planning report PDU/3092/01 16 January 2013 School at Lake Farm Botwell Common Road, Hayes in the London Borough of planning application no.68911/APP/2012/2983

Strategic planning application stage 1 referral (new powers) Town & Country Planning Act 1990 (as amended); Authority Acts 1999 and 2007; Town & Country Planning (Mayor of London) Order 2008

The proposal New 3 Form of Entry Primary School (630 students) plus a nursery (45 students) and a Special Resource Provision Unit for approximately 12 pupils, associated car parking, hard and soft play areas, sports pitches, pedestrian and vehicular access routes and landscaping. The applicant The applicant is London Borough of Hillingdon Resident Services, and the architect is 9.design and landscape architects.

Strategic issues Loss of , education use, urban design, access, sustainable development, and transport are the strategic issues relevant to this scheme.

Recommendation That Hillingdon Council be advised that the application does not comply with the London Plan, for the reasons set out in paragraph 52 of this report; but that the possible remedies set out in that paragraph of the report could address these deficiencies. The application does not need to be referred back to the Mayor if the Council resolves to refuse permission, but it must be referred back if the Council resolves to grant permission.

Context

1 On 6 December 2012 the Mayor of London received documents from Hillingdon Council notifying him of a planning application of potential strategic importance to develop the above site for the above uses. Under the provisions of The Town & Country Planning (Mayor of London) Order 2008 the Mayor has until 16 January 2013 to provide the Council with a statement setting out whether he considers that the application complies with the London Plan, and his reasons for taking that view. The Mayor may also provide other comments. This report sets out information for the Mayor’s use in deciding what decision to make.

2 The application is referable under Category 3D of the Schedule of the Order 2008: “Development – (a) on land allocated as Green Belt or Metropolitan Open Land in the development plan, in proposals for such a plan, or in proposals for the alteration or replacement of such a plan;

page 1 and (b) which would involve the construction of a building with a floor space of more than 1000 square metres or a material change in the use of such building” and Category 3E of the above order: ”Development – (a) which does not accord with one or more provisions of the development plan in force in the area in which the application site is situated; and (b) comprises or includes the provision of more than 2,500 square metres of floorspace for a use falling within any of the following classes in the Use Class Order – (xi) class D1 (non-residential institutions) .”

3 Once Hillingdon Council has resolved to determine the application, it is required to refer it back to the Mayor for his decision, as to whether to direct refusal or allow the Council to determine it itself, unless otherwise advised. In this instance if the Council resolves to refuse permission it need not refer the application back to the Mayor.

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

5 Lake Farm Country Park is located in the southern part of the London Borough of Hillingdon. It falls within Botwell ward and is located towards the west of Hayes town Centre. The entire application site falls within the Green Belt as shown on the Hillingdon Unitary Development Plan Proposals Map. The land to the west and the playing fields to the south also fall within the Green Belt. The areas to the north and east of the park are largely residential in character and the areas to the south and west predominantly comprise a mix of industrial and business areas and Green Belt land.

6 The site is bounded to the north by Botwell Common Road, beyond which are residential properties. It is bounded to the east by Botwell Lane, beyond which is Lake Gardens, a formal public open space comprising mown grass, trees and footways, which is designated as a 'Green Link.' The area beyond Lake Gardens is predominantly residential in character. To the south west the site is bounded by residential properties in Rostrevor Gardens and a privately owned former sports ground, the buildings for which are now used by a community group. The and Blyth Road/Printing House Lane Industrial and Business Area lie beyond. Informal meadow/grassland comprising the remainder of Lake Farm Country Park bounds the site's western boundary.

7 In its entirety, Lake Farm covers an area of approximately 24 hectares. Originally part of Botwell Common, it was enclosed in 1814 and subdivided; parts were used for gravel extraction and

page 2 subsequently brickworks. These were subsequently backfilled and the site used for radar testing. It is now a country park, comprising open meadowland/grassland and shrubs, interspersed by both formal and informal footpaths and bridleways. Two areas of formal grassland and trees, both with a children's playground, are situated in the north western and south western corners of the park, respectively. A BMX track and a car park for visitors to the Country Park are located adjacent to the western boundary. The park has been awarded Green Flag status.

