planning report PDU/2830/02 14 August 2012 Kodak site, Harrow View, Wealdstone in the London Borough of Harrow planning application no. P/3405/11
Strategic planning application stage II referral (new powers) Town & Country Planning Act 1990 (as amended); Greater London Authority Acts 1999 and 2007; Town & Country Planning (Mayor of London) Order 2008
The proposal Outline permission for comprehensive redevelopment of Kodak factory site and adjacent sports ground to provide up to 35,975 sq.m. business and employment space, 985 residential dwellings, up to 220 units of student accommodation, up to 9,300 sq.m. senior living accommodation and assisted living accommodation, up to 5,000 sq.m. retail and restaurant uses, up to 8,830 sq.m. of community facilities including primary school, health centre and community and leisure uses, energy centre and associated access, parking, landscaping and provision of utilities.
The applicant The applicant is LS Harrow Properties Ltd., and the architect is BDP.
Strategic issues The strategic issues raised at consultation stage with respect to employment, open land, retail, housing, student housing, health and social care, urban design, inclusive access, sustainable development and transport have been resolved, and the application now accords with the London Plan.
The Council’s decision In this instance Harrow Council has resolved to grant permission subject to planning conditions and conclusion of a section 106 legal agreement. Recommendation That Harrow Council be advised that the Mayor is content for it to determine the case itself, subject to any action that the Secretary of State may take, and does not therefore wish to direct refusal or direct that he is to be the local planning authority.
Context
1 On 30 December 2011 the Mayor of London received documents from Harrow Council notifying him of a planning application of potential strategic importance to develop the above site for the above uses. This was referred to the Mayor under the following categories of the Schedule to the Order 2008:
page 1 1A (1) “Development which comprises or includes the provision of more than 150 houses, flats, or houses and flats.”
1B (1c) “Development… which comprises or includes the erection of a building or buildings… outside Central London and with a total floorspace of more than 15,000 square metres.”
1C (1c) “Development which comprises or includes the erection of a building… more than 30 metres high and is outside the City of London.”
3B (1a,b) “Development which occupies more than 4 hectares of land which is used for a use within Class B1 (business), B2 (general industrial) or B8 (storage or distribution) of the Use Classes Order; and which is likely to prejudice the use of that land for any such use.”
3C (1b) “Development which is likely to prejudice the use as a playing field of more than 2 hectares of land which… has at any time in the five years before the making of the application been used as a playing field.”
3E (1a,b) “Development 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 comprises or includes the provision of more than 2,500 square metres of floorspace…”.
3F “Development for a use, other than residential use, which includes the provision of more than 200 car parking spaces in connection with that use.”
2 On 7 February 2012 the Mayor considered planning report PDU/2830/01, and subsequently advised Harrow Council that the application did not comply with the London Plan for the reasons set out in paragraph 193 of the above-mentioned report, but that the possible remedies set out in paragraph 195 of that report could address those deficiencies.
3 A copy of the above-mentioned report is attached. The essentials of the case with regard to the proposal, the site, case history, strategic planning issues and relevant policies and guidance are as set out therein, unless otherwise stated in this report. Since then, the application has been revised in response to the Mayor’s concerns and further information and assurances have been provided (see below). On 26 June 2012 Harrow Council decided that it was minded to grant planning permission subject to planning conditions and conclusion of a section 106 legal agreement, and on 3 August 2012 it advised the Mayor of this decision. Under the provisions of Article 5 of the Town & Country Planning (Mayor of London) Order 2008 the Mayor may allow the draft decision to proceed unchanged, direct Harrow Council under Article 6 to refuse the application, or issue a direction to Harrow Council under Article 7 that he is to act as the Local Planning Authority for the purposes of determining the application. The Mayor has until 16 August 2012 to notify the Council of his decision and to issue any direction.
4 The environmental information for the purposes of the Town and Country Planning (Environmental Impact Assessment) Regulations 2011 has been taken into account in the consideration of this case.
5 The decision on this case, and the reasons, will be made available on the GLA’s website www.london.gov.uk.
page 2 Update
6 At consultation stage Harrow Council was advised that the application did not comply with the London Plan for the reasons set out in paragraph 193 of the above-mentioned report, but the possible remedies set out in paragraph 195 of that report could address these deficiencies:
Employment: The applicant should address the concerns raised in the employment section of this report in an effort to overcome the in principle objection raised with respect to London Plan Policy 2.17.
Open land: The applicant should address concerns raised with respect to reconfiguration of open space, sports pitches and other sports facilities to ensure accordance with London Plan policies 3.19 and 7.18
Retail: The submitted retail study should be fully assessed at the local level to ensure accordance with London Plan Policy 4.7.
Housing: A proposed housing schedule, including detail of affordable housing provision, should be provided so the outline application may be assessed against London Plan policies 3.4, 3.5, 3.6, 3.11 and 3.12.
Student housing: The applicant should respond to the matters raised in the student housing section of this report to ensure accordance with London Plan Policy 3.8.
Health and social care: The applicant should have regard to the informatives raised with respect to London Plan policies 3.8 and 3.17.
Urban design: The applicant should address concerns with respect to green link, employment layout, access, movement and parking, masterplan blocks and masterplan design guidance to ensure accordance with London Plan policies 2.17, 5.10, 6.10, 7.1, 7.5 and 7.18.
Inclusive access: The applicant should respond to the matters raised with respect to dwellings and public realm to ensure accordance with London Plan policies 3.8 and 7.2.
Sustainable development: The applicant should address the matters raised with respect to renewable energy, urban greening, sustainable urban drainage, ambient noise and air quality, to ensure accordance with London Plan policies 5.7, 5.11, 5.13, 7.14 and 7.15.
Transport: The applicant should address the matters raised with respect to trip generation and highway impact, parking, London Buses, Harrow-on-the-Hill station and Harrow Bus Station, walking and cycling and travel planning, to ensure accordance with London Plan policies 6.1, 6.3, 6.7, 6.10, 6.13 and 6.14. The applicant should also have regard to the informative provided with respect to the Mayoral Community Infrastructure Levy, in accordance with London Plan Policy 8.3.
page 3 Employment
Relevant updates of employment policy and guidance
7 Since consultation stage the National Planning Policy Framework (NPPF) has been published. With respect to employment land, the NPPF states that “Planning policies should avoid the long term protection of sites allocated for employment use where there is no reasonable prospect of a site being used for that purpose. Land allocations should be regularly reviewed. Where there is no reasonable prospect of a site being used for the allocated employment use, applications for alternative uses of land or buildings should be treated on their merits having regard to market signals and the relative need for different land uses to support sustainable local communities.”
8 Since initial representations were issued at consultation stage the Mayor has published the consultation draft ‘Land for Transport and Industry SPG’. The SPG provides guidance on industrial land requirements as well as on possibilities, appropriate processes and suitable locations for release of surplus industrial land. With respect to the London Borough of Harrow, the SPG identifies the potential for the release of 18 hectares of industrial land between 2011 and 2031.
9 At the time that the Mayor’s initial representations on this application were issued, the ‘Harrow and Wealdstone AAP’ was at preferred options stage. Now, following two previous stages of early consultation, the ‘Harrow and Wealdstone AAP’ has now been published at the pre- submission stage (the final point of public consultation before the document is submitted to the Secretary of State for public examination). Public consultation is currently underway, but at the time of writing this report the Mayor is yet to express his view of the document’s general conformity with the London Plan. Nevertheless, GLA officers have maintained close engagement with the Council as the document has evolved, and the Mayor’s representations issued at the preferred options stage state that: “The GLA is satisfied that figure 6.8 [site specific guidance for preferred layout of Kodak site] represents a pragmatic, evidence based, approach to comprehensive redevelopment of this site, and one which would support wider objectives of the intensification area, including the key requirement to improve access to open space.”
10 The layout for the redevelopment of the Kodak site promoted within the ‘Harrow and Wealdstone AAP’ has been refined slightly since the previous stage of consultation, but has not changed substantially in terms of the general approach to SIL consolidation at the site. In effect, the alterations that have been made since the previous stage of consultation have resulted in an increased symmetry between the site layout promoted by the ‘Harrow and Wealdstone AAP’, and that proposed within the outline masterplan application which is currently being considered. The refined layout within the ‘Harrow and Wealdstone AAP’ is presented overleaf for reference.
Proposed approach to redevelopment
11 As discussed in detail within consultation stage report PDU/2830/01, the applicant proposes employment regeneration of the Harrow View East plot, facilitated by enabling mixed-use development. The emerging ‘Harrow and Wealdstone APP’ supports the principle of employment- led mixed use development where the extent of SIL consolidation is supported by a robust evidence base.
12 At consultation stage the applicant was advised that the proposed mixed-use redevelopment of a strategic industrial location (SIL) raised an objection in principle with respect to London Plan Policy 2.17. However, GLA officers noted that whilst the proposed scale of SIL consolidation was substantial, the scheme would provide a comprehensive developmental response within the spirit of an emerging strategically coordinated planning framework (the ‘Harrow and Wealdstone AAP’). Officers therefore advised the applicant, and the Council, that it may be possible to overcome the objection in principle subject to various related strategic employment
page 4 issues being resolved. The response to the employment issues raised at consultation stage is considered below.
(Image source: Harrow and Wealdstone Area Action Plan, pre-submission consultation document, Harrow Council, July 2012).
Employment proposals
13 At consultation stage the applicant provided details of its market testing which identified a substantial small and medium sized enterprise (SME) economy in the borough. This corresponds with the Council’s own evidence base, and the applicant has linked this economy, and that within the wider sub-region, to a demand for associated workspace. Consequently, the employment component of the proposal (35,975 sq.m. business and employment space) is configured principally towards B1 class SME space. However, to allow for maximum flexibility in response to market demand it is noted that the applicant has now revised the development zone parameters to allow for the possible inclusion of B2 uses within development zone L, adjacent to the railway. This is supported in response to initial representations which sought to ensure that where B1 use space is proposed, it would not jeopardise provision for light industrial accommodation, where there is demand.
14 Whilst the prevalence of small B1 workspaces within the masterplan would represent a shift from the general industrial activities which currently operate at the site (albeit in a state of decline), London Plan Policy 2.17 supports proposals for employment workspace where they would meet identified needs for small and medium sized enterprises (SMEs) or new emerging industrial sectors. Nevertheless, at consultation stage GLA officers sought assurance that the proposed small office space would not compete with the office market within Harrow metropolitan town centre. The Council indicates within its committee report that it is satisfied the relationship between B1 workspace at this site, and the metropolitan town centre office market, can be appropriately managed at reserved matters stage through specific controls with respect to the type and density of employment floorspace. On this basis, GLA officers are now content with the nature of the employment uses proposed.
page 5 Enabling development
15 As discussed at consultation stage, a key component of the evidence base for SIL consolidation at this site is establishing the quantum of enabling development required to facilitate employment regeneration. The GLA expects SIL enabling development to contribute towards strategic and local planning objectives, especially those to provide additional housing (London Plan Policy 4.4). As discussed at consultation stage, however, officers accept that in the interests of delivering sustainable communities it may be necessary to incorporate certain other uses which may not be directly linked to enabling employment development at the site.
16 As part of the original submission the applicant provided a viability appraisal in support of the balance of employment space, and the proposed affordable housing provision. In line with representations made at consultation stage this has now been independently assessed, and further detailed viability discussions have taken place. The GLA has been party to various key stages of these discussions, and officers have been kept informed of all relevant local negotiations.
17 Based on the findings of the independent assessment the Council is satisfied that the balance between employment space and enabling development is acceptable. The Council states within its committee report that “the proposed employment space is the maximum that can reasonably be delivered by the quantum of enabling development proposed, having regard to the provision of affordable housing and when considered in the context of other necessary infrastructure”. GLA officers concur with this view, which is set within the context of current market conditions. Nevertheless, to allow for flexibility in future (subject to market demand and scheme viability) GLA officers have successfully negotiated a viability review mechanism to examine the balance between residential and employment floorspace provision within development zones C and J, within phase 3. This mechanism will be incorporated within the section 106 legal agreement, and having regard to the outline masterplan parameters and the baseline affordable housing level, would allow a potential swing in uses to provide a modest uplift in employment floorspace under favourable market circumstances.
SIL consolidation
18 At consultation stage GLA officers acknowledged that, in accordance with the principles of London Plan Policy 2.17 part b, this proposal has come forward within the context of a strategically coordinated process of SIL consolidation. Nevertheless, in line with the emerging ‘Harrow and Wealdstone APP’ which promotes a bespoke evidence based approach to justify the extent of consolidation, it has been necessary to verify the balance of employment space and enabling development (as discussed above), and for the Council to undertaken its own assessment of the impacts of releasing this employment land within the context of the borough’s remaining stock.
19 As discussed at consultation stage, the proposal would result in a 72% consolidation of the Wealdstone Preferred Industrial Location, leaving a remaining employment land area of approximately 5.1 hectares. It is also noted that the scale of employment land release would account for the majority (74%) of the borough’s 18 hectare transfer benchmark up to 2031. Within initial representations GLA officers cautioned that such a consolidation raises concerns in principle not only because of the quantum and rate of land transferred to mixed use development, but also on the basis that the site may no longer retain the critical mass required to insulate traditional industrial activities from conflicts with other sensitive uses nearby.
20 With respect to the latter concern, however, it is acknowledged that the site is not particularly favourable in terms of its potential to support distribution uses, and that trends within the sub-region indicate that a large scale general industrial role for this site would be unlikely for the foreseeable future.
21 It is also recognised that whilst the typical approach to industrial land management would be to preferentially release smaller sites for town centre infill first, in this instance, this site presents
page 6 an opportunity for a comprehensive intervention to deliver a broad range of benefits, facilitated by a strategically coordinated framework for development (the ‘Harrow and Wealdstone Area Action Plan’).
22 As part of its assessment considering the impact of the proposal on local employment land stock, and having considered the recently published consultation draft ‘Land for Transport and Industry SPG’ the Council finds that “given the particular circumstances of the site and proposal… the proposed release of 16 hectares of SIL land (albeit with approximately 2 hectares to be re- provided as part of the development) would be acceptable”. The Council also states within its committee report that it’s officers “are satisfied that the extent of the employment zones (together with mixed employment/residential uses in Zones C and J) could provide the necessary flexibility to accommodate a range of unit types and sizes to meet what officers expect Harrow’s sub-regional employment role to be in the future.”
23 Within its sub-regional context, and taking into account the characteristically superior, and commercially preferential, industrial locations in neighbouring boroughs of Brent, Ealing and Hillingdon (discussed in GLA report PDU/2830/01), GLA officers are now satisfied that the rationale for the proposed level of employment land consolidation at this site, as part of a strategically coordinated planning process, is justified. It is noted that whilst the scale of proposed SIL consolidation is substantial, the proposal would, nevertheless, provide a comprehensive developmental response in line with adopted and emerging policy and guidance, and offers the potential to deliver a bespoke, modern and marketable employment hub for SMEs, stimulating outer London economic growth on what is currently a constrained suburban employment site, in a state of managed of decline.
24 It is also noted that previous representations with respect to employment land fragmentation and managing conflicts of use have been addressed (refer to paragraphs 66 to 68 within the urban design section of this report), and that a marketing and inward investment strategy has been secured as part of the section 106 legal agreement. GLA officers are now content that the application is acceptable in line with London Plan Policy 2.17. Open land
25 The outline masterplan promotes extensive reconfiguration of open land across the two development plots at the site. Whilst the approach proposed was broadly supported at consultation stage in line with emerging site specific guidance within the ‘Harrow and Wealdstone Area Action Plan’, strategic issues were raised with respect to reconfiguration of open space, sports pitches and other sports facilities. The applicant’s response to these issues is detailed below.
Reconfiguration of open space
26 Whilst it was acknowledged that the proposal would be likely to result in an increased provision of open space across the scheme as a whole, the applicant was asked to provide accurate comparative figures, based on the Council’s adopted designations, clearly demonstrating that there would be no net loss of open space between development phases. Furthermore, officers sought assurance that a strategy for open space re-provision would be secured by planning condition/obligation, to avoid any temporary loss of open space between development phases.
27 Since these representations were made the applicant has engaged in further detailed discussion with the Council and the GLA, and has provided the requested figures for detailed comparison of open space provision. Based on these figures the Council has assessed the proposed reporvision of open space within the outline masterplan. The Council’s committee report finds that, in total, 58,247 sq.m. of open space would be provided. This represents an uplift of 5,937 sq.m. over the existing provision on the Harrow View West plot.
page 7 28 In response to representations made at consultation stage the applicant has also submitted an outline open space strategy which has been designed to ensure that there would be no net loss of open pace at the site between phases. This is particularly important as the full extent of the green link (where the majority of the open space is to be reprovided) would not be achieved until phases two and three are completed. Having assessed the outline strategy, the Council are satisfied that the approach proposed (including the provision of high quality temporary open space) would ensure that there would be no net loss of open space at any stage of the development. The Council has imposed a planning condition to secure detailed approval of the open space strategy prior to commencement, and has confirmed that the reprovided open space would be appropriately designated within the local development plan and the next opportunity for boundary review. On this basis GLA officers are content that the application accords with London Plan Policy 7.18.
