GURNELL LEISURE CENTRE FULL PLANNING APPLICATION

ALTERNATIVE SITE ASSESSMENT APRIL 2020

Gurnell Leisure Centre

London Borough of Ealing

Alternative Site Assessment

Prepared by Barton Willmore LLP on behalf of Ecoworld Ltd.

October 2019

Gurnell Leisure Centre

London Borough of Ealing

Alternative Site Assessment

Prepared by Barton Willmore LLP on behalf of Eco World Ltd.

Project Ref: 24313/A5 Status: Pre-App Issue Issue/Rev: 04 Date: 27th November 2019 Prepared by: Andrew Lightstone Checked by: Bob McCurry

Barton Willmore LLP 7 Soho Square London W1D 3QB

Tel: 0207 446 6849 Our ref: 24313/A5/AL Fax: 0207 446 6889 Email: [email protected] Date: 27th November 2019

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CONTENTS

PART A - PROJECT CONTEXT ...... 6 1.0 INTRODUCTION ...... 1 PART B – METHODOLOGY ...... 8 2.0 PROPOSED ASSESSMENT METHODOLOGY ...... 8 3.0 STAGE 1: LONG LIST CREATION AND SIEVING ...... 9 4.0 STAGE 2: MINI ASSESSMENTS ...... 14 5.0 STAGE 3: CAPACITY STUDY ...... 30 6.0 STAGE 4: DETAILED SITE ASSESSMENT ...... 34 PART C – RESULTS SUMMARY ...... 42 6.0 LONG LIST SIEVING ...... 38 7.0 STAGE 2: MINI-ASSESSMENTS ...... 49 8.0 STAGE 3: CAPACITY STUDY ...... 55 9.0 STAGE 4: DETAILED SITE ASSESSMENT ...... 56 PART D – CONCLUSION ...... 62 CONCLUSION ...... 62

APPENDICES

APPENDIX 1 : STAGE 1: LONG LIST CREATION AND SIEVING

APPENDIX 2 : STAGE 2: MINI ASSESSMENTS FOR URBAN SITES

APPENDIX 3 : STAGE 2: MINI ASSESSMENTS FOR PUBLIC / COMMUNITY OPEN SPACES

APPENDIX 4 : STAGE 2: MINI ASSESSMENTS FOR GREEN BELT SITES AND METRPOLITAN OPEN LAND

APPENDIX 5 : STAGE 3: CAPACITY STUDIES

APPENDIX 6 : STAGE 4: DETAILED SITE ASSESSMENTS

PART A - PROJECT CONTEXT

Gurnell Leisure Centre Introduction

1.0 INTRODUCTION

Background

1.1 Gurnell Leisure Centre (GLC) opened in 1981 and is one of London’s busiest leisure centres. The current usage of GLC is as high as it has ever been: in 2009 the total number of visits to the centre was 531,201, and by 2016 this rose to 692,906, an increase of 30% in 7 years. In the same period, the number of children enrolled on the Swim School scheme rose from 2,301 in 2009 to 3,741 in 2016, an increase of 62% in 7 years - meaning that it is the largest ‘learn to swim’ school in London. The centre is also home to Ealing Swimming Club, the largest swimming club in the country.

1.2 However, the leisure centre is near the end of its operational life. It either requires a significant level of repair to bring it up to modern standards or else its complete redevelopment is required. The latter is the preferred option as any retrofitting would have a considered cost of only marginally less than that of a wholesale replacement – though with few of the benefits of a new leisure centre custom designed for modern usage.

1.3 In this respect, the Ealing Sports Facility Strategy 2012-21 identifies the redevelopment of GLC as being of key importance to the provision of water space in Ealing, addressing both existing latent demand and potential future demand for access to pool space for participation in Ealing.

Opportunity and Importance

1.4 GLC is not just a local asset but has the opportunity to be a regionally significant facility, given that it offers a 50m pool. London currently only has four indoor 50m swimming pools, including GLC. This is compared to Paris which has over twenty, so it is clear that London is lagging behind in this aspect.

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Vision

1.5 The vision is to deliver a new flagship leisure centre to create a first-class leisure destination for existing residents and future generations. The new destination facility needs to have the ability to accommodate a ten lane 50m pool (four additional lanes), a themed leisure pool focused on engaging families with under 8’s, a large gym, a themed soft play area and café. In addition, the indoor studio space and outdoor facilities should be provided.

1.6 A new leisure centre and its wide range of programmes for people of all abilities will contribute greatly to the aims and objectives identified in the Council’s Health and Wellbeing Strategy 2016-21 and seek to contribute to sustaining good health and wellbeing for the wider community.

1.7 The new facility should therefore have a positive impact on a number of active residents, especially amongst sedentary target groups, and will also focus on engaging families by offering inclusive, family orientated and innovative activity programmes designed to encourage people of all ages and abilities to start and stay active.

1.8 When this new facility becomes operational the number of visitors are expected to increase significantly, anticipated to reach 1 million per year.

Proposal

1.9 Whilst GLC is well used, it is in need of a significant level of repair and investment. In fact, it is near the end of its operational life - the industry standard lifespan for similar facilities is 30 years and GLC has already been open 35 years.

1.10 As noted above, refurbishment and retrofitting of the existing facility was considered as a first option, however it was ruled out as it would likely cost around 80% as much as providing an entirely new facility, and would be without the benefits that a new facility could bring. The level of refurbishment required to the structure, roof and plant areas would also result in a prolonged closure of the centre, with individual facilities and spaces likely to be unusable for much longer.

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1.11 Consequently, in March 2015, the London Borough of Ealing (LB Ealing) Cabinet made the decision to close down the existing centre and construct a modern, energy efficient building that could deliver the leisure facilities required to meet the needs of the local and regional community.

1.12 LB Ealing are working in partnership with Eco World Limited for the duration of this project. Accordingly and as LB Ealing’s Capital Investment Programme are part funding the scheme, the brief for the new leisure centre has been compiled by them. This brief includes the requirement for a ten lane 50m pool (four additional lanes) with moveable floor and booms which would allow the pool to be subdivided for different user groups; a themed leisure pool focused on engaging families with under 8’s; an enalrged gym; double the amount of studio spaces allowing for more group based exercise classes to be offered; a themed soft play area; and café which can generate further revenue.

1.13 These additional indoor leisure facilities are intended to be combined with outdoor enhancements to the adjacent park in order to provide clubs and sporting organisations with the opportunity to use quality training and competition facilities as well as ancillary facilities that meet the needs and requirements of their sport. The borough-wide requirement for such facilities is illustrated in LB Ealing’s Sports Facility Strategy (2012-2021) and their Playing Pitch Strategy (2017-2031). Both of these documents were compiled with input from Sport England to ensure accuracy and robustness.

1.14 The creation of a single new leisure facility alongside the ehanced park would achieve key Council targets, enabling the delivery of benefits for its residents across three key strategic areas:

a. Promoting Health, Wellbeing and Independence, enabling healthy lifestyles is part of making Ealing a Healthier Borough; the first strategic theme to be met by this project. A key aim of the Council’s Corporate Plan is supporting the delivery of the borough’s health and wellbeing offer by maximising the use of park, leisure and sports facilities to encourage healthy lifestyles including the redevelopment of GLC.

b. Housing quality and supply, whereby the enabling residential uses of the project will result in the provision of 612 new homes.

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c. The third strategic theme on which the project has a real positive impact is Place and public realm, driving improvements to the wider environment. The new and much enhanced indoor and outdoor sporting and recreational facilities will have a significant impact on people’s lifestyle choices and future wellbeing.

Funding

1.15 LB Ealing have carefully considered how much of the new leisure centre they can fund directly, having undertaken a full assessment of the funding options available.

1.16 Accordingly, the resulting Funding Assessment found that, in the context of ongoing savings which the Council needs to find in the period until 2020/21 (at least), LB Ealing are unable to fund the leisure centre through borrowing. This is due to the Council’s legal obligation to meet a balanced budget, across a range of council services, on behalf of its residents.

1.17 The Assessment also considers LB Ealing’s Medium Term Financial Strategy (MTFS). The MTFS allocates funding across the full range of the Council’s services, including identifying and allocating the receipts from any potential capital receipts and/or revenue funding streams. Discussions with LB Ealing Officers revealed that funding generated through this process has already been allocated within the Council’s budgets and that there is no provision available for Gurnell.

1.18 However, as LB Ealing are fully committed to the project and to the provision of the new leisure centre, they have assessed the potential to dispose of assets further to those originally considered as part of its MTFS. Accordingly, the Council have now successfully been able to generate substantial additional capital receipts as part of their future Asset Management Programme. These funds have thusly been allocated towards funding of the new leisure centre through LB Ealing’s May 2016 Cabinet.

1.19 Further to this, LB Ealing have carefully considered the potential for outside funding from charity of other sources. The largest possible funder would be Sport England . However, following discussions between LB Ealing and Sport England, it was confirmed that Sport England would not be in a position to fund this project given the limited level of Strategic Project funding they have; the majority of which has already been committed to projects already in development. Consequently, with LB Ealing only able to commit towards a proportion of the cost of funding a new leisure centre, there is currently a substantial funding shortfall.

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1.20 In seeking to plug the gap, LB Ealing have entered into a joint-venture with the developer, Eco World, in order to provide residential uses to help generate additional revenue. The new leisure facility is therefore proposed to be part-funded by LB Ealing directly and part-funded through enabling 612 residential units.

Viability

1.21 A Financial Appraisal, submitted with this application, has been undertaken to determine the quantum of enabling residential development that is required in this instance to plug the gap and allow for the leisure centre’s construction.

1.22 The appraisal sets out the minimum required provision of residential floorspace required in order to generate sufficient funding to fill the gap between LB Ealing’s contribution and the total cost of the leisure centre. Based on a mixed provision of Build to Rent and private for sale units, this floorspace equates to approximately 612 units. These 612 units would therefore constitute enabling development to part-cross- fund the new leisure centre.

1.23 As is set out in the accompanying Financial Appraisal, a deliverable and fair approach has been taken to both the revenue streams and cost inputs to try and ensure that the amount of enabling development required is accurately calculated; and that it is as minimal a quantum as possible.

Purpose of this Document

1.24 As above, it has been established that there is a need for a new leisure centre (which would involve the associated demolition of the current facility) alongside a need for 612 enabling residential units to cross-fund its construction.

1.25 The existing site however, currently occupied by the leisure centre, associated car parking and wider open space, is designated Metropolitan Open Land (MOL). MOL is defined as “strategic open land within the urban area” that “plays an important role in London’s green infrastructure”.

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1.26 Accordingly in replacing the leisure centre in this location alongside the required enabling residential uses, Draft London Plan (2017) Policy G3 is relevant which seeks to protect MOL. It states that “development proposals that would harm MOL should be refused” on the basis that MOL protects and enhances the open environment – improving Londoners’ quality of life by providing open space and facilities suitable for sporting and leisure uses. The supporting text for Policy G3 states that the principles of Green Belt policy should be applied to MOL land.

1.27 In this respect, paragraph 144 of the National Planning Policy Framework (2019) is relevant which, with regards to Green Belt, notes that:

“Inappropriate development is, by definition, harmful to the Green Belt and should not be approved except in very specicl circumstances.

When considering any planning application, local planning authorities should ensure that substantial weight is given to any harm... Very Special Circumstances will not exist unless the potential harm… by reason of inappropriateness, and any other harm resulting from the proposal, is clearly outweighed by other considerations.”

1.28 In line with the NPPF and draft London Plan above therefore, any proposal for a new leisure centre and residential development on the existing site is contrary to national and regional policy on the basis that it would constitute inappropriate development . Such development would only be allowed on the current site in Very Special Circumstances (VSC) whereby the potential harm of the proposal is outweighed by other factors.

1.29 As is set out in the accompanying Planning Statement and assessed in more detail in this document, there are a number of benefits associated with reproviding the leisure centre on the existing site alongside the enabling residential uses . However, the requirements of the NPPF and the London Plan are clear in that harm to MOL land must be minimised by inappropriate development.

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1.30 In response to this, it was agreed by the GLA and by LB Ealing that an objective assessment of all other alternative sites must be carried out in order to ascertain if the existing GLC site represents a genuine “site of last resort”. Such an assessment would go towards establishing if the proposal could be delivered on an alternative site with either (i) a greater degree of benefits, or (ii) a lesser degree of harm, than that of the existing GLC site.

1.31 This document thusly comprises the above; first setting out the methodology for reviewing and assessing each of the identified sites in turn; followed by the findings of each assessment. The review of the alternative sites follows a staged sieving approach which reduces an initial long list of sites to a short list of potentially suitable sites. These sites are then subject to a more detailed analysis.

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PART B – METHODOLOGY

Gurnell Leisure Centre Long List Creation and Sieving

2.0 PROPOSED ASSESSMENT METHODOLOGY

2.1 As discussed the aim of the document is to complue an objective assessment of all other alternative sites in order to ascertain if the existing GLC site represents a genuine “site of last resort”.

2.2 The proposed method of doing so is broken into 4 stages, as follows:

1) Long List Creation and Sieving: Formation of a long list comprising 543 sites, sifted via a series of identified parameters in order to progress to Stage 2.

2) Mini-Assessments: Via the sieving process, 183 sites are progressed into the mini-assessment stage, split into three sub-categories of land, being Urban Sites; Public and Community Open Spaces; and MOL and Green Belt Sites.

3) Capacity Studies: From the Mini-Assessment, 15 sites score adequately enough to be further considered for a capacity study.

4) Detailed Assessments: These 15 sites are then moved through to a detailed assessment, in part informed by the capacity study.

2.3 From these 4 stages, a conclusion is drawn as to where there are any suitable alternative sites the GLC.

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3.0 STAGE 1: LONG LIST CREATION AND SIEVING

Minimum Development Parameters

3.1 In compiling a list of alternative sites for assessment, it was first important to devise the baseline and comparative type and quantum of proposed development that was to be accommodated. Accordingly, the two fundamental uses required by this proposal and their respective minimum parameters are set out below.

Leisure Centre

3.2 LB Ealing’s brief stipulates that all essential leisure functions must be accommodated as part of a single new “landmark” facilty. It would therefore be neither feasible nor wanted for the components of the leisure centre to be split up and distributed ac ross other sites as this would fail to meet LB Ealing’s sporting requirements. Accordingly, a complete leisure centre that incorporates the facilities required by LB Ealing and designed and costed in accordance with their brief has been devised by the appointed project architect to comprise a minimum footprint of approximately 0.55ha. This excludes car parking and access roads.

3.3 This footprint could be delivered in any shape or configuration across a site, so long as there is a single rectangular expanse of space suitable for the swimming pool and its associated plant and changing facilities. The pool itself, required to be 10 lanes and 50 metres long, would comprise an area of 0.125ha with the ancillary accommodation also calculated to be 0.125ha – a total required rectancular footprint of 0.25ha.

3.4 Accordingly in searching for an alternative site for the leisure centre, the site must be a minimum of 0.55ha in size, with a shape that allows for an uninterrupted 0.25ha rectangular footprint for the pool.

Residential

3.5 Whilst ideal in the interests of minimising land-take, it is not considered a necessity for all enabling 612 residential units to be provided on the same site as the leisure centre. It is similarly not considered a requirement that all 61 2 units themselves must be delivered on a single site. Rather, where there is scope for the residential units to be apportioned across different sites this should be a matter for consideration.

