References: 00505/H/P19 P/2020/3099

Address: Homebase, Syon Lane, Isleworth TW7 5QE

Proposal: Full planning application for the demolition of existing building and car park and erection of buildings to provide residential units, a replacement retail foodstore with additional commercial, business and service space, and a flexible community space, and ancillary plant, access, servicing and car parking, landscaping and associated works.

This application has been referred to Planning Committee as major planning application that would require a legal deed if approved.

Application received: 22 September 2020

1.0 SUMMARY

1.1 The application proposes the redevelopment of the Homebase site with mixed-use proposal, comprising a large supermarket and associated car parking as well as 473 homes (35% affordable). The new homes would sit above a podium containing the supermarket and car park, in a series of tall buildings that range in height from 4 to 17-storeys. There are also small community and retail spaces, as well as residential parking, landscaping and areas of new public realm.

1.2 The proposal is integrally linked with a concurrent planning application for the redevelopment of the existing nearby Tesco Osterley site with a mixed-use proposal providing up to 1,677 homes (35% affordable), commercial uses and new public spaces. Relocation of the existing Tesco supermarket to the Homebase site would enable the comprehensive development of the Tesco site and together the schemes are a major strategic regeneration opportunity for the Borough.

1.3 The mixed-use, high density proposal is consistent with objectives promoting the regeneration of the Great West Corridor Opportunity Area through optimising use of previously developed land with new, high quality buildings and public realm including new and improved footpaths and cycleways. The high density scheme optimises the use of the existing under-utilised land with new housing and commercial uses that will help to meet the strategic housing need in the borough, including affordable housing, and will promote and sustain local economic activity and employment.

1.4 The 473 homes proposed equates to 26.5% of the minimum annual housing target for Hounslow. A total of 164 affordable homes (35% of the total homes proposed) would be affordable housing, with 100% being ‘London Affordable Rent’.

1.5 The new buildings would transform the site with contemporary and bold architecture that is appropriate for the prominent location adjacent to the Great West Road. The varied materials and form of the buildings make reference to the surrounding context and has had regard to the constraints of the site. The height and massing of buildings has been moderated to reduce towards more sensitive neighbouring development.

1.6 Owing to the step change in the overall height and massing of the buildings proposed, the development will significantly change the character of the area and there are some harmful impacts to the significance of certain heritage assets through change to their setting, including some assets of the very highest significance. In respect of the significance of the harm identified to heritage assets, officers consider this is to be less than substantial harm. In such instances great weight must be given to the asset’s conservation. The government’s advice is that where a proposal will lead to less than substantial harm to the significance of a designated heritage asset, this harm should be weighed against the public benefits of the proposal.

1.7 The scale of the development and number of new dwellings also has some adverse implications for the local environment, through increased noise and disruption in the area, especially during construction and there would be some adverse effects on some neighbours in respect of daylight and sunlight, though in general environmental impacts on the surrounding area are acceptable and would be able to be mitigated if conditions and obligations were applied.

1.8 The new homes and amenity space would generally provide good quality living conditions with inclusive design, good levels of privacy and outlook, landscaping and children’s play spaces. Owing to its proximity to the Great West Road, appropriate mitigation of air and noise pollution is necessary.

1.9 Expected transport impacts are acceptable with the proposal improving conditions for walking and cycling in the area, aiding the transition to more sustainable travel, whilst the effects on the highway network from traffic and parking impacts are considered satisfactory, with the cumulative car parking numbers across the Homebase and Tesco sites being substantially reduced from the existing parking provision. The development meets requirements for cycle parking, electric vehicle parking infrastructure and Blue Badge spaces. Contributions towards improved bus services, in addition to major junction and public realm improvements, including a new pedestrian crossing across the Great West Road are proposed.

1.10 The proposed development would deliver public benefits to the economic, social and environmental well-being of the area, with these consistent with the aspirations for the Site and its designation as part of the Great West Corridor Opportunity Area in the London Plan and as a location for significant housing and employment growth and area as set out in the Hounslow Local Plan, and the emerging Great West Corridor Local Plan Review.

1.11 Overall the development complies with the Development Plan, and it would bring a range of public benefits from the significant provision of new housing, affordable housing, regeneration of the Site and enhancement of the public realm including improved conditions for walking and cycling, increased economic activity and ecological enhancements. Taking all these matters into account, the public benefits of the development outweigh the harmful impacts identified, and so approval is recommended.

1.12 The recommendation includes relevant and necessary planning conditions, as well as planning obligations, to ensure that the development is acceptable in planning terms and the environmental, and socio-economic impacts are satisfactorily mitigated

1.13 Following the Council’s decision, the application must be referred to the Mayor of London for him to determine whether he is content for the Council to determine the application, direct its refusal, or if he wishes to determine it himself.

2.0 SITE

2.1 The application site (“the Site) is an irregular but broadly rectangular shaped plot with an area of approximately 1.4 hectares. It is located at the corner of Syon Lane and the Great West Road (A4) and is positioned at the western end of the historic stretch of the Great West Road known as the ‘Golden Mile’ at Gillette Corner. The land falls around 4m from its highest point at the northwest corner of the Site to the south of the Site.

2.2 The Site is bounded by a railway to the south, with frontage to the A4 and Syon Lane to the north and west respectively. A car showroom adjoins the eastern boundary. Syon Gate Way, which gives vehicular access to service neighbouring commercial premises, extends along the south-eastern boundary, parallel to the railway.

2.3 At present the Site has a large retail DIY store (Homebase) provided within a modern industrial style building. The existing building has a floor area of 4,180sqm. The building is of metal cladding construction and has a distinctive, tall, mast like structure which gives structural support to the main building. There is car parking to the front and south-west side of the building and a fenced yard, used as an outdoor garden centre, to the rear. Overall there are 295 parking spaces. Trees and shrubs are found along the frontages of the Site with the Great West Road and Syon Lane.

2.4 Vehicular access is from Syon Lane at two points, one midway along the western boundary that serves the main Homebase car park and service yard. A second access is to the Syon Gate Way service road, at the southern end of the Site.

2.5 The A4 is part of the Transport for London Road Network (“TLRN”) and is a ‘red route’ with no stopping. A pedestrian underpass crosses the A4 at its junction with Syon Lane adjacent to the northwest corner of the Site. There are also signalled pedestrian crossings on the A4 just to the west of the Gillette corner junction and to the north east corner of the site opposite Harlequin Avenue. On Syon Lane there are two signalled pedestrian crossings, one is directly to the north of the access to Syon Lane Station and the other is to the north of the car park access to the Site.

2.6 The western side of Syon Lane and Northumberland Avenue which extends westward from Syon Lane, as well as the nearby residential streets forming the Northumberland Estate are part of the Syon Lane South Controlled Parking Zone (“CPZ”) with resident permit holder parking only on Monday-Friday between 9am to 6pm. Other areas in the localities to the north and south of the Site, the latter including the Marlborough Road CPZ are also subject to CPZ restrictions that limit on-street parking.

2.7 Syon Lane station is immediately to the southwest of the site with access from Syon Lane. This railway operates services to London Waterloo with 4 direct services an hour on weekdays. Osterley station (Piccadilly Line) is around 1.9km to the west on the A4. Various bus services are located within walking distance of the site including the H28 on Syon Lane providing a route to West Middlesex Hospital, Hounslow town centre and Cranford, and the H91 a route to Osterley Station and Hammersmith. The existing Public Transport Accessibility Level (“PTAL”) of the Site is 2 on a scale of 0- 6b, where 6b is highest., which is poor, though the southern end of the site is 3 or moderate on account of its proximity to Syon Lane Station.

Figure 1: Application site

2.8 The Site is not allocated in the Hounslow Local Plan (“HLP”). It has previous industrial history. The Site has no listed buildings and is not within a conservation area.

2.9 The London Plan (“LP”) identifies the Site and wider area along the A4/M4 corridor (Great West Corridor) as an Opportunity Area suitable for significant intensification to provide a minimum of 7,500 new homes and 14,000 jobs, as well as transport and environmental improvements.

Surrounds

2.10 The character of the immediate locality is very mixed, with the Site being located opposite suburban areas to the west and south but with large scale, mostly commercial development, opposite to the north and adjacent to the east. The broad boulevard like but traffic dominated Great West Road has generally large, sometimes monumental scale buildings along its frontage, which differs markedly from the much finer urban grain, and domestic scale (mostly 2-storey) of the nearby suburban areas.

2.11 On the opposite side of Syon Lane from the Site to the southwest there are 2-storey semi-detached maisonettes (1-20 Northumberland Gardens) beyond which there is overwhelmingly interwar suburban housing. This residential area is recognised in the Council’s Urban Character and Context Study as being an ‘Area of Special Character’ with the townscape being very uniform in character. There is also newly constructed commercial self-storage building on the opposite corner of Syon Lane and the Great West Road (up to 5-storeys). Crossing railway lines to the south, passing Syon Lane Station, there are playing fields of The Green School for Girls and further areas of suburban housing, including 2-storey houses and maisonettes on Brambles Close and 2-storey terraced and semi-detached houses in Cherry Crescent which back onto the railway.

2.12 Syon Park, a Grade I registered park and garden with many listed buildings and designated as Metropolitan Open Land (“MOL”), lies to the south of London Road, at its closest approximately 450m away, with there also being a number of listed buildings including the Grade I listed Syon House which is around 1km away. This area is part of the Isleworth Riverside Conservation Area. Further south, across the Thames around 1.4km to the southeast is the Royal Botanic Gardens at Kew, a World Heritage Site (“WHS”). Part of the WHS buffer zone includes Syon Park. The WHS is also a Grade I registered park and garden and a conservation area.

2.13 North of the Site, on the opposite side of the Great West Road and extending along Syon Lane is the landmark Gillette Factory, a large 1930s brick factory and office building with a tall brick clocktower. This building is Grade II listed. Adjacent and nearby are other listed buildings and structures including the former Natwest Bank building (Grade II), lamp standards and phone kiosk (also Grade II). To the north of the Gillette building is the Osterley Tesco site. Other development on the north side of the Great West Road includes a former office complex, ‘New Horizons Court’ which is being converted to housing under permitted development, and commercial buildings including the Sky Campus. There is also a small shopping parade on Syon Lane beyond which is more suburban housing and Osterley Park, the latter being a Grade II* registered park with listed buildings including Grade I Osterley House, with the area and surrounds forming part of the Osterley Park Conservation Area and the park itself also designated as MOL.

2.14 To the immediate east is a modern car showroom and then the Grade II listed ‘Coty Factory’ (now the Syon Clinic) a modernist 1930s building. Commercial buildings including a number of Art Deco style listed buildings are found along the Great West road heading east. Very tall buildings are found at the GSK site, the University of West London and Great West House along the Great West Road.

2.15 In the wider region around 800m to the north-east, Boston Manor Park falls within the Grand Union Canal and Boston Manor Conservation Area and includes the Grade I Listed Boston Manor House and around 700m to the west is the Spring Grove Conservation Area.

Emerging Planning Framework

2.16 The Site is allocated for development in the emerging Hounslow Local Plan review (‘Site Allocations – Local Plan Review Volume 2 Submission’, September 2020). The allocation proposes a mixed-use development with large format retail, new housing, employment uses and parking with an enhanced public realm. The minimum quantum of development is:

 Retail and Business – (10,940 sqm)  Housing – 370 homes

3.0 PLANNING HISTORY

Application Site

3.1 Up until the building of the Great West Road in the 1920s, the long established use of the Site and surrounds was mostly as agricultural land comprising market gardens providing produce for nearby London, along with some historic settlements and large private estates including Syon House and Osterley House. From the late 1920s the areas along the Great West Road east of Syon Lane developed as a manufacturing area with many Art Deco style factories being built including Gillette. This distinctive character of modern manufacturing buildings was labelled the ‘Golden Mile’. During the 1930s much of the surrounding housing in the locality was built to provide accommodation for workers with this corresponding with improvements to transport.

3.2 A winery and brewery was built on the Site in the 1930s and it remained an industrial site until the existing Homebase building was built in the 1980s. Planning permission 00505/H/P16 was granted in 1987 for the erection of a DIY retail store with garden centre and associated parking. The existing building was designed by Nicholas Grimshaw and Partners. Since it was built there have been various consents for minor alterations and advertisements at the Site.

3.3 Following requests to heritage list the building the applicant applied for immunity from listing. The Secretary of State for Digital, Culture, Media and Sport issued a decision1 in December 2019 that provides immunity from listing (for five years) The decision commented that the building “…has a degree of interest as a building of some note designed by an eminent architectural practice, but overall it lacks the requisite special architectural and historic interest for a post-war building of this type to be listed.”

Significant Development Proposals on Nearby Sites

1 Certificate of Immunity issued 3 December 2019. 3.4 Gillette Factory – Gillette ceased production of products in 2006 and subsequently sold their building. In 2007 planning permission (00505/AP/P74) was granted for the comprehensive redevelopment of the site with the conversion and extension of the main building to a 505 room hotel with ancillary conference facilities, 624 parking spaces and new buildings to the rear and fronting the Great West Road (4 to 6- storey) for office and light industrial; use. This permission was extended in 2010 for a further three years but it was not implemented and it has expired. The building is currently used for film production.

3.5 Former Syon Gate Service Station, Land at South of Gillette Corner, Great West Road – A proposal for a mixed-use development of the former petrol station site, providing 102 homes and self-storage in a building of between 4 to 11-storeys was refused permission in 2017 (00505/AF/P27). Reasons for refusal were its harmful effect on the character of the area and setting of heritage assets and an unacceptable affordable housing offer. Planning permission (00505/AF/P28) was subsequently granted in 2020 for a new building for self-storage and office use, of up to five-storeys (36.3m – 37.65m AOD), and 25 car parking spaces and this building is nearing completion.

3.6 New Horizons Court, Ryan Drive, Great West Road – Various prior approvals (permitted development) and planning applications relating to the former office complex to convert buildings to residential use, with alterations and additions, have been allowed on appeal or granted from 2017-2019. These have authorised a total of 302 homes and these are now being provided with works having commenced.

Tesco Site Planning Application

3.7 The application for the Site has been submitted in conjunction with a planning application (01106/B/P137) for the redevelopment of the existing Tesco Osterley Site. Once a new Tesco supermarket has been opened on the Site, the current Tesco Site would be redeveloped with a mixed-use scheme that has up to 1,677 new homes (35% affordable), and associated commercial uses, public realm and open space, and parking, within buildings that are 2 to 17-storeys.

4.0 PRE-APPLICATION PROCESS & CONSULTATION

4.1 Planning Performance Agreement

4.2 The Council and applicant entered a Planning Performance Agreement (“PPA”) in 2019. The agreement sought to provide pre-application advice to assist the preparation of an application and establish key issues and procedural requirements. The process did not involve a full assessment of the proposals and comments made were without prejudice to formal consideration of any planning application.

4.3 The PPA meetings identified the main issues to be considered, including the townscape and heritage impacts, transport and parking impacts, walking and cycling improvements, environmental issues, affordable housing and housing quality, infrastructure, and impacts on neighbours. The applicant also consulted the Mayor of London and Transport for London during this process.

4.4 The PPA confirmed an Environmental Impact Assessment (“EIA”) was required, and the Council issued a formal Scoping Opinion on the applicant’s EIA Scoping Report on 11 October 2019.

4.5 Community consultation

4.6 The applicant has undertaken pre-application consultation comprising public exhibitions, newsletter drops, online surveys and meetings with local stakeholders. This included establishing a ‘community liaison group’ (“CLG”) comprising of residents from local community groups and interested residents. Early on in the process, an architects selection panel was held with the local community for the Osterley site in October 2019, as well as door knocking and two ‘walk and talk’ events in November 2019 to understand residents aspirations for the sites & surrounding area.

4.7 Separate consultation has been carried out directly with:

 Greater London Authority  Transport for London  Historic England  Hounslow Chamber of Commerce  North West London Clinical Commissioning Group  Nishkam School

4.8 The applicant held three public consultation events, advertised as ‘drop in’ consultations with information posted on local websites, in the local newspaper and via 3,500 flyers distributed locally. Key members of the applicant’s design team including architects attended to explain the scheme. The dates of the physical consultation events, which were all held at the Marlborough Primary & Nishkam Schools are as follows:

 1st Consultation Event: 3rd & 8th October 2019  2nd Consultation Event: 27th and 29th February 2020  3rd Consultation (Virtual): Two weeks between 14 August and 28 August.

4.9 Alongside the exhibition events, a number of other consultation events were undertaken:  Introductory presentation to ward councillors and residents groups  Walk and talk sessions  Door knocking  Establishment of CLG  Community Christmas events and pop-up stalls  Regular updates through community newsletters & website updates  Engagement with local schools and youth groups

4.10 The application undertook three rounds of online surveys in conjunction with the public exhibition events; The first round of took place in October 2019 with the second round taking place in February 2020, and with the final feedback round in October 2020. Each round lasted for three weeks and generated over 3,500 pieces of detailed feedback.

4.11 Eight local residents and seven local organisation groups joined the CLG. Between December 2019 and August 2020 Six CLG meetings were held, each focusing on a different discussion topic, Dates for these are as follows:

 CLG 1: Community and Local Identity 6th December 2019  CLG 2: Traffic and Transport 17th December 2019  CLG 3: Open Space & Plan 14th January 2020  CLG 4: Public Exhibition Preview 25th February 2020  CLG 5: Architecture and Landscape 18th June 2020 (VIRTUAL)  CLG 6:Pre-Submission Update 13th August 2020 (VIRTUAL)

4.12 Alongside these formal consultation events, the applicant undertook a number of community activities; in December 2019 St Edward hosted two community Christmas events (a Christmas Film screening event and Santa’s Grotto at the Tesco store) and in October and November 2020 pop-up coffee stalls were held at the Tesco store to engage with local residents and interested parties. There was also a programme of youth engagement in February 2020, running skills and CV workshops with Nishkam School and Hounslow Youth Council.

4.13 Information was sent to local ward members and the Planning Committee. A proposal was presented to members of the Planning Committee for comments by the developer at the ‘Planning Development Proposals Forum’ on 28th July 2020.

5.0 DETAILS OF THE PROPOSAL

5.1 The application seeks full planning permission for the redevelopment of the site to provide a mixed use scheme with a new Tesco superstore, 473 new homes, of which 164 would be affordable homes (London Affordable Rent), car parking, landscaping and public realm and highways works. The relocated Tesco store will facilitate the redevelopment of the existing Tesco Osterley site with a comprehensive scheme of regeneration comprising up to 1,677 homes and a range of local commercial and community uses as well as extensive areas of new public realm and landscaping with this proposal the subject of an application for outline planning permission.

5.2 In summary the proposal for the Site is for:

 473 homes of mixed tenure  35% affordable housing (by unit)  A new Tesco retail store of circa (10,550sqm GIA)  Community space of 200sqm;  137sqm (GIA) of flexible retail floorspace;  400 retail car parking spaces  99 residential car parking spaces (amended from 105 spaces to accommodate improved cycle parking provision)  88 retail cycle parking spaces  843 residential cycle parking spaces  Communal amenity space including open space and children’s play space  New public realm to Great West Road and Syon Lane  New ‘clean air route’ along Syon Gate Way and along eastern side of site  Highways works to improve pedestrian and cycle movement and accommodate vehicular traffic

Design and Layout

5.3 The proposed development is in the form of a new ‘urban block’ comprising a three level podium that covers most of the Site above which would be a series of tall residential blocks that range in height up to 17-storeys. The new Tesco store occupies much of the ground floor and fronts the Great West Road and Syon Lane, with servicing, staff areas, plant and storage provided to the rear of the main retail area. The customer entrance is at the front of the Site facing Gillette Corner. A small unit for flexible business use is located to the ground floor facing Syon Lane and a 200sqm space for community use is proposed on the first floor.

5.4 An existing means of access from Syon Lane would give vehicular access to a vehicle ramp that serves a two level car park that sits over the Tesco store within the podium, with this providing 400 customer parking spaces, as well as 99 resident car parking spaces, 3 visitor and 2 car club spaces. Landscaped public realm, including pedestrian pathways are provided around the perimeter of the block. There is a part lower ground floor to the southern side of the site containing access for servicing, including deliveries and refuse collection, and access to a small residents’ car park.

5.5 The new housing sits above the landscaped podium within seven main blocks some of which are conjoined. The blocks have a rectangular form apart from the distinctively stepped and curvilinear shaped building adjacent to Gillette Corner. These blocks range in height (including the podium) from 6 to 17-storeys. The main entrance to the housing is located at the southern corner, adjacent to Syon Lane, closest to Syon Lane station. This entrance includes a lobby and concierge and would be used for access to all blocks via the landscaped podium. Other residential entrances to individual blocks are located on Syon Lane, the Great West Road and a new laneway proposed along the eastern side of the Site.

Figure 2: Layout of Proposed Housing Blocks

5.6 The residential blocks are designed as a composition of buildings with heights and spacing between designed to respond to the surrounding context and housing standards. The general design of each main block is described as follows:

5.7 Block A – Located adjacent to Gillette Corner, at the junction of the Great West Road and Syon Lane, this building has a terraced form with curved floorplan to the west. It has 6-storeys adjacent to Syon Lane and then rises in double storey steps across the Great West Road frontage to be 12-storey at the centre of the frontage (62.8m AOD). It has Art Deco inspired styling and looks to mark the junction. It would be of brick construction with a distinctive blue colour articulated by a hierarchy of horizontal banding including white brick with bronze and white metal details. There are inset balconies and large terraces. The podium elevations have large areas of glazing and open louvres plus store signage. A residential entrance is located central from the ground floor facing the Great West Road.

Figure 3: Gillette Corner streetscene – Blocks A and B1

5.8 Blocks B1, B2 and B3 – Extending from the northeast corner fronting the Great West Road and along the length of the eastern side of the Site, these conjoined blocks together form the tallest and largest buildings. Block B1 fronts the Great West Road and is a tall tower (17-storey). This tower is the tallest building proposed and sits adjacent to Block A. It has vertical detailing with strong horizontal banding every two floors, with curved details with balconies, and has similar Art Deco inspired styling to Building A. Blocks B2 and B3 are located in the middle and rear of the site respectively and are each 15-storey with 10-storey elements joining them to each other and Block B1. They have a more regular form and are articulated by different brickwork, balconies and recesses. Residential entrances are provided at the ground floor to each block.

5.9 Block C – This Block is at the southern end of the Syon Lane frontage and is designed to emphasise the main arrival point for the housing, the ground floor providing the main residential entrance and residents’ lobby. It has 10-storeys and has a residential character with wide balconies to Syon Lane and projecting balconies to the south elevation. It would be of brick construction (brown coloured) with secondary brick and metal detailing for articulation. The ground floor is recessed at the corner to highlight the entrance.

Figure 4: Syon Lane streetscene – Blocks C, D and E

5.10 Blocks D and E – These two blocks front Syon Lane and are 7-storey, with an additional storey set back 17.3m from the street frontage. These buildings share the same design and are separated by the car podium and supermarket. They extend perpendicular to the Syon Lane across the podium, so have their narrowest end facing the road. Both buildings are of brick construction, with lighter colours (white and cream, accentuated by green coloured glazed brick panels to the façade.

5.11 Building Heights – The development is comprised of an urban block with a series of towers rising above the large podium. The maximum building heights for blocks (plus with recessed roof plant and parapet) (above ordnance datum) within the proposal are:

Block Maximum Height (AOD) A 62.8m (+0.3m) B1 78.55m (+1.8m) B2 72.25 (+1.8m) B3 71.95 (+1.8m) C 55.9m (+1.8m) D &E 46.45m – 49.9m Syon Lane 35.3m Podium Table 1: Proposed Maximum Building Heights

5.12 The overall building massing is shown in the following image:

Figure 5: Syon Lane streetscene – Blocks C, D and E

Non-residential Uses

5.13 The proposed Tesco Extra store occupies most of the ground floor with the 400 customer parking spaces provided at the first and second floors of the podium. The new store has a floor area of 10,550 sqm (GIA) providing a retail supermarket and household goods and clothing, a café as well as an instore pharmacy and opticians. It fronts Syon Lane and the Great West Road where there will be glazed frontages, with the entrance facing Gillette Corner. A 200 sqm community space for flexible use is proposed on the first floor overlooking the corner. This space is to be managed by Tesco and would be available free of charge. Access to the first and second floor car parking and community space is provided by travellators and lifts. The store’s opening hours would be the same as the existing Tesco Osterley Store, 7AM – 10PM Monday to Saturday and 10AM – 4PM on Sundays and Bank Holidays. The proposed store would replace the existing Tesco Osterley store, which has c.11,582 sqm GIA of retail floorspace a petrol filling station and car parking (625 spaces).

5.14 A separate unit, for flexible retail use, with an area of 137sqm (GIA) is proposed fronting Syon Lane, adjacent to the main residential entrance for the development.

Housing

5.15 A total of 473 homes are proposed within Blocks A-E. All homes meet the minimum space standards. Affordable housing is proposed in Blocks B2 and B3, with a total of 164 homes to be provided as affordable rent units at London Affordable Rent (“LAR”). The proposal is to be considered as ‘fast track’ affordable housing, with the scheme achieving the requirement to have a minimum of 35% affordable housing There are a total of 1,252 habitable rooms (776 private and 476 affordable), with 38% of the habitable rooms to be affordable. At least 10% of the homes (48 proposed), across the tenures would be provided as ‘wheelchair user dwellings’. All housing is in the form of 1, 2, 3, or 4-bedroom flats with the mix of units as follows.

Size Tenure Total 1 bed 2 bed 3 bed 4 bed No. 136 153 20 - Market 309 Mix 44% 60% 6% - Affordable No. 62 57 40 5 164 Mix 37.8% 34.8% 24.4% 3%

No. 198 210 60 5 473 Total Mix 42% 44% 13% 1% 100%

Table 2: Proposed Schedule of Accommodation

Size Block A Block B1, Block C Block D Block E Total B2 and B3

1 bed 19 104 45 18 12 198

2 bed 38 113 31 12 16 210

3 bed 8 44 0 4 4 60

4 bed 0 5 0 0 0 5

Total 65 266 76 34 32 473

Table 3: Proposed Schedule of Accommodation

Public Realm, Landscaping and Amenity Space

5.16 The development proposes new landscaped public realm around the base of the building, with new and improved walking and cycling routes along the perimeter of all four sides of the Site. A ‘Clean Air’ route, providing an alternative to using Syon Lane and the Great West Road, is proposed along the southern and eastern sides of the Site. Along Syon Lane and the Great West Road, enhanced cycleways and new street tree planting is proposed. A stepped ‘amphitheatre’ space, providing new public realm for access and seating is proposed to the north-east corner, outside the proposed Tesco store entrance.

5.17 The homes have private amenity space from balconies and roof terraces (with two having an internal amenity area). Communal amenity space is provided on the roof of the podium (level 4) with landscaped areas and playspace between blocks. Access to the amenity space will be step free from each block and is available to all residents. The overall area of communal amenity space on the podium is 4,928 sqm, with this area including children’s play space. Access and Parking

5.18 Access around the site would be improved through new public realm works around the perimeter of the building with wider pedestrian pathways and new cycleways. Pedestrian access to the residential cores will be from the site’s four frontages, on the Great West Road, Syon Lane, Syon Gate Way and Syon Gate Lane. There are lifts and stairs to all levels of the buildings, with access between the retail parking and Tesco store also by travellator. A dedicated Tesco staff entrance is located midway along Syon Gate Lane.

5.19 The existing vehicular access from Syon Lane would be used to provide access to the main car parking area for the Tesco and residential parking, with new signal controlled access proposed. The proposed car park is accessed by ramp with two exit lanes and one entry lane onto Syon Lane. No barrier is proposed. Syon Gate Way would also provide access to a second access for further residential parking spaces that are provided at lower ground level.

5.20 A total of 499 car parking spaces are proposed. Of these, 400 are for the Tesco store and 99 are for the housing (including 2 car club and 3 visitor spaces). The residential parking ratio is 0.20 spaces per unit. Of the Tesco spaces, 20 are wheelchair accessible and 16 are family with children spaces, and for the residential parking 26 are wheelchair accessible.

5.21 Cycle parking for residents is provided throughout the residential blocks, with 13 separate long-stay cycle storage areas providing a total of 843 cycle parking spaces. Cycle parking will take the form of both two-tier stackers (500mm spacing) and Sheffield stands. Of the 843 spaces provided, 250 would take the form of a Sheffield stand (30%). Of these, 42 (5%) would be oversized to accommodate non-standard cycles. There is also a space provided for accommodation of communal residential shower and locker facilities for cyclists.

5.22 The new ‘Clean Air Route’ proposed for pedestrians and cyclists, along Syon Gate Way and the new lane to the eastern side of the site (Syon Lane Way), will be a minimum of 3m wide.

5.23 Works to the adjoining highways, Syon Lane and the Great West Road, to junctions, the pedestrian and cycle network and public realm, including pedestrian crossings, are also proposed. The cycleway along the Great West Road frontage would be made continuous and separated from the adjacent traffic lanes.

Servicing and Deliveries

5.24 All servicing for the Tesco and housing would be provided from Syon Gate Way. A new service yard and loading bay for Tesco is proposed within the ground floor, with delivery vehicles able to enter and exit the site in a forward direction. Servicing and deliveries to residential buildings will be from the loading bay on Syon Gate Way with all deliveries taken to the residents’ lobby and concierge.

5.25 Waste and recycling from Tesco would be managed commercially using the Tesco servicing yard. For the housing, a refuse/ recycling store is located at the podium level for each building core. Building management will move full bins on a daily basis and replace them with empty ones. They will be transported via a lift to the lower ground floor where they will be stored. On collection day, bins will be transported to Syon Gate Way for collection.

Sustainable Design

5.26 The new buildings and public realm have been designed to maximise sustainable design performance. The energy strategy follows the London Plan’s energy hierarchy to reduce CO2 emissions, including use of Air Source Heat Pumps for heating and hot water requirements plus rooftop solar PV for on-site renewable energy. These measures result in an estimated CO2 emissions reduction of 51% over the Part L 2013 baseline.

5.27 The development also incorporates measures to minimise water consumption, facilitate recycling, use sustainably sourced materials where possible, control flood risk and surface water runoff and enhance greenery and biodiversity across the Site including through new landscaped areas with tree planting and from use of green/ brown roofs to the flat roofs of the housing blocks. The improved conditions for cycling and walking, optimisation of the density of the Site and limited car parking for residents would also help ensure the sustainability of the development is promoted.

Further Information and Amended Drawings

5.28 The applicant submitted further information and made amendments to the proposal in response to comments from officers and consultees on a range of issues, with these including:

 Materials and detailing of eastern façade  Refuse and recycling store design  Location of wheelchair units in Block B2  Design of the ‘Clean Air’ route  Revised Energy Strategy  Revised Drainage Strategy  Correction to Community Infrastructure Levy form  Additional information about Play Strategy, links to the Tesco Site, and Urban Greening Factor-Biodiversity Net Gain  Additional viewpoints for the heritage impact assessment  Cycle storage and access

Environmental Impact Assessment

5.29 The application includes an EIA. Before determining the application the Council must consider the environmental information contained in the Environmental Statement (“ES”), including the further information submitted, as well as representations from consultees about the environmental effects of the development.

5.30 The ES assesses likely environmental impacts from the development including its construction and operation, cumulative impacts from other committed and proposed developments including the proposals for the Tesco site. The ES identifies the existing (baseline) environmental conditions, and the likely environmental impacts (including magnitude, duration, and significance) and also identifies measures to mitigate any adverse impacts. A summary of potential positive and negative residual effects remaining after mitigation measures is also given.

5.31 The ES itself does not necessarily consider compliance with planning policies and so planning permission does not have to be granted or refused based on its findings, but these are material considerations. Where significant adverse effects are found, consideration will need to be given to mitigation proposed and then ultimately to whether the remaining impact warrants refusal or if such harm is outweighed by other benefits.

5.32 The ES contains analysis of impacts for the following topics:

 Alternatives and Design Evolution  Construction Methodology and Phasing  Population and Human Health  Built Heritage  Townscape and Visual Effects  Transport and Access  Noise and Vibration  Air Quality  Daylight, Sunlight and Overshadowing and Solar Glare  Wind Microclimate  Summary and Residual Effects

5.33 Officers are satisfied the ES (taken together with the other application documents) and the further information submitted which includes some revised drawings and addenda to the original statement, which do not alter the conclusions about the likely effects of the development, and has adequately considered the potential environmental impacts of the development.

6.0 CONSULTATION

6.1 The application is accompanied with an ES, with publicity and consultation being carried out in accordance with the Town and Country Planning (Environmental Impact Assessment) Regulations 2017 and Planning (Conservation and Listed Buildings) Act 1990.

6.2 A site notice and a press notice advertised the application, and copies of the ES and other application documents were made available on the Council’s website. Consultation letters were sent on 25 September 2020 to statutory consultees, neighbouring boroughs and local amenity societies, and to 2,700 properties within the surrounding area. Notice and details of the application were included on the Pending Decisions List (20 – 27 November 2020) sent to members of the Planning Committee, ward Councillors and amenity groups.

6.3 Following preliminary assessment of the application, further information was provided by the applicant in response to comments from officers and consultees.

6.4 Further site and press notices advertised the application and receipt of further information and a second consultation was undertaken, with letters sent on 25 January to all original consultees and those people that had made a submission.

Responses

1st Consultation

6.5 Apart from responses from statutory consultees and local bodies and amenity groups, there were 490 objections, 2 neutral response and 25 in responses in support from individuals.

2nd Consultation

6.6 There were a further 333 objections, 1 neutral response and 2 responses in support from individuals, including responses from people that had already objected.

6.7 Responses from individuals, amenity groups and statutory consultees to the consultations are summarised below.

Objections

6.8 Heritage

 Substantial harm to the setting of the Royal Botanic Gardens, Kew, which is a World Heritage Site (WHS) and also Grade I Registered, and Grade I Syon Park which forms part of the buffer zone for the WHS  The development would damage to an unacceptable degree the historic setting of internationally significant ‘Capability’ Brown designs at Syon Park-Kew and the significance of the two landscapes will be compromised by the substantial harm  There is a substantial likelihood of the Kew WHS being put on the ICOMOS At Risk list of WHS  It causes ‘substantial harm’ to the setting of heritage assets , including Gillette building (Grade II), Syon Clinic (Grade II), Natwest Bank (Grade II)  Harm to views from Osterley Park (Grade II*) and Syon Park (Grade I).  Would dwarf the surrounding heritage assets  Poor relationship to existing heritage  Should not be higher than the Gillette Clock Tower which is an iconic landmark  Views of Gillette tower from Kew Gardens would be lost  The Area reflects the Art deco period and Gillette is the gateway to the Golden Mile which will be overshadowed as will period housing, Adini and St Francis Church which are also listed buildings

6.9 Design and Townscape

 Buildings are too tall for the area and would dominate the skyline  High-rise buildings are out of keeping with the scale and character of the surrounding suburban houses  The building heights (4 to 17-storeys) are excessive and overbearing  Would dramatically change the appearance and character of the area  Design, appearance and materials do not fit the local area  Architectural design is of poor quality for such an important landmark location  Contrary to Mayor of London’s guidance on tall buildings  Excessive bulk  Height and congested site would dominate and detract from other potential developments further east along the Great West Corridor  Out of character for the green, family-focused, community-minded character of the Osterley area  Would be an eyesore  Massive overdevelopment  Should be houses, not flats  Should be no higher than 4 to 6-storeys  Lack of green space  Need more open spaces rather than buildings  Inadequate building setbacks that are not in keeping with surrounds  Inadequate building setback reduces openness for pedestrians and cyclists  Agree with many of the recommendations from Hounslow’s Design Panel  Development far exceeds the appropriate density and does not balance the needs of the local area with an improved design  Loss of iconic Homebase building and sign

6.10 Environmental and Amenity Issues

 Harm to the quality of life of the existing neighbouring residents  Disruption from construction activity including dust, unacceptable noise levels, heavy goods vehicle construction traffic to neighbouring residents and access  Overlooking and loss of privacy from new housing  Increased air pollution  Increased noise pollution  Adverse health effects from air pollution including asthma  Loss of daylight to Northumberland Gardens  Loss of daylight to Brambles Close  Homes are not zero carbon  Use of gas boilers  No justification for demolishing Tesco and Homebase instead of reuse  Does not meet Zero Carbon targets and Climate Emergency measures  Increased level of CO2 emissions from new residents  Solar panels not fully exploited  Tall buildings require huge foundations, produce big shadows, especially in winter  Concrete foundations and a steel framework are the least sustainable of building materials  Solar glare to drivers on Great West Road and railway  Over use of the carbon offset which can only be used if the emissions cannot be removed by better energy design measures on site  High rise development is likely to create a wind tunnelling effect  Increased noise, carbon emissions, visitors and traffic pollution, especially during the proposed long construction time, will have an effect on the limited wildlife in the area and at Osterley Park  Loss of views of horizon over low lying development  Effects on bats  Possible adverse effect on employment at nearby businesses from construction work

6.11 Housing and density

 Too many units  Flats are not required in the area  Should be two-storey homes  Housing too dense as density is 15 times the rest of the ward  Densely populated blocks risk another ‘Grenfell’  Poor quality housing for new residents  Only meet minimum standards  Insufficient storage for residents  Units suffer from poor air quality and noise, especially adjacent to the Great West Road and at times rely on mechanical ventilation  Amenity space only at podium level  Amenity space/ gardens, overlooked by blocks of flats  Concerned about safety for children’s play spaces from climbing balconies  Inadequate area of amenity space for new residents  High density will lead to future mental and physical health problems  Congestion will lead to social problems and increasing crime levels  Most homes are 1 or 2 bedroom  Proposed housing mix of 42% 1-bed flats, 44% 2-bed flats, and 13% 3-bed and 1% 4+ bed – does not meet the current needs of the area.  Will not result in any significant increase in homes for families. Instead it will be occupied by working week commuters, transient renters etc.  Commercial area not suitable for housing due to poor environment  Should not increase in population or have smaller units due to coronavirus  Does not incorporate Active Design using Sport England guidance  Adverse social impact from density  Will cause an urban slum in an open suburban area  Enables private landlords to exploit people too poor to get onto the property ladder  The duty to provide additional homes must not be at the expense of the incumbent population

6.12 Transport

 Traffic generation would exacerbate existing traffic congestion  Increased congestion at peak hours at Syon Lane and Gillette corner  Increased traffic at unsafe intersection (Great West Road and Syon Lane) also affecting access to new Tesco store entrance and Northumberland Avenue  Entrance and egress from the new Tesco store will cause congestion and danger  Area already suffering from traffic of the Great west Road, with pick up and drop off to Nishkam School, building works at Bolder academy and traffic to Tesco  Traffic will block the Northumberland Road, preventing local residents accessing their homes  Previous traffic forecasts (Nishkam School) underestimated reality  Road safety would be decreased  No evidence for claim of reduced traffic  Inadequate public transport and no new transport proposed  Safety issue and shoppers will use taxis and vans more due to poor traffic layout  Decreased in safety for children crossing roads caused by increased traffic pushed onto Northumberland road  No funding is available for the proposed Southall Rail Link or West London Orbital Link, or improvements to Hounslow Loop or Piccadilly line.  New development should only be considered in the light of Golden Mile station actually being built and not in advance of it  Impact on Syon Lane station that has restricted carriages that can be used due to small platforms  Insufficient infrastructure budget to support scale of development - circa £30 million proposed versus probable figure more like £50 to 100 million  Bus and trains are already at capacity and overcrowded  Extra footfall in the narrow alleyway of Northumberland Gardens to the station  Car spaces for residents is inadequate  3 car parking visitor spaces are totally inadequate  Lack of car parking for the Tesco store (reduced from existing store)  Adverse impact on elderly and families from reduced Tesco store parking  There are people who do not like to use multi-storey car parks and yet there is no parking at ground level  Overspill parking onto neighbouring residential streets including overnight parking in CPZ area  On street parking in locality is already congested  No evidence of involvement of Sustran or Active Travel plans as part of the development  Transport Assessment was carried out prior to local road changes which has led to more congestion especially in rush hours. The TA should be updated to take into account the congestion caused and provide suitable mitigation measures  Impacts from construction traffic on local roads

6.13 Infrastructure

 The density of the residential development will put too great a strain on the transport and social infrastructure of the locality.  Extra 1,100- 1,500 residents cannot be accommodated  Addition of 1,500 residents on this site and 5,000-6,000 residents on the nearby Tesco site will overwhelm local services, transport and infrastructure  Inadequate amenity space for new residents  Adverse impact on health services including GPs and West Middlesex hospital  Increased pressure on emergency services  Insufficient school places for new residents  Insufficient GP places for new residents  Cumulative impacts on infrastructure with Tesco Site proposal  Lack of water supply  Where will new residents work?

6.14 Policy and Uses

 Contrary to Local Plan policies for design, housing, heritage  Fails to comply with the Council's own Local Plan and Great West Corridor Plan.  Need destination restaurants, cafes, retail shopping and vibrant leisure facilities both private and public and a greater choice of essential shopping that serves the increased population  No GP surgery or dentist proposed  There is a need for a swimming pool and gym in the area  No proposal to build a petrol station on the new Tesco site, meaning the Shell garage at Gillette Corner will need to fulfil the needs of a hugely increased number of customers, causing tailbacks and long waiting times  Private podium space is only accessible to residents in the blocks of flats so the local community will not benefit

6.15 Other

 Inadequate consultation  Publicity material not representative of the proposal and did not show true density and height  Consultation responses ignored  The Council has agreed to purchase 164 units off plan, before planning consent has been granted so it is difficult to understand how the Council can reach an objective decision on the project

Support

6.16 Regeneration and Economic Activity

 Will create jobs and homes  Investment this development will bring to the local area and the Borough should contribute substantially to the community, particularly welcome given current economic downturn  Releases the existing Tesco site for a huge new mixed use scheme bringing significant economic stimulus to Hounslow  Converting car parks to green spaces, homes and jobs is a fantastic opportunity for the regeneration of the Golden Mile  Will help catalyse the regeneration of the Golden Mile that is critical to the future of our local area.  A positive proposed development, in line with the Borough's vision for this location  Safeguarding and creating 650 permanent jobs  As a local business facing the toughest economic climate in decades due to COVID19 we particularly look forward to the employment opportunities arising from the scheme  The exponential rise in unemployment in the Hounslow area will require new investments to create job opportunities in the local area.  The creation of construction jobs will provide much needed apprenticeship opportunities for local people in the construction industry  Employment and Skills Plan to help maximise local employment opportunities and improve local skills levels through school and further education engagement in the local area

6.17 Townscape and Design

 Creates a landmark building creating new homes, shops and employment will revitalise this rundown area which is currently a decaying and shabby site  High quality, well designed homes with smart landscaped areas  Enhances the appearance of the locality which currently is dominated by a massive car park and warehouse style building  The proposed scale and massing of the scheme is appropriate due to the significant setback between the site and any sensitive receptors

6.18 Transport and Infrastructure

 Improves the junction at Gillette corner  New and safer pedestrian and cycle routes to be delivered  Supporting new local bus routes  Proposed improvements to the local road network  Improvements to the local roads and other infrastructures that come with the new development will also benefit all sporting venues as well as the Bolder and Nishkam schools  Very accessible location as close to Syon Lane station

6.19 Environment and Amenity

 Great project it will create a family environment where the community will enjoy the area more  A commitment to our green economy supporting carbon positive and sustainable practise from construction to the operational phase

6.20 Other

 Welcome new affordable housing  35% affordable housing  Will enhance the demographic mix of the local population bringing much needed mix of families and young professionals to the area with additional spending power for all local businesses and a future source of available workforces as and when the economy revives  Demographic mix will provide a substantial opportunity to support membership of local sports club.

6.21 A summary of the main issues from responses from amenity groups and other bodies is as follows:

6.22 Hounslow Chamber of Commerce Support (both schemes)  Support the proposals which will provide 12% of LB Hounslow’s ten-year housing requirement in the London Plan with around 725 affordable homes, more than twice as many affordable homes as any other development in Hounslow in the last 15 years.  Welcome new public open space and improvements to transport and connectivity  New village square and mixed-use space (Tesco Site) will provide much-needed jobs and activity.  Converting this large car park site to deliver green spaces, homes and especially jobs is a fantastic opportunity for the regeneration of the Golden Mile.  Financial injection the developments should contribute substantially to the community, particularly important given the current economic downturn.  Construction period will bring a multitude jobs and spending to the area whilst supporting a variety of apprenticeships, work placements and training.

6.23 Brentford Voice Objection  Appreciate that the bar is set very high for sustaining refusal on the grounds of prematurity. However, the National Planning Policy Framework supports this approach in the context of the current stage of the Great West Corridor Local Plan Review. Paragraph 49 of the NPPF states that:

"49. However in the context of the Framework – and in particular the presumption in favour of sustainable development – arguments that an application is premature are unlikely to justify a refusal of planning permission other than in the limited circumstances where both: a) the development proposed is so substantial, or its cumulative effect would be so significant, that to grant permission would undermine the plan-making process by predetermining decisions about the scale, location or phasing of new development that are central to an emerging plan; and b) the emerging plan is at an advanced stage but is not yet formally part of the development plan for the area."

 We believe that approval of these planning applications at this stage would "undermine the plan-making process" and that "the emerging plan is at an advanced stage".  The levels of housing development currently proposed greatly exceed those postulated for these sites in the Draft GWC Local Plan Review. The proposed total of 2,150 homes on the sites would constitute almost 30% of the indicative total of 7,500 homes for the entire Great West Corridor over the period 2019-2041, as set out in The London Plan (March 2021).  The primary objectives of the forthcoming Public Examination are to ensure that the submitted GWC Local Plan Review meets the tests of soundness defined in the NPPF, and that it is legally compliant.  The granting, at this stage, of planning permission for these proposals on the Tesco and Homebase sites would gravely constrain the Public Examination's consideration of the soundness of the Plan, in particular the need to ensure that the Plan is "positively prepared".

