planning report PDU/2434/01 22 December 2009 Unit 2, Hannah Close, Neasden London Borough of Brent planning application no. 09/2245

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

The proposal Change of use of warehouse to a materials-recovery facility (MRF), including workshops, offices and 2.5MW biomass CHP plant.

The applicant The applicant is Careys Environmental Services Ltd, and the agent is RPS.

Strategic issues The use of the site for recycling of construction and demolition waste is appropriate in this strategic industrial location, the design of the new buildings is appropriate, and the proposal is acceptable in terms of equal opportunities. However, the applicant needs to provide further information regarding energy, air quality and transport. Recommendation

That Brent Council be advised that the application is broadly acceptable in strategic planning terms, but does not comply with the London Plan, for the reasons set out in paragraph 90 of this report. The possible remedies set out in paragraph 92 of this report could address these deficiencies.

Context 1 On 2 November 2009 the Mayor of London received documents from Brent 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 23 December 2009 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 2B of the Schedule to the Order 2008: ‘’waste development to provide an installation with capacity for a throughput of more than 50,000 tonnes per annum of waste produced outside the land in respect of which planning permission is sought”.

page 1 3 Once Brent has resolved to determine the application, it is required to refer it back to the Mayor for his decision, as to whether to direct refusal or allow the Council to determine it itself, unless otherwise advised.

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 is a vacant B8 warehouse/distribution building at Unit 2, Hannah Close, Neasden within the London Borough of Brent. The site is located to the north of Great Central Way, to the east of Wembley Stadium, and adjoining the site to the north are a series of railway lines and sidings.

6 The site is triangular in shape and approximately three hectares in area including part of the rail sidings. The warehouse building is approximately 12,000 square metres in area with an eaves height of 10.9 metres. It also has an ancillary office of 320 square metres, an engine shed of 105 square metres and a small security hut. The site has rail sidings, an internal access road, hard surfacing, a car park and a landscaped area fronting Great Central Way.

7 The site was previously used as a transport and logistics distribution centre and is surrounded by industrial warehouses.

8 The site has a public transport accessibility level (PTAL) of 1b, on a scale of 1-6, where 6 is most accessible. The site is approximately 0.5km from the A406 North Circular which is part of Transport for London’s Road Network (TLRN). The nearest bus stop is 250m away located on Great Central Way, served by bus routes 92 (Brent Ikea to Ealing Hospital) and PR2 (Wembley Park to Willesden Junction). The nearest Underground station is Neasden, approximately 1km from the site.

Fig 1 and 2: Site location and aerial photo (Source: Application documents)

Details of the proposal

9 The applicant is proposing a change of use and conversion of the existing unit to provide a materials recovery facility (MRF). It is anticipated that the waste throughput will be up to 1.5 million tonnes per annum.

10 The MRF will deal with three main waste streams, namely:

• municipal sold waste (5-10%);

page 2 • commercial and industrial waste – including segregated card, paper, plastics and wood; dry recyclables; glass; and waste electrical and electronic equipment (20-30%);

• construction, demolition and excavation waste – encompassing excavation soils, utility waste soils and other construction and demolition waste products (50-65%).

11 The waste streams will be sourced from Brent, the West London Waste Authority area and Greater London as a whole. Approximately three quarters of the construction waste would come from the applicant. Waste materials would be brought to the site primarily by road, but there being railway sidings within the application site, there is potential to take advantage of the rail link to import and export materials.

12 The proposal includes a biomass CHP plant which would thermally treat approximately 30,000 tonnes of waste wood, to generate both electricity and heat.

13 Physical works that are proposed included external alterations to the existing warehouse, the erection of a 35 metre high flue stack for a biomass CHP plant, and erection of a 3 storey ancillary building (1788 square metres) to provide staff welfare, office and workshop facilities.

14 The MRF would operate 24 hours a day, 7 days a week.

Fig 3: Site Layout Plan (Source: Design and Access Statement)

Case history

15 The lawful use of the site is as a warehouse and distribution centre (Use Class B8) which was granted planning permission in 1986.

