planning report PDU/2968a/01 27 February 2013 The former Dairy Crest site, Yiewsley in the Borough of planning application no.45200/APP/2012/3082

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

The proposal A residential-led, comprehensive redevelopment of the site, including the former Dairy Crest Depot, Padcroft Works Globe House and Globe Court, and the erection of three main buildings (part 9, part 7 and part 5-storey) to provide 241 residential units; approximately 190sq.m. of floor space for uses within class D1 (non-residential institutions); and 64sq.m. of space for uses within class A1 (retail/food and drink); together with associated public and private amenity space, hard and soft landscaping, lower ground floor parking for vehicles and bicycles; and alterations to No.9 High Street to form a new pedestrian route. The applicant The applicant is Kitewood Estates Ltd and the architects are Rolfe Judd.

Strategic issues A disused industrial enclave set within Yiewsley/ town centre. The principal issues are the loss of industrial land; town centre policy; land use and the principle of a residential- led development; its design and appearance in the townscape; together with details of the density, quality, unit size and mix of housing; the proportion of affordable housing; transport and energy provisions.

Recommendation That Hillingdon Council be advised that while the application is generally acceptable in strategic planning terms, it does not comply fully with the for the reasons set out in paragraph 86 of this report, but that the potential remedies also set out in that paragraph could address those deficiencies.

Context

1 On 18 January 2013, the Mayor of London received documents from Hillingdon Council notifying him of a planning application of potential strategic importance to develop the above site for the above uses. Under the provisions of The Town & Country Planning (Mayor of London) Order 2008 the Mayor has until 1 March 2013 to provide the Council with a statement setting out

page 1 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 Categories 1A and 1C of the Schedule to the Order 2008:

1A: “Development which comprises or includes the provision of more than 150 houses, flats or houses and flats.”

1C: “Development which comprises or includes the erection of a building of the following description—(c) the building is more than 30 metres high and is outside the City of London.”

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

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

5 The grossly underused site is approximately 0.87 of a hectare in size, but presents an excellent opportunity for infill development by reason of its town centre (Yiewsley/West Drayton) location and good public transport accessibility.

6 The site is located north-east of the First line ( to Bristol) and is bounded on the north by a linear block of industrial workshops that abut the rear gardens of traditional terraced houses fronting onto Winnock Road; on the west by Tavistock Road and on the east by Bentinck Road. The southern boundary is marked by a parade of shops beneath two storeys of residential and some office accommodation that front onto High Street. (See map 1 below).

Map 1: Location map of the back land site in the town centre. Source: Rolfe Judd Design & Access Statement.

page 2 7 The West Drayton national rail and proposed station is a short (200m) walking distance to the south, on the opposite side of Yiewsley High Street and is well-served by buses. It will further benefit from Crossrail upon the opening of that line in 2019. Five bus routes operate via West Drayton station (the 222, 350, U1, U3 and U5) and as such the site has an average public transport accessibility level (PTAL) of 3, on a scale from 1 (very poor) to 6 (excellent). A small part of the site closest to the station will see an increase in PTAL to 4 (representing good accessibility) following the introduction of Crossrail.

8 The High Street, Tavistock Road, Winnock Road and Bentinck Road are all roads for which the London Borough of Hillingdon is the highway authority. The A4 Bath Road, located approximately 3km to the south of the site, is the nearest part of the Transport for London Road Network (TLRN). The nearest part of the Strategic Road Network (SRN) is the A4020 Road, approximately 3.5km to the north-east.

9 The application site is presently occupied by low-rise industrial units, including the former Dairy Crest depot; most of which have reached the end of their useful life.

10 The surrounding area comprises a mixture of retail uses along both sides of the High Street; some industrial/commercial uses and extensive areas of residential and open space.

Details of the proposal

11 The development would entail demolition of all buildings within the application boundary shown on map 1 above and the construction of:

 Three main blocks, each split into sub-blocks.

 241 one, two and three-bed room apartments.

 254 sq.m. of retail and community space (comprising 190 sq.m. community/class D1 space and 64 sq.m of retail /café space).

 Lower ground floor parking space for 185 vehicles and 282 bicycles.