8 The proposed new three form of entry primary school would occupy an irregularly shaped plot located at the eastern side of the Country Park. The school site itself will occupy an area of approximately 3.6 hectares. However, due to proposed offsite works, such as landscaping enhancements, the application site comprises a total area of approximately 5.6 hectares.

9 The north east corner of the site comprises formal open space, delineated by a mature hedgerow to the west and south. This area of mown-grass includes tree planting, a small children's playground, formal footpaths, a statue named by local people as the 'Tyler of Eden - The Skylark', and it also accommodates the park's green flag. The remainder of the application site comprises informal meadowland and grassland, which for the most part of the year is allowed to grow wild, interspersed with mown paths for use by walkers, cyclists and horse riders. Formal paths also cross the site. The site is predominantly flat with very little undulation.

10 The site is located approximately 1.5 km from the A4020 ( Road) which is part of the Strategic Road Network (SRN), and 1.5 km from the A312 (The Parkway) which is part of the Road Network (TLRN). Two high frequency bus routes are within walking distance of the site (routes U4 and U5), providing links to Uxbridge and Hayes. Hayes and Harlington station is approximately 1 km from the site, which will benefit from Crossrail services from 2018. The site’s public transport accessibility level (PTAL) is 2 (on a scale of 1 to 6, where 6 is the most accessible).

Details of the proposal

11 This application seeks full planning permission for the erection of a new three form of entry primary school with associated facilities including playgrounds, playing fields, car parking, access and landscaping, on land at Lake Farm Country Park in Hayes.

12 The three form of entry school would be capable of accommodating up to 630 students, plus a nursery for 45 children per session in two sessions and a SEN/SRP (Special Education Needs) unit for approximately 12 pupils with Autism Spectrum Disorder. A school of this size would require approximately 60 staff. The buildings would have a total floor area of approximately 3,300 sq m and the school would occupy an overall area of approximately 3.6 hectares. Case history

13 An informal pre-application meeting was carried between Hillingdon Council and GLA officers in mid August 2012. Major concerns were raised in regard to the “inappropriateness” of a new school development on Green Belt. The applicant was advised of the need to demonstrate very special circumstances having regard to the need for the additional spaces and lack of alternative sites.

14 The applicant was advised that the proposed site layout and the spread of development appeared to make the impact on the openness of the Green Belt more harmful.

Strategic planning issues and relevant policies and guidance

page 3 15 The relevant issues and corresponding policies are as follows:

 Green Belt London Plan  Education London Plan  Urban design London Plan  Access London Plan; Accessible London: achieving an inclusive environment SPG; Planning and Access for Disabled People: a good practice guide (ODPM)  Sustainable development London Plan; Sustainable Design and Construction SPG; Mayor’s Climate Change Adaptation Strategy; Mayor’s Climate Change Mitigation and Energy Strategy; Mayor’s Water Strategy  Transport London Plan; the Mayor’s Transport Strategy; PPG13; Land for Transport Functions SPG

16 For the purposes of Section 38(6) of the Planning and Compulsory Purchase Act 2004, the development plan in force for the area is the 2012 Hillingdon Council Core Strategy and the 2011 London Plan.

17 The following are also relevant material considerations:  The National Planning Policy Framework and Technical Guide to the National Planning Policy Framework  The Revised Early Minor Alteration to the London Plan

Green Belt and educational use

18 The National Planning Policy Framework (paragraph 67) and the London Plan (policy 7.16) set out that only development associated with agriculture, forestry, outdoor sport and recreation is appropriate in the Green Belt. All other forms of development are, by definition, ‘inappropriate’. In order for ‘inappropriate’ development to be acceptable in the Green Belt, very special circumstances must apply.

19 The NPPF sets out that new buildings are inappropriate in the Green Belt although some exceptions to this are set out including limited infilling or the partial or complete redevelopment of previously developed sites (brownfield land), whether redundant or in continuing use (excluding temporary buildings), which would not have a greater impact on the openness of the Green Belt and the purpose of including land within it than the existing development.

20 The application site is entirely located within the Green Belt. The buildings would have a total floor area of approximately 3,300 sq m and the school would occupy an overall area of approximately 3.6 hectares, with few elements of the buildings having 2 storeys as maximum height whilst most of the buildings are single storey. The proposed development for the erection of a new three form of entry primary school with associated facilities for educational use is “inappropriate” development on Green Belt. Therefore, the applicant is required to demonstrate very special circumstances.