16 There is no planning history of a strategic nature that is relevant to this proposal, however the applicant did engage in a series of pre-application discussions with the GLA in the lead up to submission of the planning application. page 3

Strategic planning issues and relevant policies and guidance

17 The relevant issues and corresponding policies are as follows:

• Waste London Plan; the Municipal Waste Management Strategy; PPS10 • Urban design London Plan; PPS1 • Access London Plan; PPS1; Accessible London: achieving an inclusive environment SPG; Planning and Access for Disabled People: a good practice guide (ODPM) • Equal opportunities London Plan; Planning for Equality and Diversity in Meeting the spatial needs of London’s diverse communities SPG; Diversity and Equality in Planning: A good practice guide (ODPM) • Sustainable development London Plan; PPS1, PPS Planning and Climate Change Supplement to PPS1; PPS3; PPG13; PPS22; the Mayor’s Energy Strategy; Sustainable Design and Construction SPG • Ambient noise London Plan; the Mayor’s Ambient Noise Strategy; PPG24 • Flooding London Plan; Mayor’s draft Water Strategy; PPS25, RPG3B • Safeguarded wharves London Plan; Safeguarded Wharves on the River Thames Implementation Report • Transport London Plan; the Mayor’s Transport Strategy; • Parking London Plan; the Mayor’s Transport Strategy; PPG13

18 For the purposes of Section 38(6) of the Planning and Compulsory Purchase Act 2004, the development plan in force for the area are the 2004 Brent Unitary Development Plan, Brent Council’s 2003 add the London Plan (Consolidated with Alterations since 2004)

19 The ‘Destination Wembley’ supplementary planning guidance and the Brent Core Strategy and Site Allocations (informal pre-submission) and Development Control Policies (preferred options) development plan documents are also material considerations.

20 The draft replacement London Plan, which was released for consultation on 12 October 2009, is also a material consideration. Employment

21 The site lies within the Wembley Preferred Industrial Location (which is a subset of Strategic Industrial Locations) as identified in Annex 2 of the London Plan and Annex 3 of the draft replacement London Plan.

22 The London Plan and draft replacement have specific policies to protect, promote and manage the varied industrial offer contained within Strategic Industrial Locations. The London Plan also supports the establishment of green industries (policy 3B.10 of the London Plan and policy). The proposal is an appropriate use for and supports the continued operation of the identified Strategic Industrial Location.

23 Consideration should be given to initiatives for employment and training. The applicant has confirmed its agreement to the imposition of a planning obligation regarding local employment, and subject to this being confirmed, the scheme is in accordance with London plan policy 3B.11 and policy 4.12 of the draft replacement London Plan. Waste management

page 4 24 The London Plan’s strategic framework for waste management is set out in policies 4A.21-29 of the London Plan and policies 5.16 to 5.19 of the draft replacement London Plan. The policies focus on minimising the level of waste generated, increasing re-use, recycling and composting of waste and promoting advanced waste conversion technologies in order to reduce the amount of waste going to landfill and to support London’s environmental industries. London Plan policy 4A.21 and emerging policy 5.16 set a target to achieve recycling and re-use levels in construction, excavation and demolition waste of 95% by 2020. The London Plan also seeks to increase London’s ability to deal with its own waste (to be self-sufficient) through a range of measures, including by increasing waste management capacity. The draft London Plan makes clear that the Mayor supports self-sufficiency (Policy 5.6) and the need to increase waste processing capacity (Policy 5.17). Policy 4A.21 of the London Plan states that the Mayor will work in partnership with others to ensure that facilities with sufficient capacity to manage 75% of London’s waste are in place by 2010, rising to 80% by 2015 and 85% by 2020. The draft London Plan maintains this objective and aims for zero waste to landfill by 2031.

25 Policy 4A.23 of the London Plan and policy 5.17 of the draft replacement identify criteria for the selection of sites for waste management and disposal, namely proximity to the source of waste, the nature and scale of the proposed activity, the environmental impact on surrounding areas, the full transport impact of all movements and maximising the potential use of rail and water transport, and primarily using sites located in Strategic Industrial Locations or existing waste management locations. The policies also seek to maximise the potential use of rail transport for waste collection, transfer and disposal movements. London Plan policy 4A.28 (‘Construction, excavation an demolition waste’) supports the provision of new construction, excavation and demolition waste management facilities in London. Policy 5.18 of the draft replacement London Plan specifically relates to construction, excavation and demolition waste, whereby more beneficial and higher order uses of this inert waste is supported.

