planning report PDU/3047/01 6 February 2013 Sainsbury’s, Long Drive, South

in the Borough of planning application no. 33667/APP/2012/3214

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

The proposal Redevelopment of the existing Sainsbury’s store to allow for a replacement store comprising 11,706 sq.m. gross internal floorspace, increasing the provision of car parking to 582 spaces, providing retail/ commercial starter units adjacent to Long Drive, the refurbishment of the existing petrol filling station and landscaping improvements. The applicant The applicant is Sainsbury’s Supermarkets Ltd, and the agent is Turley Associates.

Strategic issues The principle of the proposed retail development requires further justification and clarification.

Other issues that need to be addressed before the application is referred back to the mayor at stage two relate to urban design and need for significant public realm investment, access, climate change mitigation, air quality, flood risk and transport.

Recommendation That Hillingdon Council be advised that while the application is generally acceptable in strategic planning terms the application does not comply with the London Plan, but that the possible remedies set out in paragraph 103 of this report could address these deficiencies.

Context

1 On 2 January 2013 the Mayor of London received documents from Hillingdon Council notifying him of a planning application of potential strategic importance to develop the above site for the above uses. Under the provisions of The Town & Country Planning (Mayor of London) Order 2008 the Mayor has until 12 February 2013 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.

S:\Planning Decisions\Cases\3047\Stage 1 page 1 2 The application is referable under Category 3E and 3F of the Schedule to the Order 2008:

 3E (a) which does not accord with one or more provisions of the development plan in force in the area in which the application site is situated.

 3E (b) comprises or includes the provision of more than 2,500 sq.m. of floorspace for use falling within any of the following in the use class order – (i) class A1 retail.

 3F Developemnt for a use other than residential use, which includes the provision of more than 200 car parking spaces in connection with the use.

3 Once Hillingdon Council has resolved to determine the application, it is required to refer it back to the Mayor for his decision, as to whether to direct refusal or allow the Council to determine it itself, unless otherwise advised. In this instance if the Council resolves to refuse permission it need not refer the application back to the Mayor.

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 located within local/neighbourhood centre and is occupied by an existing Sainsbury’s store. The site is located to the south of Long Drive, to the west of Victoria Road and east of the .

6 The nearest section of the Road Network (TLRN) is the A40 Western Avenue, which is to the south of the site at a distance of 2.7 kilometres away. The A312 Hill Road, part of the Strategic Road Network (SRN), is also at a similar distance to the southeast.

7 One bus route (144) operates along Victoria Road, with the southbound bus stop located directly opposite the site and the northbound stop to the north of the Victoria Road/Long Drive junction. This route operates between Mill Hill Broadway Station and Ruislip Station. provides both Central Line services between Epping and Hainault, and West Ruislip, and mainline services between Marylebone and Gerrards Cross. The Public Transport Accessibility Level (PTAL) for the site is moderate and estimated at 3 (based on a scale of 1 to 6 where 6 is the highest).

Details of the proposal

8 Redevelopment of the existing Sainsbury’s store to allow for a replacement store comprising 11,706 sq.m. gross internal floorspace, increasing the provision of car parking to 582 spaces, providing retail/ commercial starter units adjacent to Long Drive, the refurbishment of the existing petrol filling station and landscaping improvements.

Case history

9 The site has an extant consent from a planning permission granted on 13 November 2006 for the extension of the existing Sainsbury’s store, the provision of a new borough library, decked car park and associated landscaping. This allowed the supermarket an additional 1,444 sq.m. (net) of retail floorspace delivering a store of 4,998 sq.m. net sales area. Hillingdon Council have confirmed the scheme has been implemented.

S:\Planning Decisions\Cases\3047\Stage 1 page 2 10 The applicant attended a pre-application meeting on 6 November 2012 and a pre- application report was issued on 21 November 2012. Strategic planning issues and relevant policies and guidance

11 The relevant issues and corresponding policies are as follows:

 Mix of uses London Plan  Retail/town centre uses London Plan  Urban design London Plan;  Transport London Plan; the Mayor’s Transport Strategy; Land for Transport Functions SP;, Land for Industry and Transport SPG  Parking London Plan; draft Early Minor Alteration to the London Plan; the Mayor’s Transport Strategy  Access London Plan; Accessible London: achieving an inclusive environment SPG; Planning and Access for Disabled People: a good practice guide (ODPM)  Equal opportunities London Plan; Planning for Equality and Diversity in London SPG; Equal Life Chances for All (Mayor’s Equalities Framework); Equalities Act 2010  Air quality London Plan; draft Early Minor Alteration to the London Plan; the Mayor’s Air Quality Strategy;  Sustainable development London Plan; Sustainable Design and Construction SPG; Mayor’s Climate Change Adaptation Strategy; Mayor’s Climate Change Mitigation and Energy Strategy; Mayor’s Water Strategy

12 For the purposes of Section 38(6) of the Planning and Compulsory Purchase Act 2004, the development plan in force for the area is the Hillingdon Core Strategy 2012, the saved policies of the Hillingdon Unitary Development Plan, Hillingdon Draft early Consultation Site Allocations DPD and the 2011 London Plan.

