planning report D&P/4192/01 26 June 2017 Bolder Academy, MacFarlane Lane, in the London Borough of Hounslow planning application no.01106/W/P9

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

The proposal The proposal comprises demolition of existing clubhouse and construction of a secondary school.

The applicant The applicant is Education Funding Agency, the agent is Cushman & Wakefield and the architect is Callison RTKL.

Strategic issues summary Principle of land use: provision of school on MOL and playing fields: Pressing educational need and lack of available alternative sites are accepted as ‘very special circumstances’ which outweigh the potential harm to the MOL by reason of inappropriateness. The applicant must address the potential impact on playing fields (paragraphs 13 to 28). Community use: A community use plan agreement, which secures the use of the school’s facilities outside core hours, should be submitted and secured (paragraphs 29). Urban and inclusive design: The Council should secure key details of the cladding system to ensure the best possible build quality is delivered. The approach to inclusive design is supported and the measures proposed should be appropriately secured (paragraphs 30 to 33). Sustainable development: The carbon dioxide savings meet the target set within the London Plan. Clarification is required regarding solar gains, overheating and cooling demand, communal heating system. BRUKL worksheet and roof layout plan should be provided (paragraph 36). Transport: Revised modelling is required to assess the impact on local junctions. Concerns related to cycle parking should be addressed. The travel plan should be improved and secured by s106 agreement, and a DSP and CLP should be secured by condition, (paragraphs 37 to 49).

Recommendation That Hounslow Council be advised that the application does not fully comply with the London Plan, for the reasons set out in paragraph 53 of this report; but that the possible remedies set out in that paragraph 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.

page 1 Context

1 On 21 April 2017 the Mayor of London received documents from Hounslow Council notifying him of a planning application of potential strategic importance to develop the above site for the above uses. The referral documents were received complete on 28 April 2017. Under the provisions of The Town & Country Planning (Mayor of London) Order 2008 the Mayor had until 8 June 2017 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 the following Categories of the Schedule to the Order 2008:  Category 3D: “”Development – (a) on land allocated as Green Belt or Metropolitan Open Land in the development plan, in proposals for such a plan, or in proposals for the alteration or replacement of such a plan; and (b) which would involve the construction of a building with a floor space of more than 1,000 square metres or a material change in the use of such building.”  Category 3E: “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 floor space for a use falling within any of the following classes in the Use Classes Order—(ix) class D1 (non- residential institutions).”

3 Once Hounslow 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 The application site is designated Metropolitan Open Land and located at MacFarlane Lane, north of Great West Road in the London Borough of Hounslow. The site is currently occupied by Grasshoppers Rugby Club, with Wyke Green Golf Course to the west and Goals Gillette Corner Football Club to the south. The MOL also extends into Park further to the west.

6 The site area extends to 4.5 hectares and comprises 3 sports pitches (rugby), a multi-use games area (MUGA) providing 1 football pitch and 3 netball courts, a two storey club house and parking for approximately 115 cars. A resolution to grant planning permission has been secured to relocate the Grasshoppers Rugby Club to the northern part of the Nishkam School Site (former Conquest Club, Syon Lane). The existing playing fields currently sit on three virtually flat plateaux across the development site. The levels between plateaux vary in elevation with a level difference of up to 2 metres. The surrounding land to the pitches is uneven and the levels vary considerably. In particular, the levels to the north-west of the site fall steeply down several metres to a small stream that adjoins the neighbouring golf course.

page 2 7 The main vehicular access road to the site is via MacFarlane Lane, a private cul-de-sac which serves the application site, Goals Football Club, a small area of allotments and a small area of parking for a van hire business. Adjacent is a multi-storey car-park area, and a number of industrial and office buildings occupied by BSkyB (on a site designated as Strategic Industrial Land), which are served by a separate access road, although they retain a service access from Macfarlane Lane.

8 The nearest section of the Transport for London Road Network is A4 Great West Road, located approximately 480 metres south east of MacFarlane Lane. The nearest part of the Strategic Road Network is A315 London Road, approximately 1.1 kilometres south east. The nearest bus stop is around 700 metres from the proposed school entrance, beyond the bus planning standard. It serves the H28 which is a low-frequency single-decker bus which runs a zig-zag route from Tesco Osterley to Tesco Bulls Bridge. Other buses, as well as National Rail and London Underground services are further away. The public transport accessibility level (PTAL) of the site is 0, which is the lowest level of connectivity to public transport.

