Sustainable Development Committee – 03.02.04 Rep7411 Lesley Underwood (tel.020 8583 5207) Lesley.Underwood @hounslow.gov.uk 00505/W/P69 P/2003/1345 (LU)

1.0 SITE

1.1 GLAXO SMITHKLINE HEADQUARTERS, 980 GREAT WEST ROAD, , (OSTERLEY AND SPRING GROVE) (16.4.2003).

2.0 PROPOSAL

2.1 This proposal seeks permission for an additional 179 car parking spaces, to include some surface parking and an additional storey on the existing multi-storey car park near to Boston Manor Road. This would increase the parking on site from 1,045 to 1,224 spaces.

(Drawing Numbers: CL/6197/6, Traffic Statement, Landscape Statement, Planning Statement, 3036.01.SK.01 Rev D Sheets 1-4, SKS/01RevP1- SKS/04RevP1, SKS/09RevP1, SKS/10RevP2, SKS/11RevP1).

3.0 INTRODUCTION

3.1 GlaxoSmithKline, formerly known as Smithkline Beecham have occupied several major sites along the Great West Road since the 1950’s. The company chose to develop a new International Headquarters Building on a new site along the Great West Road, and in March 2001 relocated their staff from existing sites at New Horizons Court and Wallis House to GSK House. Located at the junction of the Great West Road and Boston Manor Road, GSK House is probably the most prestigious development to have been built in the Borough during the last decade. It is a highly visible landmark building which has an immense impact on the image of the Great West Road as a gateway to London and a strategic employment location within London.

3.2 Prior to moving to the site, GSK envisaged having 2,500 people working at the site and anticipated that this was likely to rise to 3,000 over a ten year period. Current employment projections show that this figure represents a significant under estimate in terms of GSK’s emerging business plans and that the workforce is expected to grow to 4,000. This increase in employment is to be welcomed in an office market which is in decline along the Great West Road and within West London generally.

3.3 In order to accommodate the access needs of this increased workforce, GSK have applied for planning permission to create an additional 179 car parking spaces within the site (5 of which are being created through the realignment of existing spaces). The maximum parking allowance for offices in this area of the borough is 1:100m². The additional parking proposed would result in parking provided at a ratio of 1:68m² (when applied to the gross floor area of the building) or 1:59m² when applied purely to the office floorspace. Both, substantially in excess of the maximum allowance contained within the Council’s recently adopted UDP. The proposal is therefore contrary to the overall objectives of parking policy. However, the policy does state that the existence of any ‘exceptional circumstances’ should be given consideration in the event that additional parking is proposed.

3.4 Members will be aware that the Council have allocated a significant amount of time and resources, both currently and in the past, to delivering and encouraging regeneration in this area of the Borough. Area strategies such as the Great West Road Strategy and the Brentford SRB programme sought to deliver a package of measures which would bring a wide variety of economic, social and environmental benefits to the area and its people. The Great West Road has historically been a key employment location within the area and strategies sought to promote and encourage the continuation of this role. The Great West Road also formed a key element of the Green Corridors SRB Programme which sought to enhance the environment along the A4/M4 corridor.

3.5 More recently, the Council has embarked on producing a new planning and regeneration framework for Brentford in order to build on the successes of previous initiatives and develop a planning framework for the area which responds to the aspirations of the local population. All existing strategies and initiatives have been subsumed within the Council’s UDP. Those currently being developed will be incorporated within Hounslow’s emerging new planning framework, the ‘Local Development Framework’. (See separate agenda item).

3.6 Although this may appear to be a relatively straightforward proposal for additional parking, it is essential that this proposal is considered ‘in the round’. As such this proposal is considered within the wider context set out within National and Strategic planning policy, the Council’s recently adopted UDP and the more focussed strategies and initiatives referred to above. Regeneration and employment issues are considered together with accessibility and location generally. The sustainability of the proposal with regards to its social, economic and environmental impact on the area is assessed.

3.7 The following report sets out the details of the proposal and focuses on 9 issues that are considered to be key to its consideration. These are listed below;

1) Parking policy. 2) Factors affecting existing parking provision 3) Current public transport and potential for improvements 4) Highway access and traffic generation 5) Area Regeneration and Employment implications 6) Environment and Landscape issues 7) Impact of the multi storey car park 8) Local opinion 9) S106

3.8 The conclusion clearly sets out both the benefits, disbenefits and ‘risks’ associated with the proposal in order that Members are in a position to make an informed decision. The officer recommendation is an ‘on balance’ view which represents a pragmatic approach in the light of the circumstances of the company and the overall objectives of the Council as the Planning Authority.

4.0 SITE DESCRIPTION

4.1 This 5.44 hectare site is home to the international headquarters of Glaxo SmithKline (GSK House). The site currently contains 1,045 car parking spaces. GSK House has a gross floor area of 88,722 square metres. It is located within the E10 designation for Employment Sites of Strategic/West London Importance within the Council’s UDP and a Strategic Employment Site within the Draft London Plan. It is located on the corner of the Great West Road and Boston Manor Road, just a short walk from Brentford Station. The Great West Road (A4) to the south of the site is a Strategic Route of National/ Regional Importance. Boston Manor Road to the east is a London Distributor Road. To the north-east is the elevated section of the M4 Motorway. To the north is Boston Manor Park which is designated as Metropolitan Open Land.

5.0 DETAILS

5.1 The application proposes the provision of an additional 179 parking spaces which would be provided in the following locations:

53 parking spaces as an additional storey on top of the existing multi-storey car park. 66 spaces as an extension to the West Visitors surface car park. This would replace existing grassed amenity area. 55 spaces as an extension to the East Visitors surface car park. This would replace existing landscaping. 5 spaces from realignment of existing spaces.

6.0 HISTORY AND BACKGROUND

6.1 (505/W/P64)-Planning permission following the completion of a Section 106 agreement was granted on 17 December 1998 for the redevelopment of the site specifically for GSK Headquarters. The development included 72,462 square metres of office floorspace including conference and training rooms, and 11,167m²ancillary facilities including reception, restaurants and retail outlets, with 1,045 parking spaces, amenity space and landscaping. The development was completed and occupied in March 2001 when GSK consolidated their operation within this building and vacated Wallis House and New Horizons Court.

6.2 Contributions payable under the Section 106 Agreement amounted to a total of £1.75million of which £1,375,000 was allocated to public transport, pedestrian and cycle improvements. Key schemes which funds have contributed to include improvements to Brentford Station, the ‘Brentford exemplar’ and improvements to the E8 which runs along Boston Manor Road. Schemes which have yet to be implemented include the Boston Manor Residents Parking Scheme (presented as a proposal to residents in the summer 2000 but which only received 50% support at the time) and provision of CCTV between Brentford Station and environs. In addition to the above £150,000 was allocated to improvements within Boston Manor Park, £125,000 to improved street lighting along the Great West Road and £50,000 to employment training.

6.3 Until very recently, GSK have been utilising existing parking spaces (880) at Wallis House to accommodate staff parking needs. A shuttle bus service has been provided between the two sites. Staff have also until recently been parking in the Boston Manor Park car park.