21 The applicant demonstrated educational need and the lack of more appropriate alternative site options for the provision of the school, combined with the low impact design, high quality landscaping scheme and incorporation of high levels of sustainable build measures, as very special circumstances.

22 Educational need: The applicant’s assessment of the future educational need in the area is well presented. It has analysed the increasing demand for school places across Hillingdon and in

page 4 particular the area covered by pupil planning area 11 – essentially the wards of Townfield and Botwell. This is primarily as a result of increased birth rate, but also changes to net migration, both of which are likely to be sustained for longer than previously thought. This has given rise to approximately 26 additional forms of entry across the borough. Much of this is being met through expansion of existing schools. The Council has stated that within pupil planning area 11 existing primary schools are operating at or close to capacity or are oversubscribed, and that those that can are undergoing expansion. Similarly the Council has stated that nearby schools within the surrounding pupil planning areas, which can do so, are also undergoing expansion. However, across the borough the Council believes two new schools are required. One is planned as part of the RAF Uxbridge redevelopment and a second is required within Botwell/Townfield wards, as the area of greatest need.

23 The increased demand for places is compelling and is accepted. It is understood that there are two free schools proposed within the Hayes area (Guru Nanak and Rosendale Hewens) and it is unclear whether the capacity that these will create has been included within the Council’s assessment. This should be confirmed. Subject to this and based on the Council’s statements that all other schools that can do so are being expanded, the need for places is accepted as a very special circumstance.

24 Alternate site options: The Council has carried out a thorough criteria based assessment of alternative sites within the catchment area. This has concluded that none of the 25 sites surveyed were deemed suitable for a range of reasons as detailed in the report and were thus rejected. The findings of this are broadly accepted. However, further clarification is required about the site size, in particular the extent to which the Education (School Premises) Regulations 1999 are a fixed criteria and whether there is potential to split the playing fields requirement. If the site area could be reduced this may bring forward other potential sites (e.g. the site across Botwell Lane) or reduce the impact on other discounted sites. While the chosen site is placed centrally within the broad catchment area, it is noted that large areas of the land to the west and south are either protected open space or employment land, thus reducing the effective catchment of the school.

25 The other very special circumstances put forward, low impact design, high quality landscaping scheme and incorporation of high levels of sustainable build measures can not be considered as very special circumstances, as they themselves are requirements for any planning application appraisal irrespective of Green Belt issues.

Urban design

26 There are concerns regarding the proposed layout of the development, as raised through the informal pre-application process. The layout, as shown overleaf proposes a primarily single storey ‘L’ shaped building, which is set some way into the Green Belt. There are hard play areas either side of the building and playing fields further to the south. A narrow strip of public open space is created between the new school and Botwell Lane. The main concern is that the layout spreads development (buildings, hardstanding, fencing etc) further into the Green Belt and country park, thus increasing the impact on openness. The Council has indicated that there are covenants that prevent a building closer to Botwell Road. The details of these should be provided since it may be the case that they can be insured against or varied by agreement. The Council has also put forward other reasons for the layout, relating to direct vehicle access to Botwell Lane and impact on neighbouring residential properties. The GLA would welcome further discussion on these, since it could be argued that the balance of judgement on these issues should weigh in favour of the Green Belt.

27 The layout also prevents any direct access to the country park from Botwell Road and prevents any direct visibility of it. This potentially undermines its amenity value and utility to local residents. An alternative layout may have allowed a direct route through.

page 5 28 There are no strategic design concerns with the design of the buildings, which it is recognised have been kept to one storey to minimise visual impact.

Inclusive design

29 The London Plan expects the highest standards of accessibility and inclusion (not just the minimum). The application generally demonstrates a good standard of inclusive design, with level access throughout. However there are some concerns regarding the parking arrangements for disabled people, since there is none allocated in the 42 space set down and pick up area (which is also designed to serve the country park. Spaces conveniently located for both uses and appropriate in terms of numbers of bays (see London Plan table 6.2) should be provided and designed in accordance with the guidance found in BS8300:2009 + A1:2010. There is a similar concern with the nursery parking area.

