Stockley Park, Iron Bridge Road, West Drayton

planning report PDU/1825a/02 1 September 2010 Stockley Park, Iron Bridge Road, West Drayton

in the London Borough of Hillingdon planning application no. 2009/2079

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

The proposal Outline planning permission for a mixed used development comprising a 450 room hotel, data centre, offices, exhibition space and retail floor space, together with associated parking and landscaping.

The applicant The applicant is Stockley Park Consortium Limited, and the architect is JAC Architects.

Strategic issues The principle of development on Green Belt land has already been established. The key issues in relation to mitigating the impact to the Green Belt, the mix of uses, the energy strategy and transport issues in particular the provision of vehicle and cycle parking have been resolved and the scheme is now in accordance with the London Plan.

The Council’s decision

In this instance Hillingdon Council has resolved to grant permission. Recommendation That Hillingdon Council be advised that the Mayor is content for it to determine the case itself, subject to any action that the Secretary of State may take, and does not therefore wish to direct refusal or direct that he is to be the local planning authority.

Context

“Development (other than development which only comprises the provision of houses, flats, or houses and flats) which comprises or includes the erection of a building or buildings—(c) outside Central London and with a total floorspace of more than 15,000 square metres”;

page 1 “Development—(a) on land allocated as Green Belt or Metropolitan Open Land in the development plan, in proposals for such a plan, or in proposals for the alteration or replacement of such a plan; and (b) which would involve the construction of a building with a floorspace of more than 1,000”; and

“Development for a use, other than residential use, which includes the provision of more than 200 car parking spaces in connection with that use

2 On 11 November 2009 the Deputy Mayor and Chief of Staff considered planning report PDU/1825a/01, and subsequently advised Hillingdon Council that the application did not comply with the London Plan, for the reasons set out in paragraph 93 of the above-mentioned report; but that the possible remedies set out in paragraph 95 of that report could address these deficiencies.

3 A copy of the above-mentioned report is attached. The essentials of the case with regard to the proposal, the site, case history, strategic planning issues and relevant policies and guidance are as set out therein, unless otherwise stated in this report. On 13 July 2010 Hillingdon Council decided that it was minded to grant planning permission, and on 20 August 2010 it advised the Mayor of this decision. Under the provisions of Article 5 of the Town & Country Planning (Mayor of London) Order 2008 the Mayor may allow the draft decision to proceed unchanged, direct Hillingdon Council under Article 6 to refuse the application or issue a direction to Hillingdon Council under Article 7 that he is to act as the Local Planning Authority for the purposes of determining the application. The Mayor has until 2 September 2010 to notify the Council of his decision and to issue any direction.

4 The environmental information for the purposes of the Town and Country Planning (Environmental Impact Assessment) (England and Wales) Regulations 1999 has been taken into account in the consideration of this case.

5 The decision on this case, and the reasons will be made available on the GLA’s website www.london.gov.uk.

Update

6 At the consultation stage Hillingdon Council was advised that the application did not comply with the London Plan in relation to inclusive design and accessibility, climate change and transport. The applicant and Hillingdon Council have subsequently provided further information on these matters. Addressing each of these points in turn, the following is noted:

Inclusive design and access

7 At the initial consultation stage, the accessibility statement that had been submitted was noted, and consideration given to access routes through the site, drop-off points, and the provision of ramps along pedestrian spines (in light of the level changes on the site) was welcomed. However, concerns were raised that due to the outline nature of the application, there was a lack of detail about the internal layouts and levels of accessibility within the buildings.

8 In response to these concerns, Hillingdon Council has secured a series of conditions which will ensure that the detailed design of the buildings at a later date demonstrate inclusive design principles. A requirement that 10% of hotel rooms are wheelchair accessible has been secured by condition, which is welcomed.

9 On this basis, it has been assured that the proposal will be in accordance with policies 4B.5 and 3D.7 of the London Plan and policies 4.5 and 7.2 of the draft replacement London Plan.

page 2 Climate change mitigation and adaptation

10 At the initial consultation, additional details were requested in order to accord with relevant energy and sustainability policies. This included confirmation of the proposed approach to climate change mitigation and adaptation, including benchmarks, district heating, combined heat and power plant (CHP) sizing and the renewable energy approach.

11 The applicant has subsequently provided further information and assessment in order to address these points. The applicant has committed to the principle of optimising the size of the CHP in relation to the heat load of the site before the biomass boiler sizing is considered. A condition has been secured by Hillingdon Council, which ensures that the plant is sized to the average combined space heating and domestic hot water thermal demand, and that it is the lead heat source. The applicant has also committed to appropriate thermal management of the buildings and to looking further into the possibility of using the canal water at the detailed design stage, also secured by condition.

12 The applicant has acknowledged that the sizing and applicability of a biomass boiler for the development may be affected once the CHP size has been optimised and other factors are taken into account. In terms of renewable energy, the applicant has committed to safeguarding individual developments to allow for the installation of photovoltaic panels (PV) in the future. A condition is included in the draft decision notice that requires commitment to, and details of, PV to be confirmed at the detailed planning stage.

13 In relation to air quality, in light of the possibility of a biomass boiler being proposed at detailed design stage, a condition has been included in the draft decision notice, which requires control of air pollutants, together with a financial contribution towards air quality monitoring. This is welcomed.

14 On this basis, subject to these details being secured at detailed design stage, the scheme would accord with relevant climate change policies within the London Plan and draft replacement London Plan.

Transport for London comments

15 At the initial consultation stage, several concerns were raised about the proposal, including the trip rates for the hotel, junction capacity at Horton Interchange roundabout, car parking and electric vehicle charging provision, and taxi facilities. Contributions towards improving walking and cycling infrastructure, bus service and bus stop improvements, a travel plan, delivery and servicing plan and construction logistics plan were sought. Since stage 1, TfL has worked with the Council and the applicant to address and resolve these issues, so as to make this proposal acceptable in transport terms.

16 A total of £500,000, to be paid to the Council, has been secured to fund studies and works to improve traffic flows and public transport in the vicinity of the site. Furthermore, a study at Horton Interchange covering pedestrian crossings and junction capacity will be secured through the section 106 agreement. Following agreement being reached with the Council, any necessary works resulting from these studies will be carried out accordingly. The trip generation for the hotel element has also been agreed. These measures ensure general conformity with London Plan policy 3C.2 ‘Matching development to transport capacity’ and draft replacement London Plan policies 6.3 ‘Assessing transport capacity’ and 6.11 ‘Smoothing traffic flow and tackling congestion’.