 Alterations to form new pedestrian route.

 Landscaped public and private amenity space. Case history

12 In June 2012, GLA officers held a pre-application planning meeting with representatives of Kitewood Estates Ltd, for a redevelopment of the site, including the former Dairy Crest Depot, Padcroft Works and Globe House; to provide 260 market and affordable housing units, with 550sq.m. of commercial space, associated parking and external amenity space.

13 The principal differences between the pre-application scheme and these application proposals are a reduction in number of residential units from 260 to 241; and a significant reduction and change in the amount of non-residential space, from 550 sq.m. of predominantly retail/other commercial space to 254 sq.m. of space for community and retail uses.

14 In its written response to the pre-application scheme, GLA officers accepted that, in principle, the proposals were in line with the strategic objectives of London Plan policy 2.5 (Town Centres), which aim to coordinate the development of London’s network of town centres as the

page 3 main foci outside the Central Activities Zone for commercial development and intensification, including residential development. Hillingdon Council was, however, requested to ensure that the loss of potential employment floorspace would be acceptable locally. Strategic planning issues and relevant policies and guidance

15 The relevant issues and corresponding policies are as follows:

 Retail/town centre uses London Plan  Regeneration London Plan; the Mayor’s Economic Development Strategy  Mix of uses London Plan  Housing London Plan; Housing SPG; draft Revised Housing Strategy; Providing for Children and Young People’s Play and Informal Recreation SPG;  Affordable housing London Plan; Housing SPG; Housing Strategy; draft Revised Housing Strategy;  Density London Plan; Housing SPG;  Urban design London Plan  Access London Plan; Accessible London: achieving an inclusive environment SPG; Planning and Access for Disabled People: a good practice guide (ODPM)  Transport/parking London Plan; the Mayor’s Transport Strategy;  Crossrail London Plan; Mayoral Community Infrastructure Levy; Crossrail SPG  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

16 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 2012 Hillingdon Local Plan: Part 1- Strategic Policies: A Vision for 2026 (formerly known as the Core Strategy), and the 2011 London Plan.

17 The following are material planning considerations:  The National Planning Policy Framework and Technical Guide to the National Planning Policy Framework  The South Hillingdon Area Action Plan.

 The draft Revised Early Minor Alteration to the London Plan.

Land use policy and the principle of development

18 The site lies within the southern portion of Yiewsley/West Drayton town centre, which is classified as a ‘district centre’ in the London Plan town centre hierarchy (Annex 2); however, it has no specific land use designation within the plan. Policy 2.5 (Town Centres) states that the Mayor will and the boroughs and other stakeholders should coordinate the development of London’s network of town centres to become:

 The main foci outside the Central Activities Zone for commercial development and intensification, including residential development;

page 4  The structure for sustaining and improving a competitive choice of goods and services conveniently accessible by public transport cycling and walking; and  Together with local neighbourhoods, the main foci for most Londoners’ sense of place and local identity within the capital.

19 In particular, development proposals in town centres should, amongst other things, sustain and enhance the viability of that centre; accommodate economic and/or housing growth through intensification and selective expansion in appropriate locations; support and enhance the quality and diversity of town centre retail, leisure, arts and cultural, other consumer and public services; promote access by public transport, walking and cycling; and promote safety, security and lifetime neighbourhoods.

20 Hillingdon’s Local Plan (Part 1- Strategic Policies) was adopted in November 2012. Strategic objectives SO16, 18 and 20 of the plan looks to manage appropriate growth, viability and regeneration of town and neighbourhood centres; improve access to local services and facilities (including employment and training; local shopping, community, cultural, sport and leisure) particularly for those without a car; and improve facilities at bus and underground/rail interchanges to promote sustainable growth and accessibility to town centres such as West Drayton.

21 Policy E5 of the plan aims to diversify the future role of Hillingdon’s local centres and historic environment, access to public transport, affordable small office units and opportunities for social interaction. In particular, the policy proposes to allocate land for mixed-use employment, residential and transport-led regeneration schemes in Yiewsley/West Drayton and other centres.

