Report by: Borough Planning Officer Case Officer: frank.genna@.gov.uk (020 8583 4967) & Area Planning Committee 03 June 2004

1.0 LOCATION: 1.1 Land between Bridge, Kew Bridge Road and the (a.k.a. Scottish Widows land), Brentford, TW8.

2.0 PROPOSAL: 2.1 00607/ P/ P10 Proposed erection of a mixed use building varying in height from 3 storeys adjacent to the river and 5 storeys adjacent to the Wagon & Horses Pub - stepping up through 4, 5 and 6 storeys – and rise to an average height of 7 storeys along the Kew Bridge and Kew Bridge Road frontages. On the junction of these two roads the height would rise to 9 full storeys with an additional 1½ storey penthouse on top. The development comprises parking facilities at basement level, commercial uses (B1, A1 & A3) at ground floor level and 250 residential flats on floors 1-10.

2.2 00607/G/L2 (listed building application) Proposed demolition of single-storey disused toilet block attached to Kew Bridge.

2.3 Documents & Plans: Drawing / Document Title Number Revision Scale Location Plan 21910 (02)01 1:1250 Basement Plan 21910 (03)-1 B 1:200 Ground Floor Plan 21910 (03)00 B 1:200 First Floor Plan 21910 (03)01 B 1:200 Second Floor Plan 21910 (03)02 B 1:200 Third Floor Plan 21910 (03)03 B 1:200 Fourth Floor Plan 21910 (03)04 B 1:200 Fifth Floor Plan 21910 (03)05 B 1:200 Sixth Floor Plan 21910 (03)06 B 1:200 Seventh Floor Plan 21910 (03)07 B 1:200 Eighth Floor Plan 21910 (03)08 B 1:200 Ninth Floor Plan 21910 (03)09 B 1:200 Tenth Floor Plan 21910 (03)10 B 1:200

Sections Sheet 1 21910 (04)01 1:200 Sections Sheet 2 21910 (04)02 1:200 Sections Sheet 3 21910 (04)03 1:200

Elevations Sheet 1 21910 (05)01 B 1:200 Elevations Sheet 2 21910 (05)02 B 1:200 Elevations Sheet 3 21910 (05)03 B 1:200 Elevations Sheet 4 21910 (05)04 B 1:200 Elevations Sheet 5 21910 (05)05 B 1:200

Elevation Keyplan NA 1:300

B.Malyan Urban Design Doc NA Planning Statement PDA 02038 April 2003 EPDM Ecological Assessment 03010/Reports/R030401a April 2003 PCA Ltd Archaeology Evaluation KWB 03 Mar 2003 WSP Transport Assessment 11140184TA/Rev2 Rev2 (Apr 03) CG Geology Survey Report CG/1389/Rev1 Rev1 (Apr 03)

2.4 RECOMMENDATION That Members comment on this revised planning application and that their comments be reported to the June SDC Committee.

3.0 SITE DESCRIPTION 3.1 The site is known locally as both 'the Scottish Widows site' and 'the Kew Bridge site'. The application site is a vacant piece of land with an area of 0.73ha (1.80 acres) in total, bounded by Kew Bridge Rd to the north, Kew Bridge to the east, and by ‘The Hollows’ towpath and the Thames to the south

3.2 To the east, Kew Bridge is a Grade II listed building, containing the South Circular Road (A205), which merges with the A315 (Kew Bridge Road) at a traffic light- controlled junction to the north-east of the site. There are a number of lock-up arches under the Kew Bridge, which are currently occupied by a car repair business, furniture restoration company and scout group. Another arch is used for public access under the bridge adjacent to the river. The existing footpath along the River Thames is owned and controlled by the Port of Authority. The area to the east of Kew Bridge, bordering the river, was designated as the Strand-on-the-Green Conservation Area in 1968. Development within that neighbourhood consists of 2-3-storey terraces of residential properties. Fifty buildings and structures within the Strand-on-the-Green Conservation Area are listed, and the area is renowned for its panorama of picturesque Thameside views.

3.3 To the north, the surroundings are a mixture of residential and commercial, about 3-4 storeys high. Beyond the traffic lights adjacent to Kew Bridge Station, the South Circular Road becomes lined with various derelict shops – many of which are empty. Kew Bridge Station is a Grade II listed building. River House opposite the station is a substantial 8-storey building converted to residential use. Other buildings (Nos.56, 57, 58, 59 and 60) on the north side of the street have been identified as Buildings of Local Townscape Character. This area has been recently identified for inclusion in a new ‘Kew Bridge’ Conservation Area to complement Strand-on-the-Green Conservation Area and LB Richmond’s Conservation Areas across the Thames.

3.4 To the west, the scene is dominated by the Thameside Business Centre a complex of office buildings 4-5 storeys high with pitched roofs. Beyond lies the former BT Exchange converted into the residential ‘Regatta Point’ (6-storeys and penthouse). Appearing above these developments is the Grade I Kew Bridge Steam Museum stand-pipe campanile, and in the distance is the backdrop of the 22 storey high tower blocks at Green Dragon Lane. From the south bank of the river, and from Kew Bridge, these various buildings produce a vigorous and at times somewhat inharmonious landscape.

3.5 To the south lies ‘The Hollows’ footpath and the River Thames. This footpath winds down from Kew Bridge Road to follow the River Thames, eventually rejoining Kew Bridge Road just east of Victoria Steps and Waterman’s Park. There is also a link underneath Kew Bridge to complete a somewhat disjointed access to Strand-on-the- Green, past the complication of a slipway, which is also a public right of way. On the south bank are the tranquil approaches, via the towpath, to the borders of the World Heritage Site of . , with its large trees, is visible to the west. There are a number of large houseboats moored along The Hollows.