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3.6 It has thusly been agreed with LB Ealing that in order for a site to be considered suitable it must be able to deliver a “meaningful provision of residential” – a minimum of 50 dwellings.

3.7 As set out in the associated planning statement, the proposed density of the scheme on the existing Site (1.42ha) comprises 431 units per hectare (uph) and 1,083 habitable rooms per hectare (hrph). Given the current context of the Site itself, we would consider the current London Plan Density Matrix to otherwise allow for a minimum density in this location of 100 uph; or 275 hrph. As a balance of the ratio of habitable rooms and units, the scheme proposed is therefore circa 4.5 times the density suggested by the Density Matrix.

3.8 It is acknowledged that, in accordance with draft London Plan Policies D1A and D1B, the opportunities and unique context of the existing GLC Site allow for this level of density to be justified. Assessing every alternative site with this level of density however would be considered unduly onerous – not allowing for minor site constraints; resulting in potential exclusions of sites that could otherwise have still accommodated 50 units albeit at a slightly lower density. Whilst this point is clear, draft Policies D1A and D1B still requires any development to truly optimise the use of a site to secure the maximum degree of benefit. It must also be acknowledged in this respect that residential densities on a site must be pushed in order to generate maximum receipt to fund the leisure centre. An appropriate balance must therefore be struck.

3.9 Accordingly, in excerising objectivity and finding the optimum density balance, the unit capacity of each site is assessed and explored within a range whereby:

• The minimum residential capacity would be calculated based on double the density expressed by the Density Matrix, ensuring optimisation whilst still allowing flexibility to account for site-specific constraints; and

• The maximum residential capacity of a site would be calculated based on 4.5 times the density expressed by the Density Matrix, equivalent to the current proposal on the GLC Site.

3.10 On the basis of the above, utilising a baseline minimum density of double that expressed in the Density Matrix (2 x 100 uph = 200uph), the 50 unit “meaningful

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contribution” would require 0.25ha in space. Accordingly, this would be the minimum size to allow for residential uses.

Defining the Area of Search

3.11 With the key baseline development parameters known, the next stage is to ascertain the area of search for the alternative sites. In this instance, the search area for the potential replacement GLC and associated enabling 612 residential units is defined within the administrative area of the LB Ealing only. The decision to define the area as such is based on the need to re-provide an existing council owned leisure facility, which is currently located within LB Ealing, with associated enabling residential development which is needed to fund the redevelopment. It is therefore not feasible for either the leisure or the residential element of the proposals to be provided outside of the Borough.

Long list: Creation

3.12 The next stage of the methodology is to generate a long list of sites, using the boundary of Ealing as the search area. In creating the long list, only sites owned by LB Ealing are included. It is not considered feasible for privately owned sites to be included because the joint venture would not be able to compete with the private market to purchase them. Further, given the funding gap already present in the leisure centre’s construction, the joint venutre would be starting from a deficit land value position.

3.13 Purchasing privately owned sites would also have timescale implications - whereby even if private land could be purchased, it would likely take a considerable amount of time prior to identify, purchase and then prepare an application. This is not acceptable given the critical timescales required to replace the GLC which, as noted above, is already operating beyond its expected operational life.

3.14 In order to compile the long list, the project team obtained a list of all LB Ealing owned sites that were located within the Borough’s administrative boundary. Eco World Ltd currently own no assets or sites within this area.

3.15 With regards to those sites which are on Green Belt or MOL, they typically comprised expansive areas with no ownership changes between them. Accordingly and as agreed with the Council, these larger sites where appropriate were subdivided along the boundaries of any respective land use designations (MOL / GB / Public Open

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Space (POS) / Community Open Space (COS)) as these typically denoted changes to the use or function of the land. This would allow for a more accurate assessment of a smaller site.

3.16 Accordingly, as illustrated in Appendix 1 the long list comprises a total of 543 individual LB Ealing owned sites that are to be progressed through to assessment.

Long List: Cascade Sieving

3.17 As illustrated in Appendix 1, the first stage of assessing the long list sites comes by way of a high level “Cascade Sieve” which would exclude those sites which, fundamentally, are either inappropriate, unsuitable or unavailable.

3.18 The sites are considered sequentially, first of all reviewing the suite of ‘urban’ sites that otherwise have no other designations or protections. This follows the NPPF’s preference for prioritising the utilisation of brownfield land if this is an appropriate option.

3.19 Following this, sites designated as POS and COS are considered. These sites are locally protected by LB Ealing as spaces which are, fundamentally, to be retained as open space or community uses. There are however a number of POS and COS sites also designated as either MOL or GB. Given the national significance of the MOL and GB statuses, such sites are assessed separately as below.

3.20 The third suite of sites included in the long list for assessment are the MOL and Green Belt sites. Whilst it is acknowledged that the proposed scheme on MOL or Green Belt land is considered inappropriate development, there is a possibility that there are such sites within the borough that are more suitable than the existing. As such, it was considered comprehensively robust to review them as part of this assessment.

3.21 The sieving process is based on a cascade methodology, by which if the first criteria is not met, the site is not considered further. This creates an ever decreasing list of sites which, by sequence, become increasingly more suitable for the proposed development.

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3.22 The three criteria selected for the cascade sieve were formulated to respond to the minimum development parameters set out in more detail above. These criteria are as follows:

1. Size: The site must measure greater than or the same as 0.25ha Justification: As set out above, the intention of this ASA is to find a site or set of sites that are capable of delivering a new leisure centre in its entirety and / or a minimum of 50 residential units up to a total of the requisite 612 enabling dwellings. Working at a minimum residential density of double that expres sed in the London Plan Density Matrix (200uph), a minimum of 50 residential units could be accommodated on a site comprising a minimum of 0.25ha in size. It should be reiterated here that 0.25ha would not be large enough to accommodate a leisure centre – for which a minimum of 0.55ha is required. However, as any alternative site must be assessed for its capacity to accommodate, either together or separately, residential and a new leisure centre, it was not considered appropriate to use the 0.55ha as a minimum threshold for the cascade sieve. The specific needs of the leisure centre will be assessed at a later stage.

2. Medium Term Financial Strategy (MTFS): The site should not have already been allocated for disposal as part of the Council’s MTFS programme. Justification: If the site has already been allocated for disposal it means that funds from its future sale have already been factored into the Council’s delivery of services. Accordingly, the commitment to dispose of a site means it is not possible to include as part of this development. It should be noted here that LB Ealing’s property team confirmed that the nature of services being funded through the disposal of assets is ringfenced. Thusly, even with these disposals, no additional funding is available towards the reprovision of Gurnell Leisure Centre beyond that already committed to.

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3. Availability: The site must be generally available so as to ensure a prompt commencement of construction. Justification: A site’s inclusion as part of the MTFS aside, the reasons why a site may not be available for the proposed development are set out below: (i) Whilst owned by the Council, it is leased out to a third party with there still being a substantial amount of time left remaining on the lease (more than 30 years). (ii) The Council may lease the land though the wider site or building is in freehold ownership to a third party. (iii) If the site is a cemetery, to allow for its redevelopment it must be deconsecrated. The Ministry of Justice must then grant a license for the existing remains to be exhumed. Neither of these are certainties. There is then the onus on the developer to relocate the remains to another location. Given the cost and critical timescales required for this project, this level of uncertainty would not be viable. Cemetries have thusly been excluded. (iv) If the site is a council-run allotment, any redevelopment will require consent from the Secretary of State (SoS). In granting this, the SoS must be satisfied that adequate provision will be made elsewhere for existing allotment holders, or else formally recognise that such provision is unnecessary. This is set out in Section 8 of the Allotments Act 1925 and carried into the “Allotment Disposal Guidance: Safeugards and Alternatives” (2014) policy document prepared by the Department for Communities and Local Government. This level of uncertainty therefore makes redeveloping council-run allotments unviable. (v) If the site is already part of a wider plan for redevelopment, as part of an implemented planning permission for example.

3.23 If a site is assessed positively against these three criteria then it would therefore establish the first principle of its redevelopment for a new leisure centre and / or residential, sufficient for it to pass onto Stage 1: Mini Assessment.

3.24 A summary of the results of the Cascade Sieve are contained in Part C, Chapter 6 of this report. The full transcript of results is included at Appendix 1.

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4.0 STAGE 2: MINI ASSESSMENTS

Defining the Criteria

4.1 Those sites that meet the criteria of the initial Cascade Sieve would then be passed onto Stage 2, which entails a Mini Assessment. Rather than excluding these sites based on fundamental baseline criteria as was the strategy with the initial Cascade Sieve, the Stage 1 Mini Assessment would begin to explore each site in more detail – analysing them against a range of criteria and scoring their performance against the benchmark of GLC.

4.2 This strategy will allow for the advantages and disadvantages of locating development on each requisite site to be explored, with any overall environmental harm or benefits able to be identified and considered.

4.3 Based on the current constraints and opportunities of the existing GLC, a set of defined criteria have thusly been created, covering ‘sensitivity to change’ and ‘capacity to meet need, and generate a receipt’. With the view that sites of each type (Urban Sites; Public and Community Open Spaces; and MOL and Green Belt Sites) would qualify for assessment at this stage, it will be important that the criteria are as such to best reflect this.

4.4 In this respect, whilst the purpose of the Mini Assessment criteria is primarily to examine the capacity of a site for change and to meet need, the specific requirements of the leisure centre must also be a consideration. The reason for this is that, whilst a site with few constraints may be appropriate for residential uses, there is no guarantee it would be appropriate for a new leisure centre.

4.5 Thusly, in addition to ascertaining the general capacity of a site both for change and to meet need, it will also be essential for the Mini Assessment criteria to identify the specific “leisure centre only” requirements. The outcomes of these assessments can then be aggregated, allowing for a conclusion to be drawn on a site’s capacity both for residential and, separately, for leisure.

4.6 Accordingly, listed below in Table 1 (Urban Sites), Table 2 (POS and COS Sites) and Table 3 (Green Belt and MOL Sites) are the criteria set to be used to assess each type of site.

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4.7 Table 1: Stage 2 Mini Assessment Criteria for Urban Sites

CRITERIA

Part 1 – General Criteria JUSTIFICATION

1A – Sensitivity to Change

Flooding – What is the Flood Zone Is the site more at risk of flooding than 1. allocation? that of GLC?

Is the site situated within or in close What level of risk would any potential proximity to a Site of Importance for development have on SINC, Green 2. Nature Conservation (SINC) whereby its Corridors or any other Nature development would likely have an adverse Conservation designation, by way of a SINC impact? major risk; minor risk; or no risk? Are there are any TPO’s on site that TPO – Does the site contain a Tree 3. could be harmed by potential Preservation Order (TPO)? development? Heritage Conservation - Does the site contain or is in close proximity to Listed Are there any nearby heritage 4. Buildings? And / or is the site located constraints or assets that could be within or in close proximity to a harmed by potential development? Conservation Area(s)? Is the site is accessible to members of the public, either paying or otherwise Public Access - Does the site have public 5. or is it inaccessible to all? If public, access? then its loss for redevelopment would be adverse on amenity terms. 1B – Capacity to meet need, and generate a receipt Is it more or less accessible by public 6. PTAL – What is the PTAL for the site? transport than that of GLC? Is it considered suburban, urban or central? (definitions considered in Setting – What is the defined setting of accordance with the supporting text of 7. the site? London Plan Policy 3.4). The higher density the location, the greatest scope for larger development The preference is always to ensure PDL is utilised first and foremost in any development. Existence of PDL is Previously Developed Land – Does the site therefore a preference. Note: PDL 8. contain previously developed land (PDL)? includes carparks, MUGA’s, areas of hardstanding and permanent buildings; and excludes paths, roads, temporary structures and turfed pitches. Part 2 – Additional Leisure Centre Criteria (Read in Conjunction with Part 1) Is the site of a sufficient size to Shape (configuration) - Is the site able to accommodate the leisure centre, with a 9. accommodate a 0.55ha leisure centre with shape allowing for a swimming pool? If 10 lane 50m swimming pool? not, then a leisure centre would not fit. Is the site within a 2km geodesic distance of the existing site? The need Catchment & Proximity - Can the site well 10a. for any new leisure centre to continue serve the existing user group catchment? to serve its original population is an essential requirement.

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If so, has the site got better public If yes, does it have better connectivity 10b. transport connectivity to the local (PTAL) than the Leisure Centre? community than the existing site? This criteria will ensure contribution Co-location - Is the site co-located with towards a “sport hub”, which is a key 11. other leisure uses in the near vicinity? LB Ealing aim in meeting their sports and leisure aspirations.

Table 2: Stage 2 Mini Assessment Criteria for POS / COS Sites

CRITERIA

Part 1 – General Criteria JUSTIFICATION

1A – Sensitivity to Change

Flooding – What is the Flood Zone 1. See Table 1 allocation?

Is the site situated within or in close proximity to a Site of Importance for 2. Nature Conservation (SINC) whereby its See Table 1 development would likely have an adverse SINC impact?

TPO – Does the site contain a Tree 3. See Table 1 Preservation Order (TPO)? Heritage Conservation - Does the site contain or is in close proximity to Listed 4. Buildings? And / or is the site located within See Table 1 or in close proximity to a Conservation Area(s)? Public Access - Does the site have public 5a. See Table 1 access? By their very function, POS and COS sites comprise open space highly sensitive to development. Where such open space is publicly accessible (as Is the site located in an area of open space 5b. per criteria 5b) and in an area of open deficiency? space deficiency, its redevelopment would be particularly adverse. Where a site is not publicly accessible however, this criteria would not be applicable. 2B – Capacity to meet need, and generate a receipt

6. PTAL – What is the PTAL for the site? See Table 1 Setting – What is the defined setting of 7. See Table 1 the site? On sites designated for their open space provision, the policy preference is always to ensure PDL is utilised first and foremost. Thusly how does the Previously Developed Land – Does the site site’s PDL provision compare to that of contain any previously developed land; GLC? In this respect, it has been 8. and does it have a bigger combined agreed that a “similar PDL quantum to quantum than that of the existing Gurnell Gurnell” is within 25% of its actual site? provision; between 10,500-17,500sqm.

See Table 1 for what we have assessed as PDL.

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It is recognised that sites with existing built PDL have a greater propensity for redevelopment than sites with only hardstanding PDL. Accordingly, this Quality of Previously Developed Land - criteria compares the level of built PDL Does the PDL include any permanent to that of GLC. In this respect, it has 9. buildings; and do they comprise a been agreed that a “similar built PDL combined larger footprint than the quantum to Gurnell” is within 25% of existing GLC? its actual provision; between 3,375- 6,625sqm.

If there is no PDL on site, this is marked negatively. Part 2 – Additional Leisure Centre Criteria (Read in Conjunction with Part 1)

Shape (configuration) - Is the site able to 10. accommodate a 0.55ha leisure centre with See Table 1 10 lane 50m swimming pool?

Catchment & Proximity - Can the site well 11a. See Table 1 serve the existing user group catchment?

If yes, does it have better connectivity 11b. See Table 1 (PTAL) than the Leisure Centre?

Co-location - Is the site co-located with 12. See Table 1 other leisure uses in the near vicinity?