13 The following are also relevant material considerations:

 The National Planning Policy Framework and Technical Guide to the National Planning Policy Framework  The Hillingdon draft Site Allocations DPD  The revised Early Minor Alteration to the London Plan Principle of retail development

14 The proposal is to redevelop the existing Sainsburys store to allow for a replacement extended store. The replacement store will comprise 13,204 sq.m. (gross) with a net sales area of 6,563 sq.m. This will result in a net increase of 3,005 sq.m of floorspace (Table 1) and is more than 4,692 gross/1,566 sq.m. net floorspace than the extant consent.

15 London Plan policy 2.15 (Town Centres), policy 4.7 (retail & town centres) and policy 4.8 (supporting a successful & diverse retail sector), provide the strategic policy context in which the applicant’s proposals are considered.

S:\Planning Decisions\Cases\3047\Stage 1 page 3 Table 1: Existing, consent and proposal floorspace

Existing Consented Proposed (sq.m.) (sq.m.) (sq.m.) Gross internal floorspace 6,000 7,561 11,706 Retail net tradable area 3,553 4,997 6,563

16 At the pre-application stage the applicant was requested to provide further retail impact analysis in relation to the proposed extension of its existing supermarket. The main issues raised were:

 Justification of the scale of development.

 The sequential test.

 Impact on the vitality and viability of centres in the London Plan hierarchy.

 Impact on proposed investment in existing centres.

 Evidence of discussion with Hillingdon Council and surrounding boroughs in the preparation of retail impact assessment

17 The applicant has undertaken further analysis in its retail impact assessment as requested at the pre-application stage and this is welcome.

Scale of development

Town Centre Classification

18 The applicant has stated in its planning and retail statement that the South Ruislip supermarket proposals are in a local/neighbourhood centre that is identified in the Hillingdon Core strategy and this means the proposals are supported by NPPF policy which supports retail development that is located in town centres. In this instance the proposals are not within a centre identified in the London Plan town centre classification, nonetheless this is a centre identified in the up to date core strategy. As local/ neighbourhood centre, the issue of scale in policy 4.7(a) is of direct relevance, this states:

“The scale of retail, commercial, culture and leisure development should be related to the size, role and function of a town centre and its catchment.”

19 For this reason further justification for the proposals was requested at the pre-application stage to explain the case for development which exceeds the identified typical neighbourhood centre 500 sq.m. threshold (Paragraph A2.3 of London Plan Annex).

20 The applicant has set out information (table 1) that in this case the existing Sainsbury’s supermarket is 6,000 sq.m (gross internal floorspace)/ 3,553 sq.m. (net tradable area) and already exceeds the typical floorspace threshold set out in the London Plan for local centres. Furthermore, an extant and implemented planning permission (see below) exists to extend the Sainsbury’s Supermarket to almost 7,561 sq.m. (gross)/4,497 (net).

21 The current application is for a replacement extended store of 11,706 sq.m (gross)/6,563 sq.m (net) which is +5,706 sq.m. (gross)/ 3,010 sq.m (net tradable area) larger than the existing

S:\Planning Decisions\Cases\3047\Stage 1 page 4 operational store. Whilst, compared to the extant consent, the proposed replacement store is some +4,692 sq.m. (gross)/ +1,556 sq.m (net tradable area) larger in terms of floorspace.

22 The scale of the existing store is substantially greater than would normally be expected in a local centre and is of a size normally expected of a district centres (paragraph A2.3). However, the argument presented by the applicant is of significance in considering this application. It is accepted in this instance that the proposals are for the extension of an existing Sainsbury’s supermarket within South Ruislip local/neighbourhood centre. However the increase in comparison floorspace in the centre requires further justification and should be discussed further with Hillingdon Council in terms of its impact.

23 In relation to the status of the local centre within the Hillingdon Council retail hierarchy, it is requested the borough engage with the London Plan Team in the current up-date of the London Town Centre Health Check. Furthermore, discussion should also be had on whether the centre status in the hierarchy should be adjusted to fit with the future revision of London Plan table A2.1 town centre classifications and broad future directions.

