Swakeleys House, Ickenham in the London Borough of Hillingdon Planning Application No

planning report D&P/2995/02 30 October 2013 Swakeleys House, Ickenham in the London Borough of Hillingdon planning application no. 23202/APP/2013/12

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

The proposal Change of use of Swakeleys House, (a Grade I listed building), from office (B1) use and sports (D2) use into a single dwelling, along with demolition and replacement of ancillary outbuildings buildings (Vyners House and the Ice House) into ancillary accommodation for Swakeleys House. The applicant The applicant is CES Properties (Ickenham) Ltd and the architect is Paul Davis & Partners.

Strategic issues The concerns raised at the consultation stage regarding affordable housing, accessibility and transport have been satisfactorily addressed, and the proposal now accords with strategic planning policy.

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

Context

1 On 25 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. This was referred to the Mayor under Category 3D of the Schedule to the Order 2008: “Development (a) on land allocated as Green Belt or Metropolitan Open Land in the development plan, in proposals for such a plan, or in proposals for the alteration or replacement of such a plan; and (b) which would involve the construction of a building with a floorspace of more than 1,000 square metres or a material change in the use of such a building.”

page 1 2 On 6 March 2013 the Mayor considered planning report PDU/2995/01, and subsequently advised Hillingdon Council that while the application was generally acceptable in strategic planning terms the application did not comply with the London Plan, for the reasons set out in paragraph 49 of the above-mentioned report; but that the possible remedies also set out in this paragraph could address these deficiencies.

3 A copy of the above-mentioned report is attached. The essentials of the case with regard to the proposal, the site, case history, strategic planning issues and relevant policies and guidance are as set out therein, unless otherwise stated in this report. Since then, the application has been revised in response to the Mayor’s concerns (see below). On 28 August 2013 Hillingdon Council decided that it was minded to grant planning permission, for the revised application, and on 17 October 2013 it advised the Mayor of this decision. Under the provisions of Article 5 of the Town & Country Planning (Mayor of London) Order 2008 the Mayor may allow the draft decision to proceed unchanged, direct Hillingdon Council under Article 6 to refuse the application or issue a direction to Hillingdon Council under Article 7 that he is to act as the Local Planning Authority for the purposes of determining the application and any connected application. The Mayor has until 30 October 2013 to notify the Council of his decision and to issue any direction.

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

Update

5 At the consultation stage Hillingdon Council was advised that while the application was generally acceptable in strategic planning terms the application did not comply with the London Plan, for the reasons set out in paragraph 49 of the above-mentioned report; but that the possible remedies also set out in this paragraph could address these deficiencies:

 Principle of development: The proposal complies with London Plan policy 7.8 ‘Heritage assets and archaeology’ and London Plan policy 7.16 ‘Green Belts’. The change of use from employment back to the former residential use does not raise any strategic concerns. The existing footpath use and open day/festival uses are also to be retained. The Council should ensure the guest and staff accommodation and banqueting facilities are secured for ancillary use only.  Housing: An affordable housing contribution is required.

 Accessibility: Further information is required to determine whether the application complies with London Plan policy 7.2

 Energy: The proposals are acceptable.

 Transport: Electric vehicle charging points should be provided.

Principle of development

6 The principle of development was accepted at the consultation stage. However, while the proposal to reuse the existing building and the construction of guest accommodation and banqueting facilities was considered not to be inappropriate development within the Green Belt, GLA officers emphasised the importance that these facilities remain ancillary to the use of the house, as independent use of them could cause harm to the Green Belt. These ancillary uses have been secured as such by planning condition and is welcomed.

page 2 7 It was noted that the use of the existing footpath and open day/festival uses should be retained. A commitment to securing these public facilities and uses has been included in the draft section 106 legal agreement and is supported. Affordable housing

8 The applicant does not propose to provide a contribution to affordable housing and does not consider that it is required, a position that is also supported by the Council. In the context of the discussions set out paragraphs 32 to 34 of the GLA stage one report, it was considered that given the size of the dwelling and its outbuildings and given that the building is in a good state of repair, and no case had been made for enabling works to fund repairs, it would seem reasonable for some contribution to be made to off-site affordable housing.