Table 3: Stage 2 Mini Assessment Criteria for Green Belt and MOL Sites

CRITERIA

Part 1 – General Criteria JUSTIFICATION

1A – Sensitivity to Change

Flooding – What is the Flood Zone 1. See Table 1 allocation?

Is the site situated within or in close proximity to a Site of Importance for 2. Nature Conservation (SINC) whereby its See Table 1 development would likely have an adverse SINC impact? Heritage Conservation - Does the site contain or is in close proximity to Listed 3. Buildings? And / or is the site located See Table 1 within or in close proximity to a Conservation Area(s)? What level of accessibility does the site have and how does this compare to that of Gurnell? LB Ealing have compiled a map showing levels of free Public Access - Does the site have free and 4a. public accessibility onto MOL and GB public access? land so this will be the primary data source. As in Table 1, the more accessible a site, the greater the adverse impact of its redevelopment.

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Is the site located in an area of open space 4b. See Table 2 deficiency?

2B – Capacity to meet need, and generate a receipt

5. PTAL – What is the PTAL for the site? See Table 1 Setting – What is the defined setting of 6. See Table 1 the site? Vehicular Access – Does the site currently 7. See Table 1 have vehicle access?

Previously Developed Land – Does the site contain any previously developed land; 8. and does it have a bigger combined See Table 1 quantum than that of the existing Gurnell site? Quality of Previously Developed Land - Does the PDL include any permanent 9. buildings; and do they comprise a See Table 1 combined larger footprint than the existing GLC? Part 2 – Additional Leisure Centre Criteria (Read in Conjunction with Part 1)

Shape (configuration) - Is the site able to 10. accommodate a 0.55ha leisure centre with See Table 1 10 lane 50m swimming pool?

Catchment & Proximity - Can the site well 11a. See Table 1 serve the existing user group catchment?

If yes, does it have better connectivity 11b. See Table 1 (PTAL) than the Leisure Centre?

Co-location - Is the site co-located with 12. See Table 1 other leisure uses in the near vicinity?

4.8 As above in Tables 1, 2 and 3, sites will be assessed against Parts A and B which are designed to review their capability for any type of development (both residential and leisure centre). Sites will then progress to the “Leisure Centre only” criterion, which will all have to be met (in addition to scoring positively for Parts A and B) if the site is to be shortlisted for leisure centre uses.

4.9 In addition to the above criteria, an ‘Any other notes?’ box will also be introduced to include any pertinent information that is not picked by up the mini assessment that would preclude the site from being considered further – such as site allocations or designations.

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4.10 Alongside the above, for each site an aerial image will also be enclosed so as it is clear to which site the assessment relates. For those Green Belt and MOL sites, as set out above, many were typically quite expansive so have been split up into smaller areas to allow for a more accurate assessment. Accordingly, the aerial images for this sites will also include a red line to show indicatively what area is being assessed.

Defining the Marking Method

4.11 A fundamental aspect of the Stage 2: Mini Assessments is to convert the qualitative features of each site into a quantitative measure. This will allow for a more objective and direct comparison to the existing GLC

4.12 Accordingly, a measureable form of analysis is to be used in these mini assessments with, for each criterion noted above, sites categorised / scored as performing:

• Worse than GLC awarded -1 • The same as GLC awarded 0 • Better than GLC awarded +1

4.13 Whilst an element of judgement may be required in some respects to assess if the any specific degrees of harm or benefit genuinely do outweigh that of GLC, this approach is still considered to be a robust method of analysis that minimises the potential for subjectivity.

4.14 In establishing which sites are then moved on to detailed assessment, due regard has to be given to the policies that govern development on Metropolitan Open Land and outline the Council’s vision for the GLC site and surrounds. These outcomes are fundamental to any site being a satisfactory alternative.

4.15 Paragraph 145 of the the NPPF (2019) states that “A local planning authority should regard the construction of new buildings as inappropriate in the Green Belt. Exceptions to this are: (g) limited infilling or the partial or complete redevelopment of previously developed land, whether redundant or in continuing use (excluding temporary buildings), which would: • not have a greater impact on the openness of the Green Belt than th e existing development; or • not cause substantial harm to the openness of the Green Belt, where the development would re-use previously developed land and contribute to

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meeting an identified affordable housing need within the area of the local planning authority.”

4.16 Policy 5.2 (Protect and Enhance Metropolitan Open Land (MOL)) of Ealing ’s Core Strategy document states that “the Council in realising the potential of the network of Metropolitan Open Land in the borough will promote the following proposals:

“(f) Brent River Park and adjacent MOL (see also Policy 2.9 above): sensitive management of this public parkland for amenity, nature conservation use, and as flood plain; scope for more intensive outdoor recreation uses in the vicinity of Gurnell pool, subject to addressing flood risk issues; improved athletics track and sports facilities. Refurbishment of stable block and animal centre.”

4.17 Policy 5.6 (Outdoor Sports and Active Recreation) of the Core Strategy states that “The Council will:(b) Seek to develop a sports hub as part of this network, with a range of sports provision in the Gurnell area, and the development of several strategic ‘satellite sites’ located strategically to serve communities across the borough.”

4.18 Thus the NPPF establishes that utilising previously developed land to meet an identified affordable housing need can be considered not-inappropriate development in some circumstances, provided it does not cause substantial harm to the openness of the Green Belt (or in this instance MOL, which is afforded the same weight). Ealing’s Core Strategy identifies a vision for enhancing the existing sports facilities and strongly emphasises the desire to build a ‘sports hub’ around the GLC site.

4.19 It is also noted, as per paragraph 1.30 of this document, that it was agreed by the GLA and by LB Ealing that the purpose of this assessment is to ascertain if the existing GLC site represents a genuine “site of last resort”, i.e. there are no better alternative options.

4.20 Therefore, the purpose of the Mini Assessment is to considered if the proposal could be delivered on an alternative site outside of the Green Belt/MOL/open space deisgnations, and if not, than an Green Belt/MOL/open space site with either (i) a greater degree of benefits, or (ii) a lesser degree of harm, than that of the existing GLC site.

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4.21 Bearing that in mind, and alongside the NPPF policies and the Council’s defined Core Strategy outcome for a consolidated sports hub here, urban sites which score the same (0) or greater than the GLC benchmark will be progressed. However, only Green Belt/MOL/Open Space sites which score greater than the Gurnell Site will be progressed to the detailed assessment. Those that score worse or the same as Gurnell will be excluded on the basis that they do not at this point present clear benefits over the existing situation.

4.22 At the end of each mini-assessment will be a summary of the residential (general criteria) score, and a summary of the score resulting from the four additional leisure centre questions (leisure score). The overall site score is the sum of these two numbers.

4.23 It is important to note that despite the overall score, if any site scores less than 0 (i.e. -1) on any of the four leisure criteria, the site cannot proceed for leisure use. This is because the four questions are fundamental to being able to re-provide the GLC on an alternative site, and thus any failures would rule out a site completely in this regard.

Defining the Benchmark

4.24 With the method of marking devised, we set out below the benchmark for each criterion that has been established by GLC. Table 4 illustrates the established benchmark for Urban Site; Table 5 for the POS and COS sites; and Table 6 for the Green Belt and MOL Sites.

Table 4: GLC Benchmark Assessment for Urban Sites Part 1 – General Criteria 1A – Sensitivity to change Criteria Answer

1 Flooding Predominately Flood Zone 3 What is the Flood Zone allocation? with some Flood Zone 2 2 Nature Conservation A large area of the site is Is the site situated within or in close proximity to a Site of designated SINC. However, Importance for Nature Conservation (SINC) whereby its given the site size and development would likely have an adverse SINC impact? development location, any potential harm to SINC is to be minor.

3 TPO No. Does the site contain TPO(s)?

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4 Heritage Conservation No. Does the site contain or is close proximity to Listed Buildings? And / or is the site located within or in close proximity to a Conservation Area?

5 Public Access Yes. Does the site have public access? 1B – Capacity to meet need, and generate a receipt Criteria Answer

6 PTAL 2-3 What is the PTAL for the site? 7 Setting Suburban What is the defined setting of the site?

8 Previously Development Land Yes. Does the site contain previously developed land?

Part 2 – Additional Leisure Centre Criteria (Read in Conjunction with Part 1) 9 Shape (configuration) Yes. Is the site able to accommodate a 0.55ha leisure centre with a 10 lane, 50m swimming pool?

10a Catchment & Proximity Yes. Can the site well serve the existing user group catchment? 10b If yes, does it have better connectivity (PTAL) than the Not Applicable. Leisure Centre? 11 Co-location Yes. Is the site co-located with other leisure uses in the near vicinity?

Table 5: GLC Benchmark Assessment for the Public / Community Open Spaces Part 1 – General Criteria 1A – Sensitivity to change Criteria Answer

1 Flooding Predominately Flood Zone 3 What is the Flood Zone allocation? with some Flood Zone 2 2 Nature Conservation A large area of the site is Is the site situated within or in close proximity to a Site of designated SINC. However, Importance for Nature Conservation (SINC) whereby its given the site size and development would likely have an adverse SINC impact? development location, any potential harm to SINC is to be minor.

3 TPO No. Does the site contain TPO(s)? 4 Heritage Conservation No. Does the site contain or is close proximity to Listed Buildings? And / or is the site located within or in close proximity to a Conservation Area?

Public Access Yes. 5a Does the site have public access? Majority of the site is not Open Space Deficiency 5b located in an area of Is the site located in an area of open space deficiency? deficiency.

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1B – Capacity to meet need, and generate a receipt Criteria Answer

6 PTAL 2-3 What is the PTAL for the site? 7 Setting Suburban What is the defined setting of the site? 8 Previously Development Land Yes. Circa 14,000sqm. Does the site contain any previously developed land; and +/-25%: 10,500 - does it have a bigger combined quantum than that of the 17,500sqm existing Gurnell site? 9 Quality of Previously Development Land Yesl. Circa 4,500sqm. Does the PDL include any permanent buildings; and do they +/- 25%: 3,375sqm – comprise a combined larger footprint than the existing GLC? 6,625sqm (If no PDL exists on the site, then answer as ‘no’)

Part 2 – Additional Leisure Centre Criteria (Read in Conjunction with Part 1) 10 Shape (configuration) Yes. Is the site able to accommodate a 0.55ha leisure centre with a 10 lane, 50m swimming pool?

11a Catchment & Proximity Yes. Can the site well serve the existing user group catchment? 11b If yes, does it have better connectivity (PTAL) than the Not Applicable. Leisure Centre? 12 Co-location Yes. Is the site co-located with other leisure uses in the near vicinity?

Table 6: GLC Benchmark Assessment for Green Belt and MOL Sites Part 1 – General Criteria 1A – Sensitivity to change Criteria Answer

1 Flooding Predominately Flood Zone 3 What is the Flood Zone allocation? with some Flood Zone 2 2 Nature Conservation A large area of the site is Is the site situated within or in close proximity to a Site of designated SINC. However, Importance for Nature Conservation (SINC) whereby its given the site size and development would likely have an adverse SINC impact? development location, any potential harm to SINC is to be minor.

3 Heritage Conservation No. Does the site contain or is close proximity to Listed Buildings? And / or is the site located within or in close proximity to a Conservation Area?

Public Access A mix of semi public and full 4a Does the site have free and open public access? public. Majority of the site is not Open Space Deficiency 4b located in an area of Is the site located in an area of open space deficiency? deficiency. 1B – Capacity to meet need, and generate a receipt Criteria Answer

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5 PTAL 2-3 What is the PTAL for the site? 6 Setting Suburban What is the defined setting of the site? 7 Vehicular Access Yes. Does the site currently have vehicular access? 8 Previously Development Land Yes. Circa 14,000sqm. Does the site contain any previously developed land; and +/-25%: 10,500 - does it have a bigger combined quantum than that of the 17,500sqm existing Gurnell site?

9 Quality of Previously Development Land Yesl. Circa 4,500sqm. Does the PDL include any permanent buildings; and do they +/- 25%: 3,375sqm – comprise a combined larger footprint than the existing GLC? 6,625sqm (If no PDL exists on the site, then answer as ‘no’)

Part 2 – Additional Leisure Centre Criteria (Read in Conjunction with Part 1) 10 Shape (configuration) Yes. Is the site able to accommodate a 0.55ha leisure centre with a 10 lane, 50m swimming pool?

11a Catchment & Proximity Yes. Can the site well serve the existing user group catchment? 11b If yes, does it have better connectivity (PTAL) than the Not Applicable. Leisure Centre? 12 Co-location Yes. Is the site co-located with other leisure uses in the near vicinity?

Stage 2: Mini Assessment Template

4.25 Guided by the benchmark assessments in Tables 4, 5 and 6 above, Tables 7, 8 and 9 below illustrate the Mini Assessment templates pursuant to the Urban Sites ; Public and Community Open Spaces; and to the Green Belt and MOL Sites, respectively.

Table 7: Mini Assessment Template for Urban Sites Part 1 – General Criteria 1A – Sensitivity to change Criteria -1 0 +1 Answers Worse Same Better than as than GLC GLC GLC 1 Flooding What is the Flood Zone allocation?

2 Nature Conservation Is the site situated within or in close proximity to a Site of Importance for Nature Conservation (SINC) whereby its development

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would likely have an adverse SINC impact?

3 TPO Does the site contain TPO(s)?

4 Heritage Conservation Does the site contain or is close proximity to Listed Buildings? And / or is the site located within or in close proximity to a Conservation Area?

5 Public Access Does the site have public access?

1B – Capacity to meet need, and generate a receipt Criteria -1 0 +1 Answers Worse Same Better than as than GLC GLC GLC 6 PTAL What is the PTAL for the site?

7 Setting What is the defined setting of the site?

8 Previously Development Land Does the site contain previously developed land? Part 2 – Additional Leisure Centre Criteria (Read in Conjunction with Part 1)

9 Shape (configuration) Is the site able to accommodate a 0.55ha leisure centre with a 10 lane, 50m swimming pool?

10a Catchment & Proximity Can the site well serve the existing user group catchment? 10b If yes, does it have better connectivity (PTAL) than the Leisure Centre? 11 Co-location Is the site co-located with other leisure uses in the near vicinity?

Any other notes

LEISURE SITE SCORE RESI SITE SCORE

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Table 8: Mini Assessment Template for Public / Community Open Spaces Part 1 – General Criteria 1A – Sensitivity to change Criteria -1 0 +1 Answers Worse Same Better than as than GLC GLC GLC 1 Flooding What is the Flood Zone allocation?

2 Nature Conservation Is the site situated within or in close proximity to a Site of Importance for Nature Conservation (SINC) whereby its development would likely have an adverse SINC impact?

3 TPO Does the site contain TPO(s)?

4 Heritage Conservation Does the site contain or is close proximity to Listed Buildings? And / or is the site located within or in close proximity to a Conservation Area?

5a Public Access Does the site have public access? 5b Open Space Deficiency

Is the site located in an area of open space deficiency?

2B – Capacity to meet need, and generate a receipt Criteria -1 0 +1 Answers Worse Same Better than as than GLC GLC GLC 6 PTAL What is the PTAL for the site?

7 Setting What is the defined setting of the site?

8 Previously Development Land Does the site contain any previously developed land; and does it have a bigger combined quantum than that of the existing Gurnell site?

