planning report GLA/4806/01 25 March 2019

Argenta House in the Borough of Brent

planning application no. 18/4847

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

The proposal Demolition of the existing building and redevelopment to provide a 28-storey building comprising 151 residential dwellings with associated cycle parking, landscaping and enabling works.

The applicant The applicant is Londonewcastle Capital Ltd and the architect is FAL Architects.

Strategic issues summary Land use principle: no objection is raised to the loss of the office use. The proposed housing use is welcomed. (paragraphs 22-28).

Affordable Housing: The application currently proposes 30% affordable housing by habitable room, comprising 71.2% social rent and 28.8% intermediate. The viability of the scheme is being robustly assessed to ensure the maximum level of affordable housing is being provided the applicant is strongly encouraged to realise the benefits of the Fast Track Route. (paragraphs 29- 39).

Urban design and heritage: further work is required to maximise active frontages on the ground level. Further information on the management of the brook and the results of design review panel is required. (paragraphs 40-52). Matters in relation to inclusive design (paragraph 53), climate change (paragraph 54-57), flood risk, drainage and water (paragraphs 58-61) and transport (paragraph 62-73) should also be addressed.

Recommendation That Brent Council be advised that whilst the scheme is supported in principle, the application does not comply with the London Plan and draft London Plan for the reasons set out in paragraph 77 of this report.

page 1 Context

1 On 16 January 2018 the Mayor of London received documents from Brent Council notifying him of a planning application of potential strategic importance to develop the above site for the above uses. Under the provisions of The Town & Country Planning (Mayor of London) Order 2008 the Mayor has to provide the Council with a statement setting out whether he considers that the application complies with the London Plan, and his reasons for taking that view. The Mayor may also provide other comments. This report sets out information for the Mayor’s use in deciding what decision to make.

2 The application is referable under the following Categories of the Schedule to the Order 2008:

• 1A – “Development which comprises or includes the provision of more than 150 houses, flats, or houses and flats.”

• 1C – “Development which comprises or includes the erection of a building more than 30 metres high outside the City of London.”

3 Once Brent 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.

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

5 The site is a block of land approximately 0.15 hectare in size located opposite Stonebridge Park station, in the . The site is bounded to the north and east by Point, a 21 storey office building (with recent permission under permitted development for conversion to 440 units) with considerable surface level parking. To the south and east, the site is bounded by Argenta Way and Point Place. Further east is the Old .

6 The existing site comprises a two storey building, the current owner-occupier is Ari D Noman Ltd, a jewellery company, who have confirmed via their agents that they have occupied Argenta House since March 1989, and use it as their business headquarters.

7 It appears from evidence provided to the GLA that any industrial activities that may previously have taken place on site have now made way for the more modernised internet-based distribution business and the current use falls within office (class B1(a). There is some storage on site but it is understood this is ancillary to the main use.

8 There is also a small news kiosk within the site fronting Argenta Way, primarily serving commuters using Stonebridge Park station.

9 The site forms part of a wider site allocation called Wembley Point, set out in Brent’s Site Specific Allocation Development Plan Document. This allocation comprised both Argenta House and Wembley Point and requires the retention of the office use of the Wembley Point building and development of part of the site for residential and other uses which are complementary to the mixed office/residential development.

10 The applicant has advised that Wembley Point site is under different ownership and the owner does not wish to bring the site forward for comprehensive redevelopment, preferring the office to residential conversion already secured.

page 2 11 No heritage assets exist near to the site, but given the scale of the building, the potential impact on heritage has a wide scope.

12 The existing building is stilted over a brook. The site falls within flood zone 3.

13 The site is adjacent to the boundary of the Old Oak and Development Corporation and Royal Park Opportunity Area but falls outside of these boundaries.

14 The site is bound by Argenta Way to the south, Point Place to the west, Wembley Point to the north and the Old North Circular Road to the east. The nearest section of the Road Network (TLRN) is the North Circular Road, located approximately 150m to the east of the site. The site is located directly opposite to the entrance to Stonebridge Park station, which is served by () and (Watford to London Euston) services. The nearest bus stop is located directly outside the site, which is served by routes 112 and 440. The site has a Public Transport Access Level (PTAL) of 4, on a scale of 0-6b, where 6b is highest.

15 The existing vehicular access on Argenta will be closed and reinstated as footway, which is supported, in line with the Healthy Streets approach. A new vehicular access is proposed on Point Place, which is considered acceptable in strategic highway terms.