6.24 The Isleworth Society Objection Overdevelopment  Too dense, too high and out of character with the surrounding areas.  Buildings soar over existing residential properties, mainly two-storey houses, and in some instances causing loss of privacy, daylight and sunlight.  Too many flats with a lack of private amenity space.  Need more family homes with gardens, social housing and affordable housing which is actually ‘affordable’.

Heritage  Buildings substantially deflect from the important heritage aspects, namely the remaining art deco commercial buildings on the famous Golden Mile,  Detrimental by cause of overshadowing to the unique structure of the Grade ll Gillette building.

Traffic  Traffic, where Syon Lane crosses the A4, is extremely dangerous for drivers.  More cars from the proposed site will cause a critical situation to become untenable.

Public Transport  Great West Road A4 has poor public transport especially the bus routes which are limited and infrequent.  Infrastructure such as doctors’ surgeries and primary school provision not considered.

6.25 Osterley and Wyke Green Residents’ Objection Association Community Engagement  Inadequate consultation process  Major concerns about excessive height, transport and traffic largely ignored.

Context and Character of Surrounding Area  Bulk and height up to 17-storeys would be wildly out of character with the surrounding area and would dwarf and dominate its suburban and historic surroundings of mainly 2-storey houses.  Negative impact on the context and character of the area.

Building Heights, Massing and Design  The proposals would have a detrimental effect on surroundings, and would overpower and intimidate with their mass, bulk and height, especially the 2-storey homes to the west on the Northumberland Estate and to the south on the Trees Estate.  Inadequate set-back from the Great West Road and Syon Lane given the volumes of pedestrian and vehicular traffic.

Housing Density  The development is too dense at 15 times higher than the rest of Osterley.  Offers a poor quality of life for new residents and exceeds approved Local Plan Site Allocation 11.  This makes for an unacceptable step change in comparison with the surrounding built environment.

Housing Type, Quality and Size of Accommodation  The layout of half of the flats is inadequate with single aspect windows, some north- facing, some floors with inadequate circulation space and ventilation.  Lack of privacy and overlooking given other buildings’ proximity.  Few (14%) 3-4 bed homes.

Daylight, Sunlight & Overshadowing  The scale and density of development would have an adverse effect on neighbouring homes through overshadowing and loss of privacy.  Potential for solar glare from the proposed highly glazed buildings for road and train drivers but no solution.

Housing Needs and Affordability  Hounslow Council's Housing Strategy document (2019-2024) states that there is a desperate and growing need for “larger family homes” (3-4 bedroom homes) to prevent forecast overcrowding in a glut of smaller-sized properties.  Fails by a large margin to meet objectively assessed local housing needs, as only 14% of dwellings would have 3-4 bedrooms.  The Council’s own objectively measured assessment shows that the combined need for larger family homes in the Market and Affordable sectors combined is 57%.  The Local Plan states that new developments should have a minimum of 25% of such larger homes.  For a development on this scale the mix should reflect known housing needs.  The proposed smaller sized flats are not only unsuitable for families, but also very unlikely to be affordable on the private sale market, by the average family in Hounslow.

Transport, Traffic & Parking  Only proposed improvement to public transport would be one additional bus route from Osterley to Ealing Broadway (E1).  There is no funding for much needed improvements to rail services (Hounslow Loop, Piccadilly line upgrade, Southall Rail Link, West London Orbital).  Existing PTAL 2 (poor), which is wholly inadequate for developments on this very significant scale.  The national financial crisis eliminates hopes for future funding.  The developer and TfL don’t agree on whether traffic will increase or decrease at Gillette Corner in the future; the developer opts for a reduction in traffic with no evidence.  Apart from the proposal for an additional right turn lane from the A4 eastbound into Syon Lane southbound, which is designed to enhance access to the Homebase site development, the two developments provide nothing else to address their combined impacts on the already congested Gillette Corner.  Parking provision at 0.21 spaces per dwelling is much lower than the recommended 1 space per dwelling in PTAL 2, which is unacceptable with no significant improvements to public transport in the foreseeable future.

Environmental Aspects, Sustainability, Climate Emergency & Ecology  Does not comply with the Climate Emergency declared by the GLA and L B Hounslow  Renewable Energy sources are not exploited, and a substantial proportion of heating and hot water would come from fossil fuels.  Only a very modest 36% of the energy consumed will be Zero Carbon, with the remainder provided by fossil fuel, using gas-fired boilers. This completely undermines LB Hounslow’s pledge to be Carbon Neutral by 2030.  The proposed design fails to achieve true Zero Carbon, as the resultant Residual Carbon emissions is substantial (283 Tonnes CO2 per year) and is mitigated by paying into a Carbon Offset Fund.  Tall buildings are not environmentally friendly, due to their intensive use of concrete and steel, which constitute a significant part of CO2 emissions.  No allowance is made for future proofing to further reduce Carbon emissions as required by the London Plan.  Thermal design of buildings and type of heating and ventilation systems used do not reflect the step-change needed for high standard of sustainability.  No justification for demolishing the current Homebase building, as part of addressing the Circular Economy, which is an integral part of sustainability, particularly in the current economic climate.  Significant glare from the large and curved façade of Block A (building at corner of A4/Syon Lane junction above the new Tesco store) to drivers using the A4 and Syon Lane, train drivers, residents on Syon Lane/Northumberland Gardens, as well as pedestrians and cyclists. No measures proposed to eliminate or reduce glare.  Wind Tunnel tests highlighted areas where adverse wind conditions would render them unsuitable for their intended use, mitigation measures proposed are insufficient  Roof-terrace amenity areas are shaded by adjacent residential blocks, which will further restrict the times of using them as intended.

Infrastructure  The location does not fulfil the requirements of a 15-minute neighbourhood as many of the amenities are further than 15 minutes’ walk.  Local infrastructure is inadequate, before the addition of thousands more residents, causing a negative impact on social infrastructure.

Local Heritage  The grossly oversized retail and residential building rising to seventeen storeys which, by virtue of its height, bulk and design, would:

(i) Have a seriously damaging impact on the immediate settings of listed former Coty Factory, Gillette Building , the separately listed, 19th century cast-iron lamp-standards and lanterns, the listed telephone kiosk outside the Gillette Building and the listed National Provincial Bank. (ii) Have significant and potentially damaging impacts on views from locations within the nearby Isleworth Riverside Conservation Area and Grand Union and Boston Manor Conservation Ares, thereby harming their special interest and significance as designated heritage assets. (iii) Harm both designated and non-designated heritage assets and the long- established, prevailing two-storey scale of the nearby residential areas to south-east, south-west, west and north-west of the application-site, including the area directly to the south- west of the application-site comprising the coherent estate of two-storey, inter-War suburban houses located on the roads extending north-westwards and south- eastwards of Northumberland Avenue, designated as an Area of Special Character. (iv) Have seriously damaging impact on views from the grade I registered Syon Park, as identified by Historic England, thereby harming its special interest and significance as a designated heritage asset.

 This would be contrary to policies of the London Plan, Local Plan and the NPPF.

Education  There is inadequate provision of primary school places in the area.

Landscaping & Amenity Space  The amenity space proposed is less than the area required in the Local Plan, and much of it would be at podium and roof level with significantly restricted use due to adverse microclimate conditions.  Communal podium gardens are 20% below standard for the new population and reliance is placed on ‘public accessible streetscape’; no outdoor children’s play space within 400m apart from podium.  Lack of privacy due to proximity of other blocks of flats.

Fire Strategy  All residential blocks feature only a single staircase, contrary to the recommendations from RIBA (Royal Institute of British Architects), following the Grenfell Tower fire tragedy, for two staircases.  There are shortfalls in compliance with Fire Engineering Codes and Regulations.

Additional response

Energy & Sustainability  The target for Zero Carbon and other energy saving measures have been improved to but they still fall significantly short of achieving Zero Carbon.  Shortfall in achieving Zero Carbon emissions is mitigated by paying into Hounslow’s Carbon Offset Fund which is meant to be a very last resort, if all other carbon saving solutions are exhausted. There is no evidence that this has been done.  The developer’s shortfalls of 49% and 41% occurring in 2021, are at a significant variance with London Borough of Hounslow’s pledge to be Carbon Neutral by 2030.  Solar roof-mounted panels are now proposed. It is assumed that the solar panels will conflict with the beneficial use of the proposed rooftop landscaped areas and their local environment the amount of green space provided needs to be recalculated.  No information about exploiting the recycling of rainwater and greywater to deliver energy savings and reduce water demand.  No information provided on future proofing and impact of climate change, based on published data.  No information on the impact of COVID-19 on environmental and building design, including well-being issues, etc. Single aspect flats do not allow natural air flow.

Further response RE Energy Statement  No improvement to emissions reduction.  The changes to the Environmental and Sustainability Statements are very disappointing and of a very minor nature. They fail to mitigate against serious harm to the environment. The proposed developments do not address the fundamental issues and dire needs to achieve Zero Carbon, both in terms of quantum and timing to achieve substantial carbon reductions.  No information as to how the Tesco store will achieve BREEAM excellent  Tesco store should be retained and development built around it.  The revised energy and sustainability statements have not responded to previous comments and questions.

Transport and Linked Vision  The only significant changes proposed are some minor tweaks to the layout of the north-south pedestrian and cycle crossing of the eastern side of Gillette Corner, which is wholly inadequate.  A number of options are proposed, some of which would retain the underpass. Signalled pedestrian/cycle crossings are needed across all 4 arms of the junction, not just across the 2 arms of the A4.  The developer is still insisting that traffic volumes will decrease at Gillette Corner. The reasons given for reduced traffic lack logic.  Gillette Corner needs to be reconfigured to make it safer for all users of the junction (vehicular traffic, pedestrians and cyclists). The right hand turns from Syon Lane on to the A4 would remain dangerous (not controlled by filter light).  Altogether these measures are needed to ensure compliance with the Mayor’s Healthy Streets and Vision Zero policies.  Where are the improvements to infrastructure? Only one in four properties would have a parking space meaning that most new residents would be relying on public transport, which is poor (PTAL 2) and already overcrowded.  The lack of good transport connections and infrastructure should mean that such a densely populated development should not be permitted on this site.  This is in addition to the fact that there is no close town centre as required for tall buildings.  Agree with Hounslow Design Review Comments

6.26 Kew Society Objection  Concerned about the impact of the proposed development from vistas within RBG Kew which will be intrusive and inappropriate building heights  Support the objections submitted from Brentford Community Council/Brentford Voice, the Osterley & Wyke Green Residents' Association and The Isleworth Society. In particular, the inappropriately tall buildings will harm the settings of nearby heritage  assets and overwhelm the character of the surrounding residential area.  Support Historic England's concerns about harm to heritage and request for additional views.  Applications represent massive and intrusive overdevelopments and should be rejected.  There is insufficient information provided to arrive at a true assessment of the adverse visual impact from RBG Kew.  Harm to Syon Vista, Isleworth gate (Grade II) where it is crucial to keep this westward panorama unspoilt , particularly given that Syon Park forms an essential relationship with the Kew World Heritage Site, falling within its buffer zone and together forming a pair of substantially intact Brownian landscapes. The highest blocks looming clearly on the horizon will have a materially adverse impact on the views westward from the Gardens and would contravene planning regulations.

6.27 Royal Botanic Gardens, Kew Objection  The proposal is contrary to policies in Hounslow’s Local Plan, including the Great West Corridor Masterplan.  Recent decisions relating to planning applications in the vicinity of Kew Gardens, such as the Chiswick Curve and Citroen site have ascribed a degree of harm to the Kew WHS as “less than substantial”. In our view the current application brings a similar or greater degree of harm as these other recent developments, due to the unspoilt character of the area affected.  The International Council on Monuments and Sites (ICOMOS) sent letters of objection relating to the Chiswick Curve, Citroen and Albany Riverside developments. Given the very high level of significance of the Kew Gardens WHS and the impact this development would have on attributes of OUV, we recommend that the view of ICOMOS be sought on the application via the UK state party.  The Syon Vista and Riverside Lawns, the Ha-ha (within Kew) and Syon Park and the Thames (in the setting of Kew) have a “very high” level of significance (A). The grounds of the Queen’s Cottage and the Towpath have a “high” level of significance (B). Isleworth Gate and the Gillette Tower have a “medium” level of significance (C).  Syon Park is assessed as being subject to a “major” scale change, resulting in a “very large” magnitude of impact. The Syon Vista and Riverside Lawn, the Ha-ha, the Towpath and the River Thames are assessed as being subject to a “moderate” scale of change, resulting in a “large” magnitude of impact.  The principal harms affect Attribute 1 of the Outstanding Universal Value of the WHS: A rich and diverse historic cultural landscape providing a palimpsest of landscape design.  More specifically these harms are as follows: - Visual intrusion into the Victorian garden layout, in particular a new cluster of buildings seen from the outlook from Syon Vista and Lawn. - Visual intrusion into the surviving Capability Brown landscape including Brown’s Ha- ha and the visual connection to the Thames and to Syon Park, which are “of a piece” with Kew. - Visual intrusion into one of the least altered reaches of the Arcadian Thames Landscape, which is in itself a heritage asset of high significance. - Harm to the setting of individual heritage assets as seen from Kew, in particular Syon House and the Great Conservatory. - The loss of the sense that this part of Kew Gardens as a “world apart” due to the visual intrusion of a cluster of buildings overtopping the current tree screen. - Night time light outspill from the cluster of buildings into what is currently a dark zone.  Cumulative harm - The proposed development - could set a precedent for further invasive developments at Syon Lane. In particular, the concurrent outline application for the Tesco site, although lower and further away, will broaden the cluster formed by the Homebase development to the right of Syon House.

6.28 Brentford Community Council/Brentford Objection Voice - Joint  The BCC and BV fully support the views adopted by OWGRA. This application is a major over-development and departure from the approved development plans  The effect of the application scheme on Brentford. - Increased pressure to meet greatly expanded housing quotas has led to over dense, over-powering schemes which could become the slums of the future. - 2019 GWC Review proposals were based on a Capacity Study and Masterplan which demonstrated the height and density limits which could be achieved without causing “harm” to the character of Brentford as a whole and to the listed buildings, conservation areas and other assets as well as the World Heritage Site - Current proposals for the Tesco and Homebase sites have paid no regard to the Capacity Study and Masterplan. The combined minimum quantum for these two sites was to be a total of 690 homes while the current proposals are for 2,150 homes, more than a threefold increase. - Despite all these indications that care was required the present application has an over-bearing character which dominates the character of Brentford like an alien intrusion. - In the light of objections raised by residents to the height, bulk, mass and dominance of the application scheme it will be additionally necessary to have regard to the precedent an approval on this site might have on any extension scheme or similar construction within the western parts of the Great West Corridor.  The effect of the application scheme on Brentford Town Centre - Relocating Tesco closer to the town centre may increase its threat to the viability of our town centre, particularly as a significant on-site car parking is to be provided. - As the connectivity is so poor our Town Centre may not benefit from the custom of residents on this site. - Request an up-to date assessment of the potential viability of town centre in competition with additional retail in the GWC and a new supermarket on the Homebase  Harm to Heritage Assets  The Supermarket proposals - Consent should not be granted without full and acceptable design details showing: - Proposals for the paved area on the A4 and Syon Lane frontages. - How customers coming by public transport can safely cross the A4 with heavy shopping, and possibly with young children. - It may be possible to introduce a really generous safety island in the A4 with a long pedestrian all red phase so that families can safely cross at grade. - Alternatively, the existing narrow and poorly built pedestrian tunnel could be re-built with easy ramps leading to large all-weather bus stop shelters. - Desirable if shoppers who have past checkout could reach the basement level within the store by lift, ramp or travellator. - Residents coming from Syon Station will need to walk along Syon Gate Way, which is the HGV entrance to the supermarket. - Need to demonstrate “guided by the TfL’s Healthy Streets indicators,  The Residential element of the application - The scheme comprises a number of tall tower and slab blocks, set on a podium which is up to 18m high, will dominate the surroundings to some distance. - The principle of building housing above a supermarket makes good use of brownfield land, but the insertion of a massive car park above the supermarket creates a major problem with the bulk and massing of the development. - Car park on the upper floors of the podium creates a dead frontage on the two main roads at street level and for many floors above. This will produce a hostile environment at street level. - Amenity space is limited to the deck over the car park. - Young children who would have to cross dangerous road to reach other open spaces. - Efforts to cram on the maximum number of units have resulted in substandard aspects - The overlooking distances between habitable rooms are frequently below the planning standards. A large number of units are north facing single aspect - Most of the blocks are single staircase. The RIBA, post-Grenfell, has recommended that blocks over 11m in height (4 storeys) should be provided with two staircases. - The appearance of the elevations is deeply disappointing. Excessive reliance is placed on varying brick colours to breathe some life into the monotonous repetition of the storeys. Little evidence of any attempt to compose the buildings in any three dimensionally satisfactory manner.  The need to phase the proposals to integrate development with infrastructure improvements - No public transport enhancements that would be directly related to Brentford Town Centre. In fact the planning application offers remarkably little in respect of public transport improvements. - If the vitality of Brentford town centre is to benefit then there is a clear need to provide cycle routes south from the site, to London Road and Cycleway 9. - Opportunity Area 6 is one of eight related to the Queen Elizabeth Line West. (Crossrail). The Great West Corridor is the only one which is not centred on a Crossrail station, but would rely on links (to Southall and Old Oak Common). It is understood that there are currently no firm proposals to finance, build and operate these links. - The GWC Review proposals (Site Allocations) spell out the appropriate phasing of construction for each development site. - Major developments in the GWC area can be reviewed when an irrevocable commitment is for finance and resources for infrastructure improvements linked to the phasing proposals for the development sites.  Energy and Climate Change - The Energy Statement has not clearly demonstrated that this development could not achieve lower carbon emissions without gas boilers. Instead it states that “it is not feasible for a communal system of this size and type to generate 100% of heat from heat pumps”. This runs counter to many other planning applications which are coming to Hounslow Council that do manage to do without gas boilers and thus substantially reduce their carbon emissions on-site.

6.29 Thames Landscape Strategy Objection  Concerned that views from river will be affected and from some viewpoints the building will sit directly above Syon House and be visible above the tree line.  Request the applicant provide further verified views from the Thames Path so that the visual impact of both schemes can be more clearly seen.

6.30 Heston Residents’ Association Objection  The proposal is a gross overdevelopment of the site. The proposed residential developments are considered to be too high, with a massing effect, dominating the local street scene with a detrimental impact on the adjacent residential and commercial builds, including the Grade ll Gillette building.  Design / appearance is out of character with the local area  Too few family homes are planned and there is a shortfall in the number of houses.  Failure to indicate provision for improved / additional public transport.  Generation of additional road traffic at an already busy junction will be a problem.  Inadequate provision for parking (100 spaces) for proposed additional homes (473).  It has a negative impact on existing social infrastructure and other services (eg medical)  Education, despite 2 new local schools, it is questioned whether there will be sufficient primary school places.  Adverse impact on local environment, including noise and air pollution.  Concern about ability of local utility services to meet the increase in demand, particularly the demand for water supply and disposal of waste water / sewage.

6.31 West Thames College Support Support the investment and economic opportunities, notably:  Safeguarding and creating 650 permanent jobs  New and safer pedestrian and cycle routes to be delivered  Proposed improvements to the local road network  Employment and Skills Plan to help maximise local employment opportunities and improve local skills levels through school and further education engagement in the local area.

6.32 Hounslow Cycling Object  The proposed Tesco Osterley and Homebase Brentford development create unacceptable levels of car traffic unless access routes for pedestrians and cyclists are materially improved. The development could be an environmentally friendly way of building much needed new homes if adequate investment is made in active travel.  Pedestrian and cyclist access is currently poor and public transport not much better. The development will significantly increase the use of cars in the area, potentially contradicting the Hounslow Local Improvement Plan, the Mayor’s Transport Strategy and other Hounslow and London policies relating to air quality, climate change and road safety.  Residential car parking provision and cycle parking should comply with the quantitative limits in the London Plan. Cycle parking should be of good quality - accessible, well lit, dry and secure. This will help to address car dependency from the outset.  Developer should fund adequate investment in better pedestrian and cycle routes by London Borough of Hounslow (‘LBH’) and Transport for London (‘TfL’):-  Gillette Corner lies to the SE of the site. The surface level crossings are slow and frustrating to use, with cattle pens of limited capacity in the central reservation. The only satisfactory crossing for pedestrians and cyclists is the subway that runs from the N corner to the E corner. That is only 7'6" wide. The access ramps are also narrow and the southern end currently emerges four steps higher than the car park. We believe that TfL should budget for a wider tunnel, with attractive entrance treatments and reassuring CCTV and lighting.  Syon Lane crosses the Piccadilly Line about 600m NW of the site. All traffic must pass through this pinch point.This stretch of road is dangerous for cyclists as the carriageway is wide enough to encourage car drivers to overtake but too narrow for them to do so safely. The footway is on one side of the road only, and it is unattractive due to the speed and volume of passing traffic. LBH should estimate the cost of this route, including the Hounslow Loop and Piccadilly Line crossings, and budget accordingly.  Osterley tube station is around a mile from the site, to the W. Boston Manor tube station is less than a mile from the site as the crow flies, to the NE. Either tube station can thus be reached by cyclists using the existing bike lane along the N pavement of the A4. Suggest that TfL should budget for the upgrade of that bike lane from Osterley to Boston Manor road.

6.33 Responses from statutory bodies

6.34 Greater London Authority (Mayor) Stage I report Stage 1 Response: Advises that while the scheme is broadly acceptable in strategic planning terms, the application does not fully comply with the London Plan. The Mayor considers that the application does not comply with the London Plan, for the reasons set out in the response but that the potential remedies also set out in that paragraph of the report could address those deficiencies.

Principle of development: The comprehensive residential-led mixed use redevelopment of this out of town retail park site within an opportunity area is strongly supported.

Housing and affordable housing: 38% affordable housing by habitable room, comprised entirely of London Affordable Rent accommodation. This is supported and complies with the criteria for the Fast Track Route. An early stage review mechanism is required, together with provisions requiring grant funding to be explored. The proposed London Affordable Rent units should be secured. The off-site play space provision should be detailed and agreed.

Urban design and heritage: The density, design and layout, residential quality and proposed height and massing is supported, subject to further information being provided to clarify the design constraints and further refinement of the architectural approach proposed for Block B. The application would cause less than substantial harm to the setting and significance of the Grade I listed Registered Syon Park, and to a lesser extent the Grade I Syon House. Less than substantial harm would also be caused to the setting and significance of the Grade II listed Former Gillette Factory and Syon Clinic. The overall cumulative harm caused to designated heritage assets could be outweighed by the proposed public benefits, subject to these being secured and detailed at Stage 2.

Climate change: The energy, drainage and urban greening strategies are generally supported subject to further information being provided on the energy strategy.

Transport: Further work is required on the modelling of highway options to ensure that a preferred option can be identified and agreed. A bus contribution of £1,700,000 is required for both development sites to mitigate the impact on bus capacity. Further detail on the public realm, site access and walking and cycling improvements is required to ensure these are safe and meet the requirements of the Healthy Streets. The retail car parking does not comply with the Intend to Publish London Plan. Measures are required to support strategic mode share targets. Further design information is required regarding cycle parking to demonstrate compliance with the LCDC.

6.35 Transport for London Highways Impact The redevelopment of the Homebase site is predicted to generate 430 two-way vehicle trips in the AM peak hour and 706 during the PM peak hour. This is a net increase of 385 trips in the AM peak hour and 586 in the PM peak hour when compared to the previous Homebase use on site. In order to test the impacts of the vehicle trips generated by both the Homebase and the Tesco Osterley sites, detailed junction modelling using VISSIM microsimulation modelling software has been undertaken. A number of different design options were modelled to mitigate the impacts of development traffic and to provide pedestrian and cycle improvements in line with the Healthy Street approach. Design Option 2a, has initially been identified as the preferred mitigation option. Design Option 2a includes a new traffic signal control junction for the Homebase site and the addition of a second right turning lane on the A4 for traffic turning into Syon Lane (towards the new Homebase site access) from the west. This option also includes the relocation of the existing bus stop layby on the A4 Great West Road (Westbound) further east to extend the cycle lane. Option 2a also includes a new at grade toucan crossing on the A4, to the east of Syon Lane. It retains a double right turn from the A4 into Syon Lane North. Option 2a also retains the pedestrian underpass beneath the A4 However, prior to the implementation of Option 2a, the applicant will be required to undertake further detailed design and highway modelling work to establish if in addition, a direct pedestrian and cycle crossing can be delivered on Syon Lane, to be incorporated within the Gillette Corner junction. If feasible, this revised design Option will be delivered via a s278 agreement.

Healthy Streets and Vision Zero The Healthy Streets approach aims to create a high quality, attractive and inclusive environment in which people choose to walk cycle and use public transport. The dominance of vehicles should be reduced by using design to ensure slower speeds and safer driver behaviour, in line with the Mayor’s Vision Zero ambition. The proposed development will generate an increase in pedestrian and cycle trips to / from the site and the local area. Further information has been provided concerning the clean air route, via Syon Gateway and the new eastern street (Syon Gate Lane) and this is now acceptable. Further information concerning the proposed off-road cycle lane along the site frontage will need to be addressed as part of the detailed design. The implementation of design Option 2a will provide a new at grade crossing across the A4 improving connections for pedestrians and cyclists. The applicant has also agreed to improve and repair the underpass, including repairing/cleaning lights and mirrors and installing corduroy tactile paving at subway steps. TfL have also identified a number of improvements at Gillette Corner which the applicant will be required to consider as part of their detailed design. The ATZ assessments and accident analysis for Routes 6 highlight the requirement for upgrading the pedestrian and cycle route on the northern and Southern sides of the A4 to Boston Manor Road as an off-carriageway active travel route (upgrading safety at junctions). IT is recommended that on the southern side of the A4 a review is undertaken of all accesses and junctions between the site and the Grand Union Canal and improvements delivered prior to first occupation of the Homebase site. This should be secured in though the s106 agreement.

Car Parking Parking provision is closely linked to use, and car use generates a host of negative impacts which need to be managed and addressed, including congestion, noise, poor air quality, climate change, severance and road danger. Parking restraint and management is therefore essential in ensuring sustainable development and underpins mode shift. Whilst the residential car parking provision remains acceptable, there has been no attempt to reduce the retail car parking so that it is London Plan 2021 compliant, which would only permit up to 141 retail spaces at this location. TfL have maintained that unless the retail car parking provision was reduced to be London Plan 2021 compliant, the applicant would need to agree to a pricing mechanism in order to achieve strategic mode share targets (75% for walking, cycling and public transport) for outer London in accordance with the London Plan 2021. TfL have continued discussions with the borough and the applicant concerning car parking and a retail car park charging mechanism has been agreed. The principles of this are required to be secured in the s106 agreement.

An updated CPMP has been provided and information is now provided detailing how the residential visitor spaces will be managed along with which residential spaces could be converted to disabled persons parking should demand arise. The CPMP also now details the correct number of disabled person parking spaces for the retail element. 20% of all residential car parking spaces will include active charging facilities with passive provision for all remaining spaces. 10% of retail car parking spaces will include active charging facilities with passive provision for all remaining spaces. The CPMP states that provision will be made for the delivery of rapid car charge points within the customer car park. The actual number of rapid charging points should be specified and secured. It is acknowledged that the car parking levels have been designed so that they are able to be repurposed in the future as commercial floorspace. The CPMP does highlight that monitoring of retail car parking utilisation rates, can provide a basis for identifying any potential spare parking capacity that is consistently under-utilised. Further detail of how this will work is still required and should be secured by the s106 agreement. In terms of the residential car parking; spaces will be leased not sold and residents will be exempt from applying for car parking permits in any existing or future CPZ which should be secured through a legal mechanism.

Cycle Parking Cycle stores have been added close to each residential core which will be far more convenient for all residential users. The application has also highlighted routes to the cycle stores and clarified the type of long stay cycle parking. The number and type of cycle parking should be secured by condition along with the detailed design of the stores.

Trip generation and modal split TfL have no further comments on the trip generation assessment.

Buses A bus capacity contribution of £1,700,000 for both development sites has been agreed. The contribution will be for general service enhancements, rather than to specific routes and adapted to local conditions upon site occupation.

Bus Infrastructure To accommodate the proposed off-road cycle lane along the site’s northern frontage it is proposed to relocate the existing bus stop further east. TfL have agreed the principle of this relocation. The bus stop relocation should occur on commencement of the Homebase development and this should be secured in the s106.

London Underground An assessment of station capacity at Osterley Station has been undertaken. The assessment still requires further work before TfL can determine if a contribution is required. However, given the Tesco Osterley site generates the greatest demand for underground trips it, is recommended that an updated assessment of station capacity and line loading capacity at Osterley Station is with the first reserved matters application. The underground trips generated by the Homebase site will also need to be included in this assessment.

Taxi The revised TA states that a taxi drop off / pick up facility will be located within the car park at Level 1. Whilst convenient for retail pick-ups it is unlikely to be used for drop offs and there is no consideration for the residential taxi pick up or drop offs which area also likely to occur on street. TfL recommend that an on-street taxi rank is identified.

Delivery and Servicing There has been no change to the service vehicle trip generation which still predicts only 58 two-way trips which TfL maintain has been significantly underestimated. The revised DSP confirms that for small residential deliveries, suppliers will be allowed to access the ground floor of each residential core to access the post boxes by the site management staff via video intercom. Given the number of residential cores a more centralised system would be more efficient. Furthermore, the core located on Syon Gate Lane would not be convenient to access. TfL remain concerned that due to the nature of residential deliveries, that these are more likely to be undertaken as closely as possible to the residential cores and potentially illegally on-street. The applicant has suggested that TRO loading restrictions can also be considered as a means to prevent unauthorised loading from taking place on Syon Lane. TfL would support LBH should they want to secure this.

Travel Plan The Travel Plan states the proposed development has been designed to accord with the policies of the London Plan 2021. This in incorrect as it exceeds the maximum car parking provision. In terms of targets this will need to be far more ambitious if the proposed Tesco store is going to achieve the strategic mode share targets (75% for walking, cycling and public transport) required for outer London in accordance with London Plan policies T1 and T2. Travel Plans should be secured, enforced, monitored and reviewed as part of the s106.

Construction A Construction Logistics Plan (CLP) will be required by condition and discharged in consultation with TfL.

Summary Subject to securing the recommended conditions and obligations the application is now considered to be in general accordance with the transport policies of the London Plan 2021.

6.36 Highways England – No objection. This is on the basis that the proposals will generate minimal additional traffic on the SRN in Peak Hours. We therefore consider that the development will not materially affect the safety, reliability and / or operation of the Strategic Road Network.

6.37 London Fire Brigade – No objection. The London Fire Commissioner (the Commissioner) is the fire and rescue authority for London. The Commissioner is responsible for enforcing the Regulatory Reform (Fire Safety) Order 2005 (The Order) in London. The Commissioner has been consulted with regard to the above- mentioned premises and makes the following observations: The Commissioner is satisfied with the proposals in regard to B5 access.

6.38 Environment Agency – No objection. There are no environmental constraints that fall within our remit as a statutory consultee at this site and therefore we would have no comments to make on this planning application.

6.39 Design Out Crime Officer (Police) – No reason the no reason why this development cannot achieve Secured by Design New Homes 2019 accreditation. Condition recommended.

6.40 NATS Safeguarding (airport traffic approach) – The proposed development has been examined from a technical safeguarding aspect and does not conflict with our safeguarding criteria. Accordingly, NATS has no safeguarding objection to the proposal.

6.41 Heathrow Airport – No objection subject to conditions regarding restrictions on crane heights/constriction and bird hazard management plan being secured.

6.42 Historic England – We recognise that this is an important development site, but consider that the way in which the development has been brought forward results in harm to the setting of the highly designated registered park at Syon. The level of harm is considered to be moderate and ‘less than substantial’ in the language of the NPPF. To a lesser degree, the setting of the Grade I listed building Syon House would also be impacted, albeit indirectly, and therefore the level of harm is lower. Further harm would be incurred through the cumulative impact of the Tesco Osterley scheme which is also under consideration. We consider that this harm does not have clear and convincing justification, contrary paragraph 196 of the NPPF.

6.43 We agree that visibility does not necessarily equate to harm in principle as the applicant has stated, but we have sought to explain why in this particular instance it is considered to arise. In summary, the presence of urban development rising above the treeline would disrupt in the compositions envisaged by Brown and runs counter to the notion of cultivated parkland merging with a romanticised countryside beyond. This is an essential characteristic of the style, normally achieved through carefully designed tree planting to the create impression of a rural idyll (whether it exists in reality or not).

6.44 The proposals would result in this designed ‘illusion’ becoming much less appreciable in key vantage points over the western parkland. This is a significant impact and in some respects a transformative change to its setting, particularly in the summer months when nearly all other existing low rise buildings are almost completely screened by tree leaves.

6.45 The connected landscapes of Syon and Kew are of global historic and artistic interest, meriting the highest possible heritage designations. The views provided illustrate demonstrable harm to the significance of the Royal Botanic Gardens (RBG), Kew World Heritage Site, Syon House and Syon Registered Park and Garden (all Grade I). The proposals are contrary to the Development Plan, including the new London Plan, which sets out a robust framework for ensuring the conservation highly designated heritage assets. This harm attracts very high weight and has not been clearly and convincingly justified. Historic England objects to the application and strongly recommends that planning permission should be refused.

6.46 The proposals would result in clear harm to heritage assets of the highest significance, and would be contrary to the Development Plan (London Plan policies HC1, HC2 and D9 in particular, and the draft site allocation). We therefore strongly recommend that planning permission should be refused.

6.47 Historic England (Archaeology) – The proposal is unlikely to have a significant effect on heritage assets of archaeological interest. The site does not lie within an Archaeological Priority Area and is unlikely to cause harm because of the lack of recorded archaeological finds in the immediate vicinity and likely extensive disturbance from modern development. No further assessment or conditions are therefore necessary.

6.48 The Gardens Trust – Objects owing to impact on setting of heritage assets, in particular Osterley Park and Syon Park owing to the damaging effect on important views. By tall buildings resulting in permanent visual intrusion into what until now has been a largely unspoilt setting on the edge of London be permitted, it will set an unwelcome precedent for further commercial development to be allowed to cause damage in similar manner. The loss of significance to these unique and irreplaceable heritage assets is in no way compensated by public benefit. Endorse concerns about impacts on views from the riverside by the Royal Botanic Garden, Kew and request further views analysis in order to obtain a full and objective understanding of the effects on these landscapes.

6.49 Hounslow CCG – The developments will give rise to a need for additional primary healthcare provision to mitigate impacts arising from the developments with funding sought through s106 to contribute to additional health care provision. This would be secured in the S106.

6.50 Thames Water – No objection.

6.51 London Borough of Ealing – No objection.

7.0 POLICY

Determining applications for full or outline planning permission 7.1 The determination must be made in accordance with the development plan unless material considerations indicate otherwise. Local finance considerations must also be assessed.

The National Planning Policy Framework 7.2 The National Planning Policy Framework (NPPF) was revised on 19 February 2019. The National Planning Practice Guidance (NPPG) is an online guidance resource that supports the NPPF. The NPPF and NPPG are material considerations.

The Development Plan 7.3 The Development Plan for the Borough comprises the Council's Local Plan (adopted by the Council on 15 September 2015), the West London Waste Plan and London Plan (2 March 2021).

7.4 The Council is undertaking Local Plan Reviews; the West of Borough Local Plan review, the Great West Corridor Local Plan review and the Site Allocations Local Plan review. These plans have been submitted to the Secretary of State for examination, however their policies are afforded little weight at this stage.

7.5 The adopted Local Plan documents and emerging Local Plan Review documents can be viewed on the Planning Policy pages of the Hounslow website.

London Plan

GG1 Building strong and inclusive communities GG2 Making the best use of land GG3 Creating a healthy city GG4 Delivering the homes Londoner’s need GG5 Growing a good economy GG6 Increasing efficiency and resilience SD2 Opportunity Areas SD6 Town centres and High Streets SD7 Town centres: development principles and Development Plan Documents D1 London’s form, characteristic and capacity for growth D2 Infrastructure requirements for sustainable densities D3 Optimising design capacity through the design led approach D4 Delivering good design D5 Inclusive design D6 Housing quality and standards D7 Accessible housing D8 Public realm D9 Tall buildings D11 Safety, security and resilience to emergency D12 Fire safety D13 Agent of change D14 Noise H1 Increasing housing supply H4 Delivering affordable housing H5 Threshold approach to applications H6 Affordable housing tenure H7 Monitoring of affordable housing H10 Housing size mix S4 Play and informal recreation E11 Skills and opportunities for all HC1 Heritage conservation and growth G1 Green infrastructure G4 Open space G5 Urban greening G6 Biodiversity and access to nature G7 Trees and woodland SI1 Improving air quality SI2 Minimising greenhouse gas emissions SI3 Energy infrastructure SI4 Managing heat risk SI5 Water infrastructure SI12 Flood risk management SI13 Sustainable drainage T1 Strategic approach to transport T2 Healthy Streets T3 Transport capacity, connectivity and safeguarding T4 Assessing and mitigating transport impacts T5 Cycling T6 Car parking T6.1 Residential parking T6.3 Retail parking T6.5 Non-residential disabled persons parking T7 Deliveries, servicing and construction T9 Funding transport infrastructure through planning DF1 Delivery of the Plan and planning obligations

London Plan Supplementary Planning Guidance (“SPG”) Affordable Housing and Viability SPG 2017 Housing SPG 2016 Accessible London SPG 2014 Character and Context SPG 2014 Control of Dust and Emissions SPG 2014 Shaping Neighbourhoods Play and Informal Recreation SPG 2012 World Heritage Sites 2012

Hounslow Local Plan Policies

Spatial Strategy Brentford TC1 Town and neighbourhood centre network TC2 Ensuring the future vitality of town centres TC3 Managing the growth of retail and other main town centres uses TC4 Managing uses in town centres ED4 Enhancing local skills SC1 Housing growth SC2 Maximising the provision of affordable housing SC3 Meeting the need for a mix of housing type and size SC4 Scale and density of new housing development SC5 Ensuring suitable internal and external space CC1 Context and character CC2 Urban design and architecture CC3 Tall buildings CC4 Heritage GB7 Biodiversity EQ1 Energy and carbon reduction EQ2 Sustainable design and construction EQ3 Flood risk and surface water management EQ4 Air quality EQ5 Noise EQ6 Lighting EQ8 Contamination EC1 Strategic transport connections EC2 Developing a sustainable local transport network IMP1 Sustainable development IMP3 Implementing and monitoring the Local Plan

Emerging Planning Framework

7.6 The Council has now submitted the ‘Great West Corridor Local Plan Review’ (2020) and the ‘Site Allocations Local Plan Review’ (2020) to the Secretary of State, with these scheduled to be examined in 2021. Once adopted the GWC Local Plan and Site Allocations will form part of the Development Plan and they will guide development in the Opportunity Area.

8.0 ASSSESSMENT

8.1 The application is a major development, which is the subject of an EIA, proposes the redevelopment of the Site with a large Tesco supermarket and car park, new housing comprising 473 homes, 35% being affordable, landscapeing, as well as new public realm.

8.2 The application has been considered concurrently with a separate planning application proposing redevelopment of the existing Tesco Osterley site, the proposal relocating the existing store to the current Homebase site. Taken together the proposals involve a wider strategic opportunity for development in the Great West Corridor Opportunity Area

8.3 The key planning issues are considered to be as follows:

A. The principle and Impacts of the Proposed Uses

 Sustainable Development and the Regeneration Context  Principle of the Proposed Uses  Other Socio-economic Impacts of the Uses  Alternatives  Conclusion

B. Affordable Housing and Tenure Mix

 Affordable Offer and Proposed Tenure Mix  Conclusion

C. Sustainability

 Sustainable Design  Sustainability Assessment  Conclusion

D. Urban Design and Impacts on the Townscape

 Design Policy Context  Urban Design and Townscape Impact Assessment  Conclusion

E. Heritage

 Heritage Policy Context  Effects on Heritage Significance  Archaeology  Conclusion

F. Housing Quality

 Quality Standards  Air and Noise Pollution  Amenity Space  Housing Mix  Density  Conclusion

G. Transport

 Introduction  Policy Background  Trip Generation  Traffic Impact  Review of the Traffic Modelling  Traffic Conclusions  Public Transport  Car Parking  On-street Parking  Cycle Parking  Deliveries and Servicing  Active Travel, Road Safety and Public Realm  Construction  Conclusion

H. Impacts on Neighbours

 Privacy and Outlook  Daylight and Sunlight  Noise, Vibration and Other Disturbance  Air Quality  Conclusion

I. Other Environmental Matters

 Flooding and Drainage  Contaminated Land  Wind  Urban Greening and Biodiversity  Conclusion

J. Planning Balance

 Public Benefits  Conclusion on Balance  Compliance with the Development Plan

A. Regeneration and the principle of the proposed uses

Sustainable Development and Regeneration Context

National Policy and Guidance

8.4 The National Planning Policy Framework (“NPPF”) emphasises that the three overarching objectives of sustainable development, relating to economic, social and environmental conditions, should be pursued together. Planning policies and decisions should play an active role in guiding development towards sustainable solutions, but in doing so should take local circumstances into account, to reflect the character, needs and opportunities of each area.

8.5 The NPPF sets out policies in relation to key planning principles including building a strong economy, promoting sustainable transport, delivering a sufficient supply of homes, making the most effective use of land, achieving well-design places, promoting healthy communities, conserving the historic environment, and meeting the challenge of climate change. The associated National Planning Practice Guidance (“NPPG”) adds further context to the policies of the NPPF.

London Plan

8.6 The new London Plan (“LP”) sets out strategic policies for planning across London. Key principles guiding policies that apply to new development are set out in the plan’s ‘Good Growth’ objectives. These objectives require high quality design that optimises the use of land to support housing and workspaces, and promote higher density development in locations that are well-connected to jobs, services, infrastructure and amenities without relying on car travel. Addressing climate change, safety and infrastructure needs are also important.

8.7 Policies require new development to make the best use of land by using brownfield sites, particularly by more intense development in Opportunity Areas. The ambitious delivery of more good quality homes, including affordable housing, new jobs, and an environment that encourages a more active and healthy lifestyle activity with better access to green spaces and safer walking and cycling are all strongly promoted.

8.8 The Plan states2 that “…if London is to meet the challenges of the future, all parts of London will need to embrace and manage change”, and that “… the areas that will see the most significant change are identified as Opportunity Areas”. The Plan defines Opportunity Areas as “…significant locations with development capacity to accommodate new housing, commercial development and infrastructure (of all types), linked to existing or potential improvements in public transport connectivity and capacity”.

8.9 LP policy SD2 sets out how the regeneration and growth potential of Opportunity Areas will be met through the planning framework. The Plan includes the ‘Great West Corridor Opportunity Area’, which encompasses the mostly commercial and industrial development extending along the A4 corridor from Gillette Corner to Chiswick Roundabout, and includes the Site and the existing Tesco Site. This Opportunity Area is identified as having an indicative capacity for at least 7,500 homes and 14,000 jobs over the period of the new Plan.

8.10 In considering the potential for growth in the corridor, the Plan identifies the importance of ensuring capacity accounts for existing and planned infrastructure. The plan also recognises that the Art Deco architecture of the Great West Road has created a distinctive local character whilst the surrounding area has many natural and historic assets, and that the opportunities to integrate and draw inspiration from the area’s heritage should be fully explored.

Hounslow Local Plan

2 2.0.3 and 2.0.4 pg 30 London Plan 8.11 Policies of the current Hounslow Local Plan (“HLP”) are consistent with these national and London-wide strategic and spatial planning objectives for regeneration and growth. HLP policy IMP1 says the Council will take a plan-led approach to all growth and development within the Borough that is considered to be in accordance with the principles of sustainable development as set out in the NPPF, with a balance of social, environmental and economic objectives.

8.12 In respect of growth and development, the HLP says that:

“Brentford will benefit from high levels of growth over the next 15 years, which will deliver much needed housing and jobs, as well as improved infrastructure, retail and leisure”3.

8.13 Aligning with the Opportunity Area designation of the new London Plan, the HLP had already identified the Site as a part of a wider area suitable for regeneration and more intense use. HLP policy SV1 of relates to the ‘Great West Corridor’ and sets out that the Council will prepare a partial Local Plan review to explore and identify the potential capacity for additional employment-led mixed use development along the Great West Corridor, and it will progress its designation as an Opportunity Area through the review of the London Plan. This policy says that the Local Plan Review will, amongst other things, identify sites with suitability for tall buildings.

Great West Corridor Local Plan

8.14 The Council has now submitted the ‘Great West Corridor Local Plan Review’ (2020) (“GWC Local Plan”) and the ‘Site Allocations Local Plan Review’ (2020) (“Site Allocations”) to the Secretary of State, with these scheduled to be examined in 2021. Once adopted the GWC Local Plan and Site Allocations will form part of the Development Plan and they will guide development in the Opportunity Area. These plans are positive and aspirational, and set out a range of strategic and places policies, and allocate sites for development, aiming to enable the successful delivery of thriving places that are well connected and which support job creation, housing delivery, and new infrastructure with this conforming to the London Plan’s ‘Good Growth’ focus. The extent of the Opportunity Area is shown below.

Figure 6: Great West Corridor Opportunity Area

3 2.50 (pg 40) 8.15 The GWC Local Plan recognises the area along the Great West Road corridor is underperforming in a range of areas with its environment traffic dominated and fragmented, with low quality public realm and poor access to transport in some areas. Overall it lacks a clear identity and it has limited amenities and poor links to surrounding residential areas and town centres, with these deficiencies restricting its ability to sustain and compete with changing business and industrial needs. It also has large sites that are underutilised and which provide development opportunities.

8.16 The overall vision of the GWC Local Plan is to transform the area designated as an Opportunity Area through regeneration and improving the environment into a place that is better for living and working, as well as for community and recreational uses. This will be achieved by making the best use of brownfield land, introducing a more vibrant mix of uses including housing, enhancing access to public transport, creating new green spaces, and making it more attractive for people to walk and cycle. New development should also acknowledge the corridor’s role as a gateway into central London and look to promote this sense of arrival and also draw on its rich history of bold architecture, whilst also accounting for the important heritage assets found within the corridor and the wider region.