26 The ‘Issues and Options’ stage of the West London Waste Plan (WLWP) underlines the need to provide additional waste management capacity in the West of London and Brent, specifically 1,790,000 tonnes of new capacity to meet self-sufficiency by 2025. Of this, 1,176,000 is for new MRF capacity. This will require in the region of 25.2 hectares of land if it were to be provided at a number of smaller sites.

27 The site is located within the Wembley Preferred Industrial Location (PIL) and is within a wholly industrial area. Given the location within a PIL, the need for additional recycling capacity in London and to achieve minimum self-sufficiency targets, the use of this site for waste management purposes is acceptable in principle.

28 The applicant has submitted a waste management plan which details:

• anticipated types and volumes of waste generated on the site;

• how each waste type generated can be re-used, recycled, or recovered;

• procedures for waste disposal;

• how hazardous waste would be segregated and stored appropriately

29 It is anticipated that the waste recovery rate of the MRF will be over 91% by tonnage. The residual waste that cannot be recovered will be further refined to create other products, including energy from waste fuel, with the residual sent to landfill. In this respect, it will be important to ensure that there is maximisation of the CHP system in order to reduce the residual waste, and therefore, as detailed later in the report, details of heat exportation should be confirmed. It is anticipated that up to 890,000 tonnes of waste (76% of the proposed processing capacity) will be transported to the MRF by road. The remaining waste will be sourced by rail utilising the existing railway siding.

page 5 30 Overall, it is considered that the proposal provides the opportunity to deliver significant additional waste management capacity to enable West London and Brent to manage a greater proportion of the waste that they generate and to contribute toward the objections of ‘proximity’ and ‘self-sufficiency in dealing with waste, in accordance with London Plan policies 4A.21-29 and policies 5.16 to 5.19 of the draft replacement London Plan. Design

31 Good design is central to all objectives of the London Plan and is specifically promoted by the policies contained within Chapter 4B (‘Design principles for a compact city’) which address both general design principles and specific design issues. London Plan Policy 4B.1 sets out a series of overarching design principles for development in London. Other design polices in this chapter and elsewhere in the London Plan include specific design requirements relating to maximising the potential of sites, tall and large-scale buildings, built heritage, views, and the Blue Ribbon Network.

32 The draft replacement London Plan reinforces these principles, with new development required to have regard to its context, and reinforce or enhance the character, legibility and permeability of the neighbourhood.

33 The design philosophy for the proposed development has been based upon the need to facilitate the conversion of the existing warehouse building to provide an efficient and safe MRF operation; the requirement to provide ancillary accommodation to support the MRF; and also to enhance the appearance of the site where possible.

34 The external alterations to the existing building are in keeping with the building’s industrial appearance. Except for the proposed flue stack, the bulk and massing of the building would remain unchanged. The flue stack itself, whilst over 30 metres high, is slender, which would mitigate its visual impact.

35 The new ancillary building would front Great Central Way and as noted by the applicant, would provide the opportunity to create a more defined frontage to the site. The building is contemporary and functional in terms of its design, appearance and materials, which is appropriate in this industrial context. The scale of the building is significant less than the warehouse building, such that it would appear subordinate. Conversely its position along the site frontage would also break up the monotony of the existing building.

36 The existing landscaping to the frontage of the site with Great Central Way will be retained and this will be extended along the entire length of the frontage, including to the front of the proposed ancillary building.

Fig 4: Proposed ancillary building (Source: Design and Access Statement)

Access and equal opportunities

page 6 37 Inclusive design principles, if embedded into the development and design process from the outset, help to ensure that all people can use the places and spaces proposed comfortably, safely and with dignity. The aim of London Plan Policy 4B.5 (‘Creating an inclusive environment’) is to ensure that proposals achieve the highest standards of accessibility and inclusion (not just the minimum as required by building regulations). Policy 7.2 of the draft replacement London Plan reiterates these policies. 38 Given the industrial nature of the proposal, comprising as it does the physical handling of waste materials, the majority of the inclusive design standards are not applicable, noting also that the site is not open to the general public. The applicant has, however, confirmed that that the ancillary office building would be DDA compliant, with level entry, lift access, and disabled toilet facilities. Blue badge parking spaces within the staff car parking area have also been shown. 39 It is considered that the measures proposed ensure that the proposal would comply with London Plan policy 4B.5 and draft replacement London Plan policy 7.2.

