planning report GLA/4572/01 9 April 2018 St John’s School, Northwood in the London Borough of Hillingdon planning application no.10795/APP/2018/149

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

The proposal Demolition of the existing sports hall and construction of a replacement sports hall.

The applicant The applicant is St John’s School and the architect is Clague Architects.

Strategic issues summary: Principle of development: The application results in partial loss of Green Belt and playing fields, and harms the openness of the Green Belt. Therefore, it is inappropriate development. The very special circumstances, which include educational facilities need, community use benefits, lack of alternative sites, and size and scale dictated by Sport England standards, minimising impacts of the proposed building, use of previously developed land; do not clearly outweigh the loss and harm caused to the Green Belt and playing fields. The proposal is not supported in principle and does not fully comply with London Plan and draft London Plan policies (paragraphs 13 to 18). Sports facilities and community use: The proposed community access to the sports hall is welcomed. A detailed community use agreement for affordable and accessible usage of the sports and school facilities must be secured by way of a s106 planning agreement (paragraphs 19 and 20). Urban and inclusive design: The Council must secure key details of materials to be used to ensure the best possible build quality is delivered in the context of the Green Belt setting. The applicant must reinstate significant amount of hardstanding to green open space, to compensate for the proposed incursion. The approach to inclusive design is supported and must be secured by condition (paragraphs 21 to 23). Climate change: The carbon dioxide savings fall significantly below London Plan targets. The applicant should achieve further carbon reductions. A drainage strategy that accords with policies of the London Plan and draft London Plan must be secured by condition (paragraphs 24 to 26). Transport: Submission of a construction logistics plan that accords with the London Plan and draft London Plan must be secured through appropriate planning condition (paragraphs 27 and 28).

Recommendation That Hillingdon Council be advised that the application does not fully comply with the London Plan and draft London Plan, for the reasons set out in paragraph 32 of this report; but that the possible remedies set out in that paragraph could address these deficiencies. The application does not need to be referred back to the Mayor if the Council resolves to refuse permission, but it must be referred back if the Council resolves to grant permission.

page 1 Context

1 On 7 February 2018, the Mayor of London received documents from Hillingdon Council notifying him of a planning application of potential strategic importance to develop the above site for the above uses. Under the provisions of The Town & Country Planning (Mayor of London) Order 2008 the Mayor must provide the Council with a statement setting out whether he considers that the application complies with the London Plan and draft London Plan, and his reasons for taking that view. The Mayor may also provide other comments. This report sets out information for the Mayor’s use in deciding what decision to make.

2 The application is referable under the following Categories of the Schedule to the Order 2008:

 Category 3D: “Development – (a) on land allocated as Green Belt or Metropolitan Open Land in the development plan, in proposals for such a plan, or in proposals for the alteration or replacement of such a plan; and (b) which would involve the construction of a building with a floor space of more than 1,000 square metres or a material change in the use of such building.”

 Category 3C: “Development which is likely to prejudice the use as a playing field of more than 2 hectares of land which—(a) is used as a playing field at the time the relevant application for planning permission is made; or (b) has at any time in the five years before the making of the application been used as a playing field.”

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

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

5 The application site is located in Hillingdon at the north-western edge of Greater London and forms part of a larger school site that adjoins the London Borough of Harrow to its east and Three Rivers District Council in Hertfordshire to its north. The school’s existing buildings and sports hall are located within a larger area of Green Belt, and as set out below, would constitute previously developed land as defined by the Government’s National Planning Policy Framework (NPPF). The total school site extends to some 12.44 hectares and contains a cluster of centrally located buildings including a two-storey former house dating from the 1920’s and more recent single and two storey purpose built buildings – one of which is the school’s sports hall which the school is looking to replace with a larger facility. The wider school site includes grass playing fields, an artificial sports pitch and two areas of woodland designated as Nature Conservation Sites of Borough Grade II or Local Importance. The site also slopes up from south to north, from 90 – 95m AOD towards Hillside Road, to 125m at the northern extreme. Details of the proposal

6 The detailed planning application comprises demolition of the existing single storey sports hall and the construction of a 2-storey sports hall as illustrated below.

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Existing and proposed sports hall impact on openness: Source – applicant’s visual assessment document.