Sports pitches
29 Following the Mayor’s representations issued at consultation stage, the GLA is now in receipt of comments from Sport England. It is noted that Sport England has raised a holding objection to the outline application until such time as the Council’s Playing Pitch Strategy has been finalised. Sport England is of the view that the conclusions of the pitch strategy will be key to assessing the merits of the off-site mitigation measures. In the absence of this strategy an objection has been raised on the basis that the scheme would result in a significant loss of the playing field at the Harrow View West plot. Sport England indicates that it would welcome the opportunity to make further comments once Harrow’s Playing Pitch Strategy has been published.
30 Notwithstanding Sport England’s holding objection, made in the absence of a published Playing Pitch Strategy, GLA officers must form a view on acceptability based on the information currently available. It is also noted that the Council’s committee report finds that Sport England’s objection is not one which can be reasonably addressed by the applicant.
31 Whilst GLA officers noted at consultation stage that the proposed mitigation package would result in a net gain of 10.5 hours of playing time at Bannister Sports Centre and 11 hours per week at Headstone Manor Recreation Ground, concern was raised that, over all, one rugby pitch would be lost as part of the wider pitch reconfiguration. The applicant was, therefore, asked to explore further options for re-provision of facilities from the Harrow View West plot, which would not result in the loss of sports pitches.
32 Whilst the applicant has revisited and refined the sports pitch mitigation strategy in response to comments from both the GLA and the Council, a solution has not been found to avoid the loss of the rugby pitch at Bannister Sports Centre. Given that London Plan Policy 3.19 seeks to resist proposals that would result in a net loss of sports facilities and playing fields, officers must now consider this loss.
33 Officers acknowledge that the overall mitigation package would result in 21.5 additional hours playing time per week at well established public local sports facilities. Furthermore, it is noted that whilst there are three local rugby clubs in the area, each club owns its own grounds, and demand for the existing public rugby pitches is low, with only one of the existing seven used on a regular basis. Considering these factors, and weighing in the additional benefits of the scheme, including: improved public access to open space; provision of new homes; and, new job creation, officers are satisfied that the loss of one rugby pitch at Bannister Sports Centre, whilst contrary to London Plan Policy, is, on balance, acceptable in this instance.
Other sports facilities
34 At consultation stage it was noted that seven disused tennis courts and two disused bowling greens at the Harrow View West plot would be lost. Whilst the applicant had broadly demonstrated that the proposed loss of these facilities would not lead to local deficiency within the
page 8 borough on a per capita basis, officers sought assurance that adequate provision would remain within fifteen minutes walk from the site.
35 In response to these representations the applicant has provided an assessment which confirms that there are a number of high quality tennis courts and bowling greens located within a fifteen minute walk of Harrow View. The applicant also indicates that the publically available tennis and bowling facilities within the locality are sufficient to meet the expected growth needs of the area. It is noted that the Council has verified this assessment, and concludes within its committee report that the loss of these facilities (which were not publically accessible when in use) can be accepted. On balance, based on the information presented, GLA officers are of the same opinion. Retail
36 Since consultation stage the applicant has submitted amendments to the proposed retail component of the outline masterplan application. The revised parameters include a reduction in retail floorspace associated with the proposed smaller units, by 1,000 sq.m. across the site. It is now proposed to provide 800 sq.m. of small retail space in zones A and B at the southern end of the site (instead of 2,000 sq.m. as previously proposed), and the remaining 200 sq.m. has been moved to zone N, to help serve the north of the site.
Scale of retail development
37 At consultation stage GLA officers stated that, based on the material available, the quantum of retail provision proposed (2,800 sq.m. [net] food store supermarket and 2,000 sq.m. [gross] small A1-A5 units) would appear to broadly fit within projected growth forecasts for the borough in strategic terms, and the Council’s aspiration for a new supermarket in Wealdstone. However, a final view was deferred until the Council had undertaken its own assessment of the local implications of the retail component the scheme.
38 Since consultation stage the Council has had the applicant’s ‘Retail Statement’ independently assessed. In response to the findings of this assessment, and subsequent local negotiations, the overall provision of retail floorspace within the scheme has been reduced by 1,000 sq.m., as discussed in paragraph 36 above.
Sequential test
39 As discussed within the Mayor’s initial representations, the application site lies outside the boundary of Wealdstone district town centre, and should be treated as an out-of-centre location. At consultation stage it was noted that, having considered thirteen other sites in Harrow and Wealdstone town centres, both within central, and edge of centre locations, the applicant’s sequential assessment concluded that none would provide an opportunity that would be suitable, available and viable.
40 The Council has now undertaken a thorough independent assessment of the applicant’s ‘Retail Assessment’, details of which are set out within the committee report. Having considered the findings of the independent assessment, and following further detailed discussion with the applicant, the Council has accepted the view that none of the sites identified would be suitable, available and viable.
Assessment of impact
41 At consultation stage GLA officers noted that the applicant’s ‘Retail Assessment’ indicated that the proposed retail provision within the outline masterplan would primarily draw trade from large existing supermarkets in and around the borough. However, given the high number of convenience retailers (of small to medium size) within Wealdstone, officers sought to ensure that
page 9 the effect of trade diversion from Wealdstone district centre, was given particular scrutiny as part of the Council’s detailed local assessment.
42 In line with representations made at consultation stage the Council has undertaken a thorough examination of the anticipated retail impact, supported by an independent assessment. This has broadly confirmed the position that the proposed supermarket is principally expected to draw trade from other large food stores, but that the extent of trade diversion was within acceptable levels. With respect to Wealdstone town centre the Council’s assessment found that it is likely that trade diversion would be concentrated mainly on the three medium-sized food stores in Wealdstone: Sainsbury’s Local; Tesco Express; and, Iceland. Given that these stores primarily serve a top-up and day-to-day shopping function, the Council concludes that it is unlikely that these stores would be marginalised as a result of the masterplan proposal. However, details of the Council’s assessment indicate that there would also be some trade diversion from other smaller convenience shops in Wealdstone, and it is possible that a small number of these could become financially unsustainable if appropriate mitigation measures are not put in place.
43 To respond to concerns with respect to impacts on small convenience shops in Wealdstone, the applicant has reduced and dispersed the quantum of smaller retail units proposed within the masterplan (as discussed on paragraph 36 above) to promote trips to Wealdstone high street for small scale A1-A5 retail uses. As an additional measure to encourage ‘linked shopping trips’, and to promote a closer affiliation between the development and the high street, the applicant has also proposed delivery of public realm enhancements between the Harrow View East plot and Wealdstone town centre. It is acknowledged that the Council’s consideration of these measures, supported by the independent assessment, confirms that suitable public realm improvements would encourage and nurture ‘linked shopping trips’, and that these could have a beneficial impact that would contribute towards offsetting the impact on Wealdstone from the identified trade draw. Officers note that a financial contribution of £470,000 is proposed to deliver various measures to promote improved links to Wealdstone town centre as part of the section 106 legal agreement. This is supported as a method of mitigation, and in line with comments made at consultation stage with respect to securing the development’s contribution towards town centre renewal.
44 In the conclusion of its assessment of the retail element of the proposal, the Council found that the reduced retail provision was acceptable in terms of its impact on town centres subject to the mitigation measures discussed above, and appropriate conditions to control the nature and balance of retail floorspace provided. These conditions will be attached the relevant future reserved matters applications, and GLA officers are now satisfied that the outline masterplan application is acceptable in accordance with London Plan Policy 4.7. Housing
45 Whilst it was noted that the outline planning application sought to establish a housing mix, balance between market and affordable housing, tenure split within the affordable provision and range of unit sizes, the detail of the housing schedule was not available at consultation stage due to ongoing local negotiations with respect to scheme viability and local housing need. GLA officers subsequently sought confirmation of the outline masterplan housing schedule so that it could be assessed against strategic housing policy within the London Plan.
46 In response to these representations, and following the conclusion of local negotiations, the applicant has provided the following residential mix, informed by scheme viability and based on the outline masterplan housing schedule:
page 10 Unit type Private market Intermediate Affordable rent One-bedroom 153 16 18 Two-bedroom 280 40 41 Three-bedroom 148 16 39 Four-bedroom 207 7 13 Five-bedroom 0 0 7 Total 788 79 118
Affordable housing
47 As discussed at consultation stage, London Plan Policy 3.12 seeks to secure the maximum reasonable amount of affordable housing. London Plan Policy 3.11 sets a strategic target seeking that 60% of the affordable housing delivered throughout the plan period is social rented housing, and that 40% is intermediate provision. The Mayor’s published proposals for ‘Revised Early Minor Alterations to the London Plan’ clarify that the affordable rent housing product should be accommodated within the 60% portion of the strategic tenure split identified in Policy 3.11, to help achieve the objectives of this Policy.
48 The GLA has been kept informed of discussions with respect to scheme viability and the applicant’s affordable housing viability statement has now undergone a detailed independent assessment. It is based on this assessment, and the outcomes of subsequent viability negotiations, that the above residential schedule has been established. The proposed schedule would achieve a 20% provision of affordable housing (197 units), and a split of 60% affordable rent and 40% intermediate (shared ownership) provision.
49 The Council states within its committee report that it is satisfied the 20% affordable housing provision represents the maximum reasonable amount that the scheme can viably provide. Nevertheless, further to comments made at consultation stage, officers note that the section 106 legal agreement will be designed to include a financial review mechanism to ensure that, should scheme viability improve, additional affordable housing could be secured in later phases. Details of the draft section 106 review mechanism clauses have been provided to the GLA and are acceptable. On this basis officers are content that the application complies with London Plan policies 3.11 and 3.12.
Mix of units
50 London Plan Policy 3.8 encourages a full range of housing choice. This is supported by the London Plan ‘Housing SPG’, which seeks to secure family accommodation within residential schemes, particularly within the social rented sector, and sets strategic guidance for councils in assessing their local needs. Policy 3.11 of the London Plan states that within affordable housing provision, priority should be accorded to family housing. Recent guidance is also set out in the ‘draft Housing SPG’ (2011). Also relevant is Policy 1.1, part C, of the ‘London Housing Strategy’, which sets a target for 42% of social rented homes to have three or more bedrooms, and Policy 2.1, part C, of the ‘draft Housing Strategy’ (2011) which states that 36% of funded affordable rent homes will be family sized.
51 The proposed mix of units is presented in the table supporting paragraph 46 above. The residential schedule provides a good range of dwelling types across all tenures. Within the affordable rent component of the mix the scheme would achieve a 50% provision of family sized dwellings. This is supported in line with the strategic context set out in paragraph 50 above, and officers are content the application accords with London Plan policies 3.8 and 3.11.
Residential standards
52 At consultation stage officers noted that the ‘Design Guidelines’ which accompany the outline application would ensure that all dwellings would meet London Plan minimum space
page 11 standards, and that the future detailed residential design would be informed by the best practice principles of the ‘London Housing Design Guide’. This was supported, and on the basis that concerns previously raised with respect to potential conflicts between industrial and residential uses have now been addressed (refer to paragraph 68), officers are now content the application accords with London Plan Policy 3.5.
Children’s playspace
53 Now that a residential mix has been established, GLA officers have calculated that the development would generate an expected child population of approximately 568 children. Using the methodology within the Mayor’s draft SPG ‘Shaping Neighbourhoods: Children and Young People’s Play and Informal Recreation’ (which considers the influence of dwelling typology, as well as dwelling size, on child yield), this child population would generate an associated requirement for 5,680 sq.m. of children’s playspace. The applicant has demonstrated that the development would provide 6,600 sq.m. of on-site playspace, which would comfortably exceed the required provision. Officers note that the Council is content that the phasing of the playspace delivery would correspond favourably with that of the new homes at the site, and that the play areas would be appropriately distributed to ensure all dwellings had access to playspace within acceptable walking distances. GLA officers are now content the application accords with London Plan Policy 3.6.
Density
54 At consultation stage GLA officers sought a greater resolution of detail with respect to proposed residential densities across the site, so that a full assessment of the application could be made against London Plan Policy 3.4. Whilst, due to the outline nature of the application, detailed figures based on net residential area have not been provided, the applicant has provided density figures on a masterplan plot basis. Officers note that densities at the site would range from 43 habitable rooms per hectare to 205 habitable rooms per hectare, responding accordingly to the varying context of the site. These densities would comfortably fit with those identified by the London Plan density matrix, which for a suburban location suggests residential densities of between 150 to 250 habitable rooms per hectare within a PTAL of two to three, and 200 to 350 habitable rooms per hectare within a PTAL of four to six. GLA officers are now content the application accords with London Plan Policy 3.4. Student housing
55 At consultation stage the applicant demonstrated that the proposed provision of student housing would respond to an identified need from numerous academic institutions. The proposed provision was, therefore, broadly supported in principle.
56 Whilst it was acknowledged that the details of this accommodation would need to be worked up at reserved matters stage, GLA officers sought assurance that the proposed accommodation would be appropriately secured for exclusive use by students, and that a 10% provision of wheelchair accessible/adaptable units would be provided.
57 In response, the applicant has confirmed that it would be content to enter into a binding planning agreement at reserved matters stage to ensure that the occupation of the accommodation would be secured for exclusive use by students. The applicant has also stated that it is committed to making an appropriate provision of wheelchair accessible/adaptable units within the student housing block. The Council will need to pursue these matters at reserved matters stage, however, in so far as the outline masterplan application is concerned, GLA officers are content that the scheme accords with London Plan Policy 3.8.
page 12 Health and social care
58 At consultation stage the applicant demonstrated that the proposed provision of senior living accommodation, an assisted living care home and a primary care centre would respond to local need, and these uses were broadly supported.
59 Whilst it was acknowledged that the details of these facilities would need to be worked up at reserved matters stage, to offer guidance for the detailed stages GLA officers provided informatives with respect to: establishing an operator; affordable residential provision for older Londoners; and, appropriately securing accommodation for care/assisted living.
60 These have been duly noted by the applicant and the Council, and officers acknowledge that since consultation stage it has been confirmed that the proposed health centre is most likely to operate as a Primary Care Centre, occupied by up to eight general practitioners (GP). The Council notes within its committee report that whilst the health centre would be larger than would be required to serve the population of the proposed development alone, the facility would respond to a wider local need.
61 It is also noted that Harrow Primary Care Trust has expressed in principle support of the proposed provision, and GLA officers understand that three existing GP practices have currently registered an interest in locating at the site. Urban design
62 The applicant has maintained a positive and open dialogue with the GLA on urban design matters since the Mayor’s initial representations were issued, and has submitted revised parameter plans in response to a number of strategic design issues. The applicant’s response to the matters raised at consultation stage is considered below.
Green link
63 Whilst officers broadly supported the general approach to delivering the proposed green link across the east and west plots at the site, concern was raised that a three metre deviation within block parameters onto the green link, and spatial competition from access routes, had the potential to significantly erode the provision of true public green space that would be delivered. The applicant was, therefore, asked to remove the deviation of blocks onto the green link, and to secure (increased) minimum widths of the green link, at key points along its length, as a masterplan parameter.
64 In response the applicant has submitted revised parameter plans which remove the building frontage deviation onto the green link, and set minimum widths of 35 metres on Harrow View West, and 35 metres opposite the school, and 45 metres at the heart of the Harrow View East plot. This is strongly supported in line with the Mayor’s previous representations, and would deliver an increased width of green link on the Harrow View West plot, and opposite the school.
65 In response to representations seeking a clearer definition of the relationship between ‘true’ green width and access/car parking, the applicant has refined and augmented detail within the ‘Design Guidelines’ with respect to ‘Access and movement’ and ‘Guidelines for parking’. The submitted revisions are considered in detail in the ‘Access, movement and parking’ section of this report, below, and would help to promote the integrity and coherence of the green link along its length. GLA officers are now satisfied the application accords with London Plan policies 5.10, 7.5 and 7.18.
page 13 Employment layout
66 At consultation stage officers noted that the applicant had sought to locate the largest of the industrial/employment uses to the west of the site, adjacent to the railway line. This approach was supported as a means of maintaining an employment cluster, and creating a buffer between the railway and some of the more sensitive residential and community uses on the site. However, as part of representations made at consultation stage, officers sought assurance that the scheme would come forward in a way which would allow access between the Harrow View West plot and Waverly Industrial Estate, promoting movement between the two estates and contributing to a coherent and integrated employment zone.
67 In response to these representations the applicant has submitted a number of design studies which explore options for links to Waverly Industrial Estate. On the basis of these officers are satisfied that the outline masterplan parameters would allow for direct connections to the Waverly Industrial Estate in future. It is accepted, however, that there is unlikely to be an incentive to deliver these links until such time as the Waverly Estate undergoes its own employment-led regeneration.
