Contact: Sonya Heenan 0208 583 4937 e-mail: [email protected] Sustainable Development Committee 4 June 2007

References: P/2007/0661 00607/42-50/P3

Address: Thameside House, 42-50 High Street, Brentford

Ward: Syon

Proposal: Erection of two additional floors to the existing building, to provide three one-bedroom flats and seven two-bedroom flats and an extension to provide a lift shaft

Drawing numbers: 001 Rev A, 005 Rev A, 006 Rev A, 007 Rev A, 008 Rev A, 009 Rev A, 010 Rev A, 011 Rev A, 030 Rev A, 031 Rev A and 032 Rev A dated 22 November 2005 and received 6 March 2007

Application received: 6 March 2007

1.0 SUMMARY 1.1 The proposal comprises the erection of two additional floors to the existing building, to provide 3 x 1 bedroom flats and 7 x 2 bedroom flats and an extension to provide a lift shaft. There would be 35 car parking spaces, and the existing offices would be retained. The proposed density for the development would be 212 habitable rooms per hectare.

1.2 The principle of the development is considered satisfactory, in the context of the Unitary Development Plan and other relevant policy and material consideration. The development can be serviced in terms of transportation, and the physical impacts of the scheme, including the size and scale of the proposal, layout and the resultant impact on surrounding area including the riverside and other environmental issues, can be mitigated subject to appropriate conditions and a unilateral undertaking.

2.0 SITE DESCRIPTION 2.1 The site is on the southern side of High Street, Brentford, and falls within the town centre boundary. There is an existing four-storey 13.6 m high office block on the site that had planning permission approved in the 1970’s.

2.2 The property has an area of 1296m2, and the existing office floor space is 2034m2. The building is an ‘L’ shape, with frontage onto the High Street, and extends down towards the . It has a flat roof, and is clad in brick, with car parking located in the ground floor. There is currently minimal landscaping to the front of the site, which consists of some grass and trees, surrounded by a predominately hard surface.

2.3 The site is in a prominent location, highly visible from the High Street and to the west of the site are some existing trees, which create a visual break. Opposite the site is Albany Parade (eight storey high) and other surrounding properties to the east include 41 High Street, which is a three storey flat roofed former office block, and the buildings to the rear are also three storeys high. Further along from the site is the Watermans Art Centre, and to the west of the site are the Goat Wharf Buildings and the Premier Travel Inn. 2.4 Nearby stations are at , Brentford and Bridge. The main bus routes that serve the site are the 235 (Brentford/Sunbury), 267 (Hammersmith to Fulwell Bus Garage), the 237 (Shepherd’s Bush/Hounslow Heath) and 65 (Kingston to Ealing Broadway). In addition, routes E2 (Brentford to Greenford) and E8 (Brentford to Ealing Broadway), which service the tube, and Brentford Train Station pass nearby. This gives a Public Transport Accessibility Level (PTAL) of 2. PTAL uses a mathematical formula to demonstrate accessibility by public transport. The values of a site may range from 1 at the lower end of the scale to 6 at the higher.

2.5 The site falls within the Thames Policy Area and the Town Centre Boundary. is located on the opposite side of the river.

3.0 HISTORY 3.1 Previous planning history for the site includes:

3.2 00607/42-50/P1 Demolition of existing buildings, erection of a four storey office block and construction of a car parking area

APPROVED – 28 December 1978

3.3 00607/42-50/P3 Erection of 2 additional floors to existing building to create an additional 10 x two bedroom apartments REFUSED – 1 June 2006

Reasons for refusal:

1. Scale, massing and design unacceptable in this riverside location, would not make a positive contribution to the site’s waterside setting, harmful therefore to this important Thameside location and the amenities of neighbouring properties including loss of outlook and harmful to the street scene. 2. Insufficient details of car and cycle facilities, refuse and recycling provision, wheelchair provision, and pedestrian access within the building and the impact on the existing office. It was considered that the proposal would likely lead to pedestrian conflict and parking congestion.

3.4 An appeal was lodged and dismissed on 22 November 2006. The Inspector made the following comments:

“I conclude that the Council’s second reason for refusal is well founded in relation to car parking provision, and that in the absence of a proper assessment there would be a significant risk of making inadequate provision and suffering the consequences of congestion and safety problems that development plan policies aim to avoid.

On the other hand I accept that the scale, massing, height and design of the proposed extension of the appeal building are not inappropriate in its surroundings. Indeed, I believe it would have a positive effect on the street-scene and the appearance of the existing building, which as the Appellant points out, is presently rather tired and dated. The additions would enliven it and would relate well to some other modern development in the locality, such as the neighbouring hotel and the development at Ferry Quays

Taking into account the height of the latter, which is nearer to the river, and other nearby buildings, including the 8-storey block on the other side of the High Street, I do not doubt that the height and scale of the appeal building would be in keeping with its surroundings. The lightweight appearance of the proposed structure, its design and its set-back from the principal elevations lead me to conclude that there would be no overpowering visual effects. Nor do I consider that it would harm views from the river, the Thames Riverside open land, or Kew Gardens on the other side of the river; or that it would conflict with UDP policies relating to the river environment and the Thames Policy Area.

I do not find that the proposals would harm the amenities of the occupiers of neighbouring properties. Some of the shortcomings of detail identified by the Council could be dealt with by means of planning conditions. I appreciate that the proposals have considerable planning merits in terms of making more efficient use of land and providing for mixed use of the appeal building. However neither of these nor any of the other merits identified in the written representations are sufficient to outweigh my adverse findings on parking provision, and it is on this limited basis that I come to my overall conclusion that the appeal scheme is unacceptable.”

4.0 DETAILS 4.1 The proposal is to build two additional floors to the existing building, raising it to six storeys, to provide three one-bedroom flats and seven two-bedroom flats, and including a lift shaft to access these floors. The proposal would retain the existing 4 floors of offices, so there would be no loss of employment.

4.2 Access to the flats is via stairs and a lift is proposed. The density for the entire site is 212 HRHA, although this does not account for any of the office floor space, which must also be considered. If all of the floors were residential based on the same layout as the proposed flats, the estimated density is 636 HRHA.

4.3 Each of flats would have either one or two bedrooms, kitchen and living area.

4.4 Each flat would have a private balcony area not less than 10 m2. Only two would be at that level and one other (at 21 m2) would be less than the UDP minimum standard of 25 m2. Most would be more generous, albeit that some are not very deep, and some can properly be considered as roof terraces, not balconies. The flats would also all have access to shared amenity areas comprising two covered and one open balcony totalling 30 square metres. The total amount of amenity space is 351m2.