17 A maximum of 1,100 car parking spaces will be provided upon completion of the development. This represents a reduction of 40 spaces and a ratio of 1 space per 66 sq.m. for the entire development, half that permitted for the extant permission. Initially 3% of spaces will be fitted with electric vehicle charging points (capable of charging multiple vehicles simultaneously), to be secured by condition. Demand and usage of these will be monitored via the travel plan. Car

page 3 parking will be introduced in phases alongside the development and 114 spaces will be designated for blue badge holders only, secured by way of condition. Overall, TfL considers that this proposal is in general conformity with London Plan policy 3.23 ‘Parking strategy’ and draft replacement London plan policy 6.13 ‘Parking’.

18 A bus network contribution of £320,000 has also been secured, to be paid to the Council for a sponsored route agreement to be agreed between TfL and Council. This will comprise three payments of £90,000 over three years towards improvements to TfL bus services, with the first amount to be drawn upon first occupation of the development. The remainder will be spent on bus stop upgrades to meet TfL accessibility standards (subject to the outcome of an audit). These measures ensure general conformity with London Plan policy 3C.20 ‘Improving conditions for buses’ and draft replacement London Plan policy 6.7 ‘Buses, bus transits, trams’.

19 The intention is that the developer will carry out works or make a financial contribution to the Council towards works, along the towpath (the London LOOP) as requested by TfL up to a value of £1,200, thus improving conditions for walking in the vicinity of the site and in line with London Plan policy 3C.21 ‘Improving conditions for walking’ and draft replacement London Plan policy 6.10 ‘Walking’.

20 A ten-year travel plan, in line with TfL guidelines has been secured through the section 106 agreement. The requested delivery and servicing plan and construction logistics plan have been secured by condition.

21 Overall the issues raised at the initial consultation stage have been satisfactorily addressed through the submission of additional information, planning conditions and obligations. Therefore, this application is considered to be in general conformity with the London Plan and acceptable in transport terms. Response to consultation

22 The application was advertised by site and press notices, and consultation letters that were sent to 39 adjoining properties. Observations were received from Hayes Town Partnership and Lake Farm Country Park, in relation to monetary contributions towards enhancement of the local area and use of the river. The officer’s report confirms the financial contributions and conditions that are being provided to mitigate the impacts of the development, and notes the contributions that were secured under previous planning permissions.

23 Other statutory consultees responded as follows:

English Heritage (Archaeology): No objections raised.

Environment Agency: Notes that the vegetative buffer between the site and canal provides a valuable wildlife habitat. The requested conditions regarding contamination and flooding have been secured by Hillingdon Council in the draft decision notice.

British Waterways: The scheme is supported in principle, subject to integration with the Grand Union Canal and that contributions towards the waterway environment are secured. The recommendation by Hillingdon Council includes the requirement for financial contributions towards such improvements, and conditions have been imposed in relation to landscaping of the buffer zone.

Highways Agency: Requests that the impact of the development take into consideration traffic impacts upon the M4. The proposed conditions and travel plan are welcomed.

Metropolitan Police: Has assessed the scheme in terms of crime prevention and raises no objection subject to defensible space between the buildings and public access ways being

page 4 designed appropriately. The landscaping details will be secured by condition, which makes specific mention of providing a safe and secure environment. Article 7: Direction that the Mayor is to be the local planning authority

24 Under Article 7 of the Order the Mayor could take over this application provided the policy tests set out in that Article are met. In this instance the Council has resolved to grant permission with conditions and a planning obligation, which satisfactorily addresses the matters raised at stage I, therefore there is no sound planning reason for the Mayor to take over this application. Legal considerations

25 Under the arrangements set out in Article 5 of the Town and Country Planning (Mayor of London) Order 2008 the Mayor has the power under Article 6 to direct the local planning authority to refuse permission for a planning application referred to him under Article 4 of the Order. He also has the power to issue a direction under Article 7 that he is to act as the local planning authority for the purpose of determining the application and any connected application. The Mayor may also leave the decision to the local authority. In directing refusal the Mayor must have regard to the matters set out in Article 6(2) of the Order, including the principal purposes of the Greater London Authority, the effect on health and sustainable development, national policies and international obligations, regional planning guidance, and the use of the River Thames. The Mayor may direct refusal if he considers that to grant permission would be contrary to good strategic planning in Greater London. If he decides to direct refusal, the Mayor must set out his reasons, and the local planning authority must issue these with the refusal notice. If the Mayor decides to direct that he is to be the local planning authority, he must have regard to the matters set out in Article 7(3) and set out his reasons in the direction. The Mayor must also have regard to the guidance set out in GOL circular 1/2008 when deciding whether or not to issue a direction under Articles 6 or 7. Financial considerations

26 Should the Mayor direct refusal, he would be the principal party at any subsequent appeal hearing or public inquiry. Government guidance in Circular 03/2009 (‘Costs Awards in Appeals and Other Planning Proceedings’) emphasises that parties usually pay their own expenses arising from an appeal.

27 Following an inquiry caused by a direction to refuse, costs may be awarded against the Mayor if he has either directed refusal unreasonably; handled a referral from a planning authority unreasonably; or behaved unreasonably during the appeal. A major factor in deciding whether the Mayor has acted unreasonably will be the extent to which he has taken account of established planning policy.

28 Should the Mayor take over the application he would be responsible for holding a representation hearing and negotiating any planning obligations. He would also be responsible for determining any reserved matters applications (unless he directs the council to do so) and determining any approval of details (unless the council agrees to do so). Conclusion

29 Having regard to the details of the application, the matters set out in Hillingdon Council’s committee report and its draft decision notice, this scheme is acceptable in strategic planning terms. Further information has been provided, which together with the conditions and planning obligations imposed by Hillingdon Council, address all the outstanding issues that were raised at Stage 1. On this basis, there are no sound reasons for the Mayor to intervene in this particular case.

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for further information, contact Planning Decisions Unit: Colin Wilson, Senior Manager – Planning Decisions 020 7983 4783 email [email protected] Justin Carr, Strategic Planning Manager (Development Decisions) 020 7983 4895 email [email protected] Samantha Wells, Case Officer 020 7983 4310 4266 email [email protected]

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planning report PDU/1825a/01 11 November 2009 Stockley Park phase III

in the London Borough of Hillingdon Planning application no. 37977/APP/2009/2079

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

The proposal

Outline planning permission for a mixed used development comprising a 450 room hotel, data centre, offices, exhibition space and retail floor space, together with associated parking and landscaping.

The applicant The applicant is Stockley Park Consortium Limited, and the architect is JAC Architects.

