planning report D&P/3304/01 18 December 2013 High School, East Lane, Wembley in the Borough of Brent planning application no.13/2961

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

The proposal Proposed new four-form of entry primary school incorporating class rooms, multi-use hall, kitchen, library, staff and administration rooms, ancillary storage and plant rooms, including new external multi-use games area, external playgrounds, new access from East Lane, staff car parking spaces and associated landscaping and lighting. The applicant The applicant is Brent Council, and the architect is Curl la Tourelle Architects.

Strategic issues Key issues are provision of educational facility/new primary school and the loss of playing fields. Other issues assessed include design, access, energy and transport.

Recommendation That Brent Council be advised that the application does not comply with the London Plan, for the reasons set out in paragraph 46 of this report; but that the possible remedies set out in that paragraph of the report could address these deficiencies. The application does not need to be referred back to the Mayor if the Council resolves to refuse permission, but it must be referred back if the Council resolves to grant permission.

Context 1 On 21 November 2013 the Mayor of London received documents from Brent Council notifying him of a planning application of potential strategic importance to develop the above site for the above uses. Under the provisions of The Town & Country Planning (Mayor of London) Order 2008 the Mayor has until 1 January 2014 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 3C of the Schedule to the Order 2008: ”Development which is likely to prejudice the use as a playing field of more than 2 hectares of land which – (a) used as a playing field at the time the relevant application for planning permission is

page 1 made; or (b) has at any time in the five years before the making of the application been used as a playing field.” 3 Once Brent Council has resolved to determine the application, it is required to refer it back to the Mayor for his decision, as to whether to direct refusal 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 Wembley High Technology College is located on East Lane in , close to Vale Farm Sports Ground. The site is bound by residential properties on three sides, East Lane runs along the south side and around the main secondary school building on the west. The current Academy is located to the far west of the site and the new build 4FE primary school will be located on the eastern part of the site.

6 The site has a change of level of approximately four metres along its length, which runs north-south. There is existing vehicular access for the secondary school adjacent to the primary school site, so regular additional vehicular crossover is not necessary for redevelopment of the site in this location. Fire engine tender and ambulance access is provided via a gate from the parking area. 7 The nearest section of the Road Network is the North Circular 3km to the east of the site. The A404 Watford Road, located 1km to the west of the site forms part of the Strategic Road Network . The site is served by bus route 245 running along East Lane with the nearest bus stops available 180m to the west of the site. North Wembley station, located 300m to the east provides access to both () and (Watford to Euston) services. The site has been estimated to have a poor public transport accessibility level (PTAL) of 2, on a scale of 1-6 where 6 is most accessible.

Details of the proposal

8 The proposal for the new primary school comprises 3 x 2 storey blocks and a single storey block - incorporating class rooms, multi-use hall, kitchen, library , staff and administration rooms, ancillary storage and plant rooms, and including new external multi-use games area, external playgrounds, new access from East Lane, staff car parking spaces and associated landscaping and lighting. Case history

9 There is no planning history relevant to the current application.

Strategic planning issues and relevant policies and guidance

10 The relevant issues and corresponding policies are as follows:  Education London Plan  Playing fields London Plan  Design London Plan  Access London Plan; Accessible London: achieving an inclusive environment SPG; Planning and Access for Disabled People: a good practice guide (ODPM)

page 2  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/parking London Plan; the Mayor’s Transport Strategy 11 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 2010 Brent Council Core Strategy Development Plan Document and the 2011 London Plan (with Alterations 2013). 12 The National Planning Policy Framework (NPPF) and Technical Guide to the National Planning Policy Framework are also relevant material considerations. Land use principle Education use 13 The proposal is to build a new four-form entry (4FE) primary school on the eastern part of the secondary school site, enabling the secondary school Academy to become an all-through school from Reception to Y13. 14 The applicant has stated that the proposals are driven by changes in the borough demographic, and is one of a number of schemes commissioned by Brent Council, as it prepares to create new primary and special educational needs (SEN) school places mainly through school expansion as part of a longer term rolling programme to accommodate the exponential growth in demand for school places. 15 The Governing Body of Wembley High Technology College is proposing to change the character of the school on a permanent basis by becoming an “all-through” school by September 2014. “All-through” means the lower age limit will change from 11 years old (Year 7) to 4 years old (Reception). The school will eventually offer places from Reception to Sixth Form (4 years old to 19 years old). There are currently two temporary Reception classes on the Wembley High Technology College site in temporary accommodation. It is intended that these pupils will become permanent students if the proposal is successful. At full capacity the school will have 840 places in the primary sector (age 4 to 11) in addition to the 1,050 places currently in the secondary sector (age 11 to 16) and the Sixth Form (currently 284 aged 17 - 19). 16 Finally, the applicant has stated that without the new primary school proposed on the site the Council would be reliant upon a strategy of providing temporary additional places, which is considered to be a less than ideal solution compared with a permanent expansion, given the short fall of places is predicted to continue unless additional places are made available. 17 To summarise, there is a significant London-wide shortage of school places, which has occurred for a number of well documented reasons. This pressing need, which has been evidenced by the applicant at a local level, should be considered in the context of the Government’s and Mayor’s strong support for new education provision as set out in the NPPF and London Plan, respectively.