9 In response to the above, the Council has considered the unique circumstances of the site and an individual assessment of what might ‘normally’ be expected to have come forward has been made, as advised at the consultation stage. Council officers are of the view that Swakeleys House represents an exceptional case and that the retention of the open house/festival use and access to the existing footpath offer considerable benefits to the wellbeing of the local community; requirements that have economic implications for the potential value of the development, and outweigh the need for a contribution to affordable housing. Furthermore, the Council has argued that the robustness of any economic viability assessment would be questionable given the unpredictability of the associated maintenance costs, economic implications of the community benefits and the costs associated with restoring the Grade I listed building. With regard to these factors the Council considers that the estimation of build costs and resultant land values would be difficult to calculate and therefore any conclusion for what constitutes the maximum reasonable contribution made on such an assessment would be subject to criticism.

10 With regards to the sites heritage value, the proposals will restore a Grade I listed building considered by English Heritage to be a very rare building type in London representing “a practically unaltered example of the Artisan Mannerist style” by giving the highest priority to the architectural integrity of the house and presenting the opportunity to remove the ancillary building uses associated with its pervious office use. Despite marketing efforts the building has remained vacant as an office location for ten years and it is considered that the proposals to return it to its original use as a single residential dwelling represent an increased opportunity for the buildings occupation, thus securing a long term future for the valuable heritage asset.

11 As set out above, the proposals will contribute to the local community by maintaining the footpath access and a firm commitment to retaining the open house and Ickenham Festival uses. Furthermore, the development will enable the sympathetic restoration of the Grade I listed building and return it to its original use, securing a long-term future for the heritage and community asset. Taking these benefits into account, and the difficulties outlined above in producing a robust financial viability assessment to support a maximum reasonable contribution to affordable housing, it is ultimately accepted in these special circumstances that an offsite contribution to affordable housing is not provided.

Accessibility

12 At the consultation stage, the applicant was requested to provide further information regarding the entrance to, and lift replacement within Swakeleys House, the level changes within the new glazed link and to demonstrate how at least one of the guest suites will be designed to be easily adaptable for occupation by a wheelchair user. Officers note that a planning condition has been secured requiring that full details of how the development will meet Lifetime Home standards, including details of how the above issues will be addressed, must be submitted to and

page 3 approved in writing by the Council. This is accepted and will ensure general accordance with London Plan policy 7.2. Transport

13 At stage 1, Transport for London requested a reduction in the level of car parking for the banqueting use, the provision of electric vehicle charging points, secure cycle parking spaces, consideration of local pedestrian and cycle improvements, as well as the submission of a delivery and servicing plan, construction logistics plan and a travel plan.

14 The requested reduction in parking was not agreed given the site’s poorly accessible location. While this is disappointing as it exceeds the London Plan standards, it is accepted that the likely impact of the proposals on the highway should be accommodated given the infrequent and off peak use of the banqueting suite, which is controlled by way of planning condition, and the site’s remote location away from any sections of the TfL Road Network. For similar reasons, the lack of any travel plan is also accepted.

15 Following the receipt of additional information related to the other transport matters, including the agreement to appropriate conditions or section 106 obligations on cycle parking, electric vehicle charging points, delivery, construction and the pedestrian environment, TfL considers that these proposals are now compliant with the transport policies of the London Plan.

Response to consultation

16 Hillingdon Council publicised the application by sending letters to 111 nearby properties and by issuing press and site notices.

Public Consultation

17 As a result of the public consultation seventeen individual representations (fourteen objecting and three supporting) and seventeen standard letters of support were received. In addition to these responses, four petitions (three in objection and one in support) were received from relevant local amenity groups and residents associations. For the convenience of the Mayor a brief summary of the issues raised by these objections is contained below:

Objections

 New residential development in the Green Belt and Conservation Area does not represent ‘very special circumstances’ and encroaches further into Green Belt.

 Hard standing should not be considered as building and included in built footprint comparisons. Building on this car park area would decrease openness of this part of the site. Overall increase in built footprint is unacceptable.

