planning report D&P/0230d/01 12 June 2017 Twyford Abbey in the London Borough of planning application no. 172220FUL

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

The proposal Redevelopment of the site for use as a secondary and sixth form school (D1 Use Class) involving the construction of two part three-storey, part four storey buildings; construction of a single storey building within the walled garden; construction of a single storey swimming pool building; construction of two buildings to provide ancillary offices and accommodation; exterior works to Twyford Abbey including demolition of later additions; and associated tree works; boundary treatments; hard and soft landscaping including the provision of a multi-use games area; and access and parking provision.

The applicant The applicant is Twyford Abbey LLP, the architect is Walters & Cohen and the planning agent is Montagu Evans.

Strategic issues summary Metropolitan Open Land: the proposal constitutes inappropriate development on Metropolitan Open Land, but development of this site is necessary to facilitate the restoration and stewardship of the Grade II listed Abbey building, which is in a ruinous condition. This is the optimum viable use. Very special circumstances have therefore been demonstrated and the proposal is supported in principle as enabling development. It has been demonstrated that the amount of development sought is required to enable the school and sixth form to function, so the impact on openness has been minimised. (paragraphs 13-18) Design and heritage: the proposal to restore the listed Abbey building, demolish the 1960s additions and reinstate much of its historic plan form and interiors is strongly supported. The siting and design of the new buildings has been well considered and there would be no harm to the listed buildings, the settings of which would be significantly enhanced. (paragraphs 20-28)

Recommendation That Ealing Council be advised that, whilst the principle of the proposal is supported, the application does not comply with the London Plan, for the reasons set out in paragraph 43 of this report. However, the resolution of those issues could lead to the application becoming compliant with the London Plan.

page 1 Context

1 On 17 May 2017 the Mayor of London received documents from Ealing Council notifying him of a planning application of potential strategic importance to develop the above site for the above uses. Under the provisions of The Town & Country Planning (Mayor of London) Order 2008 the Mayor has until 27 June 2017 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:

 Category 3D: Development on land allocated as Metropolitan Open Land in the development plan, 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.

3 Once Ealing Council has resolved to determine the application, it is required to refer it back to the Mayor for his decision as to whether to direct refusal or allow the Council to determine it itself.

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

5 The site comprises the long-vacant, Grade II listed Twyford Abbey, set in approximately 5.4 hectares of grounds. The site is bound to the north by the , to the south by Twyford Road and West Twyford Primary School and to the east and west by the rear gardens of residential properties. The whole site is designated Metropolitan Open Land (MOL).

6 The Abbey and its walled garden are statutory listed Grade II and the Abbey itself is on Historic ’s Register of Buildings at Risk, having been vacant since 1991. The buildings are now in a very poor state of repair. The last use was as a nursing home, which ceased due to statutory changes in the requirements for healthcare premises. St Mary’s West Twyford Church, another Grade II listed building, is located close to the western site boundary. The site is also within an Archaeological Interest Area and all trees are covered by a preservation order. Most of the site is in Flood Zone 1, although parts of the site are within Flood Zones 2 and 3.

7 The North Circular (A406) forms part of the Transport for London Road Network. The nearest bus stop to the site is the southbound stop on the A406 adjacent to the northern boundary, which is served by route 112. The 226 can also be accessed from Twyford Abbey Road/Bodiam Way, close to the south-western corner of the site. Hanger Lane (Central Line) and () stations are approximately 600 metres and 800 metres walk from the site respectively. The site records a Public Transport Accessibility Level (PTAL) score of 2, although the south-western corner has a score of 3.

Details of the proposal

8 It is proposed to demolish the two 1960s nursing home extensions to the Abbey followed by restoration and conversion of the building to educational use. New buildings are also proposed within the grounds, also for educational and ancillary use, totalling 12,835 sq.m., as well as sports facilities in the form of an assembly hall, sports hall, outdoor all weather courts/MUGAs and an indoor swimming pool. Comprehensive site landscape restoration works are also proposed. The development would accommodate an independent co-education secondary school and sixth form for up to 1,150 pupils with 8 forms of entry.

page 2 Case history

9 The site has been the subject of a number of applications for other uses. In the mid-1990s a proposal for a hotel and leisure complex was recommended for approval, but not granted permission due to Department for Transport objections about access. There have also been a number of proposals for residential development, including a 2001 application (ref D&P/0230) for 121 residential units that was withdrawn by the applicant, a 2005 application (ref D&P/0230a) for 317 residential units that was refused by Ealing Council and a 2012 application (ref D&P/0230b) for 92 residential units that remains undetermined.