22 To achieve its aims, the Council would accommodate additional retail growth in District Centres and promote uses appropriate to their size and location in accordance with the retail hierarchy. Local parades would be protected and managed to ensure they meet the needs of the local community and enhance the quality of life for local residents, especially those without access to a car.

23 The Council’s South Hillingdon Area Action Plan acknowledges that Yiewsley and West Drayton best illustrate the decline of town centres that followed the demise of traditional employment sector and a failure to maximise the opportunities offered by proximity to Airport, the and a relatively buoyant economy.

24 It is evident from the foregoing that whilst the strategic and emerging local policies support the principle of a residential development on the site, the development priority in town centre locations is to maintain their vitality and viability as a focus for retail, commercial community, leisure and cultural activities that are highly accessible by a variety of sustainable modes of transport.

25 Though the retention and protection of the existing parade of shops fronting the High Street is both welcome and in line with local policy aspirations, an increase in the proportion of ground floor space allocated to commercial or community uses (such as low-cost office/business, a doctor/dentist’s practice, a creche or community meeting hall) is positively encouraged, especially if the lack of frontage to the High Street deters potential occupation by retail operators. Hillingdon Council should ensure that the loss of potential employment floorspace is acceptable locally.

page 5 Housing issues

26 The London Plan has set a target for the delivery of a minimum 4,250 new dwellings in the borough of Hillingdon between 2011 and 2021. The proposal to construct 241 new dwellings on the site is a modest but welcome contribution towards that amount; representing as it does some 57% of the target for one year.

Density

27 Based on the net residential area of the site, the housing would be delivered at a density of 286 units (or 792 habitable rooms) per hectare, which significantly exceeds the upper limit (70- 170 units or 200-450 habitable rooms per hectare) of the London Plan indicative density range for a site in urban setting and a present public transport accessibility level of 3 (albeit, likely to increase to PTAL 4 once the West Drayton Crossrail service becomes operational).

28 A development of this density in the proposed location should, however, be acceptable if the detailed design of the scheme is exemplary and the living environment does not exhibit any of the typical indicators of an overdevelopment. An assessment and conclusion on this is provided in subsequent paragraphs of this report, particularly in the housing quality and design sections. Given the 2019 arrival of Crossrail at the nearby station, increasing density at this site is justified.

Housing quality

29 London Plan Policy 3.5 promotes quality in new housing provision and sets out minimum space standards at Table 3.3. The Mayor has produced a new Housing SPG (November 2012) on the implementation of Policy 3.5 for all housing tenures, drawing on his London Housing Design Guide. Paragraphs 3.37–3.39 provide further guidance on the indicators of quality covered by the SPG.

30 Assessed against the space standards, the proposed housing compares as shown in the following table:

apartment type GLA minimum size: proposed difference gross internal area development (sq.m) (sq.m.) 1 bedroom (2 person) 50 50-71.6 0 to + 21.6 2 bedroom (3-4person) 61-70 52.4-109 -8.6 to + 48 3 bedroom (4-5person) 74-86 74.1-99 0 to + 25

31 As the table shows, the development offers a wide range of unit sizes for each type apartment proposed. Although the development is broadly compliant with the internal space standards set out in the London Plan, a pair of two-bedroom apartments (E15 and E16) on the second floor of block E fall significantly (by 8.6 sq.m.) below the minimum 61 sq.m. required for occupation by three people. The applicant should reconfigure block E to ensure that the relevant units meet the minimum sizes required.

32 The proposed layout of the buildings results in some single-aspect units and irregularly- shaped rooms throughout the development. The residential accommodation would be served by a maximum of nine units per core, which is marginally above the maximum of eight recommended in the London Housing Design Guide; however, the number of units per core is progressively reduced in other parts of the development, with the core for the smallest floorplate serving only three flats. Further comments on this, relative to the orientation of the buildings, are provided in the design section of this report.

page 6 33 The applicant has indicated that the all dwellings would be built to Lifetime Homes standards, with 10% of the total designed to be wheelchair accessible or capable of easy adaptation without radical alteration to the layout.

