange Way via the Stadium concourse and the new bridge connection.

2. Match days

9.337 The applicant has assessed the impact of a football matches in detail, based on the capacity of 20,000, and as such is a ‘worst case’ scenario. Data from the club’s supporter records has been used to inform the assessment. However, there is no assessment of any other uses such as concerts or rugby, so any permission would be conditioned to allow only football use, as trip patterns and timings from other events would vary from that which has been assessed. It is noted further information in respect of transport was submitted in accordance with Regulation 22 of the EIA Regulations in response to queries from the Council and Transport for London (TfL).

9.338 The total number of home matches scheduled to be played is 26-28 depending on cup progression, with the majority on Saturday afternoons (commencing at 3:00pm and ending at around 5:00pm. Around 4 home weekday games are usually scheduled (7:45pm to 9:45pm). Progression in cup competitions or postponement of fixtures, could lead to extra games being played on weekdays. The arrival/departure pattern of weekday fixtures is likely to be less spread out as people attend games after work. The arrivals are also likely to coincide with the end of the PM network peak when people are returning from work.

9.339 Based on surveys of existing supporters and away fans at various games and modelling, the mode of transport for the maximum of 20,000 spectators is expected to be as follows.

133 Mode Share Walk 10% Cycle 2% Car Driver 14% Car Passenger 21% Coach 4% Other (mini-bus/ taxi) 1% Public transport 49% Total 100% Table 6: Transport modal share

(i) Pedestrians

9.340 The assessment predicts 10% of spectators would walk to the stadium from the local area, but also estimates that the majority of other spectators would walk for part of their journey (from public transport or to car parking) meaning that there would be large numbers of pedestrians before and after matches. The improvements to Lionel Road and the new railway bridge will assist in pedestrian movement, the former adding a 2m wide pathway to the southern side of Lionel Road South, which is in addition to the widening of the existing footway.

9.341 Spectator arrivals are likely to be dispersed over a longer time period, with departure much more concentrated. Post match, pedestrians would quickly dissipate across the pedestrian network in all directions. A large number (2,400) are predicted to walk to Gunnersbury Station with a total of 6,000 walking to public transport accessed from Chiswick High Road east of Lionel Road (includes buses, other stations). This would result in a level of crowding on Chiswick High Road, and the route to Gunnersbury station, which would be from Capital Interchange Way or Lionel Road up Chiswick High Road, across Chiswick Roundabout continuing on Chiswick High Road to the station. This is expected to significantly restrict pedestrian speed and movement, and would make it difficult for pedestrians going in the opposite direction.

9.342 Such impacts are disruptive but occur around other larger stadiums found in urban residential areas e.g. Fulham, Chelsea, and Arsenal, and large crowds (12,000+) have recently been accommodated on narrow residential streets around Griffin Park without major incident.

9.343 Other pedestrian routes outside of the site would also accommodate significant crowds. With BFC looking to provide an element of match day car parking by agreement with nearby commercial premises along the Great West Road, the route to the north and then the west of the site is also likely to be heavily used. No improvements are proposed for this part of the highway which has a narrow footway and ‘hump back’ bridge with poor forward visibility. Owing to this, pedestrians using this bridge to access the car parking areas to the north of the railway lane could potentially take longer to clear due to the distance they need to travel than that suggested in the transport assessment, which could lead to delays to traffic and this area will need either public realm improvements and/or careful oversight through the LAMP (N.B. a contribution of £45,000 for improvements is recommended this

134 regard). During the heaviest discharge of match day crowds it is likely the Lionel Road South will be closed for short periods (approximately 20-30 minutes). During this time Capital Interchange Way, an alternative route to the A4/M4 would remain open, with pedestrians crossing that road to be stewarded. The LAMP would also include a post-match retention strategy, aiming to keep spectators within the stadium through hospitality, televised matches, promotion, interviews and incentives to limit the number of people leaving at the one time.

9.344 The impacts on nearby pedestrian routes will, despite management, be substantial for a temporary period, but they are not so disruptive that day to day living in those areas is harmed to a significant degree as these conditions would only occur for the short period following the immediate discharge of crowds on match days. Given the short duration of the impact and its intermittent occurrence, and subject to appropriate management of surrounding streets through the LAMP in cooperation with the Police, to ensure people stay on designated routes and proceed safely, the disruption, is on balance considered acceptable, given positive impacts of the stadium.

(ii) Rail

9.345 The site is very close to Kew Bridge railway station, which is a 5 minute walk from the whole development. Gunnersbury station is approximately a 10 minute walk from the site, and these two stations are expected to be key routes for public transport users accessing the stadium. Notably however, football supporters are known to be willing to walk longer distances and at higher speeds than typical public transport users, and accounting for this there are other stations within a 30 minute walk, which are Acton Town, Chiswick Park, Turnham Green, Boston Manor, Northfields, Ealing Common, South Acton, North Sheen, Chiswick and Brentford, which could also be used on match days. The forecast rail usage is as follows (based on the 20,000 capacity).

Station Supporters Kew Bridge West 1,443 Kew Bridge East 1,323 Gunnersbury South 648 Gunnersbury North 1,792 Chiswick Park (2-way) 470 Acton Town (2-way) 784 South Ealing (2-way) 328 Table 7: Railway use

9.346 Kew Bridge station – This station is next to the site and provides links to Chiswick and on to Waterloo (east) and Brentford, Isleworth, Hounslow, Twickenham, Feltham and Staines (west), with 4 trains in each direction per hour on weekdays and Saturdays. Its platforms have been recently extended to take 12 carriages. The application proposes re-opening of an underpass from the east bound platform under Lionel Road to the site and provision of a fully accessible ramp to the stadium concourse plus new stairs to street level. This would allow a large number of

135 spectators to be managed on the site, reducing potential disruption to the surrounding area.

9.347 Spectators using the station are predicted to be roughly equally split between those heading east and those heading west. At present there are 4 trains per hour in each direction on weekdays and Saturdays. Noting observed occupancy levels this would mean that queues, which are to be held in the underpass and concourse area on the site, would clear after 67 minutes, though no one is expected to queue for more than 20 minutes. Clearly after an event trains would be very busy, but this level of delay is not unusual around major stadia (e.g. forecasts for impacts on stations serving the new Tottenham stadium are up to 70 minutes). Additionally, South West trains is expanding capacity on this line, with the service to change from 8 to 10 carriages on weekday peaks with an additional weekday AM peak train and from 4 to 5 carriages on weekends by February 2015. The first services on Southwest Trains network with the new 10 car configuration will commence in December 2013. The new lengthened trains will take capacity to over 4,000 people an hour on weekdays and 1,600 on Saturday.

9.348 Access to the platforms from the site would by controlled by stewards, with spectators split for east and west platforms, with transfer to the west platform controlled and routed by the internal footbridge with no queuing permitted on stairs or footbridge. Platform densities would also be controlled to allow for alighting from incoming trains. TfL accepts the forecast usage and has no concerns, but notes that the stadium retention strategy and LAMP, as well as stewarding would help manage queues. Non-football entry to station and platforms would need to be maintained by Transport Police/ staff with steward assistance at existing street level entrance, and measures to secure this will need to be included in the SMP/ LAMP.

9.349 Other stations – Other stations in the area which spectators are expected to use noting their direction of travel and destination are Chiswick Park, Acton Town and South Ealing. Numbers using these stations would be able to be accommodated on the existing services. Elsewhere other stations within a 2km radius including Brentford, may also be used but the numbers are not significant.

9.350 Gunnersbury Station – Provides both London Overground and Underground services. It is within reasonable walking distance from the stadium and as part of the Underground network, it is expected to be heavily used on match days. Its use has increased considerably in recent years due to the increased employment at Chiswick Business Park. Improvements to the station have recently been undertaken to improve passenger flow noting the increased usage. It is also noted the new rolling stock is being introduced along these services with these to significantly increase train capacity on District line trains (extra 228 passengers per hour in each direction) from June 2014 to June 2016) and the Overground will have an extra carriage from December 2014, increasing network capacity by 20%.

9.351 Underground District Line services are at a frequency of 6 trains per hour for weekday peak hours and weekends. Overground services are 4 trains per hour for these times. Data shows the services exceed seated capacity only during AM and PM peaks, and are well below ‘crush’ capacity (full with seated and standing passengers) at all times, and so train services have adequate capacity. However the

136 capacity of the station and its operation are constrained by its gateline, the width of the stairs to the platform, and the platform size, all of which restrict how many people can use the station at the same time.

9.352 Noting the constraints of the station, in the busiest period after a game, some spectators will need to queue outside. The maximum number of people queuing, for a 5 minute period, as they wait for platform space is predicted to be 320, with the whole queue down to only 8 people after half an hour. In other terms 70% of the total number of spectators using the station would have left after 20 minutes, with 95% gone after 30 minutes and all having left after 35 minutes. Management of the queue would require control by station staff, Transport Police with assistance from stewards. It is proposed to form a queue on the public highway in front of the station and nearby shopping parade. Details of the arrangements for management of the queue would need to be included in the LAMP and secured by s106 agreement as part of the Stadium Management Plan. The broad principle of the plan will be to direct spectators via Chiswick High Road. This will allow the Wellesley Road access to be used by people exiting the station, whilst also allowing access to local residents.

9.353 With the vast majority of matches on a Saturday afternoon, the stadium use will not conflict with weekday rush hour activity. The arrival times for weekday matches (approximately 4 to 6 a season) will overlap with the end of the PM peak as spectators would be expected to arrive in numbers with the peak arrival being from 6:45pm to 7:15pm when 42% of spectators (1,030) would arrive for a 7:45pm kick- off. At the same time it is forecast that there would be 245 arrivals and 162 departures of other users. The impact of the football supporters would mean that during this period it would take 3 ½ minutes to clear the platform during which 32 people would arrive to use the station but would be unable to make their way to the platform owing to people leaving. The estimated queue of 32 people is similar to observed queues during the PM peak and noting the short delay and infrequent occurrence that this may occur, it is not considered a significantly adverse impact that would warrant refusal of the application.

9.354 It is noted that there is £620,000 of funds for improvements to Gunnersbury Station presently available and unspent, from a s106 obligation for Chiswick Business Park. Officers are presently working on progressing schemes that would improve accessibility and passenger flow at the station, though to date no schemes have been approved. Separately in accordance with LP policy 6.4 the development would be required to contribute to the wider economic regeneration and its transport through an obligation for the Mayor’s Community Infrastructure Levy (CIL) to fund Crossrail. The estimated CIL payment from the stadium development is over £1m, with the residential element to be determined once full details are submitted but this would be a significant amount (over £3m).

(iii) Buses

9.355 There are 17 bus stops within 640m of the site, served with high frequency by routes H91, 237, 267, 56, 391 and 440, with 7 additional bus routes within 2kms of the site which would be able to be utilised on match days. Bus stops within 400 metres of the site have been audited for accessibility and TfL notes that they are currently

137 equipped to a high standard with well-lit shelters, seating and timetable information provided, and no improvements are necessary.

9.356 Supporter bus trip traffic is estimated to total 3,235 people. Spectators would arrive/ depart along 18 directions/ services from around the site, with the largest volume coming and going from the west and southwest (80%), based on analysis of supporter records and quickest routes. The assessment shows that match day impacts are satisfactory with sufficient capacity for expected passenger numbers.

(iv) Cycling

9.357 Approximately 2% of spectators are expected to cycle, with 400 stadium cycle parking locations provided across the site. A cycle helmet store will be provided within the Stadium, which will be operated similar to a cloakroom. Cycle storage adjacent to Lionel Road would be available to commuters on non-match days. These spaces would be secured by condition.

(v) Coaches and taxis

9.358 A proportion of away supporters would come by coach. Coach parking is proposed along Capital Interchange Way, where 10 bays would be provided. This location would provide good access to the East Stand, which is to house away supporters. At present there is metered parking along Capital Interchange Way, with these to be suspended on match days and a weight restriction to deter overnight lorry parking. The impact of the temporary suspension of parking bays to allow coach parking on match days would be minimal as parking surveys show the existing 25 Pay and Display parking spaces are not heavily used during match times, with a survey showing only 8 were used on a Tuesday evening and only 1 on a Saturday afternoon. The temporary changes would require a match day Traffic Regulation Order (TRO), and the arrangements would be detailed in the Stadium Management Plan

9.359 Provision of a taxi rank and an arrangement for private hire vehicles on match days is proposed with these to be secured by conditions, and necessary TROs. It is recommended the LAMP includes a ‘taxi management plan’ for event days that includes information on the taxi rank, taxi marshals and the setting down and picking up of passengers for both taxis and private ire vehicles, with this to help minimise congestion as well as illegal touting by minicabs.

(vi) Parking and traffic impacts

9.360 Parking – The stadium has limited match day parking, with only 150 spaces available for the club at Capital Court site and 60 spaces under the Central East Site (inclusive of 9 disabled spaces). On match days 22 disabled parking bays would be provided. To minimise conflict with pedestrians and traffic congestion, access to the stadium car parking will be closed one hour before matches and for 30 minutes after a match.

9.361 Of the total spectators, the Transport Assessment predicts 14% would be drivers and 21% passengers in private vehicles, with a total of 2,591 cars expected for an attendance of 20,000. Where these cars will park and the subsequent impacts on traffic and parking conditions are a major concern for many objectors.

138

9.362 Surveys show that car drivers would park within 1.8km of the stadium, which could include areas of Brentford, Chiswick and Kew. Parking surveys of the area within 1.8km of the stadium were undertaken during weekday and Saturdays, before, during and after match times to calculate how many parking spaces were available. Studies of the existing stadium were also undertaken, and these reflected the estimated modal split for travel and also highlighted that car drivers tend to park on their approach to the stadium and prefer to park further away from the stadium in their direction of travel meaning they are unlikely to drive past the stadium in search of a parking space (with more supporters coming from the west and southwest).

9.363 The catchment area, which is a 1.8km walking distance from the stadium, covering large areas of Brentford, Chiswick and Kew, has 12,598 parking spaces, of which parking surveys showed 4,577 were free during the Saturday match period. It is noted that parts of Kew Green have a 7-day CPZ. Using methodology agreed with TfL (to set maximum parking availability below the full capacity/ occupancy level), and based on supporter surveys of existing parking impacts from matches at Griffin Park, the assessment predicts a total of 2,719 available on-street spaces would be available with the catchment area. This amount of parking would be adequate for the expected number of cars (2,591) for a 20,000 spectator match.

9.364 However the applicant has sought to reduce demand for on-street parking spaces and intends to secure up to 1,000 managed off street spaces through reaching agreement with nearby commercial premises with large car parks that have empty car parks on weekends/ evenings. The club has engaged a property agent who has found there is good potential for up to 1,000 spaces, with 750 sought along the A4/M4 to the west of the site to avoid local traffic impacts, with the remaining 250 spaces sought on the A4 immediately east of site. No agreements are yet in place, though the applicant has agreed to use their best endeavours to secure these, and has agreed that such spaces need to be pre-sold to ensure that vehicles do not circle around the area looking for parking spaces. Such car parking areas would also need to be well sign posted, and publicised, with this to be covered by a Match Day Travel Plan, which would be secured as part of the SMP through a s106 agreement.

9.365 Officers consider agreements for such parking are realistic and that this would reduce on-street parking demand on match days and consequently impacts on residential streets, as they would provide secure, allocated parking with this being more attractive than trying to find on-street spaces.

9.366 However, as no agreements are in place for this off-street provision, Members must consider the worst case, where such provision is not made, and car parking is all on- street. As discussed, the demand could be met by available spaces. Noting the parking surveys were carried out before, during and after matches, whilst Kew Gardens was open, and the direction of travel of the main supporter base, conflict with visitors to Kew Gardens is not considered to be significant.

9.367 Nevertheless it is recommended that the applicant provide funding for a possible match day Controlled Parking Zone (CPZ), for the area within a 10 minute walk of the stadium, with this to be consulted on with the objective of introducing a CPZ should parking demand become an issue or monitoring demonstrate that total car

139 use by spectators is higher than predicted levels, or occupancy of spaces exceeds 90% of capacity.

9.368 Traffic – Highway impacts for weekday and Saturday match-day traffic have also been considered. The assessment shows that the surrounding highway network is already congested when committed developments are taken into account and that the additional traffic generated has a small impact on this situation. The Transport Assessment concluded that by optimising signal timings it is possible to reduce the effects of the development to a minimal level, and that queuing between junctions is not forecast as a result of the additional traffic proposed, though some minor increase in queuing times would be experienced. TfL did not accept the original assessment, with a range of issues to be addressed, most notably further work to be done in modelling impacts of traffic generated on the adjoining road network, to compare different scenarios within the highway modelling with TfL’s comments forming the basis of a request for further information under Regulation 22 of the EIA Regulations.

9.369 The Transport Assessment also states that due to the forecast pedestrian flows, during a maximum capacity match, it may be necessary to temporarily close Lionel Road South (in-part) for a short period (20-30 minutes) to allow for safe crowd movement. This is predominantly expected to be associated with the immediate dispersal period following a capacity match, given that during this period the density of crowd movement is greater.

9.370 This has possible implications for Chiswick Roundabout as Lionel Road is used by traffic wishing to access the A4 and M4 and as such takes a significant amount of traffic away from the roundabout and was questioned in assessment of the originally submitted assessment with further modelling requested as described.

9.371 The further information submitted in accordance with Regulation 22 notes if Lionel Road were closed temporarily it would possible to maintain vehicle movements on Capital Interchange Way, which provides an alternative route to the A4/ M4. The applicant also made a comparison of the effect of the additional traffic flows on Chiswick High Road. This showed that the traffic diverted from Lionel Road South during a 20 minute closure after a Saturday match would be expected to increase Chiswick High Road eastbound flows to levels below the existing weekday PM peak hour, and significantly less than the existing PM peak hour for a weekday match day, meaning the road could accommodate a temporary diversion. As these other periods have already been assessed, no further assessment is deemed necessary for infrequent closures which will be in managed conditions.

9.372 Following receipt of the Regulation 22 information TfL sought further information to clarify impacts in respect of pedestrians using the section of Lionel Road South to the north of the site, securing details of arrangements for coaches and taxis, and requested a contribution of £1750,00 for an additional peak hour bus service, plus a supplementary traffic assessment for impact on the adjacent road network including from traffic diverted by the possible temporary closure of Lionel Road after matches. The applicant subsequently met with TfL to provide clarification, confirming arrangements for coaches and taxis would be addressed in the LAMP, as would pedestrian movements on Lionel Road, with the latter impact also to be mitigated by

140 a contribution of £45,000 for pedestrian improvements. A contribution of £175,000 for a bus service as requested (serving A315 Brentford-Chiswick) was also agreed.

9.373 The most substantive outstanding issue was the need to supplement existing modelling of match day and non-match day traffic impacts. In this regard, although TfL stated they welcomed the alternative modelling submitted with the Regulation 22 information, which supplemented the original assessment (which had been considered unsatisfactory), further micro-simulation of impacts between signalled junctions was necessary. In this regard, TfL’s response to the Regulation 22 information stated “…that the capacity of the network in relation to proposed development traffic should be determined with micro simulation modelling in order to provide the decision maker with a level of confidence about the impact of these proposals”. It is noted that the LB of Richmond have voiced their objection to the proposal. However, it is noted that the applicant has produced additional traffic modelling and extended their parking assessment south of Kew Bridge.

9.374 The applicant noted TfL’s request and liaised with TfL directly to use their model to supplement their assessment, though they noted that as the purpose of the exercise is to show the theoretical changes at the junction as a consequence of the proposed development, both individually and cumulatively with other developments, the already submitted model was a suitable evaluation tool, and that it had showed that overall the development’s effects would not be significant.

9.375 The results of the supplementary modelling aided the assessment of the impacts of the development road network performance already provided by the earlier modelling, but did not significantly alter the earlier conclusions. In this regard, both computer models assist in understanding how a network performs and critically the likelihood of ‘blocking’ occurring in congested areas, which could potentially lead to a form of ‘grid-lock’. T

9.376 The later results shows increases in average journey times of 2-3 minutes per vehicle (on an approximate 10 minute route), which confirm the findings of the model submitted with the Regulation 22 information that there would be some minor increases to delays through the road network. The queuing would be likely to occur on the edge of the network, where traffic is gated to control the number of vehicles getting onto the network. It is therefore unlikely that there would be significant additional queuing on the main junctions within the network as a result of the addition of the proposed development.

9.377 It is noted that this is worst case, without any peak spreading. As this would be only one part of a journey, the overall journey percentage impact would be lower. Whilst this increase in journey times is not desirable, it does need to be considered in light of general policy to only provide extra highway capacity as a last resort. It should also be noted that the scheme is providing sustainable transport measures which will also help to offset the traffic impacts.