Climate change adaptation and mitigation

40 The London Plan climate change policies as set out in chapter 4A collectively require developments to make the fullest contribution to tackling climate change by minimising carbon dioxide emissions, adopting sustainable design and construction measures, prioritising decentralised energy supply, and incorporating renewable energy technologies with a target of 20% carbon reductions from on-site renewable energy. The policies set out ways in which developers must address mitigation of, and adaptation to, the effects of climate change.

41 The corresponding policies in the draft replacement London Plan are set out in Chapter 5. These policies follow the same general approach with respect to the energy hierarchy and places greater emphasis on minimising carbon dioxide emissions and making use of decentralised energy systems and networks.

42 An Energy Strategy has been submitted which provides estimates for the energy demand and carbon emissions of the development. The applicant has broadly followed the energy hierarchy of the London Plan and sufficient information has been provided to understand the proposals as a whole and to verify carbon dioxide savings in principle.

Baseline Carbon Emissions

43 The baseline emissions, on a whole-energy basis, have been calculated by the applicant using building regulations approved software. These are calculated to be 5,599 tonnes per annum. The baseline emissions are dominated by the non-regulated emissions associated with the process loads on site.

Energy efficient standards

44 The energy statement proposes a number of energy efficiency measures to reduce the energy demand of the building including improved insulation levels and lighting strategy. These measures will only reduce the carbon emissions of the buildings by 1% compared to the baseline, in part due to the influence of the process loads.

45 It is acknowledged that the process loads would indeed make it difficult to achieve significant reductions by improving the efficiency of the buildings, in particular as the main building is unheated.

District heating

46 The main opportunity with this development is to export heat from the proposed biomass power plant, and in this regard the applicant has investigated possible opportunities. The findings are that

page 7 heat could potentially be exported should enough heat be available after the drying requirements and recycling processes have been settled. It is noted that there are plans for a district heating network in the area closer to Wembley stadium, however, at this stage the energy area action extension plan does not include this particular development area. Noting that the area is categorised by industrial properties, the closest opportunities have been investigated and any surplus heat would be offered to the surrounding industrial units. A list of consultees is provided within the energy strategy.

47 Whilst it is appreciated that there may be limited opportunities for exporting heat, the surplus heat profile needs to be clarified. Furthermore, it is not clear as to the outcome of the consultation process, and this requires clarification.

48 The applicant should also provide information about what measures are proposed to ensure that heat can be exported at a future date.

Combined Heat and Power, Cooling

49 The proposals include combined heat and power capacity of 2.5 MW electrical output and approximately 10 MW heat output. This would reduce the carbon dioxide emissions by 242%. The electricity produced would therefore be counted as offset. As so much electricity is produced, it more than offsets all carbon dioxide emissions associated with the baseline after energy efficiency measures.

50 It is recognised that there would be substantial surplus waste heat resulting from the electricity production and that given that there are limited opportunities to export this heat, there needs to be a clear strategy provided in relation to the heat being produced. Clarification is required as to how much heat would potentially be wasted through the cooling towers and how much would be on-site for processes such as drying and soil sterilisation.

51 In relation to cooling, the estimated cooling demand is relatively low and it is recognised that it is unlikely to be sufficient to make CCHP viable.

Renewable energy

52 The proposals include a biomass combined heat and power (CHP) boiler of approximately 2.5 MW thermal output capacity which would be operated as a joint venture between the applicant and Bioflame Ltd. The intention is that low-grade waste wood will be recovered, pre-shredded and used to fuel the boiler, generate steam and produce electrical power to be exported to the National Grid. The electricity and heat produced from the biomass part of the waste used as fuel in the combustion to raise steam for a steam turbine qualifies as renewable technology. This process would save a total of 13,439 tonnes of CO2 per annum, which as noted above, would result in a 242% reduction in CO2 emissions. The reductions in carbon dioxide emissions are significant.