 Harm to setting of Grade 1 listed building.

 Increase in traffic in the Avenue during construction and banquets which will have public safety issues.

 Inappropriate and unsympathetic alterations to the house and grounds. Additional buildings are not consistent with a single residential dwelling and their cumulative impact is considered inappropriate development. Fear that these will become additional private residential units.

page 4  No buyer has been found, unlikely to be any more successful of finding a residential occupier than a commercial one.

 Loss of access to publicly accessible land, footpath and removal of public amenity.

 Loss of Swakeleys Bowls Club and clubhouse as an important leisure, social and community facility.

 Application does not return the property to its historic use unless the Lord Mayor of London is the tenant.

 The ballroom and gallery were there when the property was converted to officers and are recoverable.

 The application is a rouse for the conversion of Swakeley House to a small hotel complex.

 Scant information on what will happen to the courtyard buildings is a concern.

 Layout of rooms is a waste of space.

 Proposals for use of site by a charity to run a freeschool should be considered as this would maintain current public benefits.

 Confirmation that boundary strengthening treatments to not include the area of woodland to the east of the estate and boundary between the two will remain open.

 Adequate protection and insurance of the building is required.

 Application creates a ‘ransom strip’ between Vyners House and parcel of woodland as land included within the application site, but excluded from the area where buildings would not be allowed.

 Further consideration of site is required and the boundaries should enable free movement of ground dwelling animals.

 Solar and thermal PV panels are out of character.

 Remain unconvinced on the claims of the aboricultural report regarding tree planting and the screening they will provide.

 The design of the additional buildings and proposed glazed link is unsympathetic to the historic setting of the listed building and should be reconsidered.

 Use of inappropriate materials.

 Proposed banqueting hall is considered unnecessary.

 Any archaeological evidence unearthed should be made available for public inspection and scholarly interest.

page 5 Support

 Support the proposals for the return of the use as a family home, as it seems the best way to restore and retain character, avoid continued vacancy and increase public interest.

 Retention of access to public footpath, open house and Ickenham festival access is welcomed.

 Proposals support the long term future of Swakeley House.

 Support the removal of the 1980’s additions to the house which detract from its beauty.

18 The objections raised during the consultation process are addressed within the Council’s committee report and do not raise any strategic issues.

Responses from other organisations

19 The following organisation issued responses to the consultation. English Heritage raised no issues and considered the return of a residential use as a single dwelling would be sympathetic to its conservation. English Heritage Archaeology requested a condition regarding archaeological investigation and the recording of remains. This has been secured. Natural England did not object to the development and recommended the use of national standing advice to assess any impact on protected species. A condition requiring the submission of mitigation and monitoring strategy for the protection of bats and their habitats was suggested, as were the opportunities to incorporate features into the design that may help enhance the sites biodiversity.

20 Ruislip Local History supported the removal of the 1980’s additions, but raised concerns that the seven new buildings represent an overdevelopment of the site and will impact on the setting of the house. Concerns were also expressed regarding the proposed use of unsympathetic materials and that a more generous commitment to open house days should be encouraged. The Ickenham Village Conservation Area Panel welcomed the re-instatement of a suitable use at Swakeleys House but expressed concerns over the new buildings distracting from the significance of the historic asset and that they should be redesigned in a more sympathetic manner. Conditions requiring that the estate remains a single residence and that all archaeological evidence be made available for public inspection were requested, and these have been secured.

21 The statutory and non-statutory responses to the Council’s consultation, do not raise any material planning issues of strategic importance that have not already been considered by the Mayor at the consultation stage and/or in this report. Article 7: Direction that the Mayor is to be the local planning authority