6.4 Wallis House has now been sold and this parking is no longer in use. GSK have also instructed their staff to cease using the Boston Manor Park car park. GSK staff monitor the situation on a daily basis to ensure that the car park is not used by staff. CIP who mange the car park on behalf of the Council have now erected notices stating that the car park is for park users only and also leafleted cars stating that they will be clamped (with a £300 release fee) if they park in excess of 2 hours. Overspill car parking (353 spaces) is currently being provided for GSK staff at New Horizons Court.

6.5 GSK are fully aware that the current standards for B1 development in Brentford are set at a maximum of 1:100m² unless exceptional circumstances exist. Information has been submitted by GSK to assist Members in their consideration of the application. This is summarised below.

The Economic Importance of GSK

The economic importance of GSK to the national and international economy is well recognised and extends to the more local level where GSK is one of the largest single employers in Hounslow and Brentford.

GSK House, the worldwide HQ of the company, is a flagship development which has significantly raised the profile of Brentford and generated confidence in it as a business location and contributed to both the economic and physical regeneration of the area. It has also generated local employment, (26% of the workforce live within a 4 radius) both in terms of high quality permanent jobs and through locally based contractors who provide stationery, catering, travel, maintenance, cleaning services, etc.

These are jobs from a company in a national and international growth sector and hence these opportunities can be expected to increase locally, subject to available labour with the requisite skills.

At a more intangible level, GSK provides financial and other support to the local voluntary sector, which includes charities and schools and in 2004, the company is aiming to financially support a new programme with Hounslow Education Business Partnerships to involve GSK employees in local schools, focusing on:

• Supporting numeracy and literacy for primary school children • Mentoring • Science and engineering ambassadors

This activity with local groups contributes to the local skill base of the area which is a modest but nevertheless valuable contribution to the local economy.

GSK’s Previous Contribution to Sustainable Transport in Brentford

As part of the grant of planning permission for GSK House, the company entered into a Section 106 Agreement with the Council to fund a number of wide ranging sustainable transport, environmental and training measures which includes residents parking, improvements to pedestrian and cycle routes, street lighting, bus services, Brentford railway station, etc. To date, a total of £1.75 million has been paid by GSK to the Council.

GSK’s Commitment to Green Travel Measures

Since occupying GSK House, the company has introduced, and committed to, a range of Green Travel Measures which have ensured that close to 40% of staff at GSK House do not use a car to travel to work.

GSK Operational Need for Additional Car Parking

Since occupying GSK House, the company has been able to manage changing staff levels and car parking, on and off site, through the introduction of a series of Company Travel Plan measures. More recently a corporate decision has been taken to consolidate the World HQ operation at Brentford which involves increasing staff levels from the current 2,550 to 4,000 with the build up commencing immediately. It is this change in future staff levels which has made it necessary to seek the additional parking. This decision has followed exhaustive internal study and flexing of company travel measures and is, given the costs and uncertainty involved, in many respects a last resort by the company.

The justification for this position is set out below.

(a) There are presently a total of 1,045 parking spaces at GSK House; 121 are for visitors, leaving 924 to support current permanent staff of 2,550.

On a daily basis, approximately 1,600 of the current permanent staff of 2,550 attend GSK House. Detailed surveys last year indicated that 61.9% of staff drive to work, giving rise to a need for 990 spaces for permanent staff. This proportion is significantly lower than the average outer London mode share of 69% for driving to work, notwithstanding the fact that GSK’s staff catchment area is regional rather than local. The low driver mode share has only been achieved as a result of strenuous efforts to persuade staff to use non-car modes where practical.

The surveys also indicate a demand for 68 spaces for GSK staff from other sites and 95 visitors. This equates to a total demand for 1,153 spaces (990 GSK staff, 68 GSK visitors and 95 visitors) which produces a current shortfall of 108 spaces (1,045 spaces provided against a demand for 1,153 spaces).

This shortfall has been exacerbated by the recent loss of the Wallis House car park following disposal of the site to Barratt Housing. In practice, the shortage of parking means certain staff have no choice but to park in residential streets. Future localised traffic management measures could constrain this source of parking.

(b) Increasing staff levels to 4,000 will seriously exacerbate the current shortfall of parking. Assuming the same proportion of daily permanent staff attendance, this would increase from 1,600 to 2,510 (1,600 / 2,550 X 4,000). If the same proportion were to drive to work, this would result in a demand for 1,554 spaces for GSK staff. If other GSK staff and visitor levels remain unchanged (68 for other GSK staff and 95 visitors), this would increase total demand to a theoretical 1,717 (1,554+68+95).

The increase in staffing levels to 4,000 will therefore substantially increase the demand for car parking. However, it is not GSK’s intention to attempt to meet this demand. Rather, GSK are committed to a range of measures to encourage staff to travel to work by means other than by car. The loss of parking at Wallis House in the short term, combined with a gradual increase in staffing levels, means that GSK need to provide for a modest expansion in current parking levels at GSK House whilst continuing to implement measures to reduce car park demand.

The reality is that even with an increase in parking numbers by 179 spaces from 1,045 to 1,224, this will still leave a theoretical shortfall of 493 spaces against current demand.

Put another way, it will mean that even with the proposed increase in car parking the proportion of staff driving to work will still be required to reduce significantly. As indicated, this figure is currently 61.9%. As a consequence of only 1,224 spaces being provided, only 48% (1,224 / 2,550) of staff will be able to park at GSK House. If one makes the same allowance for spaces for other GSK staff (68) and visitors (95), this further reduces the supply of spaces to GSK House staff to 1,061 spaces, thus enabling only 41.6% of GSK staff to park. Achieving this change will require a very major shift in travel and working practices and close integration with various company departments, including Human Resources. All this will take time: one cannot achieve changes in travel habits on this scale overnight, particularly in cases that will involve staff moving their home.

(c) Without the increase in parking it is questionable whether the increase in staffing levels will be possible. The reason for this is that background studies and postcode analysis indicates that many GSK staff do not live locally, nor at locations sufficiently well served by public transport to allow travel by this mode. As is well known, Brentford is a location poorly served by public transport and without this parking, it is doubtful if many key staff would be able to travel to GSK House.

In addition, GSK operates within the highly competitive pharmaceutical labour market and while it recruits locally when it can, for employees with specialist skills it has little or no control over location. Where new recruits are unable to access the site by public transport, it is essential to be able to offer a combination of car parking and flexible working.

Compliance with standards

We are aware that current standards for new B1 development in Brentford indicate a maximum parking provision of 1 space per 100m2. This broadly equates to a car driver mode share of 20%. However GSK House is not new development – it is an existing business that was established when parking standards were less constrained. It is exceedingly unlikely that at current parking standards, a major headquarters building of this nature would be built on this site. This view is confirmed by the absence of similar developments in outer west London having been built on the basis of the parking standards now in force.

Accordingly, the standard of 1:100 can be seen not so much as a practical standard to be applied for new B1 development, but as a way of preventing new B1 development being located at sites without exceedingly good public transport.