Affordable housing

34 London Plan Policy 3.12 requires borough councils to seek the maximum reasonable amount of affordable housing when negotiating on individual private residential and mixed-use schemes. In doing so each council should have regard to its own overall target for the amount of affordable housing provision. This target should take account of the requirements of London Plan Policy 3.11, which include the strategic target that 60% of new affordable housing should be for social rent and 40% for intermediate rent or sale. The Mayor has published an early minor alteration to the London Plan to address the introduction of affordable rent, with further guidance set out in a draft Affordable Rent SPG. With regard to tenure split the Mayor’s position is that both social rent and affordable rent should be included within the 60%.

35 While the Mayor has set a strategic investment benchmark that across the affordable rent programme as a whole rents should average 65% of market rents, this is an average investment output benchmark for this spending round and not a planning policy target to be applied to negotiations on individual schemes.

36 Policy 3.12 is supported by paragraph 3.71, which urges borough councils to take account of economic viability when estimating the appropriate amount of affordable provision. The ‘Three Dragons’ development control toolkit or other recognised appraisal methodology is recommended for this purpose. The results of a toolkit appraisal might need to be independently verified. Paragraph 3.75 highlights the potential need for re-appraising the viability of schemes prior to implementation.

37 The supporting text for policy H2 of the Hillingdon Local Plan provides that (i) subject to viability and if appropriate in all the circumstances, 35% of all new units should be delivered as affordable housing, with a tenure mix of 70% housing for social rent and 30% intermediate housing; and (ii) that the affordable housing mix reflects housing needs in the borough, particularly the need for larger social rented family units.

38 In this instance, the development would include 34 affordable housing units, representing 14% of the total number of units or 16% of the total habitable rooms. It is also proposed that 15 of those units should be allocated for affordable renting and the remaining 19 available for intermediate tenure as Newbuild Homebuy. The affordable rents are assumed at 70% of the benchmark rents for the borough, whilst the Newbuild Homebuy units would be sold with an equity share of 40% and rent charged at 2.5% of the unsold equity.

39 The developer has submitted a financial viability appraisal alongside the application, based on the ‘Three Dragons’ toolkit, to justify the affordable housing contribution in this case. The assumptions used in the appraisal include build costs lower than that for similar schemes in Hillingdon; developers’ profit at 16% and professional fees of 8%; all of which are below the toolkit default figure and the industry benchmarks for a flatted development in that location. A further amount has also been set aside to meet the community infrastructure levy (CIL) and other legal (section 106) obligations of the scheme.

40 With those costs balanced against the existing use values and modelling of the expected revenue from the commercial elements of the scheme, the appraisal demonstrates that in its proposed form, the development has a residual value that is significantly below that of the existing use value for the site. The developer is nonetheless prepared to proceed with the scheme on that

page 7 basis and a conclusion that the suggested level of affordable housing is the absolute maximum amount that can be offered in the prevailing circumstances. The Council is however urged to commission an independent appraisal of the developer’s submission and share the results with the GLA prior to or as part any further referral of this application to the Mayor of London.

Housing choice

41 London Plan Policy 3.8 and the associated supplementary planning guidance promote housing choice and seek a balanced mix of unit sizes in new developments. The revised London Housing Strategy sets out that 36% of affordable rented homes allocated funding in 2011-15 should have three or more bedrooms. Policy H2 of the Council’s Housing Market Assessment (HMA), which served as an evidence base for the Hillingdon Local Plan indicates that 70% of net need for affordable housing is for two and three-bedroom accommodation; more than a fifth is for four-bedroom accommodation, and almost 7% is for one bedroom accommodation. It adds that the need relative to supply is greatest for larger accommodation. Current estimates indicate that less than 10% of the need for four bedroom accommodation is expected to be met, compared with almost 75% of the need for one-bedroom accommodation..