(vii) Cumulative impacts

9.378 Cumulative impacts from concurrent events at other nearby stadiums such as Fulham, Queens Park Rangers (QPR) and Chelsea are not likely to be significant noting the programming of football matches of neighbouring clubs is already

141 considered by football authorities when compiling fixtures, and these matches are normally arranged for alternate weeks (e.g. this season there is only one date Brentford and QPR play at home on the same day). If there was an occurrence that both Brentford and the other nearby clubs both played home matches on the same day, specific management measures for those fixtures would be programmed in advance and agreed with the Police, LB Hounslow, and interested parties, controlled by the Stadium Management Plan and secured as part of the S106. Twickenham stadium is used for around 12 major rugby games over the football season some of which on Sundays, with most finishing by 4PM, ensuring that there would not be any regular clashes with fixtures at the proposed stadium. Impacts from other uses on the site (housing and commercial) on match-days were considered and they do not significantly affect the reported match day impacts.

3. Match day mitigation

9.379 Measures to minimise match day impacts on traffic and transport in the surrounding area are proposed in the LAMP, a Stadium Travel Plan, and obligations to be secured through a s106 agreement. These would be in addition to proposed works to the public highway of Lionel Road and new public realm, which includes the new railway bridge, new footpaths, underpass from Kew Bridge station, and improvement of the southern pedestrian entrance to Lionel Road South.

9.380 LAMP – The Local Area Management Plan would provide detailed procedures for management of coach parking, taxi and private vehicle arrangements, crowd control and stewarding at local stations and key pedestrian routes and crossings. It would also include details of how access to the public transport network, in particular Kew Bridge and Gunnersbury stations would be maintained for non-football users.

9.381 Stadium Travel Plan – A draft has been prepared in accordance with TfL guidance 3, and would provide a structured strategy with objectives and targets to maximise walking, cycling and public transport to travel to the stadium and communicate these options to supporters, with outcomes measured through ongoing monitoring to determine the progress of the plan.

9.382 BFC would appoint a Travel Plan Co-ordinator to oversee and monitor the plan, which would be in place for the lifetime of the stadium, and undertake programmes to promote sustainable travel and review the mode of travel to the stadium.

9.383 A key to the success of a travel plan is marketing and communication with the aim of raising awareness of the availability and benefits of sustainable modes of transport. To achieve awareness the Travel Plan would be highlighted by BFC on their website, through promotions and direct communications.

9.384 The plan targets would include limiting on-street parking to a maximum of 2,519 cars, with this monitored regularly. Monitoring would be carried out formally by an independent TfL accredited company using approved methodology with this to be funded by BFC and secured through a s106 agreement. If overall demand exceeds 2,519 spaces (controlled off-street and on-street) or the parking occupancy exceeds 90%, measures would be introduced to manage and reduce on street parking.

3 Travel Planning for New Development in London; incorporating deliveries and servicing (2011)

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9.385 The primary option to reduce demand for parking is to manage availability of on-street parking through the introduction of a match-day Controlled Parking Zone (CPZ). Such CPZ are common around many stadiums located in urban areas (e.g. Twickenham, Chelsea, QPR, Fulham, Arsenal, Tottenham). Typically they operate from 12 noon to 4:30pm on a matchday, restricting parking in designated areas to residents only (and visitors with valid permits), with their range dependent on the stadium size, travel modal patterns, and existing levels of parking stress.

9.386 In respect of any proposed match day CPZ, it is recommended that this cover an area within a 10 minute walk of the stadium, with the applicant to provide funding for consultation on introduction of a CPZ, with further money for implementation if a new CPZ (and variation of existing CPZs) was agreed. It would be recommended that where a match day CPZ was introduced, that the initial permit be at no cost to residents and that ongoing monitoring be undertaken through parking beat surveys as part of the Stadium Travel Plan to determine if there is a need for further controls.

9.387 Planning obligations – In addition to the LAMP and Stadium Travel Plan, which would be secured by a s106 agreement, planning obligations in respect of securing remote locations for off-street spectator parking and funding for a possible match day CPZ consultation, which if agreed would require further funds for implementation.

9.388 Constraints that cause peak hour congestion at Gunnersbury Station are noted, however this is an existing situation. The impacts of the stadium fall largely outside those peak times and subject to appropriate management, those impacts are satisfactory. Therefore the applicant would not be expected to make any contribution to alleviate an existing deficiency not related to the proposed development. TfL has recommended mitigation in the form of securing the proposed Stadium Management Plan and its complement of plans and measures including the possible match-day CPZ, as well as reviewing the pedestrian network to identify if any improvements such as removing clutter or enlarged crossings can be made, though the applicant’s survey of the pedestrian network did not identify any particular items needing improvement.

4. Conclusion (match days)

9.389 The stadium is located in an area with relatively good public transport links, which will reduce the need for spectators to travel by car. Existing public transport modes (rail, underground and bus) have been assessed as having adequate capacity to cater for a crowd of 20,000, though services will be very busy around match times, particularly evening games and post-match where numbers of people departing are more concentrated. Extensive management of crowd movements will be required through a LAMP as part of the Stadium Management Plan, with involvement from various authorities and transport providers This LAMP would also cover taxis, coaches, private hire vehicles and includes measures to minimise disruption of main pedestrian routes and disturbance of residential areas and to maintain access to public transport for non-spectators.

9.390 As the adjacent road network is congested and on-street parking demand in some areas is heavy, minimising car use is important to reduce adverse impacts on traffic and parking conditions. The Transport Assessment has modelled the expected

143 private car use and on-street parking availability within a 1.8km radius of the stadium during scheduled match times. The assessment indicates that sufficient on-street parking spaces are available in this area for the expected number of car users, though to minimise impacts the club will endeavour to secure dedicated off-street parking (1,000 spaces) at nearby office sites where parking would not be needed when matches are played. The proposed Stadium Travel Plan will promote sustainable travel use and also monitor set targets. It is recommended a match day CPZ be consulted on with the aim of discouraging car use to the stadium, with its introduction linked to monitoring of predicted and actual private car usage and parking occupancy levels, and where these are exceeded then contributions agreed under s106 for consultation on a match-day CPZ within a 10 minute walk of the stadium would be triggered to further control traffic and parking impacts and maintain them at an acceptable level.

5. Non-match days

9.391 On non-match days the uses on the site would include activity associated with BFC offices, and the related uses (BFC Community Sports Trust, Learning Zone, Club Shop and Interim Education Centre) and the uses of the housing sites (with ancillary commercial uses).

(i) Non-residential uses

9.392 On-site parking for the stadium on non-match days is located in the podium car park of the Capital Court site (150 spaces) and the Central East site (60 spaces), giving a total of 210 spaces (inclusive of 9 disabled spaces). BFC has advised that this amount of parking is the minimum necessary for its operations and that of the associated community uses. The parking is also intended for disabled users and corporate hospitality as well as staff.

9.393 In addition to this the proposed 160 bedroom hotel has 40 car parking spaces, and the stadium’s hospitality space is expected to be used or conferences (up to 5 per year) with up to 200 attendees and events such as wedding receptions, dinners, exhibitions etc. though with these on weekends and evenings they would not conflict with existing peak hours. The LP does not set a maximum parking standard for hotels but recommends parking be limited in areas of good PTAL with this aiming to reduce congestion and traffic levels. A coach parking drop off area for the hotel will be necessary and so this will be secured by condition with details to be provided with reserved matters.

9.394 For the purposes of trip generation assessment and transport impacts, the assessment has used the ‘worst case’ of all the uses plus a conference of up to 200 people, though this would only occur irregularly. The retail and other ancillary commercial uses are small scale and would serve local residents and pedestrians and are not expected to generate additional trips.

(ii) Housing

9.395 Parking - Up to 910 dwellings are proposed on the site. LP policy 6.13 seeks to limit parking provision and aims to strike an appropriate balance between promoting new development and preventing excessive car parking provision that can undermine cycling, walking and public transport use. It sets maximum standards as follows:

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No. of beds 1-2 3 No. of spaces < 1 per unit 1 to 1.5 per unit

Table 7: London Plan Residential Parking Standards

9.396 The LP also says that developments in areas of good public transport accessibility should aim for significantly less than 1 space per unit. This site has good transport links with a moderate PTAL. Adequate spaces for parking for disabled people (10%) must be provided and provision for electric vehicles is required.

9.397 A total of 585 parking spaces are proposed for the residential units with basement/ podium parking levels for each housing block, with 10% to be disabled spaces. Provision for electric vehicles is also proposed. The overall parking ratio is 0.64:1. These details would be secured by conditions and a Car Park Management Plan that addresses phasing and allocation to units. TfL’s comments urge a reduction on the parking provision to the minimum necessary noting the level of congestion that already exists on the local and strategic road network, but noting the moderate PTAL and that 20% of the units proposed are three-bedroom, the parking ratio is considered reasonable subject to consideration of impacts on the local and wider road network (discussed below).

9.398 Walking and Cycling – LP policy 6.9 says new development should provide cycling parking to encourage more cycling. LP policy 6.10 seeks to improve the quality and safety of London’s pedestrian environment to make walking more pleasant and a viable alternative to the private car.

9.399 Secure cycle parking for each unit would be provided within each housing block in accordance with London Plan standard and the location and number of these would be secured by condition. The extensive public realm improvements will make walking to and within the site more attractive and permeable than at present, and in particular this will enhance the north-south route from Gunnersbury Park and residential areas north of the A4/M4 to Kew Bridge station and recreational areas along the river. The proposed alteration to the curve at the junction of Lionel Road and Chiswick High Road would make that space safer for pedestrians.

9.400 Despite increased numbers of pedestrians in the area, it is considered overall non- match impacts on cycling and walking from the development are positive noting the improvements to the public realm and that the additional numbers of people using the network are spread over a number of routes.

(iii) Parking, traffic and transport impacts

9.401 The following table shows the expected traffic generation and modal split for non- match day uses, assuming there is a conference, so on typical days figures would be lower.

AM Peak Hou r PM Peak Hour Mode IN OUT 2-WAY IN OUT 2-WAY Rail/ 29 63 92 45 42 87 Overground Underground 47 106 153 78 66 144 Bus 35 68 103 52 47 99

145 Taxi 1 5 6 6 2 8 Car driver 113 149 262 112 126 238 Car 12 62 74 43 48 91 passenger Motorcycle 4 4 8 3 3 6 Cyc le 14 14 28 16 15 31 Walk 26 56 82 43 37 80 Coach 0 13 13 11 1 12 Total 281 540 821 409 387 796 Table 8: Traffic generation (non-match day)

9.402 Parking – Noting the PTAL for the site the level of off-street parking is sufficient for the development and this would be capped by a condition. To ensure any potential overspill of parking from new residents onto neighbouring residential streets that are not in a CPZ, levels of parking on non-match days would require monitoring as part of a Travel Plan, with the s106 agreement to secure this plan and funding for a potential CPZ. Should adverse impacts be identified then affected areas would be consulted about whether to introduce additional parking restrictions in the form of a residents’ only CPZ.

9.403 Traffic – The primary impacts on the local traffic network relate junctions and roads under management of TfL, and as such TfL has been heavily involved in assessment of the impacts of the development. TfL has raised concerns about the level of parking proposed and its potential to generate high numbers of vehicular trips resulting in peak hour congestion, which would be inconsistent with proposals to boost cycling levels and the use of other sustainable modes. Worsening of traffic congestion in the area is also a major concern of objectors.

9.404 As noted above, to ensure the full picture of possible impacts is available, noting the existing congestion on the road network, the applicant has liaised with TfL and the Council’s consultant to refine and clarify modelling to better understand the complex interactions between closely associated junctions, in particular Chiswick Roundabout.

9.405 The applicant’s assessment originally looked to include optimisation of signal timing at Chiswick Roundabout to minimise impacts, but TfL has advised that as Chiswick Roundabout already operates close to capacity and has been optimised using years of monitoring and expert specialist experience, possible benefits from alterations are unrealistic.

9.406 The further discussions indicate that owing to the existing complexity of movements and traffic levels that mitigation of additional traffic movements is difficult. Evidence shows that the junction, notwithstanding significant new land uses in its vicinity, has experienced little growth in traffic at peak times. This situation is common across the main road network and there are many potential reasons including capacity restraint, recessionary effects, ‘peak spreading’ and greater use of public transport.

9.407 Effectively it is argued that noting the theoretical modelling and the observed impacts, traffic will materially increase at Chiswick Roundabout due to the proposed development, but the analysis from a number of models shows that the development’s effects will not be excessive or severe enough to warrant any

146 highway works. There will be additional movements, though these are dispersed over a number of directions. Cumulatively these will add to the existing traffic but not significantly so, the main impact being the probable lengthening of peak hour congestion and increased journey times on a few minutes on average.

9.408 Public transport – Given the existing capacity and planned upgrades to services using Gunnersbury Station and the existing capacity of rail services from Kew Bridge station, the non-match day impacts are acceptable and are readily accommodated by existing services.

9.409 The Gunnersbury District Line underground service has an hourly seated capacity of 1,680 passengers and crush capacity of 4,944 passengers. Assessment shows the maximum line load was 2,186 passengers in the AM peak hour (7 to 8AM) with 1,697 in the PM peak, with these being below the maximum hourly capacity of the service (4,944). The proposed development would add up to 153 passengers (2 way) in the AM peak hour and 144 to the PM peak hour, which would both be within the existing capacity

9.410 In respect of Kew Bridge station, as noted above South West trains is improving the service from Kew Bridge, with trains to increase from 8 to 10 carriages increasing hourly capacity from 3,200 to over 4,000, plus there will be an additional weekday AM peak train to Waterloo. These changes are being introduced from 2013-2015, with this being competed prior to the first phase of housing being occupied in 2016. The proposed development would add less than 100 passengers (2 way) to both the AM and PM peak hour which is again well within capacity.

9.411 Additional bus trips are likely to be spread over at least five bus routes (H91, 237, 267, 65 and 44), with the total maximum number of additional peak hour trips around 100 passengers in the AM and PM peak hours. With there being 53 west and 85 bus services per hour in each direction per average weekday peak hour, the additional passengers would be able accommodated. However TfL notes that some users of Gunnersbury Station would choose to take a bus rather than walk to the station, with this estimated to add another 40 trips to the morning peak. With other cumulative schemes in Brentford this would be likely to add pressure to the morning peak along the A315 corridor and so a contribution of £175,000 towards additional peak hour service has been requested. The applicant has agreed this contribution, which would be secured by a s106 agreement.

6. Non-match day mitigation

(i) Travel Plan

9.412 A non-match day Travel Plan has been submitted, with this to have similar objectives and mechanisms as the Stadium Travel Plan, the ultimate aim being to maximise sustainable modes of transport and reduce car use and traffic congestion associated with the development. The Travel Plan would apply to commercial and residential uses. Monitoring of modal splits and impacts would again be independently assessed, with this monitoring to cover 10 years after post occupation of the development. Given the proposed phasing, the Travel Plan itself should be for the lifetime of the development

147 9.413 The plan would include promotion and communications measures, and details of ways to maximise public transport use, cycling and walking. To incentivise such travel, it is recommended that the applicant provide a £50 sustainable transport ‘voucher’ for each residential unit, spread over two years after occupation. These vouchers could cover car club membership should the resident wish, or a cycle contribution, or public transport vouchers. Various car clubs are found in local streets surrounding the site, which would also help reduce private car trips.

9.414 The draft Travel Plan sets a target to reduce car driver trips by 5% over the initial 5- year period, but it is recommended this continue for a period of 10 years to ensure this would be maintained.

(ii) CPZ

9.415 Should the monitoring show relevant targets for car use are not met, then it would be necessary for further measures to be introduced to ensure effects on the road network and also parking in the locality are not harmful. The only option here is introduction of a CPZ to those nearby areas not covered by existing CPZs, which may suffer from overspill parking, should local residents agree, with residents of the proposed development prohibited from obtaining permits.

(iii) Conclusion

9.416 The non-match day mitigation is primarily to be achieved by the Travel Plan, which will promote sustainable modes of travel to and from the site, with it including targets to decrease car use. Additionally other obligations in respect of a sustainable transport voucher would incentivise non-private car travel up front, but if targets are not met or overspill parking resulting from the development becomes a problem then consultation on a CPZ, for which residents of the development would not be able to obtain permits, has been recommended.

7. Construction impacts

9.417 The development would be phased to be completed over 8-9 years, with this likely to have temporary local disruption to pedestrian, cycle and vehicular traffic, including public transport users for the duration of works owing to demolition and construction traffic. Additionally, owing to the phasing of the development, some resident new residents would also be subject to these potential impacts.

9.418 Some impacts from such large scale construction are an inevitable consequence of development. Expected construction traffic volumes would have a negligible impact on the wider road network though final details would not be determined until the full final phasing/ construction plans are approved. For this site, which is close to the strategic road network, routeing of construction vehicles to avoid residential areas is feasible, whilst hours of work, including for deliveries would be limited to reasonable hours, and other environmental controls including access management and wheel washing will further minimise impacts to a satisfactory level. These controls would be secured by conditions requiring a Construction Logistic Plan (covering methods and routes of delivery) and a Construction Environmental Management Plan (covering site management and environmental controls).

8. Conclusion

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9.419 As the proposal includes a large stadium with ancillary uses, a hotel, and up to 910 dwellings, it would clearly result in additional use of nearby public transport and traffic and parking on adjacent roads by new residents and visitors to the site, including for football matches, the latter to attract up to 20,000 people. The site has a moderate PTAL, with a good number of public transport options available for use, including bus, rail, and underground services. In terms of public transport accessibility this site is preferable to other possible alternatives sites in the Borough and the existing ground. The development looks to maximise use of sustainable transport modes, by limiting stadium parking and encouraging walking, cycling and use of public transport, with residential parking also limited to a ratio of 0.64:1, and travel plans for match and non-match days. Additionally, opening of direct access to the site from the London bound platform at Kew Bridge would facilitate management of spectators using rail to travel to the site.

9.420 However the site adjoins the strategic road network, which as described, already suffers from heavy traffic congestion, whilst public transport is also very busy in peak hours, and has some existing deficiencies, in particular at Gunnersbury Station where platform access is presently constrained by its physical layout. Parking of cars in surrounding streets, some already covered by a CPZ can also be difficult.

9.421 Assessment of the effects on the proposed transport network shows that both match day and non-match impacts are satisfactory and the residual cumulative impacts are not severe. In this regard the use of public transport on match days will help minimise impacts on the road network, and though there will still be additional car journeys on local roads which will result in some increased delays, these are not significant, whilst at the worst case there would be enough on-street car parking capacity for the expected number of car users (though endeavours are to be made to provide managed off-street parking to reduce reliance on on-street parking). Public transport will be very busy around match times, but this will be for intermittent periods that do not largely conflict with peak hour use and there is adequate capacity which with appropriate management will not adversely affect the safety or function of the network. Should impacts exceed those predicted then further measures to discourage car use such as a match-day CPZ may be implemented, subject to consultation of local residents. Management of spectators will be necessary to minimise disruption and this is proposed in the Stadium Management Plan, with various mitigatory measures secured by conditions and obligations. Nevertheless there would still be disruption and inconvenience to other users of the main pedestrian routes and transport at these times, as is inevitable with large spectator venues/ attractions. On balance noting these are temporary impacts and able to be managed, these adverse effects are not so significant they would harm living conditions or the amenity of the area to a degree that would warrant refusal of the application.

9.422 For non-match days, the assessment shows the public transport network is capable of accommodating additional demand generated by the development, noting planned increases in rail capacity, though a contribution for an additional peak hour bus service is required, with the applicant to contribute £175,000 towards this. Traffic impacts would be similar to match days, as the development would add to existing congestion, with a small increase in journey times. This is of course not desirable, and although no physical improvements are proposed to alleviate this, there are

149 measures proposed in the travel plan look to decrease car use from the development over time, though as noted the impact also needs to be seen in the light of the general policy to only provide extra highway capacity as a last resort. Potential for car parking overspill onto surrounding streets is a concern, and this will be monitored, with the option of a CPZ available subject to consultation of local residents should this become a problem.

H. Impacts on neighbours

9.423 The NPPF requires sustainable development, and as part of this development should aim tom minimise adverse effects on the local environment, which includes neighbouring properties.

9.424 LP policy 7.6 states buildings should not cause unacceptable harm to the amenity of the surrounding land and buildings, particularly residential buildings in relation to privacy, overshadowing, wind and microclimate. Similarly policy ENV-B.1.1 of the UDP says new development should ensure adequate daylight and sunlight reaches adjoining properties, and minimise any detrimental impact on adjoining properties.

9.425 Owing to the site being largely bounded by railways and roads, it is separated from nearby residential areas, which lie to the west and southwest. Commercial buildings adjoin the north and east, with their also being a school set to open within a former office building next to the Capital Court site. This context limits impacts on neighbouring properties, though owing to the large scale and tall height of the buildings there are potential impacts in respect of outlook and privacy and daylight and sunlight, which have all been raised in objections to the proposal.

9.426 More indirectly the development, in particular the football stadium, has potential to disturb the living conditions of residents in the locality owing to noise and light pollution and possible anti-social behaviour and overcrowding. These matters have already been discussed above, and it is considered that subject to mitigation recommended in conditions and obligations. Other potential impacts from construction activity are discussed in later sections where other environmental impacts are considered.