Playing fields

18 Sport England has objected the proposed development. It has stated that the scheme, which is the subject of this latest application, for a 4FE primary school on the eastern side of the playing field would lead to a significant loss of playing field and one ‘large grass pitch’ (measuring 57.6m x 81.5m), the relocation and reduction in size of one ‘small MUGA’ and the loss of part of the outfield for cricket. It has also stated that the proposed development would also affect the ability of the playing field to accommodate a running track and rounders’ pitch, which appear to have been marked out on the playing field in the past.

page 3 19 Furthermore, Sport England has noted that no playing pitch strategy has been undertaken by the local authority that indicates there is an oversupply of pitches and playing field and this site has not been identified as one which is surplus to requirements. In the absence of this, any development must be considered in the context of paragraph 74 of the NPPF and Sport England’s Playing Field Policy. Sport England concluded that it objects the proposal because the proposed development is not considered to accord with any of the exceptions in Sport England’s playing fields policy. Summary 20 Whilst the provision of additional educational facility to meet the pressing needs in school places is strongly supported; the loss of playing fields is a concern. Therefore, further discussion is recommended with Sport England on how to address the concern.

Urban design 21 The two KS2 buildings are two-storeys, whilst the Halls building is a single storey, but is slightly higher than average single story as it needs to accommodate PE curriculum.

22 A restrained palette of red brick is proposed to match and complement the existing brick palette of the secondary school and the surrounding residential buildings. In keeping with the existing secondary school buildings, the roof of the new buildings is flat with a parapet which articulates the simplicity of the layout while keeping the roof line lower than a pitch roof would be. This scale also suits the local residential roof heights envelope. 23 As a result, the scheme does not raise strategic design concerns. Inclusive design and access 24 The design and access statement states that the new buildings have been designed to comply with Part M of the Building Regulations and The Equality Act 2010. All new entrances/exits are provided with level threshold. Each separate building is provided with a platform lift and any level changes internally or externally is negotiated with ramps in accordance with Part M guidance or a step-free rather than a ramp. The inclusion of enlarged ambulant WC cubicles in each toilet block allows for gender specific changing throughout the school. 25 The statement demonstrates that for the hearing impaired, consideration has been made with regards to the teaching environment. For the classrooms and the larger group rooms acoustic panels have been added to the design to aid those with hearing difficulties. With regards to visual impairments, there will be full compliance with Part M of the building regulations. Induction Loops are included in the SEN Group Room and Halls. 26 The statement states two disabled parking bays may be provided close to the visitor’s entrance, these are accessed from East Lane then through the shared entrance footpath. All entrance thresholds are level for ease of entry into the building. This is welcomed, however the provision of the two disabled parking bays should be confirmed. 27 To summarise, whilst the above proposals are welcomed and should be secured through conditions, further details are needed of the lifts proposed. Platform lifts are not usually considered to be in accordance with London Plan Policy 7.2 An inclusive environment. Sustainable development/energy 28 Energy efficiency standards: The development is estimated to achieve a reduction of 8 tonnes per annum (10.8%) in regulated CO2 emissions compared to a 2010 Building Regulations compliant development (see the table below).

page 4 29 District heating: 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. The applicant should commit to installing a site heat network and consider opportunities for connection to nearby buildings and that all proposed buildings will be connected to the site heat network. A drawing showing the route of the heat network linking all buildings on the site should be provided. The site heat network should be supplied from a single energy centre. Further information on the floor area and location of the energy centre should be provided. 30 Combined Heat and Power (CHP): Due to the intermittent nature of the heat load, CHP is not proposed. The applicant should provide monthly energy load profiles for the proposed development to justify this argument. It should also be clarified whether the school facilities are likely to be used outside of standard school hours. 31 Renewable energy technologies: Solar photovoltaic (PV) is to be installed on the roof of the buildings. Clarification is required on the amount of PV proposed as the Energy Strategy Report states 175sqm in section 7.1, but 159sqm in section 8. A roof plan should be provided identifying the location of the proposed PV. A reduction in regulated CO2 emissions of 11 tonnes per annum (16%) will be achieved through this third element of the energy hierarchy (see the table below).

