planning report/PDU/2563a/01 14 July 2010 Uxbridge Golf Course, The Drive, Ickenham

in the London Borough of Hillingdon planning application no.4601/APP/2010/1103

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 Remodeling works to Golf Course, consisting of re-contouring of existing landform using imported inert soils, together with extensive landscaping associated drainage.

The applicant The applicant is Uxbridge Redevelopment Ltd, and the architect is Weller Design Ltd.

Strategic issues The improvements to this golf course are appropriate on designated Green Belt. The provision of a site waste management plan will be secured by condition and this application does not raise any additional waste management issues. In regard to biodiversity the mitigation and enhancements proposed are welcome, the proposed biodiversity management and monitoring plan must be secured by condition. The remodelling and improvement to the golf course are supported in design & access terms.

Recommendation

That Hillingdon Council be advised that the application complies with the London Plan providing the conditions set out in paragraph 43 are agreed by the applicant and the Council. The Council need not refer the application back to the Mayor if these conditions are imposed.

Context

1 On 7 June 2010 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 16 July 2010 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 2B of the Schedule to the Order 2008: “1. Waste development to provide an installation with capacity for a throughput of more than 50,000

page 1 tonnes per annum of waste produced outside the land in respect of which planning permission is sought. 2. Waste development where the development occupies more than one hectare.”

3 Once Hillingdon Council has resolved to determine the application, it is required by the Order 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. In this instance it need not refer the application back to the Mayor if the various conditions identified in the report are imposed.

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 Uxbridge Golf Course is located on 37.5 hectares of land to the north of the A40 Western Avenue (part of the TLRN network) and to the west of Ickenham. As shown in Figure 1, the site is bordered by a waste management site to the north, farmland to the northeast, residential properties along The Drive to the south-east, grazing land and the A40 to the south, and meadow grassland and wet woodland (in part a nature reserve and Sites of Special Scientific Interest) to the west. The site is within the Green Belt.

6 As shown in Figure 1, the site area for the current proposal of remodelling works encompasses only 12.5 hectares of the whole Golf Course site.

Figure 1: the application site area boundary (in red) for the current proposal (Source: applicant’s submitted drawings)

page 2 Details of the proposal

7 The proposed remodelling constitutes a major overhaul of the course, with the aim of producing a golf course that will be much improved, challenging and a well maintained public amenity for the local area.

8 It is proposed that a combination of raising and re-grading the existing topography using inert soils imported from construction sites and the installation of a new pipe drainage network will allow the course to be played throughout the year. A more undulating landscape will be created; to add golfing interest and difficulty but also to ensure that surface water moves more rapidly into the drainage network. The applicant envisages that the remodelling work will result in a course with broader appeal and accessibility to golfers of differing levels of ability.

9 The volume of soils to be imported based on the supporting statement (April 2010) submitted by the applicant is now reduced to 134, 942 cubic metres instead of the 375, 000 cubic metres proposed by the previous application.

10 The other amendments to the current scheme are:

 Withdrawal of the northern access and the use of Skip Lane for this purpose;

 Withdrawal of the proposal to remodel holes at the northern end of the site; the only remodelling to the north of the central woodland block will be on holes 14, and the lower part of hole 16 (existing hole numbers);

 A reduction in the scale of proposed works on the holes to be remodelled. Case history

11 A planning application for a similar scheme was submitted in July 2009 and was withdrawn in September 2009. This application was not referred to the GLA.

12 Another similar application was submitted in December 2009 and was referred to the GLA (PDU2563/01). Hillingdon Council refused the proposed scheme on 10 March 2010.

13 The Council’s reasons for refusal include the following (summarised):

 The application has failed to include details of the route/s of delivery Lorries and a breakdown of delivery lorry movements during the day, particularly during the traffic sensitive peak hours. The application has also failed to include satisfactory information in relation to road safety at the junction of Harvil Road and Skip Lane, at the access point off Skip Lane, and details of the northern access point, including levels and gradients.

 The submitted plans and documentation, including the submitted ecological assessment, has failed to demonstrate that the proposed development could be completed without detriment to the recognised ecological value of this area, including the adjacent Nature Conservation Sites of Metropolitan or Borough Grade I and II Importance, within which there are designated Nature Reserves and a Site of Special Scientific Interest (Frays Farm Meadows).