(i) Outlook and privacy

9.427 Given the layout of the development in relation to the siting and proximity of nearby residential development which lies to the west of the site, beyond railway lines, the proposed buildings are on the whole not considered to be overbearing. In this regard, although apparent in views from the surrounding townscape and windows/ gardens of some houses, the proposed buildings would be viewed behind a foreground containing some trees and shrubs along the railway corridor and are separated by a reasonable distance. Some properties on Green Dragon Lane and Temeraire Place that have windows and gardens with views towards the site would experience a significant change in outlook as the stadium and housing blocks on Duffy site would be very apparent. Nevertheless as noted, the new buildings are located beyond railway lines, and separated by their windows facing the site are all more than 21m from the proposed buildings (nearest opposing windows are 42m away). Other neighbours such as offices to the north and the school to the south are at least 21m (school) and 25m (offices) from the site, retaining an acceptable

150 outlook. Reserved matters and conditions in respect of materials would ensure they have a satisfactory appearance.

9.428 Similarly for privacy, the proposed residential buildings are all more than the minimum recommended distance of 21m between windows of opposing habitable windows from the nearest dwellings, with many of the latter not having windows, or having only secondary windows facing the site. This would ensure that adequate levels of privacy are maintained for neighbouring residents. The school on Capital Interchange way that adjoins the Capital Court housing plot has a car park and driveway adjacent to the application site. The closest directly opposed windows between the school and the southern end of Block K are more than 21m apart, and the latter has a dual aspect which would provide flexibility for window placement to ensure sufficient privacy between windows is maintained.

(ii) Daylight and sunlight

9.429 Policy ENV-B.1.1 of the UDP says new development should ensure adequate daylight and sunlight reaches adjoining properties, and minimise any detrimental impact on adjoining properties. The ES assesses the likely impacts of the development on daylight and sunlight. Noting the housing is in outline form, the assessment has considered the ‘worst case, using the maximum building envelopes established by the parameters to assess the likely impacts on neighbouring properties. The assessment has been undertaken in accordance with the BRE Guidance ‘Site Layout Planning for Daylight and Sunlight: A Guide to Good Practice’ 2011. Failure does not necessarily mean the impact would be unacceptable and the BRE requirements are advisory, and as they are used for urban and suburban areas they should be applied flexibly to take account of varying densities.

9.430 Daylight – This guidance takes into account the amount of sky that can be viewed from the centre of a window, utilising a method that considers the ‘Vertical Sky Component’ (VSC) for the window. This method considers the potential for daylight by calculating the angle of vertical sky at the centre of a window (with 40% being the maximum value for an unobstructed window).

9.431 The BRE target figure for VSC is 27% or greater to maintain good levels of daylight. If the 27% VSC target is not achieved, then a comparison of existing and proposed VSC levels with the new development in place is calculated. The BRE advises that acceptable levels of daylight can still be achieved if VSC levels are not reduced by more than 20%. If the loss is greater, then the reduction in daylight would be noticeable with rooms likely to become darker, though the closer to the target the less noticeable the impact will be.

9.432 The assessment considered potential impacts on residential properties on Kew Bridge Road and the residential streets off Green Dragon Lane to the southwest and west of the site, and other non-residential buildings in other directions, for which a total of 318 windows were assessed.

9.433 Taking account of the magnitude of change and sensitivity of the 318 windows tested, the proposed impact shows some windows would experience noticeable but minor impacts, but that daylight to 56 windows would be adversely affected to a medium degree and 57 to a high degree using the VSC method.

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9.434 The table below provides further information in respect of these impacts and comments on the level of harm. It is important to note that although the VSC is the best guide to determine impacts, as it describes the amount of light entering a window and how it is affected by an obstruction, other factors not considered, such the size or use of the room, how large the windows are, whether rooms have more than one window, or if they are dual aspect and so have another source of daylight, are also relevant, as they all potentially affect the significance of the impact in terms of living conditions and usability.

Property Use Windows with significant VSC impact No. 2 – Nos. 28- Residential 15 windows affected 39 Temeraire 6 medium impacts Place,10 flats in 9 high impacts five-storey block Comment: All windows affected are north facing and serve open plan rooms that are dual aspect, with each room also having south facing, full height glazed doors that are not affected. Therefore adequate daylight is likely to be maintained to the affected rooms and the impacts are on balance satisfactory. No. 3 – Nos. 20- Residential 12 windows affected 27 Temeraire 7 medium Place, 8 flats in 5 high impacts four-storey block Comment: All windows affected are north facing and serve open plan rooms, of which 4 flats are triple aspect, and 4 dual aspect. The affected windows in the triple aspect flats largely serve a hallway, whilst each room also has south facing windows and east facing full height glazed doors that are not affected. The other flats are dual aspect, with each room also having south facing, full height glazed doors that are not affected. Therefore adequate daylight is likely to be maintained to the affected rooms and the impacts are on balance satisfactory. No. 4 – Nos. 12- Residential 4 windows affected 19 Temeraire 4 medium impacts Place, 4 flats in four-storey block Comment: All windows affected are north facing and serve open plan rooms, of which are triple aspect. The affected rooms all have south facing windows and east facing full height glazed doors that are not affected. Therefore adequate daylight is likely to be maintained to the affected rooms and the impacts are on balance satisfactory. No. 5 –Nos. 4-11 Residential 12 windows affected Temeraire Place, 3 medium impacts 4 flats in four- 5 high impacts storey block Comment: All windows affected are north facing and serve open plan rooms

152 that are dual aspect, with each room also having south facing windows that are not affected. Therefore adequate daylight is likely to be maintained to the affected rooms and the impacts are on balance satisfactory. No. 6 – Nos. 38- Residential 16 windows affected 44 Green Dragon 4 medium impacts Lane, 2 storey 3 high impacts terraced houses Comment: Based on available information the affected windows are bathrooms and bedrooms at first floor level and kitchens and living spaces to the ground floor. The impact on four of the houses would be therefore be considered a major adverse impact, with the study showing with the daylight to the ground floor living/ kitchen rooms calculated as below the recommended VSC and reduced to between 52.8% to 67.2% of their former value. It is noted that some of these windows assessed are full height glass doors, so the actual daylight would be higher than a typical window. No. 7 – Nos. 1-3 Residential 3 windows affected Temeraire Place, 1 medium impact 2-storey building 1 high impact with 3 flats Comment: One affected ‘window’ is actually an entry door to a first floor flat The other window affected faces directly onto a shared landing and is only a secondary window, with the subject room being open plan and having its primary windows, which are not affected, facing west. Therefore adequate daylight is likely to be maintained to the affected rooms and the impacts are on balance satisfactory. No. 8 – Nos. 46- Residential 14 windows affected 49 Green Dragon 11 medium impacts Lane, a terrace 2 high impacts of 2/3-storey houses Comment: All first and second floor windows (medium impacts) are to bedrooms, where need for daylight is reduced. Otherwise the two mid-terrace houses have a total of four living room windows to the ground floor (three having medium impacts and one a high impact). The impact on three of the houses would be therefore be considered a major adverse impact, with the study showing with the daylight to the ground floor living rooms calculated as below the recommended VSC and reduced to between 57.5% to 67.9% of their former value. However it is noted one of the ‘windows’ to each house is actually a pair of glass doors, which would allow for grater lighting than a typical window, whilst the worst affected window, which is at western end terrace house, is actually a conservatory attached to the rear of the living room. The glazing to the rear elevation of the conservatory is much wider than a typical window, and will allow a greater amount of daylight into the room. An additional Average Daylight Factor (ADF) test was undertaken in respect

153 of these affected properties and although this is typically used for new dwellings, it can assist in considering impacts on existing properties. A room may be significantly adversely affected if the ADF is less than 1% for a bedroom, 1.5% for a living room or 2% for a kitchen. The results confirm that at ground floor level, two of the four living rooms would retain an ADF value in excess of the recommended value of 1.5% (being 2.41% and 3.44% respectively for No. 46 and No. 49. The ground floor windows to No. 47 and No. 48 would have ADF reduced below 1.5% but only to 1.41% and 1.38% which are within 6% and 8% respectively of the required value. In terms of significance criteria, the impact is Minor Adverse. At first floor level, all the bedrooms would continue to receive ADF in excess of recommended value. At second floor level, where there are only two bedrooms, the significantly smaller windows in the gable ends reduce values to 0.84% and 0.95%, compared to the recommended value of 1%. These results are 6% and 5% respectively below the recommended value, the significance of which is a minor impact noting the use of the rooms. No. 14 - 27 Commercial 60 windows Great West Rd 12 medium impacts 16 high impacts Comment: A large 7-storey largely open plan office block with windows to all sides. Light would be affected from the ground to part of the fourth floor of the south facing elevation. The affected elevation has long bands of windows running practically the whole breadth of the building. The applicant undertook a further assessment of the impacts by carrying out an Average Daylight Factor test, which showed good daylight would be maintained within the building. Therefore the impacts are considered satisfactory. No. 16 – Kew Education 67 windows House School 8 medium impacts 16 high impacts Comment: Former office building, converted to a school. There is a row of mature trees along the boundary of the site which already partly shades the affected windows. Of the rooms affected, the ground floor is craft/ design/ technology space with rooms having a dual aspect, the first floor is a flexible space with windows to three sides, and the second floor rooms are dual aspect. Noting this layout and that the façade affected has large windows as the building was formerly offices, the impact is considered to be satisfactory.

Table 9: Consideration of daylight impacts

9.435 In this instance there are a considerable number windows of surrounding buildings that do not meet the BRE test for daylight (VSC), as light to those windows would be noticeably reduced, however having further considered the details of the rooms affected, the daylight effects, are on balance, generally acceptable with other factors such as rooms having more than one source of light and their use ensuring the harm is minimised as discussed in the above table. A number of properties on Green Dragon Lane (Nos. 46-49) would have noticeable reductions in daylight, though additional information shows daylight levels would be acceptable. Other houses at

154 Nos. 40, 41, 43 and 44 Green Dragon Lane would experience more substantial adverse impacts based on the worst case outline parameters, with ground floor living rooms experiencing medium to high impact reductions in daylight. In this case, where the BRE guidance tests are not met, a major adverse impact is likely where:

• A large number of windows are affected • The loss of light is substantially outside the guidelines • All windows of a property are affected • The nature of the room affected is one where the need for light is high (e.g. living room), with the guidance stating bedrooms are less important.

9.436 Considering the above guidance, there are four remaining houses on Green Dragon Lane (Nos. 40, 41, 43 and 44) that would experience significant reduction on daylight to rear facing windows, which are to main living rooms where need for light is high. However not all the windows of the properties are affected, nor are all living spaces affected, as daylight/ sunlight to their front elevation (facing southwest), is not obstructed by the development. The earlier reduction in the height of the development achieved during the pre-application stage has reduced the impact on daylight to these properties, though the impact is still significant. Overall this would mean that although the impacts on the daylight to these properties would be significant, it would not be so severe to warrant refusal based on the wider benefits of the development of the site, and that the dwellings would still receive good daylight and sunlight to other rooms unaffected by the proposal. Some improvement in the amount of daylight maintained is also likely with the submission of detailed plans, which would include greater articulation to proposed buildings.

9.437 Sunlight – To assess sunlight impacts the BRE guidance includes a calculation of the Probable Sunlight Hours (PSH) taking into account the amount of sun available across the year and during the winter months for each window that faces 90 degrees of due south. For this development there are no residential properties in the surrounding areas adjacent to the site with windows that face 90 degrees of due south so no sunlight calculations were necessary.

9.438 Overshadowing – To asses overshadowing the BRE guidance recommends that at least 50% of outdoor amenity areas should receive at least 2 hours of sunlight on 21 March. The assessment found that there would be sensitive open spaces adversely affected by the development.

9.439 Wind – Assessment of the wind microclimate impacts show no adverse effects on neighbouring properties from the stadium and maximum parameters proposed. It is recommended further wind assessments are carried out for each phase of the housing blocks at reserved matters stage.

(iii) Noise and other disturbance

9.440 Although most neighbouring properties are separated from the site by railways or roads, there is still likely to be some disturbance from both construction activity and the completed development, the latter including impacts associated with match days. As discussed above, demolition and construction activity will be ongoing for a considerable period owing to the scale and phasing of the development.

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9.441 These would potentially adversely affect existing conditions of neighbours owing to disturbances from construction work such as noise, lighting, dust and air pollution, and traffic. Consideration also must be given to cumulative impacts noting there are other large construction sites in the area.

9.442 The ES identifies that impacts from these potential sources of pollution and disruption are not significant, and subject to appropriate management, their impacts can be satisfactorily mitigated. In this regard conditions to secure a Construction Logistics Plan and Construction Environmental Management Plan would control activity to minimise residual impacts with practical measures such as routeing of vehicles, work hours and practices, dust suppression, site hoardings, lighting, wheel washing, workers parking and access, and health and safety procedures. There are residential properties next to Kew Bridge station, which would become more heavily used on non-match days and particularly match-days, however these properties have been designed to reflect the proximity next to railway lines and the station, with windows reduced in size and acoustic enhancements incorporated in the building fabric, which would limit noise impacts.

9.443 Other impacts from the completed housing and commercial development would be compatible with surrounding land uses, and it is noted that the existing use of the site, which include a range of commercial and industrial uses, including a large waste transfer site also has some impacts on the surrounds from being unsightly and generating lorry traffic.

9.444 Impacts from the use of the stadium in respect of noise, traffic and lighting have been considered in more detail elsewhere. These impacts are not insignificant, and in particular the vehicular and pedestrian movements along main routes to the stadium generated by the stadium are likely to be harmful. However this would be for limited periods, and, subject to the recommended mitigation provided by safeguarding conditions, which require details of operations, management and restrictions on uses, as well as the reserved matters which would provide final designs for the buildings, the adverse impacts are outweighed by the overall benefits of the proposal and on balance are acceptable

(iv) Conclusion

9.445 The proposed development, owing to its large scale and design, as well as the long period of construction, has the potential to be disruptive to neighbours’ existing living conditions and the amenity of surrounding properties.

9.446 The site’s position, which includes separation from most neighbouring sites by railway lines and roads has limited most direct impacts from the building themselves and adequate privacy and outlook for neighbours would be maintained, though clearly the look of the site will be transformed. Loss of the existing uses on the site is overall a positive change, as the proposed housing and commercial uses are more compatible with the surrounds. Some properties would experience loss of daylight to windows facing the site, though in general where the impact is shown to be medium or high impact, other characteristics of affected rooms would ensure that on balance the impacts are acceptable. Some houses on Green Dragon Lane would experience more significant adverse impacts though not all windows are the houses are

156 affected, and they have other living spaces where the daylight/ sunlight would not be changed. Nevertheless there would be major adverse impacts on daylight to some rooms of these houses and noticeable reductions to daylight of other properties. Reductions in height were achieved during the pre-application stage, and no further reductions are proposed given the impact this has on the viability of the development. As such the scheme has sought to minimise impacts on neighbouring properties, and they would maintain adequate daylight and sunlight, despite some harmful reductions to certain properties. Other environmental impacts, including wider disruption resulting from construction, traffic and use of the stadium would be satisfactory with the recommended mitigation discussed, and the residual impacts, though substantial for a short period around matches, would be acceptable given their intermittent nature and the overall benefits of the development.

I. Other Environmental Matters

9.447 Consideration has been given to both wider and on-site environmental conditions and impacts, with these matters addressed in the ES as part of the Environmental Impact Assessment process.

(i) Air quality

9.448 The NPPF says planning decisions should ensure that any new development in Air Quality Management Areas is consistent with the local air quality action plan. It also requires the planning system to prevent both new and existing developments contributing or being put at unacceptable risk or being adversely affected by unacceptable levels of air pollution.

9.449 LP policy 7.14 aims to improve air quality in London and requires development to minimise increased exposure to existing poor air quality, make provision to address local air quality problems and promote the greater use of sustainable transport modes through travel plans., and ultimately be ‘air quality neutral’ through not leading to a deterioration of existing air quality.

9.450 UDP policies ENV-P.1.6 and T.5.1, also consider air quality, alongside the Council’s Air Quality Supplementary Planning Document (SPD).

9.451 The site is within the Air Quality Management Area (AQMA) that covers the whole Borough and by definition suffers from poor air quality. Thus, careful consideration needs to be given to granting planning permission for residential accommodation. However, AQMA’s do not differentiate levels of pollution between different areas and, in reality, there are differences on the ground. Whilst the designation of an AQMA is indicative of a certain level of air quality, this in itself does not prevent development in such areas.

9.452 This site is near major roads and experiences relatively high levels of air pollution. The development includes a replacement football stadium with ancillary uses plus a hotel and new housing, the latter introducing new people into the area. The principle of the stadium at the site is established by the BAAP, which supports the site as the preferred location for relocation of BFC from Griffin Park. Although there is an existing stadium a short distance from the site, the new stadium would have an increased capacity (extra 7,700). The housing is proposed to fund the stadium.

157 Traffic associated with the development (both construction and operational) would be the main air quality impact and more broadly energy use would also contribute.

9.453 Although noting the entire Borough is an AQMA, current UDP policy and government advice sets guidance on reducing and assessing the air quality implications of development and providing mitigation as appropriate rather than prescribing the acceptability of developing new homes in areas where air quality is currently poor, unless mitigation is not practical. At a strategic level this site is presently included in the draft Local Plan for a proposed use as a stadium and housing, with the site likely to make up a significant proportion of the Council’s deliverable housing supply for the future. It is also recognised that although the development, which is high density and has a football stadium, will result in more traffic movements in the area, it optimises use of previously developed land with moderate accessibility to public transport, and ultimately this site is more sustainable than an alternative location for the stadium and housing on a less dense greenfield site where traffic is likely to be higher.

9.454 The air quality implications of the proposed development both in terms of during construction and use following completion have been assessed. Further information in respect of air quality was submitted in accordance with Regulation 22 of the EIA regulations. The ES concludes that residual impacts will be satisfactory with appropriate mitigation. In this regard construction impacts would be minimised through detailed on site management to reduce emissions associated with construction traffic and dust and other airborne pollutants from demolition and construction. Residual impacts from construction are considered to be negligible.

9.455 For the completed development there is predicted to be negligible change in NO 2 and particulate emissions for neighbouring properties and so change in air quality for neighbours would be imperceptible. In respect of new occupants of the development itself, the lower floors would be exposed to the worst air quality with this improving as the height of the building increases. Use of mechanical ventilation is required for the housing to reduce exposure of future occupants to a satisfactory level, with the air intake to be at the top of the building. Further mitigation recommended is use of pollution absorbing trees with the landscape scheme, parking for electric vehicles, prohibition on biomass boilers, and the measures to be included in the match day and non-match day Travel Plans. This mitigation is to be secure by conditions and planning obligations.

(ii) Contamination

9.456 LP policy 5.21 says appropriate measures should be taken to ensure that development on previously contaminated land does not activate or spread contamination, with UDP policy ENV-P.1.8 having similar objectives.

9.457 The site has been previously developed and was once railway goods yard and has industrial uses. Owing to this history a site investigation was carried out. This indicated there is some minor land contamination but subject to mitigation during construction, there would be negligible risk to future residents. Therefore, subject to mitigation, there is no constraint to housing to the principle of housing from contaminated land.

(iii) Flooding

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9.458 LP policy 5.12 covers flood risk management and risk, with this also considered in the NPPF and various UDP policies regarding flooding and drainage.

9.459 The site is predominantly located in an area designated as Flood Zone 1 (low risk) with only small areas of land to the south and east of the application site, adjacent to the site boundary, identified as being within Flood Zone 3 (high risk). The application site is therefore not at risk of flooding from Thames, including tidal flooding. Areas adjacent to the southern and eastern boundaries of the site within railway cuttings are shown to be at risk, however they are protected from inundation by the Thames Barrier tidal defences. Therefore there is no constraint to the principle of housing from flood risk.

(iv) Noise and Vibration

9.460 The NPPF lists noise pollution as a consideration, whilst LP policy 7.15 and UDP policy ENV-P.1.5 look to protect neighbours and occupants of developments from excessive noise pollution. The site is near major roads, in a mixed-use area that has high levels of activity, whilst the site is also bounded by a number of railway lines. As such its background noise levels are high, especially towards the edges of the site, with this reflecting the site’s location with a busy urban environment. Noise measurements took account of surrounding commercial uses but none of these significantly affect the overall background levels the main sources being traffic and railway noise. Consequently there is potential for significant noise and vibration impacts on the development. Additionally, the proposed stadium, with a capacity of 20,000, would be a source of noise that has both local and possibly wider impacts.

9.461 The ES considers noise from construction and the completed development. The latter would potentially include noise associated with the development, such as traffic, the commercial uses and the stadium, and how this impacts on neighbours as well as on future residents of the proposed housing. Cumulative impacts from other developments are also considered with these found to be negligible. Further information in respect of noise was submitted in accordance with Regulation 22 of the EIA regulations.