8.17 The GWC Plan and the Site Allocations both identify the Site and the Tesco Site as being suitable for significant residential led mixed-use development and support their comprehensive redevelopment with high quality mixed-use schemes that can animate and improve the western entrance to the Opportunity Area. The Site Allocations allocates the Site for a mixed of uses with large format retail, housing, employment uses and parking plus enhanced public realm. The minimum quantum of development is 10,940 sqm of retail and business floor space and 370 homes.

8.18 The GWC Local Plan is supported by the ‘Great West Corridor Masterplan and Capacity Study’ 2020 (“Masterplan”). The Masterplan has undertaken an analysis of potential capacity for sites and looks to provide spatial and design guidance, taking into account the strengths and weaknesses of the area. It has an illustrative masterplan for development sites in the Opportunity Area which shows how the development could be provided on a site-by-site basis to deliver objectives for growth. The Masterplan comments that the relocation of the existing Tesco superstore to the Site, with housing above, in combination with redevelopment of the Tesco Site, “…will deliver a step change to the area and act as an important catalyst for other development to follow”4. The image below from the Masterplan shows illustrative proposals for the Site and other sites to be allocated for development including the Tesco site showing the expected transformation of the area.

4 Pg 97 of GWC Masterplan 2020

Figure 7: GWC Masterplan – Illustrative Development Proposal (pg 183)

8.19 At this stage, although both the GWC Local Plan and the Site Allocations have been submitted for examination, they are yet to be independently examined and so they have limited weight. However, both documents provide a strong indication of the general direction of travel for future development for the Opportunity Area with more intense development that makes better use of brownfield land, with much more housing and a better amenity offer, and enhancing economic activity and active travel all being major priorities.

8.20 Overall, the national, London and local planning policy framework strongly supports the principle of the comprehensive regeneration of the Site as this would make a substantial contribution towards achieving strategic planning aims to optimise use of previously developed land, deliver housing and enhance the environment in particular. Given this broad context of support for significant regeneration and noting the new London Plan confirming the corridor’s status as an Opportunity Area where there should be substantial housing and employment growth, some weight, albeit limited as discussed above, may be afforded to the emerging plans.

8.21 As such, the adopted HLP still provides the basis for local policies of the Development Plan that will apply to this assessment, provided they are consistent with the later NPPF and new London Plan. The proposal is also not considered to undermine the future plan making process in respect of the GWC Plan and Site Allocations as the regeneration of the Site and significant housing growth in the area is consistent and strongly supported by the policies of the adopted HLP and its Opportunity Area status and related objectives from the new LP. Additionally, the full assessment of the proposal will consider whether any adverse impacts of the proposal would significantly and demonstrably outweigh the benefits.

Principle of the Proposed Uses

8.22 The Site presently contains a large DIY retail store with associated car parking. It is not allocated for any use in the HLP though it is within the area recognised within its Spatial Strategy as a potential Opportunity Area, and as noted above, this status has now been confirmed by the new London Plan. The proposed mixed-use development would replace the existing DIY retail store with a new retail use (Tesco superstore) and housing, plus car parking and smaller retail and community spaces.

Housing Delivery

8.23 Chapter 5 of the NPPF concerns the delivery of sufficient homes, with paragraph 59 noting the government’s support for schemes that significantly boost the supply of housing. Paragraph 117 of the NPPF says planning decisions should promote the effective use of land to meet the need for homes and other uses, while safeguarding and improving the environment and ensuring safe and healthy living conditions, in a way that makes as much use as possible of previously-developed land.

8.24 Paragraph 118 of the NPPF says planning decisions should, give substantial weight to the value of using suitable brownfield land for homes and other needs, and support the development of under-utilised land, especially if this would help to meet identified needs for housing where land supply is constrained and available sites could be used more effectively (for example space above shops, and building on or above service yards, car parks, lock-ups and railway infrastructure).

8.25 New London Plan policy H1 sets 10 year housing targets for local authorities across London. For Hounslow the target equates to 1,782 homes to be delivered each year, which is more than double the target of the adopted HLP which is 822 homes per year (a 116% increase). This policy also says that to ensure the 10 year targets are achieved local authorities should allocate sites for development, enable the delivery of housing capacity identified in Opportunity Areas, and optimise the housing delivery on suitable brownfield sites and encourages, in particular, the mixed-use redevelopment of car parks, low density retail sites, and supermarkets.

8.26 HLP policy SC1 seeks to maximise the supply of housing in the Borough to meet housing need in a manner that is consistent with sustainable development principles.

8.27 The Borough has a good record of housing delivery, with the former annual target of 822 homes per year met in each of the last three years and the Borough passing the government’s Housing Delivery Test5. The 2020 test showed Hounslow delivered 911, 1,264 and 1,525 homes over the last three year period; however these are all below the new target of 1,782 homes per year. The GWC Local Plan and Site Allocations have been prepared in anticipation of the new London Plan target, and both the Site and the Tesco Site form part of the Council’s housing supply pipeline.

8.28 The proposal for 473 new homes would make a very significant contribution towards the Borough’s housing target and the objectives of the Opportunity Area, and will help meet the identified housing need, with this equating to over 26% of the Borough’s annual housing target. The redevelopment and intensification of the use

5 Housing Delivery Test January 2021 – LB Hounslow achieved 154% of requirement. of the Site, which includes a large area of car parking and a single storey retail unit, with a mixed-use housing led proposal of mix-tenure, would also be consistent with the following strategic objectives to make the most effective use of underutilised brownfield sites within the Opportunity Area as set out in the GWC Plan6:

 Strategic Objective 3 - To provide new homes in sustainable locations where residents can walk and cycle to local jobs, amenities and green space.

 Strategic Objective 4 - To provide high-quality housing at sizes, tenures and types which are affordable to local residents and helping London meet its needs.

 Strategic Objective 5 - To ensure new homes support good growth by integrating with business, shops, and community uses in order to promote mixed and inclusive communities and deliver lively and liveable places.

8.29 More detailed consideration of the quality of housing and effect on the environment are discussed below, but in terms of land use and housing delivery the proposal is a very significant opportunity to provide much needed housing in an appropriate location, and so the principle of housing at the Site is strongly supported. The related development of the Tesco Site, which is enabled by this proposal, adds further to this strategic opportunity, with that scheme proposing up to 1,677 homes.

Retail Supermarket

8.30 The proposal includes the replacement of the existing Homebase DIY retail store with a new Tesco supermarket. The existing Tesco store provides a full range supermarket with a café, clothing and homewares and includes a pharmacy and optician, with this use serving the wider suburban area. The existing Tesco store, which is located on a site approximately 260m from the Site, would be relocated allowing the Tesco Site to be redeveloped with a mixed-use proposal. The proposed Tesco would re-provide its main uses within a more efficient store layout and proposes a reduction of 1,032 sqm in floorspace from the existing store.

8.31 The two planning applications are integrally linked through the proposed relocation of the Tesco store to the Site, and it is proposed that if permission were granted, there would be a restriction on the opening of the retail use to ensure the new premises is only a replacement store and not an additional store. It is noted the proposed Site Allocations includes a provision for a new retail store on the Site, the allocation proposing a minimum capacity of 10,940 sqm of retail and business floor space. The provision of the new supermarket on the Site would therefore generally accord with the Site Allocations and satisfies policy GWC1 of the GWC Plan which requires retail proposals to have regards to site allocations.

8.32 Policy GWC1 also supports opportunities to intensify and make more efficient use of employment land by co-locating employment with residential uses, and encourages a more diverse retail and food offer to encourage a more vibrant economy.

8.33 As the proposed Tesco store is a main town centre use, and the Site is not within a designated centre, it is necessary to carry out a sequential assessment to consider

6 GWC Plan – Housing Growth pg 40 the appropriateness of the location. HLP policy TC3 and London Plan policy SD7 reflect the requirements set out in paragraph 86 of the NPPF, which requires assessment of the location of large retail proposals to consider if there is sequentially preferable location. These policies seek to locate main town centre uses in town centres as a first preference, then in edge-of-centre locations, and then only if there are no suitable sites available or expected to become available within a reasonable period, should out-of-centre sites then be considered.

8.34 Additionally, these policies and NPPF paragraph 87 also require that a retail impact assessment be carried out for such development at edge and out-of-centre locations over certain thresholds. The NPPG includes guidance on requirements for these considerations including the scope for flexibility in the format and scale of proposals, and that such assessments need to be proportionate to the development proposed. Where an application fails the sequential test and/ or is likely to have a significant impact on the vitality and viability of existing town centres, it should be refused.

8.35 London Plan policy SD7 also seeks to realise the full potential of existing out-of- centre retail sites to deliver housing intensification through redevelopment and ensure such locations become more sustainable in transport terms, by securing improvements to public transport, cycling and walking. Where this occurs, proposals should not result in a net increase in retail floorspace in an out-of-centre location unless the proposal is in accordance with the Development Plan or can be justified through the sequential test and impact assessment requirements.

8.36 The sequential test submitted with the application has considered Hounslow and Brentford Town Centres, as well as the St John’s Road Large Neighbourhood Centre and Hanwell District Centre. The assessment shows that there are no suitable sites or units that could accommodate the proposed Tesco store.

8.37 In respect of retail impact, taken together the two developments would significantly reduce retail floorspace across the two sites (c. reduction of approximately 4,200 sqm). The current thresholds set out in HLP policies (being 500 sqm for retail and 2,500 sqm for other main town centre uses) distinguish between retail and other Town Centre uses, these are now combined in Use Class terms following changes to the Use Class Order. The Tesco Site development specification provides minimum floor space for certain categories within the wider Use Class definition, thereby ensuring a mix of uses would be provided and that the overall policy thresholds for the categories of use proposed are not exceeded. Additionally, the new Town Centre uses on the Site are proposed to primarily serve new residents of the housing, and the proposed Tesco store would be relocated on the existing Homebase Site only a short distance from its existing location.

8.38 Nevertheless the applicant has undertaken a proportionate qualitative assessment to consider the impacts of the proposal on existing, committed and planned public and private investment, and on the vitality and viability of relevant designated centres and their catchments. This assessment shows none of the centres considered would be significantly adversely affected in terms of investment and delivery of proposed schemes, as the new Tesco serves a different role to the major town centre regeneration schemes that are underway in Hounslow and Brentford or planned development in other centres (and it replaces the existing nearby store). The assessment also shows that there would not be significant adverse impacts on the vitality and viability of these centres as the relocated Tesco store would not materially change existing retail shopping patterns.

8.39 Therefore the principle of the proposed new retail store on the Site is acceptable, subject to a planning obligation that ensures the new Tesco cannot open until the existing Tesco store has closed.

Other retail and community use

8.40 The proposal also includes two units of non-residential space with a 200 sqm space for use by the local community located above the entrance to the Tesco store, and a 137 sqm retail unit located on the ground floor fronting Syon Lane.

8.41 The applicant advises that the community space would be managed by Tesco and would be available to be used without charge by community groups such as local schools, non-profit organisations and cultural organisations for meetings and events. The space could also be available for other community uses such as demonstrations, education, health care advice and campaigns at a reduced rate. The use of the space would be managed by a Tesco ‘Community Champion’. Tesco currently operate 72 similar community spaces at its larger stores. This use is supported as it provides a space for local people and organisations to meet, and undertake activities and share information for social, recreational, health, education and cultural purposes.

8.42 The small retail unit, which is likely to be suited to a shop or café, is acceptable as it would help activate the street frontage to Syon Lane, and it its modest size would ensure it serves local needs.

Other Socio-economic Impacts of the Uses

8.43 The proposed housing and commercial uses would intensify the use of the Site. The ES that accompanies the application has provided information on the socio- economic impacts of these uses on the area. This information considers the impacts from employment and economic activity, and on health and education needs arising from the increased population from people living in the new homes including cumulative development. Potential impacts on other community infrastructure in respect of open space and transport are considered separately later in this report.

8.44 HLP policy SC1 expects housing proposals to be completed in balance with existing and planned infrastructure, and to contribute to the provision of further infrastructure to achieve sustainable development and sustainable mixed communities. Consideration needs to be given to the location, scale and timing of new housing, and the quality, capacity and accessibility of existing health and social care facilities to meet this growth and to infrastructure needs arising from development.

8.45 The GWC Plan has considered these considerations and incorporates infrastructure capacity planning to meet the expected strategic and local growth needs with an Infrastructure Delivery Plan (“IDP”). The IDP provides detail on the infrastructure that will be delivered and what is needed for future growth, and it has assessed the requirements for the GWC Plan area.

8.46 Policy GWC7 of the GWC Plan addresses how development would be required to contribute proportionately towards necessary infrastructure provision identified in the IDP, at a rate and scale sufficient to support the area’s development and growth. This policy recognises that the Community Infrastructure Ley (“CIL”) and section 106 contributions are important means of funding and securing infrastructure through the development process.

Education and Health Care

8.47 HLP policies C12 and C13 seek to meet the education and health needs of the existing and future population and ensure the health and well-being of residents is maintained and improved, and impacts from development are mitigated.

8.48 Taking into account size, mix and tenure, the proposal for 473 homes is expected to accommodate approximately 1,249 new residents by completion of the development in 2026. The ES has forecast the impact of the scheme on social infrastructure, including primary and secondary schools and healthcare facilities, taking into account the existing and future demand, capacity and cumulative effects from other committed and proposed developments including the Tesco Site proposal.

Schools

8.49 The ES has calculated that the development would accommodate 74 primary aged pupils and 50 secondary aged pupils. Using available data the ES identified that there is an existing modest surplus of primary school places within the relevant area but that by 2023/24 there is a forecast to be a deficit of primary places. For secondary school places the ES identified that there is currently a large surplus of pupil places, but that this will reduce but there would still be a good surplus by 2025/26. The proposal along with other cumulative schemes including Tesco Site would have up to total of 2,538 dwellings, this equates to a need for approximately 397 primary school places and in the region of 268 secondary places should all the developments be implemented.

8.50 As such the ES considers that there would be a need for mitigation to provide for additional primary school places and a negligible effect that requires no mitigation for secondary places.

8.51 The Council has examined the impact at borough and planning area levels for both primary and secondary places, for both the application proposed on the Site and the Tesco Site. This examination found that there would be no significant impact for secondary school places from the proposal itself or cumulatively with the Tesco Site proposal. It is noted the IDP has considered the proposed 7,500 homes in the GWC Plan and highlights that since 2013 six primary schools within the vicinity of the GWC Plan area were expanded and the Nishkam (all-through school) has opened. Additionally two secondary schools, Green School for Boys and Bolder Academy have opened in the area, and the Oaklands SEN school in Isleworth has also been expanded.

8.52 This examination of existing capacity identified four existing Primary schools that fall within a mile radius of the developments and within three (of the five) Hounslow Primary Place Planning areas. Three of these schools currently have a significant surplus of places. In addition, if needed, there is opportunity within adjacent planning areas to make use of available capacity that is not currently in use. It is also noted that applications to schools are based on parental preference and therefore parents can, and often do, apply to any school regardless of distance.

8.53 Currently Brentford schools are experiencing a level of surplus beyond that which was projected. For the 2020/21 academic year, factors influencing the surplus in Brentford schools include a knock-on impact from surplus in the Chiswick planning area resulting from changes in the patterns of applications to Chiswick primary schools (e.g. economic effects of Covid and independent schools). Similar patterns in Brentford are expected beyond 2020/21, resulting in a further surplus.

8.54 In the long term, projections indicate at Borough level there is sufficient capacity for an increase in pupil numbers, however in the Brentford Planning Area the forecast indicates a shortfall; this in contrast to the other four planning areas which are showing a long-term surplus. This situation is being kept under review but it is noted that the Borough’s IDP and new Site Allocation and GWC Local Plan identifies a site in Layton Road, Brentford, for a new primary school.

8.55 For this development, where a future deficit in primary places eventuates, a contribution towards additional pupil places through expansion or the new school at Layton Road would be able to be made from the CIL payment for the development.

Local Health Care

8.56 The ES has considered local health services within the locality, with GP practices and their ability to accommodate additional patients reviewed. The numbers of both patient lists and GPs does fluctuate and since 2015 GP’s have been free to register people from outside the practice the boundary of their practice area. It found there was capacity to accommodate the needs of the Homebase when applying the national average of ratio of patients to GPs.

8.57 The Hounslow Clinical Commissioning Group (“CCG”) has considered the capacity of existing GPs to accommodate demand from the Homebase development (which is projected to generate a population of 1,249 people) with the six GP practices operating within the locality of the Site being considered. This assessment has shown that there is not capacity for the additional population for the Homebase or Tesco development, with patient to GP ratios above the recommended ratio of 1 GP per 1,800 people.

8.58 As with education needs, the IDP has considered the health infrastructure needs arising from future housing growth in the GWC Plan area. It notes that the primary mechanism for Hounslow health services comes from central government capital funding but also from strategic Community Infrastructure Levy payments and s106 contributions for site specific impacts. The CCG which is responsible for planning and buying health services in the area and works with the NHS is planning to establish six health hubs in the Borough including in Chiswick Health Centre, Brentford Health Centre, West Middlesex Hospital, and Heart of Hounslow. The CCG has requested a contribution towards the primary care capital cost to improve Brentford Health Centre. The GWC Local Plan identifies the need for additional healthcare capacity in the area and supports improvements to primary care facilities and expansion of existing health facilities into health hubs. The GWC Local Plan GWC7 also supports the use of s106 contributions where necessary to make the development acceptable in planning terms. The CCG advise that although some s106 contributions have already been allocated towards Brentford Health Centre, there remains a funding gap and they need for further developer contributions to deliver the project.

8.59 In this instance the CCG requirement and the need arising from the development itself and from the cumulative impacts of other development would need to be met by both planned social infrastructure within the local area through government funding and use of section 106 contributions in line with the IDP. Therefore a contribution of towards primary health care has been recommended as a planning obligation.

Employment

8.60 The development will result in the loss of the existing Homebase store. The existing store has 35-40 FTE7 jobs. However it is noted that this store is one of 42 Homebase stores to be closed in any event by their owner as part of insolvency action.

8.61 The proposed development would provide a new Tesco store with this having 290 FTE jobs (transferred form the existing Tesco store). The proposed retail unit on Syon Lane has potential for between 6-10 FTE jobs, bringing the total employment at the site to between 296-300 FTE jobs. Additionally, there is likely to be further employment opportunities at the Site from services such as cleaning, gardening, and maintenance etc. This is consistent with policy GWC1 of the GWC Plan which seeks to provide employment in the Opportunity Area in a format which optimises the use of land and re-provides and incorporates existing businesses.

8.62 The commercial uses proposed on the related Tesco Site could provide between 46- 155 FTE jobs, so cumulatively the two developments could provide up to around 450 FTE jobs.

8.63 In addition to permanent employment, the construction of the development would also create many temporary jobs. It is estimated that over the 3 year construction period and based on the construction costs, an average of 491 FTE construction jobs per month would be directly created on the Site. A further 476 FTE jobs are estimated to be created indirectly from this construction activity and associated employment from expenditure from potential purchase of building supplies to local provision of meals, refreshments, fuel and potential temporary accommodation for the construction workforce.

Spending

7 FTE = Full Time Equivalent 8.64 The new housing would add to the local population. The ES estimates that from this there will be an increase in overall spending of +0.5% in the Borough, from consumer spending as new residents use on-site and local shops and services to meet their day to day needs.

Skills and Training

8.65 London Plan policy E11, HLP policy ED4 and policy GWC1 of the GWC Plan all seek to secure employment and training initiatives for local residents where major development is proposed. This helps increase local skills and economic well-being of local people and enables more sustainable patterns of travel to work.

8.66 The development provides an opportunity to secure opportunities for construction training and possibly job brokerage to enhance skills and opportunities for local people, and obligations in this regard would be recommended.

Alternatives

8.67 The ES has outlined reasonable alternatives to the development proposed considered by the applicant and reasons the submitted scheme is the preferred proposal. The alternatives discussed included a ‘do nothing’ scenario, alternative locations and uses, and an alternative design and layout for the proposal.

8.68 A ‘do nothing’ alternative was not accepted as this would not make the most efficient use of the Site, which offers capacity for intensification. This would not deliver housing or employment opportunities or other environmental improvements. Alternative sites were not considered as the applicant has an interest in the Site. Additionally, the Site is allocated for a significant regeneration with a mixed-use development in the emerging Local Plan (GWC Plan and Site Allocations), and is a major site in the Great West Corridor Opportunity Area where significant housing and employment growth is proposed.

8.69 In respect of alternative designs, the proposal looked to ensure the development accommodated the relocation of the Tesco store to the Site and optimised the delivery of housing. The design of the development evolved through the pre- application process and consultation with various building heights and massing being considered with this balancing various opportunities and constraints including townscape, heritage, environmental conditions and making the best use of the land. It is therefore concluded the appropriate alternatives were considered.

Conclusion

8.70 Overall the proposed uses are acceptable in principle and in accordance with the objectives of the NPPF and policies of the London Plan and HLP to encourage higher density, housing led, mixed-use development in accessible locations. The proposal is a major opportunity for regeneration of an underutilised brownfield site bringing a mix of uses that would meet objectives for the enhancement and supporting of employment and economic activity in the Great West Corridor Opportunity Area. The 473 homes would make a very significant contribution towards the Borough’s housing need and relocation of the Tesco store to the Site will in turn facilitate the potential for an even larger scheme of housing-led regeneration on the Tesco Site. This would also be consistent with the emerging policies of the GWC Local Plan and Site Allocations.

8.71 The intensification of the use of the Site is compatible with the planning policy objectives for the Opportunity Area and will optimise the use of the out-of-centre retail site and its car park to deliver housing through mixed-use regeneration. Impacts on the local community infrastructure would be acceptable or would be able to be satisfactorily mitigated through funding from CIL or s106 payments where necessary. The resultant employment and training opportunities and spending would have a positive effect on the economy and economic well-being of the Borough.

8.72 Therefore the proposal complies with London Plan policies for ‘Good Growth’ (GG1- GG6), SD2, SD7, E11 and H1, HLP policies IMP1, SV1, TC3, SC1 and ED4, and is consistent with the emerging GWC Plan and Site Allocations, and the NPPF.

B. Affordable Housing and Tenure Mix

8.73 Paragraph 62 of the NPPF says where a need for affordable housing is identified, planning policies should specify the type of affordable housing required and that it should be normally provide on-site.

8.74 The LP emphasises8 that “…affordable housing is central to allowing Londoners of all means and backgrounds to play their part in community life. Providing a range of high quality, well-designed, accessible homes is important to delivering ‘Good Growth’, ensuring that London remains a mixed and inclusive place in which people have a choice about where to live.

Affordable Housing Policy

8.75 LP policies GG4 and G5 says that to create a housing market that works better for all Londoners, more homes must be delivered, a strategic delivery target for 50% of all new homes to be genuinely affordable is supported, and that development should create mixed and inclusive communities, with good quality homes that meet high standards of design and provide for identified needs, including for specialist housing. LP policy SD1 seeks to ensure that that Opportunity Areas maximise the delivery of affordable housing and create mixed and inclusive communities.

8.76 LP policies H4, H5, H6 and H10 provide the framework setting out the requirements and approach to provision and assessment of affordable housing within developments. All major development with 10 or more homes are to provide affordable housing on-site through the threshold approach, which includes provision for a ‘Fast Track’ route to considering development viability.

8.77 LP policy H10 says that schemes should consist of a range of unit sizes depending on local need and demand, the nature and location of the site, the aim to optimise housing potential, and the role of one and two bed units in freeing up family housing.

8 Paragraph 1.4.2 8.78 HLP SC2 sets a strategic target that 40% of additional housing delivered across the borough between 2015 and 2030 be affordable. Schemes are expected to deliver a mix of 60% affordable/social rented and 40% intermediate tenures with an appropriate mix of housing size and tenure in accordance with housing need. This policy predates the ‘Fast Track’ approach set out in the Mayor’s Affordable Housing and Viability Supplementary Planning Guidance (2017) and the policies of the published LP (2021).

Fast Track

8.79 LP policy H5 explains the ‘Fast Track’ approach to viability. It sets out that eligible planning applications are not required to submit viability information. Such applications need to:

1) Meet or exceed the relevant threshold level of affordable housing (35%) on site without public subsidy. 2) Be consistent with the relevant tenure split. LP policy H6 details the recommended affordable tenure split requirements with this being 30% affordable/social rent, 30% intermediate and the remaining 40% to be determined by the borough. 3) Meet other relevant policy requirements and obligations to the satisfaction of the borough and the Mayor where relevant. 4) Demonstrate that they have taken account of the strategic 50 per cent target in Policy H4 Delivering affordable housing and have sought grant to increase the level of affordable housing.

8.80 The threshold approach, including the ‘Fast Track’ route was first introduced in the Mayor’s Affordable Housing and Viability SPG in 2017. It aims to move away from protracted viability debates, create certainty in terms of affordable housing requirements, embed the requirements into land values, and offer a clear incentive for developers to increase affordable housing delivered through the planning system above the level in planning permissions granted in recent years. The supporting text to the LP says9 applicants are strongly encouraged to take the ‘Fast’ Track route by providing the threshold level of affordable housing and meeting other Development Plan requirements to the satisfaction of the Borough.

8.81 As fast tracked applications do not require a viability assessment at the application stage, the approach obliges submission of an Early Stage Viability Review if an agreed level of progress on implementation is not made within two years of permission being granted, in order to ensure an applicant fully intends to build out the permission.

8.82 Policy GWC2 of the GWC Local Plan is aligned with the new LP. It sets a strategic target of 50% of new housing to be affordable. It permits use of the Fast Track approach where applications propose at least 35% affordable housing, with the affordable housing to have tenure split of 70% London Affordable Rent or social rent and 30% intermediate. Where these conditions are met, the viability of the development would not be tested at the application stage, and there will not be any late stage review of viability.

9 Paragraph 4.5.1 Affordable Offer and Proposed Tenure Mix

8.83 This application is integrally linked to the Tesco Site application, with it intended that the existing Tesco store relocate to the Site, freeing the former for redevelopment, but only once the new replacement Tesco Store is completed. Both applications qualify for the threshold approach for applications under LP policy H5. They both provide a minimum of 35% affordable housing by unit, with the tenure mix agreed by the Borough. This means there is no requirement for a viability assessment from the applicant. This approach is consistent with policy GWC2 of the GWC Local Plan.

8.84 The application proposes 35% affordable housing by unit with a mix of 50% London Affordable Rent/ Social Rent and 50% intermediate housing across both the Site and the Tesco Site developments. The application for the Site is a full application, proposing 100% of the affordable housing to be at London Affordable Rent/ Social Rent and this housing is to be delivered first, within two blocks, B2 and B3. The remaining affordable housing provision will be delivered on the Tesco Site. The proposed affordable housing offer including tenure is show in the table below.

Proposed Affordable Housing (Homebase Site) Bed size/ No. of London Affordable Rent/ Social Rent units Total persons General Need Wheelchair accessible 1B/2P 63 1 64 2B/3&4P 51 6 57 3B/4&5P 31 9 40 4B/6P 5 0 5 Total 148 16 164

Table 4: Affordable Housing Offer

8.85 The proposed affordable offer would provide 164 affordable rented homes on the Site (35%), resulting in a positive contribution towards the Council’s affordable housing targets. The proposed homes are good quality and are indistinguishable from other homes in the development, with residents able to access all communal areas.

8.86 The scheme would also deliver 10% wheelchair accessible units in accordance with LP polices D5 and D7 and HLP policy SC5. The Council’s Housing Occupation Therapist Team has reviewed the plans for the wheelchair units. The 16 wheelchair accessible properties within the affordable housing offer have been placed on the lowest possible levels. These wheelchair units will be delivered as fully adapted units in a range of bed sizes to accommodate single persons to large families.

8.87 All of the affordable homes on the Site would be provided at Affordable Rent/ Social Rent levels, the maximum amounts to be set at London Affordable Rent levels as shown in the following table. London Affordable Rent level 2021/22 Bed size (weekly) Studio £161.71 1 Bedroom £161.71 2 Bedroom £171.20 3 Bedroom £180.72 4 Bedroom £190.23

Table 5: London Affordable Rent Levels 2021/22

8.88 The 164 affordable homes, including wheelchair units, would be secured with rents capped at the London Affordable Rent level, by section 106 obligations. The total housing charges associated with an affordable housing unit offered at London Affordable Rent/ Social Rent will be in accordance with the GLA’s Affordable Homes Funding Guidance to ensure household costs are reasonable and proportionate for households selected from the Borough’s Housing List. There would also be an obligation that requires an Early Stage Viability Review to be undertaken if an agreed level of progress on implementation is not made within two years of permission being granted.

8.89 The GLA Stage I response has confirmed that the proposed affordable housing offer complies with the criteria for the ‘Fast Track’ route, and states that an early stage viability review mechanism should be secured, in accordance with LP policy H5, together with provision for the applicant to fully explore grant funding to be incorporated to provide additional affordable housing beyond the baseline level of affordable housing.

8.90 HLP policy SC3 sets out the objective for development to include a general mix of unit sizes, type and tenure, including for affordable housing. The affordable housing mix should confirm to the suggested mix of social/ affordable rented housing unless otherwise agreed with the Council. The recommended mix and the proposed affordable housing mix are shown below.

Size Local Plan Proposed

1 bed 25% 38%

2 bed 45% 35%

3 bed 25% 24%

4 bed 5% 3%

Table 6: Proposed Affordable Housing Mix

8.91 The proposed unit mix within the affordable housing is agreed and would meet the Borough’s housing challenges, from single persons to six person family accommodation. A total of 102 homes would be suitable for families of 3 or more persons, with 27% of the affordable homes being 3 and 4-bedroom sized units.

8.92 The proposed mixed-use development on the Tesco Site, which is enabled by the relocation of the existing Tesco store, would provide a very significant contribution to housing delivery and also proposes 35% affordable housing, using the ‘Fast Track’ route. As that scheme is in outline, the exact number of homes and tenure is to be determined, but there is expected to be over affordable 560 homes.

Conclusion

8.93 The proposed 35% affordable housing and tenure would deliver a significant number of affordable homes. The early provision of 164 100% LAR units on this Site, as part of the comprehensive affordable offer over the two linked sites, is welcomed. The proposed Fast Track approach is appropriate subject to further exploration of grant funding to potential increase the level of affordable housing, with regard to the 50% strategic affordable target of the LP and GWC Local Plan, with this requirement and the proposed affordable units to be secured by a s106 agreement.

8.94 The strategic opportunity provided by the related redevelopment of the Tesco Site, which is facilitated by this proposal is also acknowledged, with this creating potential to deliver a very large number of affordable homes (35% of up to 1,677 homes).

C. Sustainability

8.95 At the heart of the NPPF is a ‘presumption in favour of sustainable development’, which requires local authorities as part of any plan-making or decision-making to provide clear guidance on how the presumption should be applied locally. In addition, the NPPF states10:

“The planning system should support the transition to a low carbon future in a changing climate, taking full account of flood risk and coastal change. It should help to: shape places in ways that contribute to radical reductions in greenhouse gas emissions, minimise vulnerability and improve resilience; encourage the reuse of existing resources, including conversion of existing buildings; and support renewable and low carbon energy and associated infrastructure.”

8.96 The LP and HLP encourage sustainable development through many policies including promoting the use of energy efficient building design and materials, re-use of previously developed land and existing buildings, and location of development in or close to town centres and areas with good public transport.

Sustainable Design

8.97 LP policy SI2 relates to minimising greenhouse gas emissions and states major development should be net zero-carbon. The policy sets out the energy hierarchy, and that this should inform the design, construction and operation of new buildings, with the priority to minimise energy demand and then address how energy will be supplied and renewable technologies incorporated. All developments should

10 Paragraph 148 of NPPF. maximise opportunities for on-site electricity and heat production from solar technologies (photovoltaic and thermal) and use innovative building materials and smart technologies.

8.98 A minimum on-site reduction of at least 35% beyond Building Regulations is required and developments are expected to achieve CO2 reductions beyond Part L from energy efficiency measures alone to reduce energy demand as far as possible. Residential development should achieve 10 per cent and non-residential development should achieve 15 per cent over Part L.

8.99 The emissions reduction target should be achieved in accordance with the following energy hierarchy:

 be lean: use less energy and manage demand during operation  be clean: exploit local energy resources (such as secondary heat) and supply energy efficiently and cleanly  be green: maximise opportunities for renewable energy by producing, storing and using renewable energy on-site  be seen: monitor, verify and report on energy performance

8.100 Where it is clearly demonstrated that the zero-carbon target cannot be fully achieved on-site, any shortfall should be provided either through a cash in lieu contribution to the Borough’s carbon offset fund, or off-site provided that an alternative proposal is identified and delivery is certain.

8.101 In addition, the whole life-cycle carbon emissions of a development should be calculated through a nationally recognised Whole Life-Cycle Carbon Assessment and actions taken to reduce life-cycle carbon emissions should be demonstrated.

8.102 LP Policy SI3 relates to Energy infrastructure, and states major development proposals within Heat Network Priority Areas should have a communal low- temperature heating system with the heat source for the communal heating system selected in accordance with the following heating hierarchy:

a) connect to local existing or planned heat networks

b) use zero-emission or local secondary heat sources

c) use low-emission combined heat and power (CHP)

d) use ultra-low NOx gas boilers

8.103 LP Policy SI4 relates to managing heat risk states that major development proposals should demonstrate through an energy strategy how they will reduce the potential for internal overheating and reliance on air conditioning systems in accordance with the cooling hierarchy.

8.104 These policies are also supported by other policies of the LP such as SI5 Water infrastructure, SI12 Flood risk management, SI13Sustainable drainage and G5 Urban Greening to maximise the sustainability of development, with environmentally sustainable practices to be incorporated in designs including achieving internal water use of 105L/Person/Day or less and sustainable material standards.

8.105 Policy EQ1 of the HLP says all development should meet the carbon dioxide emission reduction requirements of the LP, and major developments should consider additional energy reduction measures. Policy EQ2 relates to Sustainable Design and Construction and states developments should incorporate established principles for sustainable design and construction as set out in the LP. Non-residential development should be assessed against BREEAM and meet a rating of Excellent.

Sustainability Assessment

8.106 The application was accompanied by a detailed Energy Statement and Sustainability Statement, in accordance with LP policy SI2. The submitted documents show an on- site reduction in CO2 emissions of 51% from the Part L baseline. The Tesco store unit would be designed to be BREEAM ‘excellent’.

8.107 The Report details how the development can secure an on-site CO2 emissions reduction. In this regard the development addresses the energy reduction hierarchy as follows:

Be Lean

 Demand reduction measures to be incorporated within the scheme include insulated building fabric with low air permeability, glazing with suitable U-value, g- value and daylight transmittance, mechanical ventilation with heat recovery (but with openable windows to allow natural ventilation) and low energy lighting.  The building fabric performance (thermal transmittance and air permeability) is proposed to be in excess of the minimum standard required under Building Regulations to help reduce the heating and cooling demands of the development.

 The regulated CO2 savings achieved from the application of ‘lean’ measures are calculated to be 12% over the Building Regulations 2013 Part L notional base case for residential areas and 24% for non-residential, giving a site-wide reduction of 17%.

Be Clean

 Heating and hot water for the development is provided by a heat network led by high temperature air source heat pumps, which can supply 100% of the energy demand meaning electricity is used as the fuel source (For resilience, back up gas boilers are to be designed to the full peak capacity of the site. These would only be used in the event of heat pump failure to offset the difference between heat demand and supply).  An Energy Centre will be located in the basement of Block C and this would contain the heat pump internal units, gas boilers, thermal stores and other ancillary plant.  Roof space will be utilised for the heat pump units and will all feed back to the single Energy Centre  The Energy Centre will be adaptable in the future for connection to an area-wide heat network should one become available that is appropriate to connect to. The potential for future connection has been incorporated into the design.  Heat will provided for all homes which will be connected to the Energy Centre and non-residential units. However it is not proposed to connect the Tesco store to the heat network, as it is a large store that has significant heating and cooling demands. It is more efficient for the store to have both heating and cooling provided from the same plant instead of a separate heating and cooling plant.  The use of CHP contributes savings of a further 46% over the Part L 2013 base case for residential areas and 15% for non-residential.

8.108 The feasibility of connecting to an existing or planning district heat network was considered but there are no existing or planned networks in proximity to the Site. It is proposed that a site wide heat network is installed, supplying heat from a network sourced by high temperature air source heat pumps. All homes will be connected to the heat network, with connection points provided to all on-residential units (with the exception of the Tesco store, which will have a standalone heating strategy). Provision will be made for future connection to external heat networks, with a condition requiring details of a safeguarded pipe route to the Site boundary being recommended. These measures deliver a site wide CO2 reduction of 32% over the Part L 2013 baseline.

Be Green

 Use of solar PV panels has been provided on the available roof space (Flat roofs of Blocks A, D and E). Block C contains the air source heat pumps, whilst other blocks are not suitable owing to their dimensions and other proposed plant.

 The renewable technology delivers a further site wide CO2 saving of 2%.  A condition requiring high specification panels to be required is recommended to maximise the potential savings.

Be Seen

8.109 Standard monitoring of the Energy Centre and heat network will be undertaken during operation, with this to be secured by a condition. It is expected that the following will be metered:

 Resources used in the Energy Centre;  Heat leaving the Energy Centre;  Heat entering each block;  Final customer heat consumption.

8.110 The applicant has also submitted a Whole Life Cycle Carbon Emissions Review to give early recommendations of how to minimise embodied carbon in the construction of the development. This includes encouraged reuse and recycling of materials, consideration of the building materials used for the development, as well as built form.

Carbon Offset

8.111 As noted, the CO2 emissions savings across the entire scheme following the ‘Be Lean’, ‘Be Clean’ and ‘Be Green’ measures proposed results in an estimated CO2 emissions reduction of 51% over the Part L 2013 baseline.

8.112 It is considered that the approach taken has maximised on-site emission reductions; this is considered acceptable and fully supported. In order to achieve compliance with the ‘zero carbon’ standard, the applicant is required to make a financial contribution to the Council’s Carbon Offset Fund; this will be secured through the legal agreement (s106). This contribution has been calculated at £1,228,600.

Whole Life-Cycle Carbon Assessment

8.113 A preliminary ‘Whole Life-Cycle Carbon Assessment’ has been submitted in support of the application. This is intended to aid the understanding and minimise the carbon emissions associated with building designs over the entire life cycle of the building, considering not only operational and embodied emissions but also demolition, construction, and refurbishment/replacement cycles. The assessment would be finalised as the design of the proposal is advanced at the detailed construction stage. At present early recommendations relate to considerations that may reduce embodied carbon emissions through use of local suppliers and construction materials with better carbon performance. A condition required a further assessment prior to commencement of the development is recommended.

Other Measures

8.114 The proposal has sought to incorporate comprehensive sustainable design measures to mitigate its overall environmental impacts. These are set out in a Sustainability Statement, which details the approach that the applicant and the design team have collectively taken towards sustainable development and improved environmental performance. The improved public realm and greening of the Site helps make an overall positive contribution to the local environment, whilst the optimisation of what is an underutilised brownfield site also makes effective use of the land. Other more specific sustainable measures are summarised below (and discussed elsewhere in detail in the report as necessary):

 Water efficiency: Flow control devices and water efficient fixtures and fittings will be installed in all homes to target a maximum internal daily water consumption of 105 litres/person per day.  Waste and recycling: Adequate facilities will be provided for domestic and construction related waste, including segregated bins for refuse and recycling.  Materials: Where practical, new building materials will be sourced locally to reduce transportation pollution and support the local economy.  Flood Risk and SuDS: The development lies in a low risk flood zone and includes an attenuation and flow control system that collects surface runoff for discharge into a sewer.  Sustainable transport: The Site has access to a good existing public transport network and sustainable modes will be encouraged through the provision of cycle storage for the residential and commercial uses and improved conditions for walking and cycling around the Site.  Biodiversity and ecology: Enhancements will be implemented through the inclusion of ecological valuable habitats within the landscape strategy.  Green/brown roofs: An estimated 4,537 sqm of green/brown roofs is proposed.  Sustainable construction: The Site will aim to achieve a ‘Beyond Best Practice’ score with the Considerate Constructors Scheme and will closely monitor construction site impacts.  Circular economy: Key circular economy principles have been considered in the design to minimise embodied carbon, maximising the value extracted from materials and prioritising reuse and recycling.

Conclusion

8.115 The proposal includes measures to ensure the development is able to achieve high standards for energy efficiency and sustainable building design. Conditions are recommended to secure details of the installation and monitoring of the performance of the various measures proposed. The development would satisfy requirements of the LP energy hierarchy, achieving the minimum on-site CO2 reduction of at least 35% beyond Part L of Building Regulations, the site-wide reduction being 51%. A contribution is proposed to address remaining emissions to ensure the development satisfies the ‘zero carbon’ requirement for major development. With this contribution and the design mitigation inherent within the proposed buildings, the development would meet relevant objectives in regards to sustainable design, according with LP policies SI2, SI3, SI4, SI5, SI12, SI13 and G5, and HLP policies EQ1 and EQ2.

D. Urban Design and Impacts on the Townscape

Design Policy Context

8.116 The NPPF states11 that good design is a key aspect of sustainable development. It also says that planning decisions should ensure that developments will function well and add to the overall quality of the area for the lifetime of the development; are visually attractive as a result of good architecture, layout and landscaping; are sympathetic to local character and history, including the surrounding built environment and landscape setting, while not preventing discouraging appropriate change; establish or maintain a strong sense of place; optimise the potential of the site to accommodation an appropriate amount and mix of development; and create places that are safe, accessible and promote health and well-being.

8.117 Further guidance on aspects of good design is set out in the ‘National Design Guide’ under the following 10 characteristics:  Context - enhances the surroundings.

11 Paragraphs 124 and 127 of the NPPF.  Identity - attractive and distinctive.  Built form - a coherent pattern of development.  Movement - accessible and easy to move around.  Nature - enhanced and optimised.  Public spaces - safe, social and inclusive.  Uses - mixed and integrated.  Homes and buildings - functional, healthy and sustainable.  Resources - efficient and resilient.  Lifespan - made to last.

London Plan

8.118 Chapter 3 of the LP has design policies that look to deliver the ‘Good Growth’ objectives of the plan. It notes12 that change is a fundamental characteristic of London and that respecting character and accommodating change are not mutually exclusive, and that an understanding of the character of a place should not seek to preserve things in a static way but should ensure an appropriate balance is struck between existing fabric and any proposed change.

8.119 Policies D2 and D3 seek to make the best use of London’s finite supply of land and find the most appropriate form, scale and land use for the site taking into account existing and planned infrastructure, the attributes of the site and its context, and its accessibility. These policies provide a range of urban design principles requiring the building form and character to be appropriate with high quality buildings, accommodation and spaces including public realm, inclusive and legible movement routes that promote walking and cycling, urban greening and high sustainability.

8.120 Policy D4 emphasises the importance of appropriate design scrutiny with the higher the density the greater scrutiny, including from planning, design and conservation officers, and Design Review. Policies D5, D6 and D7 set out standards for accessibility and good quality housing. Policy D8 promotes a ‘Healthy Streets Approach’ and looks to maximise high quality new public realm, especially to encourage walking and cycling and provide more attractive landscaping, greening and safety, and places for people to meet.

8.121 Policy D9 sets out how development proposals should address the visual, functional, environmental, and cumulative impacts of tall buildings. The supporting text13 to the policy says that:

“Whilst high density does not need to imply high rise, tall buildings can form part of a plan-led approach to facilitating regeneration opportunities and managing future growth, contributing to new homes and economic growth, particularly in order to make optimal use of the capacity of sites which are well-connected by public transport and have good access to services and amenities. However, they can also

12 Paragraph 3.1.7 pg 106. 13 Paragraph 3.9.1 pg 141. have detrimental visual, functional and environmental impacts if in inappropriate locations and/or of poor quality design”.

8.122 Tall buildings should be part of a plan-led and design-led approach, incorporating the highest standard of architecture and materials and should make a positive contribution to the existing and emerging skyline. There should be an appropriate transition in scale where sites adjoin buildings of significantly lower height. Buildings should aid legibility and wayfinding and include active ground floor uses to ensure such buildings form an appropriate relationship with the surrounding public realm.

8.123 They also need to be appropriately located in respect of the capacity of the area and its transport network in terms of access to facilities, services, walking and cycling networks, and public transport. Regeneration benefits should be maximised as a catalyst for further change in the area. However, tall buildings should not have an unacceptably harmful impact on their surroundings in terms of their visual, functional, environmental and cumulative impacts, including wind, overshadowing, glare, strategic and local views and heritage assets.

8.124 In respect of heritage, proposals should take account of, and avoid harm to the significance of London’s heritage assets and their settings. Proposals resulting in harm will require clear and convincing justification, demonstrating that alternatives have been explored and that there are clear public benefits that outweigh that harm. The buildings should positively contribute to the character of the area. Buildings in the setting of a WHS must preserve, and not harm, the Outstanding Universal Value of the WHS, and the ability to appreciate it. Detailed policies relating to heritage impacts are discussed further below.

8.125 Policy D11 and policy D12 require design considerations to include measures to deter crime and to incorporate appropriate fire safety standards.

8.126 Policy D13 and D14 look to ensure new development does not unduly affect existing neighbouring uses, and that potential impacts from noise are addressed in the design.

Hounslow Local Plan

8.127 The current HLP has policies with similar objectives. HLP policy CC1 says that development proposals should have due regard to the ‘Hounslow Urban Context and Character Study 2014’ which analyses the urban character of the Borough and policy CC2 states that the Council will retain, promote and support high quality urban design and architecture to create, attractive, distinctive, and liveable places.