For existing development such as GSK House, where very substantial investment in buildings has been made on the basis of a parking standard that is no longer applicable, the real planning issue is whether it is sensible to constrain the level of use of the building, or whether it is more sustainable in the broader sense to get the maximum utilisation of what already exists. We contend that the latter course of action is the right one, particularly in this instance where the investment has been so massive.

As you are aware, at the time the planning application was made for what is now GSK House, it was envisaged that the maximum occupancy of the building would be 3000. This figure was not envisaged as being achieved until 2007/8, by which time public transport would have been improved. The transport assessment submitted with the application and accepted by your Council at the time clearly stated this assumption on employee numbers. There has thus been a real change in circumstances since the consent was granted.”

GSK’s Views on Life of Permission

GSK believe that very special circumstances do exist to justify the modest permanent increase in car parking proposed at GSK House. However, in recognition of the underlying concerns of the Council and given the urgent need to address its consolidation strategy, GSK are prepared to offer the following:

(a) The introduction of a proven mechanism which will: • At defined review dates, identify improvements in public transport accessibility within the catchment area of the GSK House labour force; • In the light of identified positive changes in accessibility by public transport, revert a calculated number of surface level parking spaces up to a total of 174 to landscape.

(b) Irrespective of the timing of the outcome of the above, at the end of a period of 15 years, remove a total of 174 surface spaces;

GSK believe that 15 years should be a minimum period as this is necessary not only to recoup the significant financial investment in new parking, particularly on the decked structure, but more fundamentally to influence the location pattern of its labour force such that a higher proportion can live closer to Brentford or to a public transport connection and hence utilise public transport in their journey to work, thereby obviating the need for the additional parking spaces.

7.0. CONSULTATIONS

7.1 Street Management raise no objection to this application. They do not expect a substantial impact on the safe operation of the A4. Transport for London insists that the informal parking arrangement at the Wallis House site be discontinued, upon the opening of the new parking spaces at GSK House. The relocation of the spaces from Wallis House to GSK House will reduce traffic from those working at GSK House, however, this will be added back to the network once Wallis House is redeveloped.

7.2 On the basis of the percentage increase in traffic proposed. TfL believe that there would not be any unforeseen increase in congestion by accommodating the additional traffic associated with the new parking spaces at GSK House. As flows on the A4 have not increased as expected in the original planning application estimates, we would expect to see that the junction has no problems in accommodating the extra traffic generated from the extra 179 parking spaces at GSK House.

7.3 The Highways Agency would object to the proposals if any part of the multi-storey car park came to within 3 metres of any part of the M4 structures as it could prevent them from inspecting and maintaining the structure from underneath and would lead to the M4 having to be closed for extended periods of maintenance from the carriageway with substantial highway congestion implications for local roads. There would also be a risk that people could try to cross a small gap or that construction or maintenance of the car park could interfere with the M4. They note the extensive congestion on the M4 and there are no plans to widen this section. The congestion delays public transport and the emergency services, as well as having pollution effects. The availability of car parking is a major factor (PPG 13 para 49). They state that: 'we would urge the Council to apply RPG9 policy of 1:100 square metres and not allow any exception to parking levels in this case.'

The Head of Traffic and Head of Transport have commented as follows (summarised);

7.4 The UDP provides flexibility to apply standards of between 1:100m²-1:200m² in this area of the Borough. It is therefore clear that the maximum permitted standard for new B1 development at this location is 1:100m². When GSK House was granted permission in 1998, the maximum adopted standard was 1:50m².

7.5 The gross floor area at GSK House is 72,462m² offices plus 11,167m² ancillary facilities including reception, restaurants and retail outlets. This gives a current parking standard of 1:80m² overall (although 1:69m² if applied to the office element alone). Therefore, the additional proposed parking is contrary to policy. However, the policy does state that existence of any ‘exceptional circumstances’ should be given consideration in the event that additional parking is proposed.

7.6 The recent transport and accessibility report produced in relation to the Brentford Regeneration Framework concludes that the latest borough parking standards require a dramatic reduction in car mode share as compared to that typically observed in West London, with a maximum of 20% by car for office use…..at present only the eastern end of the study area (eg ) could be considered suitable for high trip generating office employment uses requiring large catchments. This is supported by the Draft London Plan, which suggests that major new development should be located where public transport is high; with a PTAL score of 4-6. The existing PTAL for the GSK site is low at 1-2.

7.7 The Regeneration Framework report has identified proposed public transport improvements in the area, which if they came to fruition could significantly improve public transport accessibility to the area.

7.8 Improvements to the bus network such as increased frequencies to the H91 and E8 corridors would increase the PTAL for the GSK site to 3.

7.9 Step change accessibility improvements beyond this stage would dependon investment in major schemes such as the West London Orbital and/or Crossrail 6. The report has calculated that the introduction of the West London Orbital would increase the PTAL to 6 around Brentford Station. However, it should be recognised that these schemes are unlikely to occur during the next 10-15 years and would require a strategy of lobbying for major transport investment.

7.10 GSK believes that there are special circumstances to justify the additional parking proposed. However, they are prepared to remove the additional spaces at such time as there are positive changes to public transport accessibility or irrespective of the timing of the improvements, at the end of a period of 15 years. The Draft London Plan accepts that there may be circumstances where temporary spaces are allowed on condition that these are withdrawn when better public transport access becomes available.

7.11 As the new development is already permitted and following the additional information provided, the increase in spaces could be allowed on the basis that they are removed when public transport increases. However, there should be a progressive decrease in spaces below the level currently on site if there are future major public transport improvements, which lead to higher PTAL levels.

7.12 In conclusion, the proposal does not conform with current parking policy in the adopted UDP. However, if the Authority considers that exceptional circumstances exist, the Local Authority are strongly advised to secure the following through an appropriate S106 Agreement.

• The number of spaces should be progressively reduced to the current level or preferably below as public transport accessibility improves in the future; • Implementation of a CPZ in the surrounding area; • Improvements to public transport, walking and cycling facilities;

7.13 This approval should not set a precedent for parking provision above current standards for new B1 proposals in the area. The suitability of high trip generating development should be assessed according to the PTAL of the site and should not be allowed if public transport is considered inadequate, or incapable of being improved sufficiently and the proposal cannot operate within a parking ratio of 1:100m². It is recommended that the concept of allowing temporary spaces with progressive withdrawal should not be adopted as general practice and should certainly not apply to the consideration of new development proposals.

7.14 C.I.P raised some concerns regarding the impact on the setting of the building and the Great West Road from the increased surface parking. If permission were to be granted then a contribution should be sought towards works within Boston Manor Park. In relation to the amended landscaping proposals, CIP have commented that the additional car parking does seem to be adequately screened by trees and planting along the A4 at ground level. Views from higher levels will still reveal more tarmac than at present from the front of the site.

7.15 Green Corridors Partnership consider that the extension of on site parking should be considered within the context of the impact on the wider ‘Gateway’ role of the Golden Mile and the need to improve north/south connectivity. In particular, the partnership consider that the existing footbridge should be improved to enhance north/south pedestrian accessibility and funds should be allocated to drawing up and contributing to the implementation of a detailed strategy for environmental enhancements along the A4, which would include (among other things) additional street tree planting. GSK have already contributed to an environmental ‘inception study’ in May 2001, but additional funding is necessary.