9.462 Construction – Noise and vibration from construction activity may occur from a number of sources such as use of equipment, delivery of materials, earthworks and piling. Given the scale of the development, some impact from these activities is inevitable. The significance of the impact of noise and vibration disturbance will also depend amongst other factors on the sensitivity of the receptor and their distance from the source. The proposed construction work would affect the occupiers of nearby residential areas, commercial buildings, the new school, pedestrians, and during the later phases, the occupants of new housing on the site.

9.463 The ES shows that the noise from the construction activity would result in minor to moderate negative effects on neighbours, but these would be temporary, and would not be unreasonable with mitigation also proposed such as screening, use and maintenance of vehicles and plant in accordance with best practice. Impacts from vibration, such as from piling work, would be of negligible significance. Conditions to ensure mitigation is provided are recommended.

159 9.464 Operational - Noise from traffic associated with the non-match day uses, including the hotel, would be negligible against the existing background noise level and would not significantly affect either future occupants or neighbouring residents. The use of appropriate glazing and ventilation systems to the new housing would ensure that the interior of all flats meet the necessary standards for daytime and night-time. As both the hotel and housing are in outline form, fuller details of adequate acoustic protection would be able to be incorporated in detailed designs to be submitted with reserved matters. A condition would also be recommended to require noise from any new plant associated with the stadium, hotel and residential buildings, including mechanical ventilation, to achieve BS412 levels to ensure future occupants and neighbouring residents are protected.

9.465 In respect of noise from adjoining and nearby commercial uses, this is not significant as it consists of a school, offices and warehousing, the latter not having openings fronting the closest housing site, and this would not affect the noise environment of the new housing beyond the general background noise level.

9.466 For residents of the new housing match day impacts from traffic are not considered likely to be any worse than peak hour traffic conditions, however to meet relevant standards residents would need to close windows during matches as this is likely to be disruptive noting the capacity for large crowds and the proximity of the housing blocks to the stadium, though whether they choose to do this in practice would be a personal choice. Management of spectators around the stadium concourse and along major routes of arrival and departure will be necessary with this to be covered in the various documents making up the Stadium Management Plan.

9.467 Stadium noise would be able to be heard at surrounding residential properties, with this being from the crowd and PA system. This matter has been considered in more detail above, with impacts found to be acceptable for neighbours and other uses such as open spaces and Kew Gardens. Impacts from possibly rugby use and rock concerts have not been considered as they are not proposed with this application.

(v) Ecology

9.468 The ES has determined that the site is of limited ecological value, with some low quality vegetation found around its perimeter and along Lionel Road. As such impacts on ecology are likely to be limited, but the development does provide an opportunity to enhance bio-diversity and its ecological value. In this regard new landscaping includes planting of new trees and shrubs, new amenity spaces, and wildflower garden to the side of the new bridge, with these providing opportunities to enhance ‘green corridors’ along the railways. Full details of landscaping would be submitted with reserved matters.

(vi) Conclusion

9.469 This is a brownfield site within an established and busy urban area. Owing to the characteristics of the site, which is near to major roads and railway lines, it experiences high levels of noise and air pollution, both of which would mean that mitigation will be required to provide a suitable standard of accommodation for future occupants. Other than those matters there are no significant environmental constraint that would preclude re-development of the site

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9.470 Impacts from the development itself on both neighbouring development and future occupiers are with mitigation, considered satisfactory.

J. Community Benefits

9.471 The application stresses the overall community benefits that would flow from the development, in particular from the new stadium which would provide major socio- economic benefits, enhancing the club’s existing activities and securing its long term presence in the Borough. The applicant argues the continued survival of the club, and its associated community benefits, is threatened by its unsustainable financial position that cannot be addressed at the current ground owing to its constraints and deficiencies. These limit potential revenue, and ability to attract and retain supporters, with it becoming increasingly difficult to remain competitive or achieve more success, the latter also being important in helping the club survive.

9.472 The benefits associated with the football club fall into a number of categories. On its own, BFC is an important commercial enterprise, which has a significant number of employees and is directly responsible for substantial economic activity through procurement of good and services, as well as through spending by supporters within local shops, restaurants, public houses and transport. As discussed in earlier sections, this activity is likely to substantially increase with provision of a new stadium with modern facilities, with an expected uplift in attendances. Sustained attendance increases would also be dependent on on-field success, for which there can be no guarantees, but the club states a better financial position would allow it to be more competitive.

9.473 Other benefits arising from the football club relate to the cultural and community values that result from its presence and the operations of its professional team and most significantly, from the work undertaken in the community by the Brentford FC Community Sports Trust in the Borough and neighbouring boroughs of Ealing and Richmond.

9.474 Apportioning a value, monetary or otherwise, to these community benefits is challenging, with there being no specified way of calculating their worth. Nevertheless, these benefits are important material considerations, and noting concerns regarding adverse impacts on the townscape, which have been identified as departures from policies of the Development Plan as well as other harmful disruptions to the local environment through match day activity, officers consider they are of considerable importance. In this regard, Members will need to consider that where harmful impacts remain even after mitigation either through conditions or planning obligations, such adverse impacts need to be weighed against any beneficial impacts, which include community benefits. The following sections aim to evaluate the cultural and community benefits, but the weight to be given to them is ultimately a decision for Members.

1. Cultural and Social Value

9.475 Determining the value of a football club to a community is difficult. To start, not everyone has an interest in sport, and those that do may not have an interest in football, with even fewer having an interest in Brentford FC. However BFC has been

161 a part of Brentford since 1889 and has survived the continued growth and change of the town. It is an important element of its cultural heritage, and an ongoing link to its past and to its future. Over the last decade Brentford has undergone substantial regeneration, ending a period of decline with old industrial sites being redeveloped with new mixed use schemes. This process is continuing with the town centre the subject of a large scheme for renewal and other sites along the river and Great West Road being redeveloped, but at the same time some institutions and cultural features such as its courts, police station, and some public houses have recently been lost. Development of a new stadium would be part of this process of regeneration and allow it to maintain and embellish its cultural role, its relocation also adding to the cluster of cultural and community facilities in the locality, which include Watermans Art Centre, Gunnersbury Park, Kew Steam Museum, the Musical Museum and the Kew Bridge boating arch (the latter run by the BFC Community Sports Trust). The proposal would enable its sporting element to become further embedded as part of the cultural and community landscape, while widening the scope of facilities it offers beyond football and sport in general.

9.476 The importance of the BFC to many people has been highlighted in numerous submissions have been received emphasising family connections and histories associated with the club and its role in the community and value to different generations. These have been received from local residents as well as those whose families have moved further afield but maintained their connections to family and friends in the area and BFC, as well as people that simply like the football team.

9.477 The club is the only professional sporting team in the Borough, and although not everyone is interested in sport, it does provide an identity, adds character and provides distinction to the area which is of some value given the region is now clearly a part of Greater London. Loss of the club through commercial failure or relocation to a new ground out of the Borough would be detrimental to the cultural and recreational assets of the area. The BAAP notes the cultural value of BFC and includes objectives offering continued support for its operation in Brentford and its relocation to the site on Lionel Road.

9.478 The socio-cultural significance of football in London has been acknowledged. A report on London’s football clubs by the London Assembly 4 in 2003 recognised that football stadiums are part of our cultural and sporting heritage, as well as being a focus for civic pride, regenerative growth and community projects. It found that for these reasons, local authorities, the Mayor and the football authorities should seek to accommodate football clubs’ wishes to remain in their traditional area, wherever possible.

9.479 Significantly this report also said support from authorities should be balanced against an obligation on clubs to fulfil their role within their community, through community programmes and the use of their stadiums. In addition, clubs should seek to minimise their potentially disruptive impact on the local community’s streets, transport and policing services. A key means for engaging with the local community is through a club’s stadium, with the report noting that a football stadium is often the location for a number of community schemes and football

4 The London Assembly Away from home: Scrutiny of London’s Football Stadiums June 2003

162 clubs are often the vehicles through which many social projects choose to achieve their aims. Football’s broad appeal to young people, the stimulating environment of football stadiums and the respect given to players provides one means of addressing social, health and educational problems in London.

9.480 BFC’s current operation at Griffin Park appears to coexist amicably with the adjoining residential properties, whilst its community work through the BFC Community Sports Trust is extensive and well respected. There is an extant planning permission for the redevelopment of Griffin Park with housing, provided a new stadium is provided. The legal deed that goes with this application has an obligation that BFC to undertake ‘reasonable endeavours’ to secure alternative accommodation for the Trust and to continue its programme and maintain listed activities, prior to implementing the permission. The activities listed are:

• In-school coaching • After school coaching • Holiday camps • Training of promising players • ‘Chairobics’ sessions for over 50s • An end of season fun day on the pitch • Education programmes linked to reading and classrooms sessions linked to football

9.481 To conclude, the cultural value of BFC to the Borough is considered important to many people but not all, whilst support for its continued existence in its traditional area, including possible relocation to Lionel Road, brings obligations on the club, with disruptive impacts on local communities from matches to be minimised, and most significantly, the club should give back to the community through using its stadium as a catalyst for social, health and educational work that maximises positive outcomes for people in the region.

2. Community Benefit

(i) Aims and objectives

9.482 The importance of sport, and of community facilities in developing sustainable, healthy and cohesive communities is emphasised in planning policies at all levels. At a national level the NPPF includes a core principle for the promotion of healthy communities, with it stating the planning system can play an important role in facilitating social interaction and creating healthy, inclusive communities.

9.483 The LP includes a number of relevant policies and associated guidance that support the stadium and its associated community work, in particular policies relation to access to services and facilities (3.1), improving health and addressing health inequalities (3.2), the protection and enhancement of social infrastructure (3.16), education facilities (3.18) and sports facilities (3.19).

9.484 Sport and health are one of the Mayor of London’s Priorities. Data 5 for 2009/10 shows that in London, 11.6 per cent of children aged 4-5 years and 21.8 per cent of

5 Childhood Obesity in London, GLA 2011

163 children aged 10-11 years were at risk of being obese. This is higher than the English average for both age groups. More than half of the adult population are overweight or obese. Poor health can be linked to lifestyle and socio-economic inequalities

9.485 Other regional objectives are listed in ‘A Sporting Future for London 2009’, which aims to deliver a grass-roots sporting legacy for Londoners following the 2012 Olympic and Paralympic Games by securing a sustained increase in participation in sport and physical activity amongst Londoners and using sport to assist in tackling social problems including ill health, crime, academic underachievement and lack of community cohesion.

9.486 This same document highlights that Hounslow was in the lowest quantile for sports participation in 2007/08, lower than Hammersmith and Fulham and Richmond, who both had the highest levels and Ealing and Hillingdon, who both had low-middle levels. Other key goals also include the tackling of inequality and provision of new or refurbished sports infrastructure, with the Mayor committed to ensuring that every Londoner has an equal opportunity to participate in sport and physical activity and this commitment forming a key element of his equality framework for London, ‘Equal Life Chances for All’. In particular the document notes some people within certain groups feel excluded from sporting activities and/or have particularly low rates of participation in London. They include those in lower socio-economic groups, young women aged 14 to 24; older people, black and minority ethnic people, disabled people, and non-heterosexuals.

9.487 At the local level, UDP policy C.5.1A for new stadia includes criteria for assessment, of which (ix) requires assessment of the implications of any multiple use and non- sporting activities to the environment and community.

9.488 The ‘Hounslow Physical Activity and Sport Strategy 2012-2022’ identifies objectives in respect of sport and its impacts on health, noting that physical inactivity is now widely recognised to have a direct impact on poorer health both physically and mentally. Increasing regular participation in physical activity and sport has been proven to significantly reduce the risk of a wide range of health conditions such as obesity, coronary heart disease, stroke and hypertension, diabetes, cancer, osteoporosis, a reduction in falls among older adults and minimising the effects of arthritis.

9.489 Hounslow falls below the national and regional average for sport and physical activity with the latest figures from the Active People national survey suggesting just 19.6% participate in 30 minutes of sport and physical activity at least three times per week. Whilst there has been variation in performance over the few years this performance is not significantly different to when surveying first started in 2005 (19.7%).

9.490 As with London wide assessments, Hounslow’s strategy highlights that amongst the adult population (over 16), residents’ participation is lower than average in females, those with a disability and certain ethnic groups. The report also demonstrated the strong geographical correlation between the areas with low levels of physical activity, poor health and low educational attainment.

164 9.491 The strategy highlights the need to improve the sports facilities and play facilities across the Borough and increase opportunities for people to take part in accessible, fun and safe environments. It also recognizes that a significant cultural change in participation needs to take place within the next generation. Children generally access sport and physical activity because their parents encourage them and take them to activities that they themselves enjoyed or were involved in when they were younger. The risk is that the low participation seen in the current adult population is continued in the next generation.

9.492 To significantly increase participation in children and adults in the future it is considered necessary to increase the number of children who have a positive experience with sport and physical activity and start this at an early age. The strategy considers that in order to achieve this, the Borough must have the right people in place to teach, coach and inspire young people at an early age. It is necessary to make sure that children are not excluded on the basis of talent and performance and that schools and clubs have access to high quality facilities and equipment.

9.493 The strategy notes fundamental changes will be necessary to address these issues, and it notes that BFC Community Sports Trust would be ideally placed and staffed to be at the forefront of such a change, with the strategy highlighting its work noting:

Community sports programmes such as those delivered by Brentford FC Community Sports Trust (BFSCST) offer a range of programmes targeting young people, women and those with disabilities. Activities often target the most deprived wards in Hounslow providing opportunities for people to participate in sport and physical activity. The biggest strength of the Trust is their engagement with young people using sport and exercise as a tool. The young people have the opportunity to participate in quality exercise sessions under the supervision of qualified coaches in a safe environment. Projects are also delivered in partnership with other local organisations, providing educational workshops that provide young people with the opportunity to make informed lifestyle decisions.

4.494 The strategy give’s comments on examples of the Trust’s work, stating:

Sports Jam is an example of the community sporting events that have been held in the Borough. Led by BFCCST, with events in 2008, 2009 and 2010, it aimed to showcase all positive aspects of local community sport highlighting providers, clubs and supporting partners. Such local community events can be important in supporting the promotion of opportunities in local sports clubs. Potential exists to link such events with similar regional annual campaigns such as the Clubsfest that was first held in 2010 and is designed to attract new members to participating clubs.

BFCCST has also supported the provision of football teams for youth and adults across the Borough and pathways for these players are being set up to enable the highest achievers to progress further. An example of this is that one Feltham Bees player was called up to the England Cerebral Palsy squad in 2010 and is now a regular England player representing Great Britain in at London 2012.

9.495 Similar strategies to promote healthy lifestyles and increase physical activity as part of preventative health and well-being programmes exist in Ealing and Richmond.

165 (ii) Brentford FC Community Sports Trust

9.496 The primary community benefits generated by the BFC are from its associated BFC Community Sports Trust. The trust is directly linked to the club, but is a charity registered with the Charity Commission. This status is only granted and maintained where there is a public benefit. It was established as a community organisation in 1987 becoming a trust in 2005.

9.497 The Trust’s website states that its “aim was to create a partnership that fulfilled a number of sport and community activity participation aims for all partners including making the Brentford Football Club stadium more accessible and taking the club out into schools and sports centres to promote junior football sessions.” The Trust undertakes community work in settings across Hounslow, Ealing and Richmond boroughs including sports activity in local schools and sports centres, diversionary activities for young people on estates and intervention work with people at risk of offending, these activities focusing on four themes, health, social inclusion, education, and sports participation.

9.498 The Trust currently operates out of satellite offices some distance from the main stadium, but still within Brentford as they cannot be accommodated at the current stadium. Griffin Park stadium currently provides two education resources in the form of the Griffin Park Learning Zone (90m 2), a student support centre providing out of hours learning, literacy, numeracy and ICT for under-achieving students and also children at risk of exclusion, whilst the Interim Education Centre (70m 2), which provides education for excluded pupils from across the Borough

9.499 In 2012 the Trust:

• Had 7,621 participants, with an aggregate attendance of 119,720 and 263,509 aggregate contact hours. Mean average contact hours per participant were 35 hours/week. • Delivered 424 schemes/projects, averaging 8 a week. • Delivered 6,333 individual sessions, averaging 528/month and totalling 14,000 hours of delivery (269 hours a week). • Had over 500 participants with learning and physical disabilities. • Had 5,494 male and 2,127 female participants. • Had around a quarter of participants aged less than 10 years old, a third 11-15, and a quarter 16-18. • Had 221 significant individual outcomes in 5 priority areas of health, education, sport, community safety and employment training. • Had its largest group of participants from Hounslow (35.11%), but also participants from 6 other west London boroughs, including Ealing (25.7%) and Richmond (34.84%). • Offered over 150 schools and educational outreach schemes.

9.500 It has been recognised nationally, with the Trust winning the following awards:

• 1990 - Awarded Football League Trust Commendation • 1991 - Winner: Football League Community Club of the Year • 1992 - Winner: Jewson Community Club of the Year

166 • 1995 - Awarded Football League Trust Commendation • 2005 - Awarded Charitable Sports Trust Status • 2006 - Winner: Football League Community Club of the Year • 2007 - Winner: GlaxoSmithKline Local Health Award • 2007 - Winner: Football League Best Sponsorship Award • 2008 - Winner: Pro-Active West London Best Partnership Award • 2009 - Winner: Football League Community Club of the Year (League 1) • 2010 - Brentford FC Awarded Business in the Community Mark • 2012 -Celebrating 25 Years of Community Sport

9.501 The following are current partners in the programmes the Trust offer:

• Schools/Educational – 26 in LB Hounslow, 18 in Richmond, 25 in Ealing, 1 in Hillingdon, 1 in Brent • Sports Centres – 8 in Hounslow, 5 in Richmond, 8 in Ealing • Housing Estates – 10 in Hounslow, 2 in Richmond, 2 in Ealing • Community Centres/Youth Club/Recreational Areas – 5 in Hounslow, 6 in Richmond, 2 in Ealing • Housing Associations – A2 Dominion, Catalyst, Thames Valley Housing Association

9.502 The application notes existing deficiencies at the current stadium restrict some activities and add to costs of operation as the Trust cannot be accommodated owing to a lack of space. This in turn limits opportunities for expansion, results in poorer accessibility, and the physical separation is a disadvantage in promoting and identifying the Trust with the club. Practical issues resulting from the current arrangements include Trust cannot be accommodated at Griffin Park owing to a lack of space and consequently staff must travel to and from their offices elsewhere in Brentford to pick up and drop off equipment, which individually adds only 15 minutes to programmes but cumulatively over an entire year is a significant cost. The Learning Zone and Interim Education Centre are both located at Griffin Park, but the accommodation is not fit for purpose as it cannot cater for adequate numbers nor is it accessible for people with ambulant disabilities.

(iii) BFC Objectives and Enhanced Community Benefits

9.503 The club state’s that their vision is for:

“… a modern, strikingly designed sports stadium, which will act as a vibrant community hub at the centre of a revitalised part of Brentford. Our plan is for a stadium that is not just a home for professional sport, but one that will act as a natural meeting place, with cafes, bars and restaurants, for everyone living in the surrounding area, and all of this providing much needed employment for many of those people. We see it as a location in which we can comfortably house all the elements of Brentford FC, bringing the Community Sports Trust back into the heart of the Club, enabling them to fulfil some of their grander schemes and ambitions.”

9.504 The Trust would seek to establish itself within a ‘hub and spoke’ model, using the new stadium as the focus, it housing the Trust offices as well as the Learning Zone and Interim Education Centre, with other activities reaching out to nearby facilities including Gunnersbury Park, Fountain Leisure Centre and Brentford Boating Arch.

167 Therefore a primary aim of the development is to secure the long term future of the club as a community asset, with this consolidating its operations including community work, with the new facility allowing for the current community provision and activity to be enhanced.

9.505 In addition to the premise that the new stadium provides an opportunity to enhance provision of community benefits, it is acknowledged that the current benefits offered by the club and the Trust are intrinsically linked to the success of the club on and off- field, with the Trust’s direct association with the football club being key to its profile and ability to engage participants. Given the club’s financial position the long term presence of BFC, and consequently the community benefits from the associated Trust, are not secured. These benefits would be at risk if the club were to close, move away, or decline in status through being less successful and uncompetitive which would make it harder to retain and attract new support. The current provision is not secured by planning permission or a legal obligation on the club, whilst the obligation that applies if the club were to move only requires ‘best endeavours’ for the re-provision of a much more limited programme of benefits than presently offered.

9.506 It is considered that the best chance of retaining this community benefit is to retain the club at a new site within the Borough, which will enable its aspirations to progress in status and to be more financial sustainable. The club submits that the new stadium will also enable it to continue to provide community support and to a higher number of people, in better facilities and covering a wider range of activities.

9.507 These assertions are considered further below, but should the club progress, it is appropriate that the community benefit from this enhanced status and financial prosperity is retained and it is proposed this be secured in a Section 106 deed.