Details of the proposal

9 The proposal comprises demolition of existing club house, associated car park and MUGA for construction of a new part-2/part-4 storeys secondary school with ancillary car parking, cycle parking, MUGA, hard and soft landscaping and associated works, together with improvements to MacFarlane Lane. Case history

10 On 31 January 2017, a pre-application meeting was held at City Hall on the above proposal (D&P/4192). The proposal was broadly supported subject to robust justifications to redevelop the site which is located in MOL. Concerns related to other strategic issues; playing fields and community use, urban and inclusive design, sustainable development and transport were required to be addressed. Strategic planning issues and relevant policies and guidance

11 The relevant issues and corresponding policies are as follows:  Education London Plan; Mayor’s Social Infrastructure SPG;  Metropolitan Open Land London Plan;  Playing fields London Plan;  Community use London Plan;  Urban design London Plan;  Access London Plan; Accessible London: achieving an inclusive environment;  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;

12 For the purposes of Section 38(6) of the Planning and Compulsory Purchase Act 2004, the development plans in force for the area is the 2015 Hounslow Local Plan and the 2016 London Plan. The National Planning Policy Framework, Technical Guide to the National Planning Policy Framework and National Planning Practice Guidance are also relevant material considerations.

page 3 Land use principles: provision of education facility on MOL and playing fields

13 The National Planning Policy Framework and Government Policy Statement on Planning for Schools Development emphasise that great importance should be attached to the delivery of sufficient choice of school places to meet the needs of existing and new communities. London Plan Policy 3.18 ‘Education facilities’ confirms that the Mayor strongly supports the provision of new schools in response to local need. The Mayor encourages development proposals that co- locate schools with other schools and/or other uses in order to maximise land use and reduce costs.

14 The application site is part of a larger area identified as Metropolitan Open Land and playing fields. London Plan (Policy 7.17) gives MOL the same level of protection as Green Belt, and the National Planning Policy Framework (paragraph 89) sets out that only development associated with agriculture, forestry, outdoor sport and recreation, limited infilling and redevelopment of existing sites 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. The NPPF in Para 87 sets out that inappropriate development is, by definition, harmful to the Green Belt and should not be approved except in ‘very special circumstances’. When considering any planning application, local planning authorities should ensure that substantial weight is given to any harm to the Green Belt. ‘Very special circumstances’ will not exist unless the potential harm to the Green Belt by reason of inappropriateness, and any other harm, is clearly outweighed by other considerations.

15 Whilst the scheme has been designed so as to limit as much as practicable development on those area of Metropolitan Open Land that are already developed, the applicant acknowledges that the proposed school development is ‘inappropriate’ development on MOL, and as such has identified what it considers to be very special circumstances to justify the scheme.

Very special circumstances

16 The applicant has set out that educational need and the results of the sequential assessment constitute very special circumstances justifying the proposed school on MOL. These are discussed in detail below.

Educational need

17 It is acknowledged that there is a need to increase primary and secondary school capacity in Hounslow to meet the rising population, requiring 14,600 new places by 2030, of which, approximately 10,000 will be in secondary schools. The projections for required secondary school places in Hounslow show an increase in need, beginning in 2017 and increasing to a requirement for 21 forms of entry (FE) over the next two years, the equivalent of three secondary schools, and that current projections illustrate that the most intense growth is in / Isleworth and Central Hounslow areas.

18 It is accepted that the proposed development of Bolder Academy, which will accommodate 900 places for children aged 11-16 and a further 250 places at post 16; a total of 1,150 pupils (including 25 SEN students), will play a significant part in meeting the pressing demand for school places within Brentford / Isleworth.

page 4 Alternative site analysis

19 Given that the application site is located within Metropolitan Open Land, a site sequential assessment has been undertaken; the purpose of which has been to assess whether there is a suitable site within the school’s catchment area which is available and suitable in Brentford and Isleworth. The catchment area is based on the assumption that 75% of pupil’s attending Bolder Academy would travel from within a 2.5 kilometre area surrounding the site. This is based upon the distance travelled by 75% of pupils to the existing mixed-gender secondary schools in Hounslow.

20 The assessment outlines that the gross site area for the school is determined by reference to the Department for Education’s Building Bulletin 103 (‘Area Guidelines for Mainstream Schools’), which contains guidelines for the design of schools. The report acknowledges that the approximate site area of the application site is 4.5 hectares and therefore is over and above the maximum range for a secondary school. However, for the purpose of the site sequential assessment, the assessment focused on a minimum building area of 8,000 square metres and a minimum gross site area of 0.76 hectares.