Strategic issues The principle of development on Green Belt land has already been established. The key issues, therefore, are mitigating the impact to the Green Belt, the mix of uses, the energy strategy and transport issues in particular the provision of vehicle and cycle parking.

Recommendation

That Hillingdon Council be advised that while the application is generally acceptable in strategic planning terms the application does not comply with the London Plan, for the reasons set out in paragraph 93 of this report; but that the possible remedies set out in paragraph 95 of this report could address these deficiencies.

Context

1 On 2 October 2009 the Mayor of London received documents from Hillingdon Council notifying him of a planning application of potential strategic importance to develop the above site for the above uses. Under the provisions of The Town & Country Planning (Mayor of London) Order 2008 the Mayor has until 12 November 2009 to provide the Council with a statement setting out whether he considers that the application complies with the London Plan, and his reasons for taking that view. The Mayor may also provide other comments. This report sets out information for the Mayor’s use in deciding what decision to make.

page 7 2 The application is referable under Category 1B, 3D and 3F of the Schedule to the Order 2008:

“Development—(a) on land allocated as Green Belt or Metropolitan Open Land in the development plan, in proposals for such a plan, or in proposals for the alteration or replacement of such a plan; and (b) which would involve the construction of a building with a floorspace of more than 1,000”; and

“Development for a use, other than residential use, which includes the provision of more than 200 car parking spaces in connection with that use.”

3 Once Hillingdon Council has resolved to determine the application, it is required to refer it back to the Mayor for his decision as to whether to direct refusal; take it over for his own determination; or allow the Council to determine it itself.

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

6 The site, known as Stockley Park Phase 3, is approximately 12 hectares, and is located two kilometres west of Hayes town centre and approximately 0.5 kilometres north of Junction 4 of the M4 motorway. Heathrow Airport is two kilometres south of the site, while Junction 15 of the M25 is approximately 3.5 kilometres to the west.

7 The western part of the site is within the Green Belt and the eastern part is within the Hayes/West Drayton Corridor which is identified as an Industrial and Business Area within the Hillingdon UDP. The site is adjacent to Strategic Industrial Land and falls within the Heathrow North Opportunity Area.

8 The immediate area surrounding the site is largely commercial in character. Phase Two of Stockley Park (currently occupied by Glaxosmithkline) is located to the east, and Horton Industrial Park is located to the west, beyond a strip of open space. The site is bound to the south by the Grand Union Canal, beyond which is the mainline railway connecting Paddington and Bristol. North of the site is Stockley Park golf course and further Green Belt land.

9 The site has been the subject of environmental remediation following its history of extraction and landfill, and has been serviced and prepared for development in accordance with the planning consent granted in 2000.

10 The site has access from Horton Road through Stockley Park. The nearest rail station is West Drayton, just over 1km walk from the site. Stockley Park is currently served by 3 bus routes (350, U5 and A10). Route A40 also runs along Stockley Road. The public transport accessibility level (PTAL) of the site is 2, where 6 is very high and 1 is very low.

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Figure 1: Aerial photograph (Source: Design and Access Statement)

Details of the proposal

11 Outline planning permission is sought for a mixed use development comprising a 450 bedroom hotel (26,000 sq.m.), a data centre (18,135 sq.m.), three office blocks (25,000 sq.m.) and a fourth block (3,500 sq.m.) to contain a mix of uses including offices, exhibition space, retail, financial and professional services, cafes and restaurants. The six plots would contain buildings ranging in height from three through to eight storeys, as shown in figure 2.

12 The proposals include landscaping and open space, internal roads, footways, cycle ways and an energy centre. A total of 1,140 car parking spaces are proposed, to be located around the site and within a single storey decked car parking structure along the southern boundary.

Figure 2: Annotated Masterplan (Source: Design and Access Statement)

page 9 13 As noted, the application has been submitted in outline form, with full details provided in respect of access only. The application does include details of the indicative layout, scale and landscaping for the scheme, but together with appearance, full details are all reserved for future consideration.

14 The applicant states that this development will be built out in three stages. Stage 1 will comprise infrastructure, the hotel and the mixed use amenity/office building. Stage 2a and 2b comprise the three office buildings (on a pre-let or speculative basis) and the car park. Stage 3 would incorporate the data centre.

Case history

15 Stockley Park business area has been developed in three phases, with phases 1 and 2 now complete. Phase 3A was granted consent in 1990 for 18,000 sq.m. of office space and forms the east part of the application site. This part of the site was deleted from the Green Belt in the 1998 UDP. Following further negotiations in 1998, the Council resolved to grant outline planning permission for 50,000 sq.m. of commercial floor space and 1,143 car parking spaces, which included both the east and west portion of the site (with the west side still designated as Green Belt). Following referral to GOL, planning permission was granted for Phase 3 in August 2000. This outline permission identified five plots within which each of the approved buildings were to be sited. Several reserved matters planning permission were granted in 2001 and 2002. While none of these consents have been built out, the site has been laid out with substantial hard and soft landscaping, access roads and infrastructure put in place, as can be seen in figure 1.

Figure 3 Stockley Park Phasing (Source: Design and Access Statement)

16 The Mayor received a Stage 1 referral on 30 March 2006 regarding a full planning application for erection of a 18,135 sq.m. data centre together with ancillary plant, including sub station, car parking, landscaping and associated ancillary works to be located on the south-west corner of the application site (in the position of Plot 3 on figure 2 above), which is within the Green Belt. The Mayor advised that further work was required in relation to energy, which was provided at Stage 2 and Hillingdon Council were subsequently advised that the Mayor was content for it to determine the case itself (ref PDU 1418).

page 10 17 The Mayor was consulted on 4 July 2007 regarding an outline planning application for a mixed use development comprising a 450 bedroom hotel (24,191 sq.m.), a data centre (18,135 sq.m.) and two office blocks (12,120 sq.m.) together with landscaping, internal roads, footways, cycleways, an energy centre and 794 parking spaces. This application site excluded the data centre referred to under paragraph 14 above (PDU 1418). A Stage 1 response was provided which noted that whilst the principle of development of Phase 3 at Stockley Park has been established by the 2000 master plan consent, further work to justify the hotel use in this out of town centre location was required. Concern was also raised regarding the number of vehicle parking spaces, which exceeded current London Plan maximum standards. Further work was also required on the energy calculations to substantiate the applicant’s approach to the energy strategy and ensure consistency with the existing and emerging London Plan energy policies (ref PDU/1825). This scheme significantly increased the scale of development over and above the baseline conditions approved on the site.