Details of the proposal

16 The scheme proposes redevelopment of the site to provide a residential scheme of 151 residential units in a building of 28 storeys in height, with associated cycle parking, car parking amenity space.

17 The proposals also involve the creation of a new riverway biodiversity area through the reprofiling and alignment of Wembley brook and the introduction of new planting and habitat areas. Case history

18 26 September 2018, a pre-application meeting was held with GLA and TfL officers regarding the above proposal. Advice was subsequently issued on 13 December 2018. GLA officers concluded that the proposed redevelopment of the site to provide a residential-led scheme comprising 156 units is supported in principle and the scale and massing is appropriate. The constraints faced by the site in relation to Wembley Brook and Environment Agency’s advice present various design challenges to the scheme, and in any planning application brought forward the applicant should demonstrate that the most appropriate approach has been taken to redeveloping the site independently of Wembley Point. GLA officers requested further involvement as the scheme progressed. In addition, issues relating to affordable housing; urban design; inclusive access; climate change; flood risk, drainage and water; and transport must also be addressed in order to make the proposals compliant with the London Plan and draft London Plan. Strategic planning issues and relevant policies and guidance

19 For the purposes of Section 38(6) of the Planning and Compulsory Purchase Act 2004, the development plan in force for the area comprises London Borough of Brent Local Plan (comprising its Core Strategy (2010) and Development Management policies (2016)) and the 2016 London Plan (Consolidated with Alterations since 2011).

20 The relevant issues and corresponding policies are as follows:

• Principal of development London Plan; Town Centres SPG • Housing and affordable housing London Plan; Affordable Housing and Viability SPG (this

page 3 must now be read subject to the decision in R (McCarthy & Stone) v. Mayor of London).; Housing Strategy; Shaping Neighbourhoods: Play and Informal Recreation SPG; Shaping Neighbourhoods: Character and Context SPG • Urban design and heritage London Plan; Shaping Neighbourhoods: Character and Context SPG; Housing SPG; Shaping Neighbourhoods: Play and Informal Recreation SPG • Tall buildings/views London Plan, London View Management Framework SPG • Inclusive design London Plan; Accessible London: achieving an inclusive environment SPG • Climate change London Plan; Sustainable Design and Construction SPG; London Environment Strategy • Flood risk, drainage & water London Plan; London Environment Strategy • Transport London Plan; Mayor’s Transport Strategy; the Mayor’s Transport Strategy

21 The following are relevant material considerations:

• Revised National Planning Policy Framework (February 2019); • National Planning Practice Guidance; • Draft London Plan (consultation draft December 2017, incorporating early suggested changes published August 2018) which should be taken into account as explained in the NPPF; and • Brent’s Site Specific Allocations Development Plan Document (2011).

Land use principle

22 The site allocation seeks to retain some employment uses as part of a mixed use redevelopment of Wembley Point (a large office tower) and Argenta House. It is nevertheless recognised that the office use of Wembley Point (representing the vast majority of the site allocation), has now been lost as a result of the exercise of office to residential permitted development rights. It is therefore accepted that the Wembley Point site is unlikely to come forward for the form of comprehensive development envisaged by the local plan site allocation. Therefore, GLA officers have considered the proposals for the Argenta House site as a standalone scheme on its own merits, having regard to the objectives of the local plan site allocation in so far as they may now be reasonably achieved.

23 Whilst the built characteristics of the site reflect its past industrial use, it is noted that the site does not now appear to have been used for industrial purposes for several decades.

24 The applicant has submitted evidence of the use of the site and GLA officers accept that the building is now in office use. The applicant has also confirmed that there are no tenants that would need to be moved on to facilitate redevelopment, as the property is owner occupied and the business is moving to elsewhere in the Borough.

25 The existing employment use is in poor condition and would require significant expenditure to bring it up to the required standards for modern usage. The current use of the building is for distribution of jewellery, with the applicant confirming that the manufacturing processes on site have ceased as the owner-occupier’s business has evolved.

26 London Plan Policy 4.2 and draft London Plan Policy E1 allows the release of surplus office capacity to other uses. Given the office is occupied, there is no justification of the office space being considered surplus, however, as it is not located within or near a town centre and is owner-occupied

page 4 and a business is not being displaced, GLA officers do not object to the loss of the office use in this instance.