21 Other than catchment area and building gross site area, the other elements of the criteria for the site assessment include; current uses and site conditions, local plan designations, neighbouring uses, site constraints, access issues, development delivery timeframe, availability and overall suitability. The criteria to be used for the assessment of sites was agreed with Hounslow Council prior to undertaking the study.

22 The assessment has reviewed 115 sites of which 31 were shortlisted. These 31 sites have been reviewed in more detail and this assessment exercise has demonstrated that the application site which is known as the former Grasshoppers RFC (1 MacFarlane Lane) is the only suitable, immediately available site within Brentford and Isleworth for the proposed new secondary school. There are no alternative, potentially suitable and available sites within the development delivery timeframe for the proposed new secondary school within the school’s catchment area, and within a more preferable land use or location.

23 Co-location: As part of the site search criteria, sites have also been assessed where there may be scope to co-locate with other schools or in a mixed use with other suitable uses, which in this location is primarily residential use. The EFA has stated that it is willing to accommodate a free school within a mixed-use development where value for money can be demonstrated.

24 Each site capable of accommodating a mixed-use scheme is considered on a case-by-case basis to assess the suitability of firstly, the scheme and other uses proposed on-site to ensure safeguarding measures are appropriately catered for, and secondly the availability of sufficient space to meet Building Bulletin 103 needs. From a developer or landowner’s perspective, off- setting part of the scheme – whether split horizontally or vertically – to cater for a school is not always the most viable option due to the minimum external space requirements under BB103. The instances where there has been a successful free school delivered as part of a mixed-use scheme have been mostly Primary School requirements.

25 A number of the sites contained within the longlist (115) and some within the shortlist (31), have been considered as mixed-use schemes and discussed with the respective developers, although no agreement has been reached to enable a co-location solution in this instance.

page 5 Very special circumstances conclusion

26 The pressing educational need and lack of available alternative sites are accepted as ‘very special circumstances’ which outweigh the potential harm to the MOL by reason of inappropriateness. The proposed school development is therefore acceptable.

Visual impact

27 It is acknowledged that the school has been located and designed so as to limit the amount of development located outside those areas of the site that constitute previously developed land; this approach is strongly supported. The applicant has submitted a CGI visual assessment from a series of agreed points. The visual effects of the proposed development are seen in the context of the adjacent office campus, and screened in part by existing vegetation, with the existing clubhouse featuring in a number of views, highlighting the site’s previously developed element. The use of mitigation planting will help to further alleviate views of the school building, particularly in immediate views. The Council should also secure the mitigation planting measures proposed through appropriate conditions.

Playing fields

28 London Plan Policy 3.19 ‘ Sport facilities’ sets out that those proposals that increase or enhance the provision of sports and recreation facilities will be supported; whereas those that result in a net loss of sports and recreation facilities, including playing fields should be resisted. In this context, although the applicant asserts that the proposals will enhance the existing sports facilities and improve the remaining playing fields qualitatively, the quantitative loss of playing fields (nearly 43% of the existing 2.5 hectares) needs to be addressed. In satisfying Policy 3.19, the applicant must demonstrate that there would not be a loss of sport facilities for which there is a defined need. Furthermore, the applicant must confirm what consultation with local residents, nearby schools, local cricket, athletics and football clubs has been undertaken so that any displacement can be assessed. Active engagement with local communities and Sport is highly recommended and evidence of support from these bodies should be provided. Community use

29 London Plan Policy 3.18 ‘Education facilities’ expects community use to be maximised in such proposals. School facilities can provide venues for a range of community activities, including children’s centres, and cultural and sports activities, where children and parents feel comfortable to access them. School facilities such as sports, training and meeting facilities should therefore be capable of use by the wider community outside school hours. Maximum use of schools in the evenings and at weekends will also reduce the land requirement for other uses. The design of the school should assist in this, for example by creating zones where community use can be easily provided (for instance the school hall, the football and cricket pitches), while ensuring that access to other parts of the school can be easily segregated. A detailed community use agreement for out-of-school-hours usage of appropriate facilities should therefore be secured by the Council. Urban design

30 Good design is central to all objectives of the London Plan and is specifically promoted by the policies contained within chapter seven ‘London’s Living Spaces and Places’ which address both general design principles and specific design issues.

page 6 31 Layout: The broad layout principles are supported from a strategic design perspective. The building has been positioned so as to limit the amount of development outside of previously developed land, which is supported. The access strategy prioritises pedestrians over vehicles while also ensuring that the school block is orientated to provide a sense of arrival for staff, students and visitors. The primary access routes will relate to movement routes within the campus, ensuring safe links between school facilities. The landscaping strategy illustrates how campus facilities are integrated into the existing landscape, with the aim of safeguarding the existing open quality of the site. Boundary treatments are also carefully considered to provide security while also enabling views into the site, avoiding large expanses of blank and inactive frontage.