3.6 The site is an important and prominent landmark site on the River Thames, at the junction of the North and South Circular Roads and is the first major site travelling into the borough over Kew Bridge. Kew Bridge Station forms part of the SWT Hounslow Loop Line, with links to Waterloo, Clapham Junction, Hounslow, , etc. There are a number of bus routes, including Routes 237 (Hounslow to Shepherds Bush), 267 ( to ), 65 ( to Kingston via Richmond), 391 (Richmond to Hammersmith), N97 (London to Hounslow).

4.0 HISTORY 4.1 Historically important transport routes lie within the proposed conservation area: a Roman road; and the River Thames and one of its traditional ferry crossing points. Kew Bridge Rd, High Rd and the ferry are all shown on Rocque’s map of 1746. Lionel Rd South appears on the 1865 Ordnance Survey, suggesting it was developed with the railway. Kew Bridge was the site of a market until 1893, when the market moved to a purpose built site at what is now Brentford Fountain leisure centre. Kew Bridge had become a busy junction and there was no longer room for the market. However, the drinking fountain, the centrepiece of the market, remained until 1974, when it was moved to Western International Market in Feltham. The first Kew Bridge was completed in 1759. When the current bridge was opened in 1903 the King was given a mallet and trowel, parts of which were made from the old oak piles of the first bridge.

4.2 Planning permission was granted in 1989 subject to an s106 agreement for some 5,332m² (57,400ft²) of office floorspace in a single building to replace the demolished Kew Bridge House. The permission involved a six-storey building (18.4m high) with a three-storey element (15m high) fronting Kew Bridge Road. 122 parking spaces were proposed and the legal agreement secured financial contributions for improvements to the adjoining highways.

4. 3 (P1-P4) - Duplicate applications approved in 1991 subject to an s106 agreement for demolition of all existing buildings and structures and redevelopment to provide: two B1 office buildings, relocated public house and restaurant, boathouse, boat store and workshops, sea scouts accommodation, small craft workshop, improved pedestrian access with associated parking and vehicular access. (P5-P8) - Duplicate applications (two for Scheme A and two for Scheme B) for an almost identical development, which excluded the six northern, arches under the existing Kew Bridge were resolved to be approved subject to a Section 106 agreement in August 1992. Scheme ‘A’ Proposed some 11,000m² (119,404ft²) in 2 separate buildings. One building was proposed to front Kew Bridge Road on the corner with Kew Bridge with a second linked building in the centre of the site. The proposed buildings were both 4 commercial storeys in height (22m – equivalent to 6/7 residential storeys) reducing to three storey to the west and south of the site. Both buildings were to have pitched roofs with overhanging eaves and strong horizontal emphasis. The south-east corner of the site was to be dedicated as open space. With regard to 'Scheme B' the main difference was the relocation of the Wagon and Horses PH, which resulted in a slightly reduced amount of office floor space (3,472m² - 37,383ft²) for the building fronting Kew Bridge Road.

4.4 (P9) - Renewal of permission P8 for the demolition of all existing buildings and structures and comprehensive redevelopment for class B1 business public house/restaurant, boat house, car parking and access arrangements was approved in 1997. None of the approved schemes P1-P9 were ever implemented. In 2000, the Council noted an increase in interest in the site from developers. In order to guide the redevelopment of the site, the Council formulated a Planning Brief in 2001 to guide redevelopment of the site. A study of the local townscape and urban design potential of the site was also commissioned and subsequently attached as an appendix to the brief. The brief is summarised in 7.0

4.5 P10 and P11 were submitted in April 2003 as duplicate applications. Both proposed 263 flats in a horseshoe shaped building that ran to 5 storeys on the river, 8 storeys on Kew Bridge Road and Kew Bridge. It was considered that neither scheme satisfied the aims of the planning brief and amendments were sought. During this time, the applicants appealed against non-determination on P11. However, in order to facilitate ongoing amendments to the remaining P10 scheme, the applicants, together with the Council, agreed to put the P11 appeal into abeyance pending the resolution of an amended P10 scheme. Significant changes have been secured in the revised P10 proposal – the details of which are summarised in part 5.0 of this report.

5.0 DETAILS 5.1 Revisions to the application were submitted in October 2003 and further revisions submitted in March 2004 following feedback from the public meeting held in February. In both cases, full re-consultation was undertaken with consultees, residents, businesses, amenity groups and statutory consultees as detailed in section 6.

5.2 The development is 31.15m at its highest point on the corner of Kew Bridge/Kew Bridge Road, with one commercial ground floor storey, eight residential storeys and a double height penthouse on top. The building steps down to a maximum of three storeys nearest the river, in accordance with the adopted Planning Brief. Changes have been made to all elevations and the corner to create four distinct building façades that appear autonomous whilst still being part of the larger development.

5.3 The latest revisions have further reduced the scale and massing, particularly to the Kew Bridge Rd and riverside. There have been significant height and roofline adjustments to the Kew Bridge Road elevations to improve the relationship with the streetscene and properties on the north side of the road. Heights have been dropped from 8 floors to 5, 6 & 7 storeys and the top levels have been set back from the street. The elevation has been redesigned to reflect the pattern of terraces opposite.

Elevation Fronting Kew Bridge Road

5.4 The Kew Bridge frontage has been cut back and a large wedge of building has been deleted in order to create a public square. Treatment of the elevation has been improved to define the separate elements. The river frontage is improved with an increased set back of the development by 10.8m (originally 6m) to follow the building line of the Thameside Business Centre to create a substantial towpath boardwalk and a public square.

(See over for image)

Elevation Fronting Kew Bridge

5.5 The proposals comprise 1,940m² of commercial floorspace at ground floor (B1, A1 and A3) and a total of 250 residential flats on the upper floors. The proposed density equates to 549 habitable rooms per hectare. This total is made up of 150 private units and 100 affordable units – with 40% of the total number of units affordable and comprising a mix of 1 and 2 bedroom units. The proposals incorporate a 34m x 30m public square alongside the Bridge and the Thames, a 10m deep raised seating area adjacent to new restaurants and a widened and improved riverside path and boardwalk over a new wetland ecological area. The design of the boardwalk has been amended to overcome concerns about overshadowing of the wetlands habitat. In addition to the public spaces, the affordable and private housing elements will both feature balconies and green roofs with grassed areas for private recreation.