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

23 Under the arrangements set out in Article 5 of the Town and Country Planning (Mayor of London) Order 2008 the Mayor has the power under Article 6 to direct the local planning authority

page 6 to refuse permission for a planning application referred to him under Article 4 of the Order. He also has the power to issue a direction under Article 7 that he is to act as the local planning authority for the purpose of determining the application and any connected application. The Mayor may also leave the decision to the local authority. In directing refusal the Mayor must have regard to the matters set out in Article 6(2) of the Order, including the principal purposes of the Greater London Authority, the effect on health and sustainable development, national policies and international obligations, regional planning guidance, and the use of the River Thames. The Mayor may direct refusal if he considers that to grant permission would be contrary to good strategic planning in Greater London. If he decides to direct refusal, the Mayor must set out his reasons, and the local planning authority must issue these with the refusal notice. If the Mayor decides to direct that he is to be the local planning authority, he must have regard to the matters set out in Article 7(3) and set out his reasons in the direction. Financial considerations

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

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

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

27 The issues raised at the consultation stage regarding affordable housing, accessibility, and transport have been resolved through the provision of further information and amendments secured by planning condition. As a result the application is now considered acceptable in strategic planning terms.

for further information, contact Development & Projects: Colin Wilson, Senior Manager – Development & Projects 020 7983 4783 email [email protected] Justin Carr, Strategic Planning Manager (Development Decisions) 020 7983 4895 email [email protected] Jonathan Finch, Case Officer 020 7983 4799 email [email protected]

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planning report PDU/2995/01 6 March 2013 Swakeleys House, Ickenham in the London Borough of Hillingdon planning application no. 23202/APP/2013/12

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

Strategic issues The key strategic issues for consideration are Green Belt and heritage, other minor issues relating to affordable housing, inclusive design and transport require resolution.

Recommendation That Hillingdon Council be advised that while the application is generally acceptable in strategic planning terms the application does not comply with the London Plan, for the reasons set out in paragraph 49 of this report; but that the possible remedies also set out in this paragraph of this report could address these deficiencies.

Context

1 On 25 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 7 March 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.

2 The application is referable under Category 3D of the Schedule to the Order 2008:

“Development (a) on land allocated as Green Belt or Metropolitan Open Land in the development plan, in proposals for such a plan, or in proposals for the alteration or replacement

page 8 of such a plan; and (b) which would involve the construction of a building with a floorspace of more than 1,000 square metres or a material change in the use of such a building.”

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

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

Swakeleys House and adjacent buildings (aerial view)

5 Swakeleys House is situated in Ickenham in the northern part of Hillingdon Borough. The site is in the centre of a residential area that lies between Swakeleys Road to the north and the west, Long Lane to the south and Western Avenue (A40) to the south. The A40, which is part of Transport for London Road Network (TLRN) is over 1km from the site. The accesses to the site are off Milton Road to the north and Swakeleys Drive to the south. Both of these are part of the Borough’s highway network.

6 Both Ickenham and Hillingdon Underground stations are located approximately 1km east of the site, providing frequent services into central London and Uxbridge on the Metropolitan and Piccadilly Lines. This site is only served by one bus route (U10) providing a hourly service between Ruislip, Hillingdon Underground and Uxbridge stations, with bus stops located 300m away from the site on Swakeleys Drive. As such, the public transport accessibility level (PTAL) of the site is 1 (based on a scale of 1 to 6 where 1 is lowest and 6 is highest) which equates to a very poor level of accessibility to public transport.

7 Swakeleys House is a Grade I listed 17th century mansion house, which was built for Sir Edmund Wright in 1638, a wealthy London merchant, as a family home, entertaining space and retreat from the city. It is an important example of artisan mannerism and is ‘H’ shaped in red brick

page 9 with stone and stucco dressings. It has five bays on main fronts and four on the side. There are two main floors with a third floor in the roof space. Although it has been vacant since 2003 it has been kept secure and is not on the Buildings at Risk Register.

8 There are two ‘L’ shaped stable buildings that are located immediately north of the main house, which create a stable courtyard. These are also Grade I listed (being listed in 1974). Linked to the stables is a 1980s office building known as Vyners House and another office building known as Harrington House, which stands to the east, however this does not form part of the application proposals.

9 The house and its grounds form part of Ickenham Village Conservation area and the majority of the site forms part of the Green Belt. The application site is approximately 8.61 hectares and is surrounded by suburban residential development.