7.16 Pollution Strategy Officer Air quality is a material consideration in the planning process. As such extra car parking spaces, particularly within an air quality management area (AQMA), cannot be seen as positive development. However, it is important to take a holistic view of the area as a whole. Although GSK House is outside an AQMA currently it is highly probable that the whole Borough will be designated in the future. Given the existing air pollution in the Brentford Area, although there will be no measurable change in air quality due to these additional car parking spaces, they could contribute to the incremental worsening of pollution levels over time. The Council is therefore posed with the dilemma that the additional spaces are undesirable yet the additional harm associated with the development is not enough to warrant refusal. In air quality terms, a holistic approach is necessary. Additional spaces on this site should be compensated by fewer spaces elsewhere in the area. A survey is needed to quantify the number of car parking spaces in the area and an assessment made of their monetary value. Ideally, this should lead to a cap on car parking spaces and better partnership working between businesses and developers in order to avoid excess provision of parking spaces.

7.17 Isleworth and Brentford Area Committee 24/07/03 made the following observations:

• Additional car parking should not adversely impact on the existing landscaping • There should be wider improvements to bus services along the Great West Road.

7.18 Cable and Wireless occupies nearby offices at Great West Plaza and Brentside Executive Centre. They do not object to the planning application. However, they request that the building contractor minimizes the possible effect on air-conditioning systems by keeping dust and other airborne materials under control.

7.19 The London Borough of -Transport Services objected to the proposal and considered that there should be no increase in parking. Any increase in travel demand should be met by robust Travel Plan Initiatives. Specifically, Ealing objected on the following grounds, some of which have been addressed in subsequent correspondence submitted by the applicant; • That there had been no assessment of how the development complied with parking standards (this has now been submitted) • No assessment had been undertaken on the coincidental impact on the road network from the additional car parking and a newly owned Wallis House (which may never be disposed of and therefore the applicant will have extra parking spaces. It should be made conditional that no increases in spaces would be allowed until Wallis House has been disposed. (Wallis House has now been sold and as the nature of the development is yet to be decided, an assessment of traffic related to it is premature) • No consideration has been given to how the parking will be managed. (This is considered to be a matter for GSK. Management will need to be vigilant in order to control the excess demand for spaces) • No improvements to the Travel Plan have been considered to address the shortfall of spaces (Most of the additional travel demand is not being met by additional parking. The Travel Plan will need to be robust in order to achieve a modal shift from 62%-42% car drivers as envisaged in GSK’s supporting statement)

The ’s concerns are acknowledged. Although some of these have been addressed through the submission of additional information, they do not overcome the fundamental objection to the provision of additional spaces.

7.20 There were no responses from any residents in the vicinity. 48 were consulted.

8.0 POLICY

PPG1 General Policies and Principles

8.1 One of the key principles of PPG1 is to meet the needs of a growing and competitive economy, provide for new development whilst protecting the environment. An integrated approach to land use and transport and the locational needs of businesses should be taken into account together with their contribution to regeneration areas, access and links to other businesses. Local Planning Authorities should encourage alternative means of travel which have less environmental impact and hence reduce reliance on the private car.

PPG4 Industrial and Commercial Development

8.2 One of the Governments key aims is to encourage continued economic development in a way which is compatible with its stated environmental objectives. Economic growth and a high quality environment have to be pursued together. A diverse range of employment opportunities should be encouraged as well as maximising the use of land and buildings.

PPG13 Transport

8.3 PPG13 provides advice on how local authorities should integrate transport and land use planning as a means to reduce dependence on use of the private car. It requires local authorities to carefully consider the impacts of travel demand of all new development before planning permission is granted. The guidance advocates reduced parking in locations which have good access to other means of travel and complementary traffic management measures. It also acknowledges that the private car is likely to remain the most common mode outside the centres of major towns and conurbations and highways provision should be designed accordingly to ensure that safe traffic conditions are maintained. Reducing the amount of parking in new development is essential, as part of a package of planning and transport measures, to promote sustainable travel choices.

RPG9-Regional Planning Guidance for the South East

8.4 The fostering of economic growth is a major strategic objective of RPG9 in order to maintain and develop the South East’s competitive position in Europe and give employment to its people. In particular, the planning system should provide for the location of international headquarters as a matter of national interest. However, such development needs to be achieved in a way which is environmentally sustainable, avoiding unnecessary damage to the global, local and regional environment.

8.5 With regards to transport, whilst local circumstances will influence what is possible, it is no longer acceptable to work on the premise that the car will represent the only realistic means of access. Local Authorities should aim to achieve a measurable modal shift in favour of non-car modes of travel. Parking provision within London should be no greater than 1:100m². Facilitating sustainable economic growth will depend on reducing car usage within the urban area and an improved public transport system.

RPG 3 Strategic Planning Guidance for London

8.6 The overriding theme of RPG3 is one of economic development which is compatible with environmental and social objectives which leads to the most effective use of land generally. Borough’s should adopt a positive, flexible and realistic approach to business development throughout London. The guidance states that the amount of traffic generated by new developments should be minimised by applying maximum limits on the levels of off street car parking. In considering proposals for development, Local Authorities should only permit the maximum levels set out in UDPs (1:100m² in this instance) to be exceeded where they can be specifically justified in relation to the particular traffic generation characteristics of the development and its economic and regeneration importance, having regard to the provision of public transport and the impact on the environment of extra traffic.

The Draft London Plan

8.7 The Draft London Plan identifies the Great West Road as a Strategic Employment Location. It acknowledges that, with only a few exceptions, the suburban London stock is losing its attraction as a location for strategically important office based activity. The Plan states that controlling the level of parking can contribute to reducing congestion and encouraging the use of public transport. A valuable contribution to sustainability can be made by Green Travel Plans. Development that will generate large numbers of trips should be located at places accessible by public transport and with existing or planned capacity coming on stream to meet need. Temporary car parks should be resisted and only considered in cases of exceptional need. There may be circumstances in which temporary spaces may be allowed on condition that these are withdrawn when better public transport access becomes available (3C.52). Major new development should be located where public transport accessibility is high: this is interpreted as locations with a PTAL score of 4-6. PTALs and a Transport Assessment should be used to inform the level of parking within the range of 100-600m² of gross floor area for employment uses in outer London. Normally they should not be used to increase the level of parking indicated unless there is an identified regeneration need.

The Great West Road Strategy

8.8 The strategy was approved by the Council in October 1993 and forms supplementary planning guidance to the Council’s adopted UDP. Objectives within the strategy seek to maintain and enhance the status of the Great West Road as a prime employment location, to attract major companies to locate their headquarters within prestigious development along the A4/M4 corridor and to improve the overall accessibility of the area through a comprehensive package of public transport improvements. Striking a balance between the need to improve the environment and foster economic growth is one of the most fundamental issues to be tackled by the strategy.