8.128 HLP policy CC3 outlines the approach to tall buildings, stating that to contribute to regeneration and growth, high quality tall buildings in identified locations, including along sections of the Great West Road, which accord with the principles of sustainable development will be supported. It goes on to list criteria against which proposals for tall buildings should comply as follows:  “Be sensitively located and be of a height and scale that is in proportion to its location and setting, and carefully relate and respond to the character of the surrounding area;  Be of the highest architectural design and standards; be attractive, robust and sustainable;  Be of a scale that reflects their relevance and hierarchical importance when located within a grouping/cluster of tall buildings;  Be designed to give full consideration to its form, massing and silhouette including any cumulative impacts and the potential impact of this on the immediate and wider context;  Relate heights to widths of spaces to achieve comfortable proportions, and provide a positive edge to the public realm and a human scale through the careful treatment of ground floors and lower levels;  Provide for a comfortable and pleasant microclimate which minimises wind vortices and over-shadowing;  Provide for biodiversity within the building form and be sensitive to surrounding open spaces including waterways to ensure minimal impact;  Take opportunities to enhance the setting of surrounding heritage assets, the overall skyline and views;  Carefully consider the façade and overall detailing to ensure visual interest, vertical and horizontal rhythms, an indication of how the building is inhabited, internal thermal comfort and the visual break-up of the building visually at varying scales;  Use materials and finishes that are robust, durable and of the highest quality, with facades providing innate interest, variety and function;  Incorporate innovative approaches to providing high quality, usable, private and communal amenity space where residential uses are proposed; and  Comply with the requirements of the Public Safety Zone for London Heathrow Airport, where appropriate.”

8.129 In respect of MOL, HLP policy GB1aims to protect and enhance its openness, quality and permanence, and expects development to maintain the openness, setting and visual amenity where it is located near MOL, with particular attention given to the location, setting, design, materials, height and landscaping. There is also specific heritage policy CC4 discussed further below.

8.130 HLP policy SC4 says the scale and density of development will need to make efficient use of land to achieve high quality design and accessibility, whilst responding to and reflecting local context and character and protecting existing residents’ amenity.

GWC Plan and Site Allocations

8.131 As noted, although the GWC Plan and Site Allocations, and related Masterplan are emerging planning documents of limited weight given their current status, they are consistent with the objectives for growth and development within the Opportunity Area and indicate the direction of travel for more intense development in the corridor.

8.132 These emerging documents allocate the Site for a more intense mixed-use development with a large retail store and housing above. They include recommendations in respect of appropriate building heights, including general height and massing and taller focal elements. However these heights are not a blueprint for proposed tall buildings, they are an indication of what may be appropriate. Whether or not they are acceptable would be the subject of detailed analysis and ultimately consideration of impacts and the overall planning balance. The Masterplan also acknowledges that it is unlikely that all new development will be designed so as to be invisible within the setting of nearby heritage assets such as conservation areas and listed buildings. Where acceptable levels of intrusion into important settings occur, they should be imaginative, of good design quality and appropriately scaled, and in respect of heritage assets any harm to their significance would need to be convincingly outweighed by public benefits.

8.133 GWC Plan policies GWC5 and GWC6 focus on optimising redevelopment opportunities and enhancing the overall environment, especially public realm, whilst respecting the area’s distinctive character and heritage. Harm to the setting of heritage assets including Kew WHS should be avoided. The GWC Plan and the Masterplan indicate that general building heights at the Site should be from 4 to 8- storeys, plus possibly an additional 1 or 2-storeys above this recessed from the main part of the building, with height lower towards Syon Lane. It also indicates taller elements (10-storey) may be appropriate to both the front and rear of the Site.

8.134 GWC Plan policy P1 supports the comprehensive redevelopment of Tesco and Homebase sites with quality mixed-us schemes that enhance the townscape and connections to existing new infrastructure including green spaces. Tall buildings are to be of an exemplary design and buildings should establish a strong sense of enclosure. High quality public realm improvements that improve conditions for walking and cycling, including enhancing the underpass at Gillette Corner, creating a segregated cycleway along the Great West Road, and providing a ‘clean air’ route parallel to the Great West Road.

Urban Design and Townscape Impact Assessment

Design and Access Statement

8.135 The applicant’s Design and Access Statement (“D & A”) and addendum provides information about the evolution of the design and the factors taken into consideration when preparing the scheme, which included the existing and emerging planning policy framework. It identifies site constraints and opportunities and explains how the applicant believes the scheme meets the development requirements and aims to maximise the quality of the design and minimise its negative impacts, as well as the rationale for the proposed uses, the design and layout of the buildings, the relationship to the local and wider environment, and the architectural detail and materials of the proposed buildings.

Townscape and Visual Impact Assessment

8.136 A Townscape and Visual Impact Assessment was submitted as part of the ES. This document also informs the applicant’s Heritage Statement that considers impacts of the buildings on the settings and significance of heritage assets in both the nearby streetscene and in long distance views including various listed buildings, conservation areas, registered parks and gardens and the Royal Botanic Gardens WHS. The impacts on the significance of heritage assets are considered separately below.

8.137 The ES assesses potential townscape impacts from agreed viewpoints that were selected in consultation with officers. Verified views provided in accurate visual representations (“AVRs”) show how the proposal would look from different locations. Such AVRs are static representations of how the proposal would be perceived, and views vary when moving around the site but impractical to evaluate every single point from where the development may be seen, however the selected views are considered to be the most representative and sensitive locations.

Townscape and Landscape Context

8.138 Immediate context – The Site occupies a prominent position at Gillette Corner, with it lying at a point of transition between the largely commercial development along the Golden Mile stretch of the Great West Road (north and east), and generally suburban scale housing (south and west). The Golden Mile is dominated by the traffic on the distinctly wide Great West Road. Commercial buildings are generally large but predominantly low rise though very tall buildings including the GlaxoSmithKline building are apparent in the townscape. There are some high quality historic Art Deco style buildings with positive street frontages, as well as more modern buildings that are setback from the road by car parking which also lack architectural merit. Poor quality footpaths and cycleways, and a lack of vegetation also detract from the townscape. The single level Homebase building is a distinctive, good quality structure in the streetscene and its scale is compatible with its context, but its large areas of car parking and inactive frontage makes its overall townscape contribution a negative one and the site is underutilised.

8.139 The two-storey housing on the opposite side of Syon Lane and further west and south are generally good quality and has a uniform scale. This area provides greenery with street trees and landscaped front gardens and this is an area recognised as having a special character.

8.140 The Hounslow Character and Context Study classifies the site and its surrounds on the Great West Road as being of ‘low design quality’ with a ‘low sensitivity to change’, as well as with ‘some suitability for tall buildings’. This study identifies Gillette Corner as a gateway, with both the Gillette building and Homebase building also shown as landmarks.

8.141 Wider context – With tall buildings proposed, the development would be likely to be seen from considerable distances away in some viewpoints. Further away from the Site the general pattern of large commercial buildings continues east along the Great West Road with residential areas to the west. To the north and south the suburban areas give way to large open spaces which are mostly historic listed parks and gardens and MOL including Osterley Park and Syon Park. Even further south and across the Thames, around 1.4km from the Site, is the Kew Gardens WHS, which is also a conservation area and registered park and garden. These historic listed parks and gardens also include various listed buildings include Osterley House and Syon House. A noted, the effects of the proposal on the significance of these heritage assets are discussed separately.

Design Scrutiny and Appraisal

8.142 In accordance with LP policy D4 the design of the proposal has been scrutinised by the Council’s urban design, conservation and planning officers, and has been the subject of a process of independent design review. The design of the proposal has also been assessed by officers of the GLA.

Layout, Public Spaces, Movement and Landscaping

8.143 The proposed layout would transform the Site which presently has large areas of surface car parking with the existing building set well back from the street. The development is comprised of a large podium (4-storey equivalent) with tall buildings and landscaping above. A large urban block would be formed, with this occupying most of the site. This new block would help enclose the street and better define the street edge, and with the proposed uses to the ground floor, it will provide more active frontages than at present whilst upper floor residential uses introduce more causal surveillance of the street. There would be significant areas of new public realm with landscaping around the Site, including pedestrian paths and cycleways.

8.144 The floor space requirements for the relocated Tesco store have reduced the ability to provide greater building setbacks and so this element will contrast with the building line of some other established, high quality buildings along the Great West Road. The building frontage is however setback further than the existing car park boundary, which has created a more spacious area for pedestrians, cyclists and landscaping than at present. New and enhanced street tree planting and paving will make the public realm more attractive. The car park and servicing entrances diminish the full benefit of some of the improved public realm as pedestrians must still make way for vehicles, at a number of points, though the scheme would be impractical without their provision and the landscaping design has sought to highlight the pedestrian route and overall he proposal significantly enhances the environment for pedestrians and cyclists

8.145 The new Tesco store entrance and its frontages to the Great West Road and Syon Lane provide activity to the ground floor. Elsewhere to the ground floor there will be activity from the new retail unit, the main housing entrance closer to Syon Lane Station plus the secondary residential and staff entrances around the building perimeter. There are some sections of inactive frontages, particularly around the rear and on Syon Gate Lane (eastern elevation) and good quality landscaping, including lighting will be important to ensure these spaces have a good sense of safety.

8.146 A stepped, landscaped ‘amphitheatre’ space is provided adjacent to Gillette corner outside the Tesco store entrance. This space is partly sunken below the adjacent road level so will have some shielding from the adjacent traffic and with good landscaping planting it could be a new space for waiting or meeting people which the area along the Great West Road distinctly lacks at present. New works to the adjacent public highways to provide the new cycle routes and improve pedestrian walkways have the same design as the new landscaping and paths around the Site and cumulatively they would enhance the appearance of the public realm.

8.147 A large paved forecourt (around 14m x 14m) highlights the main entrance to the housing from Syon Lane, with this appropriately located most conveniently closest to Syon Lane Station. On the podium itself, buildings are separated by communally accessible open space including play areas. Housing quality is discussed in detail further below, but the spaces between blocks will ensure satisfactory access to daylight and sunlight, and will provide adequate privacy for new residents. Residents would be able to use either the main entrance from Syon Lane to access this podium and then building cores, or they can enter individual building cores direct from the street at various points around the Site. The building layout provides some screening of noise and air pollution to the interior of the Site but homes fronting the Great West Road in Block A and B1 will be exposed to higher levels of pollution. New street trees along the Great West Road and Syon Lane will maintain and enhance greenery, especially to the former where there is currently only poor quality hedging.

8.148 The new ‘Clean Air’ route along Syon Gate Way and the new public realm along the eastern boundary (Syon Gate Lane) will address the aspiration for an alternative route for pedestrians and cyclists parallel to the Great West Road. The route varies in width from a minimum of 3.05m up to 8.505m. Amendments were made to the originally proposed design to improve the quality and function of the route by increasing its width, enhancing sightlines, and adding a residents’ space to attract footfall and activate the rear corner of the Site. If neighbouring sites come forward for development it would be expected this route would be extended eastwards, preferably alongside the railway boundary to avoid interruption for vehicle access.

8.149 The associated highway works, including a new surface crossing of the Great West Road and cosmetic improvements to the existing underpass and environmental improvements for the route between the Site to the Tesco Site, will combine with the other new public realm and landscaping and active ground floor uses, to result in a much improved environment for walking and cycling in line with objectives to encourage more active travel. These improvements are compatible with the objectives of the GWC Local Plan to transform the corridor with enhanced public realm with a continuous well connected green network that optimises urban greening.

Built Form, Height and Density

8.150 HLP policy CC3 provides support for tall buildings of high architectural quality along sections of the Great West Road however these need to relate sensitively to surrounding residential areas and should not have a significant adverse impact on the setting of, or views from heritage assets including Gunnersbury Park, Royal Botanic Gardens Kew World Heritage Site, Syon Park and Osterley Park.

8.151 The proposed development is high density and has a series of tall buildings (defined in the HLP as those over 6-storeys in 20m tall) with scheme including buildings up to 17-storeys. As noted in the GLA Stage I response, the proposed building heights would be a step-change compared to the scale of development on the Site and its surrounding context. Consequently there would be a high magnitude of change to the local townscape, and owing to the height of the buildings, they would be able to be seen from longer distances and so potentially impact on the setting of heritage assets in the surrounding area. Upper floors of some blocks would be glimpsed in views from parts of Osterley Park, more extensive views of parts of the buildings are seen from certain parts of the western side of Syon Park, and there are very limited points in and adjacent to Kew Gardens WHS where there are partial glimpses.

8.152 The emerging GWC Local Plan and Site Allocations, supported by the Masterplan, look to advance the regeneration of the great West Corridor and will identify the preferred locations for tall buildings accounting for wider impacts including heritage. These documents suggest appropriate heights and massing, though as discussed above, they are not yet adopted and so have only limited weight. They envisage substantial change in the area, with more intense development which includes tall buildings (over 6-storeys). However for the purpose of this assessment the current HLP policy CC3 and LP policy D9 provide the criteria for which tall buildings would be expected to comply with.

8.153 The new buildings would be prominent additions to the townscape. Block B1, the 17- storey tower fronting the Great West Road, and Block A, the distinctive building adjoining Gillette Corner, which both have Art Deco inspired styling, would become new features of the Golden Mile, and help mark the western entrance to the area. The height and massing of Block A has respected the setting of the Gillette building, with it stepping down towards Gillette Corner where it is 6-storey, to maintain views of the façade and tower of the Gillette building along Syon Lane in both directions. Block B1 is set further away from the corner and although being considerably taller it avoids unduly competing with the Gillette tower due to its position. Owing to its height and the rise in ground level it would be a prominent new landmark in the view approaching the Site from the east along the Great West Road. It will mark end of the Golden Mile, its height emphasising this significance, and the transition to the generally suburban character of the area further west of the Site.

8.154 The development will also change the wider townscape. It would be seen from the surrounding residential areas to the west, particularly along roads orientated towards the Site, but the layered form, with building heights lowering towards the western boundary would avoid the change in scale being too abrupt while the varied materials details will also provide articulation. From the north side of Syon Lane Blocks A and B1 have been designed to maintain the pre-eminence of the Gillette building’s clocktower, Block A stepping down in height towards the corner and Block B1 having its narrowest elevation facing the street. From parts of the residential areas to the south of the Site the upper parts of the buildings, especially Blocks B2, B3 and C would be apparent. The change in scale is acceptable given the difference in character between the Great West Road and these areas, whilst the separating distance, good quality finishes and undulating height would ensure it is not obtrusive.

8.155 Block B1 is conjoined with other buildings along the eastern flank of the Site, where there are two other tall buildings, Blocks B2 and B3, which both are 15 storeys. The height and bulk of the proposed buildings and link buildings (which are up to 10- storeys) contrast with the scale of the existing lower rise development in the foreground when seen from the east of the Site. Revisions to this eastern elevation have been made to reduce the perception of a wall of development, and the varying patterns of grid detail and range of materials and other architectural features add interest and highlight the individual blocks. These buildings will be mostly seen in the context of the Great West Road, where there is a varied townscape that includes tall and large buildings such as GlaxoSmithKline and Great West House. In longer distances from the west along the Great West Road these taller elements will form a group that with Building B1 marks the entrance to the Golden Mile, the variation in building height and form ensuring they do not appear as a solid wall.

8.156 Along Syon Lane the building height is more moderate with building heights being from 4 to 7-storeys (Blocks D and E) along most of the Site frontage, apart from the 10-storey building (Block C) which is closer to Syon Lane Station. The building heights and massing along Syon Lane satisfactorily respects the transition in scale and character between the larger, sometimes monumental scale of the mostly commercial development of the Golden Mile, and the finer grain suburban housing further west and south of the Site. The varied height and elevational detail along this frontage helps to break up the large size of the podium, with the active ground floor uses (Tesco store, retail unit and main residents’ entrance/ lobby) aiding this objective. Blocks D and E are arranged perpendicular to Syon Lane which has reduced their apparent bulk from the street. The recessed upper floors to Blocks D and E, and spacing between the blocks, have also helped to reduce daylight impacts to surrounding properties.

8.157 Block C, which has 10-storeys, is located in the southern corner of the Site near to the railway. A tall building is appropriate here as it would help to mark the location of Syon Lane station, a major transport node, and it also highlights the main arrival point for residents of the development.

8.158 Impacts on the openness of the MOL of Syon Park and Osterley Park are acceptable. The proposed buildings have only an indirect effect on the MOL through being apparent in some parts of the setting. Where the buildings are apparent they would result in only very minor changes to the skyline with a negligible effect on the openness of those spaces.

Character and Appearance

8.159 The proposed buildings satisfactorily respond to the varying character and context around the Site through careful architectural design. The details and materials of the prominent buildings facing the Great West Road incorporate strong horizontal banding, prominent fenestration, curved forms and a selection of colours and finishes that are influenced by the style and linear form of the Art Deco buildings found along the Golden Mile though being clearly contemporary additions. Block A in particular will provide a distinctive and unique, high quality architectural contribution to the townscape. Its cascading massing and curvilinear forms address the more sensitive context of Gillette Corner/Syon Lane and respects the setting of the Gillette building. Use of blue coloured brick as the main finish with white and bronze brick and metal details will distinguish the building from the surrounding development.

8.160 Block B1 has both vertical and horizontal detailing, which complements Block A. Its details and materials are also high quality. A more slender, perhaps taller building that is more clearly separated from the other proposed blocks would have made this block and Block A more distinct townscape additions in their own right, however the design strategy has appropriately sought to distribute a greater amount of building to the less sensitive eastern half of this Site.

8.161 The proposed buildings on eastern side of the Site (Blocks B2 and B3) are broken down into blocks through use of varying grids that highlight vertical and horizontal proportions through use of details and more traditional brick colours. Revised drawings have sought to add more articulation and activity to the elevations whilst balancing this against the need to have some coherence between buildings. These blocks are generally less apparent than the other elevations and they have a plainer character compared to the more unique buildings at the front of the Site.

8.162 Buildings fronting Syon Lane, comprising Blocks A, C, D and E show more variation in form and style in attempt to break up the podium as seen from Syon Lane where the Site is opposite suburban housing. Blocks D and E form a pair of buildings that incorporate a range of distinctive finishes that continue to ground level helping to divide the large podium. As noted, the ground floor elevation includes a section of inactive frontage, as a result of the main car park entrance, but there would be sufficient interest and activity provided by the large glazed shopfront to the Tesco store, three separate residential entrances including the main arrival lobby and a separate retail unit. In views along Syon Lane the development would be read as a series of buildings distinguished by their different details and colours, the lighter tone of Blocks A, D and E ensuring the Gillette building remains clearly distinct. Block C has a brown brick to give it its own identity but it includes lighter brick banding and bronze coloured metal details to windows and balconies to integrate it with other buildings of the scheme.

Design Review

8.163 LP policy D4 requires larger, higher density schemes to undergo additional design scrutiny with this to include independent design review. Applicants are also required to explain how they have considered and addressed the design review recommendations. The application (and the Tesco Site) was considered by Hounslow’s Design Review Panel (“DRP”) both prior to submission and post submission. Guidance on the role of such reviews is that they should not to dictate the design of a scheme or contradict planning policy, but look to guide better design outcomes instead.

8.164 The DRP’s initial review raised a range of issues about the amount of development and the overall strategy for the Site primarily resulting from the requirements for the Tesco store and how this has affected the design. The applicant reviewed their design as set out in the D&A accompanying this application to address some of these concerns. The post review DRP acknowledged the applicant had made changes but saw these as mitigation rather than solutions.

8.165 The latest DRP comments raised concern about the adequacy of the ‘clean air’ route and the public realm overall, in particular the space and landscaping available for residents, its sense of safety and conflicts with other uses. They understood the rationale for taller buildings on the eastern flank and lower buildings to Syon Lane and found that in general the buildings were good design but there were concerns above the amount of development above the podium. However, although they felt it was correct for the 17-storey tower to be the high point that steps down to the corner they considered it did not have enough space around it and that it could be of much higher architectural quality and they would support a more elegant taller tower to help redistribute some mass from elsewhere, subject to appropriate view testing.

8.166 The concerns about the amount of development also included the number of single aspect units and spacing of blocks on the podium. Other matters were poor environmental conditions for the ‘amphitheatre space’ from its proximity of the Great West Road and how robust the materiality and landscaping was in this context. The commitment to provide a surface crossing of the Great West Road was welcomed but there was disappointment the opportunity to show the linked vision between the site and Tesco Site had not been highlighted. Ultimately, the DRP concluded that the brief to accommodate a Tesco store of equivalent size to the existing store has made it virtually impossible to achieve a scheme of the quality aimed for.

8.167 To address comments from the DRP as well as comments from Council officers, revisions to proposal were made through the pre-application process and amendments were also made to the submitted proposal, however the store format has remain unchanged as it needs to accommodate the requirements of the replacement Tesco, and it has already been made more efficient with it having a lower floor space than the existing store. The changes that have been made focussed on the ground floor spaces and the elevational treatment of the building.

8.168 To improve the ‘clean air’ route, more active frontage has been provided with a residents’ amenity space that has glazed frontages to the new route and residential entrances were made more prominent. The route itself was also widened and service access points chamfered to improve safety. Lighting and landscaping along the route has been reviewed. To respond to comments regarding the massing and scale of the buildings, especially to the eastern elevation, various gridded detail and material palettes were explored. Amendments to the eastern faced have been made to provide a more muted colour scheme to Blocks B2 and B3 with tonal changes to the buildings that link them. At the lower level use of darker materials is now proposed to help better define the base of the building and add interest.

8.169 The changes have responded to comments and are positive improvements that will enhance the public realm and the appearance of the buildings in the townscape. Concerns regarding the overall form of the proposal are noted, however it is acknowledged that the need to provide a replacement Tesco store has constrained some design opportunities, with this also noted by the GLA Stage I response. However the overall layout and public realm, height and massing and character of the development has provided an appropriate, good quality design response to the requirements to optimise the use of the Site in the Opportunity Area, whilst respecting the surrounds given the constraints from accommodating the Tesco store.

Other design considerations

8.170 Additional matters that contribute to evaluation of design quality including housing standards, sustainability and environmental effects relating to wind, daylight and sunlight within the scheme and for neighbours, plus any necessary mitigation, are considered elsewhere in this assessment. The assessment has concluded the proposal is acceptable in each of these considerations.

Conclusion

8.171 The mixed-use proposal which includes a significant number of new homes with active ground floor uses and new public realm around the perimeter of the Site would increase the intensity and vibrancy of the development at the Site. The overall height and massing would transform the Site into a large urban block with a much stronger urban edge that also has a series of tall blocks that would create a new skyline. The buildings include varying forms and horizontal and vertical details that provide a degree of coherence across the Site but also help break up the massing, including for the large podium. The proposed materials and finishes are high quality and robust, with brick construction of various colours being the main finish throughout. The use of different colours and patterns as well as the varying form and height of buildings will provide good interest and articulation, though as noted the buildings will be larger than the surrounding development. More consideration of the effects on the settings and significance of nearby and more distance heritage assets are discussed further below.

8.172 The requirements for the Tesco store and the resultant podium design has in part compromised the layout and overall form of the development and this means it will be more assertive than had more generous building setbacks been provided. Nevertheless the massing of the blocks and location of taller elements has taken into account the surrounding context of the Site including the change in character from the Golden Mile to neighbouring residential areas, as well as the nearby buildings of character. Considerable change is expected with the growth of housing and employment planned for the Great West Corridor Opportunity Area. This emerging context and the strategic opportunity resultant from the redevelopment of the Tesco Site which is facilitated by the development have also been considered. Although resulting in high magnitude of change to the townscape, the proposed design provides a clear identity appropriate for the context and character of the Site which sits at the entrance to the Opportunity Area and Golden Mile, and on the whole the architecture would be high quality. Therefore the urban design and townscape impacts of the proposal are acceptable, the development optimising the use of the Site in a manner that satisfactorily accounts for the context of the Site with high quality architecture that would enhance the public realm and encourages active travel, with this being consistent with LP policies D2-D9, and HLP policies CC1-CC3 and GB1 and the direction of travel indicated in the GWC Local Plan. The heritage aspects of policies D9 and CC3 are considered in the following section.

E. Heritage

Heritage Policy Context

8.173 There are a range of designated heritage assets in the vicinity of the Site and the wider area that may be affected by the development, including the proposed tall buildings through change to their setting. The Council has also a relevant statutory duty under section s66(1) of the Planning (Listed Buildings & Conservation Areas) Act 1990, which requires that decision makers pay “special regard to the desirability of preserving” listed buildings or their settings.

8.174 In respect of this statutory duty case law from the Court of Appeal14 confirms that “preserving” means “doing no harm”. Further, it has been held15 that decision-makers should give “considerable importance and weight” to the desirability of preserving the setting of listed buildings when carrying out the balancing exercise in cases which involve heritage issues. This duty may be addressed through applying relevant policies of the Development Plan and the NPPF that consider effects of development on heritage.

National Policy and Guidance

8.175 Part 16 of the NPPF details policies for the conservation and enhancement of the historic environment. It states16 that heritage assets are an irreplaceable resource, and should be conserved in a manner appropriate to their significance, so that they can be enjoyed by future generations.

8.176 Paragraph 185 says that in determining applications, local authorities should take account of:

a) the desirability of sustaining and enhancing the significance of heritage assets and putting them to viable uses consistent with their conservation;

b) the positive contribution that conservation of heritage assets can make to sustainable communities including their economic vitality;

c) the desirability of new development making a positive contribution to local character and distinctiveness; and

d) opportunities to draw on the contribution made by the historic environment to the character of a place.

8.177 Paragraph 193 says:

“When considering the impact of a proposed development on the significance of a designated heritage asset, great weight should be given to the asset’s conservation (and the more important the asset, the greater the weight should be). This is irrespective of whether any potential harm amounts to substantial harm, total loss or less than substantial harm to its significance.

8.178 Paragraph 194 says that any harm to, or loss of, the significance of a designated heritage asset, including from development within its setting, should require clear and convincing justification.

14 Barnwell Manor Wind Energy Ltd v East Northamptonshire DC & Others ([2014] EWCA Civ 137) the Court of Appeal 15 Ibid. 16 Paragraph 184 of the NPPF. 8.179 Paragraph 196 says where a development proposal will lead to less than substantial harm to the significance of a designated heritage asset, this harm should be weighed against the public benefits of the proposal, including where appropriate, securing its optimum viable use.

8.180 ‘Significance’ in the context of heritage policy is defined17 as

“The value of a heritage asset to this and future generations because of its heritage interest. The interest may be archaeological, architectural, artistic or historic. Significance derives not only from a heritage asset’s physical presence, but also from its setting. For World Heritage Sites, the cultural value described within each site’s Statement of Universal Value forms part of its significance”.

8.181 Paragraph 201 notes that not all elements of a Conservation Area or a WHS will necessarily contribute to its significance.

8.182 ‘Setting’ in the context of heritage policy defined18 as:

“The surroundings in which a heritage asset is experienced. Its extent is not fixed and may change as the asset and its surroundings evolve. Elements of a setting may make a positive or negative contribution to the significance of an asset, may affect the ability to appreciate that significance or may be neutral”.

8.183 The NPPG explains why ‘significance’ is important in decision taking by advising19:

“Heritage assets may be affected by direct physical change or by change in their setting. Being able to properly assess the nature, extent and importance of the significance of a heritage asset, and the contribution of its setting, is very important to understanding the potential impact and acceptability of development proposals.”

8.184 In respect of assessing if a proposal causes substantial harm to a heritage asset, the guidance sets out that it is the impact on the significance of the heritage asset that matters, with significance deriving not only from the asset’s physical presence, but also from its setting. Whether there is substantial harm is a judgement for the decision taker. In general terms, substantial harm is a high test, so it may not arise in many cases. It is the degree of harm to the asset’s significance rather than the scale of the development that is to be assessed. The harm may arise from works to the asset or from development within its setting20.

Historic England

8.185 Historic England (“HE”) has guidance to inform planning decisions relating to heritage, including ‘Advice Note 2 – Managing Significance in Decision-Taking in the Historic Environment’ (2015) , ‘Advice Note 3 - The Setting of Heritage Assets’ (2017), and ‘Advice Note 4 – Tall Buildings’ (2015).

17 NPPF Glossary (Annex 2) 18 NPPF Glossary (Annex 2) 19 Paragraph: 007 Reference ID: 18a-007-20190723 of NPPG. 20 Paragraph: 017 Reference ID: 18a-017-20140306 of NPPG. 8.186 HE advice note 3 sets out a process for understanding setting, and how it may contribute to the significance of heritage assets and allow that significance to be appreciated, plus advice on how views contribute to setting. A staged approach to taking decisions on setting is suggested to assess the contribution of views to the significance of heritage assets. It comments21 that:

“Consideration of the contribution of setting to the significance of heritage assets, and how it can enable that significance to be appreciated, will almost always include the consideration of views”. The also guidance refers to the NPPF and NPPG’s explanation of the setting of heritage assets.

8.187 This guidance continues22 that the importance of the setting lies in “…what it contributes to the significance of the heritage asset or to the ability to appreciate that significance.”

8.188 And it considers23 effects from cumulative change, noting that where “…the significance of heritage asset has been compromised in the past by unsympathetic development affecting its setting, to accord with NPPF policies consideration still needs to be given to whether additional change will detract further from, or can enhance, the significance of the asset”.

8.189 This guidance also discusses particular circumstances such as designed settings, where planned landscapes contribute to the significance of heritage assets. It notes24 that as well as development within the immediate vicinity of an asset “…development further afield may also affect significance, particularly where it is large-scale, prominent or intrusive”.

London Plan

8.190 LP policy D9 relating to tall buildings sets out matters to be considered when assessing tall buildings including immediate, medium and long distance visual effects, functional impacts, environmental effects and also cumulative impacts from impacts of proposed, consented and planned tall buildings in an area. It says proposals should take account of, and avoid harm to, the significance of London’s heritage assets and their settings. Proposals resulting in harm will require clear and convincing justification, demonstrating that alternatives have been explored and that there are clear public benefits that outweigh that harm. The buildings should positively contribute to the character of the area. The policy also says development in the setting of a WHS must preserve, and not harm, its Outstanding Universal Value (“OUV”), and the ability to appreciate it.

8.191 Policy HC1 says development proposals affecting heritage assets, and their settings, should conserve their significance, by being sympathetic to the assets’ significance and appreciation within their surroundings. The cumulative impacts of incremental change from development on heritage assets and their settings should also be actively managed. Development proposals should avoid harm and identify

21 Views & Settings paragraph 5 Advice Note 3 - The Setting of Heritage Assets (2017) 22 Views & Settings paragraph 9 Advice Note 3 - The Setting of Heritage Assets (2017) 23 Ibid. (p4) 24 Ibid.(p5) enhancement opportunities by integrating heritage considerations early on in the design process.

8.192 Policy HC2 relates to World Heritages Sites and says that proposals in their settings should conserve, promote and enhance their OUV, including the authenticity, integrity and significance of their attributes, and support their management and protection. Where development proposals may contribute to a cumulative impact on a WHS or its setting, this should be clearly illustrated and assessed in the Heritage Impact Assessment. Finally, up-to-date WHS Management Plans should be used to inform the plan-making process, and when considering planning applications, appropriate weight should be given to implementing the provisions of the WHS Management Plan.

8.193 The Mayor’s WHS Supplementary Planning Guidance supports the LP and has guidance on the interpretation of setting and understanding its importance in contributing to an appreciation of OUV, and includes a methodology for assessing heritage impacts. It includes a requirement to consider cumulative impacts from incremental changes caused by past, present or potential developments with planning permission that cumulatively with the proposed development can have a significant impact on the setting of a WHS. The design of development proposals should be considered against their effect on the elements of setting of the WHS and the resultant degree of harm or benefit to the attributes of its OUV.

Hounslow Local Plan

8.194 HLP policy CC4 seeks to conserve and take opportunities to enhance the significance of the Borough’s heritage assets as a positive means of supporting an area’s distinctive character and sense of history. This policy expects development proposals to:

 Conserve and take opportunities to enhance any heritage asset and its setting in a manner appropriate to its significance;

 Retain, conserve and reuse a heritage asset in a manner appropriate to its value and significance;  Demonstrate that substantial harm to or loss of a heritage asset is avoided, unless exceptional circumstances can be demonstrated, consistent with the NPPF;  Demonstrate that where a development proposal will lead to less than substantial harm to the significance of a designated heritage asset, this harm will be outweighed by the public benefits of the proposal, including securing its optimum viable use; or  Have regard to any harm to, or loss of, the significance of a non-designated heritage asset, including from both direct and indirect effects.

8.195 The supporting text to this policy says25 that the “…protection and enhancement of the historic environment is a core principle that as well a legal duty underpins sustainable development” and that the “...borough’s heritage assets are irreplaceable

25 Paragraph 6.13 of the Hounslow Local Plan. resources and are particularly sensitive to change and development, requiring special protection and careful treatment to sustain their value and importance for future generations”. It also notes that “development can impinge on the settings of the most important assets”. Policy CC3 also requires buildings to carefully relate to the surrounds including the wider context of sites. Conservation Areas that are described in the HLP are also the subject of conservation area statements and appraisals that explain the key elements of their heritage significance and also pressures and opportunities relating to their character and appearance.

Other considerations

8.196 Royal Botanic Gardens WHS, Kew – The Royal Botanic Gardens WHS has a Management Plan 2019-2025 (2020) This plan defines the WHS buffer zone and important sightlines and views within, to and from Kew Gardens. It also discusses the importance of vistas and visual envelopes extending outside the WHS buffer zone to the site’s OUV.

8.197 The Management Plan says the OUV of the Kew WHS comprises26:

 a rich and diverse historic cultural landscape providing a palimpsest of landscape design;  an iconic architectural legacy;  globally important preserved and living plant collections;  a horticultural heritage of keynote species and collections; and  key contributions to developments in plant science and plant taxonomy.

8.198 This Plan states27 that the setting of Kew WHS makes a “…direct and important contribution to its significance as an evolved designed landscape representing key periods in garden history and royal history” and adds that “…this contribution has and remains under threat due to existing tall buildings and other development proposals”.

8.199 Thames Landscape Strategy (Hampton to Kew) – The Thames Landscape Strategy (“TLS”) has guidance aiming to conserve and enhance the Thames riverside landscape. The strategic role of such strategies is referred to in LP policy SI 14. The Hampton to Kew section of the Strategy recognises the verdant, rural views along this stretch of the Thames and the historic links between the landscape of Kew Gardens WHS and Syon House. Its objectives correspond with policies protecting the riverside character of the area and its heritage and views.

8.200 GWC Local Plan – The emerging plan is consistent with the above heritage policies. Policy GWC5 says the Council will optimise redevelopment opportunities whilst respecting the historic environment, including heritage assets and their settings. Development is expected to avoid any further harm to the setting, views, significance, OUV and buffer zone of the Kew WHS, and other designated heritage

26 Royal Botanic Gardens, Kew – World Heritage Site Management Plan (3.2 pg 25) 27 Royal Botanic Gardens, Kew – World Heritage Site Management Plan (3.3 pg 26) assets and their settings including listed buildings, Registered Parks and Gardens and conservation areas.

Effects on Heritage Significance

8.201 The Site is not within a conservation area and has no listed buildings. As such, there are no direct impacts on any designated heritage asset. The existing Homebase building on the Site has been given immunity from listing for 5 years and it is considered to be a non-designated heritage asset. The redevelopment of the Site and the loss the Homebase building is considered acceptable as although the building has some architectural interest it is not considered worthy of listing whilst the character of the Site with large areas of surface car parking and inactive building frontages makes a negative contribution to the townscape.

Heritage Approach

8.202 The immediate area around the Site has a number of listed buildings along the Great West Road. In the wider district there are other heritage assets of the highest significance in the form of registered parks and gardens at Syon Park and Osterley, listed buildings such as Osterley House, Syon House and Boston Manor House, and the Kew Gardens WHS, which may have their setting affected by the tall and large buildings of the proposal owing to their setting forming part of their significance and with longer views across the landscape being possible.

8.203 Consideration has been given to the effects of the proposal on the setting of these assets with this including understanding the significance of each heritage asset and what contribution its setting makes to that significance, and then determining to what degree the proposed change to the setting causes harm to the significance of the asset. Cumulative effects with other development have also been considered.

8.204 The ES has a Heritage Statement, which is informed by the views analysis of a Townscape and Visual Impact Assessment, and this has considered the impacts on the settings and significance of heritage assets. The original assessment was supplemented by additional views to ensure it was comprehensive. In respect of the impacts on settings, it is noted that simply being able to see a new building does not make the design poor or its effect on the heritage significance harmful. Further, the architectural quality of buildings is a material consideration when assessing the quality of the design and its impact on the significance of a heritage asset. However, architectural quality does not necessarily negate harm as even high quality buildings may be located inappropriately.

Appraisal

8.205 The applicant’s own assessment concluded that that there is no harm to the significance of heritage assets from the development as it conserves the heritage assets whose setting its affects, stating:

“The scale of the proposed development is clearly greater than the listed buildings in the vicinity, but the special interest of these designated heritage assets does not rely on a specific scale on the site, and their visibility along the A4 remains largely unimpeded. There will be a minimal effect on the setting of heritage assets further afield, such as the Osterley Park Conservation Area, Syon Park, Osterley Park and Boston Manor, and no effect on the Kew World Heritage Site. The proposed scheme will, on balance, preserve the setting of heritage assets and not cause harm to their heritage significance, and will bring significant public benefits.”

8.206 The applicant has noted responses objecting to the development that consider the visibility of the proposed developments results in ‘less than substantial’ harm to various heritage assess, and considers that where less than substantial harm is identified, this is outweighed by the significant public benefits of the proposal.

8.207 Officers have considered the impacts on relevant heritage assets in line with the relevant statutory duties and applicable policies and guidance. This consideration has given account to the applicant’s assessment, as well as responses from Historic England and other interested persons, with this being summarised in the following sections. It is noted that the ES identified other heritage assets in the wider district, including listed buildings and locally listed buildings, where the proposal would clearly not affect their significance owing to there being no change to their setting (due to distance and intervening development), or as they are not as highly significant and are less sensitive to changes in their setting, and so no further comments are made in these instances where this is agreed.

Gillette Factory

8.208 This Grade II listed building (1937) sits at the junction of the Great West Road and Syon Lane to the north of the Site. A building of monumental scale, it is a local landmark and is representative of the industrial history and character of the Golden Mile. Its special architectural and historic interest is best appreciated in views of its principal elevation from in front of the building and along Syon Lane, including the south side of the Great West Road. Its tall clock tower is able to be seen more widely in glimpsed views along the Great West Road and open spaces to the north and south of the Site including Osterley Park and Syon Park. There are also four lamp standards outside the main entrance and a K6 telephone kiosk close to the pedestrian subway that are Grade II listed.

8.209 The Site is located opposite the Gillette building but at an oblique angle. The height and massing of the proposal has been reduced closest to Gillette Corner and along Syon Lane to conserve the angled view of the façade of the Gillette building from the south on Syon Lane. This design and the position of the new buildings would reduce impacts on the setting of the listed buildings, however its setting when seen along Syon Lane (from north and south) and along parts of the Great West Road would be significantly changed by the much larger and taller buildings proposed on the Site. The good quality design of Block A helps to add to the significance of Gillette Corner and viewers would still be drawn to the façade and clock tower of Gillette which would remain landmarks. Some views of parts of the western flank of the Gillette building from Syon Lane would be reduced. Overall the change to the setting would have a minor negative impact on the significance of the listed buildings, with this considered to be a low level of less than substantial harm. The Tesco Site proposal would introduce buildings to the rear of the Gillette building in views down Syon Lane from the south, though these would be set back in the background, allowing for the main façade and tower to remain distinct in the middle ground of the view. Materials for the proposed Tesco Site would need to be carefully considered to minimise harm in this view. Cumulatively the Tesco Site adds to the harm identified from the proposal, with this remaining in the range of low level of less than substantial harm.

National Westminster Bank

8.210 This Grade II listed building(1935) forms a form a group with the Gillette premises and its special interest is from its architectural design and relationship with the Gillette building and commercial development .of the Golden Mile. Its setting is formed by the larger Gillette building and the Great West Road, with little contribution from the Site. Its interest is best appreciated in views of its principal façade from in front of the Site. Effects on its setting are similar to the Gillette building. The new buildings, which are of an appreciably larger size, introduce a more visually dominant building opposite the listed building but not in the best views of it, with this resulting in a minor negative impact on the significance of the listed building, with this considered to be a low level of less than substantial harm. Cumulatively the Tesco Site proposal, which would be set well behind the site, would result in little change to setting, and so this would remain at a low level of less than substantial harm.

Former Coty Factory

8.211 This Grade II listed building (1933) fronts the Great West Road and is located on the other side of the modern car showroom (Skoda) that adjoins the eastern boundary of the Site. It is a remnant of a larger building that has been altered and has some group value with nearby buildings. It also has historic and architectural value from its design, architects, and its role in the development of the Golden Mile. Its setting relates to the Great West Road where it would be seen when passing. The special interest of the building being best appreciated from in front of the property where its symmetry and Art Deco styling is most apparent. The proposed buildings would substantially change the setting of this building when coming from the east, the much taller and bulker blocks on the eastern flank of the Site forming a new backdrop in this view and looming above it, however the Coty building would remain distinct in the townscape and the harm is negligible as the Site does not contribute much its significance through setting, so this would be a very low level of less than substantial harm. The Tesco Site development would not appreciably affect the setting of this building.

Westlink House (Pyrene Factory)

8.212 This Grade II listed building (1928) is around 275 east of the Site and is one of the historic art-deco buildings along the Golden Mile. It is best seen front on or as it is approached from either direction along the Great West Road where its symmetry is appreciated. The Site makes little contribution to the setting of the building given the separating distance. Therefore there would be no impact on its significance. The Tesco Site development would not appreciably affect the setting of this building.

Church of St Francis of Assisi

8.213 Located to the west of Gillette Corner on the southern side of the Great West Road, around 330m from the Site, this is a Grade II listed building (1933-35) of Gothic design. There would be a minor change to the setting of the Church as seen looking down the Great West Road from the west with the new buildings appearing in the background. However the Church would remain the dominant feature and there would be no effect on its significance. The Tesco Site development would not appreciably affect the setting of this building.

Quaker Meeting House, Quaker’s Lane

8.214 A Grade II* listed building (1785) located around 400m to the southwest of the Site. This historic building is set amongst low rise development and playing fields the new buildings would be apparent in the background at distance, but given the separating distance would not significantly affect the setting of the building. Given the significance of this building and that its setting does contribute to the significance, there would be minor harm to its significance, with this considered to be a very low level of harm.

Syon Park and House

8.215 Located around 450 to the south of the Site, Syon Park is Grade I Registered Park and Garden, which also forms part of the Buffer Zone for the Kew Gardens WHS and is designated as part of the Isleworth Riverside Conservation Area. Within the site are a number of highly significant listed buildings including the Grade I listed Syon House (by Robert Adam) and the Lion Gate and lodges, as well as other Grade II buildings. This site has an area of around 80 hectares and is bounded to the north- west by London Road with residential and industrial developments form the boundary to the north. The River Thames provides the eastern boundary, with Kew Gardens on the opposite bank and Park Road the western boundary.

8.216 Areas of its landscaped grounds represent one of the most important examples of Lancelot ‘Capability’ Brown’s work because of their contribution to the ‘Arcadian Thames’ landscape and because his design legacy on the parkland and its rural character is still recognisably intact, particularly in the area between Syon House and London Road.

8.217 The applicant’s assessment found no harm from the development. The applicant acknowledged the pastoral element of the landscape has significance in its own right but says that its significance relies less on specific views unlike other elements of Syon Park which are more ordered and geometrical. Historic England concluded to the contrary and found that some of the most important views of the building and the rural setting of the park would be further compromised by the proposal, and noted the setting of Syon is not pristine, which increases its vulnerability. They found the impacts would cause a further moderate degree of less than substantial harm to the registered park. They also found the setting of the Grade I listed building Syon House would also be impacted indirectly, and therefore the level of harm is lower. Further harm would be incurred through the cumulative impact of the Tesco Osterley scheme which is also under consideration. They consider that this harm does not have clear and convincing justification, contrary paragraph 196 of the NPPF.

8.218 Officers conclude that in respect of Syon House itself and the Gatehouse, the effects of the proposal on their setting is limited and that the effect on their overall significance, which in the case of the House is derived from a large part from its interior and historic fabric, and in respect of the Gatehouses are best seen as a group with the House and approach from the Lion Gate (to the north). Glimpses of the upper parts of the buildings amongst trees would be seen in the some views, more so in winter. Partial glimpses of the buildings to the side of Syon House would be apparent in a significant view (non-designated), from the southeast, across the Thames from parts of the towpath outside Kew Gardens WHS. The position of this view corresponds to an historic painting of Syon House by Canaletto (from 1749). Existing riverside vegetation and mature trees in the grounds of Syon Park helps screen most of the proposals with this effect being greater when trees are in leaf. The view would not be greatly changed with or without vegetation, the limited visibility of the proposed building at considerable distance not significantly affecting prominence of the listed building in the middle ground of the view and its relationship to the river and rural like setting. The most important riverside view, which is interrelated to the WHS, is not materially affected.

8.219 Overall there would be a very low magnitude of change to the setting of these assets but given the high significance of the listed buildings, the change would be harmful to their significance, with the cumulative impact of the Tesco Site proposal not having a materially greater effect and so this will comprise a low to mid-low level of less than substantial harm individually and cumulatively with other development.

8.220 There would be greater impacts on the historic parkland landscape to the west of the House, on parts of what is now the main approach road from Park Road where the upper parts of the proposed buildings would be visible above the existing background treeline, with this being more apparent in winter. These are distant kinetic views, with the Site around 1km to 1.2 km from this area across the historic farmland and open rural landscape. The majority of the proposal would sit below the tree line within the background of this view. Cumulatively there are already some harmful impacts on significance from buildings within the setting of Syon Park, with these mostly at the eastern end, though in winter built development is visible along the northern edge of the park within and above the treeline. Visible modern intrusions include the Gillette tower. The introduction of new built forms within the setting of this highly significant heritage asset would be detrimental to the appreciation of its heritage significance. The magnitude of change would be low- moderate with this considered to be moderate harm low end, less than substantial harm. The Tesco Site proposal increases this harmful impact and cumulatively increases the harm to moderate, less than substantial harm. The applicant proposes a contribution of £20,000 to be used for possible strategic tree planting and/ or heritage signage/ heritage trail, which are actions encouraged by policy GWC5 of the GWC Local Plan. Refined massing will help to reduce harm as would design details being final for both the proposed schemes, but ultimately they would still be harmful additions.