Dimensions of Sports Hall & ancillary Footprint Floorspace Height accommodation (sqm) (sqm) (metres)

Proposed 955 1,127 7.5

Existing 347 347 6.0

Difference +608 (175%) +780 (225%) +1.5 (25%)

7 The new facility would provide the school with a double height multi-functional sports space containing 3 badminton courts and the following ancillary accommodation:

 2 changing rooms with showers and WC’s (DDA compliant).  Sports storage.  First aid room.  Staff office and an additional changing room.  Meeting room.  Kitchenette/servery, and;  2 school club spaces.

8 The number of pupils at the school is limited by planning condition to 350 and the number of staff to 65 full-time equivalents. The application does not seek to alter either of these caps. Case history

9 The planning history reveals that the existing sports hall building was constructed in 1986, under the planning permission ‘for erection of gymnasium and changing facilities (existing greenhouse and storage shed to be demolished)’, (LPA ref:10795/T/85/0747). Strategic planning issues and relevant policies and guidance

10 For the purposes of Section 38(6) of the Planning and Compulsory Purchase Act 2004, the development plan in force for the area is the 2012 Hillingdon Local Plan: Part 1-Strategic Policies, and the Part 2-Saved policies of the Unitary Development Plan (2012), and the 2016 London Plan.

page 3 11 The following are also relevant material considerations:  The National Planning Policy Framework;  The draft National Planning Policy Framework;  National Planning Practice Guidance;  Draft London Plan (December 2017);  Hillingdon emerging Local Plan: Part 2-Development Management Policies, and Site Allocations and Designations, and Policies Map; 12 The relevant issues and corresponding policies are as follows:  Education London Plan; Social Infrastructure SPG;  Green Belt London Plan;  Playing fields London Plan;  Community use London Plan;  Urban design London Plan;  Access London Plan; Accessible London: achieving an inclusive environment;  Sustainable development London Plan; Sustainable Design and Construction SPG; Mayor’s Climate Change Adaptation Strategy; Mayor’s Climate Change Mitigation and Energy Strategy; Mayor’s Water Strategy;  Transport London Plan; the draft Mayor’s Transport Strategy;

Principle of development – education facility/sports hall and Green Belt

13 The application seeks to replace the school’s existing single storey sports hall with a new two-storey (28m x 18m x 7.5m high) multi-use sports hall. The applicant has held pre-application discussions with Sport England which has indicated that the proposal could meet Sport England’s Exception Policy E5, and confirmed that: ‘The proposed development is for an indoor or outdoor sports facility, the provision of which would be of sufficient benefit to the development of sport as to outweigh the detriment caused by the loss of the playing field or playing fields.’

14 The National Planning Policy Framework and Government Policy Statement on Planning for Schools Development (2011) emphasise that great importance should be attached to the delivery of a sufficient choice of school places to meet the needs of existing and new communities. Draft London Plan Policy S3 and London Plan Policy 3.18 confirm that the Mayor strongly supports the provision of new schools in response to identified local need. These policies also encourage the shared use of services between schools, colleges, universities, sports providers, and community facilities and policy 3.19 of the London Plan sets out that proposals that increase or enhance the provision of sports and recreation facilities will be supported.

Loss of Green Belt 15 Policy 7.16 of the London Plan, Policy G2 of the draft London Plan, and the NPPF stress that the strongest protection should be given to Green Belt and that inappropriate development should be refused, except in very special circumstances. The proposed development is inappropriate and would result in a Green Belt and open space encroachment of 608 square metres as illustrated below. Accordingly, the benefits of the development must clearly outweigh the harm it would cause to the Green Belt in both principle and practice for the application to be acceptable.