4.5 The proposal would put two additional floors on the existing four-storey building. The 5th and 6th floor levels would have a curved aluminium roof when viewed from the side elevation. Around the perimeter of the building there would also be a galvanised steel balcony with glass balustrade, which would be used for amenity space for the flats. There would be an extension to the front elevation, which would be curved and would have alucobond cladding for lift access to all floors.

4.6 There would be a total of 35 car parking spaces on site, of which ten would be used by the residential units. In addition, cycle parking is proposed at ground floor level, and refuse/recycling storage would also be in this area. Pedestrian and cycle access would be off the High Street. Landscaping is proposed along the front of the site to improve the appearance from the streetscene. The key changes from the previous scheme relate to provision of car parking, cycle stands, refuse and recycling areas and landscaping. 5.0 CONSULTATIONS 5.1 The Council consulted the following properties.

Property Street Flats 1-15 High Street, Brentford 41 318

1 and 2 Goat Wharf Hotel (Premier Lodge)

1-5 (Consecutive) Ferry Lane 1-19 (Consecutive) (including flats above) Albany Parade 31-45 Waterman’s Court Kew Gardens Thames Landscape Strategy Environment Agency Brentford Waterside Forum Feltham Police Station Borough of Richmond Port of London Authority

5.2 In addition a site notice was posted, and the proposal was advertised in the Middlesex Chronicle, and available at the Brentford Library. Internal consultations were also undertaken. Two objections have been received as detailed below. The following objection was received:

5.3 OBJECTION RESPONSE Overlooking and loss of light for Goat Wharf. Refer to paragraphs 7.2. Impacts on the existing nature of the views of Refer to paragraphs 7.36 to 7.40. the river and dominant frontage. Increase in traffic congestion. Refer to paragraphs 7.45 – 7.53 Increase in parking congestion unless there is Refer to paragraphs 7.45- 7.53. offsite parking on the side for all residents and visitors.

5.4 Other External responses:

5.5 Port of London Authority The Port of London Authority raises no objection to the proposed development.

5.6 Metropolitan Police Service Their concerns have been addressed and Secured by Design has been applied for, so they have no objection to the granting of planning permission. 5.7 London Borough of Richmond The London Borough of Richmond raises no objection but would make the following provisos: Objection would be raised to the use of materials with a shiny finish in this location. REASON: To preserve views to and from the Kew Gardens Conservation Area. Refer to paragraph 7.39.

5.8 COMMENTS FROM ISLEWORTH AND BRENTFORD AREA COMMITTEE The application were reported to the Isleworth and Brentford Area Committee on 12 April 2007:

Members made the following comments: * Members queried the level impact the development would have on the local population and the contributions towards local health and education provision to help mitigate this impact. * The level of local consultation undertaken, particularly with regard to the proximity of the site to the World Heritage Site at Kew Gardens. * The proximity of the site to Lots Ait boatyards and the possibility of installing additional soundproofing for future residents of the proposed scheme in the form of glazing for the balconies on the southern side of the building. * Members requested that further drawings and elevations be drawn up before any submission to Sustainable Development Committee from the point of view of the High Street and the river. * Members noted concern at the PTAL level and informed the meeting that the 65 bus route also serviced the area and that train station was also within walking distance.

These matters are included in the issues section within paragraphs 7.2 to 7.65.

6.0 POLICY 6.1 S38 (6) of the Planning and Compulsory Purchase Act 2004 states “If regard is to be had to the development plan for the purpose of any determination to be made under the planning Acts the determination must be made in accordance with the plan unless material considerations indicate otherwise”.

6.2 The Unitary Development Plan (UDP) and London Plan are both development plans for the Borough. The UDP was adopted in December 2003, and the London Plan in February 2004. Alterations to the London Plan on housing provision targets, waste and minerals were published in December 2006 and now form part of the adopted London Plan.

6.3 Where a policy in the UDP conflicts with policy in the London Plan, the London Plan takes precedence, as it is the more recent of the two Development plans. 6.4 National Policies PPS 1: Delivering Sustainable Development PPS 3: Housing - Supporting the Delivery of New Housing PPS 6: Planning for Town Centres PPS 12: Local Development Frameworks PPG 16: Archaeology and Planning PPG 13: Transport PPS 22: Renewable Energy PPS 23: Planning and Pollution Control PPG 24: Planning and Noise PPS 25: Development and Flood Risk

6.5 The following Circulars are also relevant to this planning application: 11/95: Use of Planning Conditions in Planning Permission 05/05: Planning Obligations

6.6 The London Plan

Overall Strategy Policy 2A.1 Sustainability criteria Policy 2A.3 Areas for intensification Policy 2A.7 Strategic employment locations Living in London Policy 3A.1 Increasing London’s supply of housing Policy 3A.2 Borough housing targets Policy 3A.4 Housing choice Policy 3A.7 Affordable housing targets Policy 3A.8 Negotiating affordable housing in individual private residential and mixed-use schemes Policy 3A.15 Protection and enhancement of social infrastructure community facilities Policy 3A.21 Education facilities Working in London Policy 3B.1 Developing London’s economy Policy 3B.3 Office provision

Connecting London – improving travel in London Policy 3C.1 Integrating transport and development Policy 3C.2 Matching development to transport capacity Policy 3C.22 Parking strategy London’s metabolism: using and managing natural resources Policy 4A.6 Improving air quality Policy 4A.13 Water and sewerage infrastructure Policy 4A.14 Reducing noise Designs on London Policy 4B.1 Design principles for a compact city Policy 4B.3 Maximising the potential of sites Policy 4B.6 Sustainable design and construction Policy 4B.7 Respect local context and communities