10 The River Pinn also lies adjacent to the western part of the site within a flood risk area of zones 2 and 3.

11 The majority of the site is open land; a tree-edged lake borders this land to the east, beyond which is a public park. The house has its main historic approach along an avenue leading from the south (of which remnants remain) although access is presently gained from the north, via a private road terminating in the stables area, and leading past buildings presently used for employment purposes. A private lawn bowling club is sited on the open ground to the north-west of the house. The house was renovated in the 1980s for employment use and was occupied by a pharmaceutical company during the 1980s and 1990s, but has remained vacant since 2003, with the exception of the northern part of the western stable courtyard, which is occupied by a security company as offices.

12 A public footpath leads through the site from the southern approach, and borders the open land, running alongside the lake (shown in yellow on the plan below). This access and other uses of the land by the community, including the Ickenham festival held every two years, and house open days, were secured through legal agreements associated with previous planning consents. The green edged and hatched area shown in the plan below show site usage for the above mentioned purposes.

page 10 Site plan indicating the conditional uses of the site’s grounds

Details of the proposal

13 The proposed development is for the restoration of the Grade I listed Swakeleys House and Grade I listed stable courtyard to create a single family dwelling. The proposal also involves the demolition of Vyners House, the ‘Ice House’ (a small external plant room) and car park and construction of guest accommodation and banqueting facilities on their sites, together with the re- instatement of historic landscaped elements, involving the loss of a footpath and bowling club within the grounds of Swakeleys House.

14 There are seven guest suites proposed within the footprint of the existing Vyners House building and which provide a total of 11 bedrooms.

15 There would be associated alterations to access and routes, including deletion of the right- of-way through the site.

Case history

16 On 19 July 2012 a pre-application meeting was held at City Hall. The principle of the proposal was supported subject to resolving Green Belt, sport and heritage impacts. Strategic planning issues and relevant policies and guidance

17 The relevant issues and corresponding policies are as follows:

 Green Belt London Plan  Historic Environment London Plan;  Employment London Plan;  Housing London Plan; Housing SPG; Housing Strategy; draft Revised Housing Strategy  Urban design London Plan;

page 11  Access London Plan; Accessible London: achieving an inclusive environment SPG; Planning and Access for Disabled People: a good practice guide (ODPM)  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  Transport London Plan; the Mayor’s Transport Strategy  Parking London Plan; draft Early Minor Alteration to the London Plan; the Mayor’s Transport Strategy

18 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 Local Plan: Part 1- Strategic Policies, November 2012, the 1998 Unitary Development Plan and the 2011 London Plan.

19 The following are also relevant material considerations:

 The National Planning Policy Framework and Technical Guide to the National Planning Policy Framework  The draft Revised Early Minor Alteration to the London Plan

Principle of development – change of use, Green Belt and heritage

Change of use

20 The Hillingdon UDP (Saved Policies) does not incorporate any specific policies that preclude the loss of offices. The applicant has however provided evidence as discussed at the pre- application stage, demonstrating that the property has been marketed since September 2003, however the applicant still has not secured a tenant or purchasers for the building. The applicant has attributed this to the difficulty and expense of adapting the building to be fit for modern businesses who now seek office space close to amenities and public transport, large open plan floor plates and lower running costs with stronger green/sustainability credentials. Given that Swakeleys is a Grade I listed building it does not meet these criteria. Furthermore, the applicant is aware that the public footpath access rights are seen as a major concern to interested parties due to the privacy and security problems it poses.

21 The proposal has the benefit of restoring and bringing the listed building back into use. Therefore the proposed change of use of the house to its former residential use with additional guest facilities is accepted.

Green Belt

22 Protection of character and openness of Green Belt land is of paramount importance within the London Plan. The NPPF sets out that new buildings are inappropriate in the Green Belt. Some exceptions to this are set out including limited infilling or the partial or complete redevelopment of previously developed sites (brownfield land), whether redundant or in continuing use (excluding temporary buildings), which would not have a greater impact on the openness of the Green Belt and the purpose of including land within it than the existing development. The re-use of buildings provided that the buildings are of permanent and substantial construction is also not inappropriate in the Green Belt provided they preserve the openness of the Green Belt and do not conflict with the purposes of including land in Green Belt.

page 12 23 London Plan Policy 7.16 ‘Green Belt’ seeks to protect London’s Green Belt. Policy 7.16 states, “the Mayor will and boroughs should maintain the protection of London’s Green Belt and proposals for alteration to green belt boundaries should be considered through the DPD process in accordance with the government guidance in PPG2 [now replaced with the NPPF]. There is a general presumption against inappropriate development in the green belt, and such development should not be approved except in exceptional circumstances”.