9 Quality of Previously Development Land

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Does the PDL include any permanent buildings; and do they comprise a combined larger footprint than the existing Gurnell Leisure Centre? (If no PDL exists on the site, then answer as ‘no’)

Part 2 – Additional Leisure Centre Criteria (Read in Conjunction with Part 1) 10 Shape (configuration) Is the site able to accommodate a 0.55ha leisure centre with a 10 lane, 50m swimming pool?

11a Catchment & Proximity Can the site well serve the existing user group catchment? 11b If yes, does it have better connectivity (PTAL) than the Leisure Centre? 12 Co-location Is the site co-located with other leisure uses in the near vicinity?

Any other notes

LEISURE SITE SCORE RESI SITE SCORE

Table 9: GLC Benchmark Assessment for MOL and Green Belt Sites Part 1 – General Criteria 1A – Sensitivity to change Criteria -1 0 +1 Answers Worse Same Better than as than GLC GLC GLC 1 Flooding What is the Flood Zone allocation?

2 Nature Conservation Is the site situated within or in close proximity to a Site of Importance for Nature Conservation (SINC) whereby its development would likely have an adverse SINC impact?

3 Heritage Conservation Does the site contain or is close proximity to Listed Buildings? And / or is the site located within or in close proximity to a Conservation Area?

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4a Public Access Does the site have free and open public access?

4b Open Space Deficiency Is the site located in an area of open space deficiency?

2B – Capacity to meet need, and generate a receipt Criteria -1 0 +1 Answers Worse Same Better than as GLC than GLC GLC 5 PTAL What is the PTAL for the site?

6 Setting What is the defined setting of the site?

7 Vehicular Access Does the site currently have vehicular access?

8 Previously Development Land Does the site contain any previously developed land; and does it have a bigger combined quantum than that of the existing Gurnell site?

9 Quality of Previously Development Land Does the PDL include any permanent buildings; and do they comprise a combined larger footprint than the existing GLC? (If no PDL exists on the site, then answer as ‘no’)

Part 2 – Additional Leisure Centre Criteria (Read in Conjunction with Part 1) 10 Shape (configuration) Is the site able to accommodate a 0.55ha leisure centre with a 10 lane, 50m swimming pool?

11a Catchment & Proximity Can the site well serve the existing user group catchment? 11b If yes, does it have better connectivity (PTAL) than the Leisure Centre? 12 Co-location Is the site co-located with other leisure uses in the near vicinity?

Any other notes

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LEISURE SITE SCORE RESI SITE SCORE

4.26 A summary of the results of the Stage 2: Mini Assessments are contained in Part C, Chapter 7 of this report. The full transcript of each Mini Assessment is included as part of Appendices 2 (Urban Sites), 3 (Public / Community Open Spaces) and 4 (Green Belt and MOL Sites).

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5.0 STAGE 3: CAPACITY STUDY

Rationale for Inclusion

5.1 As set out above, the principle reason for this document is to ascertain if there is a site or else a number of sites that can accommodate the proposed development in a way that delivers either (i) a greater degree of benefits, or (ii) a lesser degree of harm, than that of the existing GLC site.

5.2 Before a detailed assessment of this nature can be carried out however, it wil l first be important to understand how much land in each shortlisted site would be required to accommodate the minimum scale of development. From this, each site can then be reviewed to assess where this development could be located in order to mitigate adverse impacts – with a comparative judgement then being made pursuant to the GLC Site.

5.3 Accordingly, it is accepted that the leisure centre must be delivered in its entirety on a single site. This is a single fixed footprint of 0.55ha whereby 0.25ha must c omprise a single rectable to accommodate the pool.

5.4 The residential element however, comprising a minimum of 50 units ensuring a “meaningful residential contribution”, is the variable in this instant. A minimum 50 unit scheme could, in theory, be delivered across any number of those shotlisted sites. However, the form and footprint of this would vary from site to site depending on its respective context and character.

5.5 This part of the assessment has therefore been established to, for each site:

• Identify the suitable residential density range set out by the current London Plan’s Densiy Matrix (Policy 3.4); • The resulting current London Plan compliant residential capacity of the site ; • The minimum capacity of the site if it were to be optimised (double the Density Matrix guidelines, considered to be the “minimum development parameter” set out earlier in this document and as required by the draft London Plan Policy D6); • The maximum capacity of the site if it were to be optimised (4.5 times the Density Matrix guidelines to reflect the scale of the current proposal on the existing GLC Site).

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5.6 From this, it would then be possible to review:

• How and where a minimum 50 unit scheme could be accommodated on each shortlisted site – alongside respective potential positive and adverse impacts. • Subject to impacts from the above, if there is scope to increase the residential area (and if so, by how much) in order to accommodate more than 50 units in a way that does not unduly impact the existing site.

Defining the Criteria

5.7 The principle for the Capacity Study would be to calculate a site’s minimum and maximum capacity (both double and quadruple the provisions set out in the Density Matrix). For this we would require details of:

• Context and setting (surrounding heights and development quantum); • PTAL; • Size; and • Recommended densities set out in the London Plan Density Matrix.

5.8 This will sit separately to the 0.55ha required for the leisure centre.

5.9 With the above criteria in mind, Table 10 below illustrates the Capacity Assessment template in which all sites shortlisted to this stage will inputted .

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Table 10: Capacity Assessment Template

Site Name and Address

Setting: Number: As per the Site Schedule at The site’s context, prevailing surrounding Appendix 1 heights and built typology.

Aerial Image: PTAL:

Size: (hectares) If relevant, subtract 0.55ha to allow for inclusion of the leisure centre.

Density Matrix: The appropriate range set out by the current London Plan Density Matrix

Guideline Capacity: The total residential capacity of the site in accordance with the Density Matrix.

Min. Optimum Capacity: The total residential capacity of the site at double that of the Density Matrix guidelines. Note, where this figure exceeds 400, a “circa” figure will be used rather than a range.

Max. Optimum Capacity: The total residential capacity of the site at 4.5 x that of the Density Matrix guidelines (commensurate to the current GLC proposal). Note, where this figure exceeds 400, a “circa” figure will be used rather than a range. 50 unit scheme at maximum optimum capacity: The area required for 50 units, if those 50 units were to be provided at maximum optimum density. This is calucluated as follows: (Site Size/Max. Optimum Capacity) x 50.

5.10 The complete Capacity Study Assessments are included as part of Appendix 5 with a summary included below in part of Part C, Chapter 8 of this report.

Defining the Capacity Benchmark

5.11 With the method of density assessment devised, we set out below in Table 11 the density benchmark established by the existing GLC Site. Alongside those sites shortlisted, the data obtained from this assessment will be utilised as part of the individual Detailed Assessments contained within Appendix 6.

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Table 11: Existing GLC Site Capacity Assessment Whilst the Application Red Line encompasses a substantial degree of the surrounding MOL, the parameters of the proposal have been devised on the basis that the focus of any development is the existing PDL (illustrated in blue in the below). Accordingly, the below assessment has been devised on this basis.

Gurnell Leisure Centre, Ruislip Road East, W13 0AL

Setting: Suburban; prevailing typology is semi- Number: N/A detached residential dwellings and flatted blocks ranging in height from 2 – 11 storeys. The north of Aerial Image: the site is entirely open.

PTAL: 3

Size: 1.42 ha

Density Matrix: 35 - 95 units per hectare

Guideline Capacity: 50 - 135 units

Min. Optimum Capacity: 100 – 270 units

Max. Optimum Capacity: Circa 610 units

50 unit scheme at maximum optimum capacity: 0.12ha (with a further 0.55ha leisure centre)

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6.0 STAGE 4: DETAILED SITE ASSESSMENT

Defining the Criteria

6.1 The sites shortlisted to this stage would have so far been assessed against specific environmental and physical constraints in order to evaluate, in an objective manner, their general capacity to accommodate the minimum 50 residential unit quantum of development (and leisure centre where relevant) – with those sites that display fewer adverse impacts progressed. A limitation of this method however is that every site is different in terms of layout, quality and use. Whilst the Mini Assessments did reference these aspects as a potential constraint, actual implications were never explored in detail.

6.2 Accordingly, the Detailed Site Assessment as the final stage of the review will seek to appraise each site on a more specific basis to establish the following:

• Site quality in terms of layout, uses and existing facilities; • The optimum location on the site for the proposed minimum level of development (and leisure centre where relevant) to be located; • Resulting impacts the proposed minimum level of development (and leisure centre where relevant) would have on site quality; • Given the resulting impacts, the scope for the level of residential development to be increased above the minimum 50 unit requirement.

6.3 With regards to resulting impacts, a balanced comparison will be made to the existing GLC Site as the benchmark in order to evaluate if the site in question represents a genuine suitable alternative for development where benefits outweigh any adverse impacts. If this is not considered to be the case then the site will be excluded.

6.4 Accordingly, Table 12 below sets out the key criteria that will be used to assess each shortlisted site. All sites will be assessed through the same set of criteria whether they are Urban, Community and Public Open Space, or Green Belt and MOL land. This will ensure impartiality when compared against the existing GLC Site which is designated MOL.

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Table 12: Detailed Assessment Criteria

CRITERIA JUSTIFICATION

General Site Description Is the site irregularly shaped; what is it bounded by; what designations does it have; what uses is it shortlisted for; and what is the minimum size required to accommodate the 50 residential unit contribution? A – Site Quality

Does the site contain any permanent Site character – Is the site built up in character 1. structures or PDL, or is it entirely or open? greenfield land?

Layout – Are any area of open space formally What is the structure of the open 2. laidout, with defined areas of landscape space, and does it have defined areas character and use? or sections?

Land uses - What are the current land uses What function does the site currently 3. across the site? serve?

Green flag awards or details of LB Ealing’s open space audit if the site Quality recognition – Has the site received any comprises a park. Where it includes a 4. recognition (locally or nationally) for the quality building, are its facilities notable in any of its facilities? way? For instance, if a school, what is its Ofsted Rating?

B – Optimum Development Location

Given the environmental and contextual constraints of the site identified through the previous assessments, what is the optimum location for development (resi and / or leisure) on the site that, whilst causing minimal impact, will ensure it can still viably operate? The considered location will be shown on the adjacent aerial image. 5. Where a site has been shortlisted for both leisure and residential, the locational possibilities will be explored for each use.

The area indicated for the leisure centre will be 0.55ha and the area indicated for the 50 residential units would be as generated through the Stage 2: Capacity Assessment.

C – Impacts of Proposed Development

Site character – To what extent would the What are the impacts and how, if at all, 6. development (if at all) alter or change the site’s do they compare to the existing GLC character? Site?

Layout – Can the development be What are the impacts and how, if at all, 7. accommodated without adversely alteraing the do they compare to the existing GLC form and layout of the site? Site?

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What are the impacts and how, if at all, Land uses - What impact would the 8. do they compare to the existing GLC development have on the existing land uses? Site? Quality recognition – Would the proposed What are the impacts and how, if at all, 9. development have an impact which may do they compare to the existing GLC prejudice any previously received recognition? Site? D – Scope for Development Above 50 Units Do the site conditions allow for an increased level of height or else an increased residential 10. footprint in a way that would not otherwise result in adverse impacts? If so, would this allow the site to accommodate a dwelling provision higher than 50? Final Consideration:

Based on the above factors, does the site present an opportunity to accommodate development in a way that result in fewer adverse local impacts than that of GLC?

Defining the Benchmark

6.5 With the method of assessment devised, we set out below in Table 13 the benchmark established by the existing GLC Site. The impact of development on all shortlisted sites will be compared to this to assessment, on balance, which one is more suitable.

Table 13: GLC Benchmark for the Detailed Assessments Gurnell Leisure Centre General Description: An irregular shaped site comprising the existing leisure centre and car park to the south, with open space to west and north.

The Site is bounded to the north by Stockdove Way, to the west by the railway and to the south by Ruislip Road East. The River Brent bisects through the middle of the site. It is designated in its entirety is designated Metropolitan Open Land, though only its northern and western portion is designated SINC.

The site comprises a total of 1.42ha PDL. As noted in Table 11, as this portion of PDL will be the optimum location for the proposed development on the site, this will form a key focus for this assessment.

The Site has a considered maximum capacity of circa 612 residential units, and a height of up to 18 storeys.

In order to provide a benchmark for smaller sites which must provide a meaningful contirbution, it is noted that a 50 unit provision would require a minimum of 0.12ha of land. We approximate that this would equate to a 6 storey building. This would be alongside the 0.55ha of land required for the leisure centre.

A – Site Quality Criteria Answer

1 Site Character Comprises open MOL land to the north and west Is the site built up in character or beyond the river. The PDL element is located to the open? south of the site and comprises the existing leisure centre and the adjacent hardstanding in use as car park.

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2 Layout The leisure centre and car park are both located Are any area of open space formally adjacent to Ruislip Road East with direct vehicular laidout, with defined areas of access. Land to the north, whilst informally laid out, landscape character and use? comprises facilities for sports and leisure activities. Land beyond the river has no formal layout though with is bisected with a tree line. 3 Land Uses Leisure centre to the south, with adjacent surface What are the current land uses across level car park and existing vehicular and pedestrian the site? access. Both these areas are considered to be semi public in terms of access, given their leisure centre usage.

Adjacent to these two functions is a children’s playground, a BMX track and a skate park. Further north is an area of open grassland marked out for sports pitches. West beyond the river, land is open though with no apparent specific use. These elements of the site are all open to the public.

4 Quality Parkland the rear of the existing leisure centre was Has the site received any recognition rated 48.5/100 in LB Ealing’s open space audit, (locally or nationally) for the quality placing it at 112th place out of 134 sites. This puts of its facilities? the site in the worst 16%. B – Optimum Development Location

5 Leisure: Located generally within the footprint of the existing leisure centre, a new leisure centre here would fully utilise existing PDL with minimal encroachment onto greenfield land and minimal encroachment onto SINC. Access already exists and the use-provision would be like-for-like. Further, there would likely be minimal impact on Ruislip Road East given it is already suitable for large vehicles and turning coaches.

Residential: As a standalone residential scheme, the site of the existing leisure centre is the ideal location for residential, given that built massing is already established in this location and it is easily accessible from access points on Ruislip Road East. It would therefore fully utilise existing PDL with minimal encroachment onto greenfield land. Whilst a residential scheme here would require partial removal of the existing leisure centre, the majority would still be able to be retained.

Leisure and Residential: If uses were to co- locate, construction of the new leisure over the existing, and construction of the residential element over the car park represents the optimum solution. The residential element would compliment existing dwellings to its south and east whilst creating an active frontage to Ruislip Road East. Whilst there would be a minor loss of car parking, the majority of these bays are in use for car washing anyway so harm and potential parking displacement will likely be nominal.

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C – Impacts of Proposed Development Criteria Answer

6 Site Character Benchmark for Min. 50 unit Scheme: To what extent would the If either the leisure centre or residential were development (if at all) alter or change provided as standalone, there would be no change in the site’s character? character as they would both be located on the part of the PDL where there is already established built massing.

If these uses co-locate, the car park which is currently flat and open would now include a 6 storey built massing. Whilst this would have a minor impact on openness local to the new massing, the size of the site means such an impact would quickly dissipate to have a compoaratively nominal effect.

Whilst the wider context displays generally suburban characteristics, local building heights range from 2 – 11 storeys in line with an urban townscape. Accordingly a 6 storey building here would be appropriate.