68 Representations made at consultation stage also sought to avoid potential conflicts of use at the interface between employment activities and more sensitive residential and educational uses on the Harrow View East plot. In response, the applicant has updated detail within the ‘Design Guidelines’ to include guidance on noise screening. The applicant has also updated its noise assessment to take account of the potential amenity impacts of B2 uses adjacent to the railway line. Having regard to the updated design guidance, and also to the consideration within the ambient noise and air quality sections of this report, officers are content that the proposed employment layout within the outline masterplan application is acceptable in accordance with London Plan policies 2.17 and 7.1. Nevertheless, the Council will need to carefully consider the mitigation measures proposed at the revised matters stage to ensure potential conflicts of use are avoided as the detailed resolution of the scheme comes forward.
Access, movement and parking
69 In response to representations made at consultation stage with respect to the stretch of green link at Harrow View West, the applicant has provided various illustrative studies to express the balance between 'true' green space, car parking, and access links along the green link. As discussed in paragraph 64, the width of the green link along the Harrow View West plot section (excluding front garden space) is now 35 metres. Of this width officers note that 3.5 metres of shared surface would be provided on each side of the green link, allowing for a width of 28 metres of ‘true’ green space. In addition to this, two metres of defensible front garden space would be provided between dwellings and shared surfaces, either side of the green link. Officers note that whilst vehicular access (including emergency access) would be possible along the shared surface areas, car parking would be prohibited along these routes. Instead, officers understand car parking would be provided within the curtilage of the residential typologies, or in dedicated parking areas behind residential blocks. The resolution of this detail is welcomed, and the restriction of car parking on the green link at the Harrow View West plot is supported as a means of promoting its open ‘Green Belt’ feel.
70 At consultation stage officers expressed disappointment that the supermarket access would cross the green link at the southern end of the Harrow View East plot. Whist the applicant has been unable to reconfigure this arrangement due to various phasing constraints, it has been demonstrated that an alternative route would become available in later phases of the development. The applicant has also confirmed within the ‘Design Guidelines’ that once the development is completed, accesses across the green link will be preserved for emergency purposes only, and appropriately controlled to ensure this is the case. Officers are content that this is acceptable.
page 14 71 At consultation stage officers noted that the outline application sought to incorporate a large roundabout and two short sections of dual carriage way at Harrow View. Whilst it was noted that this infrastructure benefited from extant planning permission, and was in the process of being implemented, officers sought a solution to provide access in a way that would be more in keeping with the nature of the outline masterplan.
72 The associated highway works are now approaching completion, and officers note that the applicant has been contractually obliged to deliver this infrastructure through agreement with the landowner of the site, to facilitate the ongoing requirements of Kodak Ltd. as southern parts of the site are sold off and redeveloped. Whilst it has not been possible to delay build out of the roundabout (so that revised highway plans could be submitted), the applicant has responded to the concerns raised by providing a number of illustrative studies seeking to demonstrate how the roundabout and associated infrastructure could be scaled down and softened once Kodak Ltd. have finally vacated the site, and the latter stages of the redevelopment are under way. GLA officers are strongly supportive of the proposal to downgrade this highway infrastructure once it is possible to do so, and encourage the Council to pursue this issue at later reserved matters stages.
73 As discussed in paragraph 43, and in response to representations made at consultation stage, officers support the proposed public realm enhancements to the railway bridge underpass at Headstone Drive, and at Cecil Road and Ellen Webb Drive in line with London Plan policies 6.10 and 7.5.
Masterplan blocks
74 At consultation stage it was noted that the applicant sought an integrated approach to the relationship between employment and residential uses in various zones on the Harrow View East plot. GLA officers sought illustrative details which more clearly defined the intended relationship in these areas. As discussed in paragraph 68 above, the applicant has further developed guidance for these areas within the ‘Design Guidelines’. Additional illustrative studies have also been provided. Whilst the detailed resolution of these interfaces will not come forward until later reserved matters stages, officers are content that based on the material provided, and principals contained within the revised ‘Design Guidelines’ and ‘Environmental Assessment’, key concerns with respect to potential conflicts of use would be avoidable through conventional mitigation methods.
75 As previously discussed at consultation stage the applicant is also strongly encouraged to engage with employment unit designers and operators to inform the design and configuration of employment units for future revised matters applications.
Masterplan design guidance
76 In response to representations made at consultation stage the applicant has augmented the ‘Design Guidelines’ with additional detail with respect to access, employment/residential zones, noise screening, masterplan block resolution, landscaping, car parking, masterplan cross-sections and illustrative views. A clear design narrative to support the future implementation of these guidelines has also been established. Whilst the level of detail now enshrined within the ‘Design Guidelines’ is by no means exhaustive, it is sufficient to be taken forward and applied as a minimum benchmark for the quality of the future scheme.
Urban design summary
77 Having considered the submitted revisions to the outline masterplan parameters, the additional detail within the ‘Design Guidelines’ and the applicant’s response to the other strategic design issues raised, GLA officers are now content that the application accords with London Plan policy on urban design. Nevertheless, the Council is advised that officers would welcome the opportunity to informally review and comment on future reserved matters applications, to assist in the ongoing regeneration of this strategic site.
page 15 Inclusive access
78 The proposed response of the outline masterplan to inclusive access was broadly supported at consultation stage, however, the applicant was asked to address issues with respect to dwellings and public realm to ensure accordance with London Plan policies 3.8 and 7.2.
Dwellings
79 Officers note that in response to representations made at consultation stage, the Council has secured a planning condition to require future reserved matters applications to be accompanied by an ‘Accessibility Strategy’. This will need to express how the detailed phases of the development would respond needs of disabled people, and must demonstrate compliance with ‘Lifetime Homes’ standards and London Plan policy on 10% provision of wheelchair accessible/adaptable housing. This is supported in line with London Plan Policy 3.8, and the applicant is advised to monitor demand for wheelchair accessible housing in early phases to inform the balance of wheelchair accessible/adaptable housing in later phases.
Public realm
80 In response to representations made at consultation stage the applicant has revised the ‘Design Guidelines’ to include additional detail with respect to the proposed treatment of flush boundaries between roads and pavements to ensure these spaces would not present unnecessary risks to disabled people. It is also noted that the conditioned ‘Access Strategy’ will require the submission of details demonstrating how the proposed public realm would be accessible to all, including details of finished site levels, surface gradients and lighting. This is supported and the application accords with London Plan Policy 7.2. Sustainable development
81 At consultation stage strategic issues were raised with respect to the proposed energy strategy (with regard to renewable energy), urban greening, sustainable urban drainage, ambient noise and air quality. Since consultation stage the applicant has engaged positively with the GLA to discuss these matters, and further information and commitments have been provided. The applicant’s response to the concerns raised previously is considered below.
Energy strategy
82 The proposed energy strategy was broadly supported at consultation stage, and would comfortably exceed the minimum carbon dioxide savings identified by London Plan Policy 5.2. In response to initial representations the applicant has now also confirmed that a range of energy efficiency measures would be incorporated within the development, including: mechanical ventilation with heat recovery; low energy lighting; high performance glazing; and, the use of natural ventilation.
Renewable energy
83 The applicant has confirmed that it proposes to install 13,306 sq.m. of roof mounted photovoltaic panels. This is supported and officers note this proposal has been secured by planning condition in accordance with the approved ‘Energy Statement’.
Urban greening
84 The proposed urban greening measures were broadly supported at consultation stage, however, the applicant was asked to commit to the inclusion of green roofs within the scheme. In response to these representations the applicant has reiterated that it intends to provide green roofs on both residential and non-residential blocks within the development, and officers note that the
page 16 Council has imposed a planning condition which will require future reserved matters applications to provide detailed specifications for green/brown roofs. This is supported and the application accords with London Plan Policy 5.11. It is also noted that since consultation stage the applicant has submitted an amended tree plan, and an accompanying report demonstrating that additional trees would now be retained. All trees with Tree Preservation Orders along Harrow View (east side) will now be retained, and officers note that through securing details of the landscaping and biodiversity strategies the Council will secure an overall net gain in trees at the site once the development is completed.
Sustainable urban drainage
85 GLA officers note that, in response to representations made at consultation stage, the Council has included a planning condition on the draft decision notice which requires future reserved matters applications to be accompanied by a ‘Surface Water Drainage Strategy’, to include details of sustainable urban drainage measures. This is supported and the application accords with London Plan Policy 7.13
Ambient noise
86 At consultation stage officers raised a number of queries with respect to the applicant’s noise assessment within the ‘Environmental Statement’. Since consultation stage the applicant has engaged in further discussion on matters of ambient noise, and additional information has been submitted.
87 The applicant has provided further discussion around a number of seemingly anomalous results within the long term measured noise levels. Officers are satisfied with the explanation provided.
88 The applicant has also introduced additional information into the noise assessment to support the potential for the introduction of B2 uses within development zone ‘L’. Officers are content that the assessment undertaken provides a sensible and pragmatic account of the potential impacts of B2 uses in this location, and agree with the applicant’s conclusion that planning conditions would provide an appropriate means of controlling the potential impact of noise from B2 uses on more sensitive receptors.
89 GLA officers note that the Council has imposed a planning condition to require future reserved matters applications to be accompanied by a detailed ‘Noise and Vibration Mitigation Strategy’ which must explain the noise attenuation measures for the proposed uses, including noise barriers, specified glazing and ventilation and orientation/layout of buildings and amenity areas. This is supported and officers are now satisfied that the outline application accords with London Plan Policy 7.15.
Air quality
90 At consultation stage officers were broadly content that the proposed development would comply with Mayor’s policies to reduce the impact of new development on emissions of air pollutants. Nevertheless, a number of detailed clarifications were sought with respect to baseline data and concentrations of emissions before a final assessment was made.
91 The applicant has responded to these initial representations by providing additional information, and confirming that the stack height of the energy centre will be increased, to increase the dispersal of emissions. Further modelling has been undertaken, using five years of local meteorological data between 2007 and 2011, and the applicant has also provided clarifications on emissions concentrations demonstrating that there would be no exceedance of background concentrations.
page 17 92 The Council has secured compliance with the ‘Environmental Impact Assessment’ by way of planning condition, and GLA officers are satisfied that the development would be at least air quality neutral in line with London Plan Policy 7.14. Transport
Trip generation and highway impact
93 As requested at consultation stage, the applicant has conducted a sensitivity test on its trip generation assessment in line with London Plan Policy 6.3. The applicant’s revised assessment shows that a number of local junctions will experience increased levels of traffic which exceed planned capacity. This is consistent with the traffic assessment work undertaken jointly by the Council and TfL in support of the emerging ‘Harrow and Wealdstone AAP’. Whilst none of the areas of stress lie on the Transport for London Road Network, TfL nevertheless welcomes the £1,000,000 section 106 contribution to be paid to the Council to improve the operation of the Harrow View/Headstone Drive junction.
Parking
94 TfL is now satisfied that the level of parking proposed is acceptable, and will be monitored over time. For the residential element of the scheme the proposals to ensure that the smaller units in the apartment blocks will be allocated fewer spaces than the larger detached and semi-detached units on the Harrow View West plot is welcomed, particularly given that the public transport accessibility level varies from two to four across the site. The above arrangements will be reflected in a car parking management plan, a draft of which has been reviewed by TfL and which will be secured and enforced through the section 106 legal agreement. This is supported in line with London Plan Policy 6.13.
95 The proposed parking levels for all remaining uses are also acceptable, falling within the maximum standards set in London Plan Policy 6.13. A condition has been agreed which ensures that minimum London Plan standards for cycle parking, electric vehicle charging points and disabled parking are to be met at the detailed reserved matters stage.
London buses
96 A contribution of £450,000 towards mitigating the impact of the proposed development on the capacity of the bus network has been agreed with the applicant and will be secured as part of the section 106 legal agreement. This is supported in line with London Plan Policy 6.1.
Harrow-on-the-Hill Station and Harrow Bus Station
97 At consultation stage TfL encouraged the Council to pool developer contributions from this and other developments towards improving the environmental quality, physical accessibility, capacity and user safety of Harrow-on-the-Hill station and Harrow Bus Station. Officers note that the Council has secured appropriated contributions towards local transport infrastructure to mitigate the impact of this development, and that Harrow Council shortly expects to publish its draft community infrastructure levy (CIL) charging schedule for public consultation. Once adopted, the Harrow CIL will act in addition to the Mayoral CIL, and will pool development contributions in the manner described above. GLA officers expect improvements to Harrow-on-the-Hill station and Harrow Bus Station to feature within the Council’s proposed CIL infrastructure project schedule. The application accords with London Plan policies 6.1 and 6.7.
Walking, cycling and travel planning
98 In response to initial representations the applicant has introduced a greater level of detail in the ‘Design Guidelines’ with respect to parking and access (refer to paragraph 76). In addition, the
page 18 Council will secure a further £1,500,000 towards sustainable transport and local connectivity. Amongst other items, associated planning obligations will include contributions towards ‘Legible London’ (£15,000), cycle and pedestrian improvements between the site and Wealdstone station and town centre (£270,000), general parking controls in the locality of the site (£150,000), and a travel plan for each phase of the development with a performance ‘bond’ of £100,000. All of these obligations were identified as priorities within initial representations made at consultation stage, and are, therefore, supported in line with London Plan policies 6.1, 6.10 and 6.14.
Mayoral community infrastructure levy
99 Since consultation stage the Mayor’s community infrastructure levy has come into effect. This development will be subject to a charge of £35 per square metre of net increase in floorspace for development in the London Borough of Harrow. This will contribute towards the funding of Crossrail, and further details are available via the GLA website: www.london.gov.uk. The GLA expect the Council, as the Collecting Authority, to secure the levy in accordance with London Plan Policy 8.3. Response to consultation
100 Harrow Council publicised the application by sending notifications to 8,345 addresses in the vicinity of the site, and issuing site and press notices. These addresses were re-consulted following the receipt of revised plans. The relevant statutory bodies were also consulted.
101 The representations received in response to the Council’s local consultation process are considered in detail within the Council’s committee report, and all representations have been made available to the Mayor.
Responses to local consultation
102 In response to both the first and second round of local consultation the Council received 53 responses. Of these: 18 representations supported the principle of the redevelopment; 26 raised an objection to the development; and, 9 provided comments/concerns without raising an objection. The Council also received a petition with 141 signatories campaigning for the use of section 106 funds from this development to address concerns of traffic ‘rat-running’ in local roads.
103 In summary, the local objections and concerns raised relate to: loss of employment space/land; nature of proposed employment offer; likelihood of scheme delivery (in terms of business attraction and job creation); configuration of retail uses; spatial location of supermarket; retail competition with Wealdstone town centre; loss of playing fields/open space, sports/leisure facilities, and function halls; adverse impacts on opportunities for informal recreation, sports and cultural events; inadequate re-provision of green space; use intensification at nearby parks; masterplan design details; spatial configuration of uses; connectivity of masterplan to adjacent streets/development; density of development; residential density; massing and scale; visual impact; impacts on residential amenity (in terms of noise, air quality and overlooking); potential conflicts of use (both within the site and with adjacent development); environmental issues (including air pollution and land contamination risks); safety and security; mixed and balanced communities; local housing need; affordability of proposed housing; residential standards; management of student accommodation; flexibility of community hall; local educational need; risks of antisocial behaviour; local infrastructure need; impact on local infrastructure and services; sustainability; energy strategy; flood risk; drainage; loss of trees; loss of light; traffic impacts; car parking provision; school drop off facilities; adequacy of transport mitigation measures; impacts on transport infrastructure (specifically rail and bus services); pedestrian safety; site/building maintenance; and, construction impacts.
104 The Council also received a letter of representation from Gareth Thomas MP, who, whilst not raising an objection to the application, highlighted a number of local concerns with respect to:
page 19 traffic congestion and parking; green and open space; transport planning; retail impact; affordable housing; gardens; and, community space.
Responses from statutory bodies, local groups and other organisations
105 Environment Agency raised no objection but sought the inclusion of planning conditions with respect to: surface water drainage; land contamination; and, protection of watercourses. Officers note that appropriate conditions have been included within the draft decision notice.
106 English Heritage noted that the proposal would affect the setting of Headstone Manor (Grade I Listed Building, registered at risk), but raised no objection to the masterplan approach based on the outline application details available. GLA officers note that a contribution of £192,000, has been secured within the section 106 legal agreement to deliver improved access to Headstone Manor, and to carry out repairs to the Listed Building. It is also noted that English Heritage will continue to be consulted as future reserved matters applications come forward.
107 English Heritage (Archaeology department) raised no objection but sought planning conditions with respect to a programme of archaeological mitigation and recording. Officers note that appropriate conditions have been included within the draft decision notice.