42 The full breakdown and housing mix of the proposed development is illustrated in the following table:

Apartment type Affordable housing % Market housing Overall % - Affordable rented Newbuild Homebuy - - - 1 bedroom 2 5 3 74 81 34 2 bedroom 8 4 5 123 135 56 3 bedroom 5 10 6 10 25 10 total 15 19 14 207 241 100

43 There is no indication that the proposed scheme would benefit from a public subsidy, but the table above illustrates the low proportion of three bedroom units within the development. It may also be argued that the town centre location of the site is not conducive to family living. However, given evidence of the need for larger units across the borough, as reflected in the provisions of Council policy H2, any officer negotiations to secure a higher proportion of three or more bedroom units within this development would be supported in strategic planning terms. Children’s play space

44 Policy 3.6 of the London Plan sets out that “development proposals that include housing should make provision for play and informal recreation, based on the expected child population generated by the scheme and an assessment of future needs.” Using the methodology within the Mayor’s supplementary planning guidance ‘Providing for Children and Young People’s Play and Informal Recreation’ it is anticipated that there will be approximately 39 children within the development. The guidance sets a benchmark of 10 sq.m. of useable child playspace to be provided per child, with under-5 child playspace provided on-site. As such the development should make provision for 390sq.m. of playspace.

45 The development includes the provision of some 350sq.m. of designated and quantified doorstep play space for each of the blocks. These are suitable for use by the 21 resident children (54% of the total) under the age of five. (See map 2 below).

page 8

Map 2: Distribution and layout of children’s doorstep play space. (Source: Applicant’s Design & Access Statement).

46 Whilst there is a shortfall of 40sq.m. in provision on site for older children, the needs of that age group can be met off site by existing play areas within the maximum distances specified in the Children and Young People’s Playspace SPG i.e. 400 metres for children between 5-11 years old and 800 metres for children above age 12. This includes the Holly Gardens Park and Lantern Way green space totalling more than two hectares in size and situated south-east of and entirely within 400-800m radius of the site. Facilities include a kick-about area, football goalposts and open amenity areas.

47 A bowling green of more than 1 hectare is also situated due north-east, which straddles the 400m radius line and provides some play equipment, basketball court and bowling green.

48 Altogether, sufficient space would be provided or available to meet the play requirements of children of all age groups in line with policy 3.6 and the Mayor’s SPG on play space.

Urban design

49 The design of the proposed scheme was commented upon at pre-application stage, but has been modified significantly since then. The current proposal is generally welcomed, providing a good link and public space between Bentwick Road and Tavistock Road, whilst optimising the use of the site.

50 The overall height and massing is acceptable in strategic terms, as it creates a good level of enclosure and definition to the proposed space, without being out of proportion with the overall contextual height.

51 However, whilst the built form successfully encloses and defines the proposed space, there is concern that the ground floor units facing this space do not have their own individual entrances from the public realm. The London Housing Design Guide sets out that this is an important indicator of residential quality as it creates legible entrances, encourages a sense of ownership of the units and provides a good distribution of activity onto public spaces critical to making them feel safe, attractive and well used. The applicant is advised to modify the scheme so that all ground floor units facing on to the proposed space have their own individual entrances directly from the public realm.

page 9

View of central open space ( Source: Design & Access Statement)

52 The proposed development leaves a narrow site facing on to Tavistock Road that needs to be considered. The applicant is advised to illustrate how the site can be developed in relation to the proposed layout to ensure that it does not preclude it from being redeveloped as high quality scheme facing Tavistock Road.

Existing view onto Tavistock Road Proposed view onto Tavistock Road

53 The residential quality of the scheme is acceptable. The low number of units per core allows a high proportion of dual-aspect units, and north-facing single-aspect units are avoided. However, as set out above, ground floor units facing the public realm need to have their own individual entrances from the public realm.

54 The height and massing of the scheme will make it a very prominent building on the townscape, making its architectural treatment a priority. The current proposal suggests a mix of materials and a very articulated building mass the detailing of which could be challenging and potentially capable of undermining the overall elegance of the scheme and the longevity of the architectural ambition. The applicant is advised to minimise the palette of materials and avoid unnecessary articulation, focusing instead creating a simple building mass with elegant detailing and high quality materials.

page 10

Existing view from Yiewsley High Street

Proposed view from Yiewsley High Street Transport for London’s comments

55 It is proposed to provide 181 car parking spaces for the 242 proposed residential units, at a ratio of 0.75 spaces per unit. This provision reflects the good accessibility of the site, close to a new Crossrail station, is in line with the London Plan standards and with the provision agreed for recent residential applications elsewhere in the borough and located near to Crossrail stations.