27 Wembley Brook runs through the site and would run beneath the proposed development. The applicant has worked with the Environment Agency to ensure that there would be no negative impact to the brook as a result of the redevelopment. Whilst the proposals are compromised to some extent in design terms by this, the presented scheme appears to be the best approach to optimise the development potential of the site.

28 Having assessed the evidence and proposals submitted, GLA officers raise no objection to the loss of the office use and the proposed housing use is welcomed. Housing and affordable housing

29 London Plan Policy 3.3 and draft London Plan Policy H1 seek to increase the supply of housing in the capital. The proposals would provide 156 homes, which equates to 10% of the annual monitoring target for London Borough of Brent of 1,525 set out in the London Plan (and 5.4% of the annual monitoring target of 2,915 set out in the draft London Plan). The increase in the housing targets identified in the draft London Plan evidences the continued need for housing in the Brent area.

30 London Plan Policies 3.11 and 3.12 and draft London Plan Policy H5 and Policy H6 seek to maximise the delivery of affordable housing, setting a strategic target of 50% across London. Draft Policy H7 provides a flexibly prescribed tenure mix of: 30% social rent / London Affordable Rent; 30% intermediate products; and, 40% to be determined by the relevant local authority based on identified need and consistency with the definition of affordable housing.

31 The draft London Plan and the Mayor’s Affordable Housing and Viability Supplementary Planning Guidance seek to increase the provision of affordable housing in London and embed affordable housing into land prices. The SPG introduced a threshold approach to viability, which is incorporated within draft London Plan Policy H6; schemes that provide 35% affordable housing by habitable room (or 50% on industrial or public land) without public subsidy and that meet other criteria, including tenure, are not required to submit viability information to the GLA. Such applications are also exempted from a late stage review mechanism; this is known as the Fast Track route.

32 The applicant has demonstrated that the current use of the site is office. To follow the Fast Track Route, 35% affordable housing by habitable room offer should be made by the applicant in accordance with the draft London Plan. In addition, the affordability of the units must accord with the requirements of Policy H7 of the draft London Plan, the Mayor’s Affordable Housing and Viability SPG and the London Plan Annual Monitoring Report. Details of the proposed social and intermediate rents must therefore be submitted, and the applicant should note that London Affordable Rent and London Living Rent are the Mayor’s preferred affordable housing tenures.

33 The application currently proposes 30% affordable housing by habitable room. Of the affordable housing offer, the proposals comprise 71.2% social rent and 28.8% intermediate when calculated by habitable room.

34 The applicant is following the viability tested route and a Financial Viability Assessment has been submitted as part of the application. This is undergoing robust assessment working in partnership with the applicant, the Council and its independent assessors, to ensure that the maximum contribution is secured in accordance with Policies 3.11 and 3.12 of the London Plan, and Policies H5 and H6 of the draft London Plan.

35 The applicant should investigate Mayoral grant funding opportunities as part of this process and demonstrate this has been fully explored.

page 5 36 In accordance with Policy H6 of the draft London Plan, the S106 agreement must include an early stage viability review mechanism to be triggered if an agreed level of progress on implementation has not been made within two years of any planning permission. Given this scheme is following the viability tested route, a late stage review will also be required and secured within the S106 to optimise affordable housing delivery in accordance with strategic policy objectives. A draft of the S106 agreement must be agreed with GLA officers during the course of the application in advance of Stage II referral.

Housing mix

37 London Plan Policy 3.8 and draft London Plan Policy H12 encourage a full range of housing choice. Draft London Plan Policy H12 recognises that central or urban sites may be most appropriate for schemes with a significant number of one and two beds, owing to the accessible location, the proposed housing mix does not raise any strategic planning concerns.

Children’s play space

38 Policy 3.6 of the London Plan and Policy S4 of the draft London Plan, seeks to ensure that development proposals include suitable provision for play and recreation. Further detail is provided in the Mayor’s supplementary planning guidance (SPG) ‘Shaping Neighbourhoods: Play and Informal Recreation’, which sets a benchmark of 10 sq.m. of useable child play space to be provided per child, with under-fives play space provided on-site as a minimum.