Sequential test

24 London Plan policy, in line with the NPPF, places a requirement that retail development should be subject to a sequential test with policy 4.7 stating:

25 “(b) retail, commercial, culture and leisure development should be focused on sites within town centres, or if no in-centre sites are available, on sites on the edges of centres that are, or can be, well integrated with the existing centre and public transport.”

26 The applicant has stated in its planning and retail statement (paragraph 5.4) that it has “not undertaken a sequential assessment, as the application site represents the most appropriate location for retail development (i.e. town centre development).” In considering this position a number of issues raised by the applicant are of relevance.

The consent

27 The issue of the requirement for a sequential test is influenced by the consent for the extension of the existing Sainsbury store on the site, which is accepted as extant and implemented as work has commenced on site.

28 The applicant has presented within its planning and retail statement information relating to the planning permission (13 November 2006 LPA reference 33667/APP/2006/2141)) this is for a 7,561 sq.m. (gross) 4,997 net sq.m. sales area supermarket. It has presented details regarding discussions with Hillingdon Council’s which are of significance, with recent correspondence (letter dated 13 November 2012) stating:

“…the site is located within a local centre, and therefore a sequential test is not required”.

29 Given that the proposals are for the rebuilding of an existing Sainsbury’s Supermarket and given that the site is subject to an extant consent for a larger store and Hillingdon Council’s position that there is no need for a sequential test are all of relevance. Taking into account these issues it is accepted that there is no requirement for a sequential test at the strategic level.

S:\Planning Decisions\Cases\3047\Stage 1 page 5 Assessment of impact

30 The London Plan, in coordination with the NPPF, requires an assessment of impact and states under policy 4.17 “(c) proposals for new, or extensions to existing, edge or out of centre development will be subject to an assessment of impact.”

31 The assessment of impact is required to have particular focus on the impact of new proposed floorspace on the vitality and viability of retail centres in the London Plan town centre classification and smaller neighbourhood centres. A further requirement is an assessment of the impact on proposed investment within the town centre classification.

Assessment of need

32 The applicant has presented the case that the enlarged store proposals are based on the deficiencies of the existing Sainsbury’s store and meet an identified qualitative need for convenience floorspace in the north of the borough identified in the Hillingdon Convenience Goods Retail Study (February 2012). It is however noted that within this study that no quantitative need was identified up to 2016 and that from 2016 through to 2021 capacity grows to 2,709 sq.m. In October 2012 ASDA was granted planning consent (at Appeal) for the development of a supermarket at Millington Road, Hayes. This store will comprise 4,111 sq.m. of net sales area, this development alone will exceed the requirements for convenience goods floorspace across the Borough in the short to medium term

33 The applicant has presented the case for expansion of the store based on overtrading and evidence of stress within the existing supermarket. This is supported by projections of future expenditure growth based on the projected population growth within the catchment. The adopted approach and findings should be supported by further evidence of over trading symptoms being experienced across identified stores in the defined catchment area.

Vitality and viability

34 The applicant has completed an assessment of the impact on vitality and viability of exiting centres and the impact on competitor supermarkets within and outside the identified centres. This analysis is welcome.

35 It is understood that the centres assessed in the applicant’s Retail Study were agreed with Hillingdon Council these are Ruislip District Centre, District Centre, Local Centre, South Ruislip Local Centre and Neighbourhood Centre. A number of centres outside the borough were also assessed.

36 In assessing the baseline position on which assessment of impact has been made the applicant has presented evidence of centre impacts in context of expected expenditure growth. Whilst this analysis is broadly acceptable the applicant is requested to place this assessment of impact in context of broader centre health checks that sets out trends within the centres of floorspace vacancy rates, footfall and rents – this is to allow for a clear understanding of strength of the centre over time, for example is the trend showing a centre under stress due to increases in vacant floorspace etc and therefore would be under greater stress should new development come forward.

37 Overall there is limited concern with the impact of the convenience aspect of the new extended store, this view has been confirmed by Hillingdon Council. The analysis demonstrates that the health of the two nearest centres of Ruislip Manor and Eastcote, that provide mainly top up shopping and secondary and top-up shopping is good. With vacancy rates for the centres at 4% and 2% respectively which are below the national average of 12%. There is however a need to

S:\Planning Decisions\Cases\3047\Stage 1 page 6 further justify the potential impact of the additional comparison floorspace in the town centres within the catchment area and given the edge of borough location the views of Ealing and Harrow Council’s should be evident in the assessment.