(iv) Current and Proposed Provision

9.508 The new stadium allocates floor space for the community uses currently accommodated at Griffin Park and the Trust’s off-site offices, with the areas provided for each to be increased and facilities and access enhanced.

9.509 BFC Community Sports Trust – New offices comprising 360m 2 of floor space, with space for 30 staff, a reception, open plan space and four cellular offices over two floors. The Trust would also be able to host events and hold sessions at the stadium unlike its present accommodation which is only office space.

9.510 Learning Zone – New Learning Zone with an area of around 310m2 (115m 2 of which would be used by the media on match days). This is larger than current floor space (90m 2) and will provide 50 workstations, as opposed to the current 14. This facility is run by the Trust and is a study support centre that seeks to raise attainment in children using the stadium, players and staff. It provides after school tutoring in literacy and numeracy, and workshops to complement school work. It also helps disadvantaged children, and those with special education needs, and has enterprise workshops, industry open days, offers support for students at risk of exclusion, , provides family learning projects, engages disengaged groups, and professional development for teachers and support staff. Overall the new facility would increase the education programme delivery by 20%

168

9.511 Interim Education Centre – This currently provides interim education for children excluded from school in excess of 5 days, working with the Police, Early Intervention Service, Intensive Family Support, Connexions and social care providers. The club provides the space and environment for an outside provider. The current facilities are cramped and not purpose built and are also used as a matchday pressroom and a programme collectors club room. It can only accommodate a maximum of 12 people, using laptops only.

9.512 The new IEC would be used by schools as an offsite learning environment (8.30- 5.30) 5 days a week. The proposal is a secure, self-contained space of 150m 2 providing three classrooms, office space and toilets, accommodating 3 teaching areas, each accommodating 10-15 pupils and 2 adults. It would include office space for 2-4 adults. It would increase the number of pupils by 30% from the level using the current site (72m 2).

9.513 Other Community/Dual Use Facilities/Benefits – The Learning Zone and hospitality areas, and other stadium facilities also offer opportunities for dual use and other proposed benefits with spaces being available for use at low cost by supporters, residents, local authorities, government agencies, and voluntary groups and clubs. These facilities include: • 70 seat lecture theatre • Media room with 29 workstations (115m 2) used for the media on match days • Hospitality lounges and rooms available for community events, including meetings, conferences, weddings • Climbing Wall • Bicycle space, cycle to work schemes, cyclist coaching • Room hire for local groups and societies at less than commercial rates

9.514 The following list highlights some of the numerous projects of the Trust over the four themes of education, health, social, and sports participation.

Education

• Griffin Park Learning Zone – Numeracy and literacy programmes to enhance reading, writing, speaking and confidence, and includes IT and multi-media activities for both young children and those about to seek employment/ qualifications. • Football League & Npower Respect – Workshops delivered to 1,200 pupils in 20 primary schools in Hounslow, Ealing and Richmond teaching them about the importance of respectful behaviour in sport and their daily lives. • National Citizenship Programme – Leadership and development skills for 12 pupils. • Work Experience and Placements – In association with schools, universities and Princes Trust providing office, administration and coaching skills (40 work experience and 5 university placements pa).

Health

169 • Extra Time – Project targeting activity for 55s, hosted at Griffin Park with health and fitness, table tennis and social club. • Bike Hub – Bicycles and cycling facilities available for Trust and volunteers • Ealing Young Carers –Delivered project that Identifies young carers and provides support and breaks for children aged 6-18 with parents or siblings with substance abuse, mental health issues or disabilities (70 carers).

Social – social inclusion, crime reduction and community safety

• Kickz – National project to engage marginalised young people from areas of high anti-social behaviour (on average 11% of participants are known to criminal justice system). 6 projects deliver 45 hours per week across Hounslow, Ealing and Richmond engaging over 1,200 young people • Sport for Change – Scheme for young women at risk of offending, excluded from mainstream or with gang links providing sport and fitness, volunteering and educational opportunities. • Mentoring – Various schemes working with young people to assist young offenders or their siblings providing diversionary activities, employment advice, and anger management • Hounslow Urban Athletics Regatta – Athletics and water sports programme for deprived areas, with 386 participants • Street Sports – Hounslow based inclusion project in partnership with Hounslow Homes and private developer, delivering multi-sports activities and youth clubs on 6 estates (40 weeks pa), which achieved a 37% decrease in anti-social behaviour in 2012. • Disability Projects – Supporting 500 young people and adults with disabilities with multi sports days, kayaking, swimming, football and inclusive programmes for autistic and deaf children. Opportunities for role models as the Trust employees coaches and volunteers who are deaf, have cerebral palsy, mental health issues and autism and lead coaches and assistants on both mainstream and disability specific projects

Sports participation – physical activity and development

• School and community group sessions – football, netball, rugby, gymnastics, athletics, handball and water sports working with 62 schools and community groups in Hounslow, Ealing, Richmond, and Hillingdon. • Football development – 230 players aged 5-16 attend training and games against other clubs. • Saturday Clubs and Holiday Courses – Saturday Morning Clubs at 5 venues (40 weeks pa) and Holiday Courses at 6 venues (10 weeks pa). • Football competitions – 2 tournaments with 36 school teams. • Matchday – BFC donates 500 tickets and 11 mascot places per game for community use, 50/50 ticket offer enables local clubs and community groups to raise funds. Over 7,000 participants of community programme. • Brentford Boating Arch – 400 participants, kayaking, canoeing and paddle boarding on the Thames and Brentford Lock promoting fitness, river awareness and environmental education.

170 • ISIS Challenge – Partnership in athletics and water sports even at Syon Park, with 580 adults and children participating. • London Youth Games – Delivery of trials, selection and coaching of boys, girls and disability teams for Hounslow, Ealing and Richmond, attended by 120 players, with 7 teams managing by Trust coaching staff at the games. • Volunteering – Management and recruitment of volunteers

9.515 Gunnersbury Park – The Trust is keen to enhance their role beyond the stadium and consider taking on the running of the sporting facilities in Gunnersbury Park. They hope to act as a catalyst for regeneration and help to facilitate funding of a proposed sports hub that is currently in development. Subject to securing funding the Trust considers that it could manage the currently proposed facilities which include new pitches, changing rooms, refurbished tennis courts and other improvements. The applicant proposes to assist with the opportunities for a wider sports facility development project at Gunnersbury Park in accordance with a Master Plan that has been given cabinet approval by both Hounslow and Ealing boroughs. However with no funding presently available it is unclear how this would develop at present and no weight can be given to the proposal, though the securing of commitment towards such as scheme could be included as a planning obligation.

9.516 Community Programmes – The following table gives a summary of the breakdown of the various elements of community benefit and what is offered now and what will be proposed, according to the Trust.

Current Proposed Sport • 600 regular attendees in • Addition of flexible playspace Development 2013, engaging in multi- would allow: sport, leisure and social • Cheerleading, dance and keep activities. fits groups- 30 girls and young • Bespoke activities: women a week, • Ability Counts, On Your • Urban Fitness Course- 50 Marks, Panathlon people/week Challenge, Hounslow Short- • Activities tied into Learning Breaks Zone 30 young people a day • Climbing wall would enable 20 participants to use 2 evenings a week Coach • Trust runs its own training • 10% increase provision of Development and accreditation database these schemes (up to 165 and their coaches run 150 schemes). school and outreach schemes: • 50 in schools, 2 at holiday camps, 14 at sports centre, 2 at advance training programmes, 41 social inclusion sport- based schemes, 24 disability schemes, 19 others

171 Education • The Griffin Park Learning • New KS2/3 transition Support Zone currently supports programme supporting up to out of hours learning, 60 students a year. literacy and numeracy • Family First Program- works education, IT support and with KS3 students referred by enterprise projects. LBH Early Intervention Team on engagement in learning, focused on truants. Aspiration to increase to family based provision. • New media facilities for up to 30 young people a year. • Summer family learning programs for up to 30 families over 6 weeks. • Over 100 adults would use the new lecture theatre. • The Trust would offer 5 work placements to local university sports science courses. • Anticipate 500% increase in commercial sector teambuilding programs. • 100 adults will be engaged in cultural activities in conjunction with the Musical Museum and Watermans. • Increase in FUTSAL NVQ participants- program starts Sept 2013. • A Bee See literacy program for 9 schools in Ealing, Hounslow and Richmond. Run in conjunction with Thames Valley Housing Association. Volunteering • 2012- 238 volunteers, fifth • Envisaged new facilities will highest in football league. increase volunteering • 1,747 volunteering opportunities by 50%. opportunities created. Of these 89 were part-time volunteers, 88.2% (210) male, 11.8% (28) female. Ages ranged from 11-25, most being in 11-155 and 16-18 ranges. These are key targets ages for tackling youth exclusion etc. Type of volunteering widespread. 124 outcomes and 52 qualifications in 2012.

172 Community • Context is LBH Community • 100 extra young people to Cohesion Safety Strategy work towards vocational • Current provision for social qualifications with 200 young inclusion, crime reduction, people involved in events at community safety stadium to celebrate schemes- Kickz, Positive achievements. Aims to bridge Futures, Street Games, gap between young and old Street Sports, Sport for and involve up to 50 new Change. Ticketing scheme young people annually. • Youth Offending Service- Volunteer meeting programme • New and improved and expanded discounted/free ticketing schemes Health and • Context Hounslow Joint • Match Day Men’s Health Wellbeing Health and Well Being Promotion- 15% increase to Strategy, which aims to reach 300 people a year. reduce differences in life • Extra Time- Increase of 30-40 expectancy, ensure every attendees. child has the best start in • Engagement with 50/60 55+ life, ensure adults retain participants. their health and independence for longer. • Greater connectivity to Cycle Super Highway • Current activities- • Would join the European Bee Active- aims to • Healthy Stadia Network increase physical activity for young children • Trust would work with LA Clinical Commissioning Bee Healthy- Aims to • Groups and offer exercise improve health of whole based referrals to support up community in partnership to 30 adults a week. Work to with Hounslow PCT be carried out with Brunel • Extra Time- funded by students on placement. Football Foundation, Sport Estimated to involve 60 Relief and Age UK, it young people a year. engages with the 55+ • Young carers project (20/30) to deliver a range increased by 15%, 10 more of social and physical young people being activities. supported. • Bike Hub, Match Day Men’s Health Promotion, Ealing Young Carers

Table 10: Proposed community benefits increase

9.517 The following table is taken from the Substance Community Impact Report which forms Appendix 8 of the Community Benefits Statement submitted with the application, and breaks the benefits down into further categories. It describes the expected community benefits from BFC and the Trust overall based on experience of evaluating other community projects, and taking into account the qualitative and quantitative improvements the to the work of the Trust the stadium will enable. The table summarises the potential increases in community use that the new

173 development could deliver, alongside a realistic short term target set at 30% increased provision for the first year of operation.

Area of Delivery Estimated Potential People Visits People Visits / Increase / Year Year (First (Based on 30 Week Year) Year x 30%) i) Sport Urban fitness 50 adults pw = 900 pa 900 300 Young People urban fitness 150 young people pw = 4,500 4,500 pa 1500 Indoor space use 30 pw = 900 pa 900 300 Climbing wall use 40 pw = 1,200 pa 1,200 400 5k Run 100 pa 100 33 Soft play area U5’s 30 parents pw = 900 pa 900 300 Schools’ work 50 visits (x 20 people) pa 1,00 = 1,000 pa 33 Subsidised ticket scheme 500/match = 2500 pa 2,500 833 Ticket scheme income to £2,000/match local groups = £40,000 / year N/A N/A Wheelchair Users 20/match = 400 pa 400 133 Stadium Tours 20/match = 400 pa 400 133 Sports Festivals 100 pa 100 33 Gunnersbury Park Festival 300 pa. 300 100 ii) Community Safety / Cohesion Facility Use Increase 300 pa 300 100 Older/younger people 50 pa 50 17 iii) Education 0 Primary/secondary schools 100 places pw = 3,000 pa 3,000 1000 Key stage 2/3 programme 60 students pa 60 20 Media facilities 30 young people pa 30 10 Wheelchair users’ 10 young people per 6–10 30 education weeks = 30 pa 10 Family learning 30 families per 6 weeks x 4 720 pa = 720 240 Lecture theatre use 100 adults pa 100 33 Work placements 5 / year 5 2 Training 10 local businesses x 4 40 people = 40 pa 13 Cultural work 100 adults pa 100 33 Secondary Schools 20 pw = 600pa 600 200

174 Partnership CST education programme 100 young/adults pw x 30 3,000 +20% weeks = 3,000 pa 1000 iv) Health Cycle proficiency courses 100 pupils pa 100 33 GP’s work 30 adults pw = 900 pa 900 300 Obesity prevention. 60 young people pa 60 20 Older people 50 / 60 per year 50 17 Supporters cycling 1,000 pa 1,000 333 Health awareness 300 young men pa 300 100 Young Carer’s 10 young people pa 10 3 Men’s health promotion 100 adults p.a. 100 30 v) Economic Regeneration 0 Vocational education 50 pupils pa 50 17 Apprenticeships 5 pa 5 2 Universities 300 pa 300 100 TOTAL 23,010 7,733 Table10: Forecast increased participation

9.518 The research assessment shows that there will be a considerable increase in delivery for young people, but also significant increases in work with adults and older people. The assessment suggests that in the short term (year one) the new stadium could help increase participation by over 7,700 people visits annually. As not all these visits are by unique individuals, the additional number of people benefitting has been estimated at 50% of the visits, giving a total of 3,866 additional unique participants.

9.519 This would effectively lead to an around 50% rise in participants from 7,621 in 2012 to around eleven and a half thousand in the first year, with further increases expected in the future. The table below offers a more general summary of the overall community benefits impacts anticipated. Given the Trust’s excellent record for delivery and expansion, these figures are considered realistic.

BFCST Community 2012 +50% Total Impact Count (Yr 1) (Yr 1) 1. Participants Total 7,621 3,866 11,487 Annual contact hours 263,509 131,755 395,264 ‘Schemes of work’ 424 212 636 Individual sessions 6,333 3,167 9,500 Hours of delivery 14,000 7,000 21,000

175 Aged 1-10 884 442 1,326 11 to 15 1371 686 2,057 16 to 18 903 452 1,355 in Hounslow 2239 1,120 3,359 in Richmond 2222 1,111 3,333 in Ealing 1639 820 2,459 Participants in Top 1482 30% (IMD) (23.2%) 741 2,223 2. Volunteering Total annual 238 119 volunteers 357 Volunteering 1747 opportunities 874 2,621 3. Outcomes (participants and volunteers) Total 348 174 522 Health 118 59 177 Education 31 16 47 Sport 128 64 192 Community safety 38 19 57 Employment/training 33 17 50 4. Qualifications (participants and volunteers) Total 193 97 290 Sport 152 76 228 Culture 26 13 39 Employment/training 15 7 22 Table 11: Existing and 1 st year community benefits comparison

(v) Value

9.520 This increased provision is significant and given the local, regional and national objectives in respect of health and well-being, education and sporting participation, the enhanced community benefits are a major positive socio-economic impact of the development. There were 7,621 unique participants in 2012. The applicant considers provides a conservative estimate that there would be a 50% rise in unique individuals, to a total of over 11,000 unique participants, based on the past experience of provision and ability to expand the Trust’s operations.

9.521 Determining a value for this community provision is not an exact science, but in order for it to be quantified in way that would assist it being secured by s106 obligations

176 and to demonstrate clearly the benefits given the enabling argument set out earlier in the report, the likely costs of provision have been calculated.

9.522 Financial savings – Operation of the community programmes run by the Trust have a financial value. Without the Trust, these programmes would either not take place or would need to be facilitated by some other organisation, such as the local authority. Essentially, the club will be providing a community service for residents of several boroughs that will enhance or improve these own authorities community benefits offer.

9.523 Relevant research on the impact of community work, with particular reference to younger age groups, can be used to estimate how much such provision saves society financially. The work in question tends to concentrate on the negative aspects of youth behavioural habits and how organisations like BFC can improve behaviour/health/educational attainment, but this can be extrapolated to a general impact on youth attainment in all groups and this can provide an indication that adult behaviour etc can also be similarly beneficially affected. The obvious implication of this is that local authorities can target stretched funds elsewhere.

9.524 ‘Sportworks’ 6, a research tool developed to demonstrate the impact and value of sport on society, can be used to estimating the positive impacts of sport against various societal impacts. It is used by Sport England as a social valuing model. It says:

• The average individual public finance cost of a young person aged 16-18 not in education, employment or training is £3,561 per year. • Each young person conviction costs society £4,585. • Each educational underachiever costs society £1,000 a year. • A truantee costs £4,000 a year. • A lower end substance abuser costs at least £11,800 per year. • Improved Psychological Health and Wellbeing saves £3,000 per year. • No action in cases of physical inactivity or obesity can lead to a cost of £2,715 per individual per year.

9.525 The report concludes that through the work of Sport Development Organisations like BFC Community Sports Trust, the financial cost to society can be lowered by reducing the risk of such outcomes/behaviours in individual participants, with potential cost savings per participant per annum as follows:

1) Crime and Anti-Social Behaviour- £724.87 2) Educational Attainment- £127.50 3) Educational Attendance- £180.40 4) Substance Misuse- £2,265.60 5) Wellbeing- £430.20 6) Fitness and Obesity- £197.65 7) NEET- £247.90

6 Sportworks. Report by Sported and Substance, 2013

177 9.526 It is not maintained that BFC can or even should solve all these problems, rather that their increased provision could further prevent the likelihood of such costs occurring in a percentage of patrons who may be at risk due to chance or various other factors. Therefore they will be making a cost saving to society, both socially and economically. It is virtually impossible to make a finite and complete cost saving, given all the factors involved, their crossover into other categories and also allowing for the impact of the physical aspect of the new facilities, but in the absence of other verified measures, the methodology of the Sportworks research can be used to provide some arbitrary figures to give an estimate of the value of the community programmes run by the Trust. Of the 3,866 additional participants projected in the first year of operation, 1,580 are under 18. Using the Sportworks methodology, the reduction in risk of negative behaviours amongst this group can be multiplied by the cost saving per person, to give an idea of the sort of annual saving to society that the increased provision will make, with this detailed in the following table as calculated by officers. Using this approach indicates a potential saving of over £7m to society from this provision alone.

Risk% Projected Revised Reduction Cost Number Potential impact% Risk% in Risk% Saving of 1,580 Saving £per now at person risk Crime/ASB 52.50 30.11 36.69 15.81 724.87 250 £181,217 Ed Attain 54.90 23.22 42.15 12.75 127.50 201 £25,627 Ed Attend 31.03 14.52 26.52 4.51 180.4 71 £12,855 Substance 58.48 32.84 39.28 19.20 2,265.20 303 £6,871,171 misuse Wellbeing 62.58 22.92 48.24 14.34 430.20 227 £97,421 Fitness 46.03 15.81 38.75 7.28 197.65 115 £22,734 and Obesity NEET 45.09 15.06 38.30 6.79 247.90 107 £29,595 TOTAL £7,240,620 Table 12: Cost Saving Analysis of additional provision for under 18 year olds

9.527 Total Estimated Cost Savings – The applicant has independently used the same methodology for calculating the overall annual value of the Trust’s activities, to generate social cost savings projections for each of the Trust’s strands of work. The research carried out has applied the methodology more conservatively than the above assessment, as it calculates an upper and lower limit, with the latter better reflecting the extent and reliability of the data being processes, to provide greater confidence in the estimated values. The results of the costs savings calculated are as follows:

• Sports and Coach Development = £1.0m to £3.7m. • Education Support = £2.0m to £3-7.2 million. • Community Cohesion and Support = £2.8m to £8.95m. • Health and Wellbeing schemes = £0.56m to £2.4m. • Mass Participation Events = £1.2m to £8.1m.

178 • The Learning Zone = £0.49m to £3.2m. • Economic Regeneration and Employment = £0.16m to £0.52m

9.528 The results therefore estimate the work delivered by the Trust in the financial year 2012/13 would have had a conservative value in terms of costs savings to society of a minimum of over £8m. On the basis of a 30% increase in participants once the stadium and its facilities are complete, the research expects the conservative value of the work delivered in terms of costs savings to the community would increase to over £11m annually (based on assessment of new facilities and opportunities).

9.529 Given these figures are estimates, and include considerable variables, they should not be taken as fixed, verified amounts, rather they should be seen as one indicator of the significant values potentially attributable to the community benefits proposed. In this context they show that the value of the community work delivered and proposed is considerable, with the new stadium providing a major opportunity to secure and enhance this work.

(vi) Securing the benefits

9.530 Ensuring the existing community benefits are maintained and that the proposed increase in provision, which is facilitated by the new stadium, is delivered is crucial. It is recommended this be achieved through the use of a planning obligation under s106 for a ‘cascade mechanism’ that secures a requirement for more community work to be carried out beyond an agreed baseline level in times of greater prosperity for the club. This would also ensure that provision never drops below this baseline level, both in terms of activities and facilities. Additionally, as circumstances will change, if these results were to be used to set a baseline for community benefits provision, the assessment should be conducted again closer to completion of the stadium.