108 Natural England raised no objection but provided a reference to standing advice and sought to ensure that proposed biodiversity enhancements would be secured by planning condition. Officers note that appropriate conditions have been included within the draft decision notice.
109 Sport England raised an objection (in the absence of the Council’s finalised Playing Pitch Strategy) on the basis that the application results in a significant loss of a playing field. These representations are considered within the open land section of this report.
110 Thames Water raised no objection but sought a planning condition with respect to drainage strategy and sewage infrastructure. Officers note that appropriate conditions have been included within the draft decision notice.
111 Harrow Primary Care Trust expressed an interest in the provision of a health facility within the development, but is not in a position to confirm floorspace requirements at this stage. A clarification was also sought with respect to potential planning obligations with respect to healthcare provision in the borough. Strategic issues with respect to health and social care are considered in the corresponding section of this report. Officers note that a financial contribution towards healthcare provision in the borough has not been sought on that basis that the health and social care facilities proposed as part of the scheme are intended to mitigate the impact of the development, as well as responding to wider local need.
112 London Underground raised no objection.
113 Council for British Archaeology raised an objection on the basis that residential development on the Harrow View West plot would have an impact on the setting of Headstone Manor. Whilst it is noted that English Heritage did not express the same degree of concern, the Council has given due consideration to this objection as part of its detailed heritage assessment, and has found the response of the outline application to the setting of Headstone Manor to be acceptable.
114 Campaign for a Better Harrow Environment did not raise an objection, but identified concerns with respect to: loss of playing fields; potential leisure diversion from the Council’s existing facilities; potential trade diversion from Wealdstone town centre; challenges in delivering employment growth at the site; transport impacts; impacts on congestion; location of the proposed school; flooding issues; land contamination; and, healthcare.
page 20 115 Harrow Agenda 21 raised an objection with respect to: the scale of the retail provision; and, loss of playing fields and green space. Concerns were also raised with respect to: impacts on local infrastructure; amenity space; residential density; pedestrian safety; and, transport impacts.
116 Harrow Friends of the Earth raised an objection with respect to: the scale of the proposed foodstore and the impacts this may generate on local centres and traffic; the scale and location of the proposed school and the impact this would have on local traffic; and, a perceived failure to promote sustainable modes of transport and improve facilities for pedestrians, cyclists, and public transport users. Harrow Friends of the Earth did, however, express support in principle for the mixed-use redevelopment of the site.
117 Hatch End Association indicated in principle support for the application but raised concerns with respect to: traffic; access; site of the proposed school; loss of playing field; loss of trees; and, quantum of employment space.
118 Roxborough Road Residents Association indicated support for the scheme in general, but raised a number of concerns with respect to: traffic congestion; access; loss of sports facilities; provision of sports facilities for the proposed school; retail impact; and, trade diversion.
Responses from other Local Authorities
119 Brent Council raised no objection to the proposal subject to contributions towards improving rail and bus services. Officers note that appropriate planning obligations with respect to related transport matters have been secured as part of the draft section 106 legal agreement.
120 Three Rivers Council raised no objection to the application an indicated support for the proposed residential and employment provision. Three Rivers Council stated that it would have concerns with respect to trade diversion if the proposed retail provision within the scheme were to increase. Officers note that the overall retail provision within the scheme has decreased since the application was originally submitted, and that the maximum provision of retail floorspace has been fixed within the outline masterplan parameters. Furthermore, Harrow Council will secure specific controls with respect to the nature and balance of retail floorspace at reserved matters stage, where Three Rivers Council will be consulted once more.
121 Hertsmere Council raised no objection.
Representations direct to the Mayor
122 The Mayor received one representation directly from a local resident. This provided a copy of an objection letter previously submitted to Harrow Council. The objections within the original letter are included within the summary in paragraph 103. The covering letter to the Mayor also queries why works on the Harrow View roundabout infrastructure (discussed in paragraphs 71 to 72) commenced before outline permission was granted, and queries whether the scheme is deliverable in the current economic climate.
Summary
123 The statutory and non-statutory responses to the Council’s consultation, and those representations made directly to the Mayor, do not raise any material planning issues of strategic importance that have not already been considered at consultation stage, and/or in this report. Article 7: Direction that the Mayor is to be the local planning authority
124 Under Article 7 of the Order the Mayor could take over this application provided the policy tests set out in that Article are met. In this instance the Council has resolved to grant permission with conditions and a planning obligation, which satisfactorily addresses the matters raised at
page 21 consultation stage, therefore there is no sound planning reason for the Mayor to take over this application. Legal considerations
125 Under the arrangements set out in Article 5 of the Town and Country Planning (Mayor of London) Order 2008 the Mayor has the power under Article 6 to direct the local planning authority to refuse permission for a planning application referred to him under Article 4 of the Order. He also has the power to issue a direction under Article 7 that he is to act as the local planning authority for the purpose of determining the application. The Mayor may also leave the decision to the local authority. In directing refusal the Mayor must have regard to the matters set out in Article 6(2) of the Order, including the principal purposes of the Greater London Authority, the effect on health and sustainable development, national policies and international obligations, regional planning guidance, and the use of the River Thames. The Mayor may direct refusal if he considers that to grant permission would be contrary to good strategic planning in Greater London. If he decides to direct refusal, the Mayor must set out his reasons, and the local planning authority must issue these with the refusal notice. If the Mayor decides to direct that he is to be the local planning authority, he must have regard to the matters set out in Article 7(3) and set out his reasons in the direction. Financial considerations
126 Should the Mayor direct refusal, he would be the principal party at any subsequent appeal hearing or public inquiry. Government guidance in Circular 03/2009 (‘Costs Awards in Appeals and Other Planning Proceedings’) emphasises that parties usually pay their own expenses arising from an appeal.
127 Following an inquiry caused by a direction to refuse, costs may be awarded against the Mayor if he has either directed refusal unreasonably; handled a referral from a planning authority unreasonably; or behaved unreasonably during the appeal. A major factor in deciding whether the Mayor has acted unreasonably will be the extent to which he has taken account of established planning policy.
128 Should the Mayor take over the application he would be responsible for holding a representation hearing and negotiating any planning obligation. He would also be responsible for determining any reserved matters applications (unless he directs the council to do so) and determining any approval of details (unless the council agrees to do so). Conclusion
129 The strategic issues raised at consultation stage with respect to employment, open land, retail, housing, student housing, health and social care, urban design, inclusive access, sustainable development and transport have been resolved, and the application now accords with the London Plan.
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] Graham Clements, Strategic Planner (case officer) 020 7983 4265 email [email protected]
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planning report PDU/2830/01 7 February 2012 Kodak site, Harrow View, Wealdstone in the London Borough of Harrow planning application no. P/3405/11
Strategic planning application stage 1 referral (new powers) Town & Country Planning Act 1990 (as amended); Greater London Authority Acts 1999 and 2007; Town & Country Planning (Mayor of London) Order 2008
The proposal Outline permission for comprehensive redevelopment of Kodak factory site and adjacent sports ground to provide up to 35,975 sq.m. business and employment space, 985 residential dwellings, up to 220 units of student accommodation, up to 9,300 sq.m. senior living accommodation and assisted living accommodation, up to 6,000 sq.m. retail and restaurant uses, up to 8,850 sq.m. of community facilities including primary school, health centre and community and leisure uses, energy centre and associated access, parking, landscaping and provision of utilities.
The applicant The applicant is LS Harrow Properties Ltd., and the architect is BDP.
Strategic issues The proposed mixed use redevelopment of strategic industrial land raises an objection in principle, however, subject to the matters raised in this report with respect to employment being resolved, the applicant may be able to overcome this. Further information, revisions and commitments are also sought with respect to the strategic issues of open land, retail, housing, student housing, health and social care, urban design, inclusive access, sustainable development and transport in accordance with the London Plan.
Recommendation That Harrow Council be advised that the application does not comply with the London Plan for the reasons set out in paragraph 193 of this report, but that the possible remedies set out in paragraph 195 of this report could address these deficiencies.
Context
1 On 30 December 2011 the Mayor of London received documents from Harrow 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 9 February 2012 to provide the Council with a statement setting out whether he considers that the application complies with the London Plan,
page 23 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:
1A (1) “Development which comprises or includes the provision of more than 150 houses, flats, or houses and flats.”
1B (1c) “Development… which comprises or includes the erection of a building or buildings… outside Central London and with a total floorspace of more than 15,000 square metres.”
1C (1c) “Development which comprises or includes the erection of a building… more than 30 metres high and is outside the City of London.”
3B (1a,b) “Development which occupies more than 4 hectares of land which is used for a use within Class B1 (business), B2 (general industrial) or B8 (storage or distribution) of the Use Classes Order; and which is likely to prejudice the use of that land for any such use.”
3C (1b) “Development which is likely to prejudice the use as a playing field of more than 2 hectares of land which… has at any time in the five years before the making of the application been used as a playing field.”
3E (1a,b) “Development 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 comprises or includes the provision of more than 2,500 square metres of floorspace…”.
3F “Development for a use, other than residential use, which includes the provision of more than 200 car parking spaces in connection with that use.”
3 Once Harrow 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; take it over for his own determination; or allow the Council to determine it itself.
4 The environmental information for the purposes of the Town and Country Planning (Environmental Impact Assessment) (England and Wales) Regulations 1999 has been taken into account in the consideration of this case.
5 The Mayor of London’s statement on this case will be made available on the GLA website www.london.gov.uk. Site description
6 The proposal site is located just to the west of Wealdstone district town centre, and falls within the Harrow and Wealdstone intensification area as identified within the London Plan, and defined within the Council’s emerging ‘Core Strategy’, and the preferred options draft ‘Harrow and Wealdstone Area Action Plan’. The site comprises two plots, either side of Harrow View.
7 To the east of Harrow View is a roughly triangular plot of approximately 16 hectares, bound by residential hinterland to the north, the Waverly Industrial Estate and railway line to the east, Headstone Drive to the south, and Harrow View to the west. The plot is occupied by Kodak Ltd. and is currently used for various manufacturing, administrative and logistical processes. The
page 24 company’s operations at the site have been gradually contracting in recent years and approximately 6.4 hectares of the plot has now been cleared of development. This plot, together with the adjacent Waverly Industrial Estate, forms the Wealdstone preferred industrial location (a strategic industrial location) as identified by the London Plan. This report will refer to this portion of the site as Harrow View east.
8 To the west of Harrow View is a roughly square plot of approximately 8 hectares, bound by Metropolitan Open Land and Headstone Manor to the west, residential hinterland to the north and south, and Harrow View to the east. The plot is primarily green open space and playingfields, and hosts the Zoom Leisure Centre complex, which officers understand has recently closed. The majority of this plot is designated as open space within the local development plan. This report will refer to this portion of the site as Harrow View west.
9 At its southern point, the application site lies some 300 metres from Harrow and Wealdstone station (national rail, London Underground [Bakerloo Line] and London Overground services). Three bus routes (H9, H10 and H14) run adjacent to the site, although a further six routes can be accessed at Harrow and Wealdstone. Further bus services run along Station Road, (350 metres to the south). There are no sections of the Transport for London Road Network in close proximity to the site, however, Station Road forms part of the Strategic Road Network. The public transport accessibility level of the site ranges from two to four (on a scale of one to six, where one is poor and six is excellent).
Details of the proposal
10 The proposals comprise an outline parameter masterplan to support phased redevelopment of the site, envisaged to occur over the next ten years. The outline masterplan parameters are also supported by various guidelines and indicative details. It is understood that later phases of the redevelopment would be intended to retain a degree of flexibility in order to respond to Kodak’s changing needs, as well as market demand for employment uses.
11 The outline masterplan proposes up to 35,975 sq.m. of employment uses (including office, SME, business units, logistics and storage); 985 dwellings; up to 220 units of student accommodation; senior living accommodation; assisted living care home; commercial leisure centre of approximately 9,300 sq.m.; up to 8,850 sq.m. of community facilities including primary school, health centre and community and leisure uses; associated parking, open space, landscaping and ancillary development. Case history
12 On 20 October 2011 a formal pre-application meeting was held at City Hall to discuss the principle of this proposal. Officers issued advice on 15 November 2011 which stated that the proposed mixed-use redevelopment of a strategic industrial location raises an in principle objection with respect to London Plan Policy 2.17. It was noted, however, that it may be possible for the applicant to overcome this objection, subject to concerns with respect to employment being addressed. Strategic issues were also identified with respect to open space, retail, housing, student accommodation, health and social care facilities, education facilities, urban design, inclusive access, sustainable development and transport. The applicant was advised to ensure these issues were addressed before the outline planning application was submitted to the local planning authority. Strategic planning issues and relevant policies and guidance
13 The relevant issues and corresponding policies are as follows:
page 25 Intensification area London Plan Employment London Plan; PPS4; Industrial Capacity SPG Open land London Plan; PPG17; draft PPS Planning for a Natural and Healthy Environment; draft All London Green Grid SPG Sports facilities London Plan; PPG17, draft PPS Planning for a Natural and Healthy Environment Retail London Plan; PPG13, PPS4 Housing London Plan; PPS3; Housing SPG; Providing for Children and Young People’s Play and Informal Recreation SPG, Housing Strategy; Assembly draft Revised Housing Strategy; Interim Housing SPG; Housing SPG EiP draft Affordable housing London Plan; PPS3; Housing SPG, Housing Strategy; Assembly draft Revised Housing Strategy; Interim Housing SPG; Housing SPG EiP draft; Affordable Rent draft SPG; Assembly draft Early Minor Alteration to the London Plan Density London Plan; PPS3; Housing SPG; Interim Housing SPG; Housing SPG EiP draft Student housing London Plan Health and social care London Plan Education facilities London Plan; Policy Statement August 2011 Urban design London Plan; PPS1 Inclusive access London Plan; PPS1; Accessible London: achieving an inclusive environment SPG; Planning and Access for Disabled People: a good practice guide (ODPM) Sustainable development London Plan; PPS1, PPS1 supplement; PPS3; PPG13; PPS22; draft PPS Planning for a Low Carbon Future in a Changing Climate; Mayor’s Climate Change Mitigation Strategy; Mayor’s Climate Change Mitigation and Energy Strategy; Mayor’s Water Strategy; Sustainable Design and Construction SPG Ambient noise London Plan; the Mayor’s Ambient Noise Strategy; PPG24 Air quality London Plan; Assembly draft Early Minor Alteration to the London Plan; the Mayor’s Air Quality Strategy; PPS23 Transport and parking London Plan; the Mayor’s Transport Strategy; PPG13
14 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 2004 Harrow Unitary Development Plan saved policies and the 2011 London Plan.
15 The following are also relevant material considerations:
Harrow Core Strategy (Post Examination Hearing Stage, for which the Planning Inspector’s report has been published); Harrow and Wealdstone Area Action Plan (Preferred Options Consultation Stage); Early Minor Alteration to the London Plan.
Intensification area
16 London Plan Policy 2.13 identifies Harrow and Wealdstone as an area for intensification capable of accommodating significant growth and change, including the delivery of 1,500 new
page 26 homes and 2,000 new jobs. The emerging ‘Harrow and Wealdstone Area Action Plan’ is intended to provide the framework for growth within the intensification area.
17 With respect to this particular site, the emerging ‘Harrow and Wealdstone Area Action Plan’ promotes the principle of managed consolidation of the Wealdstone preferred industrial location to provide a redefined employment role for the site. The intention is that this would exploit the borough’s potential employment growth niches, and be enabled by residential development forming, and supporting, sustainable communities.
18 The document presents indicative minimum outputs for the site of 1,230 jobs and 1,035 homes, and spatially identifies supported land uses within a preferred site layout option. It also presents the key aspiration of providing an unbroken swathe of green open space across the site. This is intended to lead from Headstone Manor and the adjoining Metropolitan Open Land, through both plots at the site, and down to Headstone Drive. The aspiration is that this should bring the appreciation and benefits of Green Belt into Wealdstone and the wider intensification area, providing amenity and opportunities for a variety of recreational uses. The preferred layout is presented below.
Key
(Image source: Harrow and Wealdstone Area Action Plan, preferred options consultation document, Harrow Council, January 2012). Employment
19 As discussed in paragraph seven of this report, a substantial portion of the site (Harrow View east) lies within the Wealdstone preferred industrial location, which is identified by the London Plan as a strategic industrial location (SIL).
Strategic policy context
20 London Plan Policy 2.17 affords SILs strategic protection as London’s main reservoirs of industrial and related capacity. Part B of this policy states that development proposals within SILs should be refused unless they fall within the industrial use type activities outlined in London Plan paragraph 2.79; are part of a strategically co-ordinated process of SIL consolidation through an opportunity area planning framework or borough development plan document; or, meet identified needs for small and medium sized enterprises or new emerging industrial sectors.
21 For preferred industrial locations, London Plan paragraph 2.79 identifies the following acceptable uses: general industrial, light industrial, storage and distribution, waste management,
page 27 recycling, transport related functions, utilities, wholesale markets and other industrial related activities.