39 The applicant has calculated the required play space for the proposals as 500 sq.m. Given the constraints of the site and nature of the development, the applicant has provided the under 5s play space (75 sq.m) on site on the 27th floor. S106 contributions to support improvements to local open space and an appropriate agreement should be reached with the Borough and secured in the s106 agreement. Urban design and heritage

40 Polices D1 and D2 of the draft London Plan promote the efficient use of land by optimising density through the delivery of high quality design, that responds appropriately to its local context by delivering buildings and spaces that are positioned and of a scale, appearance and shape that responds successfully to the identity and character of the locality, including the existing and emerging street hierarchy, building types, forms and proportions. Policy D2 sets out the principles for delivering good design and the process of evaluation and analysis that should underpin the design process.

41 The opportunity to redevelop this site is recognised, particularly with the site allocation and close proximity to public transport, with Stonebridge Park opposite the site. The broad massing arrangement is supported in this location.

42 The proposal brought forward here is derived as a result of the land ownership within the wider site allocation, resulting in compromised layout and massing, and considerable challenges with the presence of Wembley Brook, over which the building sits. As discussed earlier in the report, the applicant has advised that the neighbouring land owner (Wembley Point), intends to implement the prior approval permission for office to residential conversion, and there is no likely wholesale redevelopment of the site in the foreseeable future.

43 The presence of the brook significantly constrains the delivery of development on the site, particularly when seeking to deliver a scheme that is successful in terms of ground floor uses, public realm and overall urban design aspirations.

page 6 44 Nevertheless, the double height entrance provides visual interest at ground level when accessing the site from the east, and offers a legible entrance to the building from the east and when arriving from Stonebridge Park station.

45 The applicant has introduced a kiosk on Argenta Way, which activates the road frontage. Further opportunities to activate more of the ground floor of the building should also be explored, particularly given it is visible in routes to the station. There remains a great deal of inactive façade facing Argenta Way and it should be demonstrated that this has been minimised and all options considered in locating services, plant and refuse storage as it currently conflicts with the improvements required to the public realm in this area and should be reconsidered. The design should also avoid any ‘left over’ spaces or poorly overlooked areas that could encourage anti-social behaviour.

46 In landscaping terms the relocation of the brook and renewal of this space requires careful consideration and proposals have developed positively. The proposals have been supported by a comprehensive and well thought out landscaping strategy which also shows it will be accessible by ramp or staircase. It should be further demonstrated how this would be managed in terms of safety and surveillance issues, including who has access to this space and when. Further details on the boundary treatment and how the undercroft over will be treated and secured is also required.

47 It is positive that the layout allows for a maximum of seven units per core. The applicant has sought to maximise the number of dual aspect units. There are no single aspect units facing due north.

48 The application is supported by a daylight and sunlight report, which concludes that the range of detailed assessments are concluded as demonstrating only limited, but acceptable impacts to existing daylight and sunlight amenity of neighbouring dwellings and that the proposed development would provide very good amenity for future occupants.

49 The proposed tall building sits outside the LVMF corridors. A Townscape and Visual Impact Assessment has been submitted which assesses the proposals in long distance modelling. GLA officers do not raise any concerns in urban design or heritage terms in this regard and consider that the proposals will not cause any harm to heritage assets.

50 The higher the density of a development, the greater the level of scrutiny that is required of its design, particularly the qualitative aspects of the development and the proposed ongoing management. Given the accessibility of the site, the proposed density is considered appropriate subject to high quality design.

51 Development proposals for tall buildings referable to the Mayor must have undergone at least one design review early on in their preparation, before a planning application is made. The scheme was considered by the London Borough of Brent and CABE design review panel. CABE made similar recommendations to that of the GLA at pre-application stage, recommending that the two sites (Argenta House & Wembley Point) are developed together and not in isolation. They also recommended that the scheme incorporates areas surrounding the site and create a more holistic look and feel to the wider area and recommended further activation for those coming from the station past the site.

Fire safety

52 In the interests of fire safety and to ensure the safety of all building users, Policy D11 of the draft London Plan seeks to ensure that development proposals achieve the highest standards of fire safety. The applicant must provide a statement that demonstrates that all features and materials would comply with Part B of the Building Regulations.

page 7 Inclusive design

53 London Plan Policy 3.8 and Policy D5 of the draft London Plan require that ninety percent of new housing meets Building Regulation requirement M4(2) ‘accessible and adaptable dwellings’ and ten per cent of new housing meets Building Regulation requirement M4(3) ‘wheelchair user dwellings’, that is, designed to be wheelchair accessible or easily adaptable for residents who are wheelchair users. The applicant details the accessibility of the site and specified 10% accessible units. It is stated that the accessible units are provided across tenders and all unit sizes. The applicant should identify the location of wheelchair units on the plans. Details of the ramp access to the brook should also be provided, and it should be demonstrated that the proposals comply with the accessibility requirements for such space. Climate change

54 The Energy Hierarchy has broadly been followed; however, the applicant is required to review their energy proposals to ensure compliance with the London Plan policies.