Current Proposal: It is proposed to co-locate the residential and leisure centre elements on the site, and thus the car park which is currently flat and open would now include a built massing up to 18 storeys in height. The height of the leisure centre building would also, in part, increase to the same level. Whilst this would have an impact on openness of the locality around the new massing, the size of the site and the surrounding open land setting would mean that these impacts would be considerably reduced.

Whilst the wider context displays generally suburban characteristics, local building heights range from 2 – 11 storeys in line with an urban townscape. Up to 18 storeys here would be noticeable, but would not be outside the realms of possibility. The local setting of between 2 – 11 storeys would provide suitable ‘back ground’ to the development to ensure the height would not be a stark or innapropraite additional to the local skyline.

7 Layout Benchmark for Min. 50 unit Scheme: Can the development be Yes. The proportions of the site would stay the same, accommodated without adversely with all built development being located on existing altering the form and layout of the PDL to the southern edge of the site. Whilst the site? leisure centre car park would require a very minor reconfiguration to accommodate the residential element, the only resulting loss would be the removal of the car wash bays. Investment in the wider parkland would ensure its wider use can be optimised.

Current Proposal: Yes. Minor reconfiguration would be required however, the proportions of the site would stay the same with all built development being located on existing PDL to the southern edge of the site. Whilst

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the leisure centre car park would require a very minor reconfiguration to accommodate the proposed residential element, the design put forward takes its queue from the footprint of the car park area to minimise changes.

Investment in the wider parkland would ensure its wider use can be optimised.

8 Land Uses Benchmark for Min. 50 unit Scheme: Can the development be If the uses co-locate, both the leisure centre and accommodated complimentary to the residential could operate successfully and existing land uses? complimanterily whilst ensuring the usability of the wider parkland is maintained. Access to the wider site would increase and likely new investment would mean the existing sport and leisure facilities within the wider site could be upgraded. This would result in a much increased quality parkland.

The new leisure centre would be a state of the art, modern facility replacing the much older current centre. Accordingly, there would be no displacement of sports and leisure facilities.

Current Proposal: It is proposed to co-locate the residential and leisure elements of the proposal on the site, allowing the operation of both uses successfully and complimanterily whilst ensuring the usability of the wider parkland is maintained. Even at the proposed residential density, access to the surrounding parkland and sport and leisure facilities would be sustained. The quality of these elements would be considerably improved improved access through site development, greater local interest and new investment into facilities.

The new leisure centre would be a state of the art, modern facility replacing the much older current centre. Accordingly, there would be no displacement of sports and leisure facilities.

9 Quality Recognition Benchmark for Min. 50 unit Scheme: Would the proposed development Currently the quality of the wider MOL parkland is have an impact which may prejudice low. Likely investment in the parkland would mean any previously received recognition? its overall quality would increase – positively impacting its score in LB Ealing’s open space audit. Similarly, the existing leisure entre on site require significant enhancement. A new leisure centre provided here would serve as a modern and much needed replacement with no displacement of facilities.

Current Proposal: Currently the quality of the wider MOL parkland is low. The development put forward includes upgrades to existing facilities by improving landscaping, providing a footbridge, and re-providing an improved Gurnell Playground as well the BMX track and skate park. This would positively impact the parkland’s score in LB Ealing’s open space audit. Similarly, the existing leisure entre on site require significant

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enhancement. A new leisure centre provided here would serve as a modern and much needed replacement with no displacement of facilities.

D – Scope for Development Above 50 Units 10 If both uses were to co-locate, it would mean a holistic masterplan could be created for the existing PDL. Given the generally unconstrained nature of the site, such a plan could include the provision of a new basement car parking area, which in turn would free up the entirety of the remaining PDL area for new development. This would allow the residential quantum proposed to expand its footprint quite substantially above the minimum required 0.12ha - with no resulting loss of car parking or adverse impact on existing uses. For this reason, the development in its proposed form has been put forward.

Further, as a result of the Site’s current size and generally unconstrained nature alongside its proximity to other buildings which range in height between 2 – 11 storeys, it is considered there is sufficient context to increase the height above the benchmark 6 storeys to those proposed (between 3 – 18 storeys).

Cumulatively therefore, it is considered the Site has a capacity to accommodate a substantial number of residential dwellings well above the minimum 50 unit provision. The application put forward proposes 612 residential units co-located with the newly provided leisure centre.

Final Consideration The co-location of uses on this Site represents a positive opportunity to deliver a new leisure centre alongside a substantial number of residential units in a way that would have no impact on the usability of the wider MOL parkland. Subsequent and concurrent enhancements to this MOL parkland would, in the long term, actually significantly improve its quality and accessibility. There is, therefore, substantial benefit to be gained given that this current open space is of very low quality and has poor levels of access.

The replacement of the existing leisure centre with a new leisure would have no adverse impacts on levels of openness given that there is already a predecent for built massing on this site. The redevelopment of the grade-level car park however (likely to be acceptable on the basis that the existing car parking is reprovided elsewhere within the scheme) in favour of residential built massing would have adverse impacts on openness as well as blocking views across the MOL parkland from Ruislip Road East.

In terms of openness resulting from the residential massing, adverse impacts would only be felt within the immediate vicinity of the development. With distance into the large open space these impacts would quickly dissipate. And in terms of views, the scheme could be senstively articulated to ensure there would still be visual and accessible transparency through the blocks from Ruislip Road East into the parkland. This could be done in a way that still provides a desirable active façade.

In all, it is considered that co-location of a new leisure centre and the enabling 612 residential units could be provided on this Site subject to their inclusion as part of a holistic masterplan that focusses on the redvelopemnt and optimisation of the existing PDL – and paired with wider enhancements to the MOL parkland.

6.6 A summary of the results of the Stage 4: Detailed Site Assessments are contained in Part C, Chapter 9 of this report. The full transcript of each Detailed Site Assessment is included as part of Appendix 6.

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6.7 The outcome of these assessments will determine which, if any, of the final shortlisted sites are more appropriate or else would result in fewer adverse impacts than if the existing GLC Site was to be developed.

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PART C – RESULTS SUMMARY

Gurnell Leisure Centre Long List Sieving

6.0 STAGE 1: LONG LIST SIEVING

The Long List

6.1 Details of the 543 sites are set out in the Long List at Appendix 1. However, upon review it was be noted that one site (Limetrees Park Children’s Centre [Ref: 41]) was located within Lime Tree Park [Ref: 428]. It was therefore reviewed as part – giving a total of 542 sites to be assessed:

• 227 sites of which are urban; • 198 sites of which are designated public or community open space; and • 117 sites of which are designated MOL or Green Belt.

6.2 These sites were thusly put through the Cascade Sieving process.

Cascade Sieving

A. Size: As set out in Table 14, 254 of the sites were excluded on the basis that their area was less than the 0.25ha threshold. 288 sites were therefore progressed onto the next criteria assessment.

Table 14: Sites excluded on the basis of size

Ref: Site

Urban Sites 3 Albert Dane Centre, Southall 4 Broadmead Road (Taylor Woodrow), Grand Union Village, Greenford 5 Car Park, Verona Terrace Southall 6 David Cousins Centre, Greenford 7 Former Disraeli Nursery, Southall 8 Land Adjacent to Resource Centre, Southall 11 Resource Centre, Southall 12 Roslin Road Car Park 15 Gunnersbury Park small mansion 19 125 Elthorne Avenue Hanwell 20 15 Florence Road Ealing 21 164 Boston Road Hanwell 22 23 Sunnyside Road Ealing 23 239 High Street, Acton 24 3 Bancroft Court Northolt

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25 36 Inglis Road Ealing 26 50 Community Road Greenford 27 57 Oaklands Road Hanwell 28 62 Green Lane, (Brenthill Hostel) Ealing Short Bre 29 69 Studley Grange Road Hanwell 30 Academy Gardens Children’s Centre, Academy Gardens 32 Centre For Independent Living (Community Building) 34 Ealing Primary Centre 35 Grange Children's Centre 36 Hanwell Children's Centre 37 Hathaway Children's Centre 38 Horizons Centre, Cherington Depot 39 Islip Manor Children’s Centre 40 Jubilee Children's Centre 43 Michael Flanders Day Centre 44 Perivale Children's Centre 45 Northolt Park Children’s Centre 46 Petts Hill Children’s Centre 47 Southall Alcohol Advice Service, Featherstone Terrace 48 Southall Park Children’s Centre 49 Southall Young Adults Centre 50 Visions Social Club for Young People 51 W13 Youth Social Club, Churchfield Road 52 Windmill Children's Centre 53 58 Bowmans Close West Ealing 54 82 Oaklands Road Hanwell 55 Acton Park Children’s Centre and The Art Block 57 Copley Close Children's Centre 58 Cornucopia Day Centre - Travellers Education Service 59 Ealing Carers Centre 60 Ealing Hospital Children's Centre 62 Greenford Sports Centre (Sports Hall in School grou 64 Medcliffe Community Nursery 65 Medcliffe Open Door Centre 66 Northolt Family Centre, 21 Cowings Mead 67 Spikes Bridge Park Play Centre 68 Sunlight Community Nursery 69 Sycamore Lodge 71 Tideway Scullers School, Dukes Meadow, Chiswick Bri

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72 Windmill Park Children's Centre 73 Ealing Town Hall 74 Greenford Hall/Cyril Grant Hall 77 Acton Library 78 Berkeley Fields Pavilion/Changing Rooms 79 Bollo Brook Youth Centre 80 Brent Lodge Park 81 Dormers Wells Youth Centre, (Phoenix Centre) 85 Greenford Park Cemetery Depot 86 Hanwell Clock Tower 87 Hanwell Community Centre 88 Hanwell Library 90 Northfields Community Centre 92 Northolt Grange Community Centre 93 Northolt Library 95 Perivale Community Centre 96 Perivale Library 97 Pitshanger Library 99 The Rickyard 100 The Lodge Manor House Grounds (Southall Ranger Base 101 Unit 8 Roslin Road 102 Viking Community Centre 103 West Acton Youth & Community Centre 105 Woodend Library 110 Elthorne Sports Centre 111 Everyone Active Acton Centre 112 Fox Reservoir Pavilion 113 Greenford and Districts Scout Hall & Open Space 116 Horsenden Hill Toilets 118 Pitshanger Manor and Gallery 119 Scouts Hut, 50 Dabbs Hill Lane, Northolt 120 Scouts Hut, Trumpers Way, Hanwell W7 124 The Ice House 125 Twyford Sports Centre 127 Willow Cottages 128 YMCA nursery 129 17 Hanbury Road Acton 130 25 Hanbury Road Acton 131 376 Uxbridge Road

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134 Southall Town Hall 135 Trent House, Arden Road, Ealing, W13 8RP 136 1 Bordars Road Hanwell 137 1 Haydock Green Northolt 138 1 Lancaster Road Northolt 139 1 Ragley Close Acton 140 1 Ridgeway Walk Northolt 141 1 Winford Parade Southall 142 11 Haydock Green Northolt 143 13 Hanbury Road Acton 144 15 Hanbury Road Acton 145 19 Arrowscout Walk Northolt 146 19 Hanbury Road Acton 147 2 Ridgeway Walk Northolt 148 21 Hanbury Road Acton 149 23 Hanbury Road Acton 150 2-3 Ragley Close Acton 151 2-3 Winford Parade Southall 152 23-25 Down Way Northolt 153 27 Down Way Northolt 154 29 Harewood Terrace, Southall 155 29-31 Hunt Road Southall 156 3 Haydock Green Northolt 157 307 Greenford Avenue Hanwell 158 309 Greenford Avenue Hanwell 159 311 Greenford Avenue Hanwell 160 313 Greenford Avenue Hanwell 161 315 Greenford Avenue Hanwell 162 317 Greenford Avenue Hanwell 163 319 Greenford Avenue Hanwell 164 321 Greenford Avenue Hanwell 165 323 Greenford Avenue Hanwell 166 325 Greenford Avenue Hanwell 167 327 Greenford Avenue Hanwell 168 329 Greenford Avenue Hanwell 169 33 Down Way Northolt 170 331 Greenford Avenue Hanwell 171 333 Greenford Avenue Hanwell 172 335 Greenford Avenue Hanwell

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173 337 Greenford Avenue Hanwell 174 35 Hunt Road Southall 175 4 Winford Parade Southall 176 41 Hunt Road Southall 177 5 Bordars Road Hanwell 178 5 Haydock Green Northolt 179 5 Lancaster Road Northolt 180 5 Winford Parade Southall 181 59 Shadwell Drive Northolt 182 61 Marnham Crescent Greenford 183 61 Shadwell Drive Northolt 184 61-63 Churchfield Road, Acton, W3 6AY 185 63 Marnham Crescent Greenford 186 65 Marnham Crescent Greenford 187 7 Bordars Road Hanwell 188 7 Haydock Green Northolt 189 7 Lancaster Road Northolt 190 71 Shadwell Drive Northolt 191 73 Shadwell Drive Northolt 192 9 Bordars Road Hanwell 193 9 Haydock Green Northolt 194 98 Churchfield Road Acton 195 9A Haydock Green, Northolt 196 Acton Working Mens Club & Institute, Strafford Road 197 Brent Lodge 198 Brenthill Garden Centre 199 Dame Gertrude Youth Hostel 200 Hanwell House 191 Boston Road, Hanwell 201 Milap Day Centre, Shackleton Road 202 Moorlands Elderly Persons Home 203 Osborne House, 294 Osborne Road, W3 8SR 204 Poores Site and Depot 205 Rectory Park Youth & Community Centre 206 Smith's Farm Estate Hall, Hotspur Road, Northolt 207 Templeman Hall, 363 Copley Close 209 The Poplars 210 The Shop - 59 Hotspur Road 211 Unit 7, Morris House, Swainson Road, Acton 212 Unit 8, Morris House, Swainson Road, Acton W3 7UP

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213 Unit 9 Morris House, Swainson Road, Acton W3 7UP 214 William Morris House, Park Road North, W3 8RT 216 Arden Road Car Park - Arden Road W13 8RP 217 Deans Gardens Car Park - Leeland Terrace, W13 9DA 219 George Street Car Park, George Street, Hanwell W7 3TA 222 Norwood Road 1 Car Park - Norwood Road, Southall UB2 4JT 223 Norwood Road 2 Car Park - Norwood Road, Southall UB1 4DD 224 Perivale Station Car Park – Horsenden Lane, Perivale, UB6 8LE 225 Salisbury Street Car Park - Salisbury Street, Acton W3 8NW 226 Singapore Road Car Park - Singapore Road W13 0RJ 227 South Ealing Car Park - 1-3 South Ealing Road, Ealing W5 4QT 228 Witham Road Car Park, Witham Road W13 0TU Public Open Spaces and Community Open Spaces 229 Orchard Gate Open Space 230 Brentham Green Open Space 231 Green Lane Wharf 232 West Middlesex Golf Course - Footpath'B' 233 Cuckoo Lane by Church Rd Island 234 Queens Road Open Space 235 Coronation Gardens 236 Greenford Rd / Oldfield La N. Open Space 237 Whitton Drive Open Space 238 Wolf Green 239 Alexandra Rest Garden 240 Green Lane Open Space 241 Midland Terrace Gardens 242 Acton Cemetery Footpath 243 Crown Street Open Space 244 West Middlesex Golf Course - Footpath'A' 245 Cuckoo Park Rest Garden 246 Inglis Road Open Space 247 Western Road Open Space 248 St. Mary's Church - Churchyard 249 Carr Road Playground 250 Northolt Village Rest Garden 251 Frogmore Green (Almshouse) 252 St. Mary's Churchyard 253 Boundary Nature Area 254 The Crescent Open Space

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255 Bromyard Gardens 256 Friars Place Green 257 Oldfield Lane Open Space & War Memorial 258 Rothesay Recreation Ground 259 North Road Island 260 Bollo Bridge Rest Garden 261 Laughton Road Playground 262 St. John's Churchyard 263 St. Bernard's Canal Side OS 264 Tentelow Lane - Open Space 265 Claydon Garden Open Space 266 Cerebos Gardens 267 Spencer Street Play Centre 340 North Acton Allotments 347 Brentham Estate Allotments 348 Fowlers Walk 351 Long Drive Open Space 355 Dennison Road West 356 Dennison Road East 357 Brunner Road 368 Brighton Drive Allotments 361 Chilton Avenue South Allotments 362 Connell Crescent Allotments 369 Goldsmiths Close Allotments 379 Iveagh Avenue 385 Ludlow Road Allotments 394 The Link 396 St Anne's Gardens Allotments 397 St Dunstan's Allotments 404 Western Avenue Allotments 409 Tennyson Road 411 Searchlight Allotments 412 Chilton Avenue North Allotments 413 Braid Avenue 415 Walton Gardens 416 Howard Close Allotments 417 St Andrew's Allotments 421 South Acton Allotments East 422 Rushdene Crescent West

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423 Rushdene Crescent East Green Belt and MOL Sites 439 Northolf Manor (Northolt Village Green) 442 Marnham Fields (Bridge Farm Open Space) 500 Island West of Mayfield School 514 Ealing Common (part) (Ealing Common [North East]) 543 Area adjoining Gunnersbury Park (Land at Baron’s Pond, Popes Lane, Ealing)

B. MTFS: 27 of the sites were excluded on the basis that they have already be allocated for disposal as part of the Council’s Medium Term Financial Strategy , as per Table 15 below. 261 sites were therefore progressed onto the next criteria assessment.