22 For industrial business parks, London Plan paragraph 2.79 identifies the following acceptable uses: research and development, light industrial and higher value general industrial, some waste management, utility and transport functions, wholesale markets and small scale distribution. Typically such activities require better quality surroundings than those within preferred industrial locations.
23 The Mayor’s supplementary planning guidance ‘Industrial Capacity’ (2008) places Harrow in the ‘limited’ category for the purposes of managing the transfer of industrial land to other uses. This category effectively promotes the limited transfer of industrial land to other uses, taking account of local variations of demand. Boroughs within this category are encouraged to manage and, where possible, reconfigure their portfolios of industrial land, safeguarding the best quality sites and phasing release to reduce vacancy rates for land and premises.
24 The ‘Industrial Capacity SPG’ (2008) identifies Harrow as within the ‘west’ sub-region, which is apportioned a benchmark for industrial land release of 52 hectares between 2006 and 2026. The report ‘London’s Industrial Land Baseline’ (2010), commissioned by the GLA, indicates that the quantum of industrial land released within the ‘west’ sub-region since 2006 has already exceeded this benchmark.
25 Notwithstanding this, newly emerging strategic evidence has placed this benchmark under review, and suggests there may be scope for further transfer of industrial land in west London. However, this will need to be confirmed locally within employment land reviews and Development Plan Documents. The Mayor is shortly expected to publish a new draft supplementary planning guidance ‘Industry’ for consultation which will address this, and other associated matters, in more detail.
Relevant employment characteristics of the Borough
26 The ‘Harrow Employment Land Review’ (2010) states that manufacturing is proportionally over-represented in Harrow, but is declining within the borough faster than the London average. The report ‘Mayor’s Outer London Commission’ (2010) indicates that the historic decline in industrial employment within the borough is projected to progress at 1.2% per year between now and 2031.
27 Within the sub-region demand for larger distribution and industrial space tends to be focused away from Harrow, preferring locations closer, or with more direct access to, strategic routes such as M25 or A40. As a result, Harrow has not shown itself to be a successful distribution location, typically losing out to Brent, Ealing and Hillingdon. Constrained local road access to many of the borough’s main employment locations, often through residential areas, also compounds this disadvantage.
28 As a result of these trends, estimated employment floorspace requirements within the ‘Harrow Employment Land Review’ (2010), based on baseline job growth, project a negative requirement of 8.3 hectares for industrial space and 2.9 hectares for distribution space up to 2026.
29 The Harrow Employment Land Review (2010) also notes that the borough lacks an identifiable or recognised industrial product which can be marketed.
page 28 Existing employment characteristics of the site
30 The site is a large single-occupier manufacturing facility operated by Kodak Ltd., and currently employs approximately 570 people (350 in production jobs and 220 in office-based jobs). The ‘Harrow Employment Land Review’ (2010) notes that the site’s generally poor strategic road access means that it is not well suited to large-scale employment uses. Adjoining residential uses on three sides also present constraints to potential future industrial development at the site. However, the site lies close to Harrow & Wealdstone train station and Wealdstone High Street and, therefore, offers good access to services and public transport. The ‘Harrow Employment Land Review’ (2010) identifies this site as the main opportunity for future growth of the commercial property stock in the borough due to these links, and notes that it could support a wide range of smaller industrial and/or offices uses.
31 The Kodak operations at the site are consolidating, and the Harrow view east plot now has some 6.4 hectares of surplus land. Officers understand that this vacant land has been marketed nationally for open storage uses, but has generated only limited interest.
Proposed approach to redevelopment
32 The outline application proposes a mixed-use approach to redevelopment on the SIL portion of the site. Based on the material provided it is evident that approximately 65% of the floorspace proposed on the SIL would not accord with the broad industrial type activities outlined in London Plan paragraph 2.79. On this basis the proposal raises an objection in principle, with respect to part B(a) of London Plan Policy 2.17.
33 In attempting to overcome the in principle objection generated by Policy 2.17, the applicant must first demonstrate that non-compliant uses are required as enabling development, to support the provision of employment uses (further detail on enabling development is provided in the associated section below). The applicant has, therefore, been required to provide a scheme viability appraisal so that the role of the non-compliant uses in cross-subsidising provision of employment space can be verified, or that a revised balance of uses can be negotiated.
34 The applicant has submitted a viability appraisal, but at the time of writing this report the independent assessment of the appraisal is ongoing. Officers will update the Mayor of the findings of the assessment, and of any associated negotiations, in due course.
35 The applicant is advised that the GLA seeks to promote the employment function of the Wealdstone SIL in line with London Plan Policy 2.17 and the emerging ‘Harrow and Wealdstone Area Action Plan’. Subject to verification of the viability appraisal, the Council is strongly encouraged to secure the quantum of employment space proposed for the site as an absolute minimum. The Council should also seek to use a planning agreement to, not only link the potential build out of housing phases to the delivery of employment space, but also to secure opportunities for re-appraisal(s) of scheme viability at future phases, to allow for an upward review of employment space provision, where viable and deliverable. The applicant should also ensure the proposed outline masterplan parameters would be flexible enough to accommodate an uplift in employment space.
Employment proposals
36 The applicant has submitted an employment report which details the employment component of the proposal. The following assessment of these proposals is made not withstanding the in principle objection raised in paragraph 32 above.
page 29 37 Officers note that the current operations at the site provide 88,354 sq.m. of employment floorsapce for manufacturing and offices (B2 and B1), supporting approximately 570 jobs. The proposal would provide 30,865 sq.m. of employment floorspace potentially for a range of light industrial, office, logistics and other business uses (B1 and B8), potentially supporting up to 1,650 jobs. It is, therefore, noted that whilst the proposal would result in a contraction of employment floorspace at the site by 65%, the scheme could result in an uplift of up to 1,080 jobs (within Use Class B) through delivering increased employment densities at the site.
38 The applicant maintains that for the indicative masterplan to be delivered successfully, and for the employment role of the site to be self-sustaining, the scheme will require flexibility with respect to the nature of the employment offer, in order to deliver a locally specific product which could be successfully marketed. It is within this context that the applicant has proposed a significant proportion of Use Class B1 type floorspace, which would not generally fall within the uses defined for a preferred industrial location (identified in paragraph 21). The GLA acknowledges the need for reasonable flexibility at this site, and through joint discussions with the Council as part of the strategically coordinated development of the emerging ‘Harrow and Wealdstone Area Action Plan’ the GLA accepts that it may be necessary to facilitate a move towards employment uses at this site that would be more akin to an industrial business park (discussed in paragraph 22).
39 As part of joint discussions the Council and the applicant have been advised that the GLA would support a shift in the site’s strategic employment function where this is locally justified, would provide a sustainable employment role for the site, would be complementary to operations within the wider Wealdstone SIL, and would contribute towards the regeneration of Wealdstone.
40 As part of pre-application discussions on the scheme, the applicant was asked to provide local evidence to support the shift proposed (primarily towards smaller commercial units for small and medium sized enterprises). The applicant has since provided details of its market research which identifies a substantial small and medium sized enterprise economy in the borough, and broadly demonstrates a market demand for associated workspace. It is understood that these findings are generally endorsed by the Council’s own evidence base, and officers acknowledge that the vast majority of businesses in the borough employ five people or less.
41 On this basis, the principle of a reconfigured employment function of the site, tailored towards the requirements of small and medium sized enterprises, would be supported. As a cautionary note, however, the Council will need to satisfy itself that where B1(a) use space is proposed, it would not jeopardise provision for light industrial accommodation where there is demand, nor compete with the office market within Harrow metropolitan town centre.
42 It is acknowledged that the emerging ‘Harrow and Wealdstone Area Action Plan’ also seeks the provision of B2 employment uses at this site. Officers note that this use does not currently form part of the outline application proposals. Whilst supporting the principle of a reconfigured employment function at this site, the applicant is advised to consider the benefits of introducing B2 uses as part of these proposals, to enrich the diversity of the employment offer.
Enabling development
43 The GLA expects SIL enabling development to contribute towards strategic and local planning objectives, especially those to provide additional housing (London Plan Policy 4.4). Where new housing would be required as enabling development at this site it should represent a sustainable contribution to Wealdstone, and be supported, where necessary, by social infrastructure. Officers accept, therefore, that in the interests of delivering a sustainable community it may be necessary to incorporate certain other uses which may not be directly linked to enabling employment development at the site. The applicant is advised, however, that the
page 30 submitted viability appraisal, discussed in paragraph 34 above, will be carefully scrutinised to determine the credentials of uses proposed as enabling development.
44 On the basis of the considerations in paragraph 41 above (and not withstanding the in principle objection raised in respect of London Plan Policy 2.17, part B(a)), the applicant’s proposed provision of housing as a form of enabling development would be acceptable, in principle, subject to the form of financial justification described in paragraph 33 above. Similarly, the proposed student accommodation, senior living, assisted living, leisure centre, community centre, health centre and primary school would be acceptable enabling uses in principle, given their contribution towards strategic and local planning objectives for Wealdstone and the wider intensification area. However, the applicant’s proposed inclusion of a large-format convenience retail store as part of the proposal cannot be justified in these terms.
45 Whilst it is noted that the convenience store is, in financial terms, a form of enabling development that would facilitate the provision of employment floorspace, given that it has not yet been demonstrated that the location of this use at the site would accord with the London Plan’s “town centre first” approach, it cannot be demonstrated that this component of the proposal would positively contribute towards strategic and local planning objectives, or facilitate town centre renewal, in line with the principles of London Plan Policy 4.4.
46 In order to overcome these concerns in strategic terms, the applicant must address the matters raised under the retail section of this report; have the supermarket’s credentials as enabling development verified through independent assessment of the viability appraisal; and clearly demonstrate how this component of the proposal would contribute towards the renewal of Wealdstone district town centre.
SIL Consolidation
47 In response to the employment context of the borough, and of this particular site, (discussed earlier in this section), the Council has stated (within the emerging ‘Harrow Core Strategy’), that consideration will be given to the consolidation of the Wealdstone preferred industrial location where this would contribute to the promotion and development of Wealdstone in line with the objectives for the intensification area. Within his representations on the Core Strategy, the Mayor has stated that the GLA will work closely with the Council, and other strategic partners, to develop a suitable approach for the regeneration of the Wealdstone SIL, specifically considering its boundary and function, as part of the ‘Harrow and Wealdstone Area Action Plan’.
48 The preferred option draft of the ‘Harrow and Wealdstone Area Action Plan’ does not identify a preferred level of SIL consolidation, instead favouring a bespoke evidence based approach to justify the extent of consolidation required to enable a comprehensive developmental approach that would deliver a sustainable employment function for the site, and the reconfiguration of open space. It is, however, noted that the preferred site layout option for this site, presented in support of paragraph 18, does present an indicative level of SIL consolidation by nature of its proposed land use layout.
49 It is in response to this emerging policy context that this outline application has been brought forward by the applicant. The table below provides a summary breakdown, in land area terms, of the proposed uses within the SIL portion of the site, against the existing situation.
page 31 Proposed Uses Land area (hectares) Employment (SIL compliant) 2.7 Employment other (including retail) 1.2 Residential 5.7 Community uses 1.2 Open space 4.8 Energy centre/multi storey car park 0.5 Total 16.1*
Existing Uses Land area (hectares) Kodak operations (SIL compliant) 9.6 Vacant land 6.4 Total 16* *Note that totals do not exactly correspond due to rounding of figures up to one decimal place.
50 Based on the material provided it is evident that the proposal would result in an approximate SIL land area consolidation at the site of 13.3 hectares (83%). When considering the Wealdstone preferred industrial location as a whole, the proposal would result in an approximate overall consolidation of 72%, leaving a remaining SIL land area of approximately 5.1 hectares.
51 The diagram below presents the proposed configuration of employment uses on the Harrow View east plot. SIL uses are shown in blue.
(Image Source: Submitted plans, Harrow View – Employment generating land uses, BDP, January 2012).
page 32 52 The level of SIL land area consolidation proposed by the scheme is substantial, and would exceed the total projected 11.2 hectare negative requirement for industrial land in the borough, discussed in paragraph 28, by 2.1 hectares. The nature of this proposed consolidation, at such an unbroken and well defined employment site, raises concerns not only because of the quantum of land transferred, but also on the basis that the site may no longer retain the critical mass required to insulate traditional industrial uses from conflicts with other uses nearby.
53 With respect to the latter issue, it is nevertheless acknowledged that the site is not particularly favourable in terms of supporting distribution uses, and trends within the sub-region indicate that a large scale general industrial role for this site would be unlikely for the foreseeable future. It is also noted that whilst the typical approach to industrial land management would be to preferentially release smaller sites first, in this instance this site presents an opportunity for a comprehensive intervention to deliver a broad range of benefits, facilitated by a strategically coordinated framework for development (the ‘Harrow and Wealdstone Area Action Plan’).
54 In terms of loss of employment land area, the strategic context presented earlier in this section identifies that the quantum of industrial land released in west London has already exceeded its benchmark. It is, however, acknowledged that this benchmark is currently under review, in the light of newly emerging strategic evidence.
55 Within this sub-regional context, and taking into account the characteristically superior, and commercially preferential, industrial locations in neighbouring boroughs discussed in paragraph 27, the rationale for consolidation of employment land at this site, as part of a strategically coordinated process, is sound. The applicant’s response to the emerging aspirations for the site is also recognised, and it is acknowledged that delivering the green link through the site introduces additional spatial competition in terms of SIL land area. (Officers note that under the proposal approximately 4.8 hectares [30%] of the land area on the Harrow View east SIL would be transferred to open space). This, whilst helping to deliver one of the key aspirations emerging within the ‘Harrow and Wealdstone Area Action Plan’, will conversely reduce the land area available for employment uses and enabling development at the site.
56 The Council will undertake its own assessment of the proposals, as part of which it will consider the impacts of releasing this employment land within the context of the borough’s remaining stock.
Fragmentation
57 SILs are given strategic protection because their scale and relatively homogenous character means they can accommodate activities which elsewhere might raise tensions with other land uses. It is, therefore, important that these proposals would maintain sufficient critical mass of employment area, now and into the future, to facilitate the continued operation of industrial processes in this location. The aspiration to deliver employment space within the first phase at Headstone Drive is strongly supported, however, the applicant should seek to ensure this would contribute to a coherent employment zone, as future phases come forward.
58 It is also crucial that the employment areas within the cluster are able to operate collectively, facilitated by good access and permeability. The applicant should seek to ensure that the newly proposed employment space would operate in conjunction with Waverley Industrial Estate to agglomerate employment activity in this area, and ensure the two estates operate collectively, to support the strategic industrial location designation. Whilst it is understood there may be challenges to achieving direct access between the proposal and Waverly Industrial Estate, officers remain to be satisfied that a solution cannot be found. The applicant should, therefore, provide an access assessment which explores the options for links to Waverly Industrial Estate. The applicant is advised that officers will seek to secure links between these estates where feasible.
page 33 Conflicts of use
59 London Plan Policy 2.17, part C, states that development proposals within or adjacent to SILs should not compromise the integrity or effectiveness of these locations in accommodating industrial type activities. Having regard to the proposed employment layout presented in support of paragraph 51, there are a number of areas of concern in terms of potential use conflicts.
60 These concerns focus on the relationship between the proposed northern employment area (blocks N and M), and its relationship with the adjacent primary school and residential dwellings. The applicant should provide visual representations of the envisaged relationship between the uses in these areas, and ensure the ‘Design Guidelines’ explicitly address issues with respect to conflicts of use, and promote appropriate methods of mitigation where necessary. The ‘Design Guidelines’ should provide similar guidance to support the proposed pepper-potting of smaller commercial units within blocks C and K.
Future marketing
61 In order to facilitate the proposed shift in employment function and character at the site, and to ensure the scheme would represent a successful intervention, a robust marketing programme and inward investment strategy will be fundamental. The applicant has identified these components as key tools of delivery, and provided outline details on the proposed approach to each. The initial proposals are broadly supported, and officers would welcome the opportunity to review the marketing strategy as it continues to progress. Given that phase one is intended to act as a kick-start for the shift in employment dynamics at the site, officers would expect a clearly defined and targeted marketing strategy to be in place before detailed applications are submitted.
Employment summary
62 The proposal raises an objection in principle with respect to London Plan Policy 2.17. Through subsequent joint negotiations with the Council and the applicant, informed by an assessment of scheme viability, officers will seek to resolve these concerns. It is noted that whilst the scale of proposed SIL consolidation is substantial, the proposal would nevertheless provide a comprehensive developmental response within the spirit of an emerging strategically coordinated masterplan, and with the potential to deliver a bespoke, modern and marketable employment hub, stimulating outer London employment growth on what is currently a constrained employment site.