Brentford Regeneration Programme

8.9 The Brentford Regeneration Programme began in 1995 with a successful bid to the Government for SRB funds. Although the programme is now complete, it provided the foundations for area improvement, the successes of which have been recognised at a national level. The primary aim of the programme was to ‘support and encourage the physical environment and improvements to the local economy in order to achieve wider social and community benefits. One of the primary objectives of continued regeneration within the Brentford area is ‘the maintenance and support of existing businesses whilst focussing on the creation of new jobs and encouraging new investment’.

8.10 In order to maintain the momentum of the success of the regeneration programme, the Council, in partnership with West London Business have been developing a new Regeneration framework for the area. Consultants technical reports have now been completed. Some of the key issues which have emerged from the studies which are relevant to the consideration of this application include;

Accessibility • Increased congestion is reducing ease of access to and through the area. • Only the eastern part of the area (around Gunnersbury and Chiswick roundabout) is identified as having good public transport access. • Rail based improvements are unlikely to be secured in the lifetime of the BRF (15 years). However, there is potential through a variety of rail based improvements to increase public transport accessibility to a level 6 around the Brentford Station Area. • The only realistic deliverable improvements in the short to medium term will be bus, cycle and pedestrian based. (Improvements to service frequency of the E8 which runs along Boston Manor Lane and the H91 which runs along the Great West Road are suggested. North/ South pedestrian links across the A4 are considered to be a significant barrier) • It is the consultant’s view that in the light of the above, new high trip generating developments should be confined to the eastern part of the study area.

Economy • The current downturn in the office market has resulted in high vacancy levels and a halt to speculative development across the BRF area. • Employment growth is set to continue but this will be concentrated in the low value added sectors eg distribution. • The attraction of the Great West Road is diminishing over time due to increased traffic congestion and poor public transport accessibility

Adopted UDP –Dec 2003 IMP 1.1 Integrating Pattern of Land use and the Provision of Transport IMP3.1 Brentford Regeneration Area IMP4.2 Great West Road IMP6.1 Planning Obligations ENVB-1.1 New Development ENV-N.1.7 Development Near the Metropolitan Open Land Boundary ENV-N.2.9 Green Corridors ENV-P.1.6 Air Pollution E.1.2 Locations for B1(Business) uses E.2.3 Improvements to employment sites. T.1.2 The movement implications of development T.1.4 Car and Cycle Parking and Servicing Facilities For Developments T.2.3 Strategic and local cycle networks T.4.3 Traffic implications of new development T.5.1 Air quality implications of traffic T.4.5 On street parking Appendix 3 (Parking standards).

Implementation Policies 8.11 Local planning policy seeks to integrate transport provision and the location of developments in a way which contributes to urban regeneration and maximises use of previously developed land whilst minimising harm to the environment and reducing the need to travel. High trip generating development is encouraged in town centres but also in other designated areas, including the Great West Road, provided that public transport can be improved sufficiently (IMP.1.1). There is a commitment to support and encourage regeneration in the Brentford area which improves the physical environment and the local economy in order to achieve wider social and community benefits. Primary objectives of particular relevance to this application include; the maintenance and support of existing businesses, the creation of new jobs and investment, environmental improvements and the delivery of a high quality built environment (IMP.3.1). Specifically, policy relating to developments along the Great West Road seeks to maintain its status as a prime employment area. In considering planning applications, factors to be taken into account include; the contribution to sustainable access, the impact on traffic congestion, air quality and the highway network; the impact on the competitiveness and regeneration of economic activity in the area; the visual appearance of the development and its impact on adjoining land; the contribution to the objectives of the Great West Road Strategy and the regeneration of Brentford as well as the enhancement of the role of the Great West Road as London’s primary ‘Gateway’ (IMP.4.2). The provision of appropriate planning benefits associated with new development is encouraged. Such benefits will only have a bearing on the determination of a planning application if they have a bearing on the planning merits of the application itself (IMP.6.1).

Environmental Policies 8.12 All new developments are expected to make a positive contribution to overall environmental quality and any development near the MOL should be designed so that it does not detract from it (ENV.B.1.1and ENV.N.1.7). The Great West Road is identified as a Green Corridor where new development adjoining the road should contribute to improvements to landscaping (ENV.N.2.9). The effect on air quality generated by traffic will be given full consideration and detailed air quality assessments will be required where there are a significant amount of trips (ENV-P.1.9 and T.5.1).

Employment Policies 8.13 Office uses should be located in the Boroughs town centres that offer the greatest accessibility by all modes of transport. In the event that suitable sites are not available other sites, including the Great West Road that are supported by public transport improvements are considered suitable for office development. All applicants will need to demonstrate that developments are sustainable, particularly in terms of their accessibility and long-term viability (E.1.2). Improvements to the amenity, appearance and efficiency of existing employment sites will be promoted including access and landscape improvements (E.2.3).

Transport and Parking Policies 8.14 The Council must be satisfied that proposals for new development will be readily accessible by sustainable modes. All proposals should ensure that the development promotes access by walking, cycling and public transport with the aim of maximising the proportion of trips by these modes. If access to a new development is not satisfactory by sustainable modes, proposals will be expected to be brought forward to improve walking, cycling and/or public transport (T.1.2). Development will not be permitted if the traffic generated causes danger, unacceptable noise, congestion or environmental intrusion (T.4.3). The maximum parking desirable for offices in this location is 1:100m². Applicants will be expected to provide supporting evidence to justify any exceptional circumstances which are relevant to allowing more parking and applicants may be required to enter into a S106 agreement in order to secure mitigation for the potential detrimental effects of the development (T.1.4). The Council will seek contributions from developers in order to develop and improve local cycle links (T.2.3) In consultation with local residents, the Council will seek the introduction of CPZ’s to control on street parking demand (T.4.5).

9.0 KEY PLANNING ISSUES

9.1 Planning guidance at a national and local level is firmly based on the overall objective of ‘sustainable development’-balancing the needs of the economy, environment and society now and in the future. Council policies and Central Government Guidance seek to maximise the opportunities for new development and the use of existing buildings and previously developed land whilst reducing the need to travel. One of the primary issues which should be considered with regard to the acceptability of new development is the appropriateness of its location and the integration of land use and transport provision. High trip generating developments should be located in areas that are well served by public transport, promoting the proportion of trips by this means as well as walking and cycling whilst restraining the use of the private car.

9.2 There are a number of planning issues which need to be considered, namely;

• The provision of additional car parking spaces as proposed at GSK House runs counter to strategic and local parking policy. • Restraining the use of the private car and promoting the use of public transport and other sustainable modes of travel reflects the general aims of planning policy. • Maximising the use of an existing building and previously developed land is generally encouraged on the proviso that the development is in a suitable location in the first instance. • Supporting existing businesses and encouraging regeneration is key to the boroughs recently adopted UDP and reflects strategic, regional and national guidance. • Does the development result in an unacceptable impact on the environment? • Can the detrimental effects of the proposal be mitigated sufficiently by an appropriate package of planning benefits to result in the application being considered acceptable? • Planning should reflect people’s aspirations for the area in which they live as far as possible.