5.6 There are a total of 175 parking spaces within the basement car park together with secure cycle parking. Vehicular access for residents will be from Kew Bridge Road in a left in/left out arrangement. Service access will be from the Thameside Business Centre in accordance with the 1984 legal agreement attached to the original consent.

6.0 CONSULTATIONS 6.1 Several hundred properties, groups and organisations were consulted: Property Street 1-5 (cons) Bush Road, LB Richmond (LBR) 1-9 &21-24 (cons) Cambridge Cottages, LBR Capital Court Capital Interchange Way 1-4 (cons.) Carville House Carville Hall Park 525-551 (525A,B), (527A,B), (529A,C), (531A,B), Chiswick High Road (545A,B,C), 547A, (549A,B,C), 551A, 553-575 (odd), 650-654, Leisure Centre 27, Kings House, Kings Building, Great West Road 10, 14 Flats A-M, 15 Flats A-M, 1-88 (con) Green Dragon Lane Wickstead House, 1-88 (con) Fraser Hse, 1-88 (con) Cornish Hse, 1-88 (con) Harvey Hse, 1-88 (con) Maudsley Hse, 1-88 (con) Boulton Hse, 1-10 Titan Court, 1-6 Pegasus Court, 1-10 (con) Phoenix Court, 1-10 (con) Centaur Court, 2-9, 11- 30, 31-45, St.George Cmmty Centre 1, 1A, 2, 2A, 2B (3-26 cons.), 28 Hearne Road 1-16, 3 Public House, 3-5, 4-6 County House, 368 High Street, Brentford The Musical Museum, 400-403, 406, 407, 408, 410, 411 2, 1-12 (con), Priory Lodge, 1-12 (con), 12A, 14- Kew Bridge Court 33, 35-76 (odd) 1-5 (con) Thameside Centre, Parsons Hse, Kew Bridge Road Interchange Hse, 24,26, 41, 42-47(cons), 54- 61(cons), 38,47a,54a,55a,56a, 61a, 60a, 60b, KBS M'useum 57-85 (odd), Layton Hse, Royal Botanical Gdns , LBR 1-11 (cons) Kriesel Walk, LBR Units 1-6 Kew Bridge District Centre, 7-9 (cons.) Lionel Road South Kew Bridge District Centre, Old Coal Yard 2-12 (cons.) London Stile 1,3, 29-32 (con) Meade Close Green Dragon Junior and Infant School North Road St.Paul's Hall, 1-29 (odd) Pyrmont Road 1-39 (odd), 25A, 27A, 29A, Stile Hall Gardens 2-10 (con), 3A, 4A, 5A, 6A, 10A Stile Hall Parade

Property Street 2,Pier House,7-14(con) Magnolia Wharf, 20- Strand on the Green 24(con), 27 City Barge, 28-32,39- 45(con),47,49,50,52,53,53A,54-57(con)59- 61(con),63-72 (con), 70a,75,80,80a,b,c,81- 85(con),81a,82a,95-109(con),103A,1-4 The Moorings 1-23 (con) The Maltings, 4-12 (evens), 17-43 Spring Grove (odds) Ship Cottage, 1-11 (odd), 19a, 24, 24abc, 26, Thames Road 26abc, 28, 28a,b, 30a,b,c,d, 32a,b,c, 32-52 (evens), 53

Heron’s Rest, Linquenda, Shakira, Chilham, Houseboats @ The Hollows, Inmost, Induce, Cicconia, Sea Crest, Herons, River Thames, B’ford Legend, Wren, M.V.Jacana II, Vertrouen & Admiral Tromp (by hand), Ambulant, Grebe (post) 1-6 (cons) Thetis Terrace, LBR Bush, Catharina, Redder & 3 boats (names Victoria Steps, R. Thames, B’ford unknown) 1-34 (cons), 36-58 (evens), 58A Waldeck Road 68-110 (evens) Waterloo Place, LBR 1-7 (cons) Willow Cottages, LBR

Group/Body/Authority Group/Body/Authority Brentford Community Council English Heritage Met Police CPDA, Feltham Police Station Port of London Authority West London Health Estates Environment Agency LB Richmond upon Thames CABE LB Ealing Highways Agency Strand on the Green Residents Assoc BAA Green Dragon Lane Residents Assoc Network Rail (formerly Railtrack) Mayor of London @ GLA Barratts West London PDU @ GLA Ancient Monuments The Georgian Group Council for British Archaeology Soc. for Protection of Ancient Buildings The Victorian Society Royal Comm of Historical Monuments

6.2 Following advertisement in the local press, notices around the site and consultation letters, representations and petitions were received from individual residents and businesses, local groups and amenity bodies in respect of the original plans submitted in April 2003. Some people supported the principle of redeveloping the site after years of dereliction, but the majority objected to the height, and mass of the then proposed building. Amendments were made to the scheme in late October 2003 and presented to residents at a public meeting in early February 2004. At this meeting, concerns in respect of the development were re-iterated by residents and traders, but the height of the Kew Bridge Road elevation stood out as significant point of concern to nearby residents. Following the public meeting, the Council successfully negotiated major changes to the height of the development and revised plans were submitted in March 2004 - as detailed in section 5. The public have been consulted on the latest changes and comments are anticipated. Any comments received by the date of the meeting will be reported.