6.7 Unitary Development Plan 6.8 The proposal site is within the Brentford Town Centre on the UDP Proposals Map. The relevant policies are IMP.1.1 Integrating patterns of land use and the provision of transport IMP.1.2 The reuse and recycling of urban land and buildings IMP.2.1 Regeneration of Brentford Town Centre and Riverside IMP.3.1 Brentford Regeneration Area IMP.5.2 Thames Policy Area ENV-N.1.5 Protection of Metropolitan Open Land ENV-B 1.1 New Development ENV-B 1.5 Environmental Improvements ENV-B 1.8 Access and facilities for people with disabilities ENV-B 1.9 Safety and security ENV-W.1.1 Design in the Thames Policy Area ENV.W.1.2 Mixed uses in the Thames Policy Area ENV-W.1.3 Important views and structures in the Thames Policy Area ENV-P 1.5 Noise Pollution ENV-P 2.4 Recycling facilities in new developments E.1.5 Development involving loss of or changes in employment uses. E.2.1 Environmental criteria E.2.2 Mixed Uses E.3.1 Disabled access. H.1.1 Location of new housing development H.2.1 Affordable Housing H.4.1 Housing standards and guidelines H.4.2 Residential density H.4.3 Residential Mix H.4.4 Provision for children’s play in housing developments H.4.5 Associated facilities for residential developments H.5.1 Housing for people with disabilities T.1.1 The location of development T.1.2 The movement implications of development T.1.3 Development affecting public transport services T.1.4 Car and cycle parking and servicing facilities T.2.1 Pedestrian access T.2.2 Pedestrian safety and security T.2.4 Public Transport Infrastructure T.4.3 Traffic implications 6.9 Supplementary Planning Guidance General standards and controls Residential standards and controls Think Access – Design for Accessibility 6.10 Local Development Scheme 6.11 The 'Local Development Scheme April 2007' (LDS) is a project plan for the production of the Borough's Local Development Framework, which will in time replace the Unitary Development Plan 2003. A Brentford Area Action Plan (BAAP) and Employment Development Plan Document (Employment DPD) are prioritised in the LDS due in part to the pressure for change in the Brentford area, which has implications for employment land across the Borough.

6.12 The BAAP which covers Brentford Town Centre and riverside stretching north to the Great West Road includes Brentford specific policies and proposals for the future development of sites in the area. The Employment DPD seeks to plan the management, protection and release of land in industrial and commercial use and directs new employment development to appropriate locations.

6.13 The BAAP and Employment DPD are to be submitted to the Secretary of State at the end of June subject to the Council's approval. Consultation on options (June 2005) and the Council's preferred options (January 2006) has been undertaken to inform the preparation of the documents together with national and regional guidance, a sustainability appraisal and background research on employment land, retail need, flood risk and transport impacts.

6.14 The Brentford Area Action Plan (BAAP) 6.15 The Brentford Plan is a policy document that will form part of the Borough’s Local Development Framework, and will replace all ‘Brentford specific’ policies and proposals within the existing UDP. The area covers Brentford Town Centre and riverside stretching north to the Great West Road and is defined by a map within the preferred options paper. 6.16 The preferred options paper sets out the preferred approach to the consideration of new developments within the area and has been informed by the views of local people. This site now does not fall within the preferred options. 6.17 The Thames Landscape Strategy: Hampton to Kew 6.18 This takes a long view of the landscape, looking forward over the next 100 years and operating at two levels, sub-regional and detailed. Commissioned and guided by the Thames Landscape Steering Group, and Published June 1994, it has been adopted by the London Borough of Hounslow as Supplementary Planning Guidance and is cited within the UDP. The Thames Landscape Strategy: Hampton to Kew refers to Brentford/Kew as landscape Character Reach No. 12. 6.19 Hounslow’s Waterside Strategy for the River Thames, River Brent and Grand Union Canal 6.20 This aims to maintain and enhance the quality and character of the waterside environment by providing a basis for comprehensive proposals for improvements to the waterside, in order to achieve a safe, accessible and attractive environment, and through encouraging increased use of the waterways, for recreation, both formal and informal, and transportation. 6.21 Material planning considerations include The Blue Ribbon Network: The Heart of London by the Greater London Authority published in January 2006. 7.0 PLANNING ISSUES 7.1 The key issues for this development can be identified as follows:

1 Whether the principle of the development and provision of flats is acceptable in this Riverside location?

2 Is the intensity of the development appropriate for the site in principle and are the details of the scheme satisfactory? a) The suitability of the site for residential purposes in terms of flood risk and drainage, noise, and air quality?

b) Density and it’s implications – amenity space, internal space and liveability, affordable housing, design and design/daylight/sunlight/shadowing/outlook, accessibility and refuse storage?

3 Can the scheme be accommodated in terms of access and public transport? Is the parking provision appropriate?

4 Are sustainable building principles applied?

5 Is the balance of community benefits appropriate to mitigate the impact of the development and what are the proposed section 106 contributions?

Is the principle of the development and provision of flats acceptable in this Riverside location? 7.2 In the recent appeal decision, which proposed the same height as the current application, the Inspector said, “I do not find that the proposals would harm the amenities of the occupiers of neighbouring properties. Some of the shortcomings of detail identified by the Council could be dealt with by means of planning conditions. I appreciate that the proposals have considerable planning merits in terms of making more efficient use of land and providing for mixed use of the appeal building.” This proposal is the resubmission of the scheme, with the key amendments being to the proposed parking layout to include an area for the residential scheme.

7.3 The overarching aim of the UDP and its implementation principles is to encourage appropriate development in the right place, promoting high quality design and environment (Policy IMP.1.2). These principles are also reflected in relevant National Polices, The London Plan (2004) and relevant Waterside Strategies.

7.4 Policy ENV-N.1.5 seeks to safeguard the permanence, character and integrity of Metropolitan Open Land (M.O.L.) including the Thames Riverside Area, amongst the other key areas to M.O.L.

7.5 Policy ENV-N.1.7 requires that any development in areas near the M.O.L. and conspicuous from within it must not detract from it’s open aspect or visual amenities.

7.6 The site falls within the Thames Policy area where the UDP seeks to protect and enhance the status, quality and vitality of the area. In particular ENV-W.1.1 requires all development proposals: (i) To respect the scale, mass, height, silhouette and skyline; (v) To foster good urban design; and (vi) To have regard to the potential prominence and visibility for the development. 7.7 Policy ENV-W.1.3 seeks to protect important Thameside views and it specifically identifies this locality for protection from development that may impinge upon views including that from Kew Gardens which is a World Heritage site.

7.8 Policy E.1.5 deals with development involving the loss of or changes in employment uses.

7.9 Given the Inspectors report, and given the Council’s own policies, the principle of residential in a mixed-use development is satisfactory subject to the correct detail.