10 This scheme was the subject of pre-application discussions, with a pre-application meeting held on 24 January 2017. GLA officers supported the principle of the redevelopment of the site with an enabling educational development to facilitate the restoration and future stewardship of the listed building. Strategic planning issues and relevant policies and guidance

11 The relevant issues and corresponding policies are as follows:

 MOL and enabling development London Plan; NPPF;  Design and heritage London Plan; Character and Context SPG;  Inclusive design London Plan; Accessible London: achieving an inclusive environment SPG;  Sustainable development London Plan; Sustainable Design and Construction SPG;  Transport and parking London Plan.

12 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 Ealing Core Strategy DPD (2012) and Development Management DPD (2013). Also relevant is the Ealing Planning for Schools DPD (2016). The 2016 London Plan (Consolidated with Alterations since 2011), the National Planning Policy Framework and Technical Guide to the National Planning Policy Framework are also relevant material considerations. Land use principle

Metropolitan Open Land

13 London Plan Policy 7.17 affords the “strongest protection” to Metropolitan Open Land (MOL), giving the same level of protection as Green Belt, where inappropriate development should be refused except in very special circumstances. Paragraph 87 of the NPPF states that inappropriate development is, by definition, harmful to the Green Belt and should not be approved except in very special circumstances. In addition, paragraph 89 of the NPPF states that “a local planning authority should regard the construction of new buildings as inappropriate in Green Belt” and lists exceptions to this.

14 The proposed educational buildings would be inappropriate development on MOL. However, it is acknowledged that some form of enabling development is needed to restore the Grade II listed Abbey as a heritage asset and this can be regarded as very special circumstances where development can be permitted. In this regard, paragraph 140 of the NPPF states that local planning authorities should assess whether the benefits of a proposal for enabling development, which would otherwise conflict with planning policies but which would secure the future conservation of a heritage asset, outweigh the disbenefits of departing from those policies.

page 3 15 As evidenced by the extensive case history, there have been a number of applications on this site for enabling residential development, which have all either been refused or not determined. GLA officers also note the continued degradation in the condition of the Abbey, which now requires urgent works to safeguard its structural integrity that the applicant is currently undertaking, funded at their own risk. This is a finely balanced issue, concerning preservation of the listed building and the character and qualities of MOL, against the need to find the optimum viable use to secure the restoration and long term stewardship of the building and wider site. The principle of enabling development is that it will by definition involve a scheme that would otherwise be unacceptable in planning terms, but is also the minimum amount of development required to restore the heritage asset. The optimum viable use is the one that is most compatible with the fabric, interior and setting of the historic building and may not be the most profitable.

16 As part of the assessment of the previous residential applications, GLA and Council officers questioned whether a purely residential use was the only viable use for enabling development. Other uses have previously been considered, including a hotel, but have been similarly discounted. It is therefore welcomed that an educational use is now proposed, as this will have less impact on the openness of the MOL and the setting of the Abbey. It will also be more compatible with the room layout of the Abbey and will therefore minimise the loss of historic fabric of the listed building, whilst not harming its setting. These aspects are discussed in more detail in the heritage section below.

17 In view of these considerations, GLA officers are of the view that the proposed use is the optimum viable use to enable the restoration and future stewardship of the Grade II listed Abbey and grounds. This would outweigh the disbenefits of departing from policy resisting inappropriate development on MOL and constitutes the very special circumstances required under the NPPF and London Plan Policy 7.17 to justify inappropriate development. The principle of the use of the site as a secondary school and sixth form is therefore acceptable.

18 In support of the scheme, the applicant has submitted detailed curriculum, staffing and room requirements for the school. This concludes that proposed scheme is suitable for the intended number of staff and pupils, with most rooms ranging from 66-84% occupancy – considered normal for a school with such a wide curriculum. A number of sports facilities, including an all-weather pitch, indoor hall and indoor swimming pool, are also proposed, although it is expected that students would have to travel off-site at times to use larger facilities. As such, the amount of floorspace proposed is the minimum required to enable the proper functioning of the secondary school and sixth form. The amount of hardsurfacing has also been minimised and the proposed buildings would not exceed the height of the listed Abbey. Accordingly, the impact on the openness of the MOL has been minimised through the design of the scheme, which is welcomed.