63 Notwithstanding the in principle objection raised with respect to London Plan Policy 2.17, an assessment of the other strategic issues generated by the proposal is provided below. Open land
64 As discussed in paragraph eight of this report, the Harrow View west plot is occupied by a former leisure centre and playing field, with the majority of the plot locally designated as open space. The applicant is proposing to build on a proportion of the existing open space, making a re- provision at the Harrow View east plot.
Reconfiguration of open space
65 London Plan Policy 7.18 supports the creation of new open space in London to ensure satisfactory levels of provision, and to address areas of deficiency. Part B of this policy states that the loss of locally protected open spaces must be resisted, unless equivalent or better quality provision is made within the local catchment area.
page 34 66 The applicant has presented details of the proposed open space reconfiguration within the submitted design and access statement and open space and leisure study. Officers note that whilst the local development plan includes the existing tennis courts on the Harrow View west plot within the open space designation, the applicant has recorded this area as “hard surface”, effectively making it indistinguishable in land area terms from the developed (and undesignated) portion of the plot. Whilst it is acknowledged that the material provided demonstrates the proposal would result in an increased provision of open space across the scheme as a whole, the applicant should provide accurate comparative figures, based on the Council’s adopted designations, clearly demonstrating that there would be no net loss of open space between development phases.
67 The applicant should also submit a strategy for open space re-provision, for approval by the Council, which demonstrates that open space provision would be managed through the various phases of redevelopment, to avoid any temporary loss. The GLA strongly encourages the Council to secure such a strategy by planning condition or planning obligation, as appropriate. In addition, officers seek confirmation that, at least, an equivalent quantum of the reconfigured open space will be designated by the Council, to off-set that which is proposed to be displaced from the Harrow View west plot.
Sports facilities
68 London Plan Policy 3.19 seeks to enhance the provision of sports and recreation facilities, and would resist proposals that would result in a net loss of such facilities, including playing fields.
69 The proposed re-configuration of open space on the Harrow View west plot would displace the recently closed sports ground which currently occupies the site. Based on the material provided the redevelopment would result in the loss of three adult football pitches and one mini-soccer pitch at the site. Officers also understand that the seven existing tennis courts at the site would also be lost, along with two disused bowling greens, and the indoor sports centre.
70 Sport England have been consulted on the outline application, but at the time of writing this report officers have not received a copy of their representations on the proposal.
Sports pitches
71 The applicant is intending to offset the loss of sports pitches through improvements to local facilities including re-contouring and drainage improvements at Bannister Sports Ground to re-provide the pitches that would be lost a Harrow View west. Officers note, however, that one rugby pitch would be lost as part of this process.
72 The applicant also proposes to improve the quality and carrying capacity of all pitches at Headstone Manor Recreation Ground through drainage improvements and improved changing rooms.
73 Overall the proposal would result in the loss of one rugby pitch which the applicant describes as “unused”, and a net gain of 10.5 hours of playing time at Bannister Sports Centre and 11 hours per week at Headstone Manor Recreation Ground.
74 Whilst the various improvements proposed and associated gain of playing time is supported, the net loss of one rugby pitch raises concern. Whist officers note there currently appears to be a surplus of rugby pitches in Harrow, based on the applicant’s analysis of local sporting facilities, only six dedicated rugby pitches would remain in the borough following proposed reconfiguration.
page 35 75 To ensure accordance with London Plan Policy 3.19 applicant should seek to explore further options for re-provision which would not result in the loss of sports pitches, and respond to representations issued by Sport England.
Other sports facilities
76 The applicant intends to address the loss of indoor sports facilities at Harrow View west through a financial contribution towards an upgrade of facilities and increased capacity at the nearby Harrow Leisure Centre. Officers note that a commercial health and fitness facility would also be provided as part of the proposed redevelopment of Harrow View east. It is also acknowledged that a multi uses games area with full community access would be provided as part of the primary school development.
77 Officers note that the indicative masterplan indicates the provision of a multi uses games area on the Harrow View west plot. The applicant should confirm whether this is indicative, or whether this also represents part of the proposed provision.
78 The applicant is not proposing to replace the existing tennis courts or bowling greens. This is disappointing. It is understood from the applicant’s ‘Sports facilities and open space needs analysis’ report that whilst the tennis courts were of poor quality they enjoyed a degree of usage until their recent closure. With respect to the bowling greens the applicant notes that a 2009 audit assessed the quality of the Harrow View west provision as “high”. It is understood, however, that the bowling greens at Harrow View west have since become disused following the demise of the Kodak Bowling Club.
79 The applicant has broadly demonstrated that the proposed loss of tennis courts and bowling greens on Harrow View west would not lead to local deficiency within the borough on a per capita basis. However, limited details have been provided on the spatial distribution of tennis courts and bowling greens within the borough. The applicant should, therefore, identify the local provision, and quality, of tennis courts and bowling greens within 15 minutes walk from the site.
Sports facilities summary
80 The current proposals would result in the net loss of one rugby pitch, seven tennis courts, two bowling greens and the indoor sports centre at Harrow View east. Various on site facilities, financial contributions, facility upgrades and capacity increases are proposed, in effect, to mitigate this. The applicant should respond to the concerns and queries raised above with respect to sports pitches and other sports facilities, so that officers can assess the scheme fully against London Plan Policy 3.19. In forming an assessment officers will take into account the applicant’s response to representations made by Sport England. Retail
81 London Plan Policy 4.7 seeks to assess need and bring forward capacity for retail, commercial, culture and leisure development within town centres. This policy promotes a town centre first approach to such development, and seeks to firmly resist inappropriate out-of-centre development. Part B of Policy 4.7 sets out strategic principles to be applied when assessing retail and town centre development proposals. In particular, these relate to the appropriate scaling of retail proposals relative to the size, role and function of the town centre, the intention that these uses should be focused in central town centre locations first, and the need for edge or out-of- centre development to provide an assessment of impact.
page 36 Scale of retail development
82 The Harrow Retail Study (2009) forecasts sufficient expenditure growth within the catchment of the borough's town centres to support up to 38,912 sq.m. of net comparison retail floorspace, and 5,261 sq.m. of net convenience retail floorspace, over the period 2009-2025. The emerging ‘Harrow Core Strategy’ broadly identifies a need for a new large food store within the borough, and states that the vast majority of this growth is expected to be accommodated within the Harrow and Wealdstone intensification area. With respect to retail development within the intensification area, the Council intends to use the ‘Harrow and Wealdstone Area Action Plan’ as a vehicle for identifying sites for major retail/mixed-use development.
83 The ‘Harrow Retail Study’ (2009) identifies Wealdstone district centre as having potential to be a focus for helping to meet retail need in the borough, outside Harrow Metropolitan Centre. In response to this the emerging ‘Harrow and Wealdstone Area Action Plan’ identifies an aspiration for a supermarket of between 2,000 and 3,000 sq.m., to provide complementary retail uses close to the centre of Wealdstone. The preferred option draft of the document identifies a favoured site, “Wealdstone multi-storey car park” which is located on George Gange Way, within the boundary of Wealdstone district town centre.
84 As part of the outline masterplan proposals the applicant is proposing a 2,800 sq.m. (net) food store supermarket, four non-food retail units totalling 1,125 sq.m. (gross) and four bar/cafe/ restaurant units totalling 875 sq.m. (gross). London Plan Policy 4.7 states that the scale of retail and commercial development should be related to the size, role and function of a town centre and its catchment. Officers note that Wealdstone is a relatively large district centre which currently provides a limited amount of comparison retailers, a high proportion of small to medium sized convenience retailers, and a number of service uses.
85 Based on the material available, the quantum of retail provision proposed would appear to broadly fit within projected growth forecasts for the borough in strategic terms. However, in assessing the local implications of the retail component the Council will undertake its own assessment.
Town centre first
86 The application site lies outside the boundary of Wealdstone district town centre, and according to PPS4 definitions, should be treated as an out-of-centre location. Therefore, to support a proposal for retail uses the applicant has been required to undertake a sequential assessment of alternative preferential sites (giving appropriate consideration to disaggregation of the retail offer), and to undertake and submit a detailed retail impact assessment. As part of pre- application discussions both authorities have been clear that potential trade diversion from a proposed food store should not adversely impact the localised convenience retail offer of Wealdstone district centre.
Sequential assessment
87 The applicant has undertaken a sequential assessment to analyse the potential for the retail component of the proposal to occur on other more central sites. It is understood that alternative sites for assessment have been identified following engagement with the Council, and officers note that the preferred supermarket location identified by the emerging ‘Harrow and Wealdstone Area Action Plan’ has also been included within the assessment.
88 Having considered thirteen other sites in Harrow and Wealdstone town centres, both within central, and edge of centre locations, the applicant’s assessment concludes that none would provide an opportunity that would be suitable, available and viable. With respect to the preferred
page 37 “Wealdstone multi-storey car park” site, the applicant finds that it is not available and that the form of redevelopment proposed in this case is unlikely to be viable.
Assessment of impact
89 With respect to centre-specific trade impacts, the assessment finds that the proposal would have an impact on trade in existing centres, but that this is likely to be focussed on other large foodstores rather than on a wide range of shops and services. The applicant has calculated that the proposal would draw £5.45 million of trade from Harrow metropolitan town centre, representing a trade diversion of approximately 14.5%. Officers note that £4.84 million of this would be diverted from the town centre Tesco store. With respect to Wealdstone district town centre, the proposal would result in a diversion of £420,000 (5.5%).
90 It is evident that the proposal would result in a material redistribution of trade within the intensification area. Officers note that the absence of a substantial non-food offer within the proposal would mean that shoppers would still visit comparison stores across a range of centres. It is also acknowledged that trade would primarily be drawn from other large supermarkets, however, given the small to medium sized nature of convenience retailers within Wealdstone, the effect of trade diversion from Wealdstone district centre, in particular, will need to be examined in detail by the Council.
91 The Council is advised seek an independent review of the applicant’s retail study to satisfy itself of the rigour of the sequential test and the impact assessment, and to ensure the impact of likely trade diversion would be acceptable in accordance with London Plan Policy 4.7.
Contribution to town centre renewal
92 As discussed previously in paragraph 45, the applicant should seek to demonstrate how the proposed convenience store would contribute towards the renewal of Wealdstone town centre, in accordance with the principles of London Plan Policy 4.4. It is noted that the applicant has identified the contribution that the retail component would make in terms of job creation, and this is supported in principle. However, as discussed at pre-application stage, both the proposed retail component, and Wealdstone town centre, would benefit form closer affiliation delivered through improved pedestrian links.
93 In response to officer requests the applicant has informally provided a study of potential pedestrian improvements that could be delivered on the route between the Harrow View east plot and the town centre and railway station. The measures proposed are broadly supported, and the Council is encouraged to secure a financial contribution towards delivering these improvements by way of planning obligation. Housing
94 The proposal includes the provision of 985 residential dwellings, this is slightly less than the indicative figure of 1,035 presented for the site within the emerging ‘Harrow and Wealdstone Area Action Plan’, however, does not raise an objection in principle. Whilst officers understand the outline planning application does seek to establish a proposed housing mix, balance between market and affordable housing, tenure split within the affordable provision and range of unit sizes, the detail of the housing schedule is currently subject to local negotiation with the council and has yet to be defined.
95 An affordable housing viability statement has, however, been submitted, and this is currently being independently assessed. The GLA would welcome an opportunity to review the progress of housing mix discussions at the earliest opportunity, and the applicant is strongly
page 38 encouraged to present an indicative housing schedule to both the Council and the GLA, to facilitate negotiations.
96 The absence of a housing schedule in support of the application is very disappointing, and it is not currently possible for officers to fully assess the residential component of the scheme.
97 In the developing the housing schedule the applicant is advised that London Plan Policy 3.12 seeks to secure the maximum reasonable amount of affordable housing when negotiating on mixed use schemes. Once a housing schedule has been defined the applicant will be required to demonstrate that the proposed affordable provision represents the maximum reasonable amount that the scheme can deliver to ensure accordance with London Plan Policy 3.12. Officers will determine this through assessment of the applicant’s viability appraisal, and will update the Mayor of the outcome of the assessment, and any associated negotiations, in due course.
98 The applicant is also advised that London Plan Policy 3.11 seeks to ensure that 60% of the affordable housing delivered throughout the Plan period is social rented housing, and that 40% is intermediate provision. The Mayor’s recently published proposals for ‘Early Minor Alteration to the London Plan’ seek to incorporate affordable rented accommodation within the 60% portion of the strategic tenure split identified in Policy 3.11 to help achieve the objectives of this Policy.
Mix of units
99 Whilst a proposed housing schedule has not yet been provided, the applicant has provided an indicative mix for the affordable housing component of the scheme. This is provided below.
Unit type Proportion of affordable housing mix 1 bedroom flat 35% 2 bedroom flat 15% 2 bedroom house 15% 3 bedroom house 33% 4 bedroom house 17%
100 Whilst it is not possible to undertake a full assessment of residential mix, based on the material provided the proposed 42% provision of family sized affordable units would be supported in principle, subject to detailed confirmation of the affordable tenure split.
Residential design standards
101 Policy 3.5 within the London Plan seeks to ensure housing developments are of the highest quality internally, externally, and in relation to their context and to the wider environment. Table 3.3, which supports this policy, sets out minimum space standards for dwellings. The draft ‘Housing’ SPG and ‘London Housing Design Guide’ build on this approach and provide further detailed guidance on key residential design standards, including the need for developments to avoid single aspect dwellings that are north facing, exposed to noise exposure categories C or D, or contain three or more bedrooms.
102 The applicant has stated a commitment within the outline application ‘Design Guidelines’ to ensure that all dwellings would meet London Plan minimum space standards, and that detailed residential design would be informed by the best practice principles of the ‘London Housing Design Guide’. This is supported. The applicant should, however, ensure that concerns raised in the employment section of this report with respect to potential conflicts of uses are addressed to ensure accordance with London Plan Policy 3.5.
page 39 Children’s playspace
103 London Plan Policy 3.6 requires that development proposals that include housing make provision for play and informal recreation, based on the expected child population generated by the scheme and an assessment of future needs. Due to the absence of an identified housing mix it is not currently possible for officers to assess the scheme’s compliance against London Plan Policy 3.6. Once a housing mix is determined the applicant should use the methodology within the Mayor’s supplementary planning guidance ‘Providing for Children and Young People’s Play and Informal Recreation’ to calculate the expected child population of the proposed development. The applicant is advised that this guidance sets a benchmark of 10 sq.m. of useable child playspace to be provided per child, with under-5 child playspace provided on-site. The applicant should ensure these standards are incorporated into the ‘Design Guidelines’.
104 Officers acknowledge that the applicant has undertaken various studies which broadly demonstrate how the scheme would seek to provide play space for various age ranges, along with the spatial distribution and catchment areas of equipped play spaces within the scheme. These initial proposals are supported and the applicant is encouraged to provide innovative play equipment which would incorporate trees and greenery wherever possible, and to seek to exceed the minimum requirements for play through the dual use of the green link and surrounding public realm for informal play.
Density
105 London Plan Policy 3.4 seeks to optimise the housing potential of sites, having regard to local context, design principles and public transport accessibility. This site has a public transport accessibility level (PTAL) ranging from two to four, and officers have classified the setting as sub- urban in character. The London Plan density matrix (Table 3.2) suggests residential densities of between 150 to 250 habitable rooms per hectare within a PTAL of two to three, and 200 to 350 habitable rooms per hectare within a PTAL of four to six.
106 The applicant has undertaken various density studies and detail within the ‘Design and Access Statement’ indicates the applicant is proposing a broad site-wide residential density of 75 habitable rooms per hectare. However, in order to allow officers to assess the proposals against London Plan Policy 3.4 the applicant should provide an indication of the proposed residential density ranges across the site, based on net residential area, rather than site area. Student housing
107 London Plan Policy 3.8 seeks to meet strategic and local requirements for student housing by working closely with stakeholders in higher and further education, and without compromising capacity for conventional homes. Paragraph 3.52 in support of this policy also acknowledges the role that appropriate provision of student housing can play in reducing pressure on other elements of the housing stock, which might otherwise be occupied by students.
108 As part of the outline application the applicant is proposing the provision of 220 units of student housing. Officers understand that this provision would be intended to support University of Westminster, and/or potentially University Collage London. Officers acknowledge that this part of Harrow has relatively good links to the University of Westminster, which has a campus nearby at Northwick Park (in the adjoining borough of Brent) accessible by bus and the Metropolitan Line from Harrow-on-the-Hill. It is also noted that University College London has a campus in Euston, which is readily accessible from Harrow and Wealdstone station.
109 Based on the detail and correspondence provided by the applicant it is apparent that the proposal would be capable of meeting an identified need. However, the student housing proposals
page 40 remain at an early stage, and the applicant does not appear to have established details with respect to the operation or management of the student accommodation (such as whether it would enter into a lease or nominations agreement with a specific institution, or whether the accommodation will be managed by a specialist student housing operator).