7.10 Policy E.1.5 deals with development involving the loss of or changes in employment uses. However the proposal retains the existing employment use and merely adds flats to the existing building. Provided this does not prejudice the viability of the building as employment accommodation, then this is not a matter of concern.

7.11 In summary, the principle of residential development is acceptable subject to careful consideration of flood risk, impact on the riverside and the traffic implications.

Is the intensity of the development appropriate for the site in principle and are the details of the scheme satisfactory? Flood Risk and Drainage 7.12 The aim of PPS25 says that flood risk should be considered at all stages of the planning and development process in order to reduce future damage to property and loss of life.

7.13 This is supported by UDP policies (ENV-P.1.2 (Water Pollution and Water Quality), ENV-P.1.3 (Surface Water Run Off) that seeks to prevent surface water run off likely to result in adverse impact such as an increased risk of flooding and P.1.4 (Waste Water Management).

7.14 The Environment Agency have not commented on this application, but had previously advised that they have no objection but want conditions imposed on any approval given. There would be no increase in surface water run-off, but it would need to be managed through appropriate design and safeguarding conditions as proposed. Although this site is in a riverside location, this application is considered acceptable in flood-risk terms as this is an existing building, with the proposed residential part of the development being located on top of the existing building. If this was a total redevelopment of the site for just residential then additional details and a flood risk assessment would have been required to be undertaken.

Noise

7.15 PPG24 outlines the considerations to be taken into account in determining planning applications both for noise sensitive developments and for those activities, which will generate noise. It recommends appropriate levels for exposure to different sources of noise; and advises on the use of conditions to minimise the impact of noise to protect neighbours and future occupiers. The categories are grouped by noise levels and recommendations offered according to the levels of disturbance.

7.16 This is supported by UDP Policy ENV-P.1.5 (Noise pollution), ENV-B.1.1 and London Plan Policy 4a.14 states that boroughs should reduce noise by minimising the potential adverse impacts of noise on, from, within, or in the vicinity of, development proposals; by reducing the impact of traffic noise through highway management and transport policies; and by containing noise from 24-hour activities. 7.17 The property’s location along High Street Brentford, Lots Ait and the waterside means that the site is subject to noise from mixed sources being road traffic, aircraft, and boats and would put parts of the site in NEC C and D. The Environmental Health team have advised that the development would require suitable noise attenuation measures as conditions. Please refer to condition 15.

7.18 Members had questioned if glazing would help for the balconies, and the applicants submitted some additional details from their noise experts in response to this question. These details conclude, that given the elevation of the dwellings and their distance from the road network, the effect of any glazed balustrade higher than those already included in the scheme would be unnoticeable in terms of noise reduction. Also given the sensitive nature of the site and the concerns on material finishes is not considered appropriate due to the potential impact on the design and appearance of this building in this riverside location. However with mitigating conditions, the internal accommodation can be protected through the use of acoustic insulation to ensure the maximum noise level to be permitted within dwellings is satisfactory, and the proposal for residential within this noise category is appropriate. It is considered, in this case with other design constraints, that this is the best solution to the circumstances.

Air quality

7.19 UDP policy and Government guidance seek to protect or improve air quality. PPS23 advises that any consideration of the quality of land, air or water and potential impacts arising from development, possibly leading to impacts on health, is capable of being a material planning consideration, in so far as it arises or may arise from or may affect any land use. In addition PPG13: also states that air quality is a key consideration in the integration between planning and transport.

7.20 These are supported by UDP Policy ENV-P.1.6 (Air Pollution) and London Plan policy 4A.6 (Improving Air Quality). These policies seek to improve air quality and prevent pollution.

7.21 The Borough has undertaken a review and assessment of air quality as required by the Environment Act 1995. This has concluded that the target level of air quality in the Borough will not be met and has lead to the declaration of Air Quality Management Areas (AQMAs).

7.22 Therefore on 6th of March 2006 LBH declared an AQMA over the whole Borough AQMA. Current UDP Policy and indeed Government guidance sets guidance on reducing and assessing the air quality implications of traffic. The designation of the AQMA does not prevent development.

7.23 Two additional floors are proposed on the building, and a total of 35 spaces on the site are proposed. Trip generation is inevitable, although limiting parking can lead to more sustainable trips, and therefore separate parking areas for the office use and the residential use are proposed and have been conditioned. It is therefore considered that this impact from this development on Air Quality is acceptable. Density and it’s implications – amenity space, internal space and liveability, affordable housing, design and design/daylight/sunlight/shadowing/outlook, accessibility and refuse storage?

Density 7.24 Although density standards are a useful tool, these are of secondary importance after taking account of the specific requirements and merits of any scheme proposed. Residential density is therefore a tool against which an initial appraisal is made. It is a useful guide to the nature of the development, and can be used to ensure that new development reflects the character of an area, but is not a determinant in its own right.

7.25 UDP Policy H.4.2 (Residential Density) sets a range of densities to guide and control residential development and states that residential density in new schemes should normally be not less than 150 habitable rooms per hectare (HRHA) nor exceed 250 HRHA. It also states that, provided it can be achieved within a high quality environment, higher densities for predominantly non family accommodation will be considered in town centre locations, areas of good public transport accessibility, or in locations where there is no established residential character. This is a town centre location.

7.26 The thrust of Government guidance and The London Plan (and the approach adopted by the Mayor) promote greater densities than either the UDP or current practice anticipates. However, as stated above, the UDP does set out exceptions to the 150-250 HRHA range, notably town centre locations and other areas well served by public transport.

7.27 Plot ratio is also applicable to mixed sites like this. It aims to control the bulk of buildings to avoid over development and to ensure that the amount of accommodation provided does not result in excessive employment density, place a strain on the road network or overload the existing transport system. The plot ratio for this development is 2.3:1, and the existing office development is 1.56:1. According to the UDP, in town centre locations development should generally be at a plot ratio of 1:1, although development above this may be acceptable taking into account the accessibility of the site and its ability and that of the surrounding area to accommodate the development. In the UDP business developments in town centres are normally encouraged to incorporate other uses, as appropriate, including residential. Such developments should meet other relevant UDP criteria in Policy E.2.1. Some existing nearby plot ratios already exceed 1:1.

7.28 When assessing the application of plot ratios to a particular proposal the key tests are whether there would be any demonstrable harm, whether the existing public transport provision is acceptable and any contribution which a new development can make to improvements to public transport, existing traffic conditions and the level and control of parking on and off site.