Osterley Park and House

8.221 A Grade II* register park and garden, with extensive grounds which contains a number of Grade I listed buildings including Osterley House, as well as a range of Grade II and II* listed buildings set around the park. Osterley House (also by Robert Adam) is located centrally within a large area of farmland and design landscaping. It is located around 2km from the Site. Like Syon House, it is of high heritage significance mostly from its interior and historic fabric. The historic park has designed landscapes and pleasure grounds associated with the house. The park also forms the main focus of the Osterley Park Conservation Area, with the conservation area extending to include adjoining residential streets with good quality buildings. The Conservation Area’s primary special architectural and historic interest derives from Osterley House, its landscaped grounds and rural setting.

8.222 The proposal would not appear in any principal designed views in the landscaped grounds and would not be visible at all from Osterley House itself, with intervening trees and other development blocking views. Small glimpses of the buildings would be possible from a footpath within the park to the west of the House, at around 1.6km from the Site. There would be a very low level of change to the setting of the registered park. The character and appearance of the conservation area itself would not be appreciably changed. Overall this would result in negligible harm to the significance of the park, and this equates to the low end of less than substantial harm. The Tesco Site development would be more apparent in this view, which would increase the degree of change and the level of harm, but cumulatively this would remain at the low end of less than substantial harm.

Boston Manor

8.223 Boston Manor House, a Jacobean house that is sited amongst parkland, is a Grade I listed building. It also has various ancillary buildings that are Grade II listed. The building is around 1km to the northwest of the Site with the conservation area being around 500m away. The house and park and located with the Grand Union Canal and Boston Manor Conservation Area. The assessment shows that existing mature trees effectively screen views of both the proposals for the Site and Tesco Site and that there would be no harm to the significance of heritage assets.

Kew Gardens

8.224 The Royal Botanic Gardens, Kew, is a WHS, which is also designated as a Grade I registered park and garden, and a conservation area, is known internationally for its significant botanic collections and work, but also for the landscape and architectural design of the gardens and numerous high grade listed buildings, and it is of the highest heritage significance. The WHS is located south and southeast of the Site, around 1.4km away, across the Thames. Adjoining areas around the WHS are designated as a buffer zone with this WHS buffer zone including Syon Park. Together, Syon Park and Kew Gardens create a continuous parkland landscape character across the River Thames. More widely the tree-lined riverbank and neighbouring parks and gardens between Kew and Hampton Court form part of a landscape referred to as the ‘Arcadian Thames’. This stretch of the river has an idyllic rural character influenced by historic royal associations, grand houses and gardens set amongst water meadows and woodland. The proposed development is not located within the WHS buffer zone but owing to its tall buildings, it has the potential to affect the setting of the WHS beyond the buffer zone, and so indirectly it could affect the significance of the various heritage assets at Kew.

Syon Vista 8.225 The WHS buffer zone contains the focus of one of the most important vistas of the WHS, a view across the Thames towards Syon House and its associated landscape. Located at the end of the long ‘Syon Vista’, an open lawn area that is separated from the Thames path by a Ha-Ha provides a designed open view of the Thames and the ‘Capability’ Brown landscape and historic Syon House beyond. This is a key space in terms of maintaining and understanding the visual and historic connections between the WHS, Syon Park and the Thames.

8.226 Apart from the Syon Vista, the WHS is largely separated from the Thames by trees and shrubs along the western boundary alongside the river towpath, and on the whole the WHS is largely an internally-orientated landscape. The WHS Management Plan recognises that this vegetation performs a valuable screening function as well as a windbreak against prevailing winds funnelling down the Thames and that and preserving the integrity of this setting from external intrusions plays a fundamental role in supporting its OUV. The visibility of a number of existing external developments has already had a negative impact on the setting of the WHS.

8.227 Therefore the outwards views from the open lawn across to Syon Park are essential to appreciating the designed landscape. The setting of this vista is integral to the significance of the WHS and its OUV and so it is very sensitive to change. The further intrusion of urban development would be harmful to the setting of the WHS and its OUV. It is also important it consider any existing harm when determining the impact of proposed development, with any additional harm to be understood as being cumulative with existing harm. In terms of the attributes of the OUV that may be affected, in this location the proposal has the potential to affect its “rich and diverse historic cultural landscape providing a palimpsest of landscape design”.

8.228 Historic England and others have concluded that the development would harm the OUV through the introduction of large urban development that would disrupt the distinctive sense of an Arcadian landscape. This contributes significantly to the ability to appreciate the design intentions of the landscape. The proposed development would distract and effectively end the rural illusion, undermining the character of the historic landscape gardens (Kew and Syon). They consider the overall impact on OUV would moderate/ large which equates to a moderate degree of less than substantial harm. They also highlight the Inspector’s decision for the Chiswick Curve inquiry said the presence of trees should not be relied upon to justify an impact, and so they do not accept the justification that the existing screening provides adequate mitigation and note that no consideration has been given to its potential removal.

8.229 Officers have reviewed the verified images and visited the WHS to consider the impacts from the development on the setting of the Syon Vista. The Syon Vista terminates in an open lawn that focusses on an axial view towards Syon House, the latter being orientated with its eastern elevation directly facing the aspect from the WHS. Either side of the vista there are trees and shrubs that help frame the view. The proposed buildings are effectively screened by vegetation in the foreground along the river bank but also mature trees further inside Syon Park. The seating and lawn areas that are arranged to provide extended views across to the rural landscape of Syon Park are where this key view is best appreciated and it is not considered there would be a perceivable change to the setting of the view.

8.230 There is no visibility of the proposal along the Syon Vista itself due to existing trees along its edges. Very minor glimpses of the proposed buildings are possible further into the wooded area between trees to the periphery of the Syon Lawn area in an area adjacent to the ‘Woodland Walk’ in winter including near to the Isleworth Ferry Gate (also a Grade II listed building). However this area is generally heavily planted, and the main public pathway moves away from the Thames to the south of the main open view, with the trees mostly enclosing the WHS from the Thames. The changes to the setting of the WHS from within this wooded area would be very minor to negligible, owing to the views being filtered through small gaps in vegetation and also being a considerable distance (around 1.4km) from the Site. The impact would be similar to that of other tall buildings visible in Isleworth and the Great West Road which barely register in outward views owing to the thick vegetation on both sides of the Thames.

8.231 Although it is agreed the presence of trees and other vegetation does not necessarily justify development, both the WHS Management Plan and Syon Park’s masterplan note the role of screening vegetation and tree planting. Large scale removal of trees and shrubs within Syon Park that would expose the proposal would also reveal other urban development including the Syon Park Hotel and other tall buildings on the Great West Road and so this is considered extremely unlikely. Replanting where trees were lost would also be expected to maintain the current landscape.

8.232 As such there would be a very low magnitude of change to the setting of the WHS, inclusive of the Syon Vista and adjoining wooded area beside the Thames, and so the impact on the OUV will be negligible, which given the high significance of the WHS would equate to a small or very low level of substantial harm to the WHS, the Registered Park and the conservation area. There is no visibility of the Tesco Site development so there would be no additional cumulative harm with that development.

Isleworth Drawbridge and Ferry Gate

8.233 South of the Syon Vista the boundary of the gardens changes character with the open and outwards views towards Syon House from the lawn area and Ha-Ha at the end of the Syon Vista ending as the boundary becomes fenced and lined with woodland. Around 50m south of the Vista is the Isleworth Ferry Gate, a Grade II listed building. This gate once provided an entrance to the gardens but is no longer used. The gate is significant as it provides reference to the gardens relationship to the Thames and the Arcadian landscape beyond. As a listed building it is significant in its own right but it also contributes to the conservation area and the OUV of the WHS. In respect of the latter the proposal could affect the OUV through impacts on the WHS’s rich and landscape design and architectural legacy.

8.234 In winter the proposal would be party visible in the distance behind the gate in views from within the gardens. In summer trees and shrubs would screen the proposal. The change to the view is very low. There would also be some views of the proposal towards Syon Park from the towpath outside the gate where the existing 1930s tower already is partly visible in the landscape. This position does not provide a good view of Syon House owing to trees in the foreground on the opposite bank and this is not part of the Syon Vista or part of the WHS. Pedestrians in this view have views up and down the river where boundary planting to Kew WHS limits views into the gardens. Users of the path would be aware of modern development which is readily apparent in Brentford downstream. The best views of Syon House from the tow path in front of the gardens aligns with the Syon Vista where the riverside vegetation has been kept low whilst vegetation on the opposite bank and in Syon Park provide a thick screen that results in there being minimal visibility of the proposal. The effect on the setting of the listed building and WHS is very low. This would equate to low- medium less than substantial harm. Cumulatively other development would add very limited additional harm. Other views mentioned in objections including from around the Queen’s Cottage towards the Site would be screened by existing vegetation.

Archaeology 8.235 LP policy HC1 says development proposals should identify assets of archaeological significance and use this information to avoid harm or minimise it through design and appropriate mitigation. HLP policy CC4 says regard with be given to the significance of Archaeological Priority Areas.

8.236 The Site is not in an archaeological priority area and has low potential for significant finds given its location and history of use. Historic England has confirmed that the proposal is unlikely to have a significant effect on heritage assets of archaeological interest and that no further action or conditions are necessary.

Conclusion

8.237 The proposed development would result in some harmful impacts on the significance of a number of highly sensitive heritage assets through effects on setting, but in each case the harm is well below what would be considered ‘substantial harm’ having regards to paragraph 195 of the NPPF.

8.238 In summary the effects on the setting of the various listed buildings in the vicinity of the Site would be at the low end of less than substantial harm. Impacts on Osterley Park are limited, with no effect on the significance of its Listed Buildings, and a low level of harm to the Registered Park and Garden. The impact on Syon Park is greater, with this equating to a low level of less than substantial harm for the proposal by itself and moderate harm cumulatively with the Tesco Site proposal. The impacts on Kew Gardens are very low, but the harm identified to the setting would harm its OUV, the Registered Park and the conservation area at a level of low- medium less than substantial harm. Overall the development would cause a moderate level of less than substantial harm to heritage, with the cumulative impact being a little more but still in the moderate range and not close to substantial harm.

8.239 Importantly, less than substantial harm is not to be treated as a less than substantial objection to the grant of planning permission, and any harm to a listed building or its setting gives rise to a strong presumption against the grant of planning permission. Paragraph 193 of the NPPF is clear that great weight should be given to the asset’s conservation (and the more important the asset, the greater the weight should be).

Mitigation

8.240 The building design has incorporated measures to minimise the harm to heritage assets through the consideration of the context around the Site in finalising the massing and building heights, and architectural detail and materials, which have sought to reduce the overall bulk of the buildings and help them to maintain key views towards the Gillette building in particular. The applicant has agreed to make a contribution of £20,000 to be used for potential tree planting or heritage information relating to Syon Park. This would make small contribution to mitigation of the harm.

Balancing Exercise

8.241 In accordance with paragraph 196 of the NPPF, where a development will lead to less that substantial harm to the significance of a designated heritage asset, as is the case in each instance in this case, this harm should be weighed against the public benefits of the proposal. The exercise to weigh the harm to heritage assets against the public benefits of the proposal is carried out in the planning balance section below.

8.242 Given the harm to designated heritage assets that has been found, there is some conflict with Development Plan policies relating to conservation of heritage, namely elements of HLP CC4 at (d) and (i) and LP policies D9, HC1 and HC2. However this does not mean that all these policies as whole are conflicted – in respect of HLP CC4, (l) reflects the NPPF balancing exercise described above. As set out in HLP CC4 (l) and paragraph 196 of the NPPF it is necessary to weigh this harm against the public benefits of the proposals (see balancing section further below) and where the public benefits outweigh harm then overall this policy would be met. Additionally, even where there is conflict with individual policies, that does not mean that the Development Plan, including the LP, taken as a whole is conflicted.

F. Housing Quality

Quality Standards

8.243 The NPPF seeks to secure high quality design and a good standard of amenity for all existing and future occupants of buildings. The government seeks to ensure delivery of a wide choice of high quality homes of different sizes and tenures, and that land must be used efficiently with the density of development to be optimised. It has published ‘Technical Housing Standards – Nationally Described Space Standards’ that set out minimum standards and these are referenced and supported by policies of the LP and HLP.

8.244 LP policy D6 has recommendations to secure the highest quality internally and externally for new housing, and to ensure that as densities increase, quality of housing is maintained. There must be adequately-sized rooms with comfortable and functional layouts which are fit for purpose and without differentiating between tenures. There are minimum quantitative standards for private internal space, private outdoor space and floor to ceiling heights that apply to all tenures and types of self- contained housing

8.245 In addition to minimum standards, policy D6 also states that qualitative aspects of a development are important to ensure successful sustainable housing. Single aspect units should normally be avoided and only provided where they would constitute a more appropriate design solution in terms of optimising the capacity of a sites, especially where high density is promoted including Opportunity Areas, whilst ensuring good design.

8.246 The design should provide sufficient daylight and sunlight to new and surrounding housing that is appropriate for its context, whilst avoiding overheating, minimising overshadowing and maximising the usability of outside amenity space. Other environmental conditions like air and noise quality must also be considered .The on- going sustainability in terms of servicing, maintenance and management should also be demonstrated.

8.247 The Mayor’s Housing SPG also has minimum standards that set a baseline for quality and design that new homes should aim to meet including for particular needs for older people, children, amenity space and wheelchair housing as well as in relation to the liveability and operation of the site, and interaction with surrounding development.

8.248 HLP policies CC2, SC4 and SC5 are consistent with these requirements and seek to ensure that new housing provides the highest quality of internal and external space to meet the demands of everyday life for the occupants, including adequate space for people including amenity space and wheelchair housing, and that units receive good daylight and sunlight and that there is adequate separation between habitable room windows to ensure satisfactory privacy.

Unit Size and Layout

8.249 All proposed homes would meet the minimum unit and room size standards of the LP and HLP policy SC5 and satisfy the Nationally Prescribed Space Standards and recommendations of the Housing SPG. The floor plans show space for circulation, provision of furniture and storage are all acceptable.

Privacy and Outlook

8.250 LP policy D3 requires development to optimise use of land whilst providing appropriate outlook, privacy and amenity. The Housing SPG recommends minimum distances of between 18-21m between habitable rooms, with these distances being useful yardsticks for privacy. However it also says that adhering rigidly to these measures can limit the variety of urban space and housing types, and sometimes unnecessarily restrict density.

8.251 In respect of outlook, LP policy D4 says development should maximise the provision of dual aspect units and normally avoid those with only a single aspect and where single aspect units are proposed it needs to be demonstrated they have adequate conditions. The Housing SPG notes that good single aspect one and two bedroom homes are possible where limited numbers of rooms are required, the frontages are generous, the plan is shallow, the orientation or outlook is favourable, and there is mitigation of the potential overheating. It also says development should minimise single aspect dwellings that are north facing, exposed to noise levels above which significant adverse effects on health and quality of life occur, or have three or more bedrooms.

8.252 HLP policy CC2 expects development to provide adequate outlook, minimise overbearingness and overshadowing, through the careful layout, design and orientation of buildings and spaces. HLP policy SC5 says balconies should be designed as an integral part of the building’s elevation to maximise a beneficial aspect, and avoid positions that result in unacceptable overlooking and loss of privacy to other units

8.253 The layout of buildings above the podium is arranged to maximise separating distances, and though the yardstick of 18m is generally exceeded it has not been achieved in all locations. The spaces between Blocks A and B1 (13m-17.8m), A and E (17m to 36m), E and the infill block between B1 and B2 (17.2m-18.5m), and B2 and D (12.5m-13.3m) are lower than the yardstick. Where the spacing of buildings is reduced, dual aspect units have been maximised for better outlook, habitable room windows are staggered or offset to avoid undue overlooking, and projecting balconies avoided as they further reduce separation distances. Additionally, it is noted the rooms affected by lower separating distances are mostly bedrooms which are less sensitive compared to living rooms. Raised planters with boundary hedge planting will provide separation and privacy from the communal garden areas. Individual private terraces and balconies will be separated with privacy screens as required. The image below shows the separating distances between blocks.

Figure 7: Building separation and aspect (green = dual, yellow = semi-dual, blue = single)

8.254 In respect of aspect the proposed layout, of the total units proposed, 38% are dual aspect. There are no directly north-facing single aspect units but there are a significant number that face north-west, with these located in Blocks A, E, D and C, other single aspect units face east, west or south. There are 41 northwest -facing single aspect units. Those units with only a northerly aspect would experience lower daylight than units with a more favourable aspect. The overall elevation design has sought to balance a range of environmental factors including daylight, outlook, noise and overheating risk. The various passive design and ventilation measures proposed to address possible overheating are acceptable noting there are also air and noise pollution constraints at the Site.

8.255 To ensure good living conditions within these units the design has sought to incorporate design features that improve daylight and sunlight levels and outlook to many of the single aspect units. Some units include minor recesses in plan and maximum glazing to increase daylight and sunlight levels, while the floorplan and room depths are also aim to ensure living spaces enjoy good levels of daylight and views to the landscaped amenity area. The unit design below shows the following features:

 A secondary facade that accommodates a full height window/door to provide access to a balcony to provide cross ventilation  Allowing oblique views from the living space  A minimum of one aspect to the living room orientated west, south or east

Figure 8: ‘Semi- Dual’ Aspect Unit Design

8.256 The D&A describes the units with these measures as ‘semi-dual aspect’. Approximately 27% of the total units fall into this category with their design helping to mitigate the effect on quality from being only single aspect.

8.257 In considering the overall quality of this element of the scheme it is acknowledged that the proposal is a high-density development that optimises the use of the Site. Importantly, the nature of the mixed-use proposal does result in design constraints that affect the overall layout and massing, with the requirements for the relocated supermarket (floor area and servicing) reducing the ability to provide additional residential cores to ground level and these needing to be limited to the Site’s perimeter. The building massing has also been arranged to minimise height along Syon Lane to respect nearby heritage assets and amenity of existing neighbours, resulting in buildings that are orientated perpendicular to the Site boundary and so face north-south. These design considerations are accepted as justification for the relatively high number of single aspect units in this instance and the measures to optimise the internal quality with additional mitigation are recognised.

8.258 The GLA Stage I response also noted these particular design and layout constraints and how they have affected the opportunity for more dual aspect units, and they have accepted the underlying constraining factors in this instance are, on balance, acceptable in this case.

Internal Daylight and Sunlight

8.259 Sufficient daylight and sunlight is required for good quality accommodation. Policy SC4 of the HLP refers to the guidance on daylight and sunlight standards from the Building Research Establishment (“BRE”) report ‘Site Layout Planning for Daylight and Sunlight’ (2011). The BRE guidance highlights that its advice is not mandatory and although it gives numerical guidelines, these should be interpreted flexibly since natural lighting is only one of many factors in site layout design. Paragraph 123 of the NPPF also says that when considering applications for housing, authorities should take a flexible approach in applying policies or guidance relating to daylight and sunlight, where they would otherwise inhibit making efficient use of a site (as long as the resulting scheme would provide acceptable living standards).

8.260 The primary method of assessment of new build accommodation is through calculating the average daylight factor (“ADF”) which is a measure of the daylight level within a room. The BRE guidance specifies the target levels of 2% for kitchens, 1.5% for living rooms and 1% for bedrooms. Where a room has more than one use, for example a living room, kitchen and dining room (“LKD”), the higher of the ADF values for the uses is used. However with an open LKD area, the living space is the majority of the room and officers consider it is reasonable to consider whether the room without the kitchen area would achieve the suggested standard for a living room (1.5% ADF).

8.261 The daylight and sunlight report submitted demonstrates that the daylighting of the interior of the units is generally satisfactory, with 91% of habitable rooms achieving the ADF target. The non-compliant rooms are primarily located at podium level (i.e., on the lower levels) and/or are generally located in the corners of the buildings or under balconies. However if a 1.5% target for combined living/ kitchen/ dining rooms is applied, then 95%% of habitable rooms meet the target and for those units where rooms do not fully meet the target there are generally other rooms in the unit that do.

8.262 The BRE includes a further daylight measure with a test of the distribution of daylight in a room using the No Sky Line (“NSL”) test. This test shows areas of the room that can receive direct skylight. The guidelines recommend good levels of daylight distribution would be achieved if 80% of the room can receive skylight. The daylight and sunlight report comments that for urban areas, this is often not achieved and that a target of 50% is more appropriate.

8.263 The NSL test results show that approximately 86% of all rooms enjoy a good level of daylight distribution in accordance with the BRE guidelines and a further 10% (96% of total rooms) of the rooms have a daylight distribution that is considered to be a good level for an urban area (more than 50% of the rooms area). This is considered a very good level of compliance for a proposed scheme of this size and density.

8.265 Sunlight to proposed units is below the recommended level for many units as many units do not have a southerly aspect which is inevitable in a higher density and urban context. The BRE guidance includes a measure for sunlight through calculating the Annual Probable Sunlight Hours (“APSH”) at the centre of each window on the outside face of the window wall. The BRE measure target is for the window to receive over 25% of the APSH, including at least 5% of APSH in the winter months between 21st September and 21st March.

8.266 The sunlight report shows approximately 46% of rooms meet the BRE guidelines. The report also goes on to consider alternative measure for good/adequate levels of sunlight for an urban area, with this indicating an APSH of 20% or 15%, and the number of rooms that will receive some sunlight during the year. These measures show that approximately 51% of all rooms will receive a good level of sunlight for an urban area, with an APSH above 20%, and approximately 60% of all rooms will receive an APSH above 15%. In addition, 95% of all rooms would receive some sunlight during the year.

8.267 Given the nature of the proposal and urban character of the area, some flexibility from the the BRE targets is acceptable. This approach accords with the Housing SPG that says guidelines for daylight and sunlight should be applied sensitively to higher density development, especially in opportunity areas, town centres, large sites and accessible locations, where BRE advice suggests considering the use of alternative targets. This should take into account local circumstances; the need to optimise housing capacity; and scope for the character and form of an area to change over time28. As such, although the levels of daylight and sunlight to the interior of the proposed units is mixed, with some units receiving lower levels, overall the majority of rooms will receive good daylight and sunlight and an acceptable level of compliance has been achieved.

Accessible Housing

8.268 New housing must be accessible for all people with this included external areas, access and units themselves. The Mayor’s Housing SPG highlights29 that the ‘arrival’ at a building, the design of shared circulation and lift access, car parking and areas

28 Mayor’s Housing SPG (1.3.45) 29 Mayor’s Housing SPG (2.3.2) for cycle storage are important factors in making housing safe and secure, welcoming and accessible for all.

8.269 LP policies D5 and D7 requires inclusive design and development to provide suitable housing and genuine choice for London’s diverse population, including disabled people, older people and families with young children. It says residential development must ensure that:

1) At least 10 per cent of dwellings to meet Building Regulation requirement M4(3) ‘wheelchair user dwellings’; and

2) All other dwellings to meet Building Regulation requirement M4(2) ‘accessible and adaptable dwellings’.

8.270 HLP policy CC2 has similar requirements and says that developments should be designed to be fully accessible to people with disabilities or impaired mobility.

8.271 The development includes a managed communal entrance from Syon Lane, which will serve the whole development, with this providing convenient access to all blocks via the podium. Secondary entrances around the perimeter of the Site provide alternative direct access to each housing block. All levels of the building and the podium communal amenity and children’s play space areas, and residents’ space within Block C are accessible, with lifts (and stairs) to each floor. In terms of inclusive design the proposal includes:

 10% dwellings to be M4(3) compliant (48 dwellings);  90% dwellings to be M4(2) compliant;  Balcony design in compliance with Part M and GLA standards;  Wheelchair accessible units located in upper floors to be served by two lifts;  Public realm to be wheelchair friendly, including the residential courtyards;  Public realm to be suitable for those visually impaired;  Accessible housing to be delivered across all tenures and in a range of different sizes;  Accessible parking bays to be provided as close as possible to ADM4(3) compliant dwellings; and  Enlarged cycle parking to be provided within the cycle stores of each block and accessible to use by residents regardless of unit size, tenure or accessibility level.

8.272 The Mayor’s Housing SPG recommends each building core should generally be accessible to no more than eight units on each floor. This is generally achieved in the blocks, apart from lower levels (including Block, A, B, D and E) where some floors give access to between 9 and 11 units though as noted this is reduced at upper levels. Given this arrangement and the overall high density of the proposal, secure access and good maintenance of communal entrances and spaces throughout the scheme is important. Access, security and maintenance of the residential development, including accepting deliveries and arranging refuse collection would be undertaken by an on-site management and concierge service.

8.273 The design satisfies the requirements relating to accessibility and inclusive housing with all features and areas of the buildings being accessible and a minimum of 10% of the homes being wheelchair accessible (48 proposed), with this including a total of 16 affordable wheelchair units proposed. The proposal for on-site residents’ services, which are necessary given the scale and density of the housing, would provide for good security and management for residents.

Air and Noise Pollution

8.274 The Site is exposed to air and noise pollution from adjacent main roads, with aircraft and the nearby railway being additional sources of noise.

Air Pollution

8.275 LP policy SI1 says development proposals should not create unacceptable risk of high levels of exposure to poor air quality, and should use design solutions to prevent or minimise increased exposure to existing air pollution.

8.276 HLP policy EQ4 encourages air quality-sensitive development to be located in the most appropriate places, and requires mitigation measures to minimise adverse impacts on end users through planning conditions.

8.277 The proposed development has sought to address the air quality issues that affect the locality through incorporating a building setback from Great West Road, and locating units above ground level (generally above the podium level). The ES shows air quality is expected to meet all relevant air quality objectives at the location of the proposed residential units and amenity uses on the site and therefore mitigation is not required. The Council has assessed the Air Quality Assessment and notes the findings, however as the monitoring results vary over time, a condition has been recommended to secure ongoing, robust monitoring of air quality levels for set periods prior to, during and after completion, with filtered mechanical ventilation required to be installed if relevant targets are exceed (annual average measurement over 36ug/m3).

Noise Pollution

8.278 LP policy D14 and HLP policy EQ5 look to avoid harmful impacts on health and quality of life by ensuring noise-sensitive development is protected against existing and proposed sources of noise through careful design, layout and use of materials, adequate insulation of the building envelope (including both internal/external walls and ceilings), as well as protecting external amenity areas. Noise sensitive uses such as housing must be located outside of the 69 dB LAeq 16hrs noise contour of Heathrow Airport.

8.279 The Site is located outside the relevant Heathrow noise contour, and the building setbacks provide some mitigation for the high noise levels experienced. A satisfactory internal noise environment would be achieved through incorporating mitigating features into the building façade such as high acoustic performance windows and a mechanical ventilation system which does not rely on openable windows, though occupiers would have the choice of opening windows.

8.280 Noise levels to balconies and the landscaped podium would generally exceed the desired levels where elevations are exposed to traffic noise though some mitigation is provided by the inset balcony designs. Noise levels in the proposed external amenity areas are predicted to be typically between 55 and 60 dB LAeq,16hour. This is above the upper guideline value BS 8233:2014 of 55dBLAeq, though this guidance does recognises that it is not always practicable to achieve these levels in urban areas and adjacent to transport networks and therefore it states that development should be designed to achieve the lowest practicable levels in these external amenity areas but should not be prohibited. In this instance it is accepted that it will not be possible to achieve the outdoor amenity criteria recommended in all private balconies with consideration given to the Site constraints and that residents would have access to good quality communal space within the whole scheme, which provides an alternative for resident, with this area including quieter spaces, with details of the latter to be confirmed by a condition.

Amenity Space

8.281 HLP policy SC5 requires housing development to provide suitable areas of quality external amenity with flats requiring both private and communal space. HLP policy CC3 relating to tall buildings requires designers to incorporate innovative approaches to provide high quality, usable, private and communal amenity space where residential uses are proposed.

Private Amenity Space

8.282 LP policy D6 and HLP policy SC5 says flats should have a minimum of 5 sqm of privacy amenity space for 1 to 2 occupants and an additional 1 sqm for each additional occupant. Balconies should be designed as an integral part of the building’s elevation to maximise a beneficial aspect, and avoid positions that result in unacceptable overlooking and loss of privacy to other homes.

8.283 Apart from two homes in Block A, all the new homes have a private balcony or terrace that will meet the minimum standard for outdoor private amenity space. The two exceptions are at the lowest level of Block A and face Gillette Corner where additional internal amenity space is proposed to ensure it is more usable, with this extra floor area enlarging the unit by more than outdoor space standard. Noise levels from the adjacent roads mean some balconies facing those roads would exceed the recommend maximum noise exposure levels, especially where fronting the Great West Road. There is also some aircraft and railway noise. Some mitigation is inherent to these facades with inset balconies proposed, but high noise levels would remain. In this instance it is accepted that it will not be possible to achieve the outdoor amenity criteria recommended in all private balconies with consideration given to the Site constraints and the provision of good quality communal space within the whole scheme, which provides an alternative for residents.

Communal Amenity and Children’s Play Space

8.284 LP policy S4 says that residential developments should incorporate good quality, accessible play provision for all ages that is not segregated by tenure, of at least 10 sqm per child. Play space provision should normally be provided on-site; however, off-site provision may be acceptable where it can be demonstrated that this addresses the needs of the development and can be provided within an accessible and safe walking distance, and in these circumstances contributions to off-site provision may be secured by section 106 agreement.

8.285 The Mayor’s Shaping Neighbourhoods: Play and Informal Recreation SPG gives guidance for children’s’ play space. Where off-site provision is appropriate, the play space for older children must be within reasonable and safe walking distance of the new housing with it recommended that the maximum walking distance for 5 to 11 year olds is 400m, and for the 12+children 800m.

8.286 HLP policy SC5 also requires development to demonstrate through clear design rationale how benchmark external space standards have been considered, with these given as 25 sqm per flat with up to 3 habitable rooms and 30 sqm for flats with 4 habitable rooms, less a reduction for the area of private space provided for each unit.

8.287 The design has utilised the podium for communal landscaped amenity space for residents of the proposed housing. The spacing and orientation of the blocks above the podium have been designed to maximise sunlight within the gardens and to help mitigate potential issues of noise and pollution arising from the adjacent roads. The landscape plan is show in the image below.

Figure 9: Landscape Plan

8.288 The landscaped design is high quality and would provide good areas of green space for recreation, socialising and play, with all open space accessible to everyone within the housing. Different zones accommodate tree and shrub planting, lawn areas and mounds, seating and informal play spaces with pathways providing routes across the podium between buildings including the main residents’ entrance and facilities in Block C. The proposed lighting, furniture, materials and varied planting including trees, as well as hedging for privacy all create would create attractive spaces for residents and a pleasing outlook from units that overlook the podium.

8.289 The overall area of communal amenity space on the podium is 4,928 sqm. This is below the benchmark standard of 9,244 sqm for the development. The proposed communal amenity space area is acceptable as the design provides good quality landscaping and open spaces whilst optimising development on the Site, with the design considerations that have accommodated a large supermarket and podium, and the urban context of the Opportunity Area acknowledged.

8.290 As noted, the building layout has sought to optimise the environmental quality of the amenity space. Buildings are arranged to minimise disturbance from traffic on nearby roads whilst the sunlight report shows that the podium space receives good levels of sunlight, with 94% experiencing two hours of sunlight on the Spring equinox (21 March). The sunlight levels exceed the BRE guidance which suggests that at least 50% of amenity spaces should receive at least 2 hours of sunlight on 21 March. Wind and noise conditions to parts of the amenity area would require mitigation, and areas of the outdoor space exceed recommended noise levels. These issues are discussed further below, though in respect of noise, there would be quieter and more tranquil spaces would be available to the rear of the podium, and in respect of wind, mitigation can be secured by condition.

8.291 In terms of children’s play space there are a mix spaces suitable for different age groups comprising natural play features, land form and open lawns, all appropriately overlooked by housing. The development is estimated to accommodate approximately 237 children, for which 2,370 sqm of play space is required. The applicant’s play strategy proposes meeting the requirements for children aged 0-5 and 5-12 years on site, with the needs for children aged 12+ off site. A total of 1,896 sqm of play area for the children aged up to 12 is provided across the podium amenity space meeting the standard for these children. A condition requiring the further details of the play provision in the landscaping scheme to be agreed is recommended to ensure genuine play spaces are secured.

8.292 The off-site provision required is 474 sqm. The applicant has identified a number of open spaces that are located within 800m of the site including at Hawthorn Hatch (Hawthorn Road), Syon Park and Brent Lea Recreation Ground. The open space at Hawthorn Hatch is a 450m walk from the Site without crossing any main roads, whilst the other sites are accessible by crossing London Road. A financial contribution of £25,000 towards enhancement of Hawthorn Road Park has been secured to improve play space for children aged 12+ as this need is not met on the Site. With this contribution the play space provision for the development would be acceptable.

Housing Mix

8.293 LP policy H10 and HLP policy S5 require new development to generally consist of a range of unit sizes. Policy H10 and sets out a number of factors which should be considered when determining the appropriate housing mix on a particular scheme. These factors include:

 Housing need and demand;  The requirement to deliver mixed and inclusive neighbourhoods;  The need to deliver a range of unit types at different price points;  The mix of uses in the scheme;  The range of tenures in the scheme;  The nature and location of the site, with a higher proportion of one and two bed units generally more appropriate in locations which are closer to a town centre or station or with higher public transport access and connectivity;  The aim to optimise housing potential on sites;  The ability of new development to reduce pressure on conversion, subdivision and amalgamation of existing stock; and  The need for additional family housing and the role of one and two bed units in freeing up existing family housing.

8.294 The proposed housing mix has a good range of unit sizes by tenure and size. The proposed mix is acceptable given the sustainable location which is in an Opportunity Area and in close proximity to the Syon Lane station and bus routes, where development should be optimised. There would be 65 larger family sized homes (3-4 bedroom), equating to 14% of the total units, and 27% of the affordable homes are 3 and 4-bedroom sized units. The overall proposed housing mix by tenure is as follows:

Affordable Market Total 1 bed 62 136 198 42% 2 bed 57 153 210 44% 3 bed 40 20 60 13% 4 bed 5 - 5 1% 164 309 473 100% Table 7: Proposed Housing Mix

8.295 The mix proposed would ensure a good mix of homes are provided and would contribute to the objective of delivering mixed and inclusive communities to create a better overall environment. The higher proportion of one and two bedroom homes is accepted in this instance as the development aims to optimise new housing provision and the location is next to the great West Road and Syon Lane station and so a higher overall density is appropriate. The scheme delivers 65 3 and 4-bedroom homes.

Density

8.296 The LP looks to achieve the best use of land by following a design-led approach that optimises the capacity of sites. This determines the most appropriate form of development, responding to a site’s context, public transport, walking and cycling accessibility and capacity for growth and existing and planned supporting infrastructure capacity. HLP policy SC4 seeks to ensure the scale and density of new housing development balances the need to make efficient use of land and achieves high quality design and accessibility, whilst responding to and reflecting local context and character and protecting existing residents’ amenity.

8.297 The GLA has calculated30 the proposed density at 439 units per hectare which is a very high density. The urban design assessment above considered the characteristics of the Site, including its location in an Opportunity Area near to public transport. It is also noted the GWC Plan and Site Allocations look to allocate the Site for high density development. Given these considerations a good quality high density development is supported and the design quality and minimum housing standards of the scheme have been satisfactorily scrutinised. The GLA’s Stage I response confirmed adequate design scrutiny had been undertaken and concluded that the is suitable for a well-designed high density scheme, taking into account the close proximity to Syon Lane station and the mixed use nature of the proposed scheme, which enables residential uses to be raised significantly above the of the A4 Great West Road. They do however note that a high density residential scheme will, however depend on the potential to significantly improve the existing walking, cycling and public transport connections and address highways severance issues in what is a relatively car dominated junction on the A4 Great West Road.

Conclusion

8.298 Although a very high density is proposed, the scheme is capable of providing a good standard of housing that would generally meet objectives of the baseline standards for quality as recommended in the Housing SPG, with these being consistent with the Council’s own guidelines. Where there are variances from guidance the design includes satisfactory mitigation and whilst certain constraints arising from the nature of the development, in particular the re-provision of the large supermarket at the Site, and the facilitation of the wider regeneration opportunity for the related Tesco Site are also acknowledged. Further details of wheelchair housing, mitigation of noise air quality and wind conditions, landscaping, children’s play space and management of the communal spaces within the development are necessary to secure the quality of the accommodation. Subject to conditions securing these further details to ensure necessary mitigation internal living conditions would be acceptable. It is acknowledged that outdoor spaces would experience higher than desired noise levels, however these reflect the Site’s position in an urban environment near to major roads and a railway (with aircraft noise). On balance the outdoor spaces are acceptable in this instance as the proposed housing is otherwise of good quality and the main landscaped podium would provide attractive alternative outdoor space.

8.299 Therefore, overall the proposed housing is satisfactory with all the proposed homes meeting the minimum size standards, having good access and security, sufficient privacy, an appropriate mix, and in general a good outlook and access to daylight, as well as good provision of communal amenity space and children’s play within an enhanced public realm at an accessible location, with this according with LP policies

30 Density based on 77% of the site area, reflecting the ratio of non-residential uses within the scheme. D4, D5, D6, D7 and H10, HLP policies CC2, SC4, SC4, EQ4 and EQ5, and the Mayor’s Housing and Play and Informal Recreation SPGs.

G. Transport

Introduction

8.300 Two planning applications have been submitted for the Site (Homebase) and the Tesco Site. A detailed application has been submitted for a new Tesco store and 473 homes on the Site. This would require a new traffic signal junction onto Syon Lane in a similar location to the existing Homebase access providing access to the retail store car park and residential car park. Some additional residential car parking and loading facilities would be accessed from Syon Gate Way which is a private road accessed from Syon Lane.

8.301 An outline planning application has been submitted for the Tesco Site proposing up to 1,667 new dwellings on this site, together with between 3,000 and 5,000 sqm of commercial floorspace. The access to Syon Lane would be redesigned to remove the roundabout and the existing bus stands and stops will be relocated from their current location but retained on the site.

8.302 The transport impacts of both developments are inter-linked and much of the information and assessment is relevant to both sites and has been assessed in tandem, an approach required by TfL. This report therefore considers the transport impacts of both developments, providing individual comments where appropriate.

Policy Background

8.303 Paragraph 102 of the NPPF says that promoting sustainable transport should be considered from the earliest stages of plan-making and development proposals, so that: a) the potential impacts of development on transport networks can be addressed; b) opportunities from existing or proposed transport infrastructure, and changing transport technology and usage, are realised – for example in relation to the scale, location or density of development that can be accommodated; c) opportunities to promote walking, cycling and public transport use are identified and pursued; d) the environmental impacts of traffic and transport infrastructure can be identified, assessed and taken into account – including appropriate opportunities for avoiding and mitigating any adverse effects, and for net environmental gains; and e) patterns of movement, streets, parking and other transport considerations are integral to the design of schemes, and contribute to making high quality places.

8.304 Paragraphs 108-111 go on to state:

108. In assessing sites that may be allocated for development in plans, or specific applications for development, it should be ensured that:

a) appropriate opportunities to promote sustainable transport modes can be – or have been – taken up, given the type of development and its location; b) safe and suitable access to the site can be achieved for all users; and c) any significant impacts from the development on the transport network (in terms of capacity and congestion), or on highway safety, can be cost effectively mitigated to an acceptable degree.

109. Development should only be prevented or refused on highways grounds if there would be an unacceptable impact on highway safety, or the residual cumulative impacts on the road network would be severe.

110. Within this context, applications for development should:

a) give priority first to pedestrian and cycle movements, both within the scheme and with neighbouring areas; and second – so far as possible – to facilitating access to high quality public transport, with layouts that maximise the catchment area for bus or other public transport services, and appropriate facilities that encourage public transport use; b) address the needs of people with disabilities and reduced mobility in relation to all modes of transport; c) create places that are safe, secure and attractive – which minimise the scope for conflicts between pedestrians, cyclists and vehicles, avoid unnecessary street clutter, and respond to local character and design standards; d) allow for the efficient delivery of goods, and access by service and emergency vehicles; and e) be designed to enable charging of plug-in and other ultra-low emission vehicles in safe, accessible and convenient locations.

111. All developments that will generate significant amounts of movement should be required to provide a travel plan, and the application should be supported by a transport statement or transport assessment so that the likely impacts of the proposal can be assessed.

8.305 Of particular note is paragraph 109 and the impacts of the development on road safety and traffic flow are set out later in this section of the report.

London Plan

8.306 Chapter 10 of the LP sets out the transport policies that apply to new development. LP policy T1 states that development proposals should facilitate the delivery of the Mayor’s strategic target of 80 per cent of all trips in London to be made by foot, cycle or public transport by 2041. All development should make the most effective use of land, reflecting its connectivity and accessibility by existing and future public transport, walking and cycling routes, and ensure that any impacts on London’s transport networks and supporting infrastructure are mitigated.

8.307 LP policy T2 states that development proposals should deliver patterns of land use that facilitate residents making shorter, regular trips by walking or cycling. In Opportunity Areas new and improved walking, cycling and public transport networks should be planned at an early stage, with delivery phased appropriately to support mode shift towards active travel and public transport. Development proposals should demonstrate how they will deliver improvements that reduce the dominance of vehicles on London’s streets, be permeable by foot and cycle and connect to local walking and cycling networks as well as public transport

8.308 LP policy T3 states that development proposals should support capacity, connectivity and other improvements to the bus network and ensure it can operate efficiently to, from and within developments, giving priority to buses and supporting infrastructure as needed.

8.309 LP policy T4 states that development proposals should reflect and be integrated with current and planned transport access, capacity and connectivity. Transport Assessments should be submitted with development proposals to ensure that impacts on the capacity of the transport network (including impacts on pedestrians and the cycle network), are fully assessed. Travel Plans, Parking Design and Management Plans, Construction Logistics Plans and Delivery and Servicing Plans will be required having regard to Transport for London guidance. Where appropriate, mitigation, either through direct provision of public transport, walking and cycling facilities and highways improvements or through financial contributions, will be required to address adverse transport impacts that are identified. Where the ability to absorb increased travel demand through active travel modes has been exhausted, existing public transport capacity is insufficient to allow for the travel generated by proposed developments, and no firm plans and funding exist for an increase in capacity to cater for the increased demand, planning permission will be contingent on the provision of necessary public transport and active travel infrastructure. The cumulative impacts of development on public transport and the road network capacity including walking and cycling, as well as associated effects on public health, should be taken into account and mitigated. Development proposals should not increase road danger.

8.310 LP policy T5 states that development proposals should help remove barriers to cycling and create a healthy environment in which people choose to cycle. This will be achieved through supporting the delivery of a London-wide network of cycle routes, with new routes and improved infrastructure and securing the provision of appropriate levels of cycle parking which should be fit for purpose, secure and well- located.

8.311 LP policy T6 states that car parking should be restricted in line with levels of existing and future public transport accessibility and connectivity. Developments should be designed to provide the minimum necessary parking (‘car-lite’). An absence of local on-street parking controls should not be a barrier to new development, and boroughs should look to implement these controls wherever necessary to allow existing residents to maintain safe and efficient use of their streets. The maximum car parking standards set out in policy T6.

8.312 LP policy T7 states that development proposals should facilitate safe, clean, and efficient deliveries and servicing. Provision of adequate space for servicing, storage and deliveries should be made off-street, with on-street loading bays only used where this is not possible. Delivery and Servicing Plans will be required and should be developed in a way which reflects the scale and complexities of developments. Appropriate facilities are required to facilitate efficient online retailing and to enable micro-consolidation, with management arrangements set out in Delivery and Servicing Plans.

8.313 LP policy T9 (states that in consultation with the Mayor, boroughs should identify a package of strategically-important transport infrastructure, as well as improvements to public realm, along with other funding streams including CIL to deliver them. Planning obligations (Section 106 agreements), including financial contributions, will be sought to mitigate impacts from development, which may be cumulative

Hounslow Local Plan

8.314 HLP Policy EC1 promotes improvements to strategic transport connections. In particular its states:

We will work with partners to secure investments to existing and future strategic transport connections, including London Underground, rail, bus, and cycle and highway services. These enhancements will maximise the borough’s regeneration potential and support growth whilst also helping achieve our environmental objectives.

We will achieve this by

a) Supporting planned upgrades to the Piccadilly and District lines; b) Promoting the development of rail connectivity between Southall (including Crossrail) and Brentford; c) Promoting the development of the proposed rail connection from Hounslow station to Willesden Junction via Old Oak Common, with services calling at Isleworth, Syon Lane and Brentford; d) Promoting improved bus services, particularly serving growth areas and the Golden Mile; e) Supporting improved access to the Piccadilly line, including introduction of a permanent stop at Turnham Green and improved links between the line and the Golden Mile growth corridor; f) Supporting improved access to Heathrow Airport through new southern rail access; g) Supporting improvements to rail services on the South West Trains network, and in particular Sunday services; h) Promoting new cycle networks, including a ‘cycling spine’ along the A315, with connecting Greenways and Quietways, and the provision of cycle parking at transport interchanges; i) Promoting improvements to the highway network to best facilitate sustainable modes, including targeted junction improvements, targeted travel demand management (including trip banking where appropriate), signal optimisation and bridge works; and j) Supporting initiatives to reduce the impact of road infrastructure in the built environment, including tunnelling proposals relating to the M4/A4. We will expect development proposals to k) Ensure that access to existing and future strategic transport connections is considered where appropriate, including through appropriate design; and l) Contribute to improvements to the strategic transport network where appropriate, consistent with the Local Implementation Plan and Infrastructure Delivery Plan, and the findings of Transport Assessments

8.315 This policy refers to a number of planned and proposed infrastructure improvements that are relevant for the development site including the Piccadilly Line upgrade; improving bus services; improving orbital and Overground rail connections; improvements to Piccadilly Line access; and cycle superhighway.

8.316 HLP policy EC2 states the Council will develop a sustainable transport network. This will be achieved by promoting low car developments where appropriate, promoting the active management of car parking and travel demand, and using the London Plan maximum standards for car parking. Development will need to be located appropriately in relation to public transport accessibility and capacity, road capacity and active travel networks. Development will be expected to demonstrate that the impacts meet the tests set out in the NPPF and that appropriate mitigation measures are provided.