24 The applicant has provided the relevant information requested at the pre-application stage with regards to before and after views and these show that the proposal will not have any significant impact on the character and openness of the site within its Green Belt and conservation setting. The applicant has also provided details of footprint, floorspace (gross external area, with and without basement, and gross internal area) and volume. The changes in these are not significant. Therefore very special circumstances do not need to be put forward for the proposal.

25 However, the applicant has also considered various options within the design evolution of the proposal, particularly with regards to Vyners House and this has ensured that there is minimal disturbance to the Green Belt, archaeological remains and the historic landscaping. Thereby preserving both the heritage and openness of the site.

26 The guest and staff accommodation and banqueting facilities are identified as ancillary to the main house and necessary to attract the type of occupier needed for the house. These elements are not unacceptable, however, it is important that these remain ancillary to the house, as independent use could harm the Green Belt. This should be secured by the Council.

27 It is accepted that the proposal to reuse the existing building and new out building is not inappropriate development within the Green Belt.

Heritage asset

28 The applicant proposes to undertake internal changes to expose and protect historic features. Subject to the views of English Heritage the restoration and refurbishment of Swakeleys House is supported. Securing a viable long term use will safeguard the future of this valuable historic asset, which has been vacant since 2003.

29 English Heritage should also be satisfied that the replacement new-build elements do not harm the setting of the Listed Building.

Footpath

30 The footpath around the western and southern boundary of the site was originally proposed to be removed as part of the development proposals. This perimeter pathway is now proposed to be retained within the proposals, following local consultation, which identified that it was an important route. The use of the site for the annual open day and festival use and access to the House will also be kept. These elements should be secured by the Council.

Trees

31 The potential for tree loss was raised at the pre-application meeting. The applicant has carried out a thorough aboricultural survey, which identifies five trees to be removed, two category B and three category C. The impact of the loss of the category B trees will be minimised as they are screened by other trees to be retained, the loss of the category C trees does not raise concern. Other trees, sympathetic to the historic setting are to be planted.

page 13 Affordable housing

32 London Plan Policy 3.13 sets out that affordable housing is normally required on a site that has a capacity to provide ten or more homes. The policy states that the density guidelines will be applied when assessing whether as site has capacity for ten or more units. Further guidance is given in paragraph 3.78, specifically reference is made to site capacity which might normally be expected to come forward. The Housing SPG also provide guidance, making reference to use of London Plan space standards as a reference point for whether units are particularly large.

33 In this instance the application does not propose to provide affordable housing and does not consider that it is required. There are examples of listed house conversions in outer London Green Belt locations which do exceed the 10 unit threshold and where an affordable housing contribution has been sought. However, the unique circumstances of each site must be considered and an individual assessment of what might ‘normally’ be expected to have come forward has to be made.

34 As stated above the return of the listed building to its original use is supported. Whilst it would be possible to sub divide the house and outbuildings into smaller dwellings, as has been achieved in other listed buildings elsewhere in London, this would be likely to have some impact on the buildings special interest and potentially on the openness of the Green Belt, no matter how sensitively planned. Nonetheless given the size of the dwelling and its outbuildings and given that the building is in a good state of repair, and no case is being made for enabling works to fund repairs, it would seem reasonable for some contribution to be made to off site affordable housing.

Inclusive Design

35 The aim of London Plan Policy 7.2 is to ensure that proposals achieve the highest standards of accessibility and inclusion (not just the minimum). Inclusive design principles if embedded into the development and design process from the outset help to ensure that all of us, including older people, disabled and Deaf people, children and young people, can use the places and spaces proposed comfortably, safely and with dignity.