7.29 The proposed density (excluding the office element) for this site is 212 HRHA, which complies with the UDP requirements. If all of the floors were residential based on the same layout as the proposed flats, the estimated density is 636 HRHA. The implications of this density of development are addressed in more detail below, but the proposed level of development is considered acceptable, since it would not, in this case, result in adverse effects on the local area or with the site. Amenity Space 7.30 The proposal includes 351m2 of private and communal amenity space as detailed in the table below.

FLAT NUMBER FLAT SIZE (m2) AMENITY SPACE (m2) 1 (two-bedroom) 69.6 m2 29.5m2 2 (two-bedroom) 56.5 m2 11.6m2 3 (two-bedroom) 78.9 m2 45.1 m2 4 (two-bedroom) 78.9 m2 47.2 m2 5 (two-bedroom) 61.3 m2 10.9 m2 6 (one-bedroom) 44.1 m2 21.0 m2 7 (one-bedroom) 49.1 m2 37.0 m2 (Roof terrace) 8 (two-bedroom) 75.3 m2 44.5 m2 9 (two-bedroom) 76.0 m2 52.4 m2 10 (one-bedroom) 50.4 m2 37.0 m2 (Roof terrace) 6.0 m2 (Balcony) Communal areas n/a Two covered roof terraces each 7.5m2, and one open roof terrace 16.7 m2 TOTAL 351.2m2

7.31 The Supplementary Planning Guidance, sets amenity space standards for flats with 3 habitable rooms at 25m2 each, or for 4 habitable rooms, 30m2. This application therefore requires an area of 275m2 to meet these standards, and currently provides an area of 351m2 in the form of individual terraces for flats and three communal roof terrace areas. Every proposed flat would have individual amenity space in the form of balconies, although three of the proposed flats would also need to make use of the roof terraces in order to meet the standard.

7.32 Balconies are not normally acceptable as the only form of amenity space, but in this instance the proposal is considered satisfactory. The balconies along the north-east and north-west elevations are narrow (approximately 1.0 metre), but due to the length, all but three of the proposed flats would have reasonable useable outdoor space. In addition, Waterman’s Park is located approximately 150 metres to the north-east along the High Street, and this area could also be used by future residents. A contribution of £10,000 towards Waterman’s Park is requested given that 3 of the flats cannot comply with the required amenity space. The proposed units include three non-family one- bedroom units, and that there is no amenity space to serve broader recreation needs. Of the remaining seven two-bed units, five have an area of 29.5 m2 to 52.4m2 of amenity space as detailed in the table above. Only two of the units are considered unacceptable in this regard. The Inspector did not report on the amenity space, but the current provision and layout in this instance is considered acceptable with the S106 contribution towards Waterman’s Park. Internal Space and Liveability 7.33 The Council’s Supplementary Guidance regarding Housing Standards sets minimum standards to be achieved for internal floor areas in new residential buildings. The supplementary planning guidance specifies minimum floor areas of 45m2 for a two- person flat, 57m2 for a three-person flat, and 70m2 a four-person flat. The flats range in size from 44.1m2 to 78.9m2. All but one of the proposed flats meet the standards. The flat that fails is a one-bedroom flat, which has an area of 44.1, instead of the required 45m2. In a purpose designed flat, this shortfall is unlikely to be a matter of concern.

7.34 All of the flats would have access to amenity space, and the external design ensures that natural light can enter the flats. The flats are all assessed through a central spine which goes from the new lift shaft that is located on the High Street. Four of the flats would be single aspect, with two facing out to north-east, and the others facing south- west out into Goat Wharf. Of the remaining flats, two would have windows facing the High Street and the north-east, and the remaining four would have views out over the river. Given this daylight and outlook are considered acceptable for all flats. The units have combined living space and kitchens, with separate bedrooms and bathrooms. The floor plans of the proposed flats are wide and shallow with large amounts of glazing. As a result, they would all received food daylight. The layout is considered satisfactory. The Inspector did not comment on the proposed layout.

Affordable Housing 7.35 Policy H.2.1 of the UDP states that all housing developments in the Borough capable of providing 20 or more dwellings should make provision for the maximum achievable provision for on-site affordable housing. This proposal does not require provision for affordable housing as the development involves less than 20 units.

Design and the impact on surrounding sites 7.36 Under UDP Policy ENV-B.1.1 new development should be compatible with, and seek to enhance the character of the area in terms of size, scale, materials and design. Also it should ensure adequate daylight and sunlight reaches properties, and minimise any detrimental impact on adjoining properties.

7.37 This is a riverside location. The existing building is a four-storey brick clad office building 13.6 metres high to the roof ridge. The building is between Brentford High Street and the River Thames. Access to the site is off the High Street, and parking would be located in an undercroft.

7.38 The building would be near the River Thames and is likely to be visible from Kew Gardens (a World Heritage site). Given the sensitive location, any extensions need to be sympathetic to the surrounding area. In this case, appropriate use of materials is therefore essential and is dealt with by condition 3.

7.39 The proposal would put two additional floors on the existing four-storey building, bringing the total height to 19.6 metres. The 5th and 6th floor levels would have a curved aluminium roof when viewed from the side elevation. Around the perimeter of the building there would also be a galvanised steel balcony with glass balustrade, which would be used for amenity space for the flats. The plans also detail that there would be an additional 5 storey extension to the front elevation to accommodate a new lift access. A condition would need to be imposed to ensure that appropriate materials for a waterside location are used, and this would ensure that views of Kew Gardens would be preserved. The relatively visually lightweight structure on the top of the more heavy appearance of the masonary elevations below is an acceptable contrast and would relate well to similar developments nearby. It would provide an appropriate design approach for the riverside frontage without being dominant in its setting. A landscaping condition has also been recommended to ensure a satisfactory view from the streetscene. The current landscaping is minimal and new landscaping would improve the visual appearance of the development from the streetscene and improve the character of the High Street.

7.40 No daylight/sunlight studies have been submitted to provide an assessment of the impact on the surrounding area, but the Inspector’s assessment concluded that the scale, massing, height and design of the proposed extension of the appeal building are not inappropriate in its surroundings, and goes on to state that he did not find that the proposals would harm the amenities of occupiers of neighbouring properties. The previous scheme was refused as the Council considered that scale, massing and design would be unacceptable in this riverside location and would not make a positive contribution to the site’s waterside setting, harmful therefore to the amenities of neighbouring properties and the character of the streetscene. The proposed external appearance has not altered from the previous scheme, although the parking layout and servicing has been improved. In addition as Members requested, an additional viewpoint from the High Street, indicating the proposed design has been submitted. This shows the building in relation to the surrounding site, and it is considered that this information, combined with the Inspector’s findings, that with appropriate safeguarding conditions that means the development would have a positive effect on the appearance of the existing building and the surrounding area.

