planning report PDU/2995/01 6 March 2013 Swakeleys House, Ickenham

in the London Borough of Hillingdon planning application no. 23202/APP/2013/12

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 Change of use of Swakeleys House, (a Grade I listed building), from office (B1) use and sports (D2) use into a single dwelling, along with demolition and replacement of ancillary outbuildings buildings (Vyners House and the Ice House) into ancillary accommodation for Swakeleys House. The applicant The applicant is CES Properties (Ickenham) Ltd and the architect is Paul Davis & Partners.

Strategic issues The key strategic issues for consideration are Green Belt and heritage, other minor issues relating to affordable housing, inclusive design and transport require resolution.

Recommendation

That Hillingdon Council be advised that while the application is generally acceptable in strategic planning terms the application does not comply with the London Plan, for the reasons set out in paragraph 49 of this report; but that the possible remedies also set out in this paragraph of this report could address these deficiencies.

Context

1 On 25 January 2013 the Mayor of London received documents from Hillingdon Council notifying him of a planning application of potential strategic importance to develop the above site for the above uses. Under the provisions of The Town & Country Planning (Mayor of London) Order 2008 the Mayor has until 7 March 2013 to provide the Council with a statement setting out whether he considers that the application complies with the London Plan, and his reasons for taking that view. The Mayor may also provide other comments. This report sets out information for the Mayor’s use in deciding what decision to make.

2 The application is referable under Category 3D of the Schedule to the Order 2008:

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

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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; take it over for his own determination; or allow the Council to determine it itself.

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

Swakeleys House and adjacent buildings (aerial view)

5 Swakeleys House is situated in Ickenham in the northern part of Hillingdon Borough. The site is in the centre of a residential area that lies between Swakeleys Road to the north and the west, Long Lane to the south and Western Avenue (A40) to the south. The A40, which is part of Transport for London Road Network (TLRN) is over 1km from the site. The accesses to the site are off Milton Road to the north and Swakeleys Drive to the south. Both of these are part of the Borough’s highway network.

6 Both Ickenham and Hillingdon Underground stations are located approximately 1km east of the site, providing frequent services into central London and Uxbridge on the Metropolitan and Piccadilly Lines. This site is only served by one bus route (U10) providing a hourly service between Ruislip, Hillingdon Underground and Uxbridge stations, with bus stops located 300m away from the site on Swakeleys Drive. As such, the public transport accessibility level (PTAL) of the site is 1 (based on a scale of 1 to 6 where 1 is lowest and 6 is highest) which equates to a very poor level of accessibility to public transport.

7 Swakeleys House is a Grade I listed 17th century mansion house, which was built for Sir Edmund Wright in 1638, a wealthy London merchant, as a family home, entertaining space and retreat from the city. It is an important example of artisan mannerism and is ‘H’ shaped in red brick with stone and stucco dressings. It has five bays on main fronts and four on the side. There are two

page 2 main floors with a third floor in the roof space. Although it has been vacant since 2003 it has been kept secure and is not on the Buildings at Risk Register.

8 There are two ‘L’ shaped stable buildings that are located immediately north of the main house, which create a stable courtyard. These are also Grade I listed (being listed in 1974). Linked to the stables is a 1980s office building known as Vyners House and another office building known as Harrington House, which stands to the east, however this does not form part of the application proposals.

9 The house and its grounds form part of Ickenham Village Conservation area and the majority of the site forms part of the Green Belt. The application site is approximately 8.61 hectares and is surrounded by suburban residential development.

10 The River Pinn also lies adjacent to the western part of the site within a flood risk area of zones 2 and 3.

11 The majority of the site is open land; a tree-edged lake borders this land to the east, beyond which is a public park. The house has its main historic approach along an avenue leading from the south (of which remnants remain) although access is presently gained from the north, via a private road terminating in the stables area, and leading past buildings presently used for employment purposes. A private lawn bowling club is sited on the open ground to the north-west of the house. The house was renovated in the 1980s for employment use and was occupied by a pharmaceutical company during the 1980s and 1990s, but has remained vacant since 2003, with the exception of the northern part of the western stable courtyard, which is occupied by a security company as offices.