32 Scale and massing: The school building would range from between two to a maximum of four storeys, with maximum height of 17 metres. This design approach creates a logical step up in building heights and massing towards the BSkyB multi-storey car park, which is 7 storeys in height. The design approach adopts a compact deep plan arrangement by grouping what essentially is three buildings with three separate functions teaching and learning zone, gathering and study zone, and sports community hub zone, brought together on the identified build zone area to create the new Academy. Gaps in the massing have been purposely forged between these blocks to help reduce the impact on the openness, and visual amenity of the MOL, which is welcomed.

33 Overall, the scale, massing and appearance of the school building are acceptable and will have limited visual impact on the open quality of the site. The Council should secure key details of the cladding system to ensure the best possible build quality is delivered and ease of maintenance is prioritised. Inclusive design

34 Policy 7.2 of the London Plan requires all new developments in London to achieve the highest standards of accessible and inclusive design. The proposals have been developed to ensure that the school will be fully accessible with circulation routes, corridors, and stairs that will be designed in accordance with Approved Document M and British Standard (BS:8300:2009).

35 The provision of six disabled parking spaces out of the total 57 car parking spaces is welcomed. Overall, the approach to inclusive design is supported and the measures proposed should be appropriately secured. Sustainable development

36 An on-site reduction of 59 tonnes of CO2 per year in regulated emissions compared to a 2013 Building Regulations compliant development is expected for the non-domestic buildings, equivalent to an overall saving of 36%. The carbon dioxide savings meet the target set within Policy 5.2 of the London Plan. However, the comments sent separately to the Council and the applicant, which require clarifications related to solar gains, overheating and cooling demand, communal heating system, and submission of BRUKL worksheet and roof layout plan for the photovoltaic panels should be addressed before compliance with London Plan energy policies can be verified.

Transport

37 Vehicular access to the proposed school will be from Macfarlane Lane, which the applicant has proposed to upgrade to a 6 metres carriageway with 3 metres footway on the northern side along its full length from the site to Syon Lane. This is part of a wider mitigation package for Macfarlane Lane and Syon Lane to be delivered by the applicant.

page 7 38 Fifty-seven car parking spaces are proposed, including London Plan compliant levels of blue badge spaces (6 spaces) and electric vehicle charging points (EVCPs). At the pre-application stage, a maximum of 45 spaces was proposed which equates to 50% of the number of staff. The increase reflects the poor connectivity of the site. Three coach parking spaces and a turning circle are also proposed. The applicant advised that parents will not be permitted to drop off within this area, or Macfarlane Lane. Further details on how this would be managed and enforced is required. The applicant proposes to use the nearby Tesco Extra car park as a park & stride location; this is unacceptable given the large number of readily available spaces will encourage car-based travel during the school run, having a serious adverse traffic impact on the A4 Great West Road and local highway network. It is also noted that no formal agreement has been reached by the school with Tesco to use their car park nor any guarantee that the arrangement could be available in perpetuity.

39 The applicant has made use of the secondary school modal split data from the application for the nearby Nishkam School, which is not acceptable. The proposed modal split is 15.4% park & stride, 2.1% car share, 32.6% bus, 4% train/tube, 3% cycle, 42.7% walk and 0.1% scoot. In particular the proportion of bus trips is likely have been overestimated since Nishkam School is served by two nearby bus routes as well as private bus services whereas this proposal would be remote from the nearest route, and the park and stride option will be considerably more attractive, given that the school is expected to attract pupils from a 2.5 kilometres radius.

40 The applicant has undertaken local highway modelling of a number of nearby junctions. The validity of the base models should be improved and further information on the inputs to their LINSIG modelling. Notwithstanding this issue, the modelling submitted to date demonstrates an extremely oversaturated (beyond 150%) condition in the Future Year scenario ‘with development’. Without any mitigation in place, this proposal will have a significant highways impact on the A4 corridor. Furthermore, there is no mention of the traffic impact of this development being included in the A4/Syon Lane junction improvement scheme which will be funded by BskyB – suggesting that this development is not being considered in the design and capacity of the junction. TfL is therefore concerned that the development will create additional congestion at Gillette Corner and the Syon Lane/Tesco roundabout, though it is noted that a mitigation scheme for this roundabout is proposed.