110 The applicant is advised that it will need to establish these details in support of any future detailed application to deliver these units. The applicant, and the Council, are advised that the provision of student accommodation should be secured by planning agreement or condition, clearly linking the use of the land, and/or to its occupation, to members of specified educational institutions. If the accommodation is not robustly secured for students, it will be subject to the requirements of affordable housing policy. The strategic preference is for student housing to be affiliated with a specified educational institution. However, in instances where accommodation would serve more than one institution, the GLA would expect the use of the accommodation for students to be secured for approximately 50 weeks of the year by a planning agreement.
111 The GLA also seeks to ensure that 10% of student housing is wheelchair accessible or easily adaptable for wheelchair users, in accordance with the principles of London Plan Policy 3.8. The applicant should incorporate this standard within the ‘Design Guidelines’. Health and social care infrastructure
112 London Plan Policy 3.17 seeks to support the provision of high quality health and social care appropriate for a growing and changing population, particularly in areas of underprovision, or where there are particular needs. Working in tandem with this, London Plan Policy 3.8 part B(e) seeks to ensure that account is taken of the changing age structure of London’s population and, in particular, the varied needs of older Londoners, including for supported and affordable residential provision.
113 As part of the outline application the applicant has proposed senior living accommodation, an assisted living care home and a primary care centre. The applicant has broadly demonstrated that these facilities would respond to local need.
114 The applicant is advised that it will need to establish an operator to provide the necessary care, and to manage accommodation and associated facilities and services. Details in this respect should be submitted in support of any future detailed application to deliver these facilities. The applicant should also expect to demonstrate how this proposal would respond to the requirements of London Plan Policy 3.8, part B(e), with respect to affordable residential provision for older Londoners.
115 The applicant, and the Council, are also advised that past practice has demonstrated that it may sometimes be difficult to categorise assisted living units clearly under the Use Classes Order. Where standalone retirement units are proposed, with independent living or flexible care, the proposed units may appear to straddle the C2 (residential institution including nursing and care homes) and C3 (dwelling houses) use categories.
116 For this reason officers would advise both the applicant, and the Council, that the provision of care and support for these units should be secured by planning agreement or condition, and appropriately reflected within service charges to ensure the care units could be classed as C2 use. If the care accommodation is not robustly secured in this way it will be subject to the requirements of affordable housing policy. The applicant will also need to address part B(e) of London Plan Policy 3.8, as discussed in paragraph 114.
page 41 Education facilities
117 London Plan Policy 3.18 seeks to support the provision of early years, primary and secondary school and further and higher education facilities to meet the demands of a growing and changing population and to enable greater educational choice. London Plan Policy 3.16 supports this approach, and states that proposals which provide high quality social infrastructure will be supported in light of local and strategic needs assessments. Part C of Policy 3.16 states that such facilities should be accessible to all sections of the community (including disabled and older people) and be located within easy reach by walking, cycling and public transport. Wherever possible, the multiple use of these premises is also encouraged.
118 The applicant has proposed a three form entry primary school as part of the outline application which is intended to respond to an identified local need. Officers understand the proposed provision has been worked up in coordination with the Council and would help to address the needs of Wealdstone, as well as those arising as a result of the proposed development. On this basis the proposed provision is broadly supported, the intention to provide community access to the school multi uses games area is also welcomed. Urban design
119 Good design is central to all objectives of the London Plan and is specifically promoted by the policies contained within chapter seven which address both general design principles and specific design issues. London Plan Policy 7.1 sets out a series of overarching design principles for development in London. Other design polices in this chapter and elsewhere in the London Plan include specific design requirements relating to optimising the potential of sites, the quality of new housing provision, tall and large-scale buildings, views and the public realm. New development is also required to have regard to its context, and make a positive contribution to local character within its neighborhood (Policy 7.4).
120 The applicant has maintained a positive and open dialogue with the GLA on urban design matters as the proposed outline masterplan application has come forward. Progress to date has been encouraging and officers welcome the opportunity for continued engagement to address the matters discussed below before the application is returned to the Mayor for final consideration.
Masterplan approach
121 The preferred site layout option within the ‘Harrow and Wealdstone Area Action Plan’ (presented in support of paragraph 18) presents a green link of varying width that cuts an informal diagonal route through the Kodak site, connecting Headstone Drive to Headstone Manor. It is intended to unify both the east and west plots at the site, and to help draw a network of green spaces deeper into the area of intensification. The preferred layout also shows an employment zone as a physical extension (at the same width) of the Waverley estate, with a direct central connection between the two. A transition zone providing a mix of employment space and residential use is also presented, adjacent to the west of the primary employment area, intended to create a coherent and integrated employment zone. The scheme’s response to delivering these key objectives is assessed below.
Green link
122 Discussions surrounding the nature and generosity of the green link have been a key focus of pre-application urban design negotiations. The applicant has responded positively to early comments and officers acknowledge encouraging progress in the development of this component
page 42 of the scheme. Notwithstanding this, officers would welcome the opportunity for further engagement to optimise the proposals.
123 Whilst officers broadly support the general approach proposed, concern is raised that the three metre deviation within block parameters onto the green link, and spatial competition from access routes, both have the potential to significantly erode the provision of true public green space that would be delivered. This risk is particularly acute at the juncture between the east and west plots, leading from Headstone Manor past the proposed school, where the proposed provision of green link is notably less generous than elsewhere in the scheme.
124 To address these concerns the applicant should:
remove the three metre block parameter flexibility onto the green link across the scheme as a whole, or set buildings back from the green link a further three metres to compensate;
set parameters to secure a minimum width of green link, excluding front gardens, of 35 metres on Harrow View west, and 35 metres opposite the school (the applicant should also define parameters for the rest of the green link, ensuring widths of 45 meters would be achieved at the heart of the Harrow View east plot); and,
clearly define the relationship between ‘true’ green width and access/car parking.
125 The applicant is advised that officers expect a generous green link to reach across the western plot towards the school, genuinely drawing the Green Belt through the site. This link must promote unification of the east and west plots and make an essential physical and visual link between the school and the Green Belt in accordance with the principles of London Plan Policy 7.5.
126 To assist officers in assessing the quality of green link as a whole the applicant has agreed to provide indicative cross-sections at various key locations along its length. This is welcomed. Officers will fully assess the proposals against London Plan policies 5.10, 7.5 and 7.18, and the emerging preferred site layout, once this additional material has been provided and the applicant has responded to the matters raised above. Officers will update the Mayor of their assessment accordingly.
Employment layout
127 The applicant has sought to locate the largest of the industrial/employment uses to the west of the site, adjacent to the railway line. This approach is supported as a means of maintaining an employment cluster, and creating a buffer between the railway and some of the more sensitive residential and community uses on the site.
128 With regard to access to Waverley Industrial Estate, officers acknowledge that there are significant changes in levels between the Harrow View east plot and Waverley Industrial Estate, and that the presence of a concrete bunker north of Waverley Industrial Estate also represents a constraint to direct access. However, the applicant should refer to comments made within the employment section of this report and ensure that the newly proposed employment space would operate in conjunction with Waverley Industrial Estate to agglomerate employment activity in this area and support the strategic industrial location designation in accordance with the principles of London Plan policies 2.17 and 7.1.
Access, movement and parking
129 Following a joint review of the submitted design material with the applicant and the Council, the need to provide greater detail with respect to primary and emergency access routes,
page 43 paths and on street car parking has been identified. In particular, officers have requested further details with respect to the relationship between on street car parking, access routes and residential blocks adjacent to the green link. With respect to the stretch of green link at Harrow View west, the applicant stated an intention to review the balance between 'true' green space, car parking, and access links. This is welcomed, and the applicant is encouraged to provide an illustrative study of the revised relationship in this part of the site, and to secure the width of green link as described in paragraph 124.
130 The design review also highlighted the omission of parameters securing north/south access links from the surrounding neighbourhood south of the Harrow View west plot. The applicant has since proposed to introduce two links into this portion of the site as a parameter, with indicative options for further internal links shown thereafter. This approach is supported.
131 It is noted that the applicant’s indicative masterplan layout maintains a frequent rhythm of east-west streets adjacent to Harrow View which officers queried at pre-application stage. The approach was questioned as it appeared to be at odds with the adjacent urban fabric. Having reviewed the parameter plans officers note that only two of these east-west streets have been defined as a parameter of the outline application, meaning there is flexibility to review the response in this portion of the site at the detailed design stage. This is acceptable.
132 With respect to the parameter route connecting Victor Road, the applicant is asked to consider switching the open space/play space arrangement with the proposed residential blocks, to provide improved definition of this route into the site.
133 As discussed at pre-application stage, and in subsequent meetings, the proposed supermarket access over the green link is a somewhat disappointing compromise. Officers note the applicant’s rationale for this, and acknowledge options for a possible diversion of primary supermarket access as future phases would be built out. However, a diversion via Harrow View would represent a considerable detour for customers arriving from the south of the site, and would be likely to be resisted in practice. As a response to this, and other issues, the applicant is invited to consider whether a relocation of the supermarket, west of the green link, could negate the need for it to be traversed by traffic, and simultaneously provide opportunities to create a consolidated employment cluster adjacent to Waverly Industrial Estate.
134 Officers note that the outline application seeks to incorporate a large roundabout and two sections of dual carriage way at Harrow View which benefit from extant planning permission. It is understood the applicant is contractually obliged to build out the approved highway infrastructure through agreement with the landowner of the site. Officers are of the opinion that within the context of the outline masterplan the scale of the roundabout and nature of the highway infrastructure would be detrimental to aspirations to unify the east and west plots of this site, and would present additional challenges in terms of securing safe passage between the proposed school and green space at Headstone Manor.
135 It is understood the specification for the highway infrastructure was defined, in part, to support the operation of Kodak Ltd. as early phases to the south would be built out, but also as a fallback position to allow for an industrial-led redevelopment of the northern portion of the site. Whilst the need to facilitate the ongoing requirements of Kodak Ltd. is acknowledged and supported, the applicant and the landowner are strongly encouraged to delay build out of the approved infrastructure until the outline masterplan application has been determined. Were approval to be granted, the GLA would wish to see the submission of revised highway proposals of a scale capable of supporting Kodak Ltd. (and future employment uses at the site), but more in keeping with the nature and aspirations of the overall masterplan.
page 44 136 The applicant should provide visualisations of this portion of the site, with the highway works as approved, and with an alternative scaled down configuration, demonstrating the relationship between the Harrow View west plot, Harrow View itself, and the school, so officers can assess the likely relationship in terms of environmental quality, pedestrian safety and promotion of inclusive access.
137 The applicant has informally provided a study of potential public realm improvements that could be delivered along Headstone Drive and Ellen Webb Drive, to improve pedestrian links between the site and Wealdstone station and town centre. The interventions presented are supported, and the Council is encouraged to secure a financial contribution towards delivering these improvements by way of planning obligation. Delivery will involve works to third party property, including a railway bridge owned by Network Rail, the applicant and the Council are, therefore, encouraged to engage in early dialogue with all relevant landowners to move these proposals forward as quickly as possible in accordance with the principles of London Plan policies 6.10 and 7.5.
Masterplan blocks
138 In response to pre-application discussions the applicant has provided indicative details of the residential typologies that would be proposed across the site. Residential units are divided into six character zones and a site wide indicative unit layout has been provided. The applicant is encouraged to identify indicative density ranges for each of these areas and to ensure this information is carried forward into the ‘Design Guidelines’ document. The reference to the ‘London Housing Design Guide’, and inclusion of London Plan Policy 3.5 minimum dwelling space standards within the ‘Design Guidance’ document is supported.
139 It is noted that the applicant is seeking an integrated approach to the relationship between employment and residential uses at blocks P, K and C. As discussed at the previous design review meeting, the applicant should provide illustrative details which more clearly define the intended relationship in this regard. The applicant is also encouraged to engage with employment unit designers and operators to inform the masterplan design process.
140 Officers note that the applicant has proposed a residential wrap-around for the northern frontage of the supermarket block. This was welcomed in response to comments made at pre- application stage, seeking to activate this frontage. Officers acknowledge that residential units in this location must be designed carefully given their orientation. The applicant may wish to consider incorporating specific guidance to address the design of this section of the scheme.
Masterplan design guidance
141 The applicant has submitted a set of design guidelines in support of the outline application to define a set of design standards that future detailed applications will follow. This approach is strongly supported.
142 Whist the intention to keep the submitted documentation concise is welcomed, as previously discussed the applicant should seek to augment the ‘Design Guidelines’ with illustrative detail from the ‘Design and Access Statement’ to provide one stand alone document which would present both a design narrative as well as specific parameters, and be taken forward as a single point of reference for future detailed applications. The applicant has indicated it would be content to review and in places update and augment detail within the ‘Design Guidelines’ in response to officers’ request. This is welcomed.
143 Specific areas identified for further development through joint discussion include: access, employment/residential interaction zones, masterplan block resolution, landscaping, car parking,
page 45 masterplan cross-sections and illustrative views. Officers would welcome the opportunity for further informal engagement with the applicant to identify the content required and provide detailed advice. Inclusive access
144 London Plan Policy 7.2 seeks to ensure that future development meets the highest standards of accessibility and inclusion. With respect to residential dwellings, London Plan Policy 3.8, expects 10% of new housing to be wheelchair accessible or easily adaptable for wheelchair users, and 100% of units to meet ‘Lifetime Homes’ standards. Dwellings
145 The applicant has confirmed that ‘Lifetime Homes’ will be used as the standard for the detailed design and construction stages of the proposed development. This is supported. The applicant has also stated that 10% of the housing proposed will be easily adaptable for wheelchair users. Whilst this is supported in principle the applicant is encouraged to ensure that a proportion of dwellings would be wheelchair accessible from the outset. Public realm
146 The design of the landscaping and public realm, including the routes around the site and entrances to buildings, will be crucial to determining how inclusive the detailed components of this development would be to many people. The community buildings, internal courtyards and employment zones must also be designed to ensure full and easy access for all.
147 The applicant’s stated commitment to create a highly permeable and inclusive public realm which can be enjoyed by all people regardless of age or disability is supported. However, officers would welcome a greater resolution of detail with respect to internal routes at the site, and how their relationship with vehicles and cyclists will be managed (refer also to paragraph 183). It is, nevertheless, noted that the proposal intends to respond to the various level changes at the east and west plots by creating a comprehensive site-wide street block strategy that would follow the existing contours of the site. Officers understand that all pedestrian routes would in turn be designed to provide step free access, with gradients ranging from 1:30 to 1:60 along all routes. This approach is supported and the applicant is encouraged to carry this detail forward into the ‘Design Guidelines’.
148 It is noted that as part of the detailed design the applicant will propose the introduction of shared surfaces in various areas. Whilst there is no objection to this in principle, careful attention should be given to the treatment of flush boundaries between roads and pavements (including the use of tactile paving to identify kerb boundaries) to ensure this would not present unnecessary risks to visually impaired people. The applicant is strongly advised to introduce this level of detail within the ‘Design Guidelines’.
149 On the basis of the material provided officers are broadly supportive of the approach to access and inclusion emerging within this outline application, however, the applicant should address the matters raised above to ensure accordance with London Plan Policy 7.2. Sustainable development
150 London Plan climate change policies, set out in Chapter 5, collectively require developments to make the fullest contribution to the mitigation of, and adaptation to, climate change, and to minimise carbon dioxide emissions. London Plan Policy 5.2 sets out an energy hierarchy for assessing applications, London Plan Policy 5.3 ensures future developments meet the highest standards of sustainable design and construction, and London Plan policies 5.9-5.15
page 46 promote and support the most effective climate change adaptation measures including passive thermal regulation, urban greening, and water management.
Energy efficiency standards
151 The energy strategy indicates that a range of passive design features and demand reduction measures are planned to reduce the carbon dioxide emissions of the proposed development. That applicant has stated that detailed information on the planned measures will be included in support of subsequent reserved matters planning applications. However, the applicant should seek to provide further indicative information on the likely measures to be employed as an addendum to the ‘Harrow View Energy Strategy’ in accordance with the principles of London Plan Policy 5.3.
152 In terms of performance under the first stage of the London Plan energy hierarchy, the development is estimated to achieve a reduction of 373 tonnes per annum (8%) in carbon dioxide emissions compared to a 2010 Building Regulations compliant development.
District heating
153 The applicant is proposing to install a site heat network linking all the buildings on the Harrow View east plot and the five blocks of flats on the Harrow View west plot. (The individual houses on the Harrow View west element of the development will be supplied with their own individual heating systems i.e. air source heat pumps). A drawing showing the indicative route of the heat network has been provided and is acceptable.
154 The site heat network will be supplied from a single energy centre, envisaged to be on the ground floor of the multi-storey car park on the Harrow View east plot, located along the eastern boundary of the site. The energy centre is located within phase three of the development, however, the energy strategy states that it will be constructed in 2013 to enable it to supply the earlier phases of the development. This approach is supported. The energy centre would be approximately 936 sq.m. in size, with some space allowance for potential future expansion. This is welcomed. Drawings showing the location and indicative layout of the energy centre have been provided and are acceptable.