30 There is also a concern with the designated SRP unit drop off point. The need for a separate drop off point, close to the unit is appreciated. However it appears to be located at the end of the delivery access road, past the delivery vehicle turning head, next to the bin store. This route may therefore be blocked and unavailable if deliveries are taking place and does not appear to provide a particularly dignified approach for its users.

31 All of the external pedestrian routes around the school (both approaching the school boundary, and within the school boundary) should have a minimum surface width of 1800mm, and have a firm slip resistant surface. Confirmation of this should be provided.

32 The design and access statement explains that level or sloped access is to be provided up to the principal entrance. As this is a new development, level rather than sloped access should be provided wherever possible, where this is not possible, a sloped approach may be acceptable however details of the design of these areas should be provided. This should be applied to all entrances and exits. It is not entirely clear whether enough disabled persons toilets are to be provided. Disabled persons toilets should be available in the main body of the school for pupils who require the use of one, without entering the nursery or the SRP unit, or leaving to use the one in the reception area. Additional information on the approach taken to disabled persons toilets (for staff and pupils) should be provided, to justify the proposed levels.

page 6 Sustainable development

33 The applicant has proposed a range of efficiency measures which achieve a reduction of 11 tonnes per annum (2%) in regulated carbon dioxide emissions compared to a 2010 Building Regulations compliant development, as shown in the table below. This is welcomed.

34 Given the type and location of development the potential for district heating and CHP has been discounted, which is accepted.

35 The applicant is proposing to install 78 sq m of roof mounted photovoltaic panels (PV) coupled with a ground source heat pump with a COP of 3.86.

36 The applicant states that a reduction in regulated carbon dioxide emissions of 7 tonnes per annum (16%) will be achieved through this third element of the energy hierarchy (see table below).

Table: CO2 emission reductions from application of the energy hierarchy

Total residual regulated Regulated CO2 CO2 emissions emissions reductions (tonnes per annum) (tonnes per (%) annum) Baseline i.e. 2010 Building 54 Regulations Energy Efficiency 47 7 13 CHP 47 0 0 Renewable energy 40 7 15 Total 14 26

37 A reduction of 14 tonnes of CO2 per year in regulated emissions compared to a 2010 Building Regulations compliant development is expected, equivalent to an overall saving of 26%. This exceeds the targets set within Policy 5.2 of the London Plan and is welcomed.

Climate change adaptation

38 The Surface Water design statement sets out to utilise a green roof, permeable car parking and play areas, along with a swale and balancing pond to convey the surface water flows across the site to the outfall location.

39 Rainwater harvesting is proposed to be incorporated in the scheme and the proposals for limiting water use is welcomed.

40 It is understood that the site lies in Flood Zone 1 and is therefore not considered to be at risk of flooding originating from a main river or significantly sized watercourse. The Grand Union canal, approximately 250m to the south of the site is not considered a significant flood risk as water levels are regulated and it is not an embanked channel.

41 It is proposed to discharge surface water runoff to the adopted sewer network in Botwell Lane. However, the applicant should consult the Thames Water in regard to the implementation of its surface water management strategy.

page 7 Transport for London’s comments

42 Mode share for car trips is forecast to be very high as a result of the redevelopment of the site with a proportionally high provision of car parking and pick up/drop off spaces proposed. Given the already congested nature of the area, this is a concern for TfL. Bus movements along Botwell Common Road will be affected, particularly as the left turn into the car park access is located directly after the bus stop serving route U5. The cumulative impact of all redevelopment sites in the area must be assessed, while agreeing a sustainable approach towards parking provision, in order to determine the associated infrastructure required to accommodate overall growth. Provision of disable car parking spaces in accordance with the London Plan should be secured. Further discussion of this matter with the Council would be welcomed.

43 In the meantime and in order to manage this, the applicant must ensure that a robust school travel plan is in place to encourage a higher proportion of walking and cycling trips and a reduction in car trips, in compliance with London Plan policy 6.3. The travel plan should be secured, enforced, funded, and monitored as part of a legal agreement. In addition, cycle parking spaces should be provided in compliance with London Plan policy 6.9 and Table 6.3 of the Parking Addendum to Chapter 6, which require 1 space per 10 members of staff and 1 space per 10 pupils.