Table 15: Sites excluded as part of the Council’s MTFS

Ref: Site Urban Sites 1 301 Ruislip Road, Northolt 2 Acton Town Hall, Acton 9 Land at Perryn Road, Acton 10 Oldfield Road Car Park, Greenford 13 Stirling Road Day Centre 14 West Acton Community Centre, Acton 16 Access House & T Mohan, Manor Road, W13 17 Wickes South Ealing Road, W5 4QS 18 Greenford Town Hall, UB6 9QN 31 Carmelita House, 21 The Mall Ealing 42 Log Cabin Children's Centre 70 The Limes 75 Perceval House 82 Ealing Central Library 83 Greenford Community Centre 84 Greenford Library 89 Islip Manor Youth & Community Centre 91 Northfields Gardens Library 94 Northolt Village Community Centre 98 The Dominion Centre/Ealing Music Centre 108 Dormers Wells Leisure Centre 121 Stirling Road Waste & Recycling Centre

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132 Carlton Day Centre 133 Southall Library 218 Featherstone Terrace Car Park - Featherstone Terrace, Southall UB2 5AL 220 Greenford Broadway Car Park - Off Oldfield Lane, Greenford UB6 9PY 221 Herbert Road Multi-Storey Car Park, Herbert Road, Southall, UB1 1LH

C. Availability: 77 of the sites were excluded on the basis that they were not genuinely available in a way that would ensure prompty commencement of construction, as set out in Table 16 below. 184 sites were therefore shortlisted to progress through to the Stage 2: Mini Assessments.

Table 16: Sites excluded on the basis of their being unavailable

Ref: Site Reason for Unavailability Urban Sites Owned by the Council. Long lease to third 33 Cowgate Day Centre, Greenford Lodge party 76 Acton Cemetery Cemetery Located in a mixed-use building not fully 104 West Ealing Library owned by the Council Long term lease with significant length 106 Boddington Gardens Sports Ground remaining David Lloyd Leisure Centre (Ealing Long term lease with significant length 107 Northern Sports Ground) remaining. Long term lease with significant length 109 Dragons Health & Squash Club remaining 115 Greenford Park Cemetery Cemetery Owned by the Council. New lease being 122 Swift Road Outdoor Sports Centre negotiated Temporary library site, Jubilee Gardens Council leased site within CCG owned 123 Clinic building Council owned. Long Lease with significant 126 Virgin Active Sports Ground time remaining The Cattle Market, High Street, Part of future development scheme already 208 Southall, UB1 3DG underway Long Term Lease, with significant length 215 Y.M.C.A Hostel, St Marys Road, Ealing remaining Public Open Spaces and Community Open Spaces 277 St. Mary's Churchyard Cemetery 282 St. Mary's Burial Ground Cemetery Subject to an implemented estate 287 Bollo Brook Open Space regeneration project with a view to redevelopment Havelock Road Open space Open space subject to an implemented 292 planning permission for redevelopment 310 Oldfield Allotments, Carr Road, UB5 Allotment 318 Havelock Cemetery Cemetery 319 Hortus Cemetery Cemetery

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329 Acton Cemetery Cemetery 334 South Ealing Cemetery Cemetery 336 Greenford Park Cemetery Cemetery 338 Carbery Avenue Allotments Allotment 339 Dabbs Hill Allotments Allotment 343 Ascott 1 & 2 Allotments Allotment 344 Billet Hart Allotments Allotment 345 Bixley Field Allotments Allotment 346 Braund Avenue Allotments Allotment Open space subject to an implemented 349 Avenue Road Recreation Ground planning permission for redevelopment 361 Cleveley Crescent Allotments Allotment 363 Costons Lane Allotments Allotment 366 Northfields Allotment Allotment 368 Framfield Allotments Allotment 370 Horn Lane Allotment 371 Greenford Hall Allotments Allotment 377 Horsenden Allotments Allotment 378 Moat Place Allotments Allotment Open space subject to an implemented 380 Jerome Allotments planning permission for redevelopment 381 Jubilee Road Allotments Allotment 382 Lime Trees 1 Allotments Allotment 383 Lime Trees 2 Allotments Allotment 386 Manor Way Allotments Allotment 387 Mansell Road Allotments Allotment 388 Noel Road Allotments Allotment 390 Oldfield Allotments Allotment 392 Pleasant Way Allotments Allotment 393 Popes Lane Allotments Allotment 398 Stanhope Park Allotments Allotment 399 Stanley Avenue Allotments Allotment 400 Tentelow Lane Allotments Allotment 402 Village Park Allotments Allotment 405 Western Road Allotments Allotment 406 Whitton Drive Allotments Allotment 407 Whitton Place Allotments Allotment 408 Wolf Fields Allotments Allotment 410 Ravenor Park Allotments Allotment 414 Saxon Drive Allotment Blondin Allotmennts and Community 418 Allotment Park Land

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420 North Acton Cemetery Allotment 424 Carbury Avenue Allotments Allotment 426 St Mary’s Burial Ground Cemetery Green Belt and MOL Sites Northolt Golf Course and Medlar Fields Owned by the Council. Long lease to third 435 (Northolt Golf Course) party with significant time remaining Bellvue Park and adjoining OS and Owned by the Council. Long lease to third 437 Moorings (Bellvue Highschool, Gym party with significant time remaining and Grounds) King Georges Fields (Durdan’s Park 451 Allotments, off Lady Margret Road, Allotment Southall) Spikes Bridge Park (Sharks Activity Owned by the Council. Long lease to third 454 Centre) party with significant time remaining Hayes Bridge Leisure Gardens (Hayes 457 Bridge Allotments, Beaconsfield Road, Allotment Southall) Brent Meadow / Conolly Dell (Brent 462 Meadow Allotments, Brentvale Avenue, Allotment Southall) East Central Area of Brent River Park 471 (High Lane Allotments, High Lane, Allotment Hanwell, W7) West Middlesex Golf Course (Dormers 475 Allotment Wells Allotments) Greenford Park Cemetery, Allotments 476 and Playing Field (Greenford Park Cemetery Cemetery) Greenford Park Cemetery, Allotments 477 and Playing Field (Windmill Lane Allotment Allotments, Windmill Lane, Greenford) Ealing Golf Course etc. South of River 487 Brent (Brentham Allotments, Allotment Brunswick Road, Ealing W5) Ealing Golf Course etc. South of River 490 Brent (Pitshanger Allotments, Pleasant Allotment Way, Perivale) Acton Park – Bromyard Avenue Area Owned by the Council. Long lease to third 505 (Bromyard Open Space) party with significant time remaining Hanger Hill (Fox Wood Local Nature Owned by the Council. Long lease to third 510 Reserve, Ealing, W5) party with significant time remaining Area adjoining Gunnersbury Park (Old Owned by the Council. Long lease to third 522 Actonians Sports Ground and Scout party with significant time remaining Hut) Horsenden Hill [part] (Ealing Central Owned by the Council. Long lease to third 524 Sports Ground, Greenford) party with significant time remaining

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7.0 STAGE 2: MINI-ASSESSMENTS

7.1 As a result of the exclusions of the Cascade Sieving, the 184 sites listed below in Table 17 were progressed to the Stage 2: Mini Assessments.

Table 17: Sites progressed to the Stage 2: Mini Assessments

Ref: Site Urban 56 Chestnut Lodge, Woodfield Road, Ealing W5 1SL 61 Elm Lodge, Marley Close 63 Martin House, Swift Road 114 Greenford Depot & Refuse Transfer Centre, UB6 9AR 117 Northolt Leisure Centre, Swimerama site, Eastcote Lane Open Space 268 Windmill Lane / Tentelow Lane Open Space, UB2 4LF 269 Walmer Gardens Open Space, W13 9TS 270 Ormsby Green, UB6 9NR 271 Bramley Road Rest Garden, W5 4UA 272 Mill Hill Gardens, W3 8QJ 273 Windmill Lane Recreation Ground, UB6 9DR 274 Lower Boston Road Open Space, W7 3TP 275 Haslemere Open Space, W7 2BT 276 West Gate Open Space, W5 1UP 278 Fielding Walk Verges, W13 9XW 279 Maytrees Rest Garden, W5 4QT 280 Wood End Recreation Ground East, UB5 4QS 281 West Ridge Green, UB6 9PE 283 Mandeville Green, UB5 5HG 284 King George V.Field (Poor's Piece), W7 2PN 286 St. Dunstans Gardens Open Space, W3 6QG 288 Village Park Recreation Ground, W5 4LD 289 The Green, East Acton, W3 7PQ 290 Down Way Playground, UB5 6PH 291 Heathfield Gardens, W3 8EY 293 The Woodlands, W3 8SA 294 Rosewood Avenue Open Space, UB6 7QP 295 Twyford Crescent Gardens, W3 9PP 296 Cranleigh Park, UB1 2BY 297 Castlebar Halt, Chelsea Gardens, W13 0DH

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298 Northolt Village Green, UB5 5HG 299 Gurnell Grove Play Area, W13 0AW 300 Fairview Playground, UB5 4JB 301 Litten Nature Trail, UB6 9JX 302 Bixley Field, UB2 4EL 303 Manor House Grounds, UB2 4BJ 304 Wood End Recreation Ground West, UB5 4QS 305 Dormers Wells Green, UB1 3JH 306 Dean Gardens, W13 9BG 307 Ridding Lane Open Space, UB6 0JZ 308 West Ealing Sports Ground, Mervyn Road, W13 9UW 309 Wolf Fields, UB2 4JT 311 Wesley Playing Fields, NW10 6PF 312 South Acton Recreation Ground, W3 8DD 313 Montpelier Park, W5 2QS 314 Oldfield Recreation Ground, UB6 8QB 315 Greenford Park Recreation Ground, UB6 9EJ 316 RAF Wireless Station, Wood End Lane, UB5 4JL 317 Spingfield gardens, W3 6NT 320 Drayton Green, W13 0LT 321 Cayton Green Park, UB6 8BQ 322 Mount Pleasant Fields, Dormer’s Wells Lane, Southall, UB1 3HZ 323 Mandeville Parkway, UB5 4LU 324 Acton Green Common, W4 5EA 325 Jubilee Park, UB1 2EZ 326 Cuckoo Park, W7 1PD 327 Southfields Recreation Ground, W4 5LD 328 Northolt Park, UB5 4HB 330 Islip Manor Park, Northolt, UB5 5BT 331 Southall Recreation Ground, UB2 5PE 332 Blondin Park, Northfields, W5 4UL 333 North Acton Playing Fields, Westfields Road, W3 0AX 335 Southall Park, Uxbridge Road, UB1 3BT 337 Ravenor Park, Greenford, UB6 9LG 341 Acton High School Sports Ground 342 Alwyn Gardens Sports Ground 350 Beaconsfield Road Open Space 352 Yeading Lane Estate Open Space, Northolt 353 Uxbridge Road Park, Ellis Road

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354 Haselmere Avenue Sports Ground 359 Cayton Road Playing Fields 364 Durston House School Playing Field 365 Ealing Cricket Club 367 Ealing Lawn Tennis Club 372 Gunnersbury Avenue (Ealing Riding School) 373 Haberdashers Askes Sports Ground 374 Hanger Hill Garden Estate Sports Ground, W3 375 Haslemere Wildlife Reserve, Clitherow Avenue, W7 376 Horn Lane Sports Ground 384 Liverpool Victoria Sports Ground 389 Noel Road Open Space, Alwyn Gardens, W3 391 Osterley Lane Open Space, Southall 395 Western Gardens, Springfield Bowls Club, W5 3RS 401 Twyford Avenue Sports Ground, W3 403 West Acton Primary School Playing Fields, Noel Road, W3 0JL 419 Popefield Sports Ground, W3 425 St Columbus Tennis Club, Carbury Avenue, W3 9AL Green Belt and MOL Sites Down Barns / West London Shooting Grounds (Land south of London Shooting 427 Grounds) 428 Lime Tree Park – A40 (Lime Tree Park, Northolt) 429 Lime Tree Park – A40 (Lime Tree Golf Course and Alec Reed Academy) 430 Western Avenue Parkway (part) 431 Western Avenue Parkway (part) 432 Area south of Rectory Fields 433 Rectory Fields (Rectory Park, Northolt) 434 Northala Fields (Northala Fields including Medlar) 436 Northolt Golf Course and Medlar Fields (Land North of Gifford Primary School ) 438 Bellvue Park and adjoining OS and Moorings (Northolt Manor and Bellvue Park) 440 Marnham Fields (Bridge Farm Open Space) 441 Marnham Fields (Marnham Fields) 443 Smith’s Farm (Smith’s Farm, Northolt - North) 444 Smith’s Farm (Smith’s Farm, Northolt - South) 445 Islip Manor - A40 (Islip Manor Meadows) 446 Islip Manor - A40 (Prior Fields) 447 Islip Manor - A40 (Lord Halsbury’s Memorial Playing Fields, Northolt) 448 Islip Manor - A40 (Land at Willow Tree Primary School) 449 King Georges Fields (King George’s Playing Fields, Southall) 450 King Georges Fields (Southall Cricket Club, Southall)