18 This revised master plan scheme was refused by Hillingdon Council on several grounds, namely inappropriate development in the Green Belt due to its scale, overbearing impact and visual dominance, together with inadequate landscaping and failure to provide s106 contributions. A series of pre-application meetings were held with Hillingdon Council following the refusal, and the current application seeks to address these matters. The current application also varies from the previous in that the amount of business floor space is increased by approximately 16,000 sq.m. because it also includes the site containing the previously approved (but not constructed) data centre. The amount of car parking spaces has also increased by 346. Strategic planning issues and relevant policies and guidance

19 The relevant issues and corresponding policies are as follows:

 Economic development London Plan; the Mayor’s Economic Development Strategy  World city role London Plan  Density London Plan; PPS3;  Urban design London Plan; PPS1  Mix of uses London Plan; PPS6  Regeneration London Plan; the Mayor’s Economic Development Strategy  Transport London Plan; the Mayor’s Transport Strategy; PPG13;  Parking London Plan; the Mayor’s Transport Strategy; PPG13  Retail London Plan; PPS6; PPG13; Draft PPS4  Green Belt/MOL London Plan; PPG2  Employment London Plan; PPG4; draft PPS4; Industrial Capacity SPG  Biodiversity London Plan; the Mayor’s Biodiversity Strategy; PPS9  Access London Plan; PPS1; Accessible London: achieving an inclusive environment SPG; Planning and Access for Disabled People: a good practice guide (ODPM)  Equal opportunities London Plan; Planning for Equality and Diversity in Meeting the spatial needs of London’s diverse communities SPG; Diversity and Equality in Planning: A good practice guide (ODPM)  Tall buildings/views London Plan; View Management Framework SPG, draft Revised View Management Framework SPG  Air quality London Plan; the Mayor’s Air Quality Strategy; The Control of dust and emissions from construction and demolition BPG; PPS23

page 11  Sustainable development London Plan; PPS1, PPS Planning and Climate Change Supplement to PPS1; PPS3; PPG13; PPS22; the Mayor’s Energy Strategy; Sustainable Design and Construction SPG  Tourism/leisure London Plan; Good Practice Guide on Planning for Tourism (DCLG)  River Thames/flooding London Plan; Mayor’s draft Water Strategy; PPS25, RPG3B

20 For the purposes of Section 38(6) of the Planning and Compulsory Purchase Act 2004, the development plan in force for the area is the 1998 Hillingdon Unitary Development Plan (Saved Policies) and the 2004 London Plan (Consolidated with Alterations since 2004).

21 The Hillingdon Core Strategy Preferred Options as well as the draft replacement London Plan are also relevant material considerations.

Principle of development on Green Belt

22 Part of the site to the west is designated as Green Belt in the Hillingdon Unitary Development Plan 1998. As such, the proposal must be considered against Planning Policy Guidance Note 2: Green Belts. Paragraph 3.2 of PPG2 states that “Very special circumstances to justify inappropriate development will not exist unless the harm by reason of inappropriateness, and any other harm, is clearly outweighed by other considerations”. Policy 3D.9 of the London Plan states that “There is general presumption against inappropriate development in the Green Belt, and such development should not be approved except in very special circumstances”. The corresponding policy within the Draft Replacement London Plan is 7.16 which reiterates this policy. This approach is consistent with PPG2.

23 PPG2 establishes five purposes of including land in Green Belts:

 to check the unrestricted sprawl of large built-up areas;  to prevent neighbouring towns from merging into one another;  to assist in safeguarding the countryside from encroachment;  to preserve the setting and special character of historic towns; and  to assist in urban regeneration, by encouraging the recycling of derelict and other urban land.

24 As detailed above, the planning history of the site is extensive. The fundamental consent that has established development within the Green Belt in this case is based on the original master plan granted planning permission in August 2000. (Shown in figure 4 below)

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Fig 4 : Master Plan as approved, 2000 (Source: Hamiltons architects)

25 The approved master plan allows the erection of three office buildings in the western portion of Phase 3, within the Green Belt. The most recent detailed planning permission was for Plot 3, known as Data Centre 1, which is the building shown in the south west corner of the master plan. As stated above, this was granted planning permission in January 2007, following Mayoral consideration in October 2006 (PDU/1418a). The principle of development in this Green Belt location is an issue that has been thoroughly scrutinised both by the Council, and by GOL, as part of the earlier decision making process. The very special circumstances, which have allowed all of the Stockley Park development to proceed within the Green Belt at each stage has focussed on the following key points:

 The employment benefits from bringing new commercial development into a defined regeneration area within West London, noting the site’s position adjacent to SEL [the rest of Stockley Park] and within the Heathrow North Opportunity Area.

 The environmental benefits from cleaning up large areas of heavily contaminated land.

 The amenity benefits associated with the re-landscaping of large areas of land as public accessible open space for community use.

26 Whilst PPG2, London Plan policy 3D.9 and draft replacement London Plan policy 7.16 advocate that any changes to Green Belt should be made through the development plan process, this particular case is exceptional as the principle has been established first as part of Phase 3A’s development, then later in the 2000 master plan consent and the 2007 detailed planning consent for Data Centre 1. Under normal circumstances the Council should propose alterations to the Green Belt boundary through the development plan, rather than taking a development control approach to the site’s development. Given that the planning principle of development has been accepted by both the Council and the Secretary of State, in these circumstances consideration should instead be given to the proposed form of buildings and limiting its impact on the openness of the Green Belt. This is keeping in mind that the site is surrounded on two sides by industrial land, the canal to the south and the golf course to the north, and would therefore not result in unrestricted sprawl. It is also noted that the infrastructure and landscaping for the site has been laid out already in accordance with the extant permission from 2000.

27 The current application follows a recent scheme which was refused by Hillingdon Council because it was considered that the harm to the Green Belt outweighed the special circumstances of

page 13 the scheme by reason of the height and siting of the buildings (which had altered significantly from the 2000 scheme). The current application has pulled the buildings away from the western boundary and the heights have been lowered so that the scheme is now more in line with the 2000 approval, and the impact upon the openness to the Green Belt is reduced. Furthermore, the landscaping and design for all of Phase 3, in particular the green swath along the western boundary, the Grand Union Canal Towpath, and the woodland in the north-eastern corner, is substantial. It is reasonable to conclude that the impact would be an improvement upon the scheme considered by the Mayor in October 2007 and that appropriate and reasonable mitigation measures (through landscaping) have been applied in this case.