Climate change adaptation

53 The London Plan contains five principles in policy 4A.9 to promote and support the most effective adaptation to climate change. These are to minimise overheating and contribute to heat island effects; minimise solar gain in summer; contribute to flood risk reduction, including applying sustainable drainage; minimising water use; and protect and enhance green infrastructure. The corresponding draft replacement London Plan policy is policy 5.3. There are specific policies covering overheating, living roofs and water. Further guidance on these policies is given in the Mayor’s SPG Sustainable Design and Construction.

54 Policy 4A.14 of the London Plan and Policy 5.13 of the draft replacement seek to ensure that surface water run-off is managed as close to its source as possible and sets out a hierarchy of preferred measures to achieve this. Policy 4A.16 of the London Plan and Policy 5.15 of the draft replacement seek to ensure that new development has proper regard to the impacts on water demand and existing

page 8 capacity by minimising the use of treated water and maximising rainwater harvesting. Policy 4A.11 seeks major developments to incorporate living roofs and walls where feasible. The corresponding policy within the draft replacement London Plan is policy 5.11.

55 In terms of water efficiency, measures proposed include flow restrictors and meters, together with rainwater harvesting being used for cooling of the CHP system and boiler top up, as well as dust suppression. Natural ventilation will be used in the new building, with louvers and brise soliel, together with a green roof. Whilst the majority of the site is covered by impermeable surfacing, a drainage strategy is proposed, comprising storage tanks fitted with hydrobreaks, and attenuation for 530 cubic metres of rainwater storage. Through its construction and design, the scheme is expected to achieve a BREEAM rating of ‘Excellent’, with two BREEAM predictive assessments having been submitted.

56 Subject to these measures being secured by way of condition, the climate adaptation measures are considered to be acceptable. Biodiversity

57 Opportunities for improvements to biodiversity are limited given the nature of the use and the amount of hardstanding. Land alongside the northern and southern boundaries of the site is identified as wildlife corridors. These corridors provide links between local sites of nature conservation and are protected from fragmentation to prevent isolation of species. There are no features of ecological importance within the proposed development boundary. The proposals include a green roof on the ancillary building, suitable species mix within the landscaping planting, and installation of a series of bird and bat boxes at suitable locations, all of which should be secured by condition. On this basis, the proposal complies with London plan policy 3D.14 and draft replacement London Plan policy 7.19.

Noise

58 The Noise Assessment identifies noise arising from the buildings and operation, including the fixed plant, mobile plant, the Biomass CHP stack and air handling coolers, as well as off-site road noise and noise from the train and the impacts of this noise on nearby receptors. The assessment concludes that only 'neutral’ to ‘minor’ noise impacts are predicted following assessment of the MRF operational noise, and these will occur at a limited number of receptors. The noise assessment concludes that the MRF can operate on a 24 hour, 7 day a week basis without significant impact upon the surrounding environment in terms of noise.

59 The nearest residential area and educational facilities, are some distance (250 - 300 m) from the site and if it is enclosed, the proposal should not generate major noise problems. The applicant has confirmed that trains will be loaded within the building and thus any loading and unloading noise will be contained. Overall, it is considered that given the industrial location of the proposal that there would be no adverse impact in terms of noise levels. Air Quality

60 The London Plan aims to reduce pollutant emissions and public exposure to pollution through a range of measures linked to the Mayor’s Air Quality strategy (policy 4A.19 of the London Plan and policy 7.14 of the draft replacement London Plan). In particular it aims to ensure that formal air quality assessments are undertaken where appropriate for planning applications.