155 The applicant has investigated the possibility for the site heat network to serve other heat demands in the vicinity of the development. This is welcomed. There is potential for buildings adjacent to the development to be connected. However, it is acknowledged that the potential for connecting the greater number of buildings, some of which with large heat loads, to the north east of the site is severely constrained by the West Coast main line.
Combined heat and power
156 The applicant is proposing to install a 1.2 MWe gas fired combined heat and power unit (CHP) as the lead heat source for the site heat network, with thermal storage used to smooth demand profiles. The CHP size will be optimised to provide the domestic hot water load, as well as a proportion of the space heating. This is supported in accordance with London Plan Policy 5.6.
157 A reduction in regulated carbon dioxide emissions of 2,429 tonnes per annum is envisaged to be achieved under the second part of the London Plan energy hierarchy.
page 47 Renewable energy
158 The applicant has investigated the feasibility of a range of renewable energy technologies and identified photovoltaic panels (PV) as a technology which could achieve additional carbon dioxide reductions for the development. The applicant should, however, confirm that PV would be used, and provide details of the amount of PV proposed, and the associated carbon dioxide savings, in accordance with the principles of London Plan Policy 5.7.
Overall carbon dioxide savings
159 The estimated carbon emissions of the development are 1,819 tonnes of carbon dioxide per year after the cumulative effect of energy efficiency measures, CHP and renewable energy has been taken into account.
160 This equates to a reduction of 2,802 tonnes of carbon dioxide per year in emissions compared to a 2010 Building Regulations compliant development, equivalent to an overall saving of 60%.
161 The carbon dioxide savings proposed would exceed the minimum targets set within Policy 5.2 of the London Plan. This is supported.
Urban greening
162 London Plan Policy 5.10 seeks to promote and support urban greening, such as new planting in the public realm (including streets, squares and plazas) and multifunctional green infrastructure, to contribute to the adaptation to, and reduction of, the effects of climate change. In addition, London Plan Policy 5.11 requires major development proposals to be designed to include roof, wall and site planting, especially green roofs and walls, where feasible.
163 The applicant’s aspiration of providing a landscaped green link running through the heart of the development is strongly supported in accordance with London Plan Policy 5.10, nevertheless, the applicant should have regard to comments made with respect to the green link in the urban design section of this report.
164 The applicant has started to investigate the potential for the inclusion of green roofs within the scheme, however, at present there is no firm commitment to include them. The applicant is strongly encouraged to develop a roof strategy for inclusion within the ‘Design Guidelines’ that would optimise the relationship between green roofs and the provision of photovoltaic panels.
Sustainable urban drainage
165 London Plan Policy 5.13 seeks to ensure that development utilises sustainable urban drainage systems unless there are practical reasons for not doing so. Proposals should aim to achieve greenfield run-off rates, and ensure that surface water run-off is managed as close to its source as possible in line with the London Plan drainage hierarchy.
166 The applicant has developed a conceptual sustainable urban drainage systems (SUDS) drainage strategy to support the outline application. The drainage strategy seeks to ensure that all properties within the development would be protected from flooding in a sustainable manner, through the provision of appropriate on-site attenuation facilities and SUDS techniques, including swales, ponds, attenuation tanks and permeable paving. The indicative proposals are broadly supported, and subject to Environment Agency advice, should be secured by planning condition. However, the applicant is encouraged to consider the benefits that green roofs could offer in the attenuation of rainwater, particularly within the employment zones.
page 48
Ambient noise
167 London Plan Policy 7.15 seeks to minimise the existing and potential adverse impacts of noise on, from, within, or in the vicinity of, development proposals. The applicant has submitted an ‘Environmental Statement’ which addresses the noise and vibration impacts associated with the proposed development.
168 The site is surrounded by noise sources including busy roads, a busy train line and existing industrial sources, including air conditioning units.
169 Officers note that the noise and vibration surveys have either used, or designed the use of, the worst case scenario, including the addition of a tonal penalty for noise of an industrial nature. This approach is supported.
170 The assessment and accompanying appendix presents data in a clear manner. However, officers are of the opinion that ‘Table 7.6’ (which provides a summary of the long term measured noise levels), presents a number of results that have not been fully discussed in the report.
171 Officers would welcome the opportunity to discuss detailed queries with respect to ‘Table 7.6’ with the applicant to obtain clarification before making a final assessment of the outline application against London Plan Policy 7.15.
Air quality
172 London Plan Policy 7.14 seeks to ensure that development proposals minimise increased exposure to existing poor air quality and make provision to address local problems of air quality, particularly within air quality management areas and where the development is likely to be used by large numbers of those particularly vulnerable to poor air quality, such as children or older people. Development proposals should be at least air quality neutral, and not lead to further deterioration of existing poor air quality.
173 The site is located within an air quality management area and the applicant has submitted an ‘Environmental Statement’ which addresses the air quality issues associated with the proposed development.
174 The applicant’s assessment suggests that the proposed development would broadly comply with the Mayor’s policies to reduce the impact of new development on emissions of air pollutants. This is supported in principle, however, officers have a number of detailed queries with respect to the use of 2005 as a baseline, and concentrations of emissions, which need to be addressed before a final assessment is made against London Plan Policy 7.14. Officers would welcome the opportunity to discuss these queries with the applicant. Transport
Trip generation and highway impact
175 Whilst TfL is satisfied that, on its own, the proposed development will not result in any significant additional congestion on the Transport for London Road Network, it is important that any localised traffic impact is identified and mitigated, particularly in the interests of smoothing
page 49 traffic flow at junctions where there are known issues of congestion. To assist this, and given that operations at the existing Kodak site have declined gradually over a long period of time, TfL expects the applicant to prepare a sensitivity test for its traffic assessment using a different, more recent, base year/operation from that originally submitted (2005). This will allow TfL and the Council to appreciate more accurately the scale of impact and determine appropriate levels of mitigation on the highway network. TfL is engaged in discussions with the applicant in this regard in accordance with the principles of London Plan Policy 6.3.
Parking
176 Ranges of parking standards are proposed for the various non-residential uses. Whilst the principle of applying for a maximum level/standard for non-residential uses is accepted given the outline nature of the application, it is unclear how many parking spaces will actually be provided across the whole development. For the residential element, an overall ratio of just under one space per unit across the site is proposed, although details of the exact management and allocation of these spaces has not been provided.
177 London Plan Policy 6.13 seeks to ensure that an appropriate balance is struck between promoting new development and preventing excessive car use. Accordingly, TfL expects the applicant to prepare a stand-alone parking strategy to clarify and justify its proposals further. The strategy should identify the maximum parking levels by use-class and unit size in the completed phase and explain how these spaces will be allocated and managed. This will be a more appropriate basis for negotiation than the current parking chapter in the transport assessment, and should also form the basis of a future Car Parking Management Plan, into which TfL expects to provide input.
178 Whilst reference has been made to the minimum standards required by the London Plan for electric vehicles, disabled parking provision and cycle parking, details with respect to the precise quantum and location of these facilities has not been indicated. TfL therefore expects a condition to be attached to the outline permission to ensure that subsequent detailed applications would meeting the standards contained in the London Plan, in accordance with London Plan Policy 6.13.
London Buses
179 TfL considers that additional demand from this development will mean that the bus services close to the site will be over capacity. TfL therefore requests contributions equivalent to the cost of providing an extra journey in the schedule (£90,000 per year) over a 5 year period. A total contribution of £450,000 should therefore be secured from the proposed development in line with London Plan Policy 6.1. TfL also requests a contribution of £22,000 to be secured towards provision of real-time information boards.
180 TfL understands that the two bus stops on Harrow View may be relocated, should the enabling site access roundabout (agreed under a separate planning permission and renewed in 2011) be implemented. TfL London Buses must be consulted prior to any relocation to ensure that the bus stops continue to operate safely. Given the reliance placed on these bus stops by the proposed development, and in order to encourage sustainable trips to and from the development site by bus in line with London Plan Policy 6.7, a contribution of £20,000 should be secured from the proposed development towards their upgrade in line with TfL’s ‘Accessible Bus Stop Design Guidelines’.
Harrow-on-the-Hill Station and Harrow Bus Station
181 TfL is satisfied that the likely number of London Underground trips associated with the proposed development can be accommodated at all nearby Underground stations. Notwithstanding this, Harrow-on-the-Hill station and the surrounding public realm would benefit from improvement
page 50 through developer contributions, including providing step-free access, as would Harrow Bus station. TfL wishes to see these aspects of the Harrow-on-the-Hill interchange improved and supports the Council’s aspirations, as set out in its emerging ‘Harrow and Wealdstone Area Action Plan’ in this respect.
182 Considering the benefits these improvements at the interchange could bring to enhancing accessibility to the proposed development and the intensification area more generally, TfL encourages the Council to pool developer contributions from this and other developments towards improving the environmental quality, physical accessibility, capacity and user safety of Harrow-on- the-Hill station and Harrow Bus Station. This would ensure consistency with London Plan Policy 6.1 and the objectives of emerging local policy.
Walking and Cycling
183 Whilst the ‘Design Guidelines’ submitted by the applicant provide some indication of the primary and secondary routes across the site, any insight into how people will move and navigate around the scheme is absent. Considering the size of the site and the scale of the proposed development, TfL expects greater detail of these routes to be provided to show how different users might move around the site to access various services and facilities. A commentary should also be provided as to how the possible conflict between on-street parking spaces and pedestrians and cyclist will be managed, and how other barriers to movement for people with reduced mobility, children and the elderly might be overcome. As the development will include a new primary school, a commitment should be made to ensure that walking routes to the school building are safe, secure, well lit and accessible.
184 Whilst TfL agrees that the surrounding walking routes are of an ‘average-good’ condition, the PERS audit identifies a number of aesthetic and environmental shortcomings and the ‘Transport Assessment’ should explain how these might be overcome. A contribution towards improving the surrounding pedestrian realm, as identified in the PERS audit, should be secured based on these conclusions in accordance with London Plan Policy 6.10.
185 A wayfinding strategy should be implemented across the site, to allow easy navigation of routes between the site, Harrow and Wealdstone town centres, and nearby public transport nodes. TfL’s Legible London scheme should be used in this respect, and the applicant should demonstrate how this could be implemented across the site. A pair of signs cost around £15,000, therefore, an appropriate financial commitment towards this should be secured through the section 106 legal agreement in accordance with London Plan Policy 6.10.
Travel Planning
186 The applicant has submitted a Framework Travel Plan for TfL’s consideration, which is welcomed in line with London Plan Policy 6.1. This is not, however, in line with TfL’s travel plan guidance as it does not contain any preliminary mode share targets. Such targets must be included to provide an effective framework under which individual full travel plans may be developed as the site is built-out. A commitment should also be made to periodically review the plans.
187 Whilst the principle of securing a construction logistics plan through condition is agreed, information on the likely content, methodology and targets for such a plan are absent from the applicant’s ‘Transport Assessment’. TfL expects further information to be provided in this regard, although it is satisfied that this may be agreed with the Council due to the site’s distance from the Transport for London Road Network. TfL requests that further information is provided on suitable targets for delivery and servicing trips and how these might be managed, making reference to possible incentives to encourage off-peak journeys. A delivery and servicing plan should be secured by condition in accordance with London Plan Policy 6.14.
page 51 Community Infrastructure Levy
188 In accordance with London Plan Policy 8.3, the Mayor of London proposes to introduce a London-wide Community Infrastructure Levy (CIL) that will be paid by most new development in Greater London. Following consultation on both a Preliminary Draft, and then a Draft Charging Schedule, the Mayor has formally submitted the charging schedule and supporting evidence to the examiner in advance of an examination in public. Subject to the legal process, the Mayor intends to start charging on 1 April 2012. Any development that receives planning permission after that date will have to pay, including:
Cases where a planning application was submitted before 1 April 2012, but not approved by then. Cases where a borough makes a resolution to grant planning permission before 1 April 2012 but does not formally issue the decision notice until after that date (to allow a section 106 agreement to be signed or referral to the Secretary of State or the Mayor, for example).
189 The Mayor intends to arrange boroughs into three charging bands, with a rate of £35 per square metre of net increase in floorspace proposed for Harrow. More details are available via the GLA website: www.london.gov.uk. Local planning authority’s position
190 Harrow Council is expected to formally consider the application at planning committee in March/April 2012. Legal considerations
191 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, or issue a direction under Article 7 of the Order that he is to act as the local planning authority for the purpose of determining the application and any connected 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
192 There are no financial considerations at this stage. Conclusion
193 London Plan policies on employment, open land, retail, housing, student housing, health and social care, education facilities, 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, for the following reasons:
page 52 Employment: The proposed mixed use redevelopment of strategic industrial land raises an objection in principle with respect to London Plan Policy 2.17, other associated issues are raised with respect to fragmentation and potential for conflicts of use.
Open land: Clarifications, potential revisions and commitments are sought with respect to reconfiguration of open space, sports pitches and other sports facilities to ensure accordance with London Plan policies 3.19 and 7.18.
Retail: An independent review of the submitted retail study is sought to ensure accordance with London Plan Policy 4.7.
Housing: A proposed housing schedule has not been provided. On this basis it has not been demonstrated that the outline application would accord with London Plan policies 3.4, 3.5, 3.6, 3.11 and 3.12.
Student housing: Broadly supported, however, commitments are sought and informatives are provided to ensure accordance with London Plan Policy 3.8.
Health and social care: Broadly supported, however, informatives are provided to ensure accordance of future detailed applications with London Plan policies 3.8 and 3.17.
Education facilities: Broadly supported in accordance with London Plan Policy 3.18.
Urban design: Revisions and commitments are sought with respect to green link, employment layout, access, movement and parking, masterplan blocks and masterplan design guidance to ensure accordance with London Plan policies 2.17, 5.10, 6.10, 7.1, 7.5 and 7.18.
Inclusive access: Clarifications and commitments are sought with respect to dwellings and public realm to ensure accordance with London Plan policies 3.8 and 7.2.
Sustainable development: Clarifications and commitments are sought with respect to renewable energy, urban greening, sustainable urban drainage, ambient noise and air quality, to ensure accordance with London Plan policies 5.7, 5.11, 5.13, 7.14 and 7.15.
Transport: Clarifications and commitments are sought with respect to trip generation and highway impact, parking, London Buses, Harrow-on-the-Hill station and Harrow Bus Station, walking and cycling and travel planning to ensure accordance with London Plan policies 6.1, 6.3, 6.7, 6.10, 6.13 and 6.14. An informative is provided with respect to the Mayoral Community Infrastructure Levy in accordance with London Plan Policy 8.3.
194 On balance, the application does not comply with the London Plan.
195 The following changes might, however, remedy the above-mentioned deficiencies, and could lead to the application becoming compliant with the London Plan:
Employment: The applicant should address the concerns raised in the employment section of this report in an effort to overcome the in principle objection raised with respect to London Plan Policy 2.17.
Open land: The applicant should address concerns raised with respect to reconfiguration of open space, sports pitches and other sports facilities to ensure accordance with London Plan policies 3.19 and 7.18
page 53 Retail: The submitted retail study should be fully assessed at the local level to ensure accordance with London Plan Policy 4.7.
Housing: A proposed housing schedule, including detail of affordable housing provision, should be provided so the outline application may be assessed against London Plan policies 3.4, 3.5, 3.6, 3.11 and 3.12.
Student housing: The applicant should respond to the matters raised in the student housing section of this report to ensure accordance with London Plan Policy 3.8.
Health and social care: The applicant should have regard to the informatives raised with respect to London Plan policies 3.8 and 3.17.
Urban design: The applicant should address concerns with respect to green link, employment layout, access, movement and parking, masterplan blocks and masterplan design guidance to ensure accordance with London Plan policies 2.17, 5.10, 6.10, 7.1, 7.5 and 7.18.
Inclusive access: The applicant should respond to the matters raised with respect to dwellings and public realm to ensure accordance with London Plan policies 3.8 and 7.2.
Sustainable development: The applicant should address the matters raised with respect to renewable energy, urban greening, sustainable urban drainage, ambient noise and air quality, to ensure accordance with London Plan policies 5.7, 5.11, 5.13, 7.14 and 7.15.
Transport: The applicant should address the matters raised with respect to trip generation and highway impact, parking, London Buses, Harrow-on-the-Hill station and Harrow Bus Station, walking and cycling and travel planning, to ensure accordance with London Plan policies 6.1, 6.3, 6.7, 6.10, 6.13 and 6.14. The applicant should also have regard to the informative provided with respect to the Mayoral Community Infrastructure Levy, in accordance with London Plan Policy 8.3.
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] Graham Clements, Strategic Planner (Case Officer) 020 7983 4265 email [email protected]
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