Education development

19 London Plan Policy 3.18 states that proposals for new schools should only be refused where there are demonstrable negative local impacts. Furthermore, Ealing Council’s Planning for Schools DPD identifies a secondary school need for 23 forms of entry by September 2019, although Twyford Abbey is not identified for school provision in this strategy. Whilst the fee-paying nature of the school means that it may not fully satisfy local needs, the provision of a new secondary school and sixth form is supported in line with London Plan policy. In accordance with London Plan Policy 3.18, public access and community use outside of school hours to the indoor hall and sports facilities should be secured through the S106 agreement. Design and heritage

20 London Plan Policy 7.8 states that development should identify, value, conserve, restore, re- use and incorporate heritage assets where appropriate. Twyford Abbey and the walled garden are Grade II listed, as is the nearby Church of St Mary, to the west of the Abbey building and outside of

page 4 the site boundary. The Planning (Listed Buildings and Conservation Areas) Act 1990 sets out the tests for dealing with heritage assets in planning decisions. In relation to listed buildings, all planning decisions should “have special regard to the desirability of preserving the building or its setting or any features of special architectural or historic interest which it possesses”.

21 The NPPF states that when considering the impact of a proposal on the significance of a designated heritage asset, great weight should be given to the asset’s conservation, and the more important the asset, the greater the weight should be. Significance is the value of the heritage asset because of its heritage interest, which may be archaeological, architectural, artistic or historic, and may derive from a heritage asset’s physical presence or its setting. Where a development will lead to ‘less than substantial harm’, the harm should be weighed against the public benefits of the proposal, including securing its optimum viable use. Recent court judgments confirm that considerable weight and importance must be given to any harm caused to a listed building or its setting.

Significance of the heritage asset

22 Twyford Abbey and its walled garden (separately listed) are included in the Statutory List of Buildings of Architectural and Historic Merit (Grade II). As noted in paragraph 6 of this report, the Abbey is identified on Historic England’s ‘Heritage at Risk’ register, at Priority Category A: “immediate risk of further rapid deterioration or loss of fabric; no solution agreed”. As part of the planning submission, the applicant has submitted a Heritage Statement which assesses the significance of Twyford Abbey and its setting. Twyford "Abbey" is not a monastic building, but it does stand on a medieval moated site that has associations with the nearby Grade II listed St Mary’s Church. It dates from the Georgian period, and is the work of a notable architect, William Atkinson, in a Georgian Gothic style. The Abbey is part of a small estate containing the walled garden, an entrance lodge, and other ancillary structures. The listed Abbey, the Church and the walled garden have interrelated settings that extend throughout the estate.

23 Despite the significant loss of the Abbey’s built fabric arising from years of dereliction, it is concluded that the buildings are of significant historical, communal and aesthetic value, and are of particular special interest as a group. The current poor condition of the Abbey in particular is an indication that a scheme of conversion, restoration and enabling development is required in order to save its fabric, as discussed above.

Assessment of heritage impact

24 Along with the conversion of the Abbey building, a number of new buildings are proposed within its grounds. These include a part 3, part 4 storey classroom building along the northern boundary with the North Circular, a part 2, part 3 storey hall and sports building to the east of the Abbey and a single storey swimming pool in the north-western corner of the site. A lightweight single storey structure is proposed within the walled garden and it is also proposed to replace the existing lodge with two 2 storey buildings either side of the entrance gate, as well as construct a small security building adjacent to the service access. Outdoor sports facilities are also proposed, including a MUGA.

25 The siting of the new buildings has been carefully considered to safeguard the relationship between the Abbey, the walled garden and St Mary’s Church. The large southern lawn with its parkland setting and tree-lined approach, which is the largest area of undeveloped space within the site, would be kept free of buildings and enhanced with new landscaping. Vegetation clearance would enable improved views of the Abbey from Twyford Abbey Road and from Brentmead Gardens, enhancing the setting and public appreciation of both the Abbey and St Mary’s Church. The long, single aspect classroom building will provide a valuable noise attenuation function, shielding the school and grounds from traffic noise and visual intrusion from the busy North Circular. The new- build sports and community building has been sited a respectful distance from the Abbey, an

page 5 improvement on the existing 1960s three storey wing in this position, which in GLA officers’ view compromises the integrity of the listed building to a significant degree. Servicing and parking requirements have been carefully considered as part of the landscape masterplan and tucked away into the less sensitive edges of the site.