56 Of the total parking provision, 25 spaces are to be designated for blue badge use, to provide one blue badge parking space for each accessible unit. Whilst this meets London Plan standards and is welcomed, those spaces should be designed to provide a 1.2m buffer zone at the rear. In addition, 37 spaces (20%) will be equipped with an active electric vehicle charging point, with a further 20% passive provision.

57 For the non-residential uses, the only parking provision will be four operational spaces; three linked to the proposed community (class D1) unit and a further space for site maintenance workers. One of the D1 spaces will also be marked out for blue badge use. The applicant also proposes to install a car club space on street on Bentinck Road by relocating an existing on-street parking bay. These measures are welcomed, and the application is considered to be compliant with London Plan Policy 6.13 Parking.

58 The transport assessment considers the net impact of the development, assuming that the existing uses on the site are fully occupied. However, it is understood that the existing buildings are currently empty, and the applicant should confirm for how long this has been the case. In line with TfL’s Transport Assessment Best Practice Guidance, if the site has been vacant for over a year then no allowance should be made for existing trips. Notwithstanding this, TfL has concerns with the methodology used for the trip generation exercise presented as explained in TfL’s detailed comments to Hillingdon council on 14 February 2013. Until this has been clarified, TfL is unable to comment on the likely impact of the proposals on the transport network.

59 A pedestrian audit has been carried out as part of the development proposals, and has identified some improvements that could be made both to the footways surrounding the site and local bus stops. Hillingdon Council should secure a sum of money as part of the Section 106

page 11 agreement to implement these suggested improvements in line with London Plan Policy 6.10 Walking.

60 266 cycle parking spaces are proposed for residents of the new development, with a further six visitor spaces, all located at basement level. Additionally, ten cycle parking spaces are proposed for the community use, also at basement level, with showers and lockers provided internally for staff. This provision is in line with London Plan standards and is welcomed. However, cycle parking at basement level may not be obvious to people who are not familiar with the site. As such, TfL would recommend providing the residential visitor parking and a portion of the community parking at ground floor level within the public realm so that it can be easily used by visitors to the development.

61 A travel plan has been submitted with the application and should be secured as part of the Section 106 agreement for the site. TfL considers that the plan contains all the fundamental information that is expected, although some minor revisions are recommended, as detailed in TfL’s direct response to the council.

62 The transport assessment states that a delivery and servicing plan will be produced for the site, and this is also welcomed. This should however be secured by condition on any consent. Similarly, measures to minimise the impact of construction should be dealt through a construction logistics plan, to be secured by an appropriate condition on any consent. This is required in order to comply with London Plan policy 6.3 (C).

63 London Plan Policy 6.5 and the associated Supplementary Planning Guidance (SPG) ‘Use of planning obligations in the funding of Crossrail’ (July 2010) set out the mechanism for contributions towards Crossrail. The SPG states that contributions should be sought in respect of proposals for uplifts in floorspace for office, retail and hotel uses close to proposed Crossrail stations where there is a cumulative uplift in such floorspace of more than 500sq.m. However, this application does not propose such an uplift and therefore does not require money to be secured under the SPG.

64 The Mayor of London introduced his Community Infrastructure Levy (CIL) on 1 April 2012. Most development that receives planning permission after this date will be liable to pay this CIL. The proposed development is in the London Borough of Hillingdon, where the charging rate is £35 per square metre of floorspace. Further details can be found at http://www.london.gov.uk/publication/mayoral-community-infrastructure-levy.

65 To summarise, consideration needs to be given to the approach taken to the trip generation of the existing uses on site. Some minor revisions to car and cycle parking and the travel plan are also required. Hillingdon Council should also look to secure improvements to the pedestrian environment around the site, as well as securing the travel plan, CLP and DSP before the application can be considered compliant with the transport policies of the London Plan. Energy provisions

Be Lean

Energy efficiency standards

66 A range of passive design features and demand reduction measures are proposed to reduce the CO2 emissions of the proposed development. Both air permeability and heat loss parameters will be improved beyond the minimum backstop values required by building regulations. Other

page 12 features include high efficacy lighting and mechanical ventilation with heat recovery (MVHR).The demand for cooling will be minimised through façade design.

