planning report D&P/3432/01 2 July 2014 West Twyford Primary School, in the London Borough of planning application no. PP/2014/2436

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 Phased demolition of existing and temporary classroom buildings and the erection of a two storey 2-form entry primary school, providing 16 classrooms and associated facilities, car parking area, landscaping and associated works. The applicant The applicant is Ealing Council, and the architect is ASTUDIO.

Strategic issues School provision on Metropolitan Open Land and transport are the most relevant strategic issues to this application.

Recommendation That Ealing Council be advised that the application complies with the London Plan, for the reasons set out in paragraph 33 of this report and does not need to be referred back to the Mayor.

Context 1 On 23 May 2014 the Mayor of London received documents from Ealing 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 03 July 2014 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 to 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; 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.” 3 Once Ealing 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, the Mayor does not need to be consulted again on this application.

page 1 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 school site is located on land designated as Metropolitan Open Land and is located on the Park Royal Opportunity Area. West Twyford Primary School is located in the Park Royal area on Twyford Abbey Road in a residential area in Ealing, West London. Twyford Abbey is situated adjacent to the site albeit some distance from the school itself. Twyford Abbey, though derelict, is a listed building (grade II) and is set in substantial grounds. The wider area is occupied by industrial units stretching along the .

The application school site and existing location plan: Source – Applicant’s submitted planning docs. 6 The A406, also to the north of the application site, is part of the Transport for London Road Network (TLRN). It can be accessed by the Hanger Lane roundabout, 800m away to the south-west of the site. The nearest Strategic Road Network (SRN) is the A404 Harrow Road, located approximately 2kms to the north east of the site. 7 Bus service 226 and 224 can be accessed within accessible walking distance from stops on Bodiam Way and Twyford Abbey Road. The closest London Underground (LU) station is Hanger Lane which is located 860m west of the school. As such, the public transport accessibility level (PTAL) for the site is 2, on a scale of 1-6 where 6 is the most accessible. Details of the proposal 8 Phased demolition of existing building and removal of temporary classroom buildings and the erection of a two storey 2-form entry primary school in the centre of the site, erection of sprinkler tank, bin stores and scooter stores, resiting of shed and bike sheds, rearrangement of car park to provide 10 spaces (1 disabled) and resiting of vehicular access to Twyford Abbey Road and alterations to the hard and soft landscaping (Deemed Consent). Case history 9 In 2010, a planning application was approved for the construction of a single storey detached children's centre, with south canopy extension, within existing school and formation of pedestrian access to Twyford Abbey Road. Strategic planning issues and relevant policies and guidance

10 The relevant issues and corresponding policies are as follows:

page 2  Metropolitan Open Land London Plan  Education London Plan  Transport London Plan; the Mayor’s Transport Strategy

11 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 Ealing Core Strategy DPD, 2013 Development Management DPD and Development Sites DPD, and the 2011 London Plan (with Alterations, 2013). 12 The following are also relevant material considerations:  The National Planning Policy Framework and Technical Guide to the National Planning Policy Framework  Park Royal Opportunity Area Framework, 2008  The draft Further Alterations to the London Plan (January 2014). Principle of Land Use: Education facility on Green Belt 13 In relation to the provision of educational facilities, policy 3.18 'Education facilities' of the London Plan states that “Development proposals which enhance education and skills provision will be supported, including new build, expansion of existing facilities or change of use to educational purposes”. The policy states ‘The Mayor will support provision of early years, primary and secondary school and further education facilities adequate to meet the demands of a growing and changing population and to enable greater educational choice, particularly in parts of London with poor educational performance. …Development proposals which enhance education provision will be supported, including new build, expansion of existing facilities or change of use to educational purposes. 14 The Mayor within the draft FALP 2014 notes that access to high quality school education is a fundamental determinant of the future opportunities and life chances of London’s children and young people. This document taking the most up to date available census data notes London’s population will continue to be younger than elsewhere in and Wales and by 2036, its school age population is projected to increase by 18 per cent further highlighting the wider London need for increased capacity within the capitals schools. The Mayor’s 2020 vision identifies a need for 4,000 extra primary classes by 2020. 15 The application site is part of a Metropolitan Open Land. The London Plan gives equal weight for the protection of MOL as Green Belt. The National Planning Policy Framework (paragraph 89) and the London Plan (policy 7.16) set 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. 16 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. 17 West Twyford Primary School accommodates children from 3-11 years of age with approximately 300 pupils on role. The school has one form of entry with an additional class in Reception and Year 1. There are also two Nursery classes, with 25 children in each. Additionally, on site is a Children’s Centre (opened September 2011) with facilities for pre-school care. The proposed expansion of the school to 2FE will result in the school population increasing from 300 to 420.