 The submitted plans and documentation do not clearly illustrate the route of the proposed northern haul road or provide details of the proposed access at the northern boundary of the golf course or provide sufficient information regarding the impact of these works on existing vegetation, including trees and woodland.

page 3  The applicant has failed to provide contributions towards the improvements to facilities as a consequence of demands created by the proposed development (in respect of a contribution towards the management and maintenance of the adjacent Nature Reserves and improvements to the public footpath (boardwalks).) Strategic planning issues and relevant policies and guidance

 Green Belt London Plan; PPG2  Biodiversity London Plan; the Mayor’s Biodiversity Strategy; PPS9; draft PPS Planning for a Natural and Healthy Environment  Waste management London Plan; the Municipal Waste Management Strategy; PPS10  Urban design London Plan; PPS1  Access London Plan; PPS1; Accessible London: achieving an inclusive environment SPG; Planning and Access for Disabled People: a good practice guide (ODPM)  Transport London Plan; the Mayor’s Transport Strategy; PPG13

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

15 The draft replacement London Plan, published in October 2009 for consultation (which is currently at Examination in Public stage) and the Hillingdon revised Core Strategy Preferred Options 2007 are material considerations. Green belt and waste management

16 The application site is designated as Green Belt. Policy 3D.9 of the London Plan clearly indicates that Green Belt is to be protected from inappropriate development, and such inappropriate development should not be approved except in very special circumstances. The London Plan also makes clear that London’s growth should be sustainable and not encroach on London’s own precious green spaces (paragraph xi). The reference to “inappropriate development” flows directly from PPG2, which sets out the Government’s policy towards Green Belt.

17 PPG2 identifies the purposes of Green Belt, which are: to check the unrestricted sprawl of large built up areas; to prevent neighbouring towns from merging; to assist in safeguarding the countryside from encroachment; and to assist in urban regeneration by encouraging the recycling of derelict land.

18 Paragraph 3.12 of PPG2 states that the carrying out of engineering and other operations (which this proposal is) are inappropriate unless they maintain openness and do not conflict with the purposes of including land in the Green Belt.

19 The proposal for remodelling works to improve the quality and condition of Uxbridge Golf Course, consisting of reshaping works using imported inert soils (that facilitates the waste management in the area) and extensive landscaping to enhance visual and ecological amenity would maintain openness and fits within the purposes of including land in the Green Belt. However, it is important that the works are fully carried out as described ensuring that they are completed without detriment to the recognised ecological value of this area, within an agreed timeframe and secured by condition.

page 4 20 The proposal is also assessed in the context of PPG17, which identifies outdoor recreation as an appropriate Green Belt activity. Given the limited visual impact, and the fact that ‘openness’ does not necessarily equate to flatness or an absence of tall vegetation it is considered that the proposal does maintain the openness of the Green Belt and also increases its attractiveness as a recreational destination.

21 The inert material that will be used on the golf course is defined as waste material for planning and environmental purposes, hence the referral to the Mayor. Inert waste is defined by the landfill directive and can be summarised as waste that does not undergo significant change, react with other material or leach into the ground. Under the Directive such inert waste cannot be landfilled untreated- only the unusable residues can be landfilled therefore there is no risk of this site diverting waste from reuse/recycling. Preference should be given to sites closest to the source of waste.

22 The applicant has committed to provide a site waste management plan and this should be conditioned.

Biodiversity and landscaping

23 The applicant has submitted an ecological impact assessment to support the proposed scheme. Since consideration of the previous application a biodiversity mitigation, management and monitoring plan (BMMMP) has been submitted.

24 The landscaping proposals aim to create a more varied mosaic of habitats within the areas between golf holes. The new habitats will be created within a new landscape that will feature a more varied micro-topography and microclimate, the creation of wet and drier areas, substantial native planting and enhanced physical connectivity throughout the site and with the adjoining wetland habitats to the west. It is hoped that complementary habitat areas can be created and managed, with minimal intervention, to encourage ecological diversity.

25 The revisions to the scheme mean a large reduction in the proposed clearance of trees and shrubs. The only mature trees that were to be removed in the previous applications were non- native poplars and in the current proposal almost all of these are now to be retained. The issue of potential harm to existing oak trees is now also reduced given that there are less works proposed to the northern area of the site.

26 Natural England and the London Wildlife Trust objected to the previous applications and the applicant has been working to address the concerns of these organisations in the meantime. The issues revolved around a lack of firm information concerning the needs of the habitats within and bordering the SSSI (i.e. whether more or less water run-off would be beneficial to the SSSI and its features of interest). Accurate prediction of runoff at the current stage in the development process is limited as the actual make-up of the material to be imported to remodel the golf course is not certain. The approach now agreed with Natural England, the Environment Agency and the London Wildlife Trust is to create a flexible solution in which water is channelled into new storage areas from which it can be released in a controlled and variable manner into the SSSI. This flexibility is believed to enable a significant enhancement to the future management of the SSSI, allowing greater control over water levels than exists at present. The proposed measures also incorporate a range of opportunities to enhance water quality entering the SSSI. The Council should confirm that Natural England, the Environment Agency and the London Wildlife Trust are satisfied with the measures proposed prior to determination of the application.