12 A public footpath leads through the site from the southern approach, and borders the open land, running alongside the lake (shown in yellow on the plan below). This access and other uses of the land by the community, including the Ickenham festival held every two years, and house open days, were secured through legal agreements associated with previous planning consents. The green edged and hatched area shown in the plan below show site usage for the above mentioned purposes.

Site plan indicating the conditional uses of the site’s grounds

page 3 Details of the proposal

13 The proposed development is for the restoration of the Grade I listed Swakeleys House and Grade I listed stable courtyard to create a single family dwelling. The proposal also involves the demolition of Vyners House, the ‘Ice House’ (a small external plant room) and car park and construction of guest accommodation and banqueting facilities on their sites, together with the re- instatement of historic landscaped elements, involving the loss of a footpath and bowling club within the grounds of Swakeleys House.

14 There are seven guest suites proposed within the footprint of the existing Vyners House building and which provide a total of 11 bedrooms.

15 There would be associated alterations to access and routes, including deletion of the right- of-way through the site.

Case history

16 On 19 July 2012 a pre-application meeting was held at City Hall. The principle of the proposal was supported subject to resolving Green Belt, sport and heritage impacts. Strategic planning issues and relevant policies and guidance

17 The relevant issues and corresponding policies are as follows:

 Green Belt London Plan  Historic Environment London Plan;  Employment London Plan;  Housing London Plan; Housing SPG; Housing Strategy; draft Revised Housing Strategy  Urban design London Plan;  Access London Plan; Accessible London: achieving an inclusive environment SPG; Planning and Access for Disabled People: a good practice guide (ODPM)  Sustainable development London Plan; Sustainable Design and Construction SPG; Mayor’s Climate Change Adaptation Strategy; Mayor’s Climate Change Mitigation and Energy Strategy; Mayor’s Water Strategy  Transport London Plan; the Mayor’s Transport Strategy  Parking London Plan; draft Early Minor Alteration to the London Plan; the Mayor’s Transport Strategy

18 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 Hillingdon Local Plan: Part 1- Strategic Policies, November 2012, the 1998 Unitary Development Plan and the 2011 London Plan.

19 The following are also relevant material considerations:

 The National Planning Policy Framework and Technical Guide to the National Planning Policy Framework  The draft Revised Early Minor Alteration to the London Plan

page 4 Principle of development – change of use, Green Belt and heritage

Change of use

20 The Hillingdon UDP (Saved Policies) does not incorporate any specific policies that preclude the loss of offices. The applicant has however provided evidence as discussed at the pre- application stage, demonstrating that the property has been marketed since September 2003, however the applicant still has not secured a tenant or purchasers for the building. The applicant has attributed this to the difficulty and expense of adapting the building to be fit for modern businesses who now seek office space close to amenities and public transport, large open plan floor plates and lower running costs with stronger green/sustainability credentials. Given that Swakeleys is a Grade I listed building it does not meet these criteria. Furthermore, the applicant is aware that the public footpath access rights are seen as a major concern to interested parties due to the privacy and security problems it poses.

21 The proposal has the benefit of restoring and bringing the listed building back into use. Therefore the proposed change of use of the house to its former residential use with additional guest facilities is accepted.

Green Belt

22 Protection of character and openness of Green Belt land is of paramount importance within the London Plan. The NPPF sets out that new buildings are inappropriate in the Green Belt. Some exceptions to this are set out including limited infilling or the partial or complete redevelopment of previously developed sites (brownfield land), whether redundant or in continuing use (excluding temporary buildings), which would not have a greater impact on the openness of the Green Belt and the purpose of including land within it than the existing development. The re-use of buildings provided that the buildings are of permanent and substantial construction is also not inappropriate in the Green Belt provided they preserve the openness of the Green Belt and do not conflict with the purposes of including land in Green Belt.

23 London Plan Policy 7.16 ‘Green Belt’ seeks to protect London’s Green Belt. Policy 7.16 states, “the Mayor will and boroughs should maintain the protection of London’s Green Belt and proposals for alteration to green belt boundaries should be considered through the DPD process in accordance with the government guidance in PPG2 [now replaced with the NPPF]. There is a general presumption against inappropriate development in the green belt, and such development should not be approved except in exceptional circumstances”.