28 The principle of development has been established through the decision making process that has preceded this application and holds substantial weight in the consideration of this case. On this basis, the application is accepted in principle subject to other detailed considerations set out in the rest of this report. Mix of employment uses

29 Policy 3B.4 of the London Plan and corresponding draft replacement London Plan policy 4.4 establish a framework for protection of employment sites, recommending that ‘Boroughs…identify Strategic Industralt Locations in DPDs, and develop local policies for employment sites outside the SILs’. Any such policies should have regard to a range of criteria, including the locational strategy in the London Plan, accessibility to the local workforce, quality and fitness for purpose of sites, and the need to release surplus land for other uses in the light of local demand.

30 In terms of overarching spatial policies, London Plan policy 5F.1 (West London Sub Regional Development Framework) and policy 5F.2 (Heathrow Opportunity Area) concentrate primarily on the need for adequate provision for manufacturing, warehousing and office activities to meet airport related needs. The London Plan makes specific reference to Stockley Park in paragraph 3.148 in relation to strategic office policy where it states that conventional business parks such as this are competitive key locations where a market can be developed for new and existing occupiers. Paragraph 5.163 also makes mention of Stockley Business Park in relation to its capacity for employment expansion to support Heathrow Airport. Policy 2.13 of the draft replacement London Plan refers to Opportunity Areas and Intensification Areas, and Stockley Park is identified as an important office location within the Heathrow OAPF/IAPF. Whilst the site is not identified as Strategic Industrial Land in the London Plan, part of it is located within an Industrial Business Area (IBA) as identified within the Hillingdon UDP.

31 In considering the types of uses that would be appropriate to the site and in light of UDP policy, the applicant has undertaken an assessment of demand for a hotel on the site. This is keeping in mind the proposal for a hotel in an industrial business area, and requirements of PPS6 with respect to the location of a hotel use outside of a town centre. In the previous Stage 1 response, it was highlighted that no consideration had been given to a sequential test and whether a more sustainable location for hotel of this scale could be provided in a town centre.

32 The applicant has submitted a hotel sequential assessment with this application, carried out in accordance with PPS6. A comprehensive review of potential development sites in nearby town centres has been undertaken, which concludes that there are no other viable or suitable alternative sites available in such locations, or in the required timescales. Given the requirements in terms of scale and setting, as well as accessibility, the applicant has demonstrated that there are no sequentially preferable locations to the application site and that Stockley Park is the most suitable site for the proposed hotel. The applicant notes that the development is likely to provide accommodation for businesses in Stockley Park and people wanting to stay in the Heathrow area.

page 14 Supporting evidence has been provided which suggests that there is a substantial market for a hotel in this location on the basis of the current Stockley Park Business market and the proximity to Heathrow.

33 In further support, London Plan policy 3D.7 recognises a need for 40,000 additional hotel bedrooms by 2026. In the draft replacement plan, the requirement is for 40,000 new hotel rooms of which at least 10% should be wheelchair accessible. Outside of Central London, the expectation is that hotels be located in town centres and other locations, such as Opportunity Areas, with good public transport access to Central London and national and international transport termini. This development would help to meet the demand and help meet Mayoral objectives to diversify and increase tourism provision across the capital in accordance with the London Plan and draft replacement London Plan. Design

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

35 The draft replacement London Plan reinforces these principles, with new development required to have regard to its context, and reinforce or enhance the character, legibility and permeability of the neighbourhood (policy 7.1).

36 The application is submitted as outline, and details in respect of appearance, landscape, layout and scale are reserved for future consideration. The applicant has submitted a design and access statement, and whilst there is limited information regarding the proposed buildings, the landscaping plan suggests a lively and imaginative treatment of the main spaces within the site. It indicates that the proposed development will be landscape-led, and on this basis, the architects are urged to follow a ‘pavilion’ or campus-type approach in the design of the buildings, so that the landscaping remains the dominant element.

37 The indicative layout of the site is logical and largely based on the existing road network as laid out on the site. It is expected that the landscaping provision within the open car parking areas will be more plentiful and generous than the indicative layouts shown, given that this is a landscape-led scheme. Pedestrian access throughout the site is good, but it will be important to ensure that the building design on plot 7 gives obvious and unhindered pedestrian access between the central area and the south-western corner of the site, particularly as this is on the main axial pedestrian movement route. Additionally, the internal streets, especially around the central garden, should be designed for pedestrian priority, with vehicles encouraged to access parking spaces directly from the perimeter roads.

38 The proposed height strategy and building layouts ensure that the highest buildings are outside of the Green Belt land, although the data centre will be within Green Belt land. Whilst the proposed heights are acceptable, the detailed design of the buildings should ensure that the buildings are as lightweight as possible so that they do not dominate the landscape, and that as suggested by the architect, that this will be a landscape-led scheme. This could be realised through choice of materials, variations in the massing and changes in height throughout the plots, to ensure that the proposed buildings have minimal impact on close views from within Stockley Park and surrounding development, and the views across the green belt.

page 15 39 In summary, the indicative details suggest that the proposal will be a landscape-led scheme, with a high design quality. Hillingdon Council to ensure that this design quality is carried through to detailed matters stage. Inclusive Design and Access

40 Inclusive design principles, if embedded into the development and design process from the outset, help to ensure that all individuals, including older people, people with disabilities, children and young people, can use the places and spaces proposed comfortably, safely and with dignity. The aim of London Plan policy 4B.5 (‘Creating an inclusive environment’) and Draft Replacement London Plan policy 7.2 is to ensure that proposals achieve the highest standards of accessibility and inclusion, not just the minimum as required by building regulations. London Plan policy 3D.7 seeks to increase the quality and quantity of fully wheelchair accessible accommodation in London. Furthermore, the GLA’s hotel demand study assessed the supply of wheelchair accessible hotel accommodation in London and identified a shortfall of suitable accommodation. In recognition of the shortfall, the draft replacement London Plan expects that 10% of rooms should be fully wheelchair accessible where possible (Policy 4.5).

41 The applicant has provided an accessibility statement within the design and access statement which indicates disabled accessible routes through the site, and drop off points. It is noted that there is level change between the site and the canal towpath, and the plans indicate DDA compliant ramps along the primary pedestrian spine. Subject to detailed design, the design aspirations of the masterplan are welcomed and would ensure ease of access across the site, and to open spaces, in particular the Grand Union Canal.

42 It is noted that whilst consideration has been given to the external environment, the applicant has failed to demonstrate that the buildings themselves would be fully accessible, including level threshold at ground floor level, lift access, or compliant door way and corridor width. Whilst it is noted that this is an outline application, the applicant should indicate their commitment to an inclusive environment, and provide schematic plans that show how the scheme would achieve the highest level of accessibility and inclusion.