36 The design and access statement has set out how the proposal has addressed access and inclusive design issues. Whilst noting that the application is for a single family dwelling, there is an opportunity through refurbishment and the new build elements for the development to demonstrate best practice in inclusive design.

Entrances

37 The access statement states that the main entrance into Swakeleys House and into the stables has a level change of between 90mm and 800mm. The existing entrances are proposed to be largely retained in their current state given their Heritage significance but any adaptations are to be carried out in accordance with good practice guidance on accessibility. However, no detail is included on what this means or how this will be achieved. Further details should be provided to demonstrate how access will be achieved here. It may assist to know that Kew Palace, illustrated in the planning statement as another example of Artisan Mannerism architecture and a Grade one listed building, has been made fully accessible to disabled people by the provision of a gently sloping external ramp at the main entrance. This demonstrates that access for disabled people can be achieved at the front entrances of a grade 1 listed building. Further details of how the level change within the new glazed link will be achieved should also be provided.

page 14

38 No mention is made in the access statement of the lift replacement however, the plans state that the lift car within Swakeleys House will be replaced. The opportunity should be taken to install a lift that is fully accessible to disabled people to ensure that the upper floors of Swakeleys House are accessible.

Guest Suites

39 The access statement provides a detailed assessment of how the new guest suites will meet the Lifetime home standards. However, there is no consideration of whether any of the guest suites can meet the key features of wheelchair accessible homes. Given the nature of the development it is recommended that at least one of the guest suites is designed to be easily adaptable for occupation by a wheelchair user. Further details should be submitted to demonstrate how this might be achieved.

Energy

40 The applicant has applied the energy hierarchy and achieved carbon savings of 1% from energy efficiency compared to a 2010 Building Regulations compliant. District heating and combined heat and power have been discounted due to the location of the site and nature of the development, which is accepted. The applicant is proposing to install air source heat pump to provide renewable heat and 157sq.m. of PV and 18sq.m. of roof mounted solar thermal panel. This will provide a further 10% carbon savings.

41 This falls short of the 25% savings sought by the London Plan. However, given the nature of the development as a single dwelling house with ancillary facilities and the constraints of the listed building this is acceptable.

Transport

42 The site consists of a vacant office building with 104 associated car parking spaces. The application proposes 14 garage/covered spaces with additional spaces (up to 40) for use in connection with the banqueting facility. The overall reduction in spaces is supported, and whilst the proposed level exceeds the maximum standard for residential use, it is accepted that the unique nature of the proposal makes application of these difficult. Electrical Vehicle Charging Points should be provided in accordance with the London Plan Policy 6.13 “Parking” as proportion of the fixed parking provision.

43 The trip generation exercise presented within the Transport Assessment did not follow TfL’s Best Practice Guidance. However, due to the scale, location and nature of the development, TfL ultimately accepts the output of the impact assessment and the likely level of additional trips will have no impact on either the public transport or highway network.

44 It is proposed that there will be 18 covered cycle spaces located in the Courtyard. This level of spaces is in line with London Plan Policy 6.9 ’Cycling’. In addition TfL however recommends that secure storage and showers are provided for staff members.

45 In accordance with London Plan policy 8.3 ‘Community Infrastructure Levy’, the Mayor has agreed a CIL Charging Schedule which came into operation on 1 April 2012. It will be paid by most new development in Greater London. Boroughs are arranged into three charging bands with rates of £50 / £35 / £20 per square metre of net increase in floorspace respectively. The proposed development is in the Borough of Hillingdon, where the charge is £35 per square metre.

page 15 Local planning authority’s position

46 The Council’s position is unknown. Legal considerations

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

48 There are no financial considerations at this stage. Conclusion

49 London Plan policies on Green Belt, heritage, housing density, inclusive design, energy, and transport are relevant to this application. In general, the application complies with some of these policies but not with others. The reasons for this and the remedies are set out below:

 Accessibility: Further information is required to determine whether the application complies with London Plan policy 7.2

 Energy: The proposals are acceptable.

Transport: Electric vehicle charging points should be provided.

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] Sukhpreet Khull, Case Officer 020 7983 4806 email [email protected]

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