55 The applicant is encouraged to use the GLA’s Carbon Emission Reporting spreadsheet, which has been developed to allow the use of the updated SAP 10 emission factors alongside the SAP 2012 emission factors. The link to the spreadsheet can be found here: https://www.london.gov.uk/what- we-do/planning/planning-applications-and-decisions/pre-planning-application-meeting-service-0 This is encouraged to be submitted for review.

56 For the purposes of this assessment, the applicant should confirm whether they will be estimating the CO2 emission performance against London Plan policies using the SAP 2012 or SAP 10 emissions factors. Robust justification should be provided for the use of the SAP 2012 emissions factors.

57 A detailed report on energy has been issued under separate cover to the LPA and applicant. The key points requiring action are outlined below:

• The DER worksheets for each stage of the energy hierarchy should be provided;

• Further passive measures for Be Lean and overheating need to be considered;

• Dynamic overheating analysis needs to be undertaken and provided;

• CHP is not supported for this development and alternative technologies must be used; and

• Further information on the design for connection to district heating; and

• A detailed roof layout should be provided demonstrating that the roof’s potential for a PV installation has been maximised and clearly highlighting any constraints.

Flood risk, drainage and water

58 A detailed report on flood risk, drainage and water has been issued under separate cover to the LPA and applicant. The key points requiring action are outlined below.

59 The approach to flood risk management for the proposed development generally complies with London Plan policy 5.12 and draft London Plan Policy SI12). The Applicant should consider flood resilient construction for the ground floor to a suitable freeboard depth above the modelled flood level.

60 The surface water drainage strategy for the proposed development does not comply with London Plan policy 5.13 and draft Policy SI13), as it does not give appropriate regard to the drainage

page 8 hierarchy and greenfield runoff rate. Further details on how SuDS measures at the top of the drainage hierarchy will be included in the development, and how greenfield runoff rate will be achieved should be provided. Additional attenuation storage volume calculations should also be provided.

61 The proposed development generally meets the requirements of London Plan Policy 5.15 and draft London Plan Policy SI5. The Applicant should also consider water harvesting and reuse to reduce consumption of wholesome water across the entire development site. This can be integrated with the surface water drainage system to provide a dual benefit.

Transport

Public Transport Impact

62 The development will add noticeable demand to services at Stonebridge Park station and TfL are concerned about gate line capacity for which a contribution is sought. Options are currently being considered and it is expected the development will contribute towards a feasibility study and infrastructure. As an alternative to insufficient and sub-standard disabled parking, an additional contribution towards the study should be secured.

63 The proposals would not give rise to any capacity issues on buses or London Overground services. However, the development should not impact bus services on Argenta Way, and therefore the location of disabled car parking should be carefully considered so as not to interfere or impact on this.

Walking, Cycling and Healthy Streets

64 In order to support the Healthy Streets approach, it is recommended that ‘places to stop and rest’ such as benches are provided. Additional active frontage would further help to contribute towards delivering improvements against the Healthy Streets indicators, as well as providing natural surveillance, ensuring the safety and security of passengers using Stonebridge Park station.

Car Parking

65 No general car parking is proposed, which is supported, in line with draft London Plan policy T6.1.

66 Two disabled parking spaces are proposed to the west of the main building, requiring users to travel a significant distance from their car to the site entrance, therefore TfL does not consider these to be fit for purpose. The provision represents a shortfall against Draft London Plan Policy T6.1, which requires at least one disabled persons parking bay for 3% of dwellings (5) from the outset and it to be demonstrated on a plan how an additional 7% of dwellings (15) could be provided upon request. On- street options to deliver the 5 required blue badge spaces have been presented, however a number of these raise highway safety issues, relocation of bus stops, as well as requiring disabled residents to walk significant distances, therefore these are not considered acceptable. It is strongly recommended that the applicant significantly contribute towards feasibility work and infrastructure at Stonebridge Park station, where Step Free Access could be provided as an alternative to providing insufficient and sub- standard disabled persons car parking.