Accessibility 7.41 Council policies require that all new developments should provide for the needs of people with disabilities, and have regard to the Council’s ‘Think Access’ guidelines. They emphasise the special needs of wheelchair housing for people with disabilities (UDP policies H.3.5, H.4.1, and H.5.1). New housing should contribute to meeting the needs of people with disabilities and enable them to live as independently as possible in the community. Part M of the Building Regulations ensures that new build housing meets mobility standards. All housing built to mobility standards should accord with the Council’s supplementary planning guidance ‘Think Access’. Lifetime Homes emphasises that the future of housing is about sustainability and integration.

7.42 The London Plan supports the principles of ‘Lifetime Homes’ and views them as a fundamental key to delivery of the government’s objectives of social inclusion, sustainability, equality and valuing diversity. The proposal provides lift access for wheelchair users at the front of the building, and there is currently one disabled parking bay for the site. There is no wheelchair flat proposed, but disabled facilities have been proposed on site.

Refuse/Recycling 7.43 New applications for housing developments should “…provide space for composting facilities and readily accessible recycling facilities” under UDP Policy ENV-P.2.4 (Recycling facilities in new developments). These facilities should be sited in convenient, locations and should be screened in order that they can protect the amenities of nearby residents whilst making a positive contribution to the local environment. 7.44 The applicants have indicated that an area for refuse and recycling storage would be provided in the basement within a bin store area, which complies with the requirements. If planning permission is granted, details would be required to be submitted to ensure compliance with the requirements. Refer to condition 6.

Can the scheme be accommodated in terms of access and public transport? Is the parking provision appropriate? 7.45 Transport guidance places much emphasis on the need for integration between transport modes with improvements to pedestrian and cycle facilities, to bus links to stations and to taxi rank facilities. Parking should be provided at a level that encourages alternative means of travel other than the private car. All developments should provide access for people with disabilities. When considering works to the highway, the safety of all users must be a priority (PPS1 and PPG13). These documents are supported by UDP policies T.1.2, T.1.4, T.2.1, T.2.2, T.4.3 and ENV- P.2.5.

7.46 The Council’s parking standards (UDP Policy T.1.4 and Appendix 3) are considered to be the maximum desirable provision unless there are exceptional circumstances, with UDP policies seeking to reduce the need to travel, reduce reliance on the private car and promote the use of sustainable modes.

7.47 Policy T.1.4 of the UDP states that all developments must provide parking and servicing facilities in accordance with the Council’s standards. The maximum parking standard specified in Appendix 3 of the UDP for B1 development is 1:100 m2 within a regeneration area (including Brentford). Disabled persons provision is required at a standard of one wider space per 1,000m2 and thereafter 1 per 2,500m2 where development requires”. Appendix 3 states that for offices cycle provision of 1 space per 700m2 is required, and for housing 1 space per 150m2 is required.

7.48 London Plan Policy 3C.22 (Parking Strategy) similarly seeks to ensure that on-site car parking at new developments is the minimum necessary and that there is no over- provision that could undermine the use of more sustainable non-car modes.

7.49 There are 15 existing car parking spaces marked out on the ground floor of the office building. The Inspector indicated that, in this location, it was not acceptable for no parking to be provided for the flats or for the development to be a low car scheme. The current scheme amends the proposed layout for the proposed offices and residential elements as detailed in 7.51 below.

7.50 The main bus routes that serve the site are the 235 (Brentford/Sunbury), 267 (Hammersmith to Fulwell Bus Garage), and the 237 (Shepherds Bush/Hounslow Heath). In addition, routes E2 (Brentford Bridge to Greenford), E8 (Brentford Bridge to Ealing Broadway) and 65 (Kingston to Ealing Broadway) are nearby, which service the tube, and Brentford Train Station. Although the PTAL of 2 suggests this is not a very accessible site, it is in a Town Centre, reasonable well provided with facilities and one where the Council’s intended regeneration will improve such provision. Overall the level of accessibility in this case is considered acceptable for a higher density development on a mixed-use site.

7.51 Under the UDP the maximum car parking provision for an office located within a town centre is one space per 100m2. The subject site has an area of 2034m2, meaning that a maximum of 20 car parking spaces would comply with the current UDP requirements.

7.52 The maximum parking provision that would be permitted for the residential part of the development in accordance with the UDP is 11 car spaces (including a visitor’s space). The requirements for private residential for 1 and 2 bedroom units is one space per flat, plus 10% visitor space per flat and 6% of visitors parking spaces are to be for people with disabilities.

7.53 The applicants have indicated a split of the existing car parking. This would provide five shared spaces for visitors to the flats and the offices (the Inspector did not dismiss the possibility that some sharing might be an appropriate arrangement); ten spaces for the flats and 20 spaces in a ‘tandem’ layout. Cycle parking would be provided on the ground floor. This site exceeds the maximum parking standards, but in this instance it is using the existing parking area, and not creating any additional hard surfacing. Parking allocations would be required to be protected by planning condition, and therefore this proposal is considered acceptable. This amended layout is considered to overcome both the Council and the Inspectors previous concerns regarding proposed parking.

Are sustainable building principles applied? 7.54 Planning Policy Statement 1: Delivering Sustainable Development (PPS1) sets out the Government's overarching planning policies on the delivery of sustainable development through the planning system.

7.55 Sustainability underpins many of the UDP policies and The London Plan. These require developments not only to be sustainable in transport terms; but also to include appropriate recycling facilities and to minimise waste; to include energy efficiency measures and promote the use of renewable energy; and not to significantly increase the requirement for water supply or surface water drainage.

7.56 UDP Policies ENV-B.1.1 (New Development), ENV-P.1.3 (Surface Water Run Off), ENV-P.2.1 (Waste Management), ENV-P.2.4 (Recycling Facilities in New Developments), ENV-P.2.5 (Energy and Resource Efficiency) and ENV-P.2.6 (Renewable Energy) require that all developments should include recycling facilities and minimise waste, include energy efficiency measures, be sustainable in transport terms, promote the use of renewable energy and not significantly increase the requirement for water supply or surface water drainage.