61 The site is located within an Air Quality Management Area and an air quality assessment has been prepared for the environmental statement submitted with the planning application, and this has been found to be generally thorough. There are not anticipated to be any adverse effects related to the construction of the recycling facility or effects from road traffic, dust or odours during its operation.

page 9 62 The primary issues in relation to potential air quality effects are connected to the operation of the proposed CHP plant. At present, the potential effects have been fully evaluated in the context of the existing baseline concentrations of NO2. The screening criteria used in the assessment (derived from the Environment Agency's Horizontal Guidance Note EPR - H1 Part 2), are not intended as an assessment metric for determining the significance of impact based on detailed dispersion modelling results. It is therefore recommended that the applicant undertake a revised assessment following EPUK's document 'Development Control: Planning for Air Quality' whilst also considering more fully representative baseline pollutant concentrations at sensitive receptor locations.

63 There are implications for local air quality should this development proceed. The air quality impact assessment is not considered to be fully conclusive, and as such it is possible that the air quality effects may be significant at some receptor locations. However, as the proposed development will require an Environmental Permit issued by the Environment Agency, the applicant will have to clearly demonstrate adherence to emission limits and the stack height will need to be adequate for dispersal of emissions and the plant will need to be compliant with best available techniques for minimising and abating emissions.

64 The above clarifications should be submitted as part of the Stage 2 referral.

Transport for London

65 The London Plan and draft replacement set the strategic policy framework for development which concentrate upon ensuring that sufficient capacity is provided to meet demand and that transport infrastructure improvements are phased together with or in advance of development. The cumulative impact of developments must also be assessed. There is a strong emphasis on sustainable forms of transport including walking and cycling. Encouraging mode shift and behaviour will be key in achieving these objectives, including preparation of robust and committed travel plans. Reference is also made to TfL’s Transport assessment best practice guidance. Freight is a key objective and in particular protecting sites with freight uses which is also supported by the Land for Transport SPG, London Plan policy 3C.4 policy 6.2 in the draft replacement London Plan.

66 It is noted that a TfL pre-application meeting has been held where principle support for the development proposals on transport grounds was confirmed, subject to a number of detailed issues being addressed in the full transport assessment and through planning conditions and s106 obligations.

67 The transport assessment has been prepared in accordance with TfL’s transport assessment best practice guidance following advice provided by TfL at the pre application meeting. The highway study area was previously agreed with TfL and the council. TfL confirms that the transport assessment is of a very good quality, however in order to make the development acceptable, there are some issues that will need to be addressed, as outlined below.

68 The proposed development will generate approximately 72 am peak hour trips (50 arrivals and 22 departures). For the pm peak there are 24 trips (20 arrivals and 4 departures). The distribution of these trips is spread east and west, however it is assumed that all use the A406, which provides a worst case for TfL. The wider distribution is not clear and would be useful to understand how the site will be managed. This number of trips is unlikely to have an adverse impact on operation of the TLRN. However some careful management of the site and monitoring of trips is essential in ensuring that the local highway network and conditions at junctions serving the North Circular are not worsened in the peak hours, or that vehicles do not tailback onto the local highway when the facility is full or not fully operational. Measures to safeguard this have been included in the transport assessment. The developer should ensure that the majority of trips occur outside the peak period.

69 The trip generation and mode split are accepted for the proposed use in this location, given the site’s existing use. On this basis the application is considered to be in general conformity with London Plan Policy 3C.1 and Policy 6.2 of the draft replacement London Plan. page 10 70 The transport assessment sets out the general layout of the site and how it will be serviced. TfL previously requested information on where and how servicing will be carried out and managed. A delivery and servicing plan has been produced, together with a construction management plan, both of which are welcomed. Both documents are referenced in the travel plan, and these should be secured and enforced by use of planning condition.

71 The site will be served by a one way system and a stacking system is proposed to restrict any backing up onto the highway. The transport assessment states that the anticipated vehicle movements, loading and site access will be managed using an automated number plate recognition system. An on- site traffic management system will be developed to assist safe movement on site. The developer is advised to use operators committed to best practice and who are members of TfL’s freight operator recognition system.

72 .

73 The transport assessment states that a maximum cap of 1.4 million tonnes of waste per annum (mtpa) will be transferred by road. The applicant has confirmed their willingness to accept a planning condition whereby the total weight of material that can be delivered to/from the site by road will be capped at a total of 1.4 mtpa. It is requested that this be clarified in terms of approximate vehicle numbers.