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The wider area of the School and the redline boundary: Source – applicant’s design and access statement. Very special circumstances 16 The applicant has acknowledged that the new sports facility would be inappropriate development and has put forward the following very special circumstances case to support its proposals. GLA officer commentary on the applicant’s case is provided against each point as follows:  Need for the accommodation: The applicant contends that its current facility (a single 1986 gymnasium building) is too small to meet all of the School’s current curricular needs including the increasing importance of physical fitness in education, and that the existing facility does not meet modern standards. It has also confirmed that its proposals have been designed to allow additional non-sporting uses such as live drama performances and musical recitals. The school’s need for new indoor sports facilities is accepted by GLA officers and the multi-use nature of the new facility is welcomed.  Community use: The applicant has confirmed that it would make the new facility available for community use (particularly to local primary schools). This is welcomed and accords with London Plan and draft London Plan policy.  Alternative solutions: The applicant has looked at alternative locations within the site and satisfactorily demonstrated that none are suitable or would cause more harm to the Green Belt than the existing site it has chosen. This is accepted.  Size and scale: The applicant has confirmed that the size of the proposed sports hall primarily derives from its need to provide three badminton courts and is based on Sport England standards in ‘Sports Hall Design and Standards’. This is accepted.  Minimising impacts: The applicant contends that the amount of accommodation it is proposing is the least it needs to meet its sporting and educational needs and takes account of published standards. It has also orientated the building to minimise its impact and is proposing a curvilinear roof, visually softer textures, and appropriately coloured and high-quality landscaping to minimise the overall impact of the building on the Green Belt. This is noted and accepted.  Previously-developed land: The applicant argues that it has designed the new sports hall to use previously-developed land as far as possible. This is noted and accepted, however, the applicant should change an existing area of previously developed hard standing to green open space to compensate for the proposed incursion. Conclusion 17 The application results in partial loss of Green Belt and playing fields, and harms the openness of the Green Belt. Therefore, it is inappropriate development. Whilst the applicant has set out very special circumstances, which include educational facilities need, community use benefits, lack of alternative sites, size and scale dictated by Sport England standards, minimising impacts of the proposed building, and use of previously developed land; these do not clearly outweigh the loss and harm caused to the Green Belt and the playing fields.

page 5 18 GLA officers therefore conclude that the applicant must provide a significant and compensatory reduction in hard standing to mitigate the harm caused to Green Belt in terms of footprint, which equates to an area of 608 square metres. As it stands, the proposal is not acceptable and does not fully comply with the relevant policies of London Plan and draft London Plan, and the NPPF. Community use 19 Policies 3.18 and 3.19 of the London Plan and Policy S3 and S5 of the draft London Plan expect community use of education and sports facilities to be maximised. The design of the new sports hall and its facilities would achieve this, for example by creating zones where community use can be easily provided while ensuring that access to other parts of the school can be easily segregated. 20 St John’s already provides opportunities for local primary schools who use their external sports facilities for an annual rugby festival, cricket tournament and cross-country event. The current application proposes public use of the improved sports facilities including the new indoor sports hall. The exact details of the community use agreement would come forward prior to approval, and secured by way of a S106 planning agreement. This must include arrangements for the affordable and accessible usage of the sports facilities in consultation with Sport England. Further active engagement with Sport England, local schools and sports communities, is recommended to ensure that the community use agreement meets expected demands. Urban design 21 The design of the new sports hall demonstrates that careful consideration has been given to the layout, design and shape of the building to ensure that encroachment into the Green Belt and playing field to the north, and impact on openness is minimised. The change in ground levels across the site reduces the visual impact of the building when viewed from the north and with the curvilinear roof and proposed landscaping, the building will effectively appear to sit within the landscape. Care has also been taken to also ensure that the building does not appear as overly dominant when viewed from the south, where ground levels are much lower. However, the Council must secure key details of materials to be used to ensure the best possible build quality is delivered in the context of the Green Belt setting. The applicant must consider re-instating significant amount of hardstanding areas to green open space, to compensate for the proposed incursion. 22 Fire safety: In accordance with Policy D11 of the draft London Plan, the Council should secure an Informative requiring the submission of a fire statement, produced by a third party suitable qualified assessor and agreed with the London Fire Brigade. Inclusive design 23 Policy 7.2 of the London Plan and Policy D3 ‘Inclusive design’ of the draft London Plan seek to ensure that proposals achieve the highest standards of accessible and inclusive design (not just the minimum). The proposed new sports facilities will offer a fully inclusive access and sports programme to all users. The approach to inclusive design is supported and must be secured. Climate change Energy 24 In accordance with the principles of London Plan Policy 5.2 and Policy SI2 of the draft London Plan, the applicant has submitted an energy statement, setting out how the development proposes to reduce carbon dioxide emissions. An on-site reduction of 3.1 tonnes of CO2 per year in regulated emissions compared to a 2013 Building Regulations compliant development is expected for the proposed non-domestic buildings, equivalent to an overall saving of 8.1%. The carbon dioxide savings fall significantly below the target set out within Policy 5.2 of the London Plan and Policy SI2 of the draft London Plan.

page 6 25 The applicant must therefore consider the scope for additional measures aimed at achieving further carbon reductions. In addition, all other outstanding technical issues regarding overheating and cooling, centralised boiler-led hot water system, BRUKL sheets and photovoltaic panels should be addressed before full compliance with the energy policies of the draft London Plan and London Plan can be verified. Full details of the issues have been provided directly to the applicant and Council.