Impact on investment

38 The applicant states within its planning and retail statement that there is no evidence to suggest that the current proposals would adversely impact upon future in-centre investment in the local area (paragraph 5.133). It provides two examples of extant permissions in and Harrow. It is requested that a more extensive assessment is provided of potential investment in Hillingdon, Ealing and Harrow, and where possible include detail of expected delivery timescales.

Cumulative impacts

39 Linked to the issue of impact on investment is the need to demonstrate how the Sainsbury’s store proposal relates to the potential cumulative impact of identified potential and on- going applications. It is understood that there is concern that the cumulative impact of all the planned supermarket proposals including the Arla site in South Ruislip and Tesco's and Morrison's on Hillingdon Circus could have a substantial impact. The applicant is requested to justify the development proposals in this context. Urban design

Layout and urban form

40 The proposed layout raises the retail store sales and support services on stilts above an extended ground floor car park, whilst retaining the existing building line to Long Drive. The ground floor to Long Drive is fronted by small shop/business units and turns the corner onto Victoria Road, where an atrium provides an entrance into the store and escalators to the supermarket retail sales floorspace on the first floor. There is in addition a mezzanine floor that includes a restaurant and further retail sales floorspace. Overall these design proposals provide a strong design solution that attempts to integrate the development with Long Drive, the main retail street of the local shopping centre. This is a positive response compared to the existing store, which offers a blank brick wall to Long Drive, with a main entrance to the rear, facing the existing car park. This layout approach is welcome.

41 The inclusion of ground floor business units fronting the ground floor car park provides an active frontage to Long Drive and this approach is also welcomed. At the pre-application stage an amendment was requested that required the addition of a business unit adjacent to the Council car park, so it turns the corner and offers further active frontage/ surveillance. As this would break the currently blank wall on the view entering Long Drive from South Ruislip station. The applicant has included this component within the submitted design and this is welcome.

42 The atrium on Victoria Road offers a strong feature onto the street and further visual activation to the prominent corner of Long Drive/Victoria Road. It is however important to establish how this atrium will function as a feature to the street, and it should not be used as a storage area for shopping trolleys.

43 As with the existing layout, the eastern part of the site is dominated by car parking and service areas and the retained petrol station. The car park and servicing is over four levels. This reflects the existing functional division of the site and is an acceptable approach.

S:\Planning Decisions\Cases\3047\Stage 1 page 7 Scale and massing

44 The massing and scale of the proposed building responds to the height of the existing buildings on Long Drive and offers an appropriate level of enclosure to bring balance to the street profile. The massing is slightly reduced along Victoria Road and creates a new edge to the street in context of the existing park/sports fields. There heights are appropriate to their location.

Roof form

45 Given the larger scale of the roof and car parking area the applicant is requested to explore the potential for a green roof or green roof elements. This feature would have an impact on both softening the bulk and massing of such a large building (supermarket and car park) and contribute to reduction of flood risk as well as other benefits. (Refer to section on flood risk).

Activation and public realm

46 The inclusion of shop units on the Long Drive elevation responds appropriately to the main retail street and link to South Ruislip station. The proposed landscaping will positively contribute to an improvement of the public realm – although this is subject to use of robust quality materials and responding to the issues raised in paragraphs 48 - 57. The applicant is encouraged to engage with Hillingdon Council and develop a public realm programme that enhances both sides of Long Drive to enhance the environment of the centre.

47 The extensive decked car parking is hidden behind a timber cladding screen with landscape planting in front. Whilst it is accepted this frontage has less need for activation, a high quality planting and landscape regime should be adopted and a management strategy should set out its maintenance. Given the location, mature trees are preferable facing onto the playing fields. It is also important that a generous pavement width is provided, given the traffic flows from the expanded car park. Access

Public realm

48 The indicated seating in public realm areas should incorporate a proportion with both back rests and arm rests to enable a range of people to use it with ease.

49 The applicant has set out assurances that all entrances will be at grade, however further information regarding the gradients which are proposed externally and to the public realm should be provided Given that the drawings of the approach to the entrance are not clear. This is because looking at the proposed elevation it is not clear whether level access, or a sloped approach is provided up to the left entrance door (as viewing the main Sainsbury’s entrance elevation). .

50 External furniture, i.e. cycle stands and bollards should be carefully positioned so they do not obstruct pedestrians, especially blind and partially sighted people.

Car parking

51 The design and access statement needs to further demonstrate that adequate provision of blue badge parking bays has been made for employees and visitors, in line with London Plan policy 6.13 (Parking) and Table 6.2.

52 The parking management plan should include a mechanism to ensure that the supply and demand of the blue badge bays are regularly monitored and provision reviewed if it is felt to be

S:\Planning Decisions\Cases\3047\Stage 1 page 8 insufficient, to ensure that provision equates to the demand from disabled residents and visitors, and that the bays are effectively enforced.