GWC Local Plan

8.317 An Examination in Public to consider the GWC Local Plan will take place in 2021. This will include an assessment of the transport improvements that are proposed and which have been developed in a transport study (jointly commissioned by the Council and TfL). The transport study forms one of the background documents for the Examination in Public.

8.318 The transport study looked at how public transport capacity, network and accessibility could be improved to support the level of development proposed in the Opportunity Area. Existing accessibility and travel patterns were examined, and the potential number of trips related to future development predicted and modelled by consultants. As a result of this work two packages, one bus-based package and one rail-based package, were assessed in terms of their ability to improve public transport accessibility and provide the additional capacity necessary to be able to deliver the proposed level of development. The conclusion reached was that both packages would improve the public transport accessibility of the Opportunity Area but the rail-based package would provide better improvements and therefore this package was favoured.

8.319 Both packages included the same basic package of measures including:

 Improved walking and cycling connections to stations.  Healthy Streets improvements across the area and within development sites to unlock new quieter parallel routes to the A4.  Local bus network enhancements providing additional network capacity, better local public transport accessibility levels and improved connectivity to stations and local centres.  The delivery of future rail and LUL network enhancements planned for the Piccadilly line, District line and SW rail line.  Station capacity, accessibility and other customer experience enhancements at Gunnersbury Station, Kew Bridge and Syon Lane.  Improvements to key junctions on the road network including at Syon Lane, Boston Manor Road, Windmill Road, Ealing Rd and Chiswick Roundabout.  Demand management measures including car-free and car-lite developments with low car parking standard, employee travel plans for existing and new businesses with ambitious mode share targets

8.320 These measures would need to be delivered in the short to medium term to mitigate the impacts of earlier developments in the Opportunity Area. The transport study identifies that the rail based measures such as the proposed new passenger rail link from Brentford (Golden Mile) to Southall (Elizabeth Line) and the West London Orbital, and which would support LP Policy EC1 in particular, are medium to long terms measures and are likely to require a range of funding solutions rather than s106 funding.

8.321 The Council has been working with TfL on developing a more detailed set of transport interventions, based on those set out in the transport study, that include bus service improvements, public realm and active travel improvements, and junction improvements that could be delivered in the short to medium term and would support the delivery of, and mitigate the impacts of, early developments. The proposed s106 obligations would deliver a number of these measures.

8.322 The Council is currently working with Network Rail and the Department for Transport on developing the rail link to Southall and the proposed opening date for this link is currently 2027. This scheme is currently going through Networks Rail’s design process. The council is also working with TfL and the West London Alliance on the proposed West London Orbital. This is at an earlier stage of development but is proposed to open by around 2030 and would link Syon Lane station to north London. If these timeframes are maintained then opening of these links would be around the forecast time of occupation of the Tesco Site.

8.323 The Council has proposed a Workplace Parking Levy (“WPL”) to help fund the rail link. The business case for this proposal is currently being developed but is only one funding option that is available.

Public Transport Accessibility

8.324 The Site currently has a PTAL score of 2-3 on a scale where 1 is the lowest and 6 is the highest. The majority of the Site is in band 2 other than the south western part of the Site which is band 3 due to its proximity to Syon Lane station and bus stops on London Road to the south.

Opportunity Area Transport Study

8.325 As stated above, the transport study for the GWC Local Plan proposes a package of measures designed to improve the current PTAL within the Opportunity Area. Both the bus-based and rail-based packages would lead to an improvement in the PTAL and this supports the LP policy.

8.326 The transport improvements will be delivered over a number of years to allow development to match the expected growth within the Opportunity Area. It is envisaged that the first of these improvements would be delivered in advance of the proposed occupation of the Homebase Site, with further improvements coming online prior to occupation of the Tesco Site which would follow.

8.327 The table below is an extract from the transport study that sets out the predicted improvements in PTAL as a result of the implementation of each transport package.

Table 8: Predicted PTAL Improvement

Trip Generation

Existing trip generation

8.328 In order to provide a base for an assessment of trip generation the applicant undertook a range of surveys at the Tesco and Homebase stores. The scope of the traffic surveys were agreed with TfL to ensure the traffic modelling accurately reflects existing traffic generation for the existing sites.

Homebase site

8.329 Existing traffic generation from the Homebase is set out in Table 8.1 (pg 72) of the Transport Assessment. These surveys were undertaken in July 2019. Saturday was measured as having the most trips (around 947 visits) although the peak hour was Sunday lunchtime. Traffic generation was generally similar for other days of the week, between 700-800 visits. The surveys also indicated relatively low traffic generation at typical network peak times which reflects the nature of the use. Homebase currently attracts fewer than 50 vehicle movements on average in the weekday AM peak hour and approximately 120 in the weekday PM peak. Maximum parking accumulation was measured at 93 cars on a Tuesday afternoon.

Tesco site

8.330 The traffic surveys indicated that Saturday was the busiest day with around 5,650 visits but other than Sunday there were over 5,000 visits per day. Sunday was around 3,600 visits. Details are set out in Table 8.2 of the TA (p73). Tesco currently attracts around 395 vehicle movements in the weekday AM peak (8-9AM) and around 750 in the weekday PM peak (5-6PM). The applicant split these down further to measure single trips to the petrol filling station (“PFS”) because the PFS is not proposed to be replaced. These are set out in Table 8.3 (p74) of the TA. The applicant also undertook parking surveys to understand use of the car park. The results are set out in 8.3.4 of the Transport Assessment but in summary are:

 Saturday 29th June 2019 – 420 cars at 10:30  Thursday 4th July 2019 – 414 cars at 11:30  Saturday 6th July 2019 – 415 cars at 14:30  Tuesday 9th July 2019 – 499 cars at 11:15

8.331 Multi modal surveys were undertaken between 7AM-7PM on a Sunday and a Tuesday to count other modes of travel to the store as set out in table 8.4 of the TA (p74) and reproduced here.

Table 9:Multi-modal Trip Attraction – Existing Tesco

8.332 The applicant also undertook video surveys of existing traffic movements at key locations around the sites. These surveys were video surveys to allow validation of the traffic model, i.e. to ensure the model replicates actual conditions as best as possible. The surveys allowed origins and destinations of traffic and therefore trip distribution to be noted.

Covid-19 Impacts

8.333 It should be noted that the traffic surveys were undertaken prior to the Covid-19 pandemic so reflect traffic flow at that time. Although is it noted that traffic levels have increased since the first lockdown in 2020 there is still uncertainty about the longer-term impacts. There is also uncertainty about how long it will take public transport usage to recover to 2019 levels but current predictions are that this will not be until the mid-2020s at the earliest. There has been a considerable move towards homeworking during the pandemic in line with the government’s message to stay at home. This has led to businesses reassessing how they operate, including the need for people to travel to work.

8.334 Therefore, the trip generation and traffic modelling reflects pre-pandemic information. However, it is considered that the surveys are robust for the purposes of assessing the traffic impacts of the proposed development. In cases where there is more than a 12 month gap between initial surveys and the detailed traffic modelling for traffic signals and agreeing the detailed junction design TfL will require updated surveys and modelling to be undertaken. In this case this work will also pick any post- pandemic changes.

Predicted traffic generation

8.335 The method for predicting trip generation has been agreed with the Council and TfL and for the residential units for both sites was undertaken using the standard approach of interrogating the TRICS database for similar developments and applying local mode share based on Census travel to work data. In both cases, account was taken of the proposed level of parking. The applicant used the TRICS database to assess trip generation per-parking space based on similar developments but TfL required a higher trip rate to be used to ensure the assessment was robust.

8.336 Delivery trips have also been included within the assessment. There has been a significant increase in home deliveries over the last few years and therefore predicting how this will develop in the future is difficult.

8.337 Traffic generation for the new Tesco retail store was based on existing traffic generation at the current Tesco store. Trips to the petrol filling station were removed and traffic was re-distributed to the new site based on the traffic surveys. Residential trip generation was then added. Weekday peak hour traffic generation was predicted to be 430 movements (arrivals and departures) in the weekday AM peak and 706 in the weekday PM peak. This is set out in tables 10.2 and 10.5 of the TA (p99 & 103).

Traffic Impact

8.338 The applicant agreed a scope for the traffic modelling with TfL and a full VISSIM microsimulation model has been developed. Traffic generation for both developments have been included within the traffic model. The results of the traffic surveys were fed into a microsimulation traffic model that includes the following junctions:

 A4 Great West Road - B454 Syon Lane  A4 Great West Road – Harlequin Avenue  A4 Great West Road – Wood Lane  Syon Lane by Northumberland Avenue

Figure 10: Traffic Junctions Modelled

8.339 A separate model was used to assess the proposed access to the Tesco Site as this is proposed to be a priority junction and not connected to the traffic signals at Gillette Corner.

8.340 All of the traffic modelling has been agreed with and validated by TfL. It should be noted that this is a detailed process and a conservative approach has been taken. Full consideration has been taken of all roads in the vicinity of the site, not just the A4. The modelling has also been independently reviewed for LBH and details of this assessment are provided below.

8.341 The Tesco traffic was split and PFS traffic reduced, but not fully removed. This was redistributed from the northern arm of the junction to the south. The traffic model includes background traffic growth up to the year of completion, in this case 2035 which is the date provided by the applicant. The predicted traffic generation was then added and distributed as agreed by TfL.

8.342 Government and local policy is to push for a “green recovery” from the Covid-19 pandemic with increased use of home working, public transport and active travel. These factors are likely to affect traffic levels in the future but the actual impact will only be known once the additional traffic surveys have been undertaken and the position of businesses with regard to homeworking. However, it is considered by TfL that the assessment is robust.

Traffic modelling options testing

8.343 The traffic model for Gillette Corner covers the area shown on the map above. This therefore assesses impacts not only on the A4 but also Syon Lane, Northumberland Avenue, Harlequin Avenue, Grant Way and the new Homebase site access. The applicant was initially asked to model three options for the junction layout:

 Option 1 proposed an additional right turn lane from the A4 into Syon Lane (south) but no improvements for pedestrians or cyclists.  Option 2 included the above and also proposed a new pedestrian/cycle crossing on the eastern arm of the junction, over the A4, to complement the subway.  Option 3 proposed the above but included new controlled pedestrian/cycle crossings on all arms of the junction.

8.344 The options were tested by TfL who looked at the impact on journey times for general traffic and buses.

8.345 Option 1 was not considered to be acceptable to the Council or TfL as it provided no active travel improvements at the junction. This is considered to be a key requirement given the low levels of parking and the need to promote mode share change towards public transport and active travel.

8.346 Option 2 was considered to be acceptable to TfL in terms of traffic and journey time impacts but does not propose a full set of active travel improvements, with crossings on each arm of the junction that are considered by the Council and TfL to be required to improve active travel improvement at this junction. A new crossing over the A4 on the eastern side of the junction would provide an alternative to the existing subway, which is welcomed. This would provide a new link in particular for residents of the Tesco site to Syon Lane station and residents of the Homebase site to link to Osterley Park. However, it is considered that improved links across Syon Lane are also necessary in order to provide access on the southern side to the Tesco store on pedestrian and cycle desire lines, and across the northern side to link the new residential development on the Tesco site to Osterley station.

8.347 Option 3 was considered to provide the required active travel improvements but this would require changes to the A4 approaches to the junction. In order to run separate pedestrian stages across Syon Lane the nearside lanes of the A4 would have to be changed to become left-turn only. This then impacts on journey times for through traffic, including buses, and the changes could not be accepted by TfL. The impacts were felt particularly on the eastbound approach from the A4 as a result of providing a new crossing on the northern arm of the junction.

8.348 In order to test other potential options for improving the pedestrian crossings at Gillette Corner the applicant was asked to model an additional scenario in detail, Option 4.

8.349 Option 4 was similar to Option 2 but added a new pedestrian crossing on the southern arm of the junction to test whether the potential traffic impact could be accommodated. The existing pedestrian crossing on Syon Lane, close to the existing Homebase access, is proposed to be retained by the applicant but moved 15m south. However, this would not be on a desire line for people visiting the proposed Tesco store. In order to try to deliver meaningful mode change a crossing on the southern side of Gillette Corner, leading people to the entrance to the Tesco store, needs to be provided if possible. This would also benefit people passing the Site along the A4 who wished to visit the Tesco store as well as local residents. Therefore, the applicant was asked to model a further option (Option 4) that included a crossing on the southern arm of the junction.

8.350 However, when this scenario was tested it was clear that the impact in the weekday afternoon and Saturday peak hours would be unacceptable again and TfL again considered that the impact on journey times would be too great. The main impact again being the need to accommodate a dedicated left-turn lane into Syon Lane which was having too great an impact at peak times.

8.351 Therefore, TfL have stated that Option 2 is their preferred option. However, this is only to be considered an interim solution. A pedestrian/cycle crossing on the southern arm of the junction is still considered to be a key mitigation measure and therefore it has been agreed with TfL and the applicant that Option 4 would be reviewed prior to opening of the retail store. TfL would require the traffic surveys and modelling to be updated as part of the process for agreeing the detail of the highway works.

8.352 During this process TfL will review all details of how the signals should be set up and optimised. Following this review, if a crossing can be accommodated then it will be included in the junction design. TfL are supportive of this crossing but need to be assured that the traffic impact would be acceptable. If the provision of the southern crossing is not considered to be acceptable at that time, a further review and detailed traffic modelling would be undertaken after the occupation of the Homebase Site, in advance of construction of the Tesco Site, allowing actual traffic impact from the Homebase Site to be reviewed.

8.353 As part of this second review, the Council and TfL would also require the applicant to test a further scenario, Option 5, which would add a pedestrian/cycle crossing on the northern arm of the junction, and Option 6 which would add a left slip turn for traffic turning left into Syon Lane (southbound). The applicant has undertaken a high-level review of Option 5, testing the principle of whether a new staggered pedestrian/cycle crossing over the northern arm of the junction could be provided. This high-level review indicated that a staggered crossing could be physically provided. However, the current traffic impact would preclude this at the current time. This crossing would complete a key cycle link from the residential development on the Tesco Site towards Osterley station and other destinations to the west. Option 6 would require removal of the subway and changes to the pedestrian crossing over the A4 but could improve traffic flow making it more likely that the active travel improvements could be accommodated.

8.354 Given that the provision of a crossing on the northern arm of the junction provides particular mitigation for residents of the Tesco Site, although it does bring other benefits, it is recommended that this is reviewed prior to commencement of development of the Tesco Site along with Option 6. New traffic surveys and modelling will be undertaken that take into account the actual impact of the Homebase Site and any post-pandemic changes to traffic. It would provide the most up to date and accurate assessment to be made. These reviews will be secured in the s106 Agreement.

Review of the traffic modelling

8.355 In order to verify the process and results of the traffic modelling the Council employed transport consultants to review the information submitted by the applicant. This review included a focus on Syon Lane and Northumberland Avenue and concludes that there are benefits and disbenefits to each option, and that these vary dependent on the time being tested. The general conclusions are set out below.

Analysis of traffic modelling

8.356 Each peak period was observed to demonstrate a set of road network behaviour and issues specific to it. These characteristics are pronounced to varying degrees in each design option, but in general the southbound and eastbound movements are of concern and at higher risk of congestion in the AM peak. In contrast, PM and Saturday peak periods are characterised by larger vehicle volumes and therefore higher queue levels westbound and northbound.

AM Peak

8.357 In the AM peak the overall network was observed to be very busy for all scenarios, including the future year base (“FYB”). A major factor in this is the rolling queue along southbound Syon Lane which impacts the operation of Gillette Corner for the middle part of the peak hour. The scale of its impact varies between scenarios, for example by how quickly southbound traffic is released from Gillette Corner, resulting in the queue extending back to Gillette Corner sooner or later in the peak hour. Once the rolling queue reaches Gillette Corner, it starts to impact all its approaches, in particular southbound Syon Lane, delaying traffic discharge and extending the total length of southbound queuing further along the road.

8.358 In the FYB scenario, Syon Lane congestion north of Gillette Corner is attributable to the additional factor of poor lane use by traffic. Last-minute lane changes by simulated vehicles slow down vehicle progress at the northern Gillette Corner approach and have a knock-on effect on the overall link flow, resulting in queuing upstream. As a consequence, the AM FYB displays high levels of congestion for Syon Lane, with some of the subsequent development options – where the above poor lane behaviour is less pronounced – appearing to operate better as a result. It is likely that tweaks to connectors and decision distances within the FYB model would resolve this issue. For example, network-wide results indicate, in a comparison between FYB and option 1:

 Less delay per vehicle in option 1 (129 seconds v’s 187 seconds)  Higher average speeds in option 1 (13mph v’s 10mph)  Greater network peak hour throughput in option 1 (6,692 vehicles v’s 6,420 vehicles)

8.359 Because of high levels of congestion amongst the option models as well as poor operation of the FYB during the AM peak, it is not possible to identify a clear preferred ‘with scheme’ arrangement. However, given the high levels of congestion observed for options 3 and 4, it is likely that the extensive pedestrian facilities that these options propose would result in disproportionate levels of delay for road traffic, including buses. Option 2 therefore presents a favourable arrangement whereby pedestrian facilities are improved but with no disproportionate impact on overall junction operation.

PM Peak

8.360 The PM peak model operates with a lower level of demand overall and as a result is better able to withstand increased demand resulting from the proposed development as well as additional pedestrian green time for proposed crossing facilities at the Gillette Corner junction. Although some queuing has been observed in all scenarios, particularly along northbound Syon Lane and westbound A4, this is predominantly intermittent and largely clears during the next green phase. It was observed that the northbound Syon Lane queue is often attributable to traffic having to stop at the Gate Centre pelican crossing, followed by the southern site access junction, followed again shortly by the Gillette Corner stop line. The phasing of those signals does not seem aligned for this movement and result in slow progress along the link, allowing the northbound queue to build. It is possible that this queueing could be reduced with a more ‘streamlined’ green wave for Syon Lane.

8.361 Options 3 and 4 demonstrate high levels of congestion on the A4, mostly for the westbound approach, but also affecting the eastbound movement. The results of the three variants for option 4 suggest that the queue length is sensitive to changes such as minor alterations to signal timings. Nevertheless, the queue lengths for those options indicate that Gillette Corner does operate much less efficiently with the additional pedestrian facilities in place. Both options 1 and 2 operate with much less queuing. As option 2 appears to be able to accommodate the additional pedestrian facility without undue impact on the wider junction, it would appear to also be the preferred option for the PM peak.

Saturday Peak

8.362 The operation of the Saturday network is comparable to the PM one in the context of dominant movements and overall network behaviour. For most of the scenarios tested, generally the network operates well, with no excess congestion or persistent queuing. Syon Lane queue northbound is intermittent and largely dependent on the signal sequencing and green time along the link. Although the queue does build at times, it regularly clears and is not thought to be severe.

8.363 Options 3 and 4 demonstrate a much greater scale of impact on the A4 than was observed in the PM peak. A key issue for the Saturday peak is the large proportion of westbound A4 traffic wishing to turn left into Syon Lane. This demand is not adequately accommodated by the proposed signal arrangement of either option, resulting in long delays for this movement, impacting westbound A4 traffic overall. As a result, option 2 would be a preferable alternative for the Saturday peak, allowing improvements to be made for pedestrian movements at a scale which can still accommodate vehicular demand at Gillette Corner.

Harlequin Avenue

8.364 Harlequin Avenue serves as a primary access for businesses. Any queuing on Harlequin Avenue was only observed in the PM peak, presumably as this is the end of the working day for staff. The Harlequin Avenue queue length varies depending on the level of congestion on westbound A4, as this determines the level of discharge from the Harlequin Avenue approach. In addition, the signal arrangements at the junction allow for no more than four vehicles to exit at any one time, resulting in extended queuing. This is despite the modelling allowing for the Harlequin Avenue green phase to be activated at every cycle, as advised by the modelling consultant.

Grant Way

8.365 The approach to the Sky campus, off Syon Lane is Grant Way. Again, this link is included in the model for background flows only. The link operation shows to be relatively good for all scenarios, although its traffic discharge rate is closely linked to the level of queuing along southbound Syon Lane. Traffic exiting Grant Way in the AM peak, when Syon Lane congestion is greatest, is relatively low. Therefore, the road is not significantly affected by any of the delay. At other times, some queuing and congestion has been observed along Grant Way, albeit only intermittently and clearing relatively quickly. As a result, no option or development scenario can be identified as having the greatest benefit or disbenefit for this link.

Northumberland Avenue

8.366 As with other side roads in the model, Northumberland Avenue has been modelled with background flows only and does not include any of the proposed development traffic in any of the modelled options. Congestion levels on Northumberland Avenue are low during both PM and Saturday peaks. In the AM peak, a queue builds gradually during the peak hour, extending the full length of the modelled link. A review of the CCTV footage and discussions with the modelling consultant have identified that this is in fact an accurate reflection of the on-street behaviour, albeit the exact length of the queue has not been measured or validated.

8.367 A route alternative exists for traffic wishing to bypass Gillette Corner by travelling via Wood Lane and Northumberland Avenue instead. This is a possible ‘rat-run’, the likelihood of which has not been investigated in the model. It seems unlikely that such behaviour would occur in the AM peak when network-wide queues are greatest, given the queue already observed on the link. During other time periods, the queue observed along Syon Lane and A4 does not appear to be sufficiently extensive to promote rat-running, although such behaviour cannot be fully discounted as a possibility. Wider network operation seems to have little impact on Northumberland Avenue. Therefore, no specific option can be identified as having the greatest benefit or disbenefit for it. However, officers are concerned that people living close to the south and west of the Homebase Site may decide to use this road instead of the A4 to avoid the traffic signals. Therefore, whilst the traffic modelling does not indicate that there would be an increase in journey times on Northumberland Avenue it is considered that this needs to be reviewed post- occupation of the Homebase Site.

Traffic Conclusions

8.368 The traffic modelling indicates that the A4/Syon Lane road network experiences periods of high congestion levels at present, particularly during the morning peak and would struggle to accommodate extensive alterations to the junction including pedestrian crossing facilities on all of its approaches. Development options proposing signalised crossings at three or four arms of the junction demonstrate much longer queues than observed at present and suggest that the impact on the local road network may be significant.

8.369 The greatest impact of signalised pedestrian crossings on Gillette Corner junction approaches, evidenced in options 3 and 4, is observed along the A4. Syon Lane experiences congestion in all scenarios, particularly in the AM peak, whereas the Saturday and PM peak periods operate with less queuing. Although congestion levels are highest in the AM peak across all options, some options demonstrate an improvement in junction operation as compared with the FYB scenario. This is particularly evident for options 1 and 2.

8.370 Option 1 does not provide any improvements to pedestrians and as such is inadequate in its proposals. Option 2 offers an additional surface level crossing facility on the eastern approach of the junction, improving pedestrian permeability while not disproportionately impacting on junction operation. As such it could be viewed as preferable in the sense of minimising the impact of the scheme on the existing road network. However, it does not provide a significant improvement to pedestrian facilities at the junction. Further investigation into the mitigation measures of Option 4 would need to be considered and tested further to ascertain whether additional crossing facilities on the Syon Lane approaches can be considered to be acceptable.

Public Transport Impacts

8.371 LP policy T1 states that all development proposals need to reflect current and future public transport accessibility. Although the area currently has low to moderate public transport accessibility the proposals being developed for the Great West Corridor Opportunity Area will ensure these levels are increased. Therefore, it is correct to consider the nature of the developments against the future predicted level of accessibility. At the same time, however, as set out in the transport study it is also correct to consider what short to medium term mitigation measures will be required to ensure there is adequate capacity available to cater for demand in advance of the delivery of more strategic transport improvements.

Buses

8.372 The two sites are currently served by the following bus routes:

 Route H28 currently terminates at the Tesco Site and runs between there and Tesco at Bulls Bridge via Syon Lane Station, West Middlesex Hospital and Wood Lane. This service has a 20 minute frequency Monday to Saturday, and 30 minutes on a Sunday. Frequencies reduce in the early mornings and evenings.  Route H91 runs along the A4 between Hounslow East and Hammersmith via Osterley Station, Gunnersbury Station and Chiswick. This service has a frequency of 7-11 minutes on a weekday, 9-10 minutes on a Saturday and 14 minutes on a Sunday. Frequencies reduce in early mornings and evenings.

8.373 TfL has consulted on changes to the H28 which would mean it no longer terminates at the Tesco Site but would continue to serve it. Instead, it is proposed that the E1 would be extended from Ealing Broadway and serve the A4 and terminate at the Tesco Site. There is currently no date for these changes to be made but is due to link with opening of the Elizabeth Line.

8.374 It is predicted that there would be 74 bus trips generated in the AM peak and 57 in the PM peak from the Homebase Site. TfL is the transport authority responsible for delivering bus services and were consulted on these planning applications. TfL have undertaken a detailed review of the impacts on bus services of the two proposed developments and have requested a contribution of £1.7M to provide improved bus services. TfL has not currently identified which routes this would go towards but they would review the situation in advance of the occupation of the Homebase Site and allocate as appropriate in accordance with the Opportunity Area transport study. It is proposed to relocate bus stops on the A4 and Syon Lane to accommodate the junction works and this is acceptable in principle subject to detailed design in the s278 agreement.

Underground

8.375 The closest underground stations are Osterley and Boston Manor on the Piccadilly Line. It is predicted that there would be an additional 64 AM peak trips resulting from the Homebase Site and 225 from the Tesco Site. In the PM peak these numbers are predicted to be 50 and 174 respectively. TfL have reviewed the applicant’s assessment of station capacity and line loading capacity at Osterley Station taking into consideration the anticipated demand of consented schemes. However, the assessment still requires further work before TfL can determine if a contribution is required. However, given the Tesco Osterley site generates the greatest demand for underground trips TfL recommend that an updated assessment of station capacity and line loading capacity at Osterley Station is accompanied with the first reserved matters application, and any identified improvements to be delivered prior to first occupation. This is to be secured in the s106 agreement.

8.376 The Piccadilly Line is due to be upgraded by TfL to provide increased capacity. It has recently been announced that final design of the new trains has been agreed and the current estimate is that work to upgrade the line will be completed and the new trains running by 2025. This would coincide with the occupation of the Homebase Site and in advance of occupation of the Tesco Site.

Rail

8.377 The nearest rail station to the sites is Syon Lane which is on the Hounslow Loop line linking Waterloo, Clapham Junction, Barnes, Chiswick, Kew Bridge, Brentford, Syon Lane, Isleworth, and Hounslow with Feltham, Reading and Windsor. The route is operated by Southwestern Railways (“SWR”) and is currently served by 2 trains per hour in each direction under a Covid timetable but this will return to 4 trains per hour. Syon Lane station has recently been provided with step-free access to both platforms. SWR have also confirmed that new trains are due to be operated on this line which will lead to an increase in capacity. These trains will be introduced on their network from this summer and likely to be on the Hounslow Loop within a year.

8.378 Syon Lane station is well used by Sky employees and is known to be particularly busy at peak times due largely to the number of passengers disembarking from a train. Data supplied by SWR indicates that during the morning peak of 0720-0850 between 250-400 people can alight from a train, and that in the evening peak of 1650-1850 between 150-350 people can alight from a train.

8.379 In the AM weekday peak it is predicted that the Homebase Site would generate an additional 69 trips and the Tesco Site 188. In the PM peak these are predicted to be 53 and 188 respectively.

8.380 SWR has been consulted on the planning applications and have confirmed they have no objections and require no contributions. In discussions with SWR it is clear that train use has declined significantly as a result of the Covid-19 pandemic and they are currently running a reduced timetable as a result and it is unclear when this will increase to pre-pandemic levels. It is also unclear how businesses, including Sky, will respond to the pandemic and if similar numbers of passengers will return to Syon Lane station. As a result of this, and when taken with the increased capacity of the new trains SWR do not raise an objection or require a contribution to improved train capacity.

8.381 SWR have also confirmed that there are no plans to increase circulation space on the platforms. This was raised as a concern at the station but investigations have shown that potential improvements would be limited to widening at the country end of the station and are not currently proposed. Therefore, no contribution is required and no objection raised.

Car Parking

8.382 Car parking provision has been assessed against LP parking standards which are a maximum.

8.383 It is proposed that 400 parking spaces will be provided for the retail uses and 99 spaces for the residential use. As submitted the application had proposed 105 parking spaces for the residential use (of which 100 were for residents, 3 were visitor spaces and 2 car club spaces), but this was reduced to allow for improved cycle storage/ access. The original residential parking ratio was 0.21:1, with the minor revision this is now 0.20:1.

8.384 The site is located in an Opportunity Area which has a lower maximum parking standard than for other areas. The applicant proposes 94 parking spaces for at a ratio of 20% (94/473 homes) together with 3 visitor parking spaces and 2 car club parking spaces. This is within the maximum parking standards and no objection is raised in principle. However, in accordance with the Opportunity Area transport study it is expected that the applicant will provide mitigation measures to promote public transport and active travel trips, both physical improvements and a travel plan, as well as providing an appropriate number of car club parking spaces for residents. The number will be decided through an agreement with a car club provider and secured in the s106 agreement.

8.385 It is proposed to provide 26 disabled parking bays which is in accordance with the LP. These spaces will need to be allocated to those who require them and not to specific dwellings. This will be set out in a Residential Car Parking Management Plan (“CPMP”) but also included as a principle in the s106 agreement. It is proposed to provide Electric Vehicle (“EV”) charging points in accordance with LP standards. The CPMP must ensure that these are able to be used by those who need to do so, and not allocated to specific dwellings, i.e. if residents are allocated a specific parking space then it must be possible to change this if required by a resident with an EV.

8.386 The applicant is proposing 400 parking spaces for the retail use which is the number Tesco say they require. It is noted that this is a reduction in the number of spaces on the current site but that car park is not fully utilised, as shown by the parking surveys. However, this is significantly in excess of the LP standard of 1 space per 75 sq. internal floorspace and therefore TfL have raised concerns. Following discussions with the applicant the following measures have been agreed with the applicant:

 The use of the parking spaces will be monitored and if the level of use indicates that not all spaces are required a mechanism to convert these to other uses will be applied. This will be secured in the CPMP but set out in the s106 Agreement.  A charging mechanism will be introduced at peak times to encourage use by people undertaking larger shops and to spread the peak impact. This will also make it more likely that pedestrian crossings can be provided at the time of the reviews by reducing the amount of car borne trips to the store at peak times. This will be based on the following principles:

i. ANPR monitoring of the new Tesco car park occupation and length of stay should be undertaken by Tesco, for the first 12 months of occupation and reported monthly to the council. This will allow the monitoring to capture other seasonal peak times such as Christmas. ii. Subject to agreement with the Council and TfL, the monitoring and reporting can be reduced to quarterly monitoring for the following 12 months, and then 6 monthly until the Tesco Osterley site is fully occupied (and then annually). iii. A minimum stay charge, to be agreed in advance of occupation, will be applied during the peak traffic times, initially PM and Sat peak periods, for stay times less than a set duration, initially set at 60 minutes. The peak periods will be the network peak plus half an hour either side. iv. Other seasonal peak times may require additional management and charges. v. In addition to this, if car park capacity exceeds 95% at any other time, as highlighted by the monitoring, then the minimum stay charge will be applied for that 1-hour period also. vi. The maximum duration of stay should be maintained as originally proposed at 3 hours. vii. The final Car Parking Management Plan (CPMP) will need to include specific measures to discourage travel at the peak times identified by the car park monitoring.

 The car park will not be controlled by barriers to reduce the potential for queuing back onto Syon Lane. Management at peak times to prevent queuing will be agreed prior to occupation of the retail store.  Advanced signage will need to be provided in appropriate locations (suggested adjacent to the car park entrance and on the A4) to advise drivers if there are spaces in the car park in advance of turning onto Syon Lane and to minimise the possibility of queuing.

8.387 These principles will be set out in the s106 agreement but administered in the retail CPMP which will be agreed in detail prior to occupation of the store. The residential and retail elements will require separate CPMPs because the car parks will be managed separately.

On-street parking

8.388 Neither the Homebase Site nor Tesco Site is located within a Controlled Parking Zone (“CPZ”). Therefore, residents would not be eligible to apply for permits within neighbouring CPZs. This will be reinforced in the s106 agreement.

8.389 There are currently on-street parking bays on the western side of Syon Lane opposite the site that serve residents of that road. Some of these will need to be relocated in order to provide the new car park access. The applicant has identified a location for 3 bays that cannot be re-provided on Syon Lane on Northumberland Avenue. These will still be a short distance from the Syon Lane properties and is considered to be acceptable in principle, subject to a Stage 2 Road Safety Audit. The principle will be secured in the s106 agreement and delivered in the s278 Agreement.

8.390 The adjoining Syon Lane Station CPZ operates Monday to Friday from 9am-6pm and Northumberland Estate CPZ from 9-11am. The Marlborough Road CPZ operates Monday to Friday 9.30am-5.30pm. This zone is further from the site but could be affected by parking from residents of the development. The streets to the east (Brentford End) are currently uncontrolled and could also be affected. As such it is recommended that parking surveys are undertaken prior to occupation and post occupation and if there is found to be an increase attributable to the development then consultations should be undertaken. It is not possible to provide accurate costs at this time but the principle should be secured in the s106 agreement.

Cycle Parking

8.391 It is proposed to provide 843 residential cycle parking spaces which is in accordance with the LP (minimum of 828 spaces). These would be provided in a number of internal cycle stores. Each core would be provided cycle parking although in most cases this would not be the full allocation for each block. These stores would be accessed by lift.

8.392 The remainder of the cycle parking would be provided on the southern side of the site, spread over 2 floors. These stored would be accessed by one lift which is not ideal and it is recommended that this element of the design is reconsidered prior to construction. The layout of these cycle stores on the southern side of the site also need to be re-designed to be reduce the number of stands in each store and make them more attractive to users. The applicant advises that the main entrance for residents is on the south eastern corner of the site so these stores would be close to that location.

8.393 A number of stands for non-standard bikes are proposed for the ground floor on the southern side of the site. These will need to be in accordance with LP cycle parking standards. Cycle parking for the retail store is proposed around the site. Some of the locations are not considered to be acceptable as they are not overlooked or convenient for the store. This will need to be reviewed prior to occupation. Some stands will need to be accessible by non-standard bikes in accordance with LP Plan cycle parking standards.

8.394 Full details of the cycle stands, stores and lifts (to be reviewed with the view of increasing the number of lifts on the southern side of the building) for the residential and retail uses will need to be submitted for approval prior to commencement of construction and secured by condition to ensure that the building design can be amended to accommodate these changes if required.

Deliveries and Servicing

8.395 It is proposed to provide a dedicated loading bay for the Tesco store within the site accessed from Syon Gate Way. The capacity of this facility has been modelled in terms of likely use and accessibility by articulated lorries. A total of 36 trips per day are expected based on surveys at the existing store. The majority of these are smaller vehicles.

8.396 There is space for up to 3 lorries to wait inside the facility but it is proposed that all delivery vehicles visiting the Tesco store are pre-booked. It is also proposed that Tesco will actively promote consolidation. This is considered to be acceptable with changes made to improve visibility for and of vehicles entering and exiting the loading area. A Delivery and Servicing Plan (“DSP”) specific to Tesco will be required to ensure that the facility is managed in an efficient way and that there is no impact on streets surrounding the site including Syon Gate Way and Syon Lane.

8.397 Changes are also proposed to Syon Gate Way and its junction with Syon Lane to ensure that the largest delivery vehicles do not obstruct other traffic whilst turning into or out of Syon Gate Way. These details will need to be included within the s278 agreement. Internal loading bays for the residential element of the development have been provided within the residents’ car park, also accessed from Syon Gate Way. A loading bay is also proposed on Syon Gate Way itself.

8.398 Given the nature of the site, and the roads surrounding it, all residential deliveries must be accommodated within the site or on Syon Gate Way. The applicant has submitted a draft DSP for the residential element of the development but pro-active management of deliveries will be essential. A final DSP is secured by a s106 obligation.

8.399 The applicant has estimated that there would be 29 residential deliveries per day. However, the nature of deliveries has changed in recent years with more home shopping occurring and this has been exacerbated by the pandemic. A review of recent surveys at flatted developments suggests that this number could be 38. However, this number could have increased again during the pandemic. For this reason, a more up to date review of potential trip generation will need to be undertaken prior to submission of a DSP for approval. It is acknowledged that if the same company is delivering to a number of properties then this will allow consolidation of deliveries which will reduce the overall number of trips. However, the number of delivery trips will need to be monitored and reviewed, and if necessary additional delivery bays provided on the site or on Syon Gate Way. This is to be part of the ongoing monitoring and review of the DSP that will be required in the finally approved document.

8.400 The applicant has stated that residential deliveries will be managed on site, through a concierge at the main residential lobby at the junction of Syon Lane and Syon Gate Way. Space must be provided for storage of deliveries. This will be essential in order to prevent delivery drivers from parking on either Syon Lane or the A4 close to residential cores and obstructing traffic. Waste and recycling from Tesco would be managed commercially using the Tesco servicing yard. For the housing, a refuse/ recycling store is located at the podium level for each building core. Building management will move full bins on a daily basis and replace them with empty ones. They will be transported via a lift to the lower ground floor where they will be stored. On collection day, bins will be transported to Syon Gate Way for collection. TfL will advise on any required measures that may be required on the A4 but on Syon Lane no waiting restrictions must be in place, and the s278 Agreement should investigate the introduction of red-route restrictions together with CCTV cameras to monitor and enforce this restriction. The public realm improvements that are proposed for Syon Lane can also act as a deterrent to unauthorised stopping on Syon Lane and this is to be a key part of the s278 Agreement.

Active Travel, Road Safety and Public Realm

8.401 The applicant has undertaken an Active Travel Zone Assessment (“ATZ”) for both applications. This has identified the most popular walking and cycling routes that people are likely to use to travel to and from the proposed developments. The assessments have included a comprehensive review of road safety, identifying locations of Personal Injury Collisions (“PICs”). Many of these routes overlap, for both sites, and concentrate on the obvious routes such as Syon Lane and the A4. The ATZs identify locations where improvements could be made to encourage more walking and cycling trips.

8.402 Some of the locations have been picked up within the highway or public realm works around the site and others are in locations where the Council is already working on schemes. This includes works to improve Gillette Corner for pedestrians and cyclists, improvements to the subway, routes from Gillette Corner to both sites, and the areas adjacent to both sites, with a s106 contribution agreed for environmental improvements for the link between the two sites.

8.403 Locations along the A4 have been identified as being in need of improvement, especially junctions to the east (linking the site to the Grand Union Canal and Boston Manor Road) and the west linking the sites to Osterley station). These locations have been raised in discussions with TfL as Highway Authority for the A4 and improvements should be agreed and delivered prior to occupation.

8.404 Some locations for improvement have been identified on Syon Lane either through site assessment of collision data. In relation to collision data, pedestrians crossing Syon Lane to the north of Syon Lane station was identified, but the introduction of a controlled pedestrian crossing has improved safety at that location. Busch Corner has also been identified as a location with a significant number of PICs. Improvements to this junction are being proposed as part of the C9 (cycleway) proposals along London Road, together with s278 works relating to the Green School for Boys development.

8.405 The GWC Local Plan identifies pollution and noise from traffic on the A4 as a barrier to active travel and proposes a “Clean Air Route” for walking and cycling parallel to the A4. Syon Gate Way would be the western “gateway” to this route and improved access for pedestrians and cyclists is proposed. A minimum 3m shared route would be provided on the norther side of Syon Gate Way as a temporary arrangement until such time as a permanent route can be provided on the southern side of the road. This will also provide access to and around the site for pedestrians and cyclists.

8.406 It is proposed to provide improved footways around the site. On the A4 frontage a segregated cycle lane will be provided for much of the length of the site, with a wide shared area provided where this is not possible. A shared footway is proposed on the Syon Lane frontage between the A4 and Syon Gate Way. Both frontages would have improved landscaping, seating, and cycle stands. All of these works would be secured in the s106 agreement and delivered in the s278 agreement.

8.407 Links to London Road and C9 are key to promoting active travel from the site. London Road has cycle lanes in place for much of its length between Brentford and Hounslow, or bus lanes that cyclists can use. The Council is currently working with TfL to deliver C9 which is proposed to extend eventually to Hounslow town centre. The section between Bretford and Hounslow has not yet been designed in detail or programmed and a s106 contribution to this is not sought. If match funding for this route is required a bid to use CIL will be made. There are existing cycle lanes on London Road and it has been confirmed that no interim works are currently planned or designed in advance of the delivery of C9 and therefore no s106 funding is sought.

8.408 The main route linking the site to London Road and Brentford town centre is Syon Lane. Providing a cycle link across the railway would require major scheme funding and therefore use of CIL funding is more appropriate. A s106 contribution is not sought. South of the railway bridge the main route to London Road and from there to Brentford town centre is using Syon Lane which is traffic calmed and has a 20mph speed limit. It is not considered that there are any necessary improvements to this route.

8.409 The A4 has off carriageway cycle routes and footways that provide an alternative route to Brentford town centre and it is for TfL, as Highway Authority, to consider whether they require improvements to these routes. If they do, it will need to be included in the s106 agreement or s278 agreement.

8.410 To promote active travel it is recommended that there are separate travel plans for the residential and commercial uses as they are distinct uses, which would have different impacts and needs and therefore need to be considered and managed separately. The Travel Plan must refer to and be in accordance with the council’s 10 Point Guide to Development Travel Plans, which includes provision of a £100 voucher for new residents to encourage use of sustainable modes of transport. Monitoring of modal splits and impacts would again be independently assessed, with this monitoring to cover 10 years after post occupation of the development. The Travel Plans themselves should be for the lifetime of the development. They should meet targets agreed with the Council and apply for initial 5-year period, and continue for a further 5 year period if the targets are not being met.

Construction

8.411 In accordance with policy the applicant has submitted a draft Construction Logistics Plan (“CLP”) for both sites. The development would be likely to have temporary local disruption to pedestrian, cycle and vehicular traffic, including public transport users for the duration of works owing to demolition and construction traffic. Some impacts from such large scale construction are an inevitable consequence of development.

8.412 For the Homebase Site it is proposed that all construction vehicles would access the Site from the A4 at Gillette Corner, with access taken from Syon Lane and potential egress to the A4. This is considered to be acceptable in principle. The applicant has submitted more detailed tracking to show that large vehicles can access the site. However, a revised CLP will be required prior to commencement of construction once a contractor has been appointed and a more detailed method of construction proposed. In accordance council policy, there should be no HGV trips in the network or school peaks (i.e. all deliveries from HGVs to occur between 9.30AM-3PM) unless specifically agreed in advance and for exceptional reasons and with additional measured to protect the safety of pedestrians. The CLP will be monitored and reviewed throughout construction. The CLP will be secured as a planning condition.

Conclusion

8.413 The developer has submitted Transport Assessments for the Homebase Site and Tesco Site. The transport impacts of these developments, as set out in the Transport Assessments and associated documents, have been considered in detail and against national, London and local policy. It is considered that the proposed developments are in accordance with policies set out in these documents.

8.414 Following consultation with TfL and public transport providers, it is considered that there would not be a severe residual cumulative impact from the relocation of the existing Tesco store to the Homebase Site together with 473 new residential dwellings, or the subsequent redevelopment of the Tesco store for up to 1,677 new dwellings and local commercial units. It is also considered that there would not be a significant impact on road safety as a result of the proposed developments, all subject to delivery of the proposed mitigation measures.

8.415 The Homebase Site and the Tesco Site are located in the Great West Corridor Opportunity Area where it is proposed to deliver significant levels of residential and commercial development over the coming years. The transport study that was commissioned jointly with TfL has proposed a series of transport interventions designed to increase public transport accessibility and these are proposed to be delivered using a range of funding opportunities including s106 and CIL. The LP requires development to be assessed against current and future levels of public transport accessibility as well as considering shorter term mitigation measures to ensure that any impacts on the public transport network are mitigated.

8.416 In accordance with the LP the developer has agreed to a number of measures to mitigate the traffic, public transport, and active travel impacts of the proposed developments. This includes works to improve traffic flow and pedestrian/cycle accessibility at Gillette Corner, a £1.7m contribution towards improved bus services, and active travel improvements around the site. Strategic transport improvements, as identified in the transport strategy, will require CIL (and other) funding to be delivered, to which this and other developments in the Opportunity Area will contribute. Use of s106 contributions is not considered to be appropriate in such cases. The timescale for the delivery of the development of the Tesco Site, in particular, will allow further development and delivery of the wider transport improvements in advance of the occupation of the Tesco Site which is envisaged for 2030. Therefore, there is no transport objection to the proposed developments and the proposal is consistent with the aims of LP polices T1-T9 and HLP policies EC1 and EC2.

H. Impacts on Neighbours

8.417 The proposed mixed-use development, which includes the large Tesco retail store and high density housing, would significantly intensify the use and amount of development on the Site. The proposed uses would bring increased activity from new residents, shoppers, and servicing/ deliveries whilst the proposed buildings have a substantially greater height and bulk compared to the existing use and buildings at the Site.

8.418 LP policy D9 relating to tall buildings acknowledges tall buildings and are likely to have a greater impact on their environment and says that where a Site is adjacent to buildings of significantly lower height there should be an appropriate transition in scale between the tall building and its surrounding context to protect amenity or privacy.

8.419 Various policies of the HLP, including SC4, CC2, CC3, EQ4 and EQ5 seek to protect existing residents’ living conditions by providing adequate outlook, minimising over overbearingness and overshadowing, and ensuring sufficient sunlight and daylight to adjoining/adjacent dwellings, and including measures to minimise noise disturbance to adjoining properties.

Privacy and Outlook

8.420 As noted, the Housing SPG recommends minimum distances of between 18-21m between habitable rooms, with these distances being useful yardsticks for privacy. However it also says that adhering rigidly to these measures can limit the variety of urban space and housing types, and sometimes unnecessarily restrict density.