9.3 These issues are considered within the following broad headings;

1) Parking policy. 2) Factors affecting existing parking provision 3) Current public transport and potential for improvements 4) Highway access and traffic generation 5) Area Regeneration and Employment implications 6) Environment and Landscape issues 7) Impact of the multi storey car park 8) Local opinion 9) S106

Parking policy

9.4 The extra parking proposed would result in a total of 1,224 parking spaces at GSK House representing a ratio of 1:68m² (1:59m² applied to office floorspace only) as opposed to the current ratio of 1:80m² (1:69m² applied to office floorspace only). Although maximum parking standards at the time the original permission was granted were 1:50m², the Council was keen to move towards the emerging standards, 1:100m² wherever possible. The Council has now formally adopted the maximum standard of 1:100m² which is contained within the UDP and reflects guidance contained within the Draft London Plan.

9.5 The proposal for 179 additional parking spaces at GSK House is contrary to parking policy contained within the Draft London Plan and the Council’s UDP unless Members consider that there are ‘exceptional circumstances’ which have sufficient weight to allow the extra parking.

Factors affecting existing provision

9.6 At the time when the application for GSK House was made, both the Council and Glaxo Smithkline were relatively confident that with a substantial S106 contribution to bus services and improvements to Brentford Station, it was realistic to assume that public transport had the potential to improve sufficiently to justify the application of restraint parking standards on the site. This was given further support by the launch and promotion of the A4 ‘Fast Lane’ tram initiative soon after GSK had moved to GSK House. The anticipated public transport improvements were expected to deliver the step change which was needed to public transport provision necessary to make this site suitable for a high trip generating development.

9.7 The A4 tram would have run from Hammersmith to Heathrow and it was estimated that 20% of journeys currently made by car or public transport at peak times could be attracted to the route. However, TfL supported the West London Transit scheme which proposes a tram along the and did not offer support for this scheme. Despite the fact that the Draft London Plan identifies the Great West Road for office development, it does not propose any improved public transport infrastructure to support this development. Although Hounslow submitted an objection with regard to this issue, the Panel report indicates that this is unlikely to be forthcoming in the lifetime of this plan.

9.8 Essentially, this lack of investment and provision in public transport means that a major high trip generating development has been located in an area which has an inadequate public transport infrastructure and services to support it. Despite the efforts of GSK and their rigorous application of initiatives contained within their green travel plan they have been unable to achieve the modal switch to public transport necessary to allow them to contain their parking demand within the overall on site provision. Although they have achieved a car modal share of 62% as opposed to the West London average of 69%, overspill, offsite parking has been integral to the GSK operation. Wallis House parking (880 spaces) is no longer available and overspill parking has shifted to New Horizons Court (353 spaces).

Current Public transport provision and potential for improvements

9.9 As part of an area accessibility study undertaken to provide supporting material for the emerging Brentford Regeneration Framework, Symonds Transport consultants have considered current public transport provision in the area and the potential for improvement.

9.10 A widely accepted method of assessing how well areas are served by public transport is known as the PTAL (Public Transport Accessibility Level) method. This method measures the relative PTAL of areas across London from level 1-6, level 1 being the lowest. The Draft London Plan states that high trip generating development should be located in areas with a PTAL of 4 or greater. The majority of GSK House lies within PTALs 1 and 2, with the western corner lying in 3.

9.11 Apart from identifying necessary works to improve local access by walking and cycling, (which can in some cases be quicker than using the bus) Symonds consider that improvements to the E8 and H91 bus services are likely to be achievable in the short term. These improvements will result in a small but valuable improvement in accessibility to and within the area and should enable suspension of the shuttle buses which many companies along the Great West Road are currently dependant on (Gillette, Sky, GE Insurance, GSK and Harrods). Improvements to North/South pedestrian links would also be valuable as the A4 has a considerable severance effect on local access.

9.12 The Isleworth and Brentford Area Committee commented on the application that local employees should endorse the need for a public bus service to serve all the business on the Great West Road instead of individual companies providing shuttle buses for their own employees.

9.13 In response to this concern GSK stated the following;

“We can confirm that GSK are actively involved, though their representation in West London Business' in promoting improvements to public transport along the Great West Road. The need to improve the public transport accessibility of the Great West Road is both recognised and endorsed by GSK who themselves have made significant investment towards achieving this aim i.e at Brentford Station. However, as part of a wider aim of encouraging a modal shift of their staff towards public transport, GSK have adopted a range of measures including providing a shuttle bus service from GSK House, not only to other GSK facilities but to Northfields tube station. Until such time that public transport accessibility improves along the Great West Road, GSK remain committed to such initiatives on the bus shuttle service in order to reduce staff demand for car parking at GSK House”.

9.14 The impact of improved bus services on GSK House is that the majority of the site (which includes the building itself) would lie within a PTAL 3 with a small part of the western corner lying within a PTAL 4.

9.15 The report also considers more significant improvements to public transport which could have an effect on the area. Those of particular relevance to this site include the A4 tram, the A4 monorail, the West London Orbital (which includes an option to link Brent Cross with Surbiton passing directly through Brentford Station), and the electrification of the Chiswick Freight line which is included within Hounslow’s option for Crossrail 6 allowing the Hounslow loop to be used by Crossrail services. Although all these improvements are ambitious it does indicate the continual commitment of the Borough as well as West London Business to improve public transport to the area. In the event that the West London Orbital was to be delivered, this would raise the public transport accessibility around Brentford Station to a level 6. Crossrail 6 would offer complimentary improvements.

9.16 However, neither of these initiatives may ever come to fruition and, even if they did, it is highly unlikely that they would be delivered within the next 15 years. The concept of the A4 monorail is still in its infant stages and, once again, even if it were to be progressed, it is highly unlikely that this would be delivered within the next decade.

9.17 In summary, there are public transport schemes that could deliver substantial improvements to public transport accessibility in the area, but none are likely to be deliverable in the next 10-15 years. In the short to medium term improvements to walking, cycling and bus services can help to improve local access but will not deliver the ‘step change’ needed to provide this site with a high level of public transport accessibility.

Highway Access and Traffic Generation

9.18 In response to the Highways Agency's concern the applicant has confirmed that there would be no part of the expanded car park within 3ms of the M4.

9.19 TfL have assessed the application with regard to the increase in traffic flows along the A4 and at its junctions and have confirmed that the expected increase in peak hour flows to and from the site are acceptable and will not have a significant effect on traffic flow and congestion along the A4.

9.20 The Borough’s Highway Engineer has stated that although the principle of additional parking should be resisted, when compared to current and past arrangements which involve shuttling staff to and from remote sites, the impact of traffic on the wider highway network will if anything reduce impact on the adjoining network rather than increase it. In reality the change is likely to be insignificant with regards to traffic flow and congestion.

9.21 The provision of additional parking spaces is not anticipated to have an unacceptable effect on traffic flow along the adjoining highway network. The additional vehicles driving to and from this site is not considered to result in a worsening of congestion in the area.