6.3 Representations have also been received from 5 residents’ groups: The Kew Society, Westerly Ware Association (Willow Cottages & Thetis Terrace), Strand on the Green, Green Dragon Residents and Brentford Community Council. Together, these groups state that they represent over 1000 households. Objections from residents, traders and these groups covered: Comment Response 1 The development is too high on 1 The development has been amended to the corner and all other comply with the heights stated in the brief. elevations 2 Little regard for surrounding 2 The development has an interesting skyline, heights or architectural styles has been broken up into smaller elevations and the design is considered complementary. 3 The development is too tall on 3 The heights of this elevation have been the Kew Bridge Rd elevation dropped significantly and new shadow tests and overshadows flats confirm that the impact throughout the year opposite. will be negligible. 4 The development is large and 4 The elevations are broken up with different cumbersome and fails to have architectural treatments to help the elements regard for surrounding plot read as individual segments rather than one sizes or buildings whole. 5 The density is too high for this 5 Sufficient parking, amenity and internal location and too many people space provided. Site has good public will be forced on to the site with transport. Density considered appropriate for poor amenities and little this major site. parking. 6 The commercial units will 6 The mixture of commercial uses will compete with and destroy local comprise B1, A1 a& A3 operations which will trade. The businesses within befit the riverside location and create a new the archways may suffer as a leisure destination for local residents. result. Commercial competition is not a material planning consideration. 7 Access to the riverside should 7 A s106 legal agreement will secure this. be improved and public access to the ‘public’ square must be secured. 8 The developer should provide 8 40% is a significant achievement for the the highest possible affordable borough. The height limits imposed by the housing figure to accommodate brief limit the potential to increase this. Key Workers. 9 Brentford Fountain should be 9 This has been explored but the cost and risk returned to this, its original of damage to the listed structure are too home to act as a high. sentinel/landmark. 10 The development will flood 10 The development will not overburden local or local roads with cars, create strategic roads and residential parking gridlock and add more standards have been met on site. pollution.

Comment Response 11 The significance of the river 11 The development has been lowered to 3 should not be ignored and the storeys next to the river and stepped back development should be 7m from the riverside path. The path has lowered and stepped back from also been widened from 2m to 3/4m. the riverside.

12 The ecology of the inter-tidal 12 A new ecological wetland area is proposed foreshore should be beneath eh boardwalk and is supported by safeguarded and boat mooring the Environment Agency and the TLS. catered for. Indicative mooring is shown for the extant Admiral Tromp.

13 Developers have taken a 13 Major revisions to the height and mass of the lackadaisical approach to development have been secured and the consultation and ignored local Council has consulted three times through concerns the post with residents and held a public meeting.

6.4 English Heritage objected to the original April 2003 submission, but the Council also considered those plans to be inappropriate. Comments on the March 2004 plans have not yet been received, but the EH concerns largely related to the proximity of the development to the Listed Bridge and riverside. Their concerns about height conflict with the advice in the adopted brief – to which they did raise an objection – but only after the consultation period had expired. The height of the structure has been reduced on all elevations and the building moved away from the riverside. Once received, comments on the latest revisions will be reported to committee.

6.5 The case was presented to the IBAC Planning Committee in April 2004 for comment, but members decided to defer consideration of the case until the next meeting in June to allow for the responses to public consultation on the latest revisions to be incorporated into the report. The report was presented to the Chiswick Area Planning Committee in May 2004. A full up-to-date summary of the consultation responses to the latest amendments will be presented as an addendum to Members prior to the meeting.

7.0 POLICIES Unitary Development Plan 7.1 The site is designated in the Revised Deposit UDP (proposals map) as site M20. The UDP proposes ‘a mixed use of the site for business and community purposes, or mixed business and residential uses. Where residential uses are proposed, affordable housing should be provided in accordance with policy H.2.1.’ The site is also shown as being within the Brentford Regeneration Area and adjoins Metropolitan Open Land (River Thames) to the south. It is within the Thames Policy Area as set out in Strategic Planning Guidance for the River Thames (RPG3b 9b) and falls within the Hampton to Kew stretch of the Thames Landscape Strategy (TLS) objective area. ‘The Hollows’ footpath also forms part of the borough and London cycle network.

7.2 Any development should comply with the provisions of the Council's Adopted 2003 Unitary Development Plan. The policies of relevance are.

ADOPTED UDP (2003)

Env-B.1.1 All New Development H.4.2 Residential density Env-B.1.2 High Buildings Affecting H.4.4 Provision for child play in Sensitive Areas housing devts Env-B.1.3 High Buildings or Structures H.4.5 Associated facilities for in other areas residential devts Env-B.1.8 Access / facil’s for people with H.4.3 Residential mix disabilities Env-B.1.9 Safety and Security H.2.1 Affordable Housing Env-N.1.13 Protection of Open Space Env-N.1.11 Protection/Improvement Local Open Space Env-N.1.10 Provision of New Open Space C.5.4 Outdoor recreation Env P 1.8 Devt Proposals on or near Env-N.1.10 Provision of New Open contam land Space Env-B.2.1 Designation of Cons Areas T 1.1 The location of development Env-B.2.2 Conservation Areas T.1.2 Movement implications of devt Env-B.2.5 Development affecting the T 1.4 Car/cycle parking/servicing Setting of a Listed Building for devts Env-B.2.4 Demolition of Listed Bldgs T 4.5 On-street parking Env-B.2.8 Views And Landmarks T 2.3 Strategic/local cycle networks E.1.5 Devt Involving Loss of or T 2.4 Public Transport changes in empl. uses Infrastructure E.2.2 Mixed Uses T 2.1 Pedestrian Access E.2.4 Improvement of employment T 4.4 Road Safety premises E.3.1 Disabled Access IMP.1.1 Integrating land use & prov of transport E.4.1 Local Residents IMP.1.2 Reuse/Recycling of Urban Land & Bldngs E.4.2 Childcare facilities IMP.2.1 Brentford Regeneration Area H.1.1 Location of new housing IMP. 4.1 Primary locations for development economic devt H.4.1 Housing Standards and IMP.5.1 High Quality buildings and Guidelines Urban Design H.5.1 Housing for people with IMP.6.1 Planning Obligations disabilities ENV-N1 Public Open Space Deficiency

Adopted Planning and Urban Design Brief 7.3 A Planning and Urban Design Brief for the site was formally adopted as supplementary planning guidance in September 2001 following extensive public consultation. The Brief provides details to guide the development of the site, including form and scale, in accordance with its allocation for mixed-use development in the UDP.