9.531 In other words the Council and the club, through the Trust, will agree a set of ‘deliverables’, including increased sports participation and community use. The activities of the BFC and Trust would be reported annually with the volume of projects, participants and indicators of sports development, social inclusion, education, health, and community safety used to record and evaluate how the deliverable benefits have been met.

9.532 To maximise future potential for greater community benefits and share in any increased success the club may achieve as a consequence of the new stadium, it is recommended the s106 obligations include triggers requiring increased provision where events indicate increase success for the club. For example this could include where average annual attendances exceed 15,000 or the club is promoted to a higher division. This would help capture greater community benefits should there be an uplift in the success of the club, which would have been facilitated by the stadium.

3. Conclusion

9.533 The new stadium will increase the community impact and benefits of the BFC Community Sports Trust through provision of new, larger and improved facilities, as well as the creation of greater synergies with the club through co-location, which will increase its prolife and accommodate its expansion. This is consistent with

179 objectives of the BAAP which identifies the opportunity for BFC and a new stadium to make a significant contribution to local area regeneration, local pride and culture, as well as delivering initiatives that support community cohesion and facilitate greater social inclusion.

9.534 The proposal aims to provide bespoke improved facilities and this will allow the club to provide greater facilities to greater number of people and this has the potential to create a sporting legacy. Such a legacy is dependent on the stadium, which is in turn dependent on funding produced from the sale of land for residential use. In short the proposals are anticipated to eventually lead to a 50% increase in participation, with 30% to be achieved in the first year after opening.

9.535 The community benefits would be secured through agreeing a set level of deliverable projects and outcomes, based on the above analysis of forecasted results, with these to be included in a s106 obligation. This has the benefit of ensuring that BFC and its Trust’s existing community work, which is not presently adequately secured, and the future provision anticipated, are both sustained.

9.536 The tangible social, health, community and sporting benefits of the football club and its associated activities are substantial and widespread, and their particular focus on younger children, and special projects for the disadvantaged, at risk and the disabled, offers inclusive opportunities and potential savings for society as a whole.

9.537 Therefore the securing of the existing and potential community benefits is a material consideration and this is considered to have a major positive impact on social and economic life in the Borough. Balancing this against the impacts of the relocated and expanded stadium, and in particular the adverse impacts already discussed from the high density and tall residential buildings proposed to fund it is therefore a key question for this application.

K. Sustainability

9.538 At the heart of the NPPF is a ‘presumption in favour of sustainable development’, which requires local authorities as part of any plan-making or decision-making to provide clear guidance on how the presumption should be applied locally. In addition, the NPPF sets out seven core land-use planning principles that the Government has identified as underpinning both plan-making and decision-making. Of these, the following is considered relevant to sustainability:

‘Support the transition to a low carbon future in a changing climate, taking full account of flood risk and coastal change, and encourage the reuse of existing resources, including conversion of existing buildings, and encourage the use of renewable resources (for example, by the development of renewable energy).’

1. Sustainable Design

9.539 London Plan – The Mayor of London has a vision for the city to become the exemplary sustainable world city. In achieving sustainable development, the Mayor has published a series of strategy documents setting out the policies for London:

• The London Plan

180 • Mayor’s Energy Strategy • Mayor’s Air Quality Strategy • Mayor’s Biodiversity Strategy; • Mayor’s Municipal Waste Management Strategy • Mayor’s Ambient Noise Strategy • Mayor’s Sustainable Design and Construction SPG

9.540 LP policy 5.3 relates to sustainable design and construction and states the following:

'A – The highest standards of sustainable design and construction should be achieved in London to improve the environmental performance of new developments and to adapt to the effects of climate change over their lifetime.

B - Development proposals should demonstrate that sustainable design standards are integral to the proposal, including its construction and operation, and ensure that they are considered at the beginning of the design process.

C - Major development proposals should meet the minimum standards outlined in the Mayor's supplementary planning guidance and this should be demonstrated within a design and access statement. The standards include measures to achieve other policies in this Plan and the following sustainable design principles:

a minimising carbon dioxide emissions across the site, including the building and services (such as heating and cooling systems) b avoiding internal overheating and contributing to the urban heat island effect c efficient use of natural resources (including water), including making the most of natural systems both within and around the buildings d minimising pollution (including noise, air and urban run-off) e minimising the generation of waste and maximising reuse or recycling; f avoiding impacts from natural hazards (including flooding). ’

9.541 LP policy 5.5 relates how the Mayor expects 25% of the heat and power used in London to be generated through the use of localised decentralised energy systems by 2025, with the development of decentralised heating and cooling networks at the development and area wide levels, including larger scale heat transmission networks, to be prioritised. LP policy 5.6 expects developments to evaluate the feasibility of Combined Heat and Power (CHP) systems, and where a new CHP system is appropriate also examine opportunities to extend the system beyond the site boundary to adjacent sites.

9.542 Many other policies of the LP such as 5.7 (renewable energy), 5.9 (heating and cooling) and 5.10 (urban greening) look to maximise the sustainability of development, with on-site renewable energy required where feasible and energy efficient building and environmentally sustainable practices to be incorporated in designs.

9.543 LP policy 5.2 sets out a minimum target reduction for carbon dioxide emissions in buildings of 25% over the Target Emission Rates outlined in the national Building Regulations (this will rise to 40% for applications received after October 1 st , 2013). The emissions reduction target should be achieved in accordance with the “be lean, be clean, be green” hierarchy:

181 • Be Lean: The reduction of energy demand and CO 2 emissions from using less energy, in particular by adopting sustainable and passive design and construction measures;

• Be Clean: Proposals for the reduction of energy demand and CO 2 emissions through supplying energy efficiently; • Be Green: Renewable energy technologies to be incorporated.

9.544 Local Plan – Policies with similar objectives in respect of sustainability are provided the saved policies of the UDP as well as the BAAP.

2. Sustainability Assessment

9.545 The applicant has submitted a sustainability statement, which presents the outcome of the sustainability appraisal of the proposed development and details the approach that the applicant and the design team have collectively taken towards sustainable development and environmental performance. The ES also considers environmental impacts

9.546 BFC has indicated they would consider the following schemes and examples in order to ensure that sustainability is integrated into the design and operation of Brentford Community Stadium:

• Sustainability in Sport Foundation • London 2012 Olympics • ISO 20121: for Event Sustainability Management • Carbon Trust Standard • Fans with Footprints incentive scheme

9.547 A range of sustainable features are proposed to be part of the scheme as follows:

9.548 Transport – To reduce road congestion and pollution levels by enabling walking, cycling and use of public transport, and reducing the need for travel by private cars, the proposal would utilise the site’s proximity of public transport, as well as provide secure cycle storage and electric vehicle charging points. Additionally, the match day and non-match day travel plans aim to maximise sustainable modes of travel.

9.549 Energy – To address the causes of climate change by reducing emissions of greenhouse gases, in particular carbon dioxide, the development would look to be as energy efficient as possible and incorporate generate energy from low or zero carbon technologies. The proposal has sought to reduce its overall energy consumption as summarised below.

9.550 Energy Efficiency Measures :

9.551 Stadium – The following key energy efficiency design measures to reduce emissions have been incorporated in the stadium’s design:

• External shading and limited glazing on west/south/east facades to avoid the need for active cooling and limit overheating; • Proposed new thermal element U-values;

182 • Energy efficient external lighting with minimum lux levels, photo cell operation and dawn to dusk time switches to reduce the minimum safe lighting level for security. • Energy efficient lifts which operate on standby during off-peak periods, have energy efficient lighting and a regenerative drive unit to recover energy from its operation; • Building Energy Management System (BEMS) to provide accurate and robust control with monitoring, regular maintenance and inspection. • Inverter drives installed on all fans/pumps to control the speed of each fan/pump to accurately match the duty and load; • Energy-efficient heat recovery ventilation system designed to achieve a specific fan power of no greater than 2.1W/(litre.s-1); • Common areas, corridors and store areas to use dimmable PIR control to reduce energy use and reduce running costs based on reduced operation; • Photoelectric sensors provided in luminaire fittings adjacent to windows to allow for dimming when sufficient natural light is available; • Low flow PIR controlled wash hand basin taps; and • Air permeability of 5m3/m2.hr @ 50Pa or less.

9.552 Residential Accommodation: • U values of: Floors: 0.13 W/m2K; Roof: 0.13 W/m2K; External walls: 0.15 W/m2K; Windows: 1.5 W/m2K; Doors: 1.0 W/m2K (solid); Doors: 1.5 W/m2K (glazed); • 100% of all fixed internal lighting to have dedicated low energy fittings with suitable lighting controls; • Air permeability of 3m3/m2hr @ 50Pa or less; • Construction details with a y-value of 0.08; and • Display energy metering.

9.553 Be Clean Strategy – The nature of the spaces at the site means that the focus is for communal heating systems to serve the residential buildings proposed for the site. Within the communal heating systems there are broadly two options that achieve emissions reductions over a communal gas boilers system: • A communal heating system fed by a combined heat and power (CHP) engine with condensing gas-fired boiler back up; and • A communal heating system fed by air source heat pumps (ASHPs).

9.554 Be Green – The applicant considers that the renewable technologies most technically suited to the buildings would be the use of PV on the roof-space of the stadium, and ASHPs for the communal heating systems for the commercial and residential areas.

9.555 Energy targets – Consequently, as a result of the incorporation of the above passive design measures, energy efficiencies and low and zero carbon technology the proposed development has been modelled at the design stage to achieve an overall site-wide reduction in CO 2 emissions of 36% meeting the relevant target. However for the stadium alone to meet the relevant target, further measures to achieve compliance are needed. The applicant considers this can potentially be achieved in one of two ways – either through the inclusion of additional photovoltaic

183 (PV) panels, or through a s106 payment to the Council to invest in renewable energy schemes off-site. The use of PVs is not feasible given it would add significantly to the cost of the scheme, affecting its viability, whilst it may also have undesirable townscape implications. Therefore mitigation to offset the shortfall of 85.79 tonnes of CO 2 per year is recommended, with a contribution to be made Council’s up and coming Carbon Offset Fund at a rate of £46 pounds per tonnes (i.e. 85.79 tonnes of CO 2 / year x £46/tonne of CO 2 x 30 years = £118,390. This is permitted by the LP, which says where it can be demonstrated targets cannot be fully achieved on site , any shortfall may be provided off-site or through a cash in lieu contribution to the relevant borough to be ring fenced to secure delivery of CO 2 savings elsewhere.

9.556 BREEAM – The applicant has sought to achieve a BREEAM ‘Very Good’ rating for the fit-out areas of Brentford Community Stadium.

9.557 Combined Heat & Power – Combined heat and power (CHP) systems integrate the production of usable heat and power (electricity), in one single, highly efficient process. Large developments should look to include a centralised CHP to maximise energy efficiency as this can provide efficient production of electricity, heating and hot water requirements.

9.558 The application proposes decentralised CHP systems on each housing plot, as they consider they are unable to provide a centralised energy centre upfront, as part of the stadium construction due to the financial risks and capital construction costs, whilst there are no existing heat networks in the vicinity of the site. Additionally, it is understood that due to the heat profile and operational use of the stadium, it is not technically feasible or appropriate to implement a CHP for the stadium alone. Nonetheless, the club are committed to ensuring that there are appropriate provisions for the stadium to connect into an energy centre at a later date (where sufficient demand from the residential development comes forward). Additionally, the Club will ensure that the stadium does not prohibit the ability for an energy centre to be incorporated as part of the wider Masterplan. In essence, any works done for the remainder of the site should be done in a way that enables (or does not restrict) the connection of residential buildings to a future heat network. A condition in this regard is recommended.

9.559 Water – To conserve water by promoting water efficiency, water recycling and Sustainable Drainage Systems (SuDS). The proposed development will aim to develop a water strategy that reduces water demand through its design and specification. Consideration has been given to the efficient use of water in the construction phase and the team will require the contractor to monitor water consumption during the construction phase. Within the stadium, the design team will ensure that the building limits its water consumption by specifying water efficient sanitary fittings in the shower and toilet facilities to conserve water at its point of use where feasible. Rainwater harvesting with re-use on the pitch is proposed.

9.560 It is anticipated that a new surface water management system will connect to the existing infrastructure, which will require an infrastructure assessment and approval prior to commencement of work (as capacity may need to be increased at the applicant’s cost). Conditions in accordance with Thames Water’s comments are recommended. Sewerage infrastructure is adequate for the development.

184 9.561 Materials – To reduce the global, social and environmental impact of the consumption of resources by using sustainably produced and local products. Wherever possible, the materials’ specification and products used for the proposed development will display the following characteristics: • Low embodied energy that require little processing • Locally sourced • High recycled content including steel, glass, cladding and flooring products • Reused materials including reclaimed materials • Durable • Can be re-used, recycled, refilled, recharged or reconditioned • Lightweight to reduce volume of materials and require less fuel during transport • Accredited to a recognised environmental standard

9.562 Waste and recycling – Full details of waste and recycling storage facilities for the outline residential and commercial development would be submitted with reserved matters. For the stadium, a condition requiring submission of a Waste Management Strategy is recommended, with this to include measures to minimise waste and encourage recycling.

3. Conclusion

9.563 The proposal includes adequate measures to ensure the development is able to achieve current standards for energy efficiency and sustainable building design. Conditions will secure details of the various measures proposed and required. The scheme includes provision for connection to a future community heating network that may arise.

L. Equalities and Accessibility

1. Equalities

9.564 The Council has to give due regard to its Equalities Duties and in particular with respect to its duties arising pursuant to the Equality Act 2010. The application includes a football stadium, and would accommodate the existing operations of a number of community uses, including the BFC Community Sports Trust. The Trust has specific projects that include in their aims the elimination of discrimination and provide for more cohesive and inclusive communities with regards to race, age, disability, gender and sexuality.

9.565 The new stadium would provide a replacement stadium for BFC, enhancing its facilities and maintaining the cultural and recreational use for existing supporters, with significantly improved facilities for women and people with disabilities due to better access and facilities compared to the current ground. The new ground could also provide an opportunity for use by new supporters, including those from community groups under represented amongst the current fan base, such as women and people from minority groups, who may find a new facility more inviting with it not necessarily having a particular tradition or history associated with any particular group.

185 9.566 As the existing operations of the Trust would be maintained and enhanced by the proposal, and secured by a legal deed, the development is considered to have a positive impact in regards to promoting equality. If refused, the existing community work is likely to continue, though it is not secured, and in the long term it may be at risk should the club move away from the region to improve its financial sustainability.

9.567 Therefore it is considered due regard has been given to the Council’s duty in respect of its equalities duties and that if approving or refusing this proposal the Council will be acting in compliance with its duties.

2. Accessibility

9.568 Sustainable development includes meeting needs of the community. Both the London Plan and UDP have policies that promote inclusive access to the built environment and facilities.

9.569 London Plan – LP policy 7.2 requires all new development in London to achieve the highest standards of accessible and inclusive design. Other polices including those on housing design (3.5), housing choice (3.8), visitor infrastructure (4.5), and neighbourhoods (7.1) include requirements for the proposed uses within the development, as well as the design of the public realm, car parking facilities, and pedestrian environment. In particular the requirements for this development are:

• All dwellings to meet Lifetime Homes standards with satisfactory access, adequately sized rooms, convenient and efficient room layouts • At least 10% of all dwellings to be wheelchair housing, or easily adaptable for residents who are wheelchair users across a range of unit types. • At least 10% of new hotel bedrooms are wheelchair accessible • Provision of wheelchair parking spaces for the housing and stadium • Accessible commercial premises, including the stadium and its facilities

9.570 Local Plan – The UDP also has many policies in respect of accessibility for housing and new stadia (H.4.1, C.4.3, C.5.1A, T.2.1, T.3.1 and T.3.2)

9.571 Housing and hotel – As the housing and hotel are outline, full details of their design will be submitted with reserved matters and the above requirements would be the subject of conditions to ensure compliance. Ongoing arrangements for accessibility to the hotel and its facilities should be addressed in a management plan, with a further condition recommended in this regard.

9.572 Stadium – The new stadium has been designed to be fully accessible, and would provide inclusive access for wheelchair users, people with limited mobility, partially sighted and blind, deaf, people with learning difficulties, and people with mental health problems. This would be a major improvement on the existing home ground, which has inadequate facilities for disabled people.

9.573 The stadium approaches, entrances, circulation routes, pitch viewing areas and seating, as well as the stadium facilities (toilets, kiosks and hospitality areas) would be fully accessible, as would the Learning Zone, Interim Education Centre and office areas. Consideration must also been made for signage, emergency escape, ticketing and arrangements for personal assistants for disabled people. 171 wheelchair

186 viewing spaces are provided, which exceeds the minimum recommended provision of 150 spaces. These spaces are provided throughout the ground, including away supporter areas. 20 of the spaces would be accessed by a ramp (1:12 grade) which is non-compliant. Other options such as platform lifts (undesirable) or longer ramps (not practical) were discounted. Stewards would provide assistance for access to these spaces if required. There are also 252 spaces available for people with ambulant disabilities, with these spaces being easier to access and of larger dimensions.

9.574 Following comments from the GLA, the applicant has sought to refine some details of the stadium design, and appointed an Accessibility consultant in this regard to prepare a detailed Stadium Access Strategy. This strategy summarises the accessibility measures proposed, and demonstrates that the stadium meets the relevant requirements and recommendations of guidance relating to football stadia design including Accessible Stadia, Building Regulations and BS 8300. The club has also agreed to a condition requiring the formation of an access consultative group with supporters to provide a forum for any issues that may arise.

9.575 In respect of accessibility to the stadium from outside the site, the stadium would be served by many bus routes, with all buses being wheelchair accessible. The permanent opening of the underpass and provision of a new ramp (1:21 grade) to the London bound platform of Kew Bridge station would make that side of the station fully accessible on match days and non-match days. There is presently no prospect of providing step free access to the other platform as the cost is not within the scope of the club’s finances. Other stations nearby including Acton Town and Brentford are wheelchair accessible, and the club proposes a shuttle service from latter on match days for disabled visitors. On match days 22 (13%) of stadium parking spaces would be for the disabled, which exceeds the recommended minimum of 6% of stadium parking. On other days 9 spaces would be available. The proposed off-street parking to be secured, would have provision for disabled parking, with a park and ride service to the stadium

3. Conclusion

9.576 The proposed development provides opportunities for improvements in inclusiveness for different groups in the community and in particular people with disabilities. Further details of the outline elements and the proposed measures for the stadium will be secured by conditions.

10.0 Planning Obligations

10.1 A planning obligation may be required to control the impact of a development particularly in circumstances where the desired restrictions go beyond the scope of planning conditions. In accordance with section 106 of the Town and Country Planning Act 1990, the local authority will enter into a legal agreement with the applicant (including anyone else who has a legal interest in the land) to secure planning obligations.

10.2 Paragraph 203 of the NPPF says local planning authorities should consider whether otherwise unacceptable development could be made acceptable through the use of

187 conditions or planning obligations. Planning obligations should only be used where it is not possible to address unacceptable impacts through a planning condition. Whilst paragraph 204 says obligations should only be sought where they meet all of the following tests: • necessary to make the development acceptable in planning terms • directly related to the development; and • fairly and reasonably related in scale and kind to the development.

10.3 Planning obligations can include financial obligations requiring monetary contributions to the local authority to fund works or services as well as in-kind obligations requiring specific actions to be performed by specific parties.

10.4 LP policy 8.2 notes that in respect of obligations, economic viability will be considered, and that affordable housing, funding for Crossrail, and other public transport improvements will be given the highest importance. However importance should also be given to tackling climate change, learning and skills, health facilities and services, childcare provisions and the provision of small shops.

10.5 Hounslow’s Planning Obligations Supplementary Planning Document (SPD) sets out in principle what kinds of planning applications will require planning obligations and in broad terms how monies will be spent on projects related to the proposed development.

10.6 The SPD says the Council recognises that in specific instances planning obligations may be a significant factor that affects development viability. In this regard it is recognised that there may be circumstances where a developer may consider that it is not feasible for the proposed development to meet all the requirements set out in local, regional and national planning policies and still be economically viable (for example, where development specific costs are exceptionally high). The onus will be on the developer to provide information regarding the viability of the scheme. In these circumstances, the Council will review the range and nature of obligations

10.7 The following sections discuss the need for planning obligations arising from the development and its impacts.

(i) Affordable Housing

10.8 The provision of affordable housing contributes towards sustainable local communities. People on different income levels all need a choice of where they can live, close to family and community networks and accessible to workplaces.

10.9 Typically affordable housing, being a strategic requirement for London, would be insisted upon. However in this case the exceptional cost of the stadium, which facilitates major community benefits, precludes any provision at this point in time, with the applicant demonstrating through independent assessment of the development’s viability that this would make the scheme unviable and would reduce the funding available to subsidise the stadium, prohibiting its delivery. The current estimated cost of affordable housing provision that would comply with the Council’s requirements is over £87m.