67 The area around the site is not currently a Controlled Parking Zone (CPZ), however as part of the proposals, the applicant is willing to contribute towards funding the principle of introducing a CPZ in the local area, which is welcomed and supported. This contribution should be secured by S106 agreement and future residents should be prevented the opportunity to obtain a parking permit.

page 9 Cycle Parking

68 A total of 280 long-stay and 10 short-stay cycle parking spaces are proposed, in accordance with draft London Plan policy T5. All cycle parking and proposed lifts should be designed in accordance with the London Cycling Design Standards (LCDS). An alternative arrangement should be in place in the case that the lift breaks down. It is recommended that all two-tier racks should have a mechanically or pneumatically assisted system for accessing the upper levels as many people find using these spaces difficult.

69 Short stay cycle parking is proposed to be located in the public realm in the form of Sheffield stands, in line with draft London Plan policy T5.

Freight

70 The application is supported by a Construction Management Plan and a Delivery and Servicing Plan. Proposed construction arrangements which suspend the bus stop and footway outside the site are not considered acceptable. Construction arrangements should be reviewed to allow this bus stop to remain open throughout the construction process, given this is integral to an integrated transport system.

71 Draft London Plan policy T7 requires development proposals to facilitate sustainable deliveries and servicing through the provision of adequate space for servicing, storage and deliveries off street, however the site constraints are noted. It is, therefore, accepted that this will take place on Argenta Way. It should be demonstrated that delivery and servicing arrangements do not impact the safe and efficient operation of buses, including passenger safety and convenience.

Travel Planning

72 A residential travel plan should be produced and secured by condition on any consent and appropriate funding to enforce and monitor the travel plan should be secured by S106 agreement.

Mayoral Community Infrastructure Levy (MCIL)

73 MCIL is charged at a rate of £35 per square metre of floorspace in the London Borough of Brent. In June 2017, the Mayor published proposals for an MCIL2. This would be levied from April 2019 and would replace both MCIL and the S106 contributions scheme. Local planning authority’s position

74 The Council are currently considering the case and are planning to take the application to their planning committee in April 2019. Legal considerations

75 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 (the next bit is optional) and any connected application. There is no obligation at this

page 10 present stage for the Mayor to indicate his intentions regarding a possible direction, and no such decision should be inferred from the Mayor’s statement and comments. Financial considerations

76 There are no financial considerations at this stage. Conclusion

77 London Plan policies on affordable housing, urban design, heritage, inclusive design, climate change, flood risk, drainage and water and transport are relevant to this application. The application does not yet fully comply with the London Plan and draft London Plan as set out below:

• Land use: no objection is raised to the loss of the office use. The proposed housing use is welcomed.

• Affordable Housing: The application currently proposes 30% affordable housing by habitable room, comprising 71.2% social rent and 28.8% intermediate. The viability of the scheme is being robustly assessed by the GLA to ensure the maximum level of affordable housing is being provided.

• Urban design and heritage: further work is required to maximise active frontages on the ground level. Further information on the management of the brook.

• Inclusive design: further details on accessibility required, including access to the Wembley brook.

• Climate change: CHP is not supported. DER worksheets are required. Further passive measures for Be Lean and overheating need to be considered. Dynamic overheating analysis needs to be undertaken and provided. Details on district heating network and PVs is also required.

• Flood risk, drainage, and water: Consideration of flood resilient construction for ground floor to suitable freeboard depth above the modelled flood level is required; surface water drainage strategy for proposed development does not comply and need to be reconsidered; consider water harvesting.

• Transport: Disabled car parking provision is insufficient and sub-standard, therefore contributions towards Stonebridge Park station should be secured as an alternative, as well as to mitigate the development’s impact on gateline capacities. The proposed CPZ is welcomed whilst it should be demonstrated how improvements against the ten Healthy Streets indicators are achieved. Construction arrangements should be reviewed and it should be demonstrated how delivery arrangements do not impact buses.

for further information, contact GLA Planning Unit (Development & Projects Team): Juliemma McLoughlin, Chief Planner 0207 983 4271 email [email protected] John Finlayson, Head of Development Management 0207 084 2632 email [email protected] Graham Clements, Team Leader 020 7983 4265 email [email protected] Luke Butler, Senior Strategic Planner, case officer 020 7084 2562 email [email protected]

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