43 In terms of the hotel use, the applicant has not indicated that the hotel would achieve the minimum 10% requirement in terms of wheelchair accessible units. An indicative floor layout and commitment in terms of a minimum of providing 45 wheelchair accessible rooms should be provided, together with their location so that it can be established that the scheme will be compliant with the London Plan and draft replacement London Plan.

Blue Ribbon Network

44 London Plan policies 4C.3, 4C.11, 4C.12 and 4C.20 all promote the use of the Blue Ribbon Network for access to leisure and recreation and utilising opportunities for the use of water transport, and for the promotion of biodiversity. The corresponding draft replacement Policies (7.24, 7.27, 7.28 and 7.30) reiterate these policies, seeking to ensure that these waterways are restored, enhanced and managed in a sustainable way.

45 The proximity of the Grand Union Canal to the south of the site has been a key consideration, encouraging access and use along the Canal. The principles set out in the design and accesss statement are welcome and will improve access to this type of amenity for the community and users of Stockley Park (see also TfL comments). A high quality landscaped amenity area is proposed fronting the canal, with input from British Waterways having taken place. The landscaping strategy has also addressed the need to encourage and promote biodiversity across the site.

page 16 Climate change measures

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

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

Mitigation

48 Policies 4A.2 to 4A.8 of the London Plan focus specifically on how to mitigate climate change, and the carbon dioxide emissions reduction targets that are necessary across London to achieve this. Developments are required to make the fullest contribution to tackling climate change by minimising carbon dioxide emissions (be lean), adopting sustainable design and construction measures and prioritising decentralised energy (be clean), including renewables (be green).

49 An Energy Strategy has been submitted which provides estimates for the energy demand and carbon emissions of the development. The applicant has broadly followed the energy hierarchy of the London Plan.

Baseline Carbon Emissions

50 The baseline emissions for the development are estimated to 4,185 tonnes of carbon dioxide per annum using CIBSE benchmarks. Normally modelling would be required, however, considering this is an outline planning application, benchmarks are acceptable in this instance.

51 It will be necessary, however, for the applicant to provide details of the benchmarks used. The applicant should also confirm that both regulated and non-regulated energy use has been taken into account.

Energy efficient standards

52 A range of energy efficiency measures are proposed for the development, including; high performance glazing, improved U-values for building envelope, improved air tightness and energy efficient lighting and lighting controls. Other passive measures such as high thermal mass and shading, and natural ventilation. With respect to the data centre, whilst the detailed design will take place at a later stage, the focus is on lowering cooling demand. The intention is that the scheme delivers BREEAM “excellent”.

53 These measures would enable the development to exceed the requirements of building regulation 2006 Part L by 40% for the hotel and 20% in the office buildings and reduce the baseline emissions by 4% for the whole development. The reductions would be 18%, 8% and 3% respectively for phases 1, 2 and 3 compared to the baseline carbon dioxide emissions. These commitments will need to be secured by way of legal agreement or condition.

page 17 District heating

54 The applicant has investigated the availability of district heating schemes in the area, however, the closest one was found 2 km away from the site at Hayes Station Goods Yard. Another opportunity found would be to link this development to West Drayton. This is a welcomed approach, and the applicant should provide information on efforts made to pursue this option further.

55 An energy centre is proposed in the basement of the hotel (plot 5) in phase 1, with heat energy also being distributed to Plot 6 (mixed use/amenity building) via a district energy pipe. The intention is that the buildings which are constructed at phase 2 would interconnect to the phase 1 buildings via an extension to the district heating network.

56 Whilst the applicant is suggesting that the district heating system would be sized for phase 1 and 2, it is stated that this strategy would be subject to financial viability at the point of construction. Whilst it is acknowledged that the scheme is outline and therefore not at and advanced stage, the applicant is expected to commit to a more clear strategy at this stage. It is also not clear if the carbon dioxide reduction relates to the site wide strategy or only a phase 1 network approach. The applicant should present the different scenarios in terms of carbon dioxide and energy.

57 The district heating network temperatures would take into account the possibilities of using waste heat from the data centre which is intended to be the last building that is constructed. The applicant should provide an estimate of how much heat would be available. Two alternatives are presented; one using heat pumps to raise the temperature to be compatible with the network and one for pre-heating domestic hot water. The heat pump option is not supported, as CHP has a higher standing in the energy hierarchy. The applicant is advised that the option of using it to pre- heat domestic hot water is not the most robust system, considering the mix of technologies involved.

Combined Heat and Power, Cooling

58 The proposals include combined heat and power (CHP) that would be installed in phase 1 of the development. CCHP has been investigated but not found favourable for this development. The CHP capacity would be approximately 400 kW electricity output. Whilst it is noted that this is an outline application, in order to be satisfied as to compliance with the London Plan, the sizing of the CHP requires further clarification and justification so as to ensure that it workable and maximised. The CHP is proposed to work along side a biomass boiler, however, this would not supported unless the applicant can show that the CHP size has been optimised prior to considering renewable technologies. This information is required before it can be established that the scheme complies with the Mayor’s Energy Hierarchy. When sizing the CHP appropriately, there would be little scope for introducing a large biomass boiler, and as such this approach requires further details.

59 With respect to cooling, there would be several requirements in the development. Cooling would be minimised through a range of measures, such as natural ventilation, exposed thermal mass, use of free cooling (outdoor air) for the data centre and potentially the use of the canal as a heat sink. A commitment in respect of this will need to be secured as part of any planning permission.

page 18 Renewable energy

60 The proposals include a biomass boiler of approximately 500 kW thermal output capacity and which is estimated to provide a further 20% reduction of carbon dioxide emissions.. However, this needs to be re-evaluated taking into account the comments above in relation to sizing. The applicant should present possible alternative approaches for renewable contribution to carbon reductions should the biomass boiler no longer present a viable option when CHP size has been re- evaluated.

61 The applicant should be aware of the Mayor’s draft Air Quality Strategy, which states that small biomass boilers below 500kW in AQMAs are considered unsuitable unless they can demonstrate that they have no adverse effects on local air quality when compared with conventional gas fired boilers. Information to satisfy this concern should be provided.

Climate Change Adaptation

62 The London Plan promotes five principles in Policy 4A.9 to promote and support the most effective adaptation to climate change. These are to minimise overheating and contribute to heat island effects; minimise solar gain in summer; contribute to flood risk reduction, including applying sustainable drainage; minimising water use; and protect and enhance green infrastructure (the corresponding draft replacement London Plan policy is policy 5.3). There are specific policies covering overheating, living roofs and water. Further guidance on these policies is given in the Mayor’s SPG Sustainable Design and Construction. The applicant has submitted an assessment of the scheme against the essential and preferred standards within London Plan Policy 4A.3 and the Sustainable Design and Construction SPG.