74 In order to confirm a commitment to use of rail freight, it is also expected that a target be placed on waste transfer via rail. For example, the applicant could seek to increase the percentage target from a minimum 24% upwards to say 40% once the rail use has been established. This should be strengthened with a further cap on road trips to ensure that an acceptable balance between road and rail is established. For example highway trips should be capped at 50 peak hour trips as the worst case scenario. This process should be monitored through the travel plan (including delivery and servicing plan).

75 These should be secured through an appropriately worded planning obligation to ensure compliance with London Plan policy 3C.25 and draft replacement policy 6.14

Travel plan

76 A full workplace travel plan has been submitted, which as noted above, include a servicing and delivery plan and construction management plan. The document has passed an ATTrBuTE assessment. The travel plan is in line with TfL’s ‘Guidance for workplace travel planning for development’ and shows strong commitment from the occupier to encourage sustainable travel amongst its staff, visitors and for its fleet movements. It is acknowledged and accepted that it has been difficult to establish baseline travel patterns due to the nature of the land use. It is requested that within 3 months of occupation, an iTRACE compliant travel survey be undertaken to establish these baseline conditions and to enforce proposed targets. The travel plan should be suitably secured through the s106 agreement or by planning condition.

77 TfL wishes to be closely involved in developing and enforcing the travel plan and requests that planning conditions or s106 obligations refer to consultation with TfL. In particular setting and enforcing mode shift targets and reduction and consolidation of highway trips.

78 TfL confirms that these targets are necessary to ensure the planning application is in line with London Plan policy 3C.2 Matching development to transport capacity and policy 6.3 Assessing transport capacity in the Consolidated draft London Plan. The approach is welcomed by TfL

page 11 Car parking

79 The scheme proposes 35 operational parking spaces of which two are blue badge bays. The site has a low level of public transport accessibility and therefore this makes access to the site by non-car modes difficult. The level of car parking is considered to be broadly acceptable for class B1-B8 uses, however this should be capped and closely monitored against the number of staff on site at any one time, which varies from 50 in 2011 to 100 in 2013.

80 The proposals are considered to be in general conformity with London Plan policy 3C.24 and draft revised London Plan policy 6.13. Furthermore two motorcycle parking spaces will be provided.

Electric vehicles

81 The application must include the provision of infrastructure for electric vehicles as required by London Plan policy 4A.3 and the essential standards in the Sustainable design and Construction SPG. Further to this the draft replacement London Plan requires 20% of the total car parking with a further 10% passive provision be for electric vehicles. For passive provision the developer is expected to demonstrate that the additional spaces or points can be provided at the time of implementation or at some time in the future. It is not clear from the application documents where electric vehicle charging points will be located.

Cycle parking

82 The scheme proposes fifteen cycle parking spaces. TfL cycle parking standards require 1 cycle parking space per 500sq m for Class B2-B8 use. Given that the number of employees is set to rise, further space should be safeguarded subject to monitoring through the travel plan. Further information is requested regarding the location, type and safety and security measures as well as the number of spaces that will be allocated to staff and visitors. Given the nature of the proposed use, a segregated cycle access should be provided which ensured safe access for users accessing the site and traversing the site. At present, this is not evident on the plans and should be clearly illustrated. The proposal to include on-site showering and changing facilities is welcomed.

83 In summary, some further work is required to ensure accordance with London Plan policy 3C.22 and draft replacement London Plan policy 6.9.

Pedestrian and cycle access

84 The quality of the pedestrian environment both within the site and in the surrounding area, including paving on roads, has been assessed in accordance with a PERS audit. The site is located in a predominantly industrial area which makes walking and cycling quite hostile with variable levels of severance. The PERS audit showed some deficiencies in pavement width and condition on Hannah Close and Great Central Way which should be two metres. In addition, if a shared cycle/pedestrian route is proposed this will need to be clearly segregated, and where cycle/pedestrian routes are not continuous they should be made so. The Council should also consider whether the guard railing on Great Central Way could be removed. These improvements should ensure that the amber ratings in the PERS audit are brought up to green.

85 TfL requested that a new segregated access for pedestrians and cyclists be provided within the site to ensure that there is no conflict with operational vehicles. It is not clear from the plans whether this has been provided.