53 The information provided indicates that 6% of the total parking provision will be disabled persons parking. This would be acceptable if it can be shown how an additional 4% of the capacity can be converted into disabled persons parking bays if required in the future in line with London Plan policy.

54 The crossing points around this site, including those within the car parks should, where appropriate, incorporate correctly positioned tactile paving, in accordance with the DfT’s “Guidance on the use of tactile paving surfaces”.

55 The travelling distance from the disabled persons parking bays above, to the lift is quite significant. This should be measured and assessed in terms of its suitability. If it is felt to be suitable, it should be ensured that the route has an appropriate width, and is kept clear from other obstructions.

Public facilities

56 Inside the new supermarket it is stated that accessible WCs are to be provided. It should also be ensured that separate accessible baby change facilities are provided, in accordance with BS8300:2009 + A1:2010. These should not be provided within the accessible WCs.

57 Finally, a number of points from the design and access statement are of concern, and should be addressed in the application:

 The design and access statement refers extensively to Approved Document M of the Building Regulations. This is a minimum standard in terms of accessible design, which is in places far lower than other standards i.e. BS8300. London Plan policy 7.2 requires all new developments in London to achieve the highest standards of accessible and inclusive design. In general, the applicants should therefore seek to exceed the minimum standards presented in Approved Document M.

 The design and access statement on page 72 refers to the British Standard 8300: 2001. This version of the British Standard has been replaced by BS8300:2009 + A1:2010, and it is this, more up to date version which should be applied to this development, again to ensure the highest standards of accessible and inclusive design are achieved.

 The design and access statement (appendices) also refers to ‘evac chairs’ being used to evacuate disabled people in case of an emergency. This is a concern as ‘evac chairs’ cannot be used by some disabled people i.e. those who cannot transfer out of their own wheelchairs. Therefore relying on such methods is a concern. Sustainable energy

58 The applicant has broadly followed the energy hierarchy to reduce carbon dioxide (CO2) emissions. Sufficient information has been provided to understand the proposals as a whole.

59 Further revisions and information is required before the proposals can be considered acceptable and the carbon dioxide savings verified

S:\Planning Decisions\Cases\3047\Stage 1 page 9 Be Lean:

Energy efficiency standards

60 A range of passive design features and demand reduction measures are proposed to reduce the carbon dioxide emissions of the proposed development. Both air permeability and heat loss parameters will be improved beyond the minimum backstop values required by building regulations. Other features include roof lights, high efficiency lighting, daylight linked lighting controls, inverter drives on mechanical ventilation linked to carbon dioxide sensors and a full store building energy management system (BEMS). The applicant should indicate how the demand for cooling will be minimised.

61 The development is estimated to achieve a reduction of 860 tonnes per annum (40%) in regulated carbon dioxide emissions compared to a 2010 Building Regulations compliant development, as shown in the table below. However, the applicant should provide modelling output to support this level of projected savings.

Be Clean

District heating 62 The applicant should investigate whether there are any existing or planned district heating networks in the vicinity of the development and provide a commitment to ensuring that the development is designed to allow future connection to a district heating network should one become available.

63 The applicant should confirm that a site heat network will be installed and that all building uses will be connected to the network. A drawing showing the route of the site heat network linking all buildings uses on the site should be provided. The applicant should confirm that the site heat network will be supplied from a single energy centre. Further information on the floor area and location of the energy centre should be provided.

Combined Heat and Power (CHP)

64 The applicant has investigated the feasibility of CHP. However, due to the nature of the heat load, CHP is not proposed. This is accepted in this instance.

Be Green

The Renewable energy technologies

65 The applicant has investigated the feasibility of a range of renewable energy technologies and is proposing to install a closed loop ground source heat pump (GSHP) and air source heat pumps (ASHP). A description of how the two technologies will operate in conjunction with each other in the provision of heat to the development.

66 For the GSHP, an indication of land area available and proposed number of boreholes, details of the energy efficiency ratio (EER) and coefficient of performance (COP) of the heat pump is required. For the ASHP the applicant should confirm that this is a centralised unit serving a heating/cooling network and also provide details of the energy efficiency ratio (EER) and coefficient of performance (COP) of the heat pump.

67 The applicant should also consider any potential to use waste heat from refrigeration to provide heat to the development.

S:\Planning Decisions\Cases\3047\Stage 1 page 10 68 A reduction in regulated carbon dioxide emissions of 257 tonnes per annum (20%) will be achieved through this third element of the energy hierarchy (see table below).