24 The applicant has provided the relevant information requested at the pre-application stage with regards to before and after views and these show that the proposal will not have any significant impact on the character and openness of the site within its Green Belt and conservation setting. The applicant has also provided details of footprint, floorspace (gross external area, with and without basement, and gross internal area) and volume. The changes in these are not significant. Therefore very special circumstances do not need to be put forward for the proposal.

25 However, the applicant has also considered various options within the design evolution of the proposal, particularly with regards to Vyners House and this has ensured that there is minimal disturbance to the Green Belt, archaeological remains and the historic landscaping. Thereby preserving both the heritage and openness of the site.

26 The guest and staff accommodation and banqueting facilities are identified as ancillary to the main house and necessary to attract the type of occupier needed for the house. These

page 5 elements are not unacceptable, however, it is important that these remain ancillary to the house, as independent use could harm the Green Belt. This should be secured by the Council.

27 It is accepted that the proposal to reuse the existing building and new out building is not inappropriate development within the Green Belt.

Heritage asset

28 The applicant proposes to undertake internal changes to expose and protect historic features. Subject to the views of English Heritage the restoration and refurbishment of Swakeleys House is supported. Securing a viable long term use will safeguard the future of this valuable historic asset, which has been vacant since 2003.

29 English Heritage should also be satisfied that the replacement new-build elements do not harm the setting of the Listed Building.

Footpath

30 The footpath around the western and southern boundary of the site was originally proposed to be removed as part of the development proposals. This perimeter pathway is now proposed to be retained within the proposals, following local consultation, which identified that it was an important route. The use of the site for the annual open day and festival use and access to the House will also be kept. These elements should be secured by the Council.

Trees

31 The potential for tree loss was raised at the pre-application meeting. The applicant has carried out a thorough aboricultural survey, which identifies five trees to be removed, two category B and three category C. The impact of the loss of the category B trees will be minimised as they are screened by other trees to be retained, the loss of the category C trees does not raise concern. Other trees, sympathetic to the historic setting are to be planted. Affordable housing

32 London Plan Policy 3.13 sets out that affordable housing is normally required on a site that has a capacity to provide ten or more homes. The policy states that the density guidelines will be applied when assessing whether as site has capacity for ten or more units. Further guidance is given in paragraph 3.78, specifically reference is made to site capacity which might normally be expected to come forward. The Housing SPG also provide guidance, making reference to use of London Plan space standards as a reference point for whether units are particularly large.

33 In this instance the application does not propose to provide affordable housing and does not consider that it is required. There are examples of listed house conversions in outer London Green Belt locations which do exceed the 10 unit threshold and where an affordable housing contribution has been sought. However, the unique circumstances of each site must be considered and an individual assessment of what might ‘normally’ be expected to have come forward has to be made.

34 As stated above the return of the listed building to its original use is supported. Whilst it would be possible to sub divide the house and outbuildings into smaller dwellings, as has been achieved in other listed buildings elsewhere in London, this would be likely to have some impact on the buildings special interest and potentially on the openness of the Green Belt, no matter

page 6 how sensitively planned. Nonetheless given the size of the dwelling and its outbuildings and given that the building is in a good state of repair, and no case is being made for enabling works to fund repairs, it would seem reasonable for some contribution to be made to off site affordable housing.

Inclusive Design

35 The aim of London Plan Policy 7.2 is to ensure that proposals achieve the highest standards of accessibility and inclusion (not just the minimum). Inclusive design principles if embedded into the development and design process from the outset help to ensure that all of us, including older people, disabled and Deaf people, children and young people, can use the places and spaces proposed comfortably, safely and with dignity.

36 The design and access statement has set out how the proposal has addressed access and inclusive design issues. Whilst noting that the application is for a single family dwelling, there is an opportunity through refurbishment and the new build elements for the development to demonstrate best practice in inclusive design.