86 Further information is required before TfL can confirm compliance with London Plan policy 3C.21 and draft revised London Plan policy 6.10.

Buses

page 12 87 The nearest bus stop is located 250m from the sites on Great Central Way. It has been requested that this bus stop be surveyed and upgraded to ensure that it is designed to TfL Accessible bus stop guidelines (BPT 01/06). The audit does not provide details of kerb heights, and contribution of £5000 may be required to upgrade this stop. The transport assessment does not describe whether operational traffic will impact upon operation of buses in the vicinity. The likely bus trips generated by the development can be accommodated on existing services and therefore no bus contributions are required.

Summary

88 TfL supports the application in principle subject to the information requested above being provided by the applicant prior to determination. In particular TfL will require inclusion of additional targets for rail/road, further clarification and improvements to pedestrian and cycling and details of financial contributions. TfL also requests that it is consulted on changes to the travel plan, delivery and servicing plan and site traffic management system. TfL wishes to see copies of the draft committee report and draft planning conditions prior to determination to ensure that adequate controls have been put in place. TfL is satisfied that the application is acceptable in operational terms and therefore in general conformity with the adopted London Plan and the draft replacement London Plan. Local planning authority’s position

89 Brent Council’s position is as yet unknown. Legal considerations

90 Under the arrangements set out in Article 4 of the Town and Country Planning (Mayor of London) Order 2008 the Mayor is required to provide the local planning authority with a statement setting out whether he considers that the application complies with the London Plan, and his reasons for taking that view. Unless notified otherwise by the Mayor, the Council must consult the Mayor again under Article 5 of the Order if it subsequently resolves to make a draft decision on the application, in order that the Mayor may decide whether to allow the draft decision to proceed unchanged, or direct the Council under Article 6 of the Order to refuse the application, or issue a direction under Article 7 of the Order that he is to act as the local planning authority for the purpose of determining the application and any connected application. There is no obligation at this present stage for the Mayor to indicate his intentions regarding a possible direction, and no such decision should be inferred from the Mayor’s statement and comments. Financial considerations

91 There are no financial considerations at this stage.

Conclusion

92 London Plan policies on strategic industrial locations, waste, design, access, energy, air quality, and transport are relevant to this application. The application complies with some of these policies but not with others, for the following reasons:

• Employment: The proposed use is consistent with the site designation as part of a Strategic Industrial Location and supports the relevant London Plan policies. • Waste: The proposal supports the London Plan policies for waste management in principle. • Design:The design of the scheme is appropriate to its context, in accordance with relevant London Plan and draft replacement London Plan policies.

page 13 • Inclusive design: The scheme has been designed to reflect London Plan and draft replacement London Plan policies in relation to inclusive access.

• Energy: Further information is required in order to demonstrate that the scheme is consistent with London Plan policies regarding district heating and the CHP system.

• Noise: The scheme raises no strategic noise concerns, however, the borough should ensure that it addresses local noise issues appropriately.

• Air quality: The scheme would be subject to an environmental permit which would ensure that the scheme is consistent with London Plan policy 4A.19 and draft replacement London Plan policy 7.14, however further information is required to ensure that there would be no harm to the environment.

• Transport: The scheme is not yet consistent with the London Plan transport policies.

93 Whilst the application is broadly acceptable in strategic planning terms, on the balance it does not comply with the London Plan.

94 The following changes might, however, remedy the above-mentioned deficiencies, and could possibly lead to the application becoming compliant with the London Plan:

• Climate change adaptation and mitigation: A clear strategy for the heat being produced is required, including further information is required in relation to the potential export of surplus heat.

• Air quality: A more detailed air quality assessment should be provided and mitigation measures imposed by way of condition.

• Transport: Further information is required in order to be satisfied that there would not be any adverse impact upon the local highway network, together with a commitment in terms of rail freight, clarification of pedestrian access, cycle parking and electric car charging

for further information, contact Planning Decisions Unit: Colin Wilson, Senior Manager – Planning Decisions 020 7983 4783 email [email protected] Justin Carr, Strategic Planning Manager (Development Decisions) 020 7983 4895 email [email protected] Samantha Wells, Case Officer 020 7983 4266 email [email protected]

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