Overall carbon dioxide savings 69 Based on the energy assessment submitted at Stage I, the table below shows the residual carbon dioxide emissions after each stage of the energy hierarchy and the carbon dioxide emission reductions at each stage of the energy hierarchy.

Table: carbon dioxide emission reductions from application of the energy hierarchy Total residual Regulated CO2 emissions regulated CO2 reductions emissions (tonnes per (tonnes per (per cent) annum) annum) Baseline i.e. 2010 Building 2,149 Regulations Energy Efficiency 1,289 860 40 CHP 1,289 - - Renewable energy 1,032 257 20 Total 1,117 52

70 A reduction of 1,117 tonnes of carbon dioxide per year in regulated emissions compared to a 2010 Building Regulations compliant development is expected, equivalent to an overall saving of 52%.

71 The carbon dioxide savings exceed the targets set within Policy 5.2 of the London Plan and this is welcomed. Air quality assessment

72 At the pre-application stage the applicant was requested that the environmental assessment should include an air quality assessment and that the development should be air quality neutral.

73 The applicant has completed an assessment and there is concern that it does not appear that the report includes any operational information about heating plant. If the plant is being replaced or if additional plant is being installed then this information needs to be included and dispersion needs to be modelled taking into consideration sensitive receptors. If the plant will cause concentrations to increase then the applicant will need to propose mitigation strategies.

74 A further concern is the volume of additional parking spaces, which the report shows will increase emissions. The GLA would like to see the number of parking spaces reduced and further mitigation measures proposed.

75 The applicant should be aware that the GLA is currently updating the Best Practice Guidance on the control of dust and emissions from construction and demolition and this will be published in April 2013 as Supplementary Planning Guidance. All new relevant conditions/requirements included in this guidance document must be followed by the developer, particularly those relating to non road mobile machinery. .

S:\Planning Decisions\Cases\3047\Stage 1 page 11 76 Furthermore, if new gas boilers are proposed these will need to meet the standards set out in the GLA's Air Quality Neutral SPG (which will be published in early 2013). Flood Risk

77 The applicant’s Flood Risk Assessment (FRA) confirms that the site is in Flood Zones 1 and 2 and therefore the development is acceptable in principle.

Surface Water Run-off

78 The Flood Risk Assessment states that the eastern edge of the site is at risk from surface water flooding. This risk area extends further west beyond the site boundary and run-off from this site contributes to that area of flood risk. Therefore it is important that this development minimises its surface water discharge.

79 The FRA states that the new development will achieve Greenfield run-off rates by use of 4 cellular storage tanks located below the car park and totalling approx 1,000 (m3).cubic metres

80 The proposal does not appear to include provision for rainwater harvesting. This feature is at the top of the London Plan Sustainable Drainage Hierarchy (London Plan policy 5.13) and has the potential to reduce mains water consumption and reduce operating costs for the supermarket. The applicant should consider the adoption of this infrastructure.

81 The proposal does not appear to include provision for green/brown roof. On such a large building this is a missed opportunity to provide the multiple benefits that such roofs provide, amongst which is also a reduction in rainwater run-off.

82 The applicant should examine these aspects of the building specification prior to a referral back to the Mayor. Transport

Transport modelling

83 The calculation of trip rates for the existing store has been based on surveys undertaken on site in 2012. A comparison between these trip rates and those included in both the TRAVL and TRICS database is presented in the transport assessment to demonstrate robustness of the assessment. While this is acceptable, trip generation for the proposed extension is then based on surveys of other extended Sainsbury’s stores. However, many of these are not located in London and this methodology is therefore questionable. TfL understands that a Sainsbury’s store in Crayford (LB Bexley) has very similar characteristics to the proposed development and has recently been surveyed following an extension. TfL would therefore recommend that the results obtained for this development should be compared with those of the Crayford store. This is to ensure that the application complies with London Plan Policy 6.12 Road Network Capacity.

84 The transport assessment contains junction modelling for the local road network, the extent of which is considered acceptable. The modelling has been carried out in line with TfL best practice guidance, but clarification on some aspects of the modelling, as contained within TfL’s detailed initial comments issued on 17th January 2013, is required before the application can be considered to be in line with London Plan Policy 6.3 Assessing Effects of Development on Transport Capacity.

S:\Planning Decisions\Cases\3047\Stage 1 page 12 85 In light of the above, TfL is not in a position to confirm the acceptability of the likely highway impact generated by the proposals and may recommend potential mitigations on receipt of additional information.