63 Policy 4A.14 of the London Plan and Policy 5.13 of the draft replacement seek to ensure that surface water run-off is managed as close to its source as possible and sets out a hierarchy of preferred measures to achieve this. Policy 4A.16 of the London Plan and Policy 5.15 of the Draft Replacement seek to ensure that new development has proper regard to the impacts on water demand and existing capacity by minimising the use of treated water and maximising rainwater harvesting. The scheme would include water efficient taps, flow restrictors to manage water pressure and water metres, which would assist in reducing internal water consumption.

64 Policy 4A.11 seeks major developments to incorporate living roofs and walls where feasible (corresponding policy 5.11 within the draft replacement London Plan). The sustainability statement suggests that sedum roofs “will be encouraged” for all buildings where appropriate. The intention is that a sustainable drainage system is used, however it is noted that there is a surface water drainage network in place as part of the previous scheme, which discharges into the adjacent canal. Details of the proposed measures with respect to sustainable design and construction should be secured at detailed design stage. Transport for London’s comments

65 This scheme comprises a revision to the previously consented Phase 3 scheme which was granted planning permission in 2000. The main differences between the two schemes are the introduction of a hotel in the place of office floor space, a data centre (which already has planning permission, granted in 2007), and an overall increase in floor space overall (although office floor space is reduced). This total of 72,635 sq.m. represents an increase of 22,635 sq.m. compared with the 2000 planning consent.

Trip generation and highways issues

page 19 66 The trip rate and modal split for the proposed office and data centre development is acceptable. However, the trip rate assessment for the hotel site is based on the use of a single site from the TRAVL database. This should be reviewed as there is concern that the use of a single site is not sufficiently robust.

67 The modelling that has been carried out for three roundabouts in the vicinity of the site predict that the Horton Interchange Roundabout will operate above capacity for years 2012 and 2022, but that the other junctions would operate within capacity. Therefore it is recommended that mitigation measures should be identified and agreed with the local highway authority to improve capacity for the Horton Interchange roundabout. A reduction in car parking would also help to relieve congestion.

Car parking

68 It is understood that the proposal for 1,140 parking spaces is based on the previous consent in 2000 for Phase 3, where 1,143 spaces were to be provided for 50,000 sq.m. of Class B1 office development. As there is a higher amount of floor space proposed for the current scheme (72,635sqm), it is recognised that the ratio of parking to floor space would decrease as a result. However the applicant is advised that the proposed provision is excessive and is well in excess of the London Plan standards. Furthermore, there is concern that trips from the proposed development may worsen the already significantly congested SRN (Uxbridge Road A4020) and in particular the TLRN (A312 The Parkway/ Hayes bypass) although these lie some distance from the site.

69 Therefore the parking provision for all elements of the proposal should be reduced to a level which would comply with maximum London Plan standards set out in Annex 4 of the London Plan and Tavle 6.1 of the draft replacement London Plan.

70 The proposed provision of 114 disabled spaces is adequate, but it will be necessary to ensure all disabled bays should be designed in accordance with the Disability Discrimination Act (DDA 1995) Standards.

71 Further information about the levels of car parking and any surveys or accumulation in adjacent car parks where they may serve dual functions is required. The applicant should also consider car sharing and pool cars where appropriate.

72 In addition the application will need to provide electric vehicle charging points as set out in the Mayors guidelines and the London Plan: consultation draft replacement (October 2009) Policy 6.13 (Parking) which states that 20% of all commercial spaces must be for electric vehicles with an additional 10% passive provision. For passive provision the developer is expected to demonstrate that the additional spaces or points can be provided at the time of implementation or at some time in the future.

Taxis and coaches

73 The transport assessment proposes a taxi drop-off lay-by however, given the modal share for the site for taxi of 3.4% with potential for growth in this location, it is recommended that provision is made for a taxi rank (so that taxis can wait for hiring) within the hotel plot and close to the drop off area. This argument is strengthened by the fact that visitors or users of the development would not benefit from passing trade from taxis in this location. It may also be the case that with the expansion of the office buildings, that further opportunities may present themselves for extra taxi ranking within the Park.

page 20 74 The transport assessment states that two parking spaces will be provided for coaches at the rear of the hotel and that the coach drop off provision will accommodate two 15m long coaches. This level of provision for coaches is satisfactory.

Walking, cycling and public realm

75 Generally the proposals significantly improve accessibility for pedestrians and cyclists to and through the area, and are therefore supported. The figures showing the proposed walking and cycling routes were very useful. There are suggestions for further improvement in order to ensure compliance with London Plan Policy 3C.21 (Improving conditions for walking) and London Plan: draft replacement policy 6.10 (Walking):

 All new and existing crossing facilities should comply with BV165 accessibility standards, and the completed footway should have a minimum width of 2m along its length.

 It is noted that works also include completion of the Ironbridge Road North access opposite GlaxoSmithKline. It is unclear if this access also includes pedestrian crossing facilities. At the very least dropped kerbs and tactile paving should be provided across the access road. Designated 2m wide footways should be provided alongside the internal roads.

 The design of the site includes a pedestrian/cycleway (DDA compliant) from the canal towpath at the southwest corner of the site to the central area. This is welcomed as it will provide a connection from West Drayton rail station to the centre of the site and will create a direct route to the bus stops near the Horton Road/Ironbridge Road North roundabout. This should be appropriately delineated using colour and tactile information, and a minimum of 4m in width.

 It is noted that at Horton Interchange, Ironbridge Road North and Horton Road there are uncontrolled pedestrian crossings. TfL requests that the applicant investigates the potential to provide zebra crossings in place of the uncontrolled crossings to improve pedestrian permeability and safety in this location and that crossings include dropped kerbs and tactile paving.

 It is noted that there are footways on both sides of Horton Road that link to Yiewsley town centre and West Drayton Station, which form part of the London Loop. The Loop is part of the Strategic Walk Network (SWN) and is routed along the canal towpath. The applicant’s willingness to contribute towards improving the canal towpath for use as a pedestrian/cycle route is welcomed.

76 The site is adjacent to a ‘route on quieter roads recommended by cyclists’ as shown in the transport assessment. However, the personal injury accident data shows that twelve personal injury accidents occurred within the recorded period; with nine accidents occurring at the Horton Interchange junction and four of these involving cyclists. The applicant is therefore requested to investigate improving facilities for cyclists at the Horton Interchange junction in order to comply with London Plan Policy 3C.22 (Improving conditions for cycling) and London Plan: draft consultation replacement Policy 6.9 (Cycling).