Flood risk and drainage

26 The site lies within Flood Zone 1 and is not at risk of flooding. The local topography confirms overland water flows away from the site. The site is at risk from reservoir flooding although the likelihood of such an incident to occur is very low. Attenuation will be provided to reduce the run-off rates from the site. Surface water run-off will be attenuated to 3.47 l/s for the 1 in 100 plus 40% climate change storm event, through the use of permeable pavement and below ground cellular storage. A storage volume of 58 cubic metres is proposed to achieve this. Furthermore, a small green roof will be provided. As such, appropriately worded conditions in relation to flooding and sustainable drainage measures will be necessary to ensure compliance with Policies 5.12 and 5.13 of the London Plan and Policies SI12 and SI13 of the draft London Plan. Transport

27 The application site is within the Campus of St John’s School, accessed off Potter Street Hill. There is no increase of pupil numbers at the school as a result of the development, rather an improving the current facilities. Therefore, after considering the scale, nature and location of the application, TfL does not consider the proposal would give rise to strategy highway and transport concerns as there is no material change to the vehicle, pedestrian and cycle access to the site.

28 A construction logistics plan, as referred to in London Plan Policy 6.3, which identifies efficiency and sustainability measures should be submitted and secured via appropriate planning conditions/ obligations. Local planning authority’s position

29 Currently, the Council’s planning officers are assessing the scheme, and have indicated that they may recommend approval to their planning committee meeting in May 2018, provided the applicant demonstrates that it has fully taken on board their pre-application meeting advice. Legal considerations

30 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 draft London Plan, and his reasons for taking that view. Unless notified otherwise by the Mayor, the Council must consult the Mayor again under Article 5 of the Order if it subsequently resolves to make a draft decision on the application, in order that the Mayor may decide whether to allow the draft decision to proceed unchanged or direct the Council under Article 6 of the Order to refuse the application. There is no obligation at this present stage for the Mayor to indicate his intentions regarding a possible direction, and no such decision should be inferred from the Mayor’s statement and comments. Financial considerations

31 There are no financial considerations at this stage.

page 7 Conclusion

32 London Plan and draft London Plan policies on education, Green Belt and playing fields, sports facilities and community use, urban and inclusive design, climate change and transport are relevant to this planning application. The application does not fully comply with the London Plan and draft London Plan; the following matters should be addressed:

 Principle of development: The application results in partial loss of Green Belt and playing fields, and harms the openness of the Green Belt. Therefore, it is inappropriate development. Whilst the applicant has set out very special circumstances, which include educational facilities need, community use benefits, lack of alternative sites, size and scale dictated by Sport England standards, minimising impacts of the proposed building, and use of previously developed land; these do not clearly outweigh the loss and harm caused to the Green Belt and the playing fields. The proposal is not supported in principle and does not fully comply with the London Plan and draft London Plan policies, and the NPPF. The applicant must reinstate a significant and compensatory reduction in hard standing to mitigate the harm caused to Green Belt and playing fields in terms of footprint, which equates to an area of 608 square metres.

 Sports facilities and community use: The proposed community use to the sports hall is welcomed. A detailed community use agreement for affordable and accessible usage of the sports and school facilities must be secured by way of a S106 planning agreement.

 Urban and inclusive design: The Council must secure key details of materials to be used to ensure the best possible build quality is delivered in the context of the Green Belt setting. The applicant must reinstate significant amount of hardstanding to green open space, to compensate for the proposed incursion. The approach to inclusive design is supported and must be secured by condition.

 Climate change: The carbon dioxide savings fall significantly below the target set out within Policy 5.2 of the London Plan and Policy SI2 of the draft London Plan. The applicant must consider the scope for additional measures aimed at achieving further carbon reductions. In addition, all other outstanding technical issues must be addressed. A drainage strategy that accords with policies of the London Plan and draft London Plan must be secured by condition.

 Transport: Submission of a construction logistics plan that accords with the London Plan and draft London Plan must be secured through an appropriate planning condition.

For further information contact the GLA Planning Team: Juliemma McLoughlin, Chief Planner 020 7983 4271 email: [email protected] Tefera Tibebe, Case Officer 020 7983 4312 email: [email protected]

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