26 The proposal to clad the new buildings in brick and vertical timber cladding should ensure that they sit comfortably within the pastoral setting of the site and historic context of the Abbey. This will however be dependent on the highest quality of materials being secured by the Council by condition. The quality of detailing will also be important, particularly the hit and miss brickwork and the brickwork recesses to the blank facade of the classroom building, and construction detail drawings should be secured by the Council by condition.

27 The retention of the listed Abbey, reinstatement of much of its historic plan form and restoration of its principal interiors as the administrative heart of the proposed new secondary school and its sixth form is welcomed and greatly preferable to its subdivision into flats. The demolition of the 1960s additions which do little to enhance its character, appearance or integrity is also very beneficial. The erection of a simple glazed link-bridge set back from the facades at first floor level is an imaginative and subtle alteration, a significant improvement on the heavy 1960s infill structure between the south and west wings. The preservation of the notable walled garden and its attached cottage and workshop structures to the north of the Abbey is also welcomed and the lightweight studio structure proposed within would be subservient and compliment the use of this space for outdoor recreation.

Conclusion

28 In accordance with the NPPF and London Plan Policy 7.8, the proposals would safeguard the significance and setting of the Grade II listed Abbey and walled garden, as well as the adjacent St Mary’s Church, causing no harm. The high quality design and landscaping would enhance the setting of these listed buildings. Inclusive design

29 Level access is proposed to all buildings and throughout the site as part of the landscape design without the requirement for handrails. Vertical circulation through all buildings is provided by lifts. The floors of the listed Abbey require reinstatement due to rot and it is proposed to reinstate them at a single level and the link bridge will allow access between the north and south wings. Accessible toilet facilities are provided at all levels of all buildings and accessible shower and changing facilities are located adjacent in the swimming pool and sports hall building. The multi- purpose hall will be accessible, with the stage area designed to allow access for performers of all abilities. The scheme will therefore provide an accessible and inclusive environment throughout, which is supported. Air quality

30 The applicant’s Air Quality Assessment does not include an adequate assessment of the likely exposure of school pupils and staff to poor air quality arising from the proximity to the North Circular Road. The applicant should provide a detailed assessment of the long term air quality standards and detailed consideration of the impact of the northern block on pollutant levels within the outdoor spaces. Furthermore, the internal layout and ventilation strategy for this block should be re-assessed, paying particular regard to potential pollutant levels within the classrooms.

page 6 Flood risk

31 The finished floor levels of the buildings within Flood Zones 2 and 3 are set over 400 millimetres higher than the modelled flood levels. Floodplain compensation storage has been provided by designing in flood storage under the buildings using cellular crates, which also allows flood flows to pass under the building voids unobstructed. Safe access and egress are provided via Twyford Abbey Road as part of the evacuation and warning plan. The proposed drainage strategy is also supported and the proposal therefore complies with London Plan Policies 5.12 and 5.13. Climate change

32 A range of energy efficiency measures are proposed. An overheating analysis has been undertaken, but the applicant should provide evidence of how the cooling demand will be minimised, to comply with London Plan Policy 5.9. The applicant has carried out an investigation and there are no existing or planned district heating networks in the area, although given the proximity to the Old Oak Park Royal Opportunity Area the applicant should investigate whether there are plans for a network in proximity to the site. A commitment to enable future connection should be provided. The applicant should demonstrate through a detailed analysis why a CHP-led site wide network is not appropriate. The applicant has investigated the feasibility of a range of renewable energy technologies and is proposing to install photovoltaic panels, but should demonstrate that the roofspace has been fully utilised.

33 An on-site reduction of 82 tonnes of carbon dioxide per year in regulated emissions compared to a 2013 Building Regulations compliant development is expected. This is equivalent to an overall saving of 35%. The carbon dioxide savings meet the requirements of London Plan Policy 5.2, although the detailed comments should be addressed in order to comply with the London Plan climate change policies. Transport

Access

34 The proposed school will use two existing access points from Twyford Abbey Road, plus a new pedestrian access point from the A406. The western access on Twyford Abbey Road will be used as the main entrance for visitors, school minibuses and coaches and as such a turning area has been included. The eastern access will be used solely for delivery and servicing vehicles, the use of which will be restricted during the AM and PM peaks. The proposed access arrangements are supported.