32 The table below shows the residual CO2 emissions after each stage of the energy hierarchy and the CO2 emission reductions at each stage of the energy hierarchy.

Table: CO2 emission reductions from application of the energy hierarchy

Total residual regulated Regulated CO2 CO2 emissions emissions reductions (tonnes per annum) (tonnes per annum) (%) Baseline i.e. 2010 Building Regulations 74.3 Energy Efficiency 66.2 8 11% CHP 66.2 0 0% Renewable energy 56 11 16% Total 19 25%

33 Overall a reduction of 19 tonnes of CO2 per year in regulated emissions compared to a 2010 Building Regulations compliant development is expected, equivalent to an overall saving of 25%. After addressing the comments above the applicant should revise and confirm the predicted carbon savings as the figures given in the summary tables in the Energy Strategy Report do not match the figures given in the tables in sections 4 and 5.

34 The CO2 savings fall short of the 40% target set within Policy 5.2 of the London Plan, which is applicable to this development as the referral is received by the GLA after the 1st of October 2013. The applicant should consider the scope for additional measures aimed at achieving further reductions. Transport for London’s comments

35 A shared staff car park consisting of 26 spaces is proposed at the existing car park location. TfL considers this provision acceptable however to ensure full compliance with London Plan policy 6.13 an additional three passive electrical vehicles charging points should be provided. 36 Cycle parking is proposed in accordance with the London Plan standards and equates to 79 spaces. However, the applicant should confirm their location to ensure that these spaces fully conform to London Plan policy 6.9. Confirmation is also required that all staff and pupils on site will have access to shower and changing facilities. 37 A multi-modal impact assessment has been provided however before TfL can consider the impact of this development on the public transport network and in accordance with London Plan

page 5 policy 6.3, the applicant should follow the recommendations included within TfL’s detailed comments issued to the Council on the 12 December 2013, particularly the peak time assessment and distribution. Depending on the outcome TfL might be seeking for s106 contribution towards bus capacity enhancement. 38 In accordance with London Plan policy 6.7 and TfL’s accessibility guidelines an assessment of the pair of bus stops located on East Lane is required. 39 A Pedestrian Environment Review System (PERS) audit of local desire lines should be undertaken and mitigation towards any subsequent identified improvements should be secured in accordance with London Plan policy 6.10. 40 Vehicular access for refuse, delivery or servicing purposes will be taken from the joint access with the college. TfL considers these arrangements satisfactory subject to a delivery and servicing plan (DSP) being provided. In line with London Plan policy 6.14, a construction and logistics plan (CLP) will also be required. Both documents should be secured by condition and submitted to the Council for approval. 41 A school travel plan is required and should be provided to both TfL and Brent Council for assessment. Once approved and considered acceptable, it should be secured, enforced, monitored, reviewed and ensure the funding of the travel plan through appropriate legal agreement to ensure conformity with London Plan policy 6.3. 42 Considering the proposal is for educational use the Mayoral CIL would not be applicable in this instance. Local planning authority’s position 43 Brent Council planning officers have yet to confirm their position. Legal considerations 44 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 45 There are no financial considerations at this stage. Conclusion 46 London Plan policies on educational needs, playing fields, design, inclusive access, sustainable development/energy, and transport are relevant to this application. 47 Whilst the application is broadly acceptable in strategic planning terms, on balance, it does not fully comply with the London Plan. The following changes might, however, remedy the above- mentioned deficiencies, and could possibly lead to the application becoming compliant with the London Plan:  Education use: Whilst the provision of educational facilities is strongly supported, the loss of playing fields needs to be addressed.  Design: The proposal does not raise strategic design concerns.

page 6  Access: The proposed measures should be secured through conditions. Further details are required in regard to the proposed platform lifts and disabled parking spaces.  Sustainable development/energy: The applicant should revise and confirm the predicted carbon savings. Other concerns detailed in the energy section of this report should be addressed.  Transport: A number of concerns are highlighted in regard to the impact assessment, electrical vehicle charging points, local bus stop and pedestrian environment condition and finally the lack of a school travel plan. These matters should be resolved before the application can be deemed to be acceptable in strategic transport 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] Tefera Tibebe, Case Officer 020 7983 4312 email: [email protected]

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