7.4 FORM AND DESIGN - Whilst this important gateway site requires the provision of a landmark development, the brief makes it clear that this does not necessarily mean the inclusion of a tall building. Given the adjacent listed buildings and conservation areas, the form and design of any development on the site is of paramount importance. The site has three important frontages: one facing Kew Bridge Rd and the junction with the busy (north); one facing the rising flank of the listed Kew Bridge and Strand on the Green (east); and one facing the River Thames and Kew Gardens (south). Any development should enhance the views, architectural quality and relationship of the site with the three frontages. Any development should incorporate a high level of architectural quality, design and character appropriate to this busy riverside junction.

7.5 The development should cascade down towards the Thames, but not exceed 3 storeys in height along the Thames River. The development should be at its maximum height along the Kew Bridge Rd frontage and should not exceed the height of the adjoining buildings with a maximum of 8 storeys plus penthouse setback at its highest point. An interesting skyline will be an important feature of the development. The design and layout must have regard to the relationship of the site to the river and the views from the south bank. New views of the river from outside the site should be created. The development shall complement the character of listed and locally listed buildings – in particular the Kew Bridge Steam Museum tower. Similarly, the development shall preserve and enhance the adjoining conservation areas in both LB Hounslow and Richmond. There must be foot and cycle paths to which the public has access alongside the river together with riverside open spaces available to the public.

7.6 LAND USES - It is considered that the site should be developed comprehensively with a balanced mixed-use development incorporating the following: • B1 office development • Residential development (with affordable and key worker housing) • Public House • River Related Uses • Local open space

7.7 ACCESS, PARKING AND TRANSPORT - The developer will be expected to submit an Accessibility Study incorporating a TIA. This should detail the impact of the development on the surrounding transport network and access to the site by foot, cycle, public transport and other vehicles. Vehicular access should be from Kew Bridge Rd, away from the junction with Kew Bridge.

7.8 The development will be expected to provide improved conditions for pedestrians and cyclists. Pedestrian access to the river should be improved with opportunities for access across the site at various points through the development. In accordance with UDP policies, adequate and secure cycle parking should be provided for any new development. Off-site improvements in the vicinity of the site will also be sought. Developers will be encouraged to include initiatives to improve road, rail and river based public transport services in the vicinity of the site through investment in the local public transport network and infrastructure.

7.9 LANDFILL, CONTAMINATION & ARCHAEOLOGY - The site is within 200 metres of known landfill sites. Appropriate measures will need to be taken to identify and remove any contamination from previous users on the site. The development is also in an archaeological priority area. A written desktop assessment and a pre-determination assessment of the likely archaeological impact of development will be required to complete a planning application

7.10 SUPPLEMENTARY INFORMATION - Applications must be accompanied by an Urban Design Statement in accordance with the requirements of Strategic Planning Guidance for the River Thames (RPG3b); An accessibility study; An archaeological statement; Remediation measures relating to any potential contamination; An engineering survey of the waterway wall and proposed flood defence measures; and an Environmental Impact Assessment may be required.

7.11 PLANNING OBLIGATIONS - The Brief sets out a range of planning obligations that the Council may seek to secure as part of development where appropriate and applicable. This accords with UDP Policy IMP6.1 on Implementation of the Plan and other UDP policies and objectives. The most important planning benefits to be secured are: • the maximum reasonable proportion of permanently available on-site affordable housing for local people to be provided. • a financial contribution to public transport initiatives and improvements to rail and bus interchanges and infrastructures. • improvements to facilitate a better environment for pedestrians and cyclists; • improvements to the existing towpaths (to facilitate access for all (including those with disabilities, pushchairs, cyclists), and improved lighting, signing, etc; • creation of public riverside spaces and other improvements to townscape including landscaping, seating, signposting, lighting, public art etc.

7.12 DIVERSITY ISSUES - The development should provide parking for people with disabilities. It should also be designed to facilitate full access for disabled people including the landscaped open spaces in accordance with UDP Policies. Any residential units should include provision for people with disabilities. Particular attention should be paid to the location of disabled parking bays, access widths, level access and/or ramps, handrail heights and routes to doorways and entrances. The maximum reasonable proportion or permanently available affordable housing (50%) for key workers, families and local people, should be provided on-site. Residential development must include provision for people with disabilities.

7.13 PLANS AND APPENDICES - The Urban Design Plan summarises the seven urban design objectives outlined in the brief and the Objectives section of the Kew Bridge Site Urban Design Framework document produced by Aukett’s.

Conservation Areas

7.14 Within LB Hounslow: It is of particular importance that the site is developed in the context of the wider area, and in particular, the Conservation Areas surrounding the site. Strand on the Green Conservation Area was designated on 07.11.1968 with the main objective of preserving and/or enhancing the riverside character of the area and the setting of listed buildings. Development should be in keeping with the low-rise riverside character of the locality. The Kew Bridge Conservation Area currently being adopted by the Council to ensure development in this small but distinct area is high quality and has due regard for the special character and architecture of the area and grand (Kew Bridge on the river, The TW Campanile on the skyline) listed buildings. It is considered that the group of buildings dating from the 19th Century that front Kew Bridge form an interesting cluster, most of which are either Statutory listed or locally listed because of their individual architectural qualities. Kew Bridge documents a period in history when there was money to invest in industrial buildings. It is a historically important junction for at least three modes of transport. The road layout is particularly important, as it is a place where many roads meet creating vistas, focal points and landmark buildings. This is an importance entrance into the Borough that the Council would seek to preserve and enhance.