86 It is nevertheless accepted that there should be sufficient capacity on the existing public transport network to accommodate the forecast increase in trips likely to be generated by the proposed development. However, discussions have been held with the applicant at pre-application stage in respect to improving access to the new pedestrian store entrance, which is proposed to be located close to the junction of Long Drive and Victoria Road. It has subsequently been agreed that an additional northbound bus stop is to be introduced on Victoria Road south of the junction at the developer’s expense. Exact location of this new stop will need to be agreed with TfL. This is supported and TfL requests that a contribution of up to £40,000 be sought and included in the s106 agreement to ensure compliance with London Plan Policy 6.7 Better Streets and Surface Transport.

Car parking

87 It is proposed that there will be a 37% increase in car parking from 371 to 582 spaces. It has been accepted at pre-application stage that 1 space per 23 sq.m is reasonable in this location and in line with the London Plan standards. However, due to the traffic congestion in the area TfL would still encourage the applicant to consider reducing this number further.

88 The applicant proposes to provide a total of 22 active and passive electric vehicle charging Points (EVCPs), which is insufficient. In order to comply with London Plan policy 6.13 Parking, and regardless of the provision ultimately agreed, the level of EVCPs will need to be increased to meet 10% active and 10% passive provision for all spaces proposed.

89 TfL welcomes the inclusion of the car parking management plan as part of the transport assessment. TfL would recommend that monitoring of parking would need to be undertaken on a regular basis to ensure that the proposed level of provision is utilised and does not represent an over provision. Part of the monitoring will also need to assess the use of ECVPs and assist in deciding when the passive spaces will need to be brought into use to meet demand. TfL recommends that this management plan be subject to a planning condition.

Cycle parking

90 As this site is not classified as being ‘in centre’, it is accepted that the proposal to provide 36 cycle spaces for both staff and customer use is in line with the London Plan standards and its associated draft Revised Early Minor Alterations June 2012. However TfL would recommend that the staff cycle spaces should be accessible, secure and well lit, and with lockers and showers provided. In addition, given the store’s central location and proximity to South Ruislip local amenities and station, TfL would recommend additional provision be provided, which could be monitored through the Travel Plan.

High speed two (HS2) infrastructure development

91 The site lies to the east of the Chiltern Main Line and the applicant should be aware that this line is currently proposed for the alignment of the High Speed 2. As the site is immediately adjacent to the current proposed route the applicant should be aware that the form of proposed route for this section was amended last January. While this should therefore not raise any conflicting issues unless very deep foundations are required for the construction of the site, and which seems unlikely, TfL would however still recommend that the applicant consult with HS2 Ltd to confirm this, in line with London Plan Policy 6.2 Providing Public Transport Capacity and Safeguarding Land for Transport.

S:\Planning Decisions\Cases\3047\Stage 1 page 13 Public realm

92 As stated above, it is proposed that there will be a new pedestrian access to the store in the vicinity of the Long Drive/Victoria Road junction. This is welcomed as it will provide a better environment for pedestrians accessing the store than the current accesses. In addition, the inclusion of a pedestrian environmental review system (PERS) audit of the existing pedestrian conditions within the transport assessment is welcomed, together with the proposed improvements to the Long Drive and Victoria Road frontages. It is recommended that the measures identified in this audit be implemented by the developer and secured through s106 or s278 agreements. These will be required to comply with London Plan Policy 6.10 Walking. TfL also requests that Legible London signage to be introduced through this development and the local area as part of transport enhancement contributions. This signage should cover routes such as those from the development to the station and bus stops, and be secured through s106.

Delivery plans

93 A framework travel plan for the entire development was submitted as part of the application, which is supported. Unfortunately the Travel Plan has failed the ATTrBuTE tool assessment and therefore needs improvements. To ensure acceptance, additional information on the number of staff, how the plan will be secured and information on budget streams will need to be included in the final travel plan. To ensure conformity with London Plan Policy 6.3, the travel plans are expected to be secured, monitored, reviewed, and enforced through the s106 agreement.

94 The inclusion of a delivery servicing plan (DSP) within the transport assessment (TA) is supported and is in line with London Plan Policy 6.14 Freight. TfL however recommends that this should be subject of a planning condition.

95 A framework construction logistics plan (CLP) for the whole site, as referred in the London Freight Plan should have been submitted as part of the TA as advised at pre-application stage. However, TfL is content for this to be subject to a planning condition.