188 10.10 Although it is accepted that in the current circumstances no affordable housing is viable, given the provision of such housing is a local and strategic priority, it is appropriate to require a viability to be reviewed during the various phases of the development. The applicant has agreed to a review mechanism and this would be included in a section 106 agreement where if viability increases to an agreed level then affordable housing would be provided on site and/ or contributions will be made up to a capped amount, which will be the equivalent value of a policy compliant scheme.

10.11 There is a degree of uncertainty regarding viability, as the applicant is still in discussion with existing landowners and development partners. Therefore it is recommended that the viability be initially retested prior to the signing of the s106 deed. Members should note that the worst case scenario, of no affordable housing, is already proposed and so they should make a decision on this basis. Should viability worsen and the applicant is unable to complete the s106 obligations and deliver the scheme as proposed, then the application would either be refused or brought back to committee for further consideration.

(ii) Transport

10.12 New developments generate additional trips to and from the site, which can add pressure to roads, pedestrian and cycle routes, and public transport facilities, and will lead to additional problems if measures are not taken to address the impact of new developments. The Council will therefore seek to ensure that the transport impacts of new developments are mitigated or compensated for

10.13 The proposed development includes works that would improve transport infrastructure, the opening of an accessible entrance to Kew Bridge station, and enhanced pedestrian and cycle routes along Lionel Road South and by a new east- west route across the site. The SPD formula calculates contributions of £462,000 for the stadium, £1,001,000 for the housing, £35,250 for the hotel, and £45,000 for other commercial uses, giving a total of £1,543,250.

10.14 However TfL the highway authority for the adjoining road network and management of London Underground has identified only the need for a contribution of £175,000 for an additional AM peak bus service along the A315 route owing to increased demand generated by the development (cumulatively with other nearby development). Other impacts on public transport are satisfactory with management. Noting pedestrian flows to the north end of Lionel Road, a contribution of £45,000 for improvements is recommended, and a further contribution of £45,000 for provision of vouchers to new occupants to use towards sustainable transport modes (e.g car club membership) is recommended to complement the Travel Plan and assist its objectives to reduce car travel.

10.15 Impacts on local rail stations are able to be met by existing and already planned increases in capacity, including match days. Significant management of match day impacts will be required, with this to be secured through a Stadium Management Plan, which includes a Local Area Management Plan that covers crowd control and management of pedestrian routes. Existing peak hour congestion at Gunnersbury Station is acknowledged, but the proposed non-match day traffic movements from the development will not unduly add to this issue, whilst match day impacts do not

189 generally conflict with these peak usage times. The applicant would not be expected to make any contribution to alleviate an existing deficiency not related to the proposed development.

10.16 Other transport impacts from use of cars potentially require mitigation, and it is recommended that a contribution of £200,000 be made for consultation and implementation (if agreed) costs of a match day, and a non-match day CPZ, with £10,000 for the issue of an initial permit to residents subject to the match-day CPZ.

(iii) Public Realm

10.17 Contributions in respect of the public realm may be sought to enhance the local street scene and knit a development into the surrounds. The SPD recommends that is preferable that large schemes make direct improvements to the public realm in lieu of a contribution. Otherwise the formula for a contribution for the development results in a contribution of £623,723. The scheme includes extensive public realm improvements comprising 6,395sqm of new public realm and concourse areas, and a further 2,763sqm of improvements including new footpaths and so no contribution is necessary.

(iv) Amenity/ Open Space

10.18 Provision of amenity space, including children’s play space and private amenity space is important in achieving good quality housing, whilst wider recreational needs are met by larger areas of open space for which new housing can add to demand for. The proposed development only partly meets the UDP private amenity space standard, and does not provide play space on site for older children. Using the SPD formulae for private amenity space shortfall, play space, and open space, a contribution of £428,610 could be required.

10.19 However the development would meet the minimum baseline standard for private amenity space of the more recent London Plan, and includes adequate on site play space for under 5s and 6-11 year olds, also in accordance with the LP. Use of nearby open space for older children is accepted by the LP, with Gunnersbury Park and Carville Park south being within reasonable walking distance of the whole site. As a result, a contribution is not considered necessary.

(v) Education

10.20 The additional housing would accommodate a significant number of people, including children. Although assessment shows that the child yield generated by the development may be accommodated within local schools, which have recently been expanded in size to cope with high growth in demand, the ongoing demographic trends point to continued rises in demand from higher birth rates and population growth. Therefore it is recommended the development provide funding for additional primary and secondary school places in accordance with the formula of the SPD, which gives a total contribution of £2,058,810.

10.21 Noting the provision of new classrooms and staff facilities for the Interim Education Centre, as well as the benefits of the 70 seat lecture space and media room, it is reasonable to provide some credit for the in kind provision made on site. This

190 provision has been valued at £500,000 and the contribution reduced accordingly. This would reduce the required contribution to £1,558,810.

(vi) Safety and Security

10.22 The SPD says that in most cases, safety and security measures will be provided as an integral part of the development, or will be required by planning condition. In some cases, a planning obligation may be sought towards strategic safety and security measures on advice of the Metropolitan Police in order to create a safer environment within the area of the proposed development. Where this is appropriate, the Council will seek the provision of on or off site features.

10.23 For this development there will be considerable security and safety procedures required, however they will be met on site by the applicant (e.g. CCTV) and secured by condition, through licensing (e.g. Safety Certificate), or obligations relating to the management of the stadium and associated impacts (Stadium Management Plan/Local Area Management Plan).

(vii) Community and Health Facilities

10.24 Population growth can increase demand for community facilities and so the SPD says contributions may be sought where there is an identified deficiency which would arise from or be exacerbated by a development. Health contributions can be calculated using a standard model (HUDU), giving a capital contribution of £1,323,485 and revenue contribution of £5,230,900, whilst the SPD has a formula for community facilities contributions which is calculated at £222,000.

10.25 In this instance the ES has concluded there is no identified need that would arise from the development in respect of health that would require a contribution to be made. In this regard GP provision per patient was considerably under the best practice average patient list size for the 7 GPs located within 1 mile of the site, whilst in respect of acute and secondary care there will be a surplus of hospital beds by 2015/16 owing to refocus of medical care provision following abolition of Primary Care Trusts, to provide greater care within the community and more preventative health. The additional demand for hospital beds generated by the development would be readily accommodated in the expected surplus, with the first occupation of the development not occurring before 2016.

10.26 The new stadium includes various hospitality spaces and offices which would be suited to use by community groups and the local authority for meeting spaces and events, the latter potentially providing locations for health, sport and education programmes run the Council. The applicant has agreed for use of these other spaces by community groups and the local authority at low cost, with facilities to be available at subsidised rate that covers only operational costs such as insurance, lighting and security. The final rates of use are to be determined but it is recommended these be set no higher than 20% of equivalent commercial rates. Additionally, to maximise reach of community programmes, it is recommended that space be provided free to the Council for health and well-being events and training, with this to entail a minimum of 4 exhibitions and 12 events per annum.

191 10.27 The new stadium is also a major community asset, which with the associated BFC Community Sports Trust, will facilitate extensive preventative health measures, and also provide subsidised community meeting rooms. Taking these matters into account, no community and health contribution is required.

(viii) Employment and Training

10.28 A key aim of sustainability is to maintain economic growth. Employment and training contributes towards this aim, and jobs and skills for local people can reduce the need to travel. The SPD seeks obligations for strategies in respect of training during construction activity as well as job brokerage, the latter looking to secure local people employment. The proposed development would displace some existing jobs, but overall it would result in an increase in full and part time employment. The applicant has agreed that construction training opportunities would be provided by the development contractor for the duration of the works, whilst the club and the Trust already provide work placement, training and local employment opportunities, and that these would be enhanced by the development.

(ix) Stadium Management Plan

10.29 As detailed in earlier sections, this is a suite of documents that would provide from the safe and secure use of the stadium, and management of spectator impacts outside the site, particularly on main routes to and from public transport, stadium car parking management, coach and taxi management plans, and endeavours to secure and arrangements for off-street commercial car parking along the A4/ M4 corridor, with the aim of minimising match day disruption of local residents and businesses.

(x) Community Benefits

10.30 A major positive impact from the development is the stadium and its associated community benefits. Securing these benefits is important given these are amongst the key reasons justifying departure from other Development Plan policies. As already discussed, it is recommended this be achieved through the use of a planning obligation requiring an annual provision of community projects, numbers of participants and indicators of sports development, social inclusion, education, health, and community safety outcomes by the owner’s of the club, through BFC itself and the BFC Community Sports Trust.

10.31 The obligations in this regard need to be robust given they are afforded considerable weight in the assessment of the application, but only on the basis that they will be secured. It is recommended that the obligations for community work address the timing of the stadium’s delivery, to cover what the club will do after implementation of the permission whilst the stadium is under construction), what it will do as a minimum once the stadium is complete, a well as enhanced measures should the club’s circumstances improve.

10.32 In respect of the latter, the obligation would have a ‘cascade mechanism’ that secures a requirement for more community work to be carried out beyond an agreed baseline level in times of greater prosperity for the club. This would also ensure that provision never drops below this baseline level, both in terms of activities and facilities. Potential triggers for this increased provision would be negotiated but they would be reflect events linked to increased performance of the club such as a certain

192 level of average annual attendance being reached, promotion of sale of the club, though in respect of the latter it is noted that the obligation runs with the land.

(xi) Considerate Contractors Scheme

10.33 Owing to the scale of the development and duration of the works, which have the potential for significant disruption, it the developer should register with the Considerate Contractors Scheme. This will. Ensure the site activity is monitored by an experienced industry professional to assess their performance against the eight point Code of Considerate Practice which includes the categories Considerate, Environment, Cleanliness, Good Neighbour, Respectful, Safe, Responsible and Accountability.

(xii) Carbon offset

10.34 This is required to offset the shortfall in recommended CO 2 emissions relating to the stadium. A contribution of £118,390 is recommended, with this to be used to secure delivery of CO 2 savings or sustainability improvements in nearby Gunnersbury Park, where environmental improvements and retrofitting/ enhancement of existing buildings are necessary .

(xiii) Phasing/ Delivery

10.35 An obligation in respect of how the development is to be phased, to ensure the delivery of the stadium and the necessary infrastructure associated with it, including the bridge, underpass and public realm works, are completed prior to occupation of the residential development is required. Given the likely complexity of the arrangements this is considered best dealt with within a legal deed rather than as a condition.

10.36 Noting the physical constraints of the site, concurrent construction of some of the residential elements is reasonable and will assist viability and hence the potential for the site to make a contribution to affordable housing upon the viability review. Restrictions would be applied through the obligations on occupancy of residential units with these to link commencement of the residential buildings and stadium, and require contractual certainty that the build contract and funding are in place to complete the stadium before construction of the residential starts, and ultimately limiting occupation of all, or all except for a minority of units subject to adequate progress being made on the stadium, until the club is relocated to Lionel Road.

(xiv) Relocation strategy

10.37 An obligation requiring submission and implementation of a written scheme to be approved by the Council for the managed relocation of all of the firms and businesses remaining on the site.

10.38 The table below summarises the contributions discussed above.

Required/ Obligation SPD formula/ criteria Proposed Recommended Affordable 41% of dwellings, Yes None owing to effect

193 housing subject to viability on viability. (60% rented tenure Viability to be 40% shared assessed during ownership) implementation Deferred contribution should viability improve. Contributions of £200,000 – CPZ £200,000 for CPZ, £10,00 initial match £10,00 initial match day CPZ permits day CPZ permits £175,000 – buses £175,000 for buses £45,000 sustainable £1,543,250 £45,000 sustainable Transport transport transport Travel Plan (TP) £45,000 pedestrian £45,000 pedestrian network network improvements improvements Match day TP Match day TP Non-match day TP Match day TP Non-match day TP Direct improvements Preferable that large comprising 6,395sqm schemes make direct of new public realm improvements to the Yes, direct and concourse areas, Public realm public realm in lieu of improvements & a further 2,763sqm a contribution, or: of improvements £623,723 including new footpaths. Compliance with London Plan private No, taking account amenity space that more recent baseline standards, & London Plan on-site provision for standards will be met, Amenity/ Open £428,610 as UDP children’s play for and community Space standard part met. under 5s & 5-11 year benefits, which olds; plus wider include wider sporting sporting participation participation and well- impacts of BFC being benefits. Community Sports Trust. Contribution of £2,058,810 for £2,058,810 for £1,558,810 and primary and primary and provision of space for Education secondary school secondary school Interim Education places places Centre (in kind value of £500,000). Would be provided by CCTV, landscape Safety/ Security Yes applicant –secured by maintenance conditions. Community & HUDU model No, taking account of New stadium is a

194 Health facilities £1,323,485 (capital), provision of stadium & major community £5,230,900 (revenue) community benefits, facility, plus & £222,000 for including extensive community benefits, community facilities, preventative health including extensive such as libraries, halls measures, subsidised preventative health & youth centres community meeting measures; and rooms, & noting subsidised use of conclusions of ES community meeting regarding adequacy of rooms. existing health services provision. Construction company Employment & Construction training Yes to provide training Training & job brokerage strategy. Stadium Management Stadium Plan inclusive of Local Operation/ N/A Yes Area Management Management Plan Community Benefits obligation securing current & proposed Community N/A Yes provision, with Benefits additional provision required if club is more successful. Considerate Development partner contractors N/A Yes to be a member. scheme Contribution of £118,390 to be used Carbon offset N/A £118,390 locally in Gunnersbury Park for sustainability enhancements Stadium and infrastructure to be Phasing/ N/A Yes provided first, with Delivery occupation of housing restricted. Relocation strategy to Relocation assist management of N/A Yes strategy relocation of existing businesses.

11.0 COMMUNITY INFRASTRUCTURE LEVY

11.1 Some new developments granted planning permission on or after 1 st April 2012 will be liable to pay Community Infrastructure Levy (CIL) to the Mayor of London with respect to the funding of Crossrail. This is at the rate of £35 per m 2 of new floor space where the net floor area increase exceeds 100 m 2, or where a new unit is

195 created.

11.2 This proposal is liable to pay CIL. The final liability will be determined at reserved matters stages once floor plans are approved, however the stadium alone requires a contribution of £1.3m.

11.3 It is noted that the Council is in the process of preparing its own CIL, and with proposed changes by the government to CIL charging, to make this payable on the granting of the final reserved matter, the development would be liable to this if outline permission the expected Council CIL adoption date of March 2015.

12.0 CONCLUSION

12.1 The application raises numerous planning issues for consideration, and requires a difficult and complex evaluation of many impacts, both positive and negative. This assessment has taken into account relevant Development Plan policies, the NPPF, information in an Environmental Statement and other environmental information including that submitted in accordance with Regulation 22 of the EIA Regulations 2011, and considers the three elements of sustainable development, the economic, social and environmental impacts.

12.2 The issues considered relate to both the stadium and the housing that is to fund it, with the application attracting widespread public interest with large numbers of submissions for and against it. Many statutory consultees and local amenity groups have also commented.

12.3 The primary objective of the application is the provision of a new home ground for BFC, with their existing stadium at Griffin Park being outdated and lacking in facilities, and owing to site constraints being unable to be meaningfully expanded or improved. The current ground limits opportunities to generate match day income from hospitality and sponsors, and to attract and retain new supporters, all of which would assist in putting the club on a more sustainable financial footing, noting the existing annual losses are unsustainable. Owing to these issues, the ability of the club to compete is diminished, and alternatives are needed if BFC is to survive in the Borough.

12.4 The Council’s policies provide in principle support for the proposed move, with objectives from the BAAP recognising the opportunity to provide a ‘community stadium’ hub at Lionel Road, linking a range of sports, health, education, leisure and business support facilities.

12.5 There are no other preferable sites in the Borough, whilst planning permission has already been granted for redevelopment of Griffin Park, subject to provision of a new stadium. The new stadium would be integral to helping meet the club’s longer term goals for financial and sporting success and stability, also would also provide accommodation for the associated BFC Community Sports Trust, allowing its work to expand. This work is well recognised as has great community value, though determining the value and weight to give it, as well as the overall value of BFC to the Borough and wider community is difficult. Its retention and enhancement would

196 comply with UDP polices ENV-B.1.1, C.1.3, C.1.4, C.4.3, C.5.1 and C.5.1A, the objectives of the BAAP; and LP policies 3.1, 3.2, 3.16, 3.19, 4.5, 4.6 and 4.12

12.6 The impacts of the proposal are considerable and wide-ranging. The proposed football stadium with ancillary facilities, and the new housing, would completely transform the site providing a major opportunity to add to the ongoing regeneration of Brentford. This would make a major positive contribution to wider strategic objectives of the Development Plan, to promote regeneration of previously developed sites for the enhancement of the quality of life, housing and employment opportunities, and to attract new economic development, encourage economic diversity, and direct it to appropriate areas. This would be consistent with objectives IMP.1, IMP.3 and IMP.4 of the UDP.

12.7 There are no significant land use constraints that would prohibit the proposal, with the development being generally consistent with strategic policy framework for land uses, including policies of the Employment Development Plan Document and Brentford Area Action Plan (BAAP). Use of the Duffy site for housing would be a departure from the current UDP designation of it for ‘waste management’, however this is accepted as the site is not presently used for such a use, and has not been identified for such a use in more recent strategic assessments of waste site provision whilst its inclusion within the scheme is important as it complements the regeneration of the site, especially the enhancement of the public realm of Lionel Road.

12.8 The overall scheme would create many new jobs, and significantly increase spending in the Borough by spectators, visitors and residents, aiding local economic activity and growth. The construction phase would create more than 200 jobs per year over the 9 year construction phase, whilst the expanded operations for BFC, the hotel, and other commercial uses, plus the expected expenditure of football supporters and new residents would raise permanent employment in the area by nearly 200 jobs. This would be consistent with UDP policy ENV-B.1.1 Employment Development Plan Document, and BAAP; and LP policies 3.1, 4.5, 4.6, 4.7 and 4.12.

12.9 Other major issues relating to impacts from the proposal on the environment during construction, and on both match-days and non-match days are satisfactory, subject to the recommended planning obligations and conditions.

12.10 One of the main issues of contention is the impact of the uses on the transport network, including traffic on the adjacent roads, which includes strategic roads and major intersections such as Chiswick Roundabout and Kew Bridge, which presently suffer from congestion, as well as parking overspill into nearby areas, and the constraints and capacity of the public transport.

12.11 Construction traffic is potentially disruptive given the scale and duration of the works, though it would not impact significantly on the road network, and conditions requiring appropriate routing and management will minimise impacts in accordance with UDP policies ENV-P.1.5 and ENV-P.1.6. Match-day transport impacts have been thoroughly assessed in conjunction with Transport for London. The assessment indicates that there would be some considerable disruption either side of matches to nearby roads, but that this is not significant with only relatively minor additional delays noting the existing congestion, whilst impacts on public transport would be

197 satisfactory with the management plans proposed, as the network has adequate capacity, though clearly with large crowds there will inevitably be some delays and inconvenience. Surveys show sufficient on-street match day parking would be available for the worst case situation, though endeavours are being made to secure managed off-street spectator car parking to lessen impacts .Such impacts would not unduly effect the function of the transport networks and modes serving the site or the living conditions of neighbours, and measures are proposed through planning obligations and conditions to reduce impacts. On balance, with mitigation, this is considered acceptable as the harmful impacts, though disruptive, are either temporary and intermittent, or not so significant that refusal would be recommended, with this considered to conform to UDP policies ENV-B.1.1, C.5.1A, T.1.2, T.1.4, T.2.1, T.2.2, T.2.4, T.4.3, T.4.4 and T.4.5; and LP policies 6.3, 6.9, 6.10, 6.12 and 6.13.

12.12 Effects on neighbours to the site are on balance satisfactory, in accordance with UDP policies ENV-B.1.1, ENV-P.1.5, ENV-P.1.6 and ENV-P.1.7, with mitigation provided through conditions to limit impacts from the uses proposed, including noise and lighting. Some neighbouring properties would experience noticeable loss of daylight, which in some cases is significant, although the impacts on the daylight to these properties has been minimised noting viability and it would not be so severe to warrant refusal based on the wider benefits of the development of the site and particular circumstances of the affected properties.

12.13 With the mitigation recommended and to be secured by conditions, environmental conditions are satisfactory for the uses proposed, including new housing. The proposed housing would make a significant contribution to the Borough’s supply of new housing for which there is great demand, up until 2023, in accordance with requirements of the NPPF on deliverable housing supply and LP policies regarding housing supply and quality including 3.3, 3.4, 3.5, 3.6, 3.7 and 3.8.

12.14 No affordable housing is proposed, owing to the impact its provision would have on the viability of the development. This lack of affordable housing, particularly on such a large scheme, would be exceptional, though in this instance an independent assessment of the viability of the proposal confirms that in order for the scheme to be viable, and therefore deliverable, no affordable housing can be provided at this stage. However, as circumstances may change in the future, an obligation requiring the viability to be reviewed at a later date, with a mechanism to secure a deferred contribution towards affordable housing if the viability improves.