Entrances

37 The access statement states that the main entrance into Swakeleys House and into the stables has a level change of between 90mm and 800mm. The existing entrances are proposed to be largely retained in their current state given their Heritage significance but any adaptations are to be carried out in accordance with good practice guidance on accessibility. However, no detail is included on what this means or how this will be achieved. Further details should be provided to demonstrate how access will be achieved here. It may assist to know that Kew Palace, illustrated in the planning statement as another example of Artisan Mannerism architecture and a Grade one listed building, has been made fully accessible to disabled people by the provision of a gently sloping external ramp at the main entrance. This demonstrates that access for disabled people can be achieved at the front entrances of a grade 1 listed building. Further details of how the level change within the new glazed link will be achieved should also be provided.

38 No mention is made in the access statement of the lift replacement however, the plans state that the lift car within Swakeleys House will be replaced. The opportunity should be taken to install a lift that is fully accessible to disabled people to ensure that the upper floors of Swakeleys House are accessible.

Guest Suites

39 The access statement provides a detailed assessment of how the new guest suites will meet the Lifetime home standards. However, there is no consideration of whether any of the guest suites can meet the key features of wheelchair accessible homes. Given the nature of the development it is recommended that at least one of the guest suites is designed to be easily adaptable for occupation by a wheelchair user. Further details should be submitted to demonstrate how this might be achieved.

Energy

40 The applicant has applied the energy hierarchy and achieved carbon savings of 1% from energy efficiency compared to a 2010 Building Regulations compliant. District heating and combined heat and power have been discounted due to the location of the site and nature of the development, which is accepted. The applicant is proposing to install air source heat pump

page 7 to provide renewable heat and 157sq.m. of PV and 18sq.m. of roof mounted solar thermal panel. This will provide a further 10% carbon savings.

41 This falls short of the 25% savings sought by the London Plan. However, given the nature of the development as a single dwelling house with ancillary facilities and the constraints of the listed building this is acceptable.

Transport

42 The site consists of a vacant office building with 104 associated car parking spaces. The application proposes 14 garage/covered spaces with additional spaces (up to 40) for use in connection with the banqueting facility. The overall reduction in spaces is supported, and whilst the proposed level exceeds the maximum standard for residential use, it is accepted that the unique nature of the proposal makes application of these difficult. Electrical Vehicle Charging Points should be provided in accordance with the London Plan Policy 6.13 “Parking” as proportion of the fixed parking provision.

43 The trip generation exercise presented within the Transport Assessment did not follow TfL’s Best Practice Guidance. However, due to the scale, location and nature of the development, TfL ultimately accepts the output of the impact assessment and the likely level of additional trips will have no impact on either the public transport or highway network.

44 It is proposed that there will be 18 covered cycle spaces located in the Courtyard. This level of spaces is in line with London Plan Policy 6.9 ’Cycling’. In addition TfL however recommends that secure storage and showers are provided for staff members.

45 In accordance with London Plan policy 8.3 ‘Community Infrastructure Levy’, the Mayor has agreed a CIL Charging Schedule which came into operation on 1 April 2012. It will be paid by most new development in Greater London. Boroughs are arranged into three charging bands with rates of £50 / £35 / £20 per square metre of net increase in floorspace respectively. The proposed development is in the Borough of Hillingdon, where the charge is £35 per square metre. Local planning authority’s position

46 The Council’s position is unknown. Legal considerations

47 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 (the next bit is optional) 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.

page 8 Financial considerations

48 There are no financial considerations at this stage. Conclusion

49 London Plan policies on Green Belt, heritage, housing density, inclusive design, energy, and transport are relevant to this application. In general, the application complies with some of these policies but not with others. The reasons for this and the remedies are set out below:

 Principle of development: The proposal complies with London Plan policy 7.8 ‘Heritage assets and archaeology’ and London Plan policy 7.16 ‘Green Belts’. The change of use from employment back to the former residential use does not raise any strategic concerns. The existing footpath use and open day/festival uses are also to be retained. The Council should ensure the guest and staff accommodation and banqueting facilities are secured for ancillary use only.  Housing: An affordable housing contribution is required.

 Accessibility: Further information is required to determine whether the application complies with London Plan policy 7.2

 Energy: The proposals are acceptable.

 Transport: Electric vehicle charging points should be provided.

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] Sukhpreet Khull, Case Officer 020 7983 4806 email [email protected]

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