7.57 The proposal can make a substantial contribution to sustainable development in the Borough and it is important that it recognises and adopts sustainable development principles. Overall the applicant’s are committed to implement sustainable design in accordance with the best practise and the requirements of the Building Regulations. The applicants propose sustainable building forms and construction techniques, including highly insulted reducing energy requirements. In addition passive vents will be fitted with heat exchangers to recycle waste heat.

7.58 Officers recommend further safeguarding conditions on the grant of any planning permission. Is the balance of community benefits appropriate to mitigate the impact of the development, and what are the proposed section 106 contributions? 7.59 UDP policy IMP6.1 states that, in appropriate situations, the Council will seek to ensure that a developer enters into a planning obligation to secure planning benefits related to the development. Planning decisions impact on the local area and it is important when assessing a planning application to examine the overall consequences of a proposal on the locality and what the benefits and impacts of a development will be. Where these consequences and impacts can be mitigated by off-site measures, planning obligations may be appropriate.

7.60 Circular 05/2005 considers whether what is requested is reasonable in scale and kind to what is being proposed. This depends on whether what is being required:

A) Is needed to enable the development go ahead; or B) In the case of a financial payment, will the contribution meet the cost of providing the sought facility; or C) Is otherwise so directly related to the permitted development that it ought not to be permitted without it; or D) Is intended to offset the loss of or impact on any amenity resource present or on site prior to development.

7.61 If approval were to be considered, the main areas for inclusion into any agreement may be:

7.62 Education have estimated that the proposal would be likely to generate 3 children; 1 of pre-school age, 1 of primary school age and 1 of secondary school age.

7.63 At present there is a shortage of adequate permanent secondary school places in this area and the Department would expect some contribution from the developers towards maintaining current provision and providing adequate permanent provision for the private housing. The current cost of a secondary school place is £17,116. An education contribution of £17, 116 would therefore be sought.

7.64 Three of the proposed flats cannot provide the required amount of amenity space, and there is no area for wider recreation needs and therefore a contribution of £10,000 is sought.

7.65 There is likely to be a requirement to contribute to initial revenue costs and possibly some capital to meet the health care requirements of new residents. Information has been sought from the Primary Care Trust about this, but there has been no response to date. A proposal will be bought before the meeting for inclusion in this section and the S106 agreement.

8.0 EQUAL OPPORTUNITIES IMPLICATIONS

8.1 The equal opportunity implications of the proposal are discussed in the body of the report and, in particular paragraphs 7.39 to 7.40.

8.0 RECOMMENDATION 10.1 That on completion of the necessary unilateral undertaking, that the Borough Planning Officer be authorised to grant planning permission subject to the following conditions. 10.2 Reason

It is considered that this application for the erection of two additional floors to the existing building, to provide three one-bedroom flats and seven two-bedroom flats and an extension to provide a lift shaft would provide appropriate living conditions and would not harm local traffic conditions, neighbours living conditions or the appearance of the adjoining area or it’s waterside location. The proposal therefore meet policies ENV-N.1.5 (Protection of Metropolitan Open Land), ENV-B.1.1 (New Development), ENV-W.1.1 (Design in the Thames Policy Area), ENV-W.1.2 (Mixed Uses in the Thames Policy Area) and ENV-W.1.3 (Important Views and Structures in the Thames Policy Area), ENV-B.1.1 (New development), E.1.5 (Development involving loss of or changes in employment uses), Policy Env-B.1.8 (Access and facilities for people with disabilities Policy H.4.1 (Housing standards and guidelines) Policy H.5.1 (Housing for people with disabilities), T.1.4 (Car and cycle parking and servicing facilities) of the London Borough of Hounslow Unitary Development Plan Adopted 12 December 2003, and policies of The London Plan Spatial Development Strategy for Greater London Adopted February 2004.

1. The development hereby permitted shall be begun before the expiration of three years from the date of this permission.

To accord with the provisions of Section 92(1) of the Town and Country Planning Act 1990.

2. The proposed development shall be carried out in all respects in accordance with the proposals contained in the application and the plans submitted herewith and approved by the Local Planning Authority (before the building is occupied). Any applications for variation shall be accompanied, inter alia, by overlay drawings provided by the applicant for comparison with the permitted scheme

To ensure the development is carried out in accordance with the planning permission.

3. No development shall take place until samples of the materials and a sample board of the materials to be used in the construction of the external surfaces of the buildings and balconies hereby permitted have been submitted to and approved in writing by the local planning authority. Development shall be carried out in accordance with the approved details.

In order that the Council may be satisfied as to the details of the development in the interests of the visual amenity of the area and to satisfy the requirements of policy ENV B1.1 (New development), and (H6.4 Extensions and alterations).

4. No demolition or construction work shall take place on the site except between the hours of 08.00 to 18.00 on Mondays to Friday and 08.30 to 13.00 on Saturdays and none shall take place on Sundays and public holidays without the prior agreement of the Local Planning Authority.

In order to safeguard the amenities of adjoining residential properties.

4. During construction works an appropriate wheel-washing system shall be provided to remove mud, stones and any other extraneous materials from the wheels and chassis’ of construction vehicles exiting the site and all loads of construction materials, excavation spoil or other such matter shall be fully covered in order to ensure that no material leaves the site attached to the vehicle which might subsequently be deposited on the highway. The exit from the wheel washing system shall be constructed from a hard, non-porous surfacing material and sited as far away from the exit to the highway as is possible given the constraints of the site and the surface shall be kept clean at all times. Waste water discharged from the wheel washing system shall be stored and disposed of on site and shall not be discharged into the public sewerage system without prior removal of soil, stones and any other suspended material. Suitable measures to minimise dust nuisance caused by the operations and to ensure that no dust or other debris is carried on to the adjoining properties shall also be provided in accordance with the guidance at http://www.london.gov.uk/mayor/environment/air_quality/docs/construction-dust-bpg.pdf and site lighting shall be designed, positioned and directed so as not to unnecessarily intrude on passing drivers on public highways and so as not to direct light into any windows of properties outside the site.

Start of works on site shall be notified to the Council’s Community Environment Team on 020 8583 5070

In order to safeguard the amenities of adjoining residential properties, the amenities of the locality, and highway safety, and to enable the Council to monitor works on site to ensure that it is carried out in a safe and neighbourly fashion for the above reasons in accordance with Polices ENV-B.1.1 (New Development), ENV-P.1.5 Noise Pollution, ENV-P.1.6 Air Pollution, and ENV-P.1.7 (Light Pollution).