Trip generation and catchment

35 The trip generation analysis shows 100 two-way vehicle trips in the AM peak and 109 in the PM peak. The proposed figure for car trips is high, and should be reduced with the assistance of a robust, effective travel plan.

36 The proposed impact on the public transport network is generally acceptable, although further information is requested regarding the school’s catchment to determine the impact on the local bus network. A private school bus service will be operated using a combination of minibuses and coaches serving the catchment area. The acceptability of this approach and the general impacts on buses as a result of the proposed school will be determined following further discussions with TfL.

Car parking

37 34 car parking spaces are proposed, including 4 blue badge spaces. No spaces will be available for staff. Electric vehicle charging point (EVCP) provision meets the London Plan standards.

page 7 The applicant should provide further information for how on-street parking in surrounding roads will be managed, given that the demand from the development is likely to exceed availability.

Walking and cycling

38 The Council should secure the improvements identified in the PERS and CERS audits undertaken. The proposed quantum of cycle spaces meets London Plan requirements, however there are concerns over the wheeling ramp access to the basement of the Abbey, where the majority of cycle parking will be located. It is noted that access to the basement is constrained in this listed building, but the applicant should investigate whether a cycle lift access could be provided to one of the basement accesses.

Servicing, construction and travel planning

39 The submitted Delivery & Servicing Management Plan (DSMP) proposes 20 daily deliveries, which is considered excessive and this should be clarified. The DSMP also refers to deliveries not taking place during the peak hours and this should be secured by condition. The Construction Traffic Management Plan (CTMP) is welcomed and should also be secured by condition. The measures including in the Travel Plan (TP) are welcomed and a revised TP, including targets for 3 and 5 years after occupation, should be secured by condition or S106 agreement. Local planning authority’s position

40 An update from the Council will be presented verbally at the meeting. Legal considerations

41 Under the arrangements set out in Article 4 of the Town and Country Planning (Mayor of London) Order 2008 the Mayor is required to provide the local planning authority with a statement setting out whether he considers that the application complies with the London Plan, and his reasons for taking that view. Unless notified otherwise by the Mayor, the Council must consult the Mayor again under Article 5 of the Order if it subsequently resolves to make a draft decision on the application, in order that the Mayor may decide whether to allow the draft decision to proceed unchanged, or direct the Council under Article 6 of the Order to refuse the application. There is no obligation at this present stage for the Mayor to indicate his intentions regarding a possible direction, and no such decision should be inferred from the Mayor’s statement and comments. Financial considerations

42 There are no financial considerations at this stage. Conclusion

43 London Plan policies on Metropolitan Open Land, education, design and heritage, inclusive design, air quality, flood risk, climate change and transport are relevant to this application. The principle of the proposed secondary school and sixth form, as an enabling development to facilitate the restoration of the listed building, is supported. A number of outstanding concerns are raised with regard to the land use, air quality, climate change, and transport:

 Land use principle: in accordance with London Plan Policy 3.18, public access and community use of the hall and sports facilities should be secured through the S106 agreement.

page 8  Air quality: in order to comply with London Plan Policy 7.14, the applicant should provide a detailed assessment of air quality standards within the scheme and address concerns over the impact of pollutants within the classrooms.

 Climate change: the energy strategy does not fully accord with London Plan Policies 5.2, 5.6, 5.7 and 5.9. Further information regarding overheating, the on-site heat network and renewable energy is required. The final agreed energy strategy should be appropriately secured by the Council.

 Transport: in order to comply with London Plan Policies 6.3, 6.9, 6.10, 6.11, 6.13 and 6.14, further discussion is required to determine any impact on local buses and the proposed private bus service should be secured. Furthermore, the applicant should address concerns over car parking and cycle parking access. A delivery and servicing plan, construction logistics plan and travel plan should be secured by condition or S106 agreement.

for further information, contact GLA Planning Unit (Development & Projects Team): Juliemma McLoughlin, Assistant Director – Planning 0207 983 4271 email [email protected] Sarah Considine, Senior Manager – Development & Projects 020 7983 5751 email [email protected] Nick Ray, Senior Strategic Planner, case officer 020 7983 4178 email [email protected]

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