77 It is intended that within the site, cyclists would share road space with vehicles as the roads will be lightly trafficked, and access from Horton Road and Ironbridge Road North for cyclists would therefore be via the road access points. This is welcomed as it will reduce conflict between pedestrians and cyclists on the internal roads.

78 It is proposed that cycle parking will be provided in line with TfL standards in the first instance, and that usage would be monitored and the parking provision increased as demand

page 21 required it, up to the London Borough of Hillingdon standards. This is in line with London Plan Policy, however, clarification is required as to where the cycle parking for each plot will be provided. Cycle parking should be accessible and convenient and accesses should ideally be segregated from car parking accesses. Furthermore, showering and changing facilities should be provided for employees cycling to the site and CCTV is recommended as a further security measure.

Buses

79 The Stockley Park site is served by three routes and the information presented demonstrates that up to 50 people would use buses to access the site in the peak hour (although this may increase when the car parking is brought to within London Plan standards). It is considered that the development of Crossrail would contribute to increased public transport use to access the site making it more viable, with local bus services being used to transfer between the nearby stations and the site. The transport assessment details several options for improving public transport at the site. The best method of doing so is to improve the frequencies of routes passing the site as these already provide interchange with the rail network.

80 On this basis, a contribution of £90,000 per annum for three years (total £270,000) towards TfL local bus service improvements to be secured through the s106 agreement. The trigger for this contribution will need to be agreed with TfL.

81 Existing bus stops within walking distance (or 400m) of the site should also be assessed against TFL bus stop accessibility guidance in order to determine if a financial contribution towards upgrades will be required. A standard £10k capped contribution is generally sufficient to bring stops up to TfL standards. These measures will ensure compliance with London Plan Policy 3C.20 (Improving conditions for buses) and 3C.16 (Road scheme proposals) and London Plan: draft consultation replacement Policy 6.7 (Buses, bus transits, trams).

Travel plan

82 The travel plan has been reviewed and is sufficiently robust, however, it fails an ATTrBuTE assessment for the following reasons:

 Baseline modal split figures have not been included to reference against proposed targets

 It is unclear when targets will be ratified

 The monitoring programme is non-committal and does not specify the frequency of monitoring, its duration, its method, how it will be funded and who will be responsible for delivering it – TfL guidance should be consulted

 No information is given on how the travel plan and its measures will be funded

83 This information should be taken into account and resolved prior to determination of the application. The travel plan including its targets, management, measures and monitoring programme should be secured through a section 106.

Construction, Deliveries and Servicing

84 A construction logistics plan and delivery and servicing plan will be required in order to minimise the impact of vehicles on the road network and should include the following:

 booking systems

page 22  consolidated or re-timed trips

 secure, off-street loading and drop-off facilities

 mode-shift from road to rail

 using operators committed to best practice, demonstrated by membership of TfL’s Freight Operator Recognition Scheme (FORS), or similar.

85 It is recommended that these documents be secured by condition in order to comply with London Plan Policy 3C.25 (Freight strategy) and London Plan: draft consultation replacement Policy 6.14 (Freight).

86 The proposed use of the Grand Union Canal to import construction materials by boat is supported.

Traffic Management Act

87 Should this application be granted planning permission, the developer and their representatives are reminded that this does not discharge the requirements under the Traffic Management Act 2004. Formal notifications and approval may be needed for both the permanent highway scheme and any temporary highway works required during the construction phase of the development.

Summary

88 In summary, further work on trip generation (hotel aspect), highway capacity, taxis, a reduction in car parking levels, the pedestrian and cycling environments, and a bus stop accessibility audit. A total of £270,000 (split evenly over 3 years) towards TfL local bus service improvements is requested in order to mitigate increased bus trips to and from the site to be part of the s106 agreement. Both a Construction Logistics Plan and Delivery and Servicing Plan should be secured through condition. Regarding the travel plan, further work is required and it should be secured through the s106 agreement. Local planning authority’s position

89 Hillingdon Council is due to consider the application at its planning committee in late November. The Officer recommendation is to approve the application. Legal considerations

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

page 23 Financial considerations

91 There are no financial considerations at this stage.

Conclusion

92 London Plan policies on Green Belt, mix of uses, urban design, inclusive design and access, climate change adaptation and transport and parking are relevant to this application. The application complies with some of these policies but not with others, for the following reasons:

 Green Belt: the principle of development on this site has been established through a previous (implemented) planning permission and the proposal is supported by London Plan policy 3D.9 and Draft Replacement London Plan policy 7.16.

 Mix of Uses: The use of the site to provide a hotel, in addition to office and commercial uses is supported by London Plan policies 3B.4, 5F.1, 5F.2, 3D.5 and Draft Replacement London Plan policies (tbc).

 Urban design: The general design approach is supported.

 Inclusive Design: The scheme integrates inclusive design throughout the site but fails to make any commitment in relation to the internal layout of the buildings or provision of wheelchair accessible hotel rooms, contrary to London Plan policies 3A.5, 3D.7 and 4B.5 and Draft Replacement policies 4.5 and 7.2.

 Blue Ribbon Network: The landscaping proposed for alongside the canal is supported, and in accordance with London Plan policies 4C.3, 4C.11, 4C.12 and 4C.20, and Draft Replacement policies 7.24, 7.27, 7.28 and 7.30.

 Climate change mitigation and adaptation: Additional details set out above are required in order to accord with London Plan policies 4A.3, 4A.4, 4A.6, 4A.7, 4A.14 and 4A.16 and Draft Replacement policies 5.1, 5.2, 5.3, 5.5, 5.6, 5.7, 5.9, 5.13.

 Transport: The amount of car parking is not supported and further clarification is required in order to comply with London Plan policies 3C.2, 3C.20, 3C.22, and 3C.25 and Draft Replacement policies 6.3, 6.7 and 6.13.

93 On balance, the application does not comply with the London Plan.

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

 Satisfactorily demonstrating that the internal layout of the buildings would incorporate inclusive design and access, and that a minimum of 45 hotel rooms would be wheelchair accessible.

 Confirmation of the proposed approach to climate change mitigation and adaptation, including benchmarks, district heating, CHP sizing and the renewable energy approach. The agreed approach should be secured by appropriate conditions or a s106 Legal Agreement.

page 24  Satisfactorily address the transport and parking matters set out in this report, and securing these by way of S106 legal agreement.

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

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