27 The BMMP proposes a number of biodiversity enhancements including extensive woodland planting, the creation of new ponds and wetland habitat, species rich grasslands, nest boxes, the

page 5 restoration of the Harefield Place SINC and the improved management of the enhanced habitats and existing woodlands. As requested in the GLA report on the previous application further information regarding the proposed additional habitat creation and woodland extension has been provided.

28 The proposed mitigation and enhancement measures are welcomed. The proposed biodiversity management and monitoring plan must be secured through condition. Urban design and access

29 Good design is central to all objectives of the London Plan and is specifically promoted by the policies contained within Chapter 4B which address both general design principles and specific design issues. London Plan Policy 4B.1 sets out a series of overarching design principles for development in London, and policy 4B.2 seeks to promote world-class, high quality design and design-led change in key locations. In addition to Chapter 4B, London Plan policies relating to sustainable design and construction (4A.3) are also relevant. Chapter 7 of the draft replacement Plan sets out design related policies.

30 The site is within the Green Belt, so in order to comply with the London Plan and PPG2 policies, the proposed remodelling/landscaping works must maintain the openness of the area and be appropriate to the scale of the surroundings. The development must not have an adverse effect on the character of the local landscape. The design and access statement demonstrates that the site will be extensively re-contoured with imported soils to create an undulating landscape suitable for the creation of a visual interesting and strategically testing golf layout. That said no new buildings or hard landscaping features are proposed.

31 In addition to the four new lined ponds that will be created, stronger slopes off from the golf fairways, and a network of vegetated ditches to replace the existing largely linear ditch network, will channel surface water into wet grassland areas featuring deeper swales that will function as temporary ponds.

32 One of the amendments to the previous scheme is the withdrawal of the proposal to remodel holes at the northern end of the site. The only remodelling to the north of the central woodland block will be on holes 14, and the lower part of hole 16 (existing hole numbers) and this will avoid complication in the remodelling and minimises the overall scale of works.

33 The withdrawal of the northern access and the use of Skip Lane for this purpose is believed to address the concerns that were highlighted by the Council as one of the reasons for refusal of the previous application.

34 The design and access statement states that the public footpath crossing the site will be unaltered by the development (and will remain open during the construction process). The informal arrangement for vehicular access for London Wildlife Trust to their reserve will continue, although a different route across the golf course is proposed.

35 In the previous application, concerns over the usability of the remodelled golf course, for less able-bodied golfers were cited as a reason for refusal of that application. The alterations made in this revised application address this concern through the major reduction in the scale of the proposed works, the inclusion of shallower access routes in the vicinity of all steeper slopes. Whilst these measures are welcomed, the details of the landscaping and layout need extensive consultation with relevant organisations and their concerns should be addressed.

36 There is no new built development associated with the scheme and no change in existing access arrangements. The public footpath crossing the site will be untouched by the development

page 6 (and will remain open during the construction process) and thereafter. The applicant states that all construction access will be via the existing A40, the access used for the recent pipeline works, the use of which has been approved by Transport for London. (See below TfL’s comments for further confirmation).

Transport for London’s comments

37 When consulted on the previous application TfL agreed the use of the access from the A40 for construction access alongside another access on Skip Lane, and requested the submission of a construction logistics plan to be secured by planning condition with the usual requirements that facilities such as wheel washing are located on site and that vehicles do not back up on to the TLRN under any circumstances.

38 Although the current application represents a reduction in the scale of works proposed, TfL’s previous comments as detailed above still stand.

Local planning authority’s position

39 Hillingdon Council officers have yet to confirm their position. Legal considerations

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

41 There are no financial considerations at this stage. Conclusion

42 London Plan policies on green belt, waste management, biodiversity, design, access, and transport and parking are relevant to this application. The application complies with the London Plan providing the conditions set out below are agreed by the applicant and the Council:  Green belt: The proposal is an appropriate use in the Green Belt and complies with London Plan Policy 3D.9  Waste management: The provision of and adherence to a site waste management plan must be secured by condition.  Biodiversity: The mitigation and enhancements proposed are welcome. The proposed biodiversity management and monitoring plan must be secured by condition.

page 7  Urban design and access: The remodelling and improvement to the Golf Course at a lesser scale is supported.  Transport: The submission of a construction logistics plan should be secured by planning condition.

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] Tefera Tibebe, Case Officer 020 7983 4312 email [email protected]

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