7.15 Within LB Richmond: The development would be visible from the towpath areas on the borders of two Conservation Areas ‘Kew Green’ and ‘Royal Botanical Gardens’ across the river in the Borough of Richmond upon Thames. Kew Green Conservation Area lies at the southern end of Kew Bridge and was designated on 14.01.1969, and extended in 1982 and 1988. The reasons for designation related to its character as an historic open space and the associated high quality C18th development and superior riverside environment. The Royal Botanical Gardens Conservation Area was designated on 29.01.1991 for its strong definition and extensive amount of open space, detailed landscaping and plant species from around the world. Reference was also made to the many high quality listed buildings within the site including . Kew Gardens was designated a World Heritage Site in 2003 not only for its unique gardens but also in recognition of its extensive flora archiving facilities.

Listed Buildings

7.16 Kew Bridge This bridge was opened on 20.05.1903 and designed by Sir John Wolfe Barry and Cuthbert Breveton, and is Grade II listed. It is comprised of three elliptical arches over the River Thames, with a series of smaller arches under long approaches. It is constructed of granite with rock faced rustic voussoirs and bracketed cornice below the parapet. This bridge replaced a bridge of 1789, which itself replaced a bridge with seven arches of 1759. Half of this bridge is in LB Richmond’s boundary.

7.17 Kew Bridge Pumping Station, Kew Bridge Road The pumping station was designed by William Anderson, for the Grand Junction Waterworks Company, to extract river water from the Thames. It started pumping in 1838. Kew is the oldest waterworks in the world containing its original steam pumping engines, and is the most complete early pumping station in Britain. For its early date and the completeness of the station, including the offices and gatehouse, it is the most important historic site of the water industry in the country. The front was damaged and rebuilt in 1918 after one of the first German bombing raids on London. The museum site comprises a mix of Grade I and II* listed buildings dating from 1837-1932. The number 2 Boilerhouse was built in the 1860s. The building was adapted to serve as a workshop in the 1950s and currently houses the museum shop, reception and offices. The principal Grade I & II* buildings, including the 196ft 1867 Standpipe tower have all been restored with the support of EH. Pevsner considers ‘the manometer of standpipe tower of 1867 by Alexander Fraser dominates the district at over 60m high topped by a cupola’.

Strategic Guidance for London & The London Plan

7.18 RPG3’s Key Objectives promote London's role as a World City; the maintaining and enhancing the competitiveness of business, ensuring sustainable development and improving the quality and attractiveness of London's urban environment. The London Plan promotes urban regeneration and provision of affordable housing in sustainable locations. It is seen as important to encourage high quality development at sites which can are served by public transport. Because of the strong public transport linkages, this site is identified in the Plan by the Mayor as being suitable for a high density mixed use development.

Strategic Guidance for the River Thames

7.19 Strategic Planning Guidance for the River Thames (RPG3b) sets out the Government's overall objectives for the river and a strategic framework for land use planning along its banks. The guidance states that new development should: • address the River as a frontage; • open up pedestrian access to the River; • create pedestrian routes, squares and open spaces along the river front; • promote and encourage public enjoyment of the riverside; and • be accompanied by design statements.

7.20 The Thames Landscape Strategy (Hampton to Kew section). The Thames is one of the most important natural and cultural assets of London. The Thames Landscape Strategy, launched in 1994, is a 100-year blueprint for the River Thames in west London. It contains almost 200 projects to co-ordinate river interests ranging from nature conservation and historic landscapes to recreation and education. Hounslow Council has adopted the TLS as Supplementary Planning Guidance.

Planning Policy Guidance 7.21 Government Planning Policy Guidance advice must also be considered. PPG1 identifies the importance of high quality design in achieving a rich and attractive development. PPG3 states that a more flexible view should be taken towards schemes re-using existing sites for residential developments within defined urban areas. PPG15 stresses that development within conservation areas should preserve and/or enhance the historic and architectural character of the area. PPG13 provides advice on how local authorities should integrate transport and land use planning as a means to reduce further dependence on use of the private car. Also relevant are the DTLR Circulars 11/95 (The Use of Conditions in Planning Permissions) and 1/97 (Planning Obligations). The Council’s SPG on Affordable Housing was adopted in April 2002. The By Design (DTLR 2000) document advises on urban design issues.

8.0 ASSESSMENT 8.1 The main issues surrounding the proposal are: a. Suitability of the site for development & principle of this proposal; b. Impact on Listed Buildings and character of the Conservation Area; c. Impact on surrounding buildings, environments and views; d. Impact of proposal on the highway and local parking arrangements; e. Appropriateness of Affordable Housing provision; f. Compliance with Amenity and Internal Space Standards; g. Impact on Archaeological Remains beneath the site; h. Impact on Riverside Ecology; and i. Potential of the development to secure planning obligations.

Suitability of the site for development & principle of this proposal. 8.2 The Adopted Planning Brief sets out the framework for a development that is considered suitable for this site. The brief is summarised in section 7. Government Guidance (PPG3) and UDP policies H.1.1 and H.3.3 on urban in-fill development and providing homes and businesses in established urban areas also support mixed use schemes. More importantly, the Council used the UDP and the Brief to identify this site as being suitable for mixed-use development. The proposal would provide housing, commercial floorspace and a large public square with improved access to the riverside on the same site and therefore accords with the brief. The principle of the development is acceptable. The GLA London Plan supports residential densities of 400-700hrh in urban areas for mixed-use sites with good public transport links. With 677 habitable rooms, the density is 549hrh. However, the site is smaller than other sites and the provision of the open space has had the effect of compacting the residential element - so any density figure will be higher. The higher number of studio units also add to this figure. The site is well served by many forms of public transport, 4 regular reliable bus routes; mainline rail services from Reading, Waterloo and stations in between; and , District and Silverlink Metro services are within a 5 minute bus ride/10 minute walk of the site (indicative figures), and as such it is an appropriate location for a high density scheme. An implication of high density is often overdevelopment, which manifests itself through overlooking, poor layouts, lack of parking and deficient amenity space. In this case: the parking provision satisfies UDP Policy; all amenity space is provided on site, with a surplus and a large public square; 40% of the units will be affordable; and the design and height of the building complements the surrounding buildings and respects rather than harms the riverside. The density of this development is considered appropriate for this major landmark/gateway site.