Summary

96 To summarise, TfL requires some further work on trip generation and modelling to understand the likely highway impact and its relation with the proposed level of car parking provision, an increase in the number of electric vehicle charging points, and revisions to the travel plan before the application can be considered compliant with the transport policies of the London Plan. Introduction of a new northbound bus stop and improvements to the pedestrian environment around the store, including Legible London, will also need to be secured as part of the Section 106 agreement, along with the travel plan. Both a CLP and DSP should be secured by a planning condition. Community Infrastructure Levy

97 The Mayor has introduced a London-wide Community Infrastructure Levy (CIL) to help implement the London Plan, particularly policies 6.5 and 8.3. The Mayoral CIL formally came into effect on 1 April 2012, and it will be paid on commencement of most new development in Greater London that was granted planning permission on or after that date. The Mayor's CIL will contribute towards the funding of

98 The Mayor has arranged boroughs into three charging bands. The rate for Hillingdon Council is £35/sq.m. The required CIL should be confirmed by the applicant and council once the components of the development or phase thereof have themselves been finalised. See the 2010

S:\Planning Decisions\Cases\3047\Stage 1 page 14 regulations: http://www.legislation.gov.uk/ukdsi/2010/9780111492390/contents as amended by the 2011 regulations: http://www.legislation.gov.uk/uksi/2011/987/made

99 London borough councils are also able to introduce CIL charges which are payable in addition to the Mayor’s CIL. Hillingdon Council has yet to adopt a scheme. See the council’s website for more details.

100 In these situations, the Mayor’s CIL charge (but not the borough’s) will be treated as a credit towards the S106 liability. The practical effect of this will be that only the larger of the two amounts will normally be sought. As the CIL charge will not be confirmed until development is about to commence, the s106 agreement will need to be worded so that if the s106 contribution based on the assumed CIL proves incorrect the contribution is adjusted accordingly (assuming it is still more than the CIL). Other contributions towards the mitigation of transport impacts may also be sought in accordance with London Plan policy and with relevant legislation. Legal considerations

101 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. There is no obligation at this present stage for the Mayor to indicate his intentions regarding a possible direction, and no such decision should be inferred from the Mayor’s statement and comments. Financial considerations

102 There are no financial considerations at this stage. Conclusion

103 London Plan policies on retail/ town centre uses, employment, housing, urban design, access, climate change and transport are relevant to this application. The application complies with some of these policies but not with others, for the following reasons:

 Retail: the assessment of impact should provide further evidence on trends within existing centres in context of the store delivery; the applicant should also confirm discussions with Ealing and Harrow Councils have taken place, this consultation should be evident in the impact assessment; the applicant should provide more extensive assessment of impact on investment in town centre hierarchy; the applicant should provide analysis of cumulative impact of the proposals in context of other potential and on-going applications including the Arla site in South Ruislip and Tesco's and Morrison's on Hillingdon Circus; Hillingdon Council work with GLA policy team in reviewing the town centre retail network and future change to table A2.1 town centre classifications and broad future directions.  Design: the quality of design is generally acceptable and modifications requested from pre-application discussions have been included in the finalised design. Given the large scale and mass of supermarket roof and car parking area, the applicant is requested to explore potential for a green/brown roof or roof elements this would have an impact in softening the bulk and massing of such a large building. Given the very significant increase in the size and scale of the proposed store redevelopment compared to the existing store

S:\Planning Decisions\Cases\3047\Stage 1 page 15 and extant scheme. The applicant is required to make a proportionate contribution to the public realm and wider local higher to justify the impact of the extra floorspace and activity o this relatively small local/neighbourhood centre.  Access: the applicant should provide the requested additional information and respond to required clarifications in relation to the public realm, car parking and public facilities.  Climate change mitigation: the applicant should provide the requested additional information and respond to required clarifications in relation to energy efficiency standards, district heating, renewable energy technologies and overall carbon savings.

 Air quality: The applicant should resubmit the air quality assessment responding to comments made in relation to air quality impacts of the proposed heating plant and mitigation measures to be adopted.  Flood risk: The applicant should consider including provision for rainwater harvesting to reduce mains water consumption and reduce operating costs for the supermarket; the applicant should assess the feasibility of a brown/green roof to reduce rainwater run off and other environmental benefits.

 Transport Further work is required on trip generation and modelling to understand the likely highway impact and its relation with the proposed level of car parking provision; an increase in the number of electric vehicle charging points is required; revisions to the travel plan are required; the introduction of a new northbound bus stop and improvements to the pedestrian environment around the store are required, including Legible London; the applicant should agree to Section 106 clauses and planning conditions.

for further information, contact Planning Decisions Unit: Colin Wilson, Senior Manager – Planning Decisions 020 7983 4783 email [email protected] Justin Carr, Strategic Planning Manager (Development Decisions) 020 7983 4895 email [email protected] Jonathan Aubrey, Case Officer 020 7983 5823 email [email protected]

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