6. The development hereby permitted shall not be occupied until details for the storage in a suitable enclosure and subsequent disposal of waste and for the separation and storage in a suitable enclosure and the subsequent disposal for processing of recyclable materials generated by the development have been submitted to and approved in writing by the local planning authority. The details so approved shall be put into effect [before the development is first occupied and shall be permanently retained thereafter. The waste and recyclable materials shall only be stored within the areas so approved and not outside the site.

To ensure that waste from the development is properly dealt with in the interests of neighbours' living conditions, the appearance of the area, and sustainability.

7. No development shall take place until full details of both hard and soft landscape works have been submitted to and approved in writing by the local planning authority and these works shall be carried out as approved. These details shall include (proposed finished levels or contours; means of enclosure; car parking layouts; other vehicle and pedestrian access and circulation areas; hard surfacing material; minor artefacts and structures (eg. furniture, play equipment, refuse or other storage units, signs, lighting etc); proposed and existing functional services above and below ground (eg drainage power, communications cables, pipelines etc. indicating lines, manholes, supports etc); retained historic landscape features and proposals for restoration, where relevant).

Soft landscape works shall include (planting plans; written specifications (including cultivation and other operations associated with plant and grass establishment); schedules of plants, noting species, plant sizes and proposed numbers/densities where appropriate; implementation programme)

To ensure a satisfactory appearance of the site and improve the visual amenities of the locality in accordance with policy ENV.B.1.1 New development.

8. All hard and soft landscape works shall be carried out in accordance with the approved details. The works shall be carried out prior to the occupation of any part of the development or in accordance with the programme agreed with the local planning authority.

To ensure a satisfactory appearance of the site and improve the visual amenities of the locality in accordance with policy ENV.B.1.1 New development.

9. No development shall take place until there has been submitted to and approved in writing by the local planning authority a plan indicating the positions, design, materials and type of boundary treatment. The boundary treatment shall be completed before any of the residential units hereby permitted are first occupied.

To safeguard the visual amenities of the locality and privacy of adjoining properties locality in accordance with policy ENV.B.1.1 (New development).

10. A landscape management plan, including long term design objectives, management responsibilities and maintenance schedules for all hard and soft landscape areas, shall be submitted to and approved by the local planning authority prior to the occupation of the development or any phase of the development, whichever is the sooner, for its permitted use. The landscape management plan shall be carried out as approved.

In the interests of the visual amenities of the area locality and to accord with policy ENV.B.1.1 New development.

11. No development shall take place until a schedule of landscape maintenance for a minimum period of 5 years has been submitted to and approved in writing by the local planning authority. The schedule shall include details of the arrangements for its implementation. Development shall be carried out in accordance with the approved schedule.

In the interests of the visual amenities of the area locality and to accord with policy ENV.B.1.1 New development.

12. Before first occupation of the buildings the loading, unloading and turning space, and marking out and allocation of those parking spaces for office, residential and visitor (including spaces for people with disabilities) shall be provided within the curtilage of the site in accordance with the scheme and such spaces shall be permanently available and not be used for any other purpose.

In order to prevent obstruction and inconvenience to users of the adjacent highway and the premises, and in the interests of road safety available in accordance with policy ENV.B.1.1 New development and policy T1.4 Car and Cycle Parking and servicing facilities for developments and T4.4 Road Safety.

13. Before the development hereby permitted is commenced a scheme indicating the provision to be made for disabled people to gain access to buildings shall have been submitted to and approved by the Local Planning Authority. The agreed scheme shall be implemented before the development hereby permitted is brought into use.

To provide satisfactory access for people with disabilities in accordance with policy,ENV-B.1.1 New Development and E.1.3 Disabled Access.

15. No development shall take place until details shall be submitted to and approved by the Local Planning Authority for a scheme of acoustic insulation to ensure the maximum noise level to be permitted within dwellings with windows shut and any other necessary means of ventilation provided shall not exceed the "good" limits contained in BS8233:1999 these being LAeq,16hour = 30 dB in living rooms, and a night(07:00 - 23:00) LAeq,8hour = 30 dB and LAFmax = 45 dB in bedrooms, and a night LAeq,1hour = 45 dB in Kitchens, Bathrooms and Utility Rooms ". The details shall be carried out as approved.

To protect the occupiers of the development from noise in accordance with policy ENV.B.1.1 New development.

16. No development shall take place until details of cycle parking/stands have been submitted to and approved in writing by the LPA and the spaces shown on any of the approved drawings shall be available for use before the first occupation of the buildings and permanently maintained and retained thereafter.

In order that the LPA may be satisfied as to the details of the development and to encourage the use of the site by cyclists.

17. No development shall take place until a statement on the sourcing of materials to be used in the building, involving reuse, recycling and other sustainable sourcing of materials to be used in the construction and fitting out of the building wherever possible has been submitted to and approved in writing by the Local Planning Authority. These details shall be carried out as approved.

In the interests of sustainability.

18. No development shall take place until the results of a study to investigate measures for the harvesting of rainwater, the minimisation of water run-off from the proposed building and the conservation and reuse as appropriate of other water supplies in the proposed building, including recommendations for have been submitted to and approved in writing by the Local Planning Authority. These details shall be carried out as approved.

In the interests of sustainability.

19. No development shall take place until details of measures for the conservation of energy and the on site generation of energy if appropriate have been submitted to and approved in writing by the Local Planning Authority. These details shall be carried out as approved.

In the interests of sustainability.

Informatives a) Under the terms of the Water Resources Act 1991, the prior written consent of the Environment Agency is required for any discharge of sewage or trade effluent into controlled waters (e.g. watercourses and underground waters), and may be required for any discharge of surface water to such controlled waters or for any discharge of sewage or trade effluent from buildings or fixed plant into or onto ground or into waters which are not controlled waters. Such consent may be withheld. b) In relation to the wheel washing system specified above, the preferred distance between the wheel wash and the exit to the highway is 100metres, although it is recognised that the constraints of the site may not make this practical.

If site staff are instructed by a Council Officer to stop vehicle movements to and from the site if any incidents occur, they must comply with the instructions. For any further advice, contact the Council’s Community Environment Team on 020 8583 5070.