8.421 The design has accounted for the surrounding context through arranging the height and massing of the buildings to be generally lower towards Syon Lane, where the closest residential neighbours are located. The new building is located a minimum of 40m to 46m from residential buildings opposite to the west on Northumberland Gardens (Syon Lane), and 65m from houses on Brambles Close to the south, beyond railway lines. The building would also be located 65m from New Horizons Court, which is being converted to residential use, and is located on the northern side of the Great West Road opposite the Site. These distances all exceed the recommended separation between habitable room windows.

8.422 Given the layout of buildings and the good separation of the development from neighbours, the proposal would maintain sufficient privacy for residents of the surrounding area. The substantially larger buildings proposed on the Site would be much more apparent from within the surrounding locality and will be visible from windows and gardens of residential properties, changing their outlook and the townscape. However, the architectural design of the buildings, including their good quality and varied materials, undulating height and articulated massing, along with the distance of separation and landscaping, would avoid the buildings appearing overbearing or oppressive.

Daylight and Sunlight

8.423 LP policy D6 says design of development should provide sufficient daylight and sunlight to surrounding housing that is appropriate for its context. HLP policy SC4 states that development proposals should demonstrate compliance with prevailing daylighting standards (BRE guidance). The ES assesses the likely impacts of the development on daylight and sunlight on neighbouring properties with the assessment considering the targets from the BRE Guidance.

Daylight

8.424 For daylight the tests are the Vertical Sky Component test (“VSC”) which assesses daylight to the windows, and the No Sky Line test (“NSL”) which considers daylight distribution within a room. Both the VSC and NSL tests should be used to assess the impact on daylight. 8.425 VSC is assessed at the centre point of the window and looks at the angle of obstruction caused by the proposed development. The maximum value is 40% VSC for a completely unobstructed vertical window. The VSC does not consider window size, room dimensions or the properties of the window itself. The BRE guidance targets a VSC of 27% or more with this providing a good level of daylight. If this is not met, the reduction in light should not exceed 20% of the former VSC light levels. The BRE advises that acceptable levels of daylight can still be achieved if VSC levels are not reduced by more than 20%. If the loss is greater, then the reduction in daylight would be noticeable with rooms likely to become darker, though the closer to the target the less noticeable the impact will be.

8.426 At the EIA scoping stage the applicant had proposed an alternative VSC target of 15%, given the urban context of the Site. It is acknowledged that the numerical guidelines of the BRE are not mandatory and they can be applied flexibly where justified, however this alternative target was not agreed given the Site is near to suburban areas. The ES instead considers both the 27% VSC and a more appropriate alternative VSC target of 20% which reflects the area’s designation for transformation through more intense development indicates with this likely to change the form and character of the area including with some tall buildings as suggested in the GWC Local Plan.

8.427 NSL may be used where room layouts are known to assess where daylight falls within the room at the working plane (850mm above floor level in houses). The BRE says that if the area of the room that receives direct daylight is reduced by more than 20% then the occupants would notice the room being darker.

8.428 The BRE considers that where daylight (or sunlight) fails to meet the guidance, the impact can be classified as ‘minor’, ‘moderate’ or major adverse’ depending on a range of factors. These factors include how many and the proportion of windows in a property that are adversely affected and by how much, and whether the nature of the room affected is one where the need for light is higher. Where the BRE guidance tests are not met, a major adverse impact is likely where:

 A large number of windows are affected  The loss of light is substantially outside the guidelines  All windows of a property are affected  The nature of the room affected is one where the need for light is high (e.g. living room), with the guidance stating bedrooms are less important.

8.429 The ES has considered the guidance and categorised the significance of the assessed impacts as follows:

Significance Change Negligible No change, minor change < 20% reduction Minor Adverse Minor infringements 20.1% - 30% reduction Moderate Adverse Moderate infringements 30.1% - 40% reduction Major Adverse Major infringements 40.1+% reduction Table 10: Daylight Impact

8.430 A total of 280 windows (to 170 rooms) of nearby residential properties at Northumberland Gardens, Rothbury Gardens, New Horizons Court, Brambles Close and Cherry Crescent were assessed. The results for the occupied dwellings taking into account the above table are summarised in the following tables.

Property Windows with significant VSC and/or NSL impact Nos. 19-20 4 negligible impact (meet BRE) Northumberland 5 minor impact Gardens Retained VSC range 19.56 - 30.54% NSL reduction 1.9 - 6.1% Nos. 17-18 8 minor impact Northumberland 1 moderate impact Gardens Retained VSC range 14.73 - 29.16% NSL reduction 5.1 - 8.9% Nos. 15-16 2 negligible impact (meet BRE) Northumberland 6 minor impact Gardens 1 moderate impact Retained VSC range 18.06 - 28.71%% NSL reduction 10.7 - 30.7% Nos. 13-14 7 minor impact Northumberland 2 moderate impact Gardens Retained VSC range 15.41 - 27.57% NSL reduction 21.7 - 36.6% Nos. 11-12 1 negligible impact (meets BRE) Northumberland 5 minor impact Gardens 3 moderate impact Retained VSC range 17.80 - 27.57% NSL reduction 2.9 - 19.3% Nos. 9-10 6 minor impact Northumberland 3 moderate impact Gardens Retained VSC range 16.75 - 27.63% NSL reduction 5.8 - 24.2% Nos. 7-8 5 minor impact Northumberland 4 moderate impact Gardens Retained VSC range 17.32 - 27.01% NSL reduction 0.6 - 28.3% Nos. 5-6 4 minor impact Northumberland 5 moderate impact Gardens Retained VSC range16.70 - 27.13% NSL reduction 3.5 - 29.1% Nos. 3-4 2 minor impact Northumberland 7 moderate impact Gardens Retained VSC range 2.57 - 26.04% N.B. existing low = 4.2% NSL reduction 2.7 - 35.6% Nos. 1-2 1 negligible impact (meets BRE) Northumberland 3 minor impact Gardens 5 moderate impact Retained VSC range 18.06 - 27.34% NSL reduction 5.0 - 31.7% Nos. 23-24 5 minor impact Brambles Close Retained VSC range 24.29 - 26.53% NSL reduction 0 - 22.1% Nos. 25-26 5 minor impact Brambles Close Retained VSC range 24.49 - 26.85% NSL reduction 0.2 - 25.6% Nos. 27-28 3 negligible impact (meet BRE) Brambles Close 2 minor impact Retained VSC range 23.72 – 28.52% NSL reduction 4.5 - 14.7% Nos. 29-30 3 negligible impact (meet BRE) Brambles Close 2 minor impact Retained VSC range 25.24 - 29.63% NSL reduction 4.4 - 21.7% No. 40 Cherry 1 negligible impact (meet BRE) Crescent Retained VSC range 31.01% NSL unchanged Nos. 42-44 9 negligible impact (meet BRE) Cherry Crescent Retained VSC range 26.79 - 31.87% NSL reduction 0 - 3.1% No. 46 Cherry 7 negligible impact (meet BRE) Crescent Retained VSC range 29.76 - 37.09% NSL reduction 0 - 0.4% No. 48 Cherry 4 negligible impact (meet BRE) Crescent Retained VSC range 30.85 - 34.2% NSL reduction 0 - 4.3% No. 50 Cherry 3 negligible impact (meet BRE) Crescent Retained VSC range 31.04 - 34.2% NSL unchanged No. 52 Cherry 4 negligible impact (meet BRE) Crescent Retained VSC range 31.63 - 34.43% NSL reduction 0 - 2.5% Nos. 2,4 1 negligible impact (meet BRE) Rothbury 4 minor impact Gardens Retained VSC range 22.52 - 30.11% NSL reduction 9.9-18.5% Nos. 1,3 5 negligible impact (meet BRE) Rothbury Retained VSC range 25.65 - 28.93% Gardens NSL unchanged

Table 11: Consideration of daylight impacts

Table 12: VSC Assessment

Table 13 : NSL Assessment

8.431 The above tables show that various neighbouring residential properties would experience impacts of mixed significance but that most windows and rooms assessed will meet the BRE guidance. The assessment shows many windows and rooms would experience little or minor changes to daylight levels. Where the effects exceed the targets from the BRE (for VSC or NSL), the daylight to some rooms would be noticeably reduced. In those instances further consideration of the impacts has been discussed in the ES, with it noted that the affected rooms would still receive adequate daylight for the context of the Site with most windows still achieving a VSC of over 20% and rooms with a NSL over 50%, particularly as some affected windows serve the same room meaning the cumulative daylight to the room is still good for an urban area. Additionally, the ES has calculated the ADF for rooms of affected properties and the results show that is most instances the ADF targets are achieved.

8.432 In addition to the above summary of impacts on existing residential properties that are occupied, the ES considers impacts on existing windows of Blocks 1 and 4 of New Horizons Court, which is being converted to residential use under permitted development rights. A total of 55 windows serving 38 rooms in Block 1 were tested, of which 35 rooms would meet the BRE guidance. Of the 3 remaining rooms, 2 experience effects of >30% reduction and can be considered minor impacts, and 1 has major adverse impacts (over 40% reduction). The latter room has 2 windows, one of which would suffer negligible impacts and the other a significant impact using the VSC test (but not the NSL), however this is due to an existing overhang/ balcony, and if assessed without this feature it would achieve compliance. For Block 4, 74 windows serving 25 rooms were assessed with 18 of the rooms meeting the BRE guidance. A further 11 rooms had reductions of minor significance (for VSC and NSL).The 6 remaining rooms each have one window where the VSC reduction is over 30% and moderate adverse. However, these windows are affected by the existing overhanging balconies of the building. Testing without the balconies shows the effect of the development is more acceptable so it is the existing building design contributing most to the relatively large reduction.

Sunlight

8.433 The BRE guidance recommends the impact on sunlight to existing main living rooms of neighbouring dwellings should be assessed if they have a window facing within 90° of due south. If the centre of the window receives more than 25% of annual probable sunlight hours (“APSH”), including at least 5% in the winter months (between 21 September and 21 March), then the room should still receive enough sunlight. Any reduction in sunlight access below the existing level should be kept to below 20% and the reduction of the whole year below 4% of the APSH or the sunlight may be adversely affected.

8.434 The ES shows that of 84 neighbouring rooms assessed, 76 will meet the BRE guidance for sunlight. There are 2 rooms, located at Nos. 9-10 and Nos. 13-14 Northumberland Gardens where there would be a reduction of minor adverse significance (20-30% reduction). There would be 6 rooms within Block 4, 1 New Horizons Court, where the reductions exceed the BRE with 1 room experiencing a 20-30% reduction, 4 rooms a 30-40% and 1 an over 40% reduction. In each instance an existing overhang/ balcony is the primary cause of the relatively large reduction rather than the size of the development.

Overshadowing

8.435 To asses overshadowing of gardens the BRE guidance recommends that at least 50% of neighbouring outdoor amenity areas should receive at least 2 hours of sunlight on 21 March. The ES shows that every neighbouring amenity space will either continue to enjoy very good levels of sunlight or will experience a very slight reduction in their sunlight, with all being well within the BRE guidance.

Conclusion

8.436 The effects of the development on the daylight to neighbouring properties have been satisfactorily considered, with regard given to the BRE guidance, and on the whole the impacts are acceptable. The majority of the neighbouring residential properties around the Site would experience some loss of existing daylight as a result of the development, which is appreciably larger and closer to the Site boundaries than the existing building. The impact on the majority of these affected windows and rooms would however be within the BRE guidelines, or the effects are not more than minor- moderate adverse. The exceptions where there are major adverse impacts are largely the result of the existing building design of the affected properties which disproportionately obstruct daylight (within New Horizons Court). Of the existing occupied residential properties, those on Northumberland Gardens are the most affected, and the loss of daylight to some windows would be noticeable to residents, however the overall daylight levels would be satisfactory for an urban environment. Other existing residential properties are less affected. The impacts on sunlight to neighbouring properties (rooms and amenity space) are also acceptable. Overall there are very few transgressions of the BRE guidance in respect of sunlight to rooms and for the worst affected rooms this is again mostly a consequence of the design of the existing building rather than the development proposal, whilst the effect on neighbouring gardens/ amenity spaces is not significant (with all properties meeting the BRE guidance).

8.437 The context of the Site is also a consideration with the locality designated as an Opportunity Area where significant intensification is expected to deliver substantial housing and employment growth. It is also reasonable to note that in urban locations where a proposed site contains relatively low structures as is the case here, the likelihood of some reductions of daylight beyond the BRE guidelines from more intense development (which is envisaged in the existing and emerging planning framework) is greater. This is because existing levels of daylight can be relatively high. Finally, consideration has also been given to the Mayor’s Housing SPG, which seeks to avoid ‘unacceptable harm’ to the amenity of surrounding land and buildings, but also recommends31 an appropriate degree of flexibility needs to be applied when using BRE guidelines with these to be “…applied sensitively to higher density development especially in opportunity areas, town centres, large sites and accessible locations”.

Noise, Vibration and Other Disturbance

8.438 LP policy D14 and HLP policy EQ5 aim to mitigate and minimise potential adverse effects from noise and vibration from new development, and look to avoid harmful impacts on health and quality of life. The areas to the south and west of the Site are generally residential. Consequently there is potential for some disturbance for sensitive receptors from both construction activity and the completed development, the latter including impacts associated with the supermarket operation and building services plant. Other commercial development adjacent and nearby is less sensitive to noise, though there would be expected to be some potential disturbance during construction work.

8.439 Demolition and construction activity will be ongoing for a considerable period owing to the scale and phasing of the development. These works would potentially adversely affect living conditions of neighbours owing to disturbances from construction work such as noise, lighting, dust and air pollution, and traffic. Consideration also must be given to cumulative impacts noting other potential construction sites in the area.

8.440 In regards to construction work the ES identifies that noise impacts would be greatest to properties on Syon Lane, Crescent and the adjacent car showroom (Skoda) due to their proximity to the Site. Noise from construction traffic would not be

31 Mayor’s Housing SPG 1.3.45 significant. Vibration impacts from construction work are negligible to low, with this equating to an impact of minor significance with this only affecting properties on Syon Lane. Conditions are recommended to secure appropriate management of construction impacts from noise, vibration and other impacts to limit and mitigate the effects. These conditions include a Construction Logistics Plan and Construction Environmental Management Plan would control activity to minimise residual impacts with practical measures such as routeing of vehicles, working hours and practices, dust suppression, site hoardings, lighting, wheel washing, workers parking and access, and health and safety procedures.

8.441 For the completed development noise and other disturbance would not be significant. All fixed plant noise emissions are to be limited to 10dB below background sound levels, whilst servicing areas are located within the building, with conditions recommended to secure these requirements. The new housing at the Site is located above the supermarket and car park, and is setback from the building boundaries including the car showroom, this design giving account to the ‘agent of change’ principle from the LP policy D13 which places the responsibility of mitigating the impact of nuisances (including noise) from existing nuisance generating uses on proposed new development close by. These arrangements would ensure impacts on neighbouring properties are minimised and there would not be adverse impacts on their amenity.

Air Quality

8.442 Paragraph 181 of the NPPF says planning decisions should ensure that any new development in Air Quality Management Areas is consistent with the local air quality action plan and that development takes opportunities to improve air quality or mitigate impacts, such as through traffic and travel management, and green infrastructure provision and enhancement.

8.443 The whole Borough is designated as an Air Quality Management (“AQMA”) for two pollutants, Nitrogen Dioxide (NO2) and Particulate Matter (PM10). The main sources of these pollutants are road traffic and buildings (gas boiler emissions).

8.444 LP policy SI1 requires new development to be ‘air quality neutral’. It must not lead to further deterioration of existing poor air quality, create any new areas that exceed air quality limits, or delay the date at which compliance will be achieved in areas that are currently in exceedance of legal limits, or create unacceptable risk of high levels of exposure to poor air quality.

8.445 HLP policy EQ4 says the Council will seek to reduce the potential air quality impacts of development and promote improved air quality conditions across the borough, in line with the Air Quality Action Plan by ensuring that development does not exacerbate existing air pollution and wherever possible improves air quality, by promoting development that reduces and limits exposure to emissions through on- site mitigation and is ‘air quality neutral’, and through sustainable design and planning obligations. This will be achieved by assessing air quality impacts, and incorporating mitigation measures where air quality assessments show that development would cause or exacerbate air pollution, or where end users would be exposed to air pollution.

8.446 Policy GWC3 of the GWC Local Plan recognises the problem of air pollution in the GWC, particularly on its major road, including the Great West Road, and it seeks to ensure site and building design minimises exposure to elevated levels of air (and noise) pollution through:  locating sensitive uses away from existing sources of air pollution  using technology and design to prevent or minimise to pollution  the provision of winter gardens and balconies  the use of greenery to act as a “buffer”

8.447 This Site adjoins major roads (Great West Road/ Syon Lane) and experiences high levels of air pollution. The development includes a new supermarket with car park and housing, which would replace the existing DIY store and car parking. This would be a more intensive use of the Site and potentially brings new sources of air pollution as well as introducing new people into the area. Traffic associated with the development (both construction and operational) would be the main air quality impact. The locality is mixed in terms of uses, with development along the Great West Road itself mostly commercial, but there are more sensitive receptors in nearby roads with residential properties along Syon Lane. The air quality implications of the proposed development both in terms of during construction and use following completion have been assessed.

8.448 For the construction period there would be an increase in construction vehicle traffic to the site, however the impact of construction traffic emissions for NO2 is predicted to be negligible. There is also a risk of particulate pollution (PM10) from construction dust however this can be managed through appropriate environmental controls including ensuring on-road vehicles comply with the requirements of the London Low Emission Zone and the London NRMM (non-road mobile machinery) standards. Given other committed development being carried out and proposed in the wider area, all construction traffic needs to be coordinated with other sites, vehicles should not be routed through residential streets such as Northumberland Avenue Road

8.449 In respect of the completed development the assessment shows that the impact of operational traffic and emissions associated with the development is predicted to be negligible at all existing receptors and the development is air quality neutral and no further mitigation is required. The development uses emission free air source heat pumps for heating and hot water with low emissions boilers proposed only as back- up which can be used in the event of equipment failure. The emissions from the three boilers are not significant at existing or proposed receptor locations. Other measures that help to improve the overall air quality environment include the following items that would be secured by conditions and obligations:

 Ensuring overall building emissions energy efficiency.  Providing measures that encourage walking and cycle use including improvements to the public realm and pedestrian environment and new cycleways  Contribution towards public transport improvement  Commercial and residential Travel Plans– including obligations to reduce on-site car parking and maximise non-car modes of transport  Provision for electric vehicle car parking spaces  Car club spaces for residents  Green infrastructure including trees, shrubs and green and brown roofs

8.450 The air quality mitigation proposed would decisively outweigh the air quality impacts from the completed development. Cumulatively with the other development, the proposed impact on air quality remains acceptable. There would be an overall reduction in vehicle traffic if the Tesco Site proposal went ahead as across the two sites the total number of car parking spaces is reduced, with this being a positive action in respect of air quality, with this being consistent with LP policy SI1 and policy GWC3 of the GWC Local Plan which introduce the aims for new development in the Opportunity Area to be ‘air quality positive’.

Conclusion

8.451 The proposed development has been designed to give thought to the living conditions and amenity of neighbouring residents and properties. The Site would be transformed with larger buildings and more intensive use, but the separation from neighbours and considered height, orientation and massing would ensure that the neighbours retain good privacy and outlook and that satisfactory daylight and sunlight conditions are maintained. There would be some appreciable reductions to daylight and sunlight to some nearby neighbours, with the BRE guidance not met for some of the surrounding windows and rooms. However the assessment shows that these properties would still retain daylight and sunlight levels that are good for an urban setting, whilst the expected optimisation of the development on the Site means some flexibility from the targets of the guidelines is reasonable. Noise and other disturbance from the development would be appropriately mitigated and their effects on neighbours would not be significant. Air quality impacts are acceptable with the development being air quality neutral itself and with the related Tesco Site proposal there would be an overall improvement owing to the cumulative reduction in car parking across the two sites.

8.452 Therefore the impact on neighbours, including on commercial properties and nearby residents, would be acceptable, as subject to recommended safeguarding conditions, the overall effects are such that the amenity of neighbours, including residential living conditions, would be satisfactorily maintained. This would accord with requirements of LP policies D9 and D13, and HLP policies SC4 CC2, CC3, EQ4 and EQ5.

I. Other Environmental Matters

8.453 The NPPF32 says planning decisions should ensure that new development is appropriate for its location taking into account the likely effects (including cumulative effects) of pollution on health, living conditions and the natural environment, as well as the potential sensitivity of the site or the wider area to impacts that could arise from the development. Consideration has therefore been given to other wider and

32 Paragraph 180 of the NPPF on-site environmental conditions and impacts, with these matters addressed in the ES as part of the Environmental Impact Assessment process.

Flooding and Drainage

8.454 LP policies SI12 and SI13 expect flood risk to be managed sustainably with surface water managed to reduce risk and include drainage that is designed and implemented in ways that promote multiple benefits including increased water use efficiency, improve river water quality, and enhance biodiversity, urban greening, amenity and recreation.

8.455 HLP policies EQ2 and EQ3 promote the highest standard of sustainable design, including requiring sustainable drainage (“SuDS”). Flood risk is to be reduced by ensuring that developments are located appropriately and they incorporate any necessary flood resistance and resilience. Greenfield rates of runoff from development are recommended.

8.456 The Site is located in Flood Zone 1 (lowest risk). The development would use SuDS measures including the use of attenuation, soft landscaping including tree planting, and green/brown roofs to reduce water runoff to a greenfield rate. Conditions to secure details of the proposed drainage system and its maintenance are recommended, and with these the proposed flood risk and drainage management arrangements are acceptable.

Contaminated Land

8.457 HLP policy EQ8 says the Council will ensure that contamination is properly considered and promote the remediation of land where development comes forward, consistent with the Council’s Contaminated Land Strategy and the NPPF.

8.458 The Site has a former industrial use. Site investigations show remediation and further monitoring is recommended land contamination but subject to mitigation during construction, there would be negligible risk to future residents. Therefore, subject to mitigation to be secured by conditions, there are no constraints to the principle of the proposed uses on the site with regard to contaminated land.

Wind

8.459 LP policies D3, D8 and D9 require the design of buildings and the public realm to provide a comfortable environment for users and spaces around the building and pedestrians. HLP policy CC3 says proposals should provide for a comfortable and pleasant microclimate which minimises wind vortices. The ES has considered the effects of the building on a range of activities at the entrances, main thoroughfares and amenity spaces.

8.460 The wind microclimate assessment found conditions within and around the Site would be largely suitable for comfort and safety, with the exception of localised points at to some entrances, pathways and at part of the amenity space. Wind mitigation measures are proposed in these locations to ensure suitable conditions for pedestrian comfort with these to include screens, canopies, hedging and recessed entrances to buildings and a draught lobby. Subject to a condition securing this mitigation if the development was approved, the assessment concludes the development is acceptable in terms of pedestrian safety and comfort levels for users.

Urban Greening and Biodiversity

8.461 LP policy G5 says major development proposals should contribute to the greening of London by including urban greening as a fundamental element of site and building design, and by incorporating measures such as high-quality landscaping (including trees), green roofs, green walls and nature-based sustainable drainage. It also sets out a method for evaluation urban greening in new development, detailed an Urban Greening Factor (“UGF”) to identify the appropriate amount of urban greening required in new developments. LP policy G6 requires development to seek opportunities to create habitats that are of particular relevance and benefit in an urban context.

8.462 The ES has determined that the Site is of negligible ecological value with no habitats or species of value were identified with it being used mostly for surface car parking and the Homebase building. There are some trees and shrubs around its perimeter and within the street, and there is woodland along the adjacent railway lines. There is a small stand of Japanese knotweed was encountered within a flower bed at the north east of the Site.

8.463 The development includes a landscaped amenity space to the podium that includes extensive green spaces and trees planting, new trees within the public realm around the base of the building, green roofs, and a green wall to Syon Lane. This will significantly enhance the biodiversity and ecological value of the Site through adding new habitats. The landscape masterplan includes native hedgerow (239 sqm), shrub and perennial planting (1,500 sqm), wildflower meadow (40 sqm), alpine planting (180 sqm) and lawn (over 1,100 sqm). Additionally, the flat roofs of the blocks would be used as green/ brown roofs, with these spaces having a total area of 4,500 sqm. The applicant advised that the solar PV system would be able to be provided on top of the green/ brown roofs. Bat and bird boxes, as well as insect hotels are to be installed across the Site.

8.464 The existing trees at the Site and adjoining land have been assessed. There are 14 individual trees and 4 groups within the Site or on directly adjacent land. This includes 2 category ‘B’ trees and 1 group (moderate quality), 7 category ‘C’ trees and 3 groups (low quality) and 5 ‘U’ category tree (unsuitable for retention). The development would result in removal of 13 individual trees and 2 groups with this comprising 2 category B trees, 7 category ‘C’ trees and 2 groups and 4 ‘U’ category trees.

8.465 The landscape masterplan for the Site includes new tree planning with 41 new trees at ground level on and around the new public realm. The podium amenity space includes a total of 121 small and multi-stemmed trees. The overall landscaping would help replace and add significantly greater areas of green space.

8.466 Overall the development would greatly increase biodiversity of planting across the Site, enhancing its ecological value. This has maximise the potential urban green for the Site, and the estimated UGF value meets the LP target33

Solar Glare

8.467 Information regarding potential for solar glare from the new buildings was considered in respect of neighbours, road and rail traffic. At certain times of the day and year there is potential for from reflected sunlight from building surfaces, especially glazing. The ES considered these and found that the impacts would not be significant and the building has been designed to minimise the amount of potential glare. Southwestern Railways, the operator of passenger rail on the adjacent railway and Network Rail, the owner of the rail line do not have concerns regarding glare.

Conclusion

8.468 The proposal has adequately addressed requirements to consider other environmental matters and requirements arising from the development including managing flood risk, providing appropriate drainage, dealing with potential land contamination and wind microclimate impact, and improve urban greening and biodiversity.

8.469 Subject to conditions recommended to secure necessary details and mitigation these other environmental matters are acceptable, and the development would satisfy relevant LP policies including SI12, SI13, D3, D8, D9, G5 and G6, and HLP policies EQ2 , EQ3, EQ8 and CC3 .

J. Planning Balance

8.470 The application should be determined in accordance with the Development Plan, with development that accords with its policies and which constitutes sustainable development to be approved without delay, and that which conflicts with it to be refused unless other material considerations indicate otherwise.

8.471 Hounslow’s Development Plan is currently comprised of the Hounslow Local Plan (2015), the West London Waste Plan (2015) and the London Plan (2021). The above assessment has considered the proposal against the policies of the Development Plan, and other material considerations.

8.472 The assessment has shown that there is broad support for the development from many policies, but there are breaches of some policies of the Development Plan, because of the ‘less than substantial’ harm to the significance of a number of designated heritage assets. In particular there is conflict with elements of HLP policy CC4 at (d) and (i) and LP policies D9, HC1 and HC2. However this does not necessarily mean that all these policies as whole are conflicted – in respect of HLP CC4, (l) reflects the NPPF’s balancing exercise (paragraph 196). As set out in HLP CC4 (l) and paragraph 196 of the NPPF, it is necessary to weigh this harm against the public benefits of the proposal and where the public benefits outweigh harm then overall this policy would be met. Additionally, even where there is conflict with individual policies, that does not mean that the Development Plan, taken as a whole is conflicted.

33 Urban Greening Factor of 0.4 for predominantly residential development.

8.473 In respect of the other policies of the Development Plan, the development would optimise the use of the underutilised site, which as a brownfield site close to Syon Lane station and within the Great West Corridor Opportunity Area is suitable for intensification. The proposed mix-used development, bringing a good number of new homes, and commercial uses would help meet the strategic housing need in the borough, including affordable housing, and will promote and sustain local economic activity and employment. This accords with ‘Good Growth’ policies of the LP, and policies relating to Opportunity Areas, housing delivery and economic activity, including LP policies G1-G6, SD2, SD7, E11, H1, H4-H6 and H10, and HLP policies IMP1, SV1, TC3, SC1 and ED4.

8.474 Although tall buildings and high density housing is proposed, the development has accounted for its surrounding context also has good quality buildings and public realm, including new and improved footpaths and cycleways that promote active travel, which on balance accords with policies relating to design and housing quality including LP policies D2-D9, and HLP policies CC1-CC3, SC4-SC5, and GB1. The impacts on transport, neighbours and other environmental matters were also satisfactory, taking into account mitigation proposed, complying with LP polices D9, D13, SI1-SI5, SI12-SI13, and T1-T9, and HLP policies SC4 CC2, CC3, EC2, and EQ1 and EQ5.

8.475 However, as noted, the finding of harm to various heritage assets means it is necessary to consider the conflicts with the relevant policies against the other relevant policies and weigh the public benefits of the development against the harm found, so as to determine whether the development complies with the Development Plan as a whole. If there were conflict with the Development Plan overall, then consideration should be given to whether there are material considerations which indicate that the proposal should be determined other than in accordance with the Development Plan.

8.476 In this instance harmful impacts, including cumulative harm, were found to the significance of various listed buildings within the vicinity of the Site, and historic landscapes and assets in the wider district including some designated as having the highest heritage significance being Registered Parks and Gardens (Syon Park and Osterley Park both also conservation areas), and the Kew WHS, which is also a Registered Park and conservation area. These different instances of harm have been considered individually in detail above and are summarised below, and as there are multiple assets the combined effect on heritage must also be put into the planning balance. A number of assets were found to have a low level of harm, with the impact on Syon Park being moderate, with all being determined to be ‘less than substantial’ harm having regard to the NPPF, including cumulative harm.

 Gillette building, lamps, kiosk – low level less than substantial harm  Natwest Bank - low level less than substantial harm  Coty Factory – very low level less than substantial harm  Quaker’s Meeting House – very low level less than substantial harm  Syon House listed buildings – low to mid-low level less than substantial harm  Syon Park – low end moderate to moderate level less than substantial harm  Osterley Park – low level less than substantial harm  Kew Gardens WHS-OUV, Park and CA – very low less than substantial harm  Isleworth Ferry Gate – low-medium less than substantial harm

8.477 Importantly, as set out in paragraph 193 of the NPPF, when considering the impact on the significance of heritage assets, great weight should be given to the asset’s conservation (and the more important the asset, the greater the weight should be) irrespective of whether the harm amounts to ‘less than substantial harm’. Further, where there is a finding of harm to the setting of a listed building, there is a presumption against planning permission being granted with the statutory duty from section 66(1) under the Planning (Listed Buildings and Conservation Areas) Act 1990, requiring that decision makers pay "special regard to the desirability of preserving" listed buildings or their settings. In respect of this statutory duty case law34 confirms that "preserving" means "doing no harm” and35, decision-makers should give "considerable importance and weight" to the desirability of preserving the setting of listed buildings when carrying out the balancing exercise in cases which involve heritage issues.

8.478 Therefore special regard needs to be given to preservation of each of these heritage assets and overall heritage harm, with the paragraph 194 of the NPPF highlighting that any harm or loss to significance should require clear and convincing justification and great weight should be given to the asset’s conservation.

Public Benefits

8.479 Officers consider the application would bring the following public benefits:

 Provision of housing - The delivery of 473 new homes.

 35% affordable housing – 164 affordable homes (LAR).

 Regeneration – Redevelopment of the site with new buildings and landscaping that optimises the use of the Site with a mix of uses.

 Economic activity and employment – Temporary employment activity from construction, retention of permanent employment from retail use, and expenditure from construction and new residents.

 Community space – Free/ subsidised community meeting space.

 Public realm – New and enhanced public realm around the perimeter of the Site including a ‘Clean Air’ Route, improving permeability, accessibility, safety and appearance of these spaces for pedestrians and cyclists and contributing to promoting more active travel.

34 Barnwell Manor Wind Energy Ltd v East Northamptonshire DC & Others ([2014] EWCA Civ 137) the Court of Appeal 35 Ibid.  Ecology – Enhanced biodiversity and ecological value from new landscaping masterplan and use of green brown roofs.

 Tesco Site – Relocation of Tesco store the Site would make the Tesco Site available for comprehensive redevelopment and regeneration, making better use of the land, especially for housing (including affordable housing).

8.480 These benefits in more detail as below.

(i) Housing

8.481 The proposal has 473 new homes, which equates to over 26% of the annual minimum housing requirement for the Borough (1,782 per annum). This is a significant contribution towards meeting the Borough’s new housing target and the objectives of the Opportunity Area as well as the overall housing need across London. The Opportunity Area designated in the LP aligns with the aspirations of the GWC Local Plan, and includes provision of 7,500 homes over the plan period. This is also consistent with paragraph 59 of the NPPF which encourages housing to be provided to support the Government’s objective of significantly boosting the supply of homes.

8.482 The Borough currently has an adequate 5 year supply of deliverable housing sites, and it has a good record of housing delivery, however the increased annual housing target (+116%) from the new LP means that housing delivery on suitable sites, as envisaged in the GWC Local Plan and Site Allocations, will be very important to ensuring adequate housing is delivered.

8.483 Therefore given the great need for housing, the proposed housing is a public benefit of significant weight, with this helping to meet the strategic housing need and delivery targets of the H1and HLP SC1 and the NPPF.

(ii) Affordable housing

8.484 The proposal would provide 35% affordable housing. This would provide 164 homes of a mix of unit sizes, all being for London Affordable Rent. Of these homes, 16 would be built for wheelchair users and a total of 102 homes would be suitable for families of 3 or more persons, with 27% of the affordable homes being 3 and 4- bedroom sized units. It is proposed that the affordable homes be provided in the earliest phases of construction. Given the need for affordable housing this is a benefit of significant weight. It is noted that under the ‘Fast Track’ approach the applicant is to explore the use of grant funding to potential increase the level of affordable housing, but as this is not secured, no additional weight has been given to this possibility.

8.485 In respect of affordable housing provision, the strategic opportunity provided by the related redevelopment of the Tesco Site, which is facilitated by this proposal is also acknowledged, with this creating potential to deliver a very large number of affordable homes (35% of up to 1,677 homes), with this adding some further weight to this benefit.

(iii) Regeneration 8.486 There is a public benefit from regeneration and the reuse of previously developed land, optimising the use of the site and providing new buildings and landscaping in the townscape. The Site is within an Opportunity Area in the LP where substantial growth in housing and employment is directed. These same aims are integral to the spatial strategy of the HLP where significant housing growth is envisaged for the Great West Corridor area. It is also noted that the Site is also proposed to be allocated for redevelopment in GWC Local Plan and Site Allocations.

8.487 The existing Site does not make a positive contribution to the townscape. Its redevelopment with new good quality buildings which include new areas of public realm and landscaping is a public benefit. Intensification of the use of the Site, which includes a large area of car parking and a single storey retail unit, with a mixed-use housing led proposal of mix-tenure, is consistent with the strategic objectives to make the most effective use of underutilised land within Opportunity Areas.

8.488 These aspects of the proposal are consistent with paragraph 117 of the NPFF that promotes the effective use of land to meet the need for homes and other uses, while safeguarding and improving the environment and ensuring safe and healthy living conditions, in a way that makes as much use as possible of previously-developed land. Additionally, paragraph 118 of the NPPF says planning decisions should, give substantial weight to the value of using suitable brownfield land for homes and other needs, and support the development of under-utilised land, especially if this would help to meet identified needs for housing where land supply is constrained and available sites could be used more effectively (for example space above shops, and building on or above service yards, car parks, lock-ups and railway infrastructure).

8.489 The weight to this benefit is moderate given there is some residual harm to heritage assets of high significance and as there are some variances from the highest standards of housing quality and the BRE daylight and sunlight guidance.

(iv) Economic Activity and Employment

8.490 The proposal would generate temporary employment during construction, permanent employment at the Tesco store and separate retail unit, and there would be economic activity and support for employment from the local spending of new residents and associated management/ maintenance of the 473 homes.

8.491 The bulk of permanent employment would be jobs relocated with from the existing Tesco Site and some jobs are lost from the existing Homebase (though it is scheduled to be closed in any event). As such there is limited benefit from the employment at the Site itself, though redevelopment of the relating Tesco Site would bring potential for additional employment cumulatively across the two sites.

8.492 In addition to permanent employment, the construction of the development would also create temporary construction jobs with it is estimated that over the 3 year construction period, an average of 491 FTE construction jobs would be directly created on the Site with further indirect employment supported from associated spending. If approved, s106 contributions would secure skills training opportunities for local people. Redevelopment of the Site in turn permits redevelopment of the associated Tesco Site where even more considerable construction employment would be generated over a long period. Notably paragraph 80 of the NPPF says significant weight should be placed on the need to support economic growth and productivity, taking into account both local business needs and wider opportunities for development.

8.493 Only limited weight should be given to permanent employment at the Site as the jobs created are largely relocated and not new ones though there would be increased economic activity from the substantial number of new residents. For construction employment and activity, this is temporary and should also only be given limited weight, but given the scale of employment and investment into the Great West Corridor and the significant training opportunities this should be given more weight, also noting the current context of severe economic recession. Taken together these public benefits arising from the proposed economic activity and employment are considered to be of low weight.

(v) Community Space

8.494 The 200 sqm community space provided above the Tesco store is a public benefit, as it is to be made available through Tesco for community activities at no or a low cost. This provides a space for local people and organisations to meet, and undertake activities and share information for social, recreational, health, education and cultural purposes. Given the relatively small space and that is owned and managed privately, this is a public benefit but of limited weight.

(vi) Public realm

8.495 The development includes improvements and new public realm and landscaping to land around the perimeter of the Site, plus associated works to footpaths and cycleways that would significantly enhance the environment for walking and cycling, in line with objectives to encourage more active and sustainable travel choices. This includes the ‘Clean Air’ route. The proposal is satisfies objectives of the GWC Local Plan to transform the corridor with enhanced public realm with a continuous well connected green network that optimises urban greening. This is an important benefit and is given moderate weight.

(vii) Ecology

8.496 The landscape masterplan would significantly enhance the biodiversity and ecological value of the Site which would contribute positively to the greening of the area with this including tree planting and extensive areas of green/ brown roofs. This is a public benefit is of limited weight as the quality landscaping and greening of the Site would be expected and it mostly serves to meet the needs of the development itself.

(viii) Tesco Site

8.497 The is a public benefit from the proposal accommodating the relocated Tesco store, which in turn would make the Tesco Site available for comprehensive redevelopment and regeneration, making better use of the land, especially for a high number of new homes, as well as a commercial precinct that would provide better amenity for workers within the Opportunity Area and new public open spaces that would benefit the local area. This would help meet objectives to boost housing and economic activity in particular. This strategic opportunity is specifically considered in the GWC Local Plan and Site Allocations. Without the relocation of the Tesco Store, the existing Tesco Site would be more likely to be redeveloped in a piecemeal manner, if at all. These benefits are indirect as they would rely on that scheme being fully delivered but it is considered that facilitating its potential regeneration by accommodating the relocated Tesco is by itself is a considerable public benefit of moderate weight (there would be s106 obligation to ensure there is not two stores open at the same time).

Conclusion on Balance

8.498 There are a range of public benefits that weigh in favour of the development as set out above, with there being significant weight to delivery of a substantial number of new homes and affordable housing, moderate weight to regeneration and public realm improvements, and low or limited weight to other benefits to the economy, and from the community space and ecology Additionally, the proposal would help make the larger Tesco Site available for significant regeneration with this considered a public benefit of moderate weight.

8.499 The harmful impacts on the significance of each heritage asset from the proposal, including cumulative effects from other development and overall heritage harm, are given great weight, but in each case and in respect of the overall planning balance of public benefits weighed against harms from the development these would be clearly outweighed by the collective public benefits of the development, and so the proposal is acceptable.

Compliance with the Development Plan

8.500 As noted the proposal would result in ‘less than substantial harm’ having regards to the NPPF, to a number of heritage assets in the surrounding area. Consequently there is some conflict with policies relating to conservation of heritage, namely LP HC1 and HC2, though HLP policy CC4 is not conflicted overall because the policy provides for the harm to be weighed against the public benefits.

8.501 However on balance, the conflict with the above policies is significantly outweighed by the degree of compliance of the proposal with the policies of the Development Plan overall and the extent that the public benefits discussed above contribute to achieving the social, economic and environmental objectives of the plan, and so the proposal is considered to comply with the Development Plan as a whole.

9.0 Equalities Duties

9.1 The public sector equality duty applies to all council decisions.

9.2 A public authority or any person who exercises public functions must, in the exercise of those functions, have due regard to the need to:

(a) eliminate discrimination, harassment, victimisation and any other conduct prohibited by or under the Act; (b) advance equality of opportunity between persons who share a relevant protected characteristic and persons who do not share it; (c) foster good relations between persons who share a relevant protected characteristic and persons who do not share it.

9.3 Having due regard to the need to advance equality of opportunity, this involves having due regard, in particular, to the need to:

(a) remove or minimise disadvantages suffered by persons who share a relevant protected characteristic that are connected to that characteristic; (b) take steps to meet the needs of persons who share a relevant protected characteristic that are different from the needs of persons who do not share it; (c) encourage persons who share a relevant protected characteristic to participate in public life or in any other activity in which participation by such persons is disproportionately low.

9.4 This shall include, in particular, but is not limited to steps to take account of disabled persons' disabilities.

9.5 The exercise of public functions must have due regard to the need to foster good relations between persons who share a relevant protected characteristic and those who do not, in particular, to the need to:

(a) tackle prejudice; and (b) promote understanding.

9.6 Compliance with these duties may involve treating some persons more favourably than others. This is not to be taken as permitting conduct that would otherwise be prohibited by or under the Act.

9.7 The relevant protected characteristics are: age; disability; gender reassignment; pregnancy and maternity; race; religion or belief; sex; marriage and civil partnership; and sexual orientation.

9.8 Due regard needs to be demonstrated in the decision making process and requires an analysis of the material with the specific statutory considerations in mind. It does not follow that the considerations raised will be decisive in a particular case the weight given to them will be for the decision maker. The equalities duty is not a duty to achieve a particular result. Some equalities considerations are covered under other legislation such as building control matters. Officers have in considering this application and preparing this report had regard to the public sector equality duty and have concluded that due regard has been given to the Council’s duty in respect of its equalities duties and that if approving or refusing this proposal the Council will be acting in compliance with its duties.

10.0 Planning Obligations

10.1 HLP IMP3 seeks to ensure that development proposals fully mitigate the impacts of the development on the area through a Section 106 Agreement, where necessary or appropriate, having regard to supplementary planning document and provide the CIL payments required by any charging scheduled, including the Mayor of London’s CIL. A payment or other benefit offered in a Section 106 agreement is not material to a decision to grant planning permission and cannot be required unless it complies with the provisions of the Community Infrastructure Levy Regulations 2010 (Regulation 122), which provide that the planning obligation must be:

(a) necessary to make the development acceptable in planning terms;

(b) directly related to the development; and

(c) fairly and reasonably related in scale and kind to the development.

10.2 The Section 106 agreement will not address all the impacts since some of these will be addressed by CIL, in order to satisfy the Regulation 122 tests above.

10.3 The NPPG provides guidance on use of planning obligations, which may impose a restriction or requirement, or provide for payment to make acceptable development proposals that might otherwise not be acceptable in planning terms..

10.4 The following draft Heads of Terms are likely to form the basis of the Section 106 Agreement if the application was to be approved, all of which are considered to satisfy the three Regulation 122 tests referred to above:

(i) 35% Affordable housing – 164 homes, 100% to be Social Rent/ London Affordable Rent, with early stage viability review if development has not progressed. 100% nomination right to Local Authority, with controls on delivery through a Registered Provider and restrictions on rental levels. There would be an early stage viability review to be undertaken if implementation has not commenced within two years of vacant possession of the site, with work to have progressed to an agreed stage. The applicant must demonstrate that they have further explored the use of grant funding to increase the affordable housing offer.

Bed size/ No. of London Affordable Rent/ Social Rent units Total persons General Need Wheelchair accessible 1B/2P 63 1 58 2B/3&4P 51 6 57 3B/4&5P 31 9 40 4B/6P 5 0 5 Total 148 16 164

(ii) Construction training – A contribution of £2,750 for every £1m construction costs or an agreed training strategy to assist skills and training of Hounslow residents or an agreed training strategy from the Berkeley Group.

(iii) Retail Restriction - New retail store cannot commence trading until trading has ceased on the existing Tesco Osterley store.

(iv) Job brokerage – An appropriate training and/or job brokerage programme to enable residents in the Council’s Area to gain the requisite skills to access or aspire to new job opportunities such as those presented by the Development

(v) Sustainable travel – Separate Travel Plans for both the Retail and Residential uses providing measures to encourage sustainable travel to and from the site to include an action plan, monitoring, review, and updates.The retail travel plan to include measures and incentives to reduce car borne trips especially in the peak hours, residential travel plan to include voucher for residents (£100 per household) for i. purchase of an Oyster card; ii. purchase of a rail card or other means of public transport; iii. purchase of a bicycle; iv. membership of a Car Club; or v. other offers available to voucher holders;

(vi) Residents’ parking permits – Restriction that prohibits residents of the new homes from obtaining parking permits for local CPZs.

(vii) Bus Service Improvement – A contribution of £1.7m to Transport for London for improvements to local bus network (£340,000 annually for 5 years).

(viii) Access review – A review of all accesses and junctions on the southern side of the A4 between the Site and the Grand Union Canal, and the junctions of the A4 with Shield Drive and Transport Avenue shall be undertaken. Improvements identified shall be agreed, with Transport for London, and completed prior to first occupation of the development (with any resultant changes to the public highway subject to section 278 Agreement under the Highways Act 1980, with TfL and/or the Council).

(ix) Community Space Plan – Plan for management of use of 200 sqm community space, free of charge for local community groups and users, and subsidised use for agreed uses that encourage education, health, cultural and social interaction and activities.

(x) CPZ/ Parking Monitoring and Review – To include:

i. Post implementation review of traffic on Northumberland Avenue and mitigation measures ii. CPZ consultation in the Northumberland Estate and Syon Lane Station CPZs to determine support to amend the hours of operation, if so then amend the Traffic Management Orders and signs, with a contribution of £33,200 and £8,050 respectively. If the consultation is negative then the remaining contribution is to be spent on other ways to mitigate traffic impacts of the development. iii. CPZ and parking reviews in the Marlborough Road CPZ and streets to the east (Brentford End) up to the disused railway line. Parking surveys to be undertaken pre and post-occupation and if there is an increase in parking then consultation in the Marlborough Road CPZ to amend the hours and if supported amend the MTO and signs, consultation on a new CPZ in the streets to the east and if supported implement a new CPZ.