12.15 This issue of viability is central to other issues such as density and building height, with the amount of housing proposed being shown to be the minimum necessary to fund the stadium, though it is acknowledged that the club (through its owner) has and will, make a very significant investment in the project.

12.16 The need for the housing and its role in funding the costs of the stadium is a consideration when deliberating on the quality of the design of the development and its impacts on the townscape, including views from nearby sensitive areas such as the many conservation areas and listed buildings in the locality. Of particular importance must be the potential impacts on the Outstanding Universal Value of the Royal Botanic Gardens, a World Heritage Site. A form of ‘enabling development’ is

198 therefore proposed, though this is not in its strictest sense, which is usually in the context of heritage conservation.

12.17 Townscape impacts from the development are mixed, with some areas, in particular the site itself, being significantly enhanced. Although the proposed density is considerably higher than the relevant range from the LP, the large area and relatively self-contained nature of the site affords it some flexibility, whilst the illustrative material has demonstrated that minimum baseline standards for housing quality can be met, with these to be secured by conditions, consistent with UDP policies ENV- B.1.1, ENV-P.1.5, ENV-P.1.6 and H.4.1; the BAAP, and LP policies such as 3.5 and the Housing SPG. From outside the site, the tall height of the buildings would make them apparent from a number of vantage points, including sensitive areas where the implications from change are greater.

12.18 The degree of significance of these impacts varies, and much of the impact may be mitigated through submission of reserved matters for appearance and conditions noting only the maximum parameters are being determined. Use of appropriate, quality materials and sensitive refinement of the building’s form and articulation, guided by a Design Code would reduce the magnitude of the impacts.

12.19 Nevertheless in spite of this mitigation, some harm will occur, with officers considering there to be adverse impacts to surrounding conservation areas and certain views from sensitive areas owing to the out of scale height and bulk of the proposed buildings. In light of this, the development would conflict with a number of policies of the UDP and London Plan, particularly policies in respect of conservation areas and tall buildings (including UDP ENV-B.1.2 and ENV-B.2.2 and LP 7.1, 7.4 and 7.7).

12.20 Impacts on the Royal Botanic Gardens WHS and its buffer zone, are minor, despite the very high sensitivity of these areas, as although in certain areas the upper parts of some buildings are visible, these infractions are minor and are not considered significantly harmful, so they would not reduce the ability of visitors to appreciate the Outstanding Universal Value, integrity, authenticity or significance of the Gardens, thereby complying with policy 7.10 of the LP.

12.21 With regard to the townscape impacts, and the residual harm identified, the NPPF says local planning authorities should not refuse planning permission for buildings or infrastructure which promote high levels of sustainability because of concerns about incompatibility with an existing townscape, if those concerns have been mitigated by good design, unless the concern relates to a designated heritage asset and the impact would cause material harm to the asset or its setting which is not substantially outweighed by the proposal’s economic, social and environmental benefits.

12.22 In this case, although there are positive and negative townscape impacts, but given the cumulative nature of the breaches recognised, and that that some ‘major’ and therefore substantive harmful impacts would result, officers consider that on an overall basis the development is not in accordance with the Development Plan despite other policies in support.

199 12.23 Where development does not accord with the Development Plan then it should be refused, unless material considerations indicate otherwise. Consequently the assessment must take account of other material considerations including the wider public interest derived from economic, environmental and social benefits of the development, the latter relating primarily to community benefits associated with the stadium, to determine if these outweigh the harm. Ultimately, in other words are the public benefits of the development greater than the harm?

12.24 When balancing these impacts it is also useful to consider the ultimate aims of the planning system, summarised in paragraph 8 of the NPPF, which is to achieve sustainable development which has three mutually dependent dimensions, economic, social and environmental. The main benefits of the scheme are:

Social • Provision of a modern sports stadium with full disabled access and facilities, supporting and enhancing the social and cultural well being of the community and adding to the community/sporting assets of the region. • Likely improvement to the long term financial sustainability of BFC and its existence in the Borough, protecting its long heritage (over 120 years) and adding to the identity and civic pride of the area. • Likely significant expansion of the community benefits provided by BFC and the award winning BFC Community Sports Trust with major positive impacts in the region on social inclusion, health, education, and sporting activity, especially for young people and including many disadvantaged groups, with this work estimated to have a potential conservative value in terms of costs savings to society of over £8m per year, with this to increase to over £11m in the first year of the stadium’s use with higher provision forecast after that. • New and enhanced accommodation is provided for the associated BFC Community Sports Trust, Interim Education Centre and Learning Zone securing their operation. • Provision of 910 new dwellings to meet relevant Housing SPG baseline standards for quality, including 10% adaptable for wheelchair users and with all to meet Lifetime Homes standards, helping to address the current high demand for housing.

Environment • Re-use of a previously developed site for a mix of uses including housing offsetting need for greenfield development. • Regeneration of unsightly brownfield land of low townscape value, thereby enhancing the appearance of site and acting as a catalyst for improvements to nearby rundown areas. • Creation of new and enhanced public realm to Lionel Road South and Capital Interchange Way with 6,395sqm of new publically accessible space including a park, and 2,763sqm of highway and shared surface improvements. • New paving, street tree planting, lighting and pathways will enhance the permeability of the area linking places of interest to the north, such as Gunnersbury Park, to the south and River Thames, as well as creating a new east-west route across the site.

200 • Stadium and housing meet relevant targets for energy efficiency and carbon deduction, contributing to mitigation of climate change. • Improvements to access to Kew Bridge station, with London bound platform made fully accessible. • Improvements to pedestrian safety of junction of Lionel Road South and Chiswick High Road.

Economic • Significant contribution to economic activity through increased employment and expenditure from construction of the development, with 200 direct and 75 indirect construction jobs per year for 9 years and construction investment of over £200m. • Significant contribution to economic growth through increased employment and expenditure from new housing, commercial uses and stadium operation, which is likely to enhance local shops and services, with local match day spending to rise from £2.7m to £4.29m, overall on-site employment being 190 full time and 520 part time jobs, plus creation of a further additional 141 full time equivalent jobs in the area resulting from spending from new residents, giving a net increase of around 200 full time jobs compared to existing uses. • Opportunities for enhancement of skills and knowledge of local people through training initiatives.

12.25 The harmful impacts not able to be mitigated to an acceptable degree that are identified from the assessment, and which constitute a departure from the Development Plan are:

• Harm to character and appearance of Kew Bridge conservation area and its listed buildings from tall and bulky buildings that are out of scale with the surrounds. • Harm to certain outward views from Wellesley Road, Strand on the Green and Kew Green conservation areas, and view of Strand on the Green from Richmond from tall and bulky buildings that are out of scale with the surrounds. • Less than substantial harm that would occur in respect of the Kew Gardens WHS (though officers conclude the appreciation of its Outstanding Universal Value (OUV) is not adversely affected), and from some other views from surrounding conservation areas.

12.26 As mentioned, there are other disruptive and negative impacts on the local environment from additional traffic, use of public transport and pedestrian routes, noise, effects on daylight, and general disturbance from large crowds, however with the recommended obligations and conditions, these can be managed and would not constitute breaches of policy.

12.27 Taking all these matters into account, balancing the social, environmental and economic benefits of the development against the residual harm, approval is recommended, subject to conditions to safeguard the details of the development, secure mitigation measures and to restrict the proposals to the parameters assessed in the environmental impact assessment and planning application. A legal deed is

201 also required to secure delivery of the stadium and its community benefits and other mitigation, including necessary community infrastructure.

12.28 In coming to this conclusion, officers also noted that although the townscape impacts on sensitive areas are not insignificant owing to the height and bulk of the buildings given in the parameters and noting the sensitivity of items affected, which needs to be given considerable weight, there are opportunities available to further reduce impacts. In this regard the use of appropriate materials and refinement of the form of the buildings would assist in minimising their impact, with this to be developed with the submission of reserved matters when details of the scale and appearance of the buildings would be finalised. However in any event, the other extensive range of positive impacts, which are considerable and widespread in their public benefit, including those that would follow from securing a more financially stable club and especially the provision of a large number of new dwellings, new employment, new investment and spending in the area, and the opportunity to secure and enhanced the highly valued social and community work done by the BFC Community Sport Trust, are considered to provide significant public benefits, which cumulatively are considered to outweigh the harm.

12.29 The weight to give to these all matters is ultimately a decision for Members. When considering this balance of impacts, it is highlighted that they must ensure they take account of the information submitted with the Environmental Statement and further information submitted, and in considering whether to grant planning permission for development which affects a listed building or its setting, members should have special regard to the desirability of preserving the building or its setting or any features of special architectural or historic interest which it possesses; and special attention should also be had to the Outstanding Universal Value of Kew Gardens, and the character and appearance of the affected conservations areas. If Members resolve that these benefits do not outweigh the harm identified or some other harm found, the application should be refused.

13.0 RECOMMENDATION

13.1 Approval

1. That planning permission be granted subject to the following conditions and securing the abovementioned planning obligations by the prior completion of a satisfactory legal agreement or unilateral undertaking made under Section 106 of the Town and Country Planning Act 1990 and or other appropriate legislation, the exact terms of which shall be negotiated by appropriate officers within the Department of Regeneration, Economic Development and Environment on the advice of the Assistant Director Corporate Governance, subject to.

(i) The application being referred to the Mayor of London, in accordance with the Mayor of London Order 2008.

(ii) The application being referred to the Secretary of State, in accordance with Circular 02/09 noting the outstanding objection of English Heritage.

202 2. It is confirmed that the decision has taken into account has the environmental information, as required Regulation 3(4) of the Town and Country Planning (Environmental Impact Assessment) Regulations 2011;

3. A statement being placed on the Statutory Register in accordance with Regulation 24 of the Town and Country Planning (Environmental Impact Assessment) Regulations 2011, which contains the information required by Regulation 21 and for the purposes of Regulation 24(1)(c) confirming the main reasons and consideration on which the Planning Committee’s decision was based were those set out in the report.

4. If the legal agreement or unilateral undertaking is not completed by 5 April 2014 (or any agreed extended period), then the Assistant Director – Community Safety, Regulatory and Development Services or Head of Development Management is hereby authorised to refuse planning permission for the reason that the proposal should include planning obligations required to make the development acceptable in planning terms in accordance with Regulation 122 of the Community Infrastructure Levy Regulations 2010, development plan policies and the Planning Obligations SPD, as described in Section 10 of this Report.

5. Following the grant of planning permission, where (a) requested to enter into a deed of variation or legal agreement in connection with the planning permission hereby approved and by the person(s) bound by the legal agreement authorised in paragraph 1 above, and (b) where the planning obligations are not materially affected, and (c) there is no monetary cost to the Council, the Assistant Director – Community Safety, Regulatory & Development Services or Head of Development Management is hereby authorised (in consultation with the Chair of the Planning Committee and upon the advice of the Assistant Director Corporate Governance) to enter into a legal agreement(s) (deed of variation) made under Sections 106 and/or 106A of the Town and Country Planning Act 1990 and or other appropriate legislation.

6. If planning permission is refused, the Assistant Director Community Safety, Regulatory and Development Services or Head of Development Management (in consultation with the Chair of the Planning Committee) is hereby authorised to approve any further application for planning permission validated within 12 months of the date of refusal of planning permission, provided that it (a) duplicates the planning application, and (b) that there has not been any material change in circumstances in the relevant planning considerations, and (c) that a satisfactory legal agreement or unilateral undertaking securing the obligations set out in the Report is completed within any specified period of time. ------Officers

[email protected] [email protected]

203 Background Papers: The contents of planning file referenced on the front page of this report, save for exempt or confidential information as defined in the Local Government Act 1972, Sch. 12A Parts 1 and 2

204 APPENDIX 1 – Site and Building Footprints

205 APPENDIX 2 – LIST OF POLICIES

London Plan (2011) and Early Revised Alterations 2013

2.18 Green Infrastructure: The Network of Open and Green Spaces 3.1 Ensuring Equal Life Chances for All 3.2 Improving Health and Addressing Health Inequalities 3.3 Increasing Housing Supply 3.4 Optimising Housing Potential 3.5 Quality and Design of Housing Developments 3.6 Children and Young People’s Play and Informal Recreation Facilities 3.7 Large Residential Developments 3.8 Housing Choice 3.9 Mixed and Balanced Communities 3.10 Definition of Affordable Housing 3.11 Affordable Housing Targets 3.12 Negotiating Affordable Housing on Individual Private & Residential Schemes 3.13 Affordable Housing Thresholds 3.16 Protection and Enhancement of Social Infrastructure 3.18 Education Facilities 3.19 Sports Facilities 4.5 London’s Visitor Infrastructure 4.6 Support for & Enhancement of Arts, Culture, Sport & Entertainment Provision 4.7 Retail and Town Centre Development 4.12 Improving Opportunities for All 5.2 Minimising Carbon Dioxide Emissions 5.3 Sustainable Design and Construction 5.6 Decentralised Energy in Development Proposals 5.7 Renewable Energy 5.9 Overheating and Cooling 5.10 Urban Greening 5.11 Green Roofs and Development Site Environs 5.12 Flood Risk Management 5.13 Sustainable Drainage 5.14 Water Quality and Wastewater Infrastructure 5.15 Water Use and Supplies 5.17 Waste Capacity 5.18 Construction, Excavation and Demolition Waste 5.21 Contaminated Land 6.3 Assessing Effects of Development on Transport Capacity 6.5 Funding Crossrail and Other Strategically Important Transport Infrastructure 6.9 Cycling 6.10 Walking 6.12 Road Network Capacity 6.13 Parking 7.1 Building London’s Neighbourhoods and Communities 7.2 An Inclusive Environment 7.3 Designing Out Crime 7.4 Local Character 7.5 Public Realm 7.6 Architecture 7.7 Location and Design of Tall and Large Buildings 7.8 Heritage Assets and Archaeology 7.10 World Heritage Sites 7.13 Safety, Security, and Resilience to Emergency

206 7.14 Air Quality 7.15 Reducing Noise and Enhancing Townscapes 7.19 Biodiversity and Access to Nature 8.2 Planning Obligations

Unitary Development Plan (2003 – saved policies)

IMP.1.1 Integrating Patterns of Land Use and the Provision of Transport IMP.1.2 The Reuse and Recycling of Urban Land and Buildings IMP.6.1 Planning Obligations ENV-N.1.16 Historic Parks and Gardens ENV-B.1.1 New Development ENV-B.1.2 High Buildings or Structures Affecting Sensitive Areas ENV-B1.9 Safety and Security ENV-B.2.2 Conservation Areas ENV-B.2.8 Views and Landmarks ENV-B.3.2 Sites of Archaeological Importance ENV-W.1.3 Important Views and Structures in the Thames Policy Area ENV-P.1.1 Environmental Sustainability ENV-P.1.3 Surface Water Runoff ENV-P.1.4 Waste Water Runoff ENV-P.1.5 Noise Pollution ENV-P.1.6 Air Pollution ENV-P.1.7 Light Pollution ENV-P.1.8 Development Proposals on or Near Contaminated Land ENV-P.1.9 Remediation of Potentially Contaminated Land ENV-P.2.3 Waste Management Facilities ENV-P.2.4 Recycling Facilities in New Developments H.4.1 Housing Standards and Guidelines C.1.3 Existing Social and Community Facilities C.1.4 New Social and Community Facilities C.4.3 Physical Access to Social and Community Facilities C.5.1 New Leisure Development C.5.1A New Stadia S.3.1 New Retail Development T.1.2 The Movement Implications of Development T.1.4 Car and Cycle Parking and Servicing Facilities for Development T.2.1 Pedestrian Access T.2.2 Pedestrian Safety and Security T.2.4 Public Transport Infrastructure T.3.1 Improvements Sensitive to Particular Users T.3.2 Access to Public Transport (Premises) T.4.3 Traffic Implications of New Development T.4.4 Road Safety T.4.5 On-Street Parking T.5.1 Air Quality Implications of Traffic

Brentford Area Action Plan 2009

Employment Development Plan Document 2008

Supplementary Planning Documents and Guidance

UDP Supplementary Planning Guidance 1997

207 LB Hounslow Planning Obligations SPD 2008 LB Hounslow Air Quality SPD 2008 London Plan: Housing SPG 2012 London Plan: Shaping Neighbourhoods; Play and Informal Recreation SPG 2012 London Plan: London’s World Heritage Sites – Guidance on Settings SPG 2012 London Plan: Sustainable Design and Construction SPG 2006 London Plan: Land for Transport and Industry SPG 2012 London Plan: Planning for Equality and Diversity in London SPG 2007 London Plan: Accessible London: Achieving an Inclusive Environment SPG 2004

Other Circular 07/09 –Protection of World Heritage Sites Circular 02/09 – Consultation Thames Landscape Strategy Kew World Heritage Management Plan Royal Botanic Gardens, Kew Statement of Outstanding Universal Value

208 APPENDIX 3 – Conditions and Reasons

Conditions

Overarching Implementation Conditions

1 Time Limit (Stadium). 2 Land Parcelling- No development to commence until all relevant parties have signed S106. 3 Reserved Matters- Outline component- first phase submission within 3 years, must then commence any approval with 7 years of main permission, or within 2 years of date of approval of last reserved matter. 4 Reserved Matters- Outline development shall not exceed amounts stated in application in terms of both floorspace and height. 5 All housing to meet relevant Mayoral SPG standards. 6 Approval of Design Code. 7 Details of Design Code. 8 Contracts to complete Stadium to be in place before any construction of residential starts 9 No more than xxx residential units to be occupied prior to completion and handover of new Stadium. 10 No residential accommodation to be occupied until Stadium is x% complete or specified number of stands complete. 11 Demolition of Griffin Park no to commence until completion and handover of new Stadium 12 No more than 2 phased to be commenced and not practically complete at any one time 13 Phasing Plan 14 All Development in Accordance with Plans (including parameter drawings) 15 Environmental Sustainability Plan

Site-wide Conditions- phased and prior to commencement and/or occupation where considered appropriate.

16 Hours of Construction 17 Construction Environmental Management Plan 18 Construction Logistics Plan 19 Noise and Dust Emissions 20 Deliveries 21 Compliance with Flood Risk Assessment 22 Phased Contamination Condition 23 Foul and Surface Water Arrangements 24 Sustainable Urban Drainage Scheme 25 Water Supply Impact Study 26 Bird Hazard Management Plan 27 Ecology Strategy 28 Archaeological Investigation

209 29 Reasonable Archaeologist Access 30 Stable Block- Full Survey 31 Stable Block- Reclaim and Store Materials for Reuse in Stadium 32 Stable Block- Detailed Scheme for reuse of Reclaimed Materials 33 Hoarding 34 Piling 35 Removal of Permitted Development rights re aerials and satellite dishes 36 Materials Samples 37 Materials Samples Board to be kept on site 38 Residential blocks of the Southern Central site shall include revisions to the Design Code, which shall be agreed with the Local Authority in writing and shall ensure that these blocks have lower levels that are undercut or setback to maintain the Lionel Road South vista. 39 Samples of all materials to be used for the external surfaces of the concourse level floor(s)/ setback of Block E of the Central Southern site should be submitted at preliminary detailed design stage of this block and prior to any approval of reserved matters. 40 Public Realm 41 Landscaping 42 Tree protection of trees on borders of site 43 Foundation depth should compensate for trees 44 Tree protection of trees to be retained within site 45 Tree work to be carried out to BS3998 standard 46 Construction work to follow all relevant guidance in reference to protection of trees during construction. 47 Cycle Parking 48 Disabled Parking 49 Compliance with Lifetime Homes and 10% Wheelchair Accessible housing 50 Lighting Strategy 51 CCTV and Security Lighting 52 Refuse 53 Noise at neighbouring properties 54 Restriction on hours of operation of commercial uses 55 Travel Plan

Stadium and Major Event Conditions

56 Materials Samples including reuse of Stables 55 Landscaping 57 Community Programme Details 58 Limit on number of matches played in a season 59 Stadium only for commercial football use and for no other commercial sport. 60 Spectator limit of 20,000 61 Hours of operation 62 Setdown and pickup for disabled people and transport 63 Full Accessibility Strategy 64 Disabled Parking

210 65 Plans to show all vehicular movements can be clear of public highway 66 Parking to be in place before Stadium use 67 Vehicular and pedestrian access including the bridge to be complete prior to Stadium use 68 Plans to be submitted regarding ramp to connect to London bound platform of Kew Bridge Station 69 Car Park Management Plan 70 Cycle parking 71 Cycle parking to be made available to communters on non-match days 72 Anti-terrorism strategy and features 73 Use of screens associated with any sound system 74 Details of amplified sound systems/public address system 75 Location of public address system 76 Hours of use of public address system 77 Full details of lighting including floodlighting 78 Hours of use of floodlighting 79 Location of floodlighting in relation to highway traffic 80 Details of plant/machinery and noise 81 Plant machinery shall not exceed a certain level 82 Signage details and strategy 83 Study of impact on local television, radio and telecommunication signals 84 S278 Agreement

211