41 The PERS and CERS audits have identified a series of ‘quick win’ measures, including upgrading the crossing on Syon Lane to a zebra crossing and installing new tactile paving on a number of other nearby crossings. All nearby cycle routes scored amber, which suggests that a need for improvement has been identified. Additionally, a cycle lane on Syon Lane has not been proposed, which could undermine efforts to encourage cycling. These improvements should be secured by Hounslow Council. Other improvements to Gillette Corner are proposed by TfL but will depend on third party funding and therefore cannot be guaranteed to serve the proposed school.

42 A total of 150 cycle parking spaces are proposed, which falls short of the minimum standard set out in the London Plan; at least 165 cycle spaces (154 long-stay and 11 short-stay) are required for this development. Further details on the design of spaces is sought, which should be designed to ensure easy access and cater for cyclists who use adapted cycles, as outlined in the London Cycle Design Standards (LCDS).

43 A delivery and servicing plan (DSP) should be secured confirming that deliveries and servicing for the school are not proposed to take place during network or school peak hours, as well where servicing vehicles can safely and legally stop to service the site. A construction logistics plan (CLP) should also be submitted, explaining how the applicant will ensure that the construction of the development will not have a significant impact on the local road network including the nearby TLRN. The submitted travel plan is sufficient where it has passed the ATTrBuTe assessment.

page 8 However, further assertive targets and measures to encourage the uptake of sustainable modes of transport and shift from vehicle trips should be included in the plan.

Summary

48 The proposal represents a high trip generating use in a location that is poorly served by public transport, contrary to London Plan Policy 6.1. It is likely to be a car-dependent development that will lead to increased vehicle trips in the local area. Revised modelling would therefore be required to understand the impact on local junctions and to identify any necessary mitigation to be secured by Hounslow Council along with the improvements identified in the PERS and CERS audits. The applicant is also requested to address issues regarding cycle parking. The travel plan should be improved and secured by s106 agreement, and a DSP and CLP should be secured by condition.

Community infrastructure levy (CIL)

49 The proposed development is for a school defined in education legislation; therefore no Mayoral CIL will be applicable for this instance.

Local planning authority’s position

50 The Council’s planning officers are assessing the application and have not at this stage identified a date for committee. Legal considerations

51 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

52 There are no financial considerations at this stage. Conclusion

53 London Plan policies on provision of school on MOL, playing fields, community use, urban and inclusive design, sustainable development and transport are the key strategic issues relevant to this planning application. Whilst the application is broadly acceptable in strategic planning terms, on balance, the application does not fully comply with the London Plan. The following changes might, however, remedy the above-mentioned deficiencies, and could possibly lead to the application becoming compliant with the London Plan:

 Principle of land use: provision of school on MOL and playing fields: The pressing educational need and lack of available alternative sites are accepted as ‘very special circumstances’ which outweigh the potential harm to the MOL by reason of inappropriateness. The proposed school development is acceptable. The applicant must address the potential impact on playing fields, and actively engage with Sport England, the Council, and local groups to identify any necessary alternative provision.

page 9  Community use: A community use plan agreement, which secures the use of the school’s facilities outside core hours, should be submitted and secured.

 Urban and inclusive design: The Council should secure key details of the cladding system to ensure the best possible build quality is delivered. The approach to inclusive design is supported and the measures proposed should be appropriately secured.

 Sustainable development: The carbon dioxide savings meet the target set within the London Plan. However, clarification is required regarding solar gains, overheating and cooling demand, communal heating system. BRUKL worksheet and roof layout plan should also be provided.

 Transport: Revised modelling is required to understand the impact on local junctions and to identify any necessary mitigation to be secured along with the improvements identified in the PERS and CERS audits. The applicant should also review the proposed use of park and stride, and address issues regarding cycle parking. The travel plan should be improved and secured by s106 agreement, and a DSP and CLP should be secured by condition.

For further information contact GLA Planning, Development & Projects Team: Juliemma McLoughlin, Assistant Director - Planning 020 7983 4271 email: [email protected] Sarah Considine, Senior Manager - Development & Projects 020 7983 5751 email: [email protected] Tefera Tibebe, Case Officer 020 7983 4312 email: [email protected]

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