Area Regeneration and Employment implications

9.22 GSK House lies within one of the Boroughs most important employment locations as well as one of the key regeneration areas within the Borough. Although the Great West Road has historically supported a buoyant, albeit changing, economy it has recently shown signs of losing its attractiveness to Major employers. This is readily apparent through the vacant buildings along the road. It is somewhat of an anomaly that a company is choosing to consolidate their operation on the Great West Road rather than relocate. GSK have not specifically stated why they have chosen this course of action but it can be assumed that its historical location within the area, the relatively established location of its workforce, coupled with the recent substantial investment in their new International HQ building are all contributory factors.

9.23 Given the scenario that the area is losing employment and that there is an increasing pressure for alternative development (primarily residential), the potential to increase employment in the area is to be welcomed. However, this is clearly not a site which is well served by public transport and therefore any changes which result in more trips being associated with the development will inevitably raise difficult issues with regard to access. The fact that the building is already built and so recently completed does have an impact on its future use. Although access is poor, maximising the use of the building, supporting the existing business and generating new jobs within the area is considered appropriate from both a planning and economic point of view.

9.24 GSK have also contributed to the physical regeneration of the area through the construction of the GSK House development itself as well as improvements to Brentford Station and street scene improvements through the Brentford Examplar.

9.25 As stated in GSKs supporting statement, they have a continual commitment to education and training within the Borough. Apart from their direct involvement in such initiatives, they have also contributed £50,000 to employment and training initiatives as part of their S106 relating to the original permission for GSK House.

9.26 In addition to the above, their commitment to being a ‘good neighbour’ should not be underestimated. Very little parking takes place on adjoining streets and parking in Boston Manor Car park has ceased due to their vigilance as well as parking restrictions which have been imposed by the Council.

9.27 GSK are a major employer in the area who plan to continue to have a major impact on the economy, environment and community of the area. Although the location of GSK House is currently poorly related to the public transport network, there has been substantial investment in this new development and maximising its use is considered appropriate under the circumstances.

Environment and Landscape issues

9.28 The legacy of the Golden Mile has corporate H.Q. buildings set back from the road set within landscaped grounds. The office building is set within a landscaped setting to emulate the typical 1930's developments. The landscaping and mounding around the buildings gives the impression of a parkland setting.

9.29 The proposals would extend the surface car parking and bring the parking area very close to the Great West Road. As a result of the concerns raised by the Isleworth and Brentford Area Committee about possible effects on the existing landscaping a number of additional amendments have been made to the original submission:

• Existing cherry trees in west visitors car park will be transplanted to eastern boundary behind the existing hedge line. • Grove of cherry trees on lawn on top of a car park roof deck will be transplanted to eastern boundary. • Oak and ash trees in east visitors car parks, will be transplanted to adjacent soft landscape area. • Proposed box-pleached lime trees planted into hornbeam hedge on A4 boundary to be planted in groups of five with breaks between each group. • Pedestrian link to be re-installed with double row of lime trees to provide denser canopy.

9.30 The Council's landscape advisor has commented that from ground level the additional car parking would be adequately screened with the amended proposal although from higher levels, larger areas of tarmac would be visible.

9.31 The loss of the use of grassed amenity area for staff due to the extension of the western car park is also unfortunate. However it is considered that the landscape screening now proposed and the amenity area to the rear of the site provides sufficient landscaping and amenity space for the development not to warrant a refusal of the application.

9.32 Within a wider context, it is considered that there is increasing pressure on the A4 itself to offer a greater landscape setting for higher density developments within reduced areas of landscaping. As such there is a necessity for improved planning and increased investment in the ‘street scene’ to maintain the status of the Golden Mile as one of London’s most important gateways.

9.33 With regard to air quality, an additional 179 car parking spaces will increase the number of trips to and from the site adding to the vehicle emissions associated with the traffic generated by the development. Hounslow Council is bound by statute to work towards specific air quality objectives and this development runs contrary to these. However, this level of increase would not lead to a measurable change in the air quality concentrations. Due to this fact, is not considered that the impact on air quality would justify a refusal of planning permission in this instance. Nevertheless, the cumulative impact of pollution from motor vehicles is something which the council needs to take very seriously. As such it is imperative that measures are put in place, on an area basis, to manage and ultimately improve air quality within and around the Brentford area.

9.34 The overall loss of the landscaped areas within the site is not welcomed. However, GSK have adopted improved measures that attempt to compensate for this loss. These, coupled with appropriate off site improvements, could be considered acceptable within the wider context of the Great West Road as a ‘Gateway to London’. A holistic approach should be adopted with regard to the management and improvement of air quality. As such local businesses, in partnership with the Council, should take a holistic view to travel planning and parking in the area with a view to reducing the overall number of parking spaces within the area, whilst improving access by walking, cycling and public transport.

Impact of the additional storey on the multi-storey car park.

9. 35 The existing multi-storey car park is adjacent to the M4 flyover. The additional storey would be seen between this and the existing GSK building. It is not considered that this would be out of scale with its surroundings, although the height of the existing multi-storey car park does provide some break between the flyover and the main GSK building. There are two Listed Buildings located on Boston Manor Road (69 - 75 and 67). These are separated from the extension to the multi-storey car park by the M4 flyover. It is therefore not considered that these buildings will be affected by the proposal.

Local opinion

9.36 It is interesting to note that no local residents have made representations relating to this development despite 48 being consulted. However, Members should take note of the results of the recent consultation exercise relating to the Brentford Area Action Plan. Although residents were generally pleased with the quality of new development in the area, two of their major concerns related to traffic congestion and the need for investment in public transport. Neither the Head of Traffic or Tfl consider that this development will have any significant effect on traffic congestion. Measures to improve public transport are discussed below.

S106

9.37 The proposal for179 additional parking spaces is contrary to planning policy with regards to restraining parking provision. However, in the event that Members consider that the exceptional circumstances discussed in this report are of sufficient weight to consider an approval of the proposal and are minded to grant planning permission, it is considered that the following planning obligations would be necessary. • Pedestrian improvements to facilitate crossing /severance between the North and South of the A4 (specifically the footbridge) • Public Transport studies focussed on improvements to the E8 and the H91, coupled with financial improvements to service quality and frequency. • Improvements to the local cycle network, • Financial contribution to CCTV from Brentford Station to GSK House(sufficient to implement the scheme and ensure adequate surveillance in the future) • Employment training to maximise the take up of local employees and thus minimise the need to travel. • Contribution to a detailed environmental improvement strategy and off site landscape improvements in order to maintain the status of the Great West Road as a ‘Gateway to London’. • Consultation and implementation (subject to response) of a Residents Parking scheme • The promotion of an Area Green Travel Plan which promotes good practise, encourages sustainable modes of transport whilst discourages the duplication and excessive provision of parking spaces. • Agreement with regard to the detailed terms of the temporary nature of the parking arrangements applicable to this application. This will include the review of the GSK Travel Plan at set intervals, the changing travel patterns of the GSK workforce, coupled with an assessment of improvements to Public Transport Accessibility.