Impact on Listed Buildings and character of the Conservation Area. 8.3 The brief identifies a need for the redevelopment of this site to have regard for - through preservation and/or enhancement - the surrounding conservation areas and the setting and character of listed buildings. The brief states that any new building should be well designed and also complement the setting of the river. Many amendments have taken place to reduce the bulk and height of the proposal on the various elevations, to set it back from the river and away from the bridge and reduce the mass on the Kew Bridge Road frontage. The elevations have been broken down into smaller frames so that despite being a large development, there are at least four distinct building styles and elevational treatments that reduce the mass and scale of the whole development.

8.4 The revised layout of the open spaces accord with many of the fundamental urban design guidelines. Suitable conditioning of details can secure a scheme that has: • Character – A place with its own identity that promotes character in townscape. • Continuity & Enclosure – A place where public and private spaces are clearly distinguished. • Quality of the Public Realm – A place with attractive and successful outdoor areas • Ease of Movement – A place that is easy to get to and to move through. • Legibility – A place that has a clear image and is easy to understand. • Adaptability – A place that can change easily. • Diversity – A place with variety and choice.

Impact on surrounding buildings, environments and views. 8.4 The Planning brief suggests the maximum heights that any development should accord with. The March 2004 revised proposal generally satisfies these guidelines by: • proposing 5-7 storeys along Kew Bridge Road where Brief allows up to 8; • cascading gradually up from 3 floors on riverside in accordance with Brief; • setting back from the bridge and riverside to create a public square; and • rising up to a pinnacle feature on the corner of the junction to create a 9 storey landmark building with 1½ storey penthouse on top (10½ storeys proposed by developer) when the brief suggests 8 storeys plus a penthouse level (9½ storeys suggested in brief).

8.6 The design of each of the façades has been revised and elements accentuated to give each section a strong yet compatible identity with its neighbour and the surroundings:

Kew Bridge Road Elevation 8.6.1 In respect of the Kew Bridge Road Frontage, the elevation has been redesigned so that it now reflects the stagger and proportions of the staggered, terraced flats opposite. The end of the building nearest the Wagon & Horses pub steps down to the same height as the adjacent Thameside Business Centre, while the rest of the frontage now steps up gradually to its eventual height of 7 storeys, rather than earlier proposals which rose almost immediately to 7 and 8 floors. The Brief advised that heights along this road should not exceed 7 storeys. Following revisions only half of the elevation rises to 7 floors, with the remainder rising to 5 and 6 floors. With the revisions to the height taken since the public meeting, this elevation will cause much less overshadowing to residents in the flats opposite this elevation. Given the width of the road and the extent of public consultation involved in the creation and adoption of the brief, the height of this elevation is considered acceptable. The revisions to the height and appearance of the frontage is considered an improvement.

Corner Site 8.6.2 The brief stated that the development should be at its highest above this corner and that this corner should have a landmark quality. Although it was stressed that the term ‘landmark’ did not mean a tall building, the brief outlined that the development could rise to a maximum height of 8 storeys plus inset penthouse – effectively 9 or 9½ storeys depending on design. The scheme proposes a 10½ storey element (31.1m) on this corner – though the upper two floors are set back 4-5m from the rest of the elevation. The difference between commercial and residential ceiling heights was not specified in the brief and a scheme with a higher percentage of commercial floorspace would be significantly higher than this residential proposal. The proposal exceeds the brief by 1- 1½ storeys on this corner, but is set in at the highest two levels – therefore reducing the impact of the height and mass of the tallest part and meaning that on the corner, the building is only 9 storeys high.

8.6.3 The lower levels of the corner building have been fully redesigned to accentuate the commercial nature of the ground floor. The apparent height of this commercial element has been exaggerated by including the residential first floor behind a colonnade structure, and beneath the first layer of balconies. The colonnade itself emphasises the curved end, and the importance and public status of the façade when viewed from street level. The domestic storey-heights above have been disguised through use of alternating materials on balconies; a “structural frame” contains and reduces the amount of glazing. The proposals articulate this important gateway corner and create identities at both lower and upper levels, that will read from both up close to the building or from a distance. The design of this corner building accords with the aims of the brief and is considered an apt landmark for the entry to Brentford, Chiswick and Richmond.

Kew Bridge 8.6.4 Following the deletion of the large building block that ran almost down to the river in the original April 2003 scheme, it is only the appearance of this elevation that has changed slightly since October 2003. The height of the overall building has dropped by 1m as a result of the lowering of the commercial ground floor ceiling height. The buildings on this elevation have been broken into two separate block with a recess to help differentiate between the two. The appearance of these elevations are sympathetic to the setting of the listed bridge without succumbing to a pastiche design mould. The elevations give space and setting to the bridge and with the insertion of the public square help improve its setting and status. The design of the building is handled much more thoughtfully than some of the 1960/70s development in Strand on the Green closest to that side of the bridge. The view of the Steam Museum Campanile will not be totally lost from the riverside path, and views will still be possible of the highest part from along the road.