44 The development is served by routes U4 and U5, which provide a combined frequency of 12.5 buses per hour along Botwell Lane. Capacity is sufficient on these routes to accommodate the increase in demand expected from the site. However, bus stop H on Botwell Common Road is proposed to be used as a coach pick up and drop off point. Conditions of use must be agreed with TfL in advance for such an arrangement to be considered acceptable. TfL would expect coaches only to use the facility for pick up and drop off, not for standing, to ensure they do not prevent local bus services accessing the stop.

45 TfL supports the proposed provision of improved pedestrian crossings to facilitate walking trips to and from the development. Consideration however must be given to the location of the proposed zebra crossings so as to maximise driver visibility of vulnerable road users such as young children, particularly when exiting the mini roundabout. Given that on street pick up/drop off can reduce the visibility of pedestrians, TfL supports the extension of ‘no waiting at any time’ (double yellow line) restrictions along Botwell Lane, north and south of the mini roundabout. These should also be extended along Botwell Common Road as far as the School Keep Clear markings.

46 In accordance with London Plan policy 6.10, TfL welcomes the measures proposed to improve the local pedestrian environment as identified in the pedestrian audit, including a new length of footway on the south side of Botwell Common Road, maintenance of the path linking Forris Avenue and Botwell Lane, provision of a bus shelter at stop D, and improvements to the shelter at stop SH. Bus infrastructure works should be secured through a legal agreement and would require TfL approval.

47 TfL request that a construction logistics plan be developed in conformity with London Plan policy 6.14. This should be submitted to and approved by the Council, and secured by way of planning condition, to minimise impacts on the highway network during the course of construction.

48 In summary, subject to the above items being adequately addressed, TfL is satisfied that the proposed development could be considered to be in general conformity with the transport policies of the London Plan. Local planning authority’s position

49 Hillingdon Council planning officers have yet to confirm their position.

page 8 Legal considerations

50 Under the arrangements set out in Article 4 of the Town and Country Planning (Mayor of London) Order 2008 the Mayor is required to provide the local planning authority with a statement setting out whether he considers that the application complies with the London Plan, and his reasons for taking that view. Unless notified otherwise by the Mayor, the Council must consult the Mayor again under Article 5 of the Order if it subsequently resolves to make a draft decision on the application, in order that the Mayor may decide whether to allow the draft decision to proceed unchanged or direct the Council under Article 6 of the Order to refuse the application. There is no obligation at this present stage for the Mayor to indicate his intentions regarding a possible direction, and no such decision should be inferred from the Mayor’s statement and comments. Financial considerations

51 There are no financial considerations at this stage. Conclusion

52 London Plan policies on Green Belt, educational use, urban design, inclusive access, sustainable development, and transport are relevant to this application. The application complies with some of these policies but not with others and on balance does not comply with the London Plan; the reasons and the potential remedies to issues of non compliance are set out below:  Green Belt and educational use: The applicant has demonstrated educational need as a very special circumstance which is sound, and the alternate site search which is robust, subject to clarification regarding free school provision and further discussion regarding the site size criteria and the potential to consider a split site.  Urban design: Further discussion is required regarding the proposed layout, which appears to have a more harmful impact on the openness of the Green Belt than necessary.

 Inclusive design: There are minor concerns regarding disabled parking provision, external access and disabled persons toilets, which should be addressed.

 Sustainable development: The CO2 savings exceed the targets set within Policy 5.2 of the London Plan.

 Transport and parking: There are several issues that need to be resolved which include further discussion on mode share for car trips and street pick up/drop off with the Council. Bus infrastructure works should be secured through a legal agreement and would require TfL approval. Provision of disable car parking spaces in accordance with the London Plan should be secured. A travel plan should be secured, enforced, funded, and monitored as part of a legal agreement, cycle parking should be provided in compliance with London Plan. A construction logistics plan should be secured.

for further information, contact Planning Decisions Unit: Colin Wilson, Senior Manager - Planning Decisions 020 7983 4783 email [email protected] Justin Carr, Strategic Planning Manager (Development Decisions) 020 7983 4895 email [email protected] Tefera Tibebe, Case Officer 020 7983 4312 email [email protected]

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