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452 King Georges Fields (Durdan’s Park Primary School and Grounds) 453 Spikes Bridge Park (Spikes Bridge Park, Southall) 455 Spikes Bridge Park (Cranleigh Wood) 456 Hayes Bridge Leisure Gardens (Blair Peach Primary School and Nursery) 458 Fitzherbert Walk and East of the River Brent (St Margaret’s Road Open Space) Fitzherbert Walk and East of the River Brent (Grounds and buildings of St Mark’s 459 Primary School) 460 Fitzherbert Walk and East of the River Brent (Fitzherbert Walk and Hanwell Island) 461 Brent Meadow / Conolly Dell (Brent Meadow, Southall) 463 Brent Meadow / Conolly Dell (Conolly Dell, Hanwell, W7) 464 East Central Area of Brent River Park (Manor Court Green, Hanwell, W7) 465 East Central Area of Brent River Park (Churchfields Recreation Ground, Hanwell, W7) 466 East Central Area of Brent River Park (Brent Lodge Park, Hanwell, W7) 467 East Central Area of Brent River Park (Brent Valle y Golf Course) 468 East Central Area of Brent River Park (Land South of the Brent Valley Golf Course) 469 East Central Area of Brent River Park (Mayfield) 470 East Central Area of Brent River Park (Mayfield Primary School) 472 East Central Area of Brent River Park (Bittern’s Field) 473 East Central Area of Brent River Park (Drayton Manor Playing Fields) 474 West Middlesex Golf Course (West Middlesex Golf Club - East) Greenford Park Cemetery, Allotments and Playing Field (Land North of Windmill La ne 478 Allotments) 479 West of River Brent at Cardinal Wiseman School (Cardinal Wiseman School) 480 Golf Course central Brent River Park (Marnhams Field) 481 Golf Course central Brent River Park (Greenford River Side) 482 Golf Course central Brent River Park (Brent Valley golf Course 483 Golf Course central Brent River Park (West Middlesex Golf Club) 484 Golf Course central Brent River Park (Brent Valley Sports Ground) 485 Ruislip Road East at Brentside School 486 Ealing Golf Course North of River Brent (Hanwell Town Football Club) 488 Ealing Golf Course etc. South of River Brent (Pitshanger Park, Ealing, W5) 489 Ealing Golf Course etc. South of River Brent (Cleveland Park, Ealing, W13) 491 Ealing Golf Course etc. South of River Brent (West London University Sports Ground) Ealing Golf Course etc. South of River Brent (River Brent Conservation Site, Ealing, 492 W13) 493 Elthorne Park and Elthorne Waterside, Hanwell (Elthorne Park, Hanwell) 494 Elthorne Park and Elthorne Waterside, Hanwell (Elthorne Sports Centre) 495 Elthorne Park and Elthorne Waterside, Hanwell (Elthorne Waterside) 496 Elthorne Park and Elthorne Waterside, Hanwell (Evershed Sports Ground) 497 Gurnell Pool Open Space and Waterside (Perivale Park Golf Club 498 Gurnell Pool Open Space and Waterside (Perivale Park, Greenford) 499 Gurnell Pool Open Space and Waterside (Ruislip Road East)

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501 Glade Lane, Canalside Park (Land East of Glade Lane) 502 Glade Lane, Canalside Park (Glade Lane, Canalside Park, Southall) 503 Glade Lane, Canalside Park (Land at Armstrong Way) 504 Acton Park – Bromyard Avenue Area (Acton Park, Acton, W3) 506 Acton Park – Bromyard Avenue Area (Land South of Bromyard Open Space and Land) 507 Acton Park – Bromyard Avenue Area (Trinity Way Open Space, Acton) 508 Acton Park – Bromyard Avenue Area (Haddon Court Open Space) 509 Chatsworth Wood (Chatsworth Wood East of Hanger Lane) 511 Hanger Hill (Hanger Hill Crest Open Space / Fox Reservoir, Ealing, W5) 512 Hanger Hill (Hanger Hill Park, Ealing, W5) 513 Ealing Common (part) (Ealing Common [South East]) 515 Ealing Common (part) (Ealing Common [North West]) 516 Ealing Common (part) (Ealing Common [South West]) 517 Twyford Abbey 518 Ealing Green, Walpole and Lammas Park (Ealing Green, Ealing, W5) 519 Ealing Green, Walpole and Lammas Park (Walpole Park, Ealing, W5) 520 Ealing Green, Walpole and Lammas Park (Lammas Enclosure, Ealing, W5) 521 Ealing Green, Walpole and Lammas Park (Lammas Park Ealing, W5) 523 Horsenden Hill [part] (Lower Thrifts Field, Greenford and Perivale Community Centre) 525 Horsenden Hill [part] (Horsenden Hill West) 526 Horsenden Hill [part] (Horesenden Farm and Visitor Centre) 527 Horsenden Hill [part] (Horsenden Hill East) 528 Horsenden Hill [part] (Horsenden Hill Golf Course) 529 Ealing Northern (Ealing Northern Sports Centre) 530 Ealing Northern (Grove Farm) 531 Norwood Green – Osterley &Tentelow Lane Sports Ground (Norwood Green, Southall) Norwood Green – Osterley &Tentelow Lane Sports Ground (Land west of Tentelow 532 Lane) Norwood Green – Osterley &Tentelow Lane Sports Ground (Tentelow Wood and 533 Playing Fields, Southall) Norwood Green – Osterley &Tentelow Lane Sports Ground (Tentelow Lane Sports 534 Ground) 535 Warren Farm / Jubilee Meadow / Long Wood (Long Wood – adjacent to River Brent) 536 Warren Farm / Jubilee Meadow / Long Wood (Long Wood, Southall) 537 Warren Farm / Jubilee Meadow / Long Wood (Warren Farm Sports Ground) Warren Farm / Jubilee Meadow / Long Wood (Blackberry Corner and Jubilee Meadow, 538 Southall) 539 Warren Farm / Jubilee Meadow / Long Wood (Trumpers Field) 540 Birch Wood / GSK Sports Ground (Birch Wood, Greenford) 541 Birch Wood / GSK Sports Ground (GSK Sports Ground) 542 Greenford Lagoons (Greenford Lagoons, Greenford)

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7.2 The populated Mini Assessments of these 184 sites are enclosed at Appendices 2, 3 and 4. As shown, of the 184 sites progressed through the Mini Assessments, 171 were eliminated on the basis that they did not score better than the benchmark set by existing Gurnell site.

7.3 Accordingly, the 13 sites shortlisted for the Stage 3: Capacity Study (alongside the uses they are most suitable for) are set out in Table 18 below.

Table 18: Sites progressed to Stage 3: Capacity Study

Ref: Site Leisure Resi 56 Chestnut Lodge, Woodfield Road, Ealing W5 1SL N Y 61 Elm Lodge, Marley Close N Y 63 Martin House, Swift Road N Y 273 Windmill Lane Recreation Ground, UB6 9DR N Y 279 Maytrees Rest Garden, W5 4QT N Y 306 Dean Gardens, W13 9BG N Y 330 Islip Manor Park, Northolt, UB5 5BT N Y 332 Blondin Park, Northfields, W5 4UL N Y 337 Ravenor Park, Greenford, UB6 9LG Y Y 425 St Columbus Tennis Club, Carbury Avenue, W3 9AL N Y 485 Ruislip Road East at Brentside School Y Y Ealing Golf Course North of River Brent (Hanwell Town 486 Y Y Football Club) Acton Park – Bromyard Avenue Area (Land South of Bromyard 506 N Y Open Space and Land)

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8.0 STAGE 3: CAPACITY STUDY

8.1 The 13 sites that were shortlisted in the above section have been assessed for their potential residential capacities as per the method outlined in Part B, Chapter 4 of this document.

8.2 The full capacity assessments of each site are included within Appendix 5.

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9.0 STAGE 4: DETAILED SITE ASSESSMENT

9.1 13 sites were assessed for their respective capacities as part of the Stage 3: Capacity Study. The resulting capacities (and densities) thusly served as the basis for the Stage 4: Detailed Site Assessments. Whilst a full transcript of each assessment can be found in Appendix 6 of this report, the conclusions of each are listed out below in Table 20:

Table 20: Detailed Site Assessment Conclusions Development Site and Conclusion Potential Summary 56: Chestnut Lodge, Woodfield Road, Ealing, W5 1SL A minimum 50 unit scheme on the western portion of the site would require the loss of the care home’s existing car park alongside the loss of a portion of the care home itself. The result would be harm to the existing prevailing building line and a loss of care home amenity.

Whilst there may be scope to put car parking underground and incorporate any lost care home floorspace back into a new development, the short term upheaval on existing residents and long term adverse impacts on the quality of the care home as a whole GLC better would be majorly adverse. In addition to this, the home would lose suited for its western outlook which in itself would require a substantial residential reconfiguration. Relocating the care home (in part or as a whole) as part of this process is not an option as it is beyond the remit and critical time period required to support the construction of a new leisure centre in the borough.

In this regard, the GLC is better suited to the proposed residential uses as, not only could it accommodate the full 612 enabling units required but it would require no relocation of existing uses; neither would it adversely impact upon the usability of the existing open space or character of the wider area.

61: Elm Lodge, Marley CloseCayton Green Park, UB6 8BQ A minimum 50 unit scheme on the eastern portion of the site would require the loss of part of the care home’s existing car park and amenity areas alongside the loss of a portion of the care home itself. This new residential element would likely take the form of a 4 storey mass which, given the site’s generally obscured location away from the road, would not be considered an incongruous intervention.

However, should there be a requirement to reprovide any lost care home floorspace back into the development, impacts on final scale GLC better would be significant potentially necessitating a mixed-use scheme of suited for circa 7 storeys in height. Within this context and adjacent to a SINC, residential such height would be majorly adverse.

Whilst there may be scope in future to relocate the care home (in part or as a whole) off site, this is not an immediate option as it is beyond the remit and critical time period required to support the construction of a new leisure centre in the borough.

In this regard, the GLC is better suited to the proposed residential uses as, not only could it accommodate the full 612 enabling units

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required but it would require no relocation of or harm to existing uses. 63: Martin House, Swift Road A minimum 50 unit scheme on the north eastern portion of the site would require the loss of the majority of the care home’s existing car park and alongside the loss of a portion of the care home itself. This new residential element would likely take the form of a 5-6 storey mass. Whilst otherwise suitable for an urban location, its constrained nature and visible position may risk it being seen as overly bulky.

More importantly however is its adverse impact on the site’s existing care home land use. Should there be a requirement to reprovide lost care home floorspace back into the development, impacts on final scale would be significant – potentially adding another 3 floors to the minimum residential height of 5-6 storeys. Within this GLC better constrained context, such height would be considered majorly suited for adverse. This should be seen alongside the general and substantial residential reconfigurations also required to the existing care home building.

Whilst there may be future scope to relocate the care home (in part or as a whole) off site, this is not an immediate option as it is beyond the remit and critical time period required to support the construction of a new leisure centre in the borough.

In this regard, the GLC is better suited to the proposed residential uses as, not only could it accommodate the full 612 enabling units required but it would require no relocation of or harm to existing uses.

273: Windmill Lane Recreation Ground, UB6 9DR A minimum 50 unit scheme on the site, would allow for the existing Windmill Lane façade to be infilled – which may been seen as a positive. However, this would likely be outweighed by the substantial harm caused by the prevailing loss of an accessible and equipped designated public open space; a space which is rated significantly GLC better higher than the existing GLC site in terms of quality. suited for residential In this regard, the existing GLC Site is better suited to the residential uses proposed as, not only could it accommodate the full 612 enabling units required but it would result in no net loss of greenfield land and no adverse impacts on the usability of the wider park.

279: Maytrees Rest Garden, W5 4QT The site’s high density context would allow for a 50 unit scheme with a relatively small footprint and a reasonable degree of height – whilst allowing for the retention of a fair degree of the existing park.

However, the fundamental loss of high quality and designated public open space (at the time of survey, rated 35th best out of 134 in the borough) would still be a principle issue. The proposal would adversely impact the site in terms of openness, usability and landscaping. Alongside this, the proposal would also narrow the line GLC better of visibility of the park from the public highway, meaning loss of suited for open views. In this highly urban context, such an impact would residential reduce the public realm quality.

In this regard, the existing GLC Site is better suited to the residential uses proposed as not only could it accommodate the full 612 enabling units required but it would result in no net loss of greenfield land and no adverse impacts on the usability of the wider park. Whilst, like this site, the GLC scheme as proposed may restrict views from the public realm to the existing park, its more suburban context alongside the substantial enhancements to the retained MOL land is considered to lessen this impact.

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306: Dean Gardens, W13 9BG The site’s high density context would allow for a 50 unit scheme with a relatively small footprint and a reasonable degree of height – whilst allowing for the retention of a large proportion of the existing park. This is a comparative positive and makes this site, initially, a desirable prospect for the delivery of a minimum of 50 units.

However, it cannot be ignored that such a proposal here would result in the loss of designated greenfield public open land – essentially shrinking the size of the park. This harm is more substantial when it is considered that this park represents one of the highest locally rated in the borough.

GLC better In this regard, the existing GLC Site is better suited to the residential suited for uses proposed. Not only could it accommodate the full 612 enabling residential units required with no net loss of greenfield land and no adverse impacts on the usability of the wider park, but it would also facilitate the substantial enhancement of the existing MOL parkland; increasing its usability and overall quality for the benefit of the borough. This Dean Gardens site however is already of a high quality so the scope for further enhancements would be limited – coupled with the prospect of any development resulting in an overall reduction in parkland.

Accordingly, it is considered that the wider benefits of the proposal on the existing GLC site far outweigh any benefits of introducing a minimum of 50 units worth of built form onto Dean Gardens.

330: Islip Manor Park, Northolt, UB5 5BT By virtue of the park’s size, the minimum 50 unit development would result in major adverse impacts to its southern portion though relatively minor (if any) adverse impacts to the north. A sensitively designed development would ensure this.

Whilst this site does therefore present a good prospect for development, fundamentally such works would still involve the loss of open greenfield land which is fully publicly accessible, designated open space and nationally recognised as a park of quality.

In this regard, the existing GLC Site is better suited to the residential GLC better uses proposed. Whilst, like this site, the GLC Site would result in suited for localised adverse impacts on openness, the full 612 enabling units residential could be provided here with no net loss of greenfield land and no adverse impacts on the usability of the wider park. Further, the resulting enhancements across the GLC Site as a result of the development would increase the usability and accessibility of its wider MOL context.

Islip Manor Park however is already of a high quality so the scope to generate further benefits would be limited. Accordingly, it is considered that the wider benefits of the proposal on the existing GLC site outweigh any benefits of introducing the minimum of 50 units onto Islip Manor Park.

332: Blondin Park, Northfields, W5 4UL The optimum development location is considered to be the northern area due to its good levels of access, distance from SINC, GLC better compatibility with neigbours and the ability to secure a fair degree suited for of appropriate height. Much like Islip Manor Park above therefore, residential this site does present a potentially good prospect for 50 units – if not, 65-75 units given the generally height-compatible context.

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However and fundamentally the proposal here would still involve the loss of open greenfield land which is fully publicly accessible.

Development here may facilitate park enhancements (a degree of which should be focussed on reducing any adverse impacts on openness), though as the park is already of a high quality, the additional benefits felt would likely be moderate if not negligible.