page 3 18 The applicant pointed out that the proposed development is an appropriate development on the basis that the scheme is associated with demolition of the existing buildings and redevelopment of the existing site on MOL, as set out in paragraph 89 of the NPPF, i.e. that it is infill development. 19 Notwithstanding the above, the applicant has made evident that there exist very special circumstances that justify the proposal. 20 Educational needs: The Council’s evidence showed that there is significant pressure to provide new primary school places in order to deal with a surge in birth rates and increasing demand in the Borough. Even with the proposed expansion of West Twyford Primary School, the evidence demonstrates there will still be a shortfall by September 2015. The applicant has also demonstrated that there are no other alternative sites in the catchment area that are planning policy compliant and suitable for the provision of school places. It has searched and explored over six shortlisted sites and has evidenced that they do not meet the requirements.

The scale of development, existing and proposed buildings footprint: Source – applicant’s submitted planning docs 21 Limited impact on MOL: The applicant has pointed out that the proposed development will consolidate the existing built form on the site to provide a purpose built and attractive building for increased capacity. The building has been designed to reduce the overall footprint, and create a new landscape setting for the building which will preserve the function and openness of the MOL. 22 The Mayor supports the expansion and redevelopment of schools and acknowledges that there are various factors that limit potential sites and configurations to address the pressing need of school places. In this instance, as detailed above the applicant has demonstrated the pressing shortage of school places and that there are no alternative sites. 23 The NPPF (para 89) allows for redevelopment of previously developed sites but only where it would not have a greater impact on the openness of the Green Belt/MOL. As shown below in the table, although there is a slight increase in overall height of the proposed development from one to two storeys and an increase of floor space (36%), there is an overall reduction in footprint of 29%.

Buildings Footprint Floorspace Height

Existing 1,992sqm 1,817sqm One storey

Proposed 1,417sqm 2,466sqm Two storey

Difference -575sqm +649sqm +One storey

page 4 24 In summary, it is considered that the redevelopment of the school would have a limited impact on the openness of the MOL and would constitute infill development as set out in the NPPF. Given the consolidation of the existing built form within the site results in a smaller overall footprint ensuring the function and openness of the MOL are maintained, and that the pressing need for educational facilities is evidenced, on balance, the proposal is acceptable. Transport for London’s comments 25 The development proposes to retain the existing provision of car parking which consists of ten spaces for staff and one for blue-badge holders. The additional nine staff, resulting from the school expansion, are expected to use the on-street parking which is currently operating at 90% capacity. To prevent the added pressure of parents’ dropping off children outside the school, enforcement measures are proposed. These include enforcement patrols, CCTV and double yellow lines. This is supported in conformity with London Plan policy 6.13. 26 The existing provision of eight cycle parking spaces will be increased to accommodate sixteen more spaces. The provision of ninety spaces for scooters does not mitigate the need to provide a minimum of 53 cycle spaces, as required by the Draft Further Alterations to the London Plan (January 2014) to be located in a secure, covered and accessible location. This should be addressed. 27 TfL has reviewed the adopted trip generation methodology and considers it is in conformity with London Plan policy 6.3. Furthermore, TfL can confirm that this development will not have a detrimental impact on the transport network. TfL supports the initiatives set out in the transport assessment such as the “park and stride”, which is aimed at encouraging walking. However, TfL requests that the applicant undertakes a Pedestrian Environment Review System (PERS) audit in order to assess the walking amenity in accordance with London Plan policy 6.10. 28 TfL has assessed the school travel plan and can confirm that its contents are acceptable, in conformity with London Plan policy 6.3. The final travel Plan should be secured by a legal agreement. A construction logistics plan (CLP) and a delivery and servicing plan (DSP) are recommended by TfL and should be secured by planning conditions. 29 In summary, additional cycle spaces need to be provided in order to comply with the Draft Alterations to the London Plan (January 2014), a PERS audit would be recommended and a CLP and DSP need to be completed and secured by planning conditions. Local planning authority’s position 30 Ealing Council planning officers have yet to confirm their position. Legal considerations 31 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 32 There are no financial considerations at this stage.

page 5 Conclusion 33 London Plan policies on Metropolitan Open Land and transport are the most relevant strategic issues to this application. In general, the application complies with these policies, for the following reasons:  School expansion on Metropolitan Open Land: The proposal would help to address the pressing need for educational facilities. The scheme is considered to have a limited visual impact on the openness of the MOL and constitutes infilling as set out in the NPPF. On balance, the proposal is acceptable.  Transport: Additional cycle spaces need to be provided and secured in order to comply with the Draft Alterations to the London Plan (January 2014), a PERS audit is recommended and a CLP and DSP need to be finalised and secured by planning conditions. 34 The Mayor does not need to be consulted again on this application.

For further information, contact: GLA Planning Unit (Development & Projects Team): 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]

page 6