(i) Car Club – Provision of a minimum of 2 car club spaces on-site, and free 3 year membership for each household of the development. The number of car club spaces to be reviewed with the car club operator and increased if demand is there.

(ii) Residential and Retail Car Park Management Plans – Management plans to control allocation of parking spaces, access, servicing, electric vehicle charging points, and actively managed disabled spaces. Split into residential and retail, to include retail parking charges at peak times and at times of peak usage, advanced car park signs on the A4 and Syon Lane (including a variable messaging sytem), mechanism to reduce retail spaces over time and reallocate, no allocation of spaces to residents.

(iii) Retail Car Parking Management – Retail parking charges at network peak times and at times of peak car park usage with charges to be based on, advanced car park signs on the A4 and Syon Lane, details to be agreed with council and TfL prior to occupation but to include in principle:

i. ANPR monitoring of the new Tesco car park occupation and length of stay should be undertaken by Tesco, for the first 12 months of occupation and reported monthly to the council. This will allow the monitoring to capture other seasonal peak times such as Christmas. ii. Subject to agreement with the Council and TfL, the monitoring and reporting can be reduced to quarterly monitoring for the following 12 months, and then 6 monthly until the Tesco Osterley site is fully occupied (and then annually). iii. A minimum stay charge, to be agreed in advance of occupation, will be applied during the peak traffic times, initially PM and Sat peak periods, for stay times less than a set duration, initially set at 60 minutes. The peak periods will be the network peak plus half an hour either side. iv. Other seasonal peak times may require additional management and charges. v. In addition to this, if car park capacity exceeds 95% at any other time, as highlighted by the monitoring, then the minimum stay charge will be applied for that 1-hour period also. vi. The maximum duration of stay should be maintained as originally proposed at 3 hours. vii. The final Car Parking Management Plan (CPMP) will need to include specific measures to discourage travel at the peak times identified by the car park monitoring.

(iv) ‘Clean Air’ Route – Completion of ‘Clean Air’ route on Syon Gate Way and eastern boundary of the Site prior to occupation of the development.

(v) Retail and Residential Delivery and Servicing Management Plans – Delivery and servicing management plans which are to ensure that any adverse impacts to the operation of road networks surrounding the Development Land as a result of deliveries to the Development are avoided remedied or mitigated.

(vi) Syon Park – A contribution of £20,000 towards improvements including strategic tree planting and/ or heritage interpretation (signage/ heritage trail etc).

(vii) Public Realm Improvements - Link – Prior to the operation of the new retail store, a scheme of public realm improvements between the Site and the Tesco Site, including environmental improvements to the existing underpass shall be agreed (up to a value of £135,320)

(viii) Carbon Offset Fund – Contribution to the Council’s Carbon offset fund of £1,128,600 prior to commencement of substructure works.

(ix) Considerate Contractors Scheme – A scheme regulating the manner in which any demolition and construction works are carried out submitted to and approved by the Council prior to any works being carried out.

(x) Hawthorn Hatch Open Space – Contribution of £25,000 towards improvements/ play for children aged 12+.

(xi) Hounslow Clinical Commissioning Group (Health Care) – Contribution of towards primary health care facilities in Brentford.

(xii) Planning Service (Legal) and Obligations Monitoring Costs – As per the Council’s fees and charges.

(xiii) Highways Works – Full details to be secured by a s278 Agreement under the Highways Act with TfL/ Hounslow but to include in principle:

i. Works to Gillette Corner required in advance of new store including ii. Additional right turn lane iii. New pedestrian/cycle crossing over the A4 (eastern arm of the junction) iv. Improved cycle lane on the A4 v. Relocated bus stop on A4 with new shelter vi. Relocation of on-street parking on Syon Lane vii. Changes to Syon Gate Way junction viii. New traffic signal access to the retail store ix. Improvements to the subway x. Review of Option 4 junction works with updated traffic surveys and modelling and construction of a controlled pedestrian cycle crossing on the Syon Lane (southern) arm of the junction if agreed by TfL all prior to occupation xi. Modifications to Northumberland Avenue junction to improve pedestrian facilities xii. Public realm on Syon Lane in including landscaping xiii. Cycle parking on Syon Lane and A4 xiv. Any agreed improvements to cycleway/paths between Gillette Corner and Boston Manor Road following the access review xv. Review of traffic flow on Northumberland Avenue – post occupation traffic survey of Northumberland Avenue and if an increase in traffic is recorded measures to prevent the use of the road as a rat-run are to be consulted on and implemented if supported.

(xiv) LOCAL FINANCE CONSIDERATIONS AND THE COMMUNITY INFRASTRUCTURE LEVY

11.1 Section 70(2) of the Town and Country Planning Act 1990 (as amended) provides that a local planning authority must have regard to a local finance consideration as far as it is material. A local finance consideration means:

a grant or other financial assistance that has been, or will or could be, provided to a relevant authority by a Minister of the Crown; or

b) sums that a relevant authority has received, or will or could receive, in payment of Community Infrastructure Levy (CIL).

11.2 The weight to be attached to a local finance consideration remains a matter for the decision maker. The Mayor of London's CIL and Hounslow CIL are therefore material considerations.

11.3 Most new development which creates net additional floor space of 100 square metres or more, or creates a new dwelling, is potentially liable to pay the CIL to Hounslow and the Mayor of London.

Floor space Existing lawful Demolished CIL Liable (Sqm) floor space floor space floorspace Residential 0 0 45,186.22 Retail 6,586 6,586 23,843.16 Other 0 0 182.62

11.4 This proposal would be liable to pay the CIL which is index linked.

11.5 The estimated Hounslow CIL payable is £11,146,919 and estimated Mayoral CIL payable is £4,190,472. The provisional total CIL is estimated at £15,337,391.

12.0 CONCLUSION

12.1 The proposal would comprehensively redevelop the Site, making best use of the land. The scheme would be consistent with the objectives of the Development Plan to focus growth of housing and employment within the Great West Corridor Opportunity Area, especially to optimise use of such sites for housing and in a manner that would promote more active travel.

12.2 The housing is high density with some tall and large scale buildings that would transform the Site. Although considerable change is proposed, the Site sits at the entrance to the Golden Mile and the new buildings would have a design that is appropriate for the Site and that has satisfactorily accounted for the surrounding context where different the townscape is of varying form and character. There are some harmful impacts on heritage assets locally and also from distance, through change to the setting of the assets, including to some items of the very highest significance. These harmful effects, which in each case cause ‘less than substantial harm’ to the significance of the assets, have been weighed against the public benefits of the proposal. It is noted that in this balancing exercise that harm to heritage assets must be given considerable importance and weight, and that finding such harm therefore gives rise to a strong presumption against planning permission being granted and this can only be outweighed by material planning considerations powerful enough to do so.

12.3 The development would deliver public benefits to the economic, social and environmental well-being of the area providing much needed new housing including 164 affordable homes, whilst relocating the existing Tesco superstore to the Site creates an opportunity for the comprehensive redevelopment of its current site, helping to further deliver objectives of the Great West Corridor Opportunity Area in the London Plan, which aligns with the spatial policies of the Hounslow Local Plan. This would also be consistent with the emerging Great West Corridor Local Plan and Site Allocations.

12.4 Planning obligations and conditions would secure various items of mitigation that would ensure other effects of the development are acceptable including within the site itself and on the general environment, transport network and neighbours. Although the development would result in reductions to daylight and sunlight to some windows of nearby properties, these would be minor and within the context of redevelopment of an urban site, with some flexibility from the relevant guidance acceptable as the neighbours’ living conditions would not be seriously harmed. The Environmental Statement and related information submitted with the application has adequately considered the effects on the environment and confirms that there would not be significantly adverse effects from the development, with conditions securing mitigation and monitoring where necessary.

12.5 Overall the development complies with the Development Plan, and it would bring a range of public benefits from the significant provision of new housing, affordable housing, regeneration of the Site and enhancement of the public realm including improved conditions for walking and cycling, increased economic activity and ecological enhancements, and it would facilitate the comprehensive redevelopment of the existing Tesco Site which would bring a similar range of benefits. Taking all these matters into account, the public benefits of the proposal outweigh the harmful impacts identified, and so approval is recommended.

13.0 RECOMMENDATION: APPROVE subject to a legal agreement.

1. That planning permission be granted with the following conditions (subject to any minor variation of condition wording) and securing the abovementioned planning obligations by the prior completion of a satisfactory legal agreement or unilateral undertaking made under Section 106 of the Town and Country Planning Act 1990 and of highways agreements under Sections 38 and 278 of the Highways Act 1980 (at the appropriate time) and or other appropriate legislation, the exact terms of which shall be negotiated by appropriate officers within the Housing, Planning and Communities Department on the advice of the Assistant Director Corporate Governance, subject to.

(i) The application being referred to the Mayor of London, in accordance with the Mayor of London Order 2008.

(ii) The application being referred to the Secretary of State, in accordance with retained Circular 02/09 (The Town and Country Planning (Consultation) (England) Direction 2009, noting the outstanding objection from Historic England that considers the development would have an adverse impact on the outstanding universal value, integrity, authenticity and significance of a World Heritage Site or its setting.

2. It is confirmed that the decision has taken into account has the environmental information;

3. A statement being placed on the Statutory Register in accordance with Regulation 30 of the Town and Country Planning (Environmental Impact Assessment) Regulations 2017, which contains the information required by Regulation 29(2) and the main reasons and considerations on which the Planning Committee’s decision was based were those set out in the report and a summary of the results of the consultations undertaken, and information gathered, in respect of the application and how those results have been incorporated or otherwise addressed;

4. The satisfactory legal agreement or unilateral undertaking outlined above shall be completed and planning permission issued by 8 July 2021 or such extended period as may be agreed in writing by appropriate officers within the Housing, Planning and Communities Department or within Legal Services.

5. If the legal agreement or unilateral undertaking is not completed by the date specified above (or any agreed extended period), then the Assistant Director for Planning and Development or Head of Development Management is hereby authorised to refuse planning permission for the reason that the proposal should include planning obligations required to make the development acceptable in planning terms in accordance with Regulation 122 of the Community Infrastructure Levy Regulations 2010, development plan policies and the Planning Obligations SPD, described in this Report.

6. Following the grant of planning permission, where (a) requested to enter into a deed of variation or legal agreement in connection with the planning permission hereby approved and by the person(s) bound by the legal agreement authorised in paragraph 1 above, and (b) where the planning obligations are not materially affected, and (c) there is no monetary cost to the Council, Assistant Director for Planning and Development or Head of Development Management is hereby authorised (in consultation with the Chair of the Planning Committee and upon the advice of the Assistant Director Corporate Governance) to enter into a legal agreement(s) (deed of variation) made under Sections 106 and/or 106A of the Town and Country Planning Act 1990 and or other appropriate legislation.

7. If planning permission is refused following the failure to sign the S106 in time, the Assistant Director for Planning and Development or Head of Development Management (in consultation with the Chair of the Planning Committee) is hereby authorised to approve any further application for planning permission validated within 12 months of the date of refusal of planning permission, provided that it (a) duplicates the planning application, and (b) that there has not been any material change in circumstances in the relevant planning considerations, and (c) that a satisfactory legal agreement or unilateral undertaking securing the obligations set out in the Report is completed within any specified period of time.

CONDITIONS

Time Limit 1. The Development hereby approved, shall be begun no later than the expiration of three years from the date of this permission.

Reason. To accord with the provisions of Section 92(1) of the Town and Country Planning Act 1990.

Approved drawings 2. The proposed development shall be carried out in all respects in accordance with the proposals contained in the application and the plans submitted (see schedule below) therewith and approved by the Local Planning Authority.

Reason. To ensure the development is carried out in accordance with the planning permission and to ensure that any development that is carried out is that which has been assessed.

Construction Logistics Plan 3. No demolition or construction shall take place until a detailed Construction Logistics Plan (CLP) has been submitted and approved by the Local Planning Authority in liaison with Transport for London. The CLP shall cover as a minimum:

- a site plan (showing the areas set out below) - confirmation that a pre-start record of site conditions on the adjoining public highway will be undertaken with Hounslow Highways and a commitment to repair any damage caused - provision for the parking of vehicles of site operatives and visitors - provisions for loading, unloading and storage of plant and materials within the site - details of access to the site, including means to control and manage access and egress of vehicles to and from the site for the duration of construction including phasing arrangements - details of vehicle routeing from the site to the wider strategic road network - the erection and maintenance of security hoarding including decorative displays and facilities for public viewing, where appropriate - provision of wheel washing facilities at the site exit and a commitment to sweep adjacent roads when required and at the reasonable request of the council - a scheme for recycling/disposing of waste resulting from demolition and construction works - measures to ensure the safety of all users of the public highway especially cyclists and pedestrians in the vicinity of the site and especially at the access - commitment to liaise with other contractors in the vicinity of the site to maximise the potential for consolidation and to minimise traffic impacts - avoidance of network and school peak hours for deliveries and details of a booking system to avoid vehicles waiting on the public highway - the use of operators that are members of TfL’s Freight Operator Recognition Scheme (FORS) - all necessary traffic orders and other permissions required to allow safe access to the site to be secured and implemented prior to commencement of construction - details of the construction programme and a schedule of traffic movements - all deliveries to take place between 9.30am-3.00pm unless agreed in advance with the council All construction and demolition works shall be undertaken in accordance with the approved CLP.

Reason. In order to protect the environmental quality of the surrounding area and to ensure that deliveries to the site during construction are managed effectively so as to minimise impact upon the road network and to safeguard the amenities of residential properties in the locality and in the interest of road safety, in accordance with Local Plan policies CC1, CC2, EQ5, EQ4, EQ6 and EC2 of the adopted Local Plan Policy. This condition needs to be pre-commencement because to assess these details at a later stage may prevent achievement of Local Plan requirements.

Construction Environmental Management Plan 4. No demolition or construction shall take place until a detailed Construction Logistics Plan (CLP) has been submitted to and approved in writing by the Local Planning Authority. The CEMP shall provide details of how demolition and construction works are to be undertaken and include:

- The identification of stages of works; - Setting of appropriate noise criteria, trigger levels and how exceedances of those levels will be responded to by the construction contractor - Detailed calculation of noise and vibration of the construction phases based upon the latest and most up to date information - Details of working hours, which unless otherwise agreed with the Local Planning Authority shall be limited to 08.00 to 18.00 Monday to Friday and 08.00 to 13.00 on Saturdays); - Procedures for maintaining good public relations including complaint management, public consultation and liaison; - Monitoring of construction noise levels affecting the nearest noise sensitive receptors. - Review and implementation of mitigation measures (as appropriate) as defined in BS 5228: Parts 1 and 2: 2009 Noise and Vibration Control on Construction and Open Sites shall be undertaken to ensure noise disturbance from construction works is minimised. - Dust suppression measures

Reason: In order to safeguard the amenities of adjoining residents and the amenities of the locality in accordance with Local Plan policies CC1, CC2 and EQ5.

Hours of Work 5. No demolition or construction work shall take place on the site except between the hours of 8am to 6pm on Mondays to Friday and 9am to 1pm on Saturdays and not at all on Sundays and Public Holidays without the prior written agreement of the Local Planning Authority.

Reason: In order to safeguard the amenities of adjoining residents and the amenities of the locality in accordance with Local Plan policies CC1, CC2 and EQ5.

Samples of Materials 6. No development (except demolition, archaeological investigations, ground condition investigations and intrusive site surveys and other enabling works: site clearance; soil storage; remedial works in respect of any contamination or any other adverse ground conditions; erection of any temporary means of enclosure and land raising) shall take place until details and samples of all facing materials are submitted to and approved in writing by the Local Planning Authority. The samples and details shall include:

i. brick/stonework (including brick/stone and mortar on-site sample panel min. 2m x 2m); ii. cladding materials (including system specifications/details and on-site samples (where relevant); iii. window treatment (including sections/reveals and on-site sample); and iv. privacy measures, (including obscure glazing details - including where separation distances between habitable room windows are less than 18m - privacy screens - etc.); v. balustrading treatment (including details/sections/materials for each balcony type) vi. any other materials/details to be used. The development shall then be carried out in accordance with the approved details and maintained as such thereafter.

Reason. In order to safeguard the visual amenity of the area and buildings in particular and to satisfy the requirements of policies CC1, CC2, CC3 and SC4 of the Local Plan and London Plan policies D3, D4, D8 and D9.

Landscape Plan 7. Prior to the commencement of the development (except demolition, archaeological investigations, ground condition investigations and intrusive site surveys and other enabling works: site clearance; soil storage; remedial works in respect of any contamination or any other adverse ground conditions; erection of any temporary means of enclosure and land raising), details of both hard and soft landscape works shall be submitted to and approved in writing by the Local Planning Authority. The works shall then be carried out as approved.

The detailed landscaping scheme shall include: - soft planting: including any grass and turf areas, trees, planters, shrub and herbaceous areas including details of species, sizes, numbers/densities and sections of landscaped areas; - a 'Tree Planting Statement' providing full details, locations, specifications and construction methods for all purpose-built tree pits and associated above ground features, including specifications for tree protection and a stated volume of suitable growing medium to facilitate and promote the healthy development of the proposed trees, ensuring each tree has a soil volume equivalent of 0.6 times its canopy area at maturity; - hard landscaping: including ground surfaces, kerbs, edges, ridge and flexible paving, furniture, steps, refuse disposal points and if applicable synthetic surfaces for both ground level and roof terrace level (where relevant); - fences and walls and any other boundary treatments; - visitor cycle parking spaces; - quiet zones protected from excessive noise levels; - play spaces and play equipment - any signage and information boards; - brown and green (biodiversity) roofs and green walls ; - any CCTV equipment; - an external lighting strategy; and - any other landscaping feature(s) forming part of the scheme.

The submission shall include a management programme for the lifetime of the development, which shall include: long term design objectives, management responsibilities and maintenance schedules for all hard and soft landscape areas, and details of any temporary landscaping (including boundary treatment) to be provided and management thereof.

All landscaping comprised in the approved details shall be carried out during the first planting and seeding seasons following completion of construction works. Any trees or shrubs planted (including any such replacements) which die within three years from the date of planting shall be replaced in the next planting season with the same species, and of comparable maturity. The development shall be carried out strictly in accordance with the details so approved (including the River Walk delivery programme) and shall be maintained in accordance with the approved management programme.

Reason: To ensure a satisfactory appearance of the site and the adjacent the area, that the development will be accessible to all and in order that the Local Planning Authority may be satisfied that there will be ecological enhancements and as to the management of minor artefacts and structures, in accordance with Local Plan policies CC1, CC2 and GB7, and London Plan policy S4

Retained Trees 8. Prior to the commencement of development, a scheme for the protection of the retained trees, in accordance with BS5837:2012 shall be submitted to and approved in writing by the Local Planning Authority. The scheme shall include: a) A plan to a scale and level of accuracy appropriate to the proposal that shows the position, crown spread and Root Protection Area of every tree on site in relation to the approved plans and particulars. The positions of all trees to be removed shall be indicated on this plan. b) A schedule of tree works for all the retained trees, specifying pruning and other remedial or preventative work, whether for physiological, hazard abatement, aesthetic or operational reasons. All the tree work shall be carried out in accordance with BS3998:2010 – Tree Work – Recommendations. c) The details and positions (shown on plan at paragraph (a) above) of the Tree Protection Barriers, identified separately where required for different phases of construction work. The Tree Protection Barriers must be erected prior to each phase of construction commencing and remain in place, and undamaged for the duration of that phase. No works shall take place on the next phase until the Tree Protection Barriers are repositioned for that phase. d) The details and positions of any underground service runs shall be shown on the plan required at paragraph (a). The erection of fencing for the protection of any retained tree or hedge shall be carried out in complete accordance with BS5837:2012, before any equipment, machinery, or materials are brought onto the site for the purposes of development or other operations. The fencing shall be retained intact for the full duration of the development until all equipment, materials and surplus materials have been removed from the site. If the fencing is damaged all operations shall cease until it is repaired in accordance with the approved details. Nothing shall be stored or placed in any fenced area in accordance with this condition and the ground levels within those areas shall not be altered, nor shall any excavations be made without the written approval of the Local Planning Authority.

Reason: To enable the Local Planning Authority to ensure the retention of the maximum number of trees on the site and their protection from damage, in the interests of biodiversity and visual amenity area and to accord with policies CC1, CC2 and GB7 of the adopted Local Plan. This condition needs to be pre- commencement because to assess these details at a later stage may prevent achievement of Local Plan requirements.

Wheelchair Units 9. A minimum of 10% of the total dwellings shall be ‘Wheelchair User Dwellings’ built to Building Regulations M4(3) standard shall be provided as identified on the approved plans. All other dwellins shall be designed so that they meet building regulation M4 (2) 'accessible and adaptable dwellings'

Reason: To ensure a socially inclusive and sustainable development in accordance with Local Plan Policy SC3 and policies 3.5 (Quality and design of housing developments).

Housing Waste and Recycling 10. No part of the development shall be occupied until a Watse Management Strategy showing full details of the waste and recycling facilities, including management of storage areas, internal collection and collection from the site, for the relevant residential element of the development, has been submitted to the Local Planning Authority for approval in writing. The waste and recycling facilities shall be provided in accordance with the agreed details prior to occupation of the relevant residential element and such facilities shall remain throughout the lifetime of the development and shall be used for no other purposes.

Reason: To ensure that refuse can be properly stored and removed from the site as soon as the building is occupied in accordance with Local Plan Policies CC1, CC2 and EQ7.

Commercial Waste and Recycling 11. No commercial unit shall be occupied untill full details of the waste and recycling facilities, including management of storage areas, internal collection and collection from the site, for the relevant commercial unit of the development, has been submitted to the Local Planning Authority for approval in writing. The waste and recycling facilities shall be provided in accordance with the agreed details prior to occupation of the relevant commercial unit and such facilities shall remain throughout the lifetime of the development and shall be used for no other purposes.other. No refuse or recycling waste bins shall be stored outside the building.

Reason: To ensure that refuse can be properly stored and removed from the site as soon as the building is occupied in accordance with Local Plan Policies CC1, CC2 and EQ7.

Residential Cycle Parking 12. Notwithstanding the details shown on the approved plans, prior to the commencement of the development (except demolition, archaeological investigations, ground condition investigations and intrusive site surveys and other enabling works: site clearance; soil storage; remedial works in respect of any contamination or any other adverse ground conditions; erection of any temporary means of enclosure and land raising), full details (including manufacturers’ specifications) of residential cycle parking facilities including storage, access and lifts shall be submitted to and approved in writing by the Local Planning Authority. The approved facilities shall conform to current guidance from Chapter 8 of the London Cycling Design Standards in design and layout as at the date of permission and be fully implemented and made available for use before the first occupation of the development and thereafter retained for use at all times without obstruction.

Reason: To support sustainable transport objectives in accordance with adopted local plan policy EC2 and London Plan policy T5.

Residential Electric Vehicle Charging Spaces 13. Prior to the occupation of the residential element of the development hereby permitted, details of the number, location and management of electric vehicle charging points associated with the residential element of the development shall be submitted to and approved in writing by the Local Planning Authority. This shall include a minimum 20% ‘active’ Electric Vehicle Charging spaces and the remainder ‘passive’ Electric Vehicle Charging spaces. The development shall be carried out in accordance with the approved details.

Reason: In order to prevent obstruction and inconvenience to users of the adjacent highway and the premises, in the interests of road safety and in order to promote sustainable transport modes in accordance with policies CC1, CC2 and EC2 of the adopted Local Plan.

Non-residential Cycle Parking 14. Notwithstanding the details shown on the approved plans, prior to the commencement of the development (except demolition, archaeological investigations, ground condition investigations and intrusive site surveys and other enabling works: site clearance; soil storage; remedial works in respect of any contamination or any other adverse ground conditions; erection of any temporary means of enclosure and land raising), full details (including manufacturers’ specifications) of commercial/ foodstore cycle parking facilities including storage, access and lifts shall be submitted to and approved in writing by the Local Planning Authority. The approved facilities shall conform to current guidance such as the TfL London Cycling Design Standards in design and layout as at the date of permission and be fully implemented and made available for use before the first occupation of the development and thereafter retained for use at all times without obstruction.

Reason: To support sustainable transport objectives in accordance with adopted local plan policy EC2 and London Plan policy T5.

Foodstore Electric Vehicle Charging Spaces

15. Prior to the Prior to operation of the foodstore, details of the number, location and management of electric vehicle charging points associated with the foodstore car parking shall be submitted to and approved in writing by the Local Planning Authority. This shall include a minimum 10% ‘active’ Electric Vehicle Charging spaces and the remainder ‘passive’ Electric Vehicle Charging spaces The development shall be carried out in accordance with the approved details

Reason: In order to prevent obstruction and inconvenience to users of the adjacent highway and the premises, in the interests of road safety and in order to promote sustainable transport modes in accordance with policies CC1, CC2 and EC2 of the adopted Local Plan.

Heat Network Safeguarding 16. Prior to the commencement of development, evidence should be submitted to the Local Planning Authority and approved in writing to show that the development has made sufficient provisions to enable the connection to a feasible district heating network in the future including a safeguarded pipe route for future connection at the site boundary. The approved building shall be constructed and completed in accordance with the agreed details

Reason: To ensure that the development makes the fullest contribution to minimising carbon dioxide emissions in accordance with the London Borough of Hounslow Local Plan Policy EQ1 and London Plan policy SI2.

Water Use 17. Prior to first occupation of each residential block evidence (schedule of fittings and manufacturer's literature) should be submitted to the Local Planning Authority and approved in writing to show that the development has been constructed in accordance with the approved internal water use calculations and an internal water use of 105L/person/day or less is achieved.

Reason: in order to protect and conserve water supplies and resources in accordance with London Borough of Hounslow Local Plan Policy EQ2.

Wind Microclimate 18. Prior to occupation of any residential unit, wind mitigation measures detailed in pragraph 13.111 of the Environmental Statement shall be installed and completed, and further details of mitigation for locations 45, 59, 62, 66 and 171 shall have been submitted to the Local Planning Authoruty and approved in wiriting with the submitted details to demonstrate that the proposed mitigation results in acceptable conditions in terms of safety and comfort within and around the development Any further approved mitigation shall be installed and completed prior to occupation of any residential unit

Reason: To ensure a safe and comfortable environment for people at the Site in accordance with Hounslow Local Plan policy CC3 and London Plan policy D9.

BREEAM – Design Stage Certificate 19. Prior to the commencement of above ground works, a Design stage BREEAM Retail New Construction Shell only Design Stage certificate and summary score sheet (or such equivalent standard that replaces this) must be submitted to and approved in writing by the Local Planning Authority to show that an ‘Excellent’ (minimum score 70%) rating will be achieved.

Reason: To ensure that the development makes the fullest contribution to minimising carbon dioxide emissions in accordance with according with LP policies SI2 and HLP policies EQ1 and EQ2. BREEAM – Post Construction Review Certificate 20. Within six months of operation of the foodstore, a post-construction stage BREEAM Retail New Construction Shell only Design Stage certificate and summary score sheet (or such equivalent standard that replaces this) must be submitted to and approved in writing by the Local Planning Authority to show that an ‘Excellent’ (minimum score 70%) rating has been achieved.

Reason: To ensure that the development makes the fullest contribution to minimising carbon dioxide emissions in accordance with according with LP policies SI2 and HLP policies EQ1 and EQ2.

Crane Safety 21. Prior to commencement of piling, details of cranes and other tall construction equipment (Including the details of obstacle lighting) shall be submitted to and approved by the Local Planning Authority. Such details shall comply with Advice Note 4 ‘Cranes’ (available at http://www.aoa.org.uk/wp- content/uploads/2016/09/Advice-Note-4-Cranes-2016.pdf). The approved strategy (Or any variation approved in writing by the Local Planning Authority) shall be implemented prior to commencement of piling for the duration of the remaining construction period.

Reason: In the interests of public safety.

Air Quality Monitoring 22. For a minimum of 3 months prior to the occupation of the residential element and for a minimum of 12 months after completion of the development hereby permitted, diffusion tube monitoring will be undertaken at the proposed development site on the corner of Syon Lane and Great West Road and along Great West Road at proposed locations with relevant exposure to air quality objectives at heights of 2, 4, 6, and 8m. If at any time during this monitoring the annual average measurement exceeds 36ug/m3 the monitoring should continue until levels fall below 36ug/m3 for a minimum period of 12 months annual average and provision should be made for filtered mechanical ventilation for facades represented by the monitoring exceeded. The filtered mechanical ventilation should be installed and maintained at any occupied dwellings throughout the duration of the monitoring. The diffusion tube monitoring will utilise the same methodology as stated within Appendix 8.3 Ramboll Monitoring Study (Osterley Place, Tesco Osterley Site, TW7 5NZ. Volume 1: Environmental Statement Main Report Undertaken by Ramboll UK Limited, September 2020. Ref: 1620006465 Issue: Final)

Reason: To ensure satisfactory living conditions and minimise air pollution in accordance with Local Plan policy EQ4 and London Plan policy SI1.

Fixed Plant Noise 23. The cumulative noise from any fixed external plant associated with the scheme should not exceed levels more than 5 dB below representative background (LA90) levels at free field locations representing facades of nearby existing and proposed dwellings. Noise levels should be assessed by measurement or calculation based on the guidance presented within BS4142: 2014+A1:2019 or subsequent versions of this guidance.

Reason: To protect the amenities of existing and future residents in accordance with Local Plan policy EQ5 and London Plan policy D14.

Noise Levels Within Dwellings 24. Maximum noise levels permitted within the dwellings will not exceed those that are specified in Table 4 of British Standard 8233:2014 [Living Rooms = 35 dB LAeq, 16 hours; Dining room/area = 40 dB LAeq, 16 hours; Bedroom = 35 dB LAeq, 16 hours during day-time (07:00 - 23:00) and Bedroom = 30 dB LAeq, 8 hours during night- time (23:00 - 07:00), night-time (23:00 – 07:00) LAmax noise levels within bedrooms do not exceed 45 dB LAmax more than 10 to 15 times per night. The maximum noise levels described must be achieved during background ventilation rates as defined in Part F of the Building Regulations.

Reason: To protect the amenities of residents in accordance with Local Plan policy EQ5 and London Plan policy D14.

Internal Noise Transmission – Commercial-Residential 25. Details shall be submitted to the Local Planning Authority for approval prior to the commencement of construction works of the sound insulation of the floor/ ceiling/ walls separating the commercial and communal part(s) of the premises from dwellings. Details shall demonstrate that the sound insulation value DnT,w [and L'nT,w where appropriate] is enhanced by at least 10-15dB above the Building Regulations value and, where necessary, additional mitigation measures are implemented to contain commercial/ communal noise the commercial/communal areas and to achieve the criteria of BS8233:2014 within the dwellings/ noise sensitive premises. Approved details shall be implemented prior to occupation of the development and thereafter be permanently retained. Upon completion, the on-site performance of these elements will be demonstrated during pre-completion acoustic testing.

Reason: To protect the amenities of existing and future residents in accordance with Local Plan policy EQ5 and London Plan policy D14

Sound Insultation From External Noise Source 26. Prior to the residential element being occupied, facade sound insulation tests shall be submitted to and approved in writing by the Local Planning Authority. Noise tests shall be carried out taking account of worst-case environmental conditions, such as easterly operations at Heathrow, peak time traffic flows wind speed. Continuous logged data shall be submitted.

Reason: To protect the amenities of residents in accordance with Local Plan policy EQ5 and London Plan policies D13 and D14.

Contamination 27. Before the development hereby permitted commences:

a. Details of further intrusive site investigation are required in addition to the phase 1 desk study and phase 2 intrusive investigation previously submitted. These details shall be submitted to, and approved in writing by, the Local Planning Authority. The site shall be investigated by a competent person to identify the extent and nature of contamination. The report should include a tiered risk assessment of the contamination based on the proposed end use of the site. Additional investigation may be required where it is deemed necessary.

b. If required, a scheme for decontamination of the site shall be submitted to the Local Planning Authority, for written approval. The scheme shall account for any comments made by the Local Planning Authority before the development hereby permitted is first occupied.

During the course of the development:

c. The Local Planning Authority shall be notified immediately if additional contamination is discovered during the course of the development. A competent person shall assess the additional contamination, and shall submit appropriate amendments to the scheme for decontamination in writing to the Local Planning Authority for approval before any work on that aspect of development continues.

Before the development is first brought into use:

d. The agreed scheme for decontamination referred to in clauses b) and c) above, including amendments, shall be fully implemented and a written validation (closure) report submitted to the Local Planning Authority for approval.

Reason: Contamination is known or suspected on the site due to a former land use. The LPA therefore wishes to ensure that the development can be implemented and occupied with adequate regard for public and environmental safety.

Air Quality - Construction Machinery 28. All Non-Road Mobile Machinery (NRMM) of net power of 37kW and up to and including 560kW used during the course of the demolition, site preparation and construction phases shall comply with the emission standards set out in chapter 7 of the GLA’ Supplementary Planning Guidance “Control of Dust and Emissions During Construction and Demolition” dated July 2014 (SPG), or subsequent guidance. The developer shall keep an up to date list of all NRMM used during the demolition, site preparation and construction phases of the development on the online register at: https://nrmm.london/

The developer shall also demonstrate that proposed development is compliant with Building Emissions Benchmarks (BEBs), specified in GLA’s Sustainable Design and Construction SPG (Apr. 2014).

Reason: To minimise air pollution in accordance with Local Plan policy EQ4 and London Plan policy SI1.

Weed Removal 29. Prior to the commencement of above ground works, a detailed method statement for the treatment and long-term management of the Japanese Knotweed on the site will be submitted to and approved in writing by the Local Planning Authority.

Reason: To remove noxious weeds from the environment.

Habitat Management and Monitoring Plan 30. Prior to the commencement of above ground works, a Habitat Management and Monitoring Plan shall be submitted to and approved in writing by the Local Planning Authority. The agreed plan shall be carried out and adhered to thereafter.

Reason: To secure improvement in biodiversity at the site in accordance with Local Plan policy EQ4 and London Plan policies G6 and G7.

Bird Hazard Management Plan 31. Prior to the commencement of above ground works a Bird Hazard Management Plan should be submitted to and approved in writing by the Local Planning Authority. The submitted plan shall include details of:

- Management of any flat/shallow pitched/green roofs on buildings within the site which may be attractive to nesting, roosting and “loafing” birds.

The Bird Hazard Management Plan shall be implemented as approved and shall remain in force for the life of the building. No subsequent alterations to the plan are to take place unless first submitted to and approved in writing by the Local Planning Authority

Reason: In the interests of aviation safety.

Sustainable Materials 32. A. No development (except demolition, archaeological investigations, ground condition investigations and intrusive site surveys and other enabling works: site clearance; soil storage; remedial works in respect of any contamination or any other adverse ground conditions; erection of any temporary means of enclosure and land raising) shall take place until details have been submitted to and approved by the Local Planning Authority that: - At least three of the key elements of the building envelope (external walls, windows roof, upper floor slabs, internal walls, floor finishes/coverings) are to achieve a rating of A+ to D in the Building Research Establishment (BRE) The Green Guide of specification. - At least 50% of timber and timber products are to be sourced from accredited Forest Stewardship Council (FSC) or Programme for the Endorsement of Forestry Certification (PEFC) scheme. - Detail measures taken to avoid construction or insulation materials which will release toxins into the internal and external environment, including those that deplete stratospheric ozone.

B. The development shall not be occupied until evidence (e.g. photographs and copies of installation contracts) have been submitted to the Local Planning Authority to demonstrate that the development has been carried out in accordance with the approved details under Part A of this condition.

Reason: in order to ensure the sustainable sourcing of materials in accordance with the Mayor of London’s Sustainable Design and Construction SPG.

Energy Strategy 33. A) The development hereby permitted shall be implemented in accordance with the approved Energy Strategy. B) Prior to first occupation of any dwelling within the development hereby approved evidence (e.g. photographs, installation contracts and As-Built certificates under the Standard Assessment Procedure/National Calculation Method) should be submitted to the Local Planning Authority and approved in writing to show that the development has been constructed in accordance with the approved Energy Strategy, and any subsequent approved revisions, and achieved a minimum 51% reduction in emissions. C) Upon final commencement of operation of any low and zero carbon technologies, suitable devices for the monitoring of the low and zero carbon technologies shall have been installed, and the monitored data shall be submitted automatically to a monitoring web-platform at daily intervals for a period of three years from the point of full operation. Reason: To ensure that the development makes the fullest contribution to minimising carbon dioxide emissions in accordance with according with LP policies SI2, Si3 and SI4 and HLP policies EQ1 and EQ2.

Solar PV Roof Panels 34. Prior to commencement of relevant part plans, elevations and sections of the roof showing the photovoltaic array should be submitted for approval to the Local Planning Authority showing how the required quantity of PV will be accommodated. The photovoltaic array shall be implemented in accordance with the approved details and retained and properly maintained permanently thereafter

Reason: To ensure that the development makes the fullest contribution to minimising carbon dioxide emissions in accordance with according with LP policies SI2 and HLP policies EQ1 and EQ2.

Residential Car Park Management Plan 35. Prior to the first occupation of the residential element of the development hereby approved, a Car Parking Management Plan shall be submitted to and approved in writing by the Local Planning Authority. The Plan shall include the following:

i. details of parking allocations and how this will be operated and enforced ii. details of measures proposed to restrict parking to designated bays only and prohibit unauthorised parking and stopping iii. a commitment to convert passive EV bays to active when demand requires.

The car parking areas shall thereafter be managed in compliance with the approved Parking Management Plan.

Reason: In order to promote sustainable modes of transport and safeguard the amenities of surrounding residential properties and ensure minimal disruption of traffic in the locality, in accordance with policy EC2 of the adopted Local Plan and London Plan policies T6 and T6.1.

Commercial Car Park Management Plan 36. Prior to the first occupation of the residential element of the development hereby approved, a Car Parking Management Plan shall be submitted to and approved in writing by the Local Planning Authority. The Plan shall include the following:

i. details of parking allocations and how this will be operated and enforced ii. details of measures proposed to restrict parking to designated bays only and prohibit unauthorised parking and stopping iii. a commitment to convert passive EV bays to active when demand requires. iv. A commitment to reduce car parking.

The car parking areas shall thereafter be managed in compliance with the approved Parking Management Plan.

Reason: In order to promote sustainable modes of transport and safeguard the amenities of surrounding residential properties and ensure minimal disruption of traffic in the locality, in accordance with policy EC2 of the adopted Local Plan and policies T6, T6.3 and T6.5 of the London Plan.

Foodstore Opening Hours 37. The foodstore hereby permitted shall not be open to customers other than between 07:00am and 22:00pm Monday to Saturday and 10:00am – 4:00 pm on Sundays.

Reason: To protect the amenities of existing and future residents in accordance with Local Plan policy EQ5 and London Plan policy D14.

Secure by Design 38. The development shall achieve 'Secured by Design' accreditation awarded by the Design-Out Crime Officer from the Metropolitan Police Service on behalf of the Association of Chief Police Officers (ACPO). No dwelling shall be occupied until accreditation has been achieved and evidence of such accreditation has been submitted to and approved in writing by the Local Planning Authority.

Reason: To minimise opportunities for crime and to increase safety for people in the locality.

Drainage 39. Prior to commencement of groundworks (excluding site investigations and demolition), the applicant must submit a final detailed drainage design including drawings and supporting calculations and updated Drainage Assessment Form to the Lead Local Flood Authority for review and approval, aligned with the September 2020 Flood Risk Assessment and associated drawings. A detailed management plan confirming routine maintenance tasks for all drainage components must also be submitted to demonstrate how the drainage system is to be maintained for the lifetime of the development.

Reason: To prevent the risk of flooding to and from the site in accordance with relevant policy requirements including but not limited to London Plan Policy 5.13, its associated Sustainable Design and Construction SPG, the Non-Statutory Technical Standards for Sustainable Drainage Systems and Hounslow Council’s Local Plan Policy EQ3.

Drainage Implementation 40. No building hereby permitted shall be occupied until evidence (photographs and installation contracts) is submitted to demonstrate that the sustainable drainage scheme for the site has been completed in accordance with the submitted details. The sustainable drainage scheme shall be managed and maintained thereafter in accordance with the agreed management and maintenance plan for all of the proposed drainage components.

Reason: To comply with London Plan (Policies S12 and SI13) along with associated guidance to these policies and Hounslow Council’s Local Plan Policy EQ3.

Sewer Connection 41. The Prior to the occupation of the residential element of the development hereby permitted, a development and infrastructure phasing plan must be agreed with Thames Water. Where a development and infrastructure phasing plan is agreed no occupation of the residential element of the development hereby permitted shall take place other than in accordance with the agreed housing and infrastructure phasing plan.

Reason: To ensure adequate infrastructure is provided for the development.

Permitted Development 42. Notwithstanding the provisions of the Town and Country Planning (General Permitted Development) (England) Order 2015 (or any order revoking or re-enacting that order) no change of use under Part 3 Class M or Class O, Class PA, enlargement of the premises or any additional structures/buildings within the curtilage of the site shall be carried out.

Reason: In the interests of the amenity of the area and order not that the Local Planning Authority is able to exercise control over future development of the site in accordance with CC1, CC2, TC4 and EQ5 of the adopted Local Plan Policies.

INFORMATIVES

1) To assist applicants, the London Borough of Hounslow has produced planning policies and written guidance, all of which is available on the Council's website and which has been followed in this instance. The decision was made in a timely manner

2) The proposed development is located within 15m of Thames Water’s underground assets, as such the development could cause the assets to fail if appropriate measures are not taken. Please read our guide ‘working near our assets’ to ensure your workings are in line with the necessary processes you need to follow if you’re considering working above or near our pipes or other structures. https://protecteu.mimecast.com/s/P_cwCv88jhAVm75CXWgowh?domain=eur01.safelinks.p rotection.outlook.com. Should you require further information please contact Thames Water. Email: [email protected]

Approved Drawings Schedule

579-PTA-ZZ-06-DR-A-1001_P32; 579-PTA-ZZ-07-DR-A-1001_P31; 579-PTA-ZZ-08-DR-A- 1001_P28; 579-PTA-ZZ-09-DR-A-1001_P27; 579-PTA-ZZ-10-DR-A-1001_P26; 579-PTA- ZZ-11-DR-A-1001_P28; 579-PTA-ZZ-12-DR-A-1001_P28; 579-PTA-ZZ-13-DR-A- 1001_P27; 579-PTA-ZZ-14-DR-A-1001_P27; 579-PTA-ZZ-15-DR-A-1001_P22; 579-PTA- ZZ-16-DR-A-1001_P22; 579-PTA-ZZ-B1-DR-A-1001_P33; 579-PTA-ZZ-M1-DR-A- 1001_P23; 579-PTA-ZZ-RF-DR-A-1001_P11; 579-PTA-ZZ-ZZ-DR-A-0051_P04; 579-PTA- ZZ-ZZ-DR-A-0100_P02; 579-PTA-ZZ-ZZ-DR-A-1000_P04; 579-PTA-ZZ-ZZ-DR-A- 1001_P02; 579-PTA-ZZ-ZZ-ELE-A-0001_P08; 579-PTA-ZZ-ZZ-ELE-A-0002_P09; 579- PTA-ZZ-ZZ-ELE-A-0003_P09; 579-PTA-ZZ-ZZ-ELE-A-0004_P07; 579-PTA-ZZ-ZZ-ELE-A- 0005_P08; 579-PTA-ZZ-ZZ-ELE-A-0006_P07; 579-PTA-ZZ-ZZ-ELE-A-0007_P06; 579- PTA-ZZ-ZZ-ELE-A-0008_P07; 579-PTA-ZZ-ZZ-ELE-A-0009_P06; 579-PTA-ZZ-ZZ-ELE-A- 0010_P08; 579-PTA-ZZ-ZZ-ELE-A-0011_P07; 579-PTA-ZZ-ZZ-ELE-A-0012_P07; 579- PTA-ZZ-ZZ-ELE-A-0101_P04; 579-PTA-ZZ-ZZ-ELE-A-0102_P04; 579-PTA-ZZ-ZZ-ELE-A- 0103_P04; 579-PTA-ZZ-ZZ-ELE-A-0104_P04; 579-PTA-ZZ-ZZ-SEC-A-0001_P08; 579- PTA-ZZ-ZZ-SEC-A-0002_P07; 579-PTA-ZZ-ZZ-SEC-A-0101_P02; 579-PTA-ZZ-00-DR-A- 0105_P02; 579-PTA-ZZ-00-DR-A-0106_P02; 579-PTA-ZZ-00-DR-A-1001_P37; 579-PTA- ZZ-01-DR-A-1001_P43; 579-PTA-ZZ-02-DR-A-1001_P50; 579-PTA-ZZ-03-DR-A- 1001_P37; 579-PTA-ZZ-04-DR-A-1001_P32; 579-PTA-ZZ-05-DR-A-1001_P36; 579-PTA- ZZ-ZZ-SK-A-0270_P02; 579-PTA-ZZ-ZZ-SK-A-0271_P02; 579-PTA-ZZ-ZZ-SK-A- 0272_P02; 579-PTA-ZZ-ZZ-SK-A-0273_P02; 579-PTA-ZZ-ZZ-SK-A-0274_P02.

Design and Access Statement September 2020; Design and Access Statement Addendum January 2020; Flood Risk Assessment September 2020; FRA Addendum & Drainage Assessment Form January 2021; Transport Assessment (including Road Safety Audit, ATZ Route Assessment) January 2021; Energy Statement March 2021; Sustainability Statement March 2021; Ecological Assessment and Biodiversity Report September 2020; Biodiversity Net Gain Assessment January 2021; Geo-Environmental Assessment September 2020; Arboricultural Assessment September 2020; Fire Strategy September 2020 Background Papers: The contents of planning file referenced on the front page of this report, save for exempt or confidential information as defined in the Local Government Act 1972, Sch. 12A Parts 1 and 2