In this regard therefore, the existing GLC Site is better suited to the residential uses proposed. Whilst, like this Blondin, the GLC Site would result in localised adverse impacts on openness, the full 612 enabling units could be provided here with no net loss of greenfield land and no adverse impacts on the usability of the wider park. Further, the resulting enhancements across the GLC Site as a result of the development would substantially increase the usability and accessibility of its wider MOL context. Accordingly, it is considered that the wider benefits of the proposal on the existing GLC site outweigh any benefits of introducing residential uses into Blondin Park.

337: Ravenor Park, Greenford, UB6 9LG The park’s substantial size is to its benefit in this case, as a minimum 50 unit residential development to the north western corner would unlikely result in any significant adverse impacts on the park’s usability or layout. Similarly, any local impacts on openness would dissipate as one proceeds into the main park area. In this respect therefore Ravenor Park presents a good prospect for the minimum enabling residential scheme.

However, it is still a fundamental issue that the residential development would be constructed entirely on greenfield land, designated as Public Open Space and currently fully publicly accessible. In space amenity terms therefore this will therefore have GLC better an adverse impact – an impact that does not extend to GLC given suited for that the proposed residential development here would be constructed residential and on land that, in itself, already has limited public access and would leisure centre not require the loss of any greenfield land. GLC is therefore more suited to the provision of residential.

In terms of the leisure centre, in order to operate in Ravenor Park it must be within close proximity to a main road – to the south west corner. However, in this respect it obscures a key sight line and access point into the park; will increase the amount of traffic (coaches and circa 170 cars) entering; would prejudice a SINC; and will require the reprovision of the MUGA. In this respect, the existing GLC Site is more suited to the provision of a new leisure centre than this site given that one already exists here so it is already suited to the needs of such a provision.

425: St Colunba’s Tennis Courts, Carbury Avenue, W3 9AL The size of the site is its major constraint in this respect. The minimum 50 unit scheme would require the complete loss of the existing tennis courts and tennis building, with the additional potential for harm to be inflicted upon the SINC allotment space to the north. Whilst there may be scope to reduce the built footprint GLC better of this scheme by increasing the heights, this will not be sufficient suited for to ensure the retention of the tennis courts. residential and

leisure centre At the time of writing, LB Ealing’s Sports Facility Strategy (2012- 2021) stated that “it can be assumed with some degree of certainty that there is currently a balance between supply and demand” though with the view that by 2021 there would be a need for 19 additional courts. Accordingly, the loss of these tennis courts for residential will highly likely be resisted.

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The existing GLC Site is therefore more suitable for residential development as it would not result in the loss of, or adverse impacts to any existing sporting facilities. Quite the contrary, the proposal on the GLC Site would actively enhance them.

485: Ruislip Road East at Brentside School The MOL Site is relatively small though intensively used, comprising a recently constructed school, a new MUGA and soon-to-be landscaping to the north SINC. Whilst a benefit of this is that a fair degree of new development can take place on PDL rather than greenfield land, it also means that any additional development will result in the loss of school facilities – either external or internal – alongside harm to the existing SINC.

The optimum area for the residential uses is that which, whilst designated SINC, is earmarked for landscaping and informal open amenity space for pupils. Accordingly, developing this would not result in the direct loss of school buildings, neither would it adversely impact on the borough’s wider open space provision. However, given its core borough function, any harm to this school (or its essential outdoor areas) as a result of development would likely be resisted in the strongest possible terms; more so given the school facilities are GLC better (at the time of writing) less than 10 years old. suited for residential and If this site is selected for the leisure centre, once constructed it could leisure centre offer an advantage to the retained school by way of the sharing and co-location of sporting facilities. In this instant, there may also be the opportunity for a substantial provision of new residential uses to co-locate above it. However, whilst this presents the optimum solution for this Site, it would not outweigh the much wider harm to the school which would result from the direct loss of facilities. It should also be considered in this instant that should the leisure centre be constructed on the existing GLC site, it would only be a short distance from here anyway.

In light of the above constraints, it is considered that the existing GLC site is more suited to the provision of both residential and leisure than this site. Whilst both are MOL, the GLC site if redeveloped would not require the loss, harm, or downsizing of any school facilities. Neither would it result in substantial harm to a SINC.

486: Ealing Golf Course North of River Brent (Hanwell Town Football Club) Whilst the site is not considered publicly accessible open space, it still provides the key function within the borough of hosting a football club, providing formal training playing facilities to members of the public, and hosting children’s day care.

Whilst the establishment of residential uses here would not fundamentally harm this function, the resulting loss of the car park would likely be resisted in the strongest possible terms. Not only GLC better would this reduce the general accessibility of the site, but on match suited for days the resulting impact to the wider area would be majorly adverse residential and as a result of the associated car parking displacement. leisure centre

A new leisure centre here would result in the loss of a formal, floodlit playing pitch. Whilst in response, this pitch could relocate to the northern portion of the site, it would still likely be an unacceptable adverse impact that would majorly prejudice the operation and competitiveness of the football club.

Accordingly, GLC is considered to be better suited for proposed residential and leisure provision on the basis that the co-location of

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a new leisure centre here alongside all requisite 612 residential units would involve the loss of no MOL greenfield land; and no adverse impacts on the site’s usability and sporting and leisure function. 406: Acton Park – Bromyard Avenue (Land South of Bromyard Open Space and Land) New residential uses on this site would comprise entirely PDL. They would not adversely impact upon the facilities provided by the existing leisure centre neither would it harm the adjacent allotments or designated SINC land. Accordingly, this site provides one of the best opportunities for the provision of residential uses – particularly given that it has a lot in common with the existing GLC Site; with its 2-3 PTAL; leisure uses; MOL designation; and the fact that all residential development proposed can be contained on a PDL carpark.

However, in terms of the PDL itself its function is that of a well -used car park which currently serves a number of surrounding sports and leisure facilities. Developing over this car park would therefore result in the displacement of these spaces. There does not appear to be any scope for the displaced parking to be relocated elsewhere across GLC better the site without the fundamental loss of sporting facilities. Neither suited for would there be scope for the parking to be located within the new residential residential development as the site is highly constrained in space terms and the residential units themselves would also require car parking. Accordingly, the current car parking would be displaced off site and into the surrounding area. Given the generally low PTAL of the site, this may have implications on the quality of the wider area and the ability for the public to access the leisure facilities.

Conversely, whilst the existing GLC Site would also require the building over of the car park, the relatively unconstrained nature of the site would allow for its full reprovision in a new basement. Here, leisure centre car parking and residential car parking could be provided side by side, resulting in no parking displacement and no adverse impacts on users within the borough who have mobility issues. Accordingly, the Acton Park – Bromyard Avenue Area Site is not considered to be suitable for the minimum provision of residential uses.

9.2 As set out in summary above, each of the 13 sites assessed are individual with their own set of constraints, uses and opportunities.

9.3 Whilst some have fewer constraints than others with a greater capacity to accommodate development, on balance it is considered that none are able to appropriately support a meaningful provision of residential uses to the same degree and with as minimal an impact as that of the existing GLC site – much less accommodate both the residential and leisure uses at the same time.

9.4 Accordingly, it is considered the existing GLC Site represents the genuine site of last resort in terms of providing a new leisure centre alongside the requisite enabling 612 residential units.

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PART D – CONCLUSION

Gurnell Leisure Centre Conclusion

CONCLUSION

Prelude

1. GLC located within LB Ealing is well used and in need of a significant level of repair and investment. Whilst refurbishment was considered as a first option, it was ruled out as it would not be cost effective and would result in long periods of closure. As such, in March 2015 LB Ealing’s Cabinet made the decision to close the existing leisure centre and replace it with a new state-of-the-art facility.

2. In order to assist with the funding of the new leisure centre LB Ealing entered into a joint-venture with the developer, Eco World Ltd, in order to provide circa 612 residential units to help generate additional revenue.

3. The existing site is currently occupied by the leisure centre, associated car parking and open space. The site however is designated in its entirety as MOL, which is afforded the strongest degree of protection. Accordingly, the provision of a new leisure centre with enabling residential uses here is contrary to the adopted Developme nt Plan. It would only be allowed if, in accordance with the draft London Plan and NPPF 2019, any such development constitutes Very Special Circumstances.

4. In this respect, it was agreed by the GLA and LB Ealing that we must be able to robustly demonstrate that the existing GLC site represents the genuine “site of last resort” whereby no other single site or multiple separate sites within the borough are capable of supporting the minimum development provision of 50 units and / or the leisure centre.

5. Accordingly, the first stage was to create a long list of 543 council-owned sites provided by LB Ealing to be assessed first and foremost as part of the “Cascade Sieve”. In this process, those sites that were too small, already allocated for disposable as part of the Council’s MTFS, or else were generally unavailable were eliminated.

6. From this, a total of 184 sites were progressed through to the Stage 2: Mini Assessments. This stage was devised to review each site in more detail, exploring their key opportunities and constraints and quantitively assessing them against the existing GLC. Those that scored the same of worse were excluded, with those scoring bette r progressing onto the Stage 3: Capacity Study.

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7. A total of 13 sites were thusly shortlisted to the Capacity Study. This study was devised in order to assess the residential capacities of each site. Given the nature of the scheme, it was essential that any site/s chosen for development were genuinely optimised with a view to providing a new leisure and, either cumulatively or singularly, meeting the requisite 612 enabling unit provision. Accordingly, this stage reviewed the capacity of each site based on (i) the current London Plan Density Matrix; (ii) Double the London Plan Density Matrix; and (ii) Quadruple the London Plan Density Matrix commensurate with the current GLC proposal. This would allow us to then assess the smallest possible area required on each respective site that would be able to accommodate the minimum 50 unit provision.

8. With the data obtained from the Stage 3: Capacity Study, Stage 4, as the final stage, sought to examine each site in the greatest level of detail yet . This identified the optimum locations for the proposed development (whether that be the minimum 50 unit quantum or else the leisure centre) based on factors such as access, proximity to existing dwellings, proximity to SINC, existing PDL, heritage, relationship to existing uses etc. This allowed accurate assessments to be made with regards to the true impacts the development would have on each site. Building on this, any scope for increasing the unit provision above 50 in a way that would not exacerbate these impacts was also explored to ascertain a genuinely feasible capacity.

9. These cumulative impacts were then considered against the existing GLC site, and an “on-balance” judgement made to see which one was more suitable or else whose redevelopment would result in fewer adverse impacts.

Residential Conclusion

10. Whilst there were some sites more capable of accommodating new residential uses than others, none were able to accommodate the minimum 50 unit scheme (let alone the required enabling 612 units required) with as few impacts as would be present on the existing GLC site. This is because the current proposal on the existing GLC Site involves not only the comprehensive redevelopment of PDL with no net loss of greenfield land; but also substantial enhancements to the currently poor quality and wider MOL parkland. The impact of this would be an overwhelmingly positive intervention across the Site; whereby a new leisure centre will be provided, co-located with complimentary enabling residential uses and a much improved and highly accessible park.

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11. As above, there were a small number of sites that were considered to provide a generally good prospect for the provision of a minimum of 50 residential units with the view that, should these be considered to fare better than the existing GLC Site overall, they would be shortlisted to provide a proportion of the 612 enabling residential units.

12. Three of these sites were designated as Public Open Space and one was designated as MOL. Islip Manor Park (Site no. 320); Blondin Park (Site no. 332) and Ravenor Park (Site no. 337) were the Public Open Spaces. A key benefit of these sites was, like the existing GLC Site, they were substantial in size. Accordingly, a small amount of development located on their peripheries would have a comparatively nominal adverse impact on landuses and relatively isolated levels of harm on openness and sense of enclosure. The latter impact would increasingly dissipate as one moves further into the vast sites.

13. Where these three sites could not compete however is the fact they comprised little if no useable or developable PDL. Any residential schemes constructed on these sites would therefore result in the loss of greenfield land. Whilst there may have been scope for mitigation to address any harm caused by this, the fact that all three sites are already high quality, Green Flag holding amenity spaces means such improvements would unlikely have any significant and influentially widespread benefits. On balance therefore, it is considered the wider benefits of the proposal on the existing GLC Site would outweigh any benefits of developing on these sites.

14. The MOL site also initially considered as a good prospect for the minimum 50 residential units was Acton Park – Bromyard Avenue Area (Land South of Bromyard Open Space and Land) [Site no. 506]. It is very similar to the existing GLC Site in that is had the same PTAL; same selection of land uses, and there would be no loss of greenfield land given the vast expanse of PDL (an existing leisure centre with ground level car parking) .

15. However, the car park on this site which would provide the optimum location for the minimum residential uses is currently well used by both visitors of t he adjacent leisure centre and also by visitors of the nearby tennis and cricket club. Accordingly remo ving it in favour of new development would likely be highly resisted. Given the highly constrained nature of this site, there is no scope to reprovide these spaces as part of any new development (the site has a PTAL of 2-3 so the new residential units will also need their own parking spaces) which means the parking will be displaced either to the main leisure centre car park or else in the adjacent streets. The result of this will be a “sporting hub” which is substantially harder to access – particularly for members of the

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public with mobility issues, and exacerbated parking problems in the surrounding neighbourhood.

16. The existing GLC Site however is largely unconstrained, with a key facet of the proposal comprising a new basement car park. Accordingly, the leisure centre car parking lost from the ground level parking provision will be provided in its entirety (with an increase in disabled parking bays) back into the scheme. On balance therefore, it is considered that the proposal for the complete 612 residential units on the existing GLC Site would result in fewer adverse impacts than if the Acton Park – Bromyard Avenue Area Site was developed.

Leisure Centre Conclusion

17. Due to the more onerous requirements needed to establishe a new leisure centre, only three of the final shortlisted sites were considered suitable for this use. These were Ravenor Park (Site no. 337), Ruislip Road East and Brentside School (Site no. 485) and Ealing Golf Course North of River Brent (Hanwell Town Football Club) [Site no. 486].

18. In order for the leisure to operate, it must have good vehicle access and open expanse of space with a minimum 0.55ha area that can accommodate a 50 met res length pool. Accordingly, this is a space intensive use which, due to the fact they were already quite refined, was considered unsuitable for Sites 485 and 486 given their adverse impact on the existing land uses and functions.

19. Site 337 (Ravenor Park) was considered the most suitable for this reprovision given its size and current existing access points to the road. A leisure centre in this park would compliment the wider sports provision whilst introducing more investment for enhancements. However, the only suitable location adjacent to the main road would abutting a SINC and would require significant tree removal. Further, the leisure centre would attract a significant increase in road traffic (including coaches) to the local road network and into the park, whilst also (and more fundamentally) resulting in the loss of greenfield land in a designated Public Open Space. Accordingly, the existing GLC Site was considered a more suitable location for the new leisure centre.

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Overall Conclusion

20. This assessment has demonstrated that there are no other sites or combination of sites within LB Ealing that are more suitable to deliver a new leisure centre and / or a minimum of 50 residential units to contribute towards the requisite 612 enabling units.

21. Accordingly, it is considered that the existing GLC Site represents a “genuine site of last resort” – on which this proposal can be accommodated in its entirety with adverse impacts that range fewer than on any other site within the borough. Consequently and in accordance with policy, the benefits of this proposal outweigh any harm with Very Special Circumstances existing to support it.

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