Riverside 8.6.5 The riverside element of the scheme has been completely redesigned from its original submission state. The deletion of the wing closest to the bridge opened up the development and created views of the bridge from the site and of the site from the bridge and river. Most importantly, the space was given over to a public square that would complement the commercial uses and riverside walk elements of the scheme. The removal of this building and widening of the road along side the bridge will satisfy the brief by creating new glimpses and views of the river for people emerging from the railway station and environs. The widening of the riverside path from 2m to 3 and 4m will make the route more accessible and safer for all users, and the creation of the wetlands habitat beneath the boardwalk section of the path will add to the riverside’s ecological role.

8.6.6 The portion of the development nearest the Thameside Business Centre has been set back approximately 7m following the public meeting and now lies level with that sites’ building line. The wetlands area has been extended accordingly. The building itself has changed significantly and is now set in a defined frame. Along with the 7m set back, the height of the building has been reduced from 4/5 storeys to 3. After steady and regular gaps of approximately 5m, the floors rise to 4, then five then 7 storeys when adjacent to the bulk of the Thameside Business Centre. The building’s proximity to the river is now far more sympathetic to the setting and scale of neighbouring buildings and the height and mass of the bridge.

Impact of proposal on the highway and local parking arrangements. 8.7 The proposed access and parking arrangements are being assessed by the Council and TfL. It would appear that subject to the implementation of a left in/left out turning arrangement for residential vehicles, the Council’s UDP policy requirements and TfL’s objectives of keeping pedestrians and traffic moving safely and freely will be met. The frequent and numerous bus services and rail services (Kew Bridge Station , & Acton Town ) that serve the area will supplement access options of private vehicle, foot and cycle. It is not envisaged by TfL that the proposed increase in numbers of vehicles using the new dwellings will have a negative impact on the safety and free flow of vehicles on the North/South Circular, Kew Bridge Road or local roads.

8.8 The scheme proposes 175 car parking spaces underground, together with a mix of secure cycle parking areas above and below ground, together with underground motorcycle parking. Spaces will be allocated through a permit system, and occupants of the affordable units will be eligible to apply for these if the eventual housing association adopts the scheme. The provision satisfies the Council’s Maximum UDP standards for residential parking. Whilst requiring up to 20 spaces, the commercial element has no parking provision. However, the site is well served by 4 major bus routes and the Hounslow-Waterloo loop line, and the nearest Tube stations are only a short walk/bus ride away. At this time, there is no recognised need for this provision, but if it is considered appropriate, a contribution towards consultation/implementation of a CPZ could be sought to offset any potential impact on surrounding streets. The correct landscape treatment and signage of shared surfaces will help create a safe environment for pedestrians and cyclists.

Appropriateness of Affordable Housing provision; 8.9 The designation of 40% of the proposed residential units as affordable and the mix of unit sizes has been assessed against the Council’s standards and the identified need within this part of the Borough. Because of the restrictions the Council has placed on the heights of the scheme, and the significant reductions in height and units since the public meeting, the developer has justified that they consider this to be the maximum reasonable proportion of units that can be provided on site. Although the mix would be a higher proportion of larger units, the Housing Department accepts that the mix represents a ‘best fit’ given the restrictions on this site. The number of affordable homes represents 40% of the total site. These units will be split between intermediate and social rented accommodation, and discussions have commenced with a Housing Association to implement the preferred tenant mix. The suitability of the mix, and appropriateness of the total number of proposed affordable units must be assessed in the light of the UDP and London Plan.

Compliance with Amenity and Internal Space Standards 8.10 The layout of the individual units is well thought out. Following the revisions to the window positions, the amounts of natural daylight received by the new habitable rooms have been improved. The general access arrangements and internal configurations of the flats are straightforward and comply with the Council’s Think Access Guidelines. All units satisfy the Council’s standards for internal space. Many of the apartments have balconies and both the private and affordable units will have access to landscaped and turfed roof gardens. There is a surplus of private amenity space provision within the development. The use of grassed green roofs on this scale would be a first for the borough and is an innovative and sustainable solution. The public open space will complement the commercial spaces on the ground floor and allow for a multitude of uses throughout the year.

Impact on Archaeological Remains beneath the site. 8.11 The site lies on the historically important former Roman Road, adjacent to the Thames foreshore where many of the ’s artefacts were discovered. Any development permitted will be required by condition to undertake preliminary excavation survey work prior to commencement.

Impact on Riverside Ecology 8.12 The impact of the development on the ecology of the tidal foreshore, which is, exposed twice a day, and the capability of the site to deal with high tides and 1-in-50 year floods must all be assessed. Initial comments from the Environment Agency indicate that there are no major concerns with the proposal and that they support the design of the boardwalk over the proposed wetland ecological area. The Thames Landscape Strategy have also been involved with discussion on this aspect and support the details. With regards to the flood storage capacity of the site, the open plan public square will allow overflow of high and flood tides when needed, but provide a versatile open recreational space without taking away capacity. Details of the square can be regulated by condition.

Potential of the development to secure planning obligations. 8.13 The proposal has the potential to provide for a Section 106 Legal Agreement to secure environmental improvements to this section of the riverside, conservation area, urban area, transport interchange through: • the maximum reasonable proportion of permanently available on-site affordable housing for local people to be provided. • a financial contribution to public transport initiatives and improvements to rail and bus interchanges and infrastructures. • improvements to facilitate a better environment for pedestrians and cyclists; • improvements to the existing towpaths (to facilitate access for all (including those with disabilities, pushchairs, cyclists), and improved lighting, signing, etc; • creation of public riverside spaces and other improvements to townscape including landscaping, seating, signposting, lighting, public art etc.

9.0 DIVERSITY ISSUES 9.1 Level access throughout is key. The developers have stated that they are committed to incorporating this element through the public and private spaces throughout the development. Conditions can be attached to any consent to control this aspect. Important areas of concern are internal living spaces and movement, level access to retail units, roof gardens, public spaces, retail units, car parking and the riverside path.