9.38 The S106 Agreement relating to the original permission is still relevant to some, but not all, of the areas listed above. It is considered that, if Members are minded to grant planning permission, the terms of the existing S106 should be revisited and formally varied, with the intention of taking account of changing circumstances and additional measures appropriate to mitigate against the negative impact of an additional 179 car parking spaces on site.

10.0 CONCLUSION

It is considered that Members have two options.

1. The development already has parking over and above the maximum allowed in this area of the Borough. Although the development was built at a time when the adopted standard was 1:50m², the applicant was fully aware of the Councils intention to move to a more restrictive parking policy 1:100m² which has now been formally adopted. Having considered this officer report and the case put forward by GSK as ‘exceptional circumstances’, Members may consider that these are not sufficient to outweigh planning policy with regard to maximum parking provision. On the basis of the above, the application should be refused.

2. Whilst being committed to the application of the Council’s adopted parking standards for new development, Members may consider that the exceptional circumstances outlined within this report, coupled with the programme of measures proposed within the S106 Agreement are sufficient to result in a proposal which is, on balance, acceptable. The parking would in essence be granted for a temporary period of 15 years, with the potential for progressive reduction dependant on increased public transport accessibility as well as changes in the travel to work patterns of the workforce which have resulted from the initiatives contained within the GSK Green Travel Plan. At the end of, and at regular intervals during, this period the public transport accessibility of the site will be reviewed. Dependant on the level and nature of either committed or pipeline public transport improvements, this could result in;

a) Removal of additional spaces in their entirety, resulting in a development which is serviced by the same number of parking spaces granted as part of the original planning permission, or;

b) Dependent on the provision of a significantly high level of public transport accessibility improvements, parking could be reduced to a lower level than originally approved by removing all surface car parking (other than a limited provision for disabled people and visitors).

Either of these scenarios has the potential to result in a development which is as sustainable, or more sustainable, than has already been approved. However, there is a significant possibility that the public transport improvements will not be delivered. In this event, towards the end of the 15 year period, the Council would almost certainly need to give active consideration to some or even all of the additional spaces being allowed to remain in place for a further period, despite the requirement for their removal which would have been provided for in the Section 106 Agreement.

However, on the basis that the logic behind granting parking spaces subject to progressive reduction is founded on the relationship between public transport accessibility and access needs of a development, Members may consider that although it would not be desirable, there might nonetheless be good practical reasons for some of the additional parking at GSK House being maintained in place in the longer term if there is insufficient investment in public transport over the 15 year period, or in the absence of any firm commitment within plans published at that point in time. On the basis of the above, Members may be minded to grant planning permission subject to an appropriate S106 agreement.

11.0 RECOMMENDATION

11.1 This report has thoroughly assessed this proposal with regard to its planning, environmental, economic and social implications. It is considered that the changing circumstances associated with GSK House, specifically with regards to the lack of the anticipated investment and improvement in public transport, coupled with the unexpected increase in the workforce, exceptional circumstances are sufficient to consider allowing additional car parking until circumstances warrant a reduction in spaces.

11.2 In the event that Members are minded to approve the application, they should bear in mind that, although LB Hillingdon have adopted a similar approach to progressively reducing spaces at Stockley Park, this has not occurred as yet and it is questionable whether this will occur as the public transport provision anticipated has not come forward. A similar scenario at Brentford may well occur. As such the reality is that many of these spaces could remain for the foreseeable future. If Members choose the second option outlined above then, in theory, all spaces, including some of those which already exist, could be removed after 15 years. However, if public transport has not, or is not anticipated to improve substantially, delivering the step change necessary in PTAL, and changes to travel to work patterns are not as significant as anticipated, the likelihood of the spaces remaining is high.

11.3 Public transport may never improve sufficiently to warrant the removal of spaces in excess to what is currently being applied for. However, it does respond to relevant factors which will affect the access needs of GSK now and in the future and therefore directly relates to the inter relationship between the location of development and transport provision.

11.4 This application has raised extremely complex planning issues. It undoubtedly presents both benefits and disbenefits to the area, and complies or challenges planning policy. Members will need to come to an ‘on balance’ decision, dependant on the weight they put on ‘exceptional circumstances’ and the risk attached to any permission if they are minded to grant permission.

Option 2 is considered to be the most appropriate resolution to this application. However, this recommendation is finely balanced. As such, both options are included below as a basis for decision.

OPTION 1-REFUSAL The proposal for additional parking spaces is considered contrary to policy T1.4 and Appendix 3 of Hounslow’s adopted UDP as the overall number provided will exceed maximum standards. Exceptional circumstances submitted by the applicant are not considered sufficient to allow the additional parking proposed.

OPTION 2-RECOMMENDATION OF THE BOROUGH PLANNING OFFICER

THAT THE BOROUGH PLANNING OFFICER BE AUTHORISED, UNDER S106 OF THE TOWN AND COUNTRY PLANNING ACT 1990 OR OTHER APPROPRIATE LEGISLATION TO SECURE:

• Pedestrian improvements to facilitate crossing /severance between the North and South of the A4 (specifically the footbridge) • Public Transport studies focussed on improvements to the E8 and the H91, coupled with financial improvements to service quality and frequency. • Improvements to the local cycle network, • Financial contribution to CCTV from Brentford Station to GSK House(sufficient to implement the scheme and ensure adequate surveillance in the future) • Employment training to maximise the take up of local employees and thus minimise the need to travel. • Contribution to a detailed environmental improvement strategy and off site landscape improvements in order to maintain the status of the Great West Road as a ‘Gateway to London’. • Consultation and implementation (subject to response) of a Residents Parking scheme • The promotion of an Area Green Travel Plan which promotes good practise, encourages sustainable modes of transport whilst discourages the duplication and excessive provision of parking spaces. • Agreement with regard to the detailed terms of the temporary nature of the parking arrangements applicable to this application. This will include the review of the GSK Travel Plan at set intervals, the changing travel patterns of the GSK workforce, coupled with an assessment of improvements to Public Transport Accessibility.

That subject to the satisfactory completion of a legal agreement the Borough Planning Officer be authorised to grant planning permission for the following reasons;

In accordance with policy T1.4 of the Hounslow adopted UDP, the Local Planning Authority consider that the exceptional circumstances relating to this proposal are a material consideration and justify parking above normal maximum standards in this instance. These exceptional circumstances include the economic and regeneration impact of the development coupled with the mitigation measures proposed within the S106 Agreement which are considered necessary to overcome the negative impact of the development as well as put in place a mechanism which seeks to promote sustainable means of travel and ultimately reduce reliance on the private car.

Subject to the following conditions

A1 Time limit-full permission B4 Materials to match/samples B5 Detailed applications B8 Prior Approval C29 Hours of construction. Insert (8am-6pm) and (8am-1pm) C34 Illuminations, mud and dust on construction sites E1 Landscaping design proposals E2 Landscape works implementation E4 Screen planting E5 Boundary treatment E6 Landscape management plan E7 Landscape management plan E13 Proposal trees E14 Trees-detailed permission E15 Trees-detailed permission-replacements E16 Existing trees which are to be retained G8 Parking-limit on number of spaces J11 Contaminated Land