67 The development is estimated to achieve a reduction of 15 tonnes per annum (6%) in regulated CO2 emissions compared to a 2010 Building Regulations compliant development, as shown in the table below.

Be Clean

District heating

68 The applicant has carried out an investigation and there are no existing or planned district heating networks within the vicinity of the proposed development. The applicant should, however, provide a commitment to ensuring that the development is designed to allow future connection to a district heating network should one become available.

69 The applicant proposes to install a site heat network. However, the applicant should confirm that all apartments and non-domestic building uses 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.

70 The applicant should confirm that the site heat network will be supplied from a single energy centre. Further information on the floor area and location of the energy centre should be provided.

Combined heat and power

71 The applicant proposes to install a 50 kWe gas-fired combined heat and power (CHP) unit as the lead heat source for the site heat network. The CHP is sized to provide the domestic hot water load, as well as a proportion of the space heating. A reduction in regulated CO2 emissions of 56 tonnes per annum (22%) will be achieved through this second part of the energy hierarchy (see table below).

Be Green

Renewable energy technologies

72 The applicant has investigated the feasibility of a range of renewable energy technologies and is proposing to install 60 sq.m. of solar photovoltaic (PV) panels at roof level of the tallest part of the buildings. The applicant should provide a drawing of the proposed layout of the panels.

73 A reduction in regulated CO2 emissions of 3 tonnes per annum (2%) will be achieved through this third element of the energy hierarchy (see table below).

Overall carbon dioxide savings

74 Based on the submitted energy assessment, 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.

page 13

T Total residual regulated Regulated CO2 emissions CO2 emissions reductions Baseline (i.e. 2010 (tonnes per annum) (t tonnes per (per cent) Building Regulations) annum) Energy Efficiency 270 CHP 255 15 6 Renewable energy 199 56 22 Total 196 3 2 74 27

75 A reduction of 74 tonnes of CO2 per year in regulated emissions compared to a 2010 Building Regulations compliant development is expected, equivalent to an overall saving of 27%.

76 The CO2 savings exceed the targets set out within Policy 5.2 of the London Plan. Other sustainability issues

77 Developments are also required to be adaptable to the climate London will experience over their lifetime and should be designed for the warmer, wetter winters and hotter, drier summers and to withstand possible natural hazards (such as heatwaves, flooding and droughts) that may occur. Chapter 5 of the London Plan considers climate change adaptation, specifically policies 5.9 through to policy 5.15.

Flood risk

78 The nearest water course is the Grand Union Canal, which runs in a north-south direction, a short distance east of the application site.

79 The application was accompanied by a flood risk assessment report. The report indicates that with the exception of a small portion at the northern end of the site, which lies in the low risk flood zone 1 on the Environment Agency flood risk map, the majority of the site falls within zone 2; with the probability of flooding from fluvial sources calculated at between 1 in 100 and 1 in 1000. The report proposes a range of measures to mitigate that risk.

Surface water run-off

80 The flood risk assessment proposes to reduce the surface water run-off by 56% by including 324cu.m. of surface water storage by utilising green roofs, podium deck storage, soft landscaping, permeable paving and modular storage.

81 This approach should be regarded as the minimum necessary to comply with the sustainable drainage hierarchy in London Plan policy 5.13 and the measures should be secured via an appropriate planning condition. Local planning authority’s position

82 The applicant has been engaged in pre-application consultations with officers of Hillingdon Council and has significantly revised the original proposals in response; however, it could not be ascertained at the time of writing when the application would be reported the Council’s planning committee or what the officers’ recommendation was likely to be.

page 14 Legal considerations

83 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

84 There are no financial considerations at this stage. Conclusion

85 London Plan policies on the loss of industrial land, land use and the principle of a residential-led scheme, details of the density, quality, unit size and mix of residential accommodation; the proportion of affordable housing, the design and impact on the townscape, transport issues; and the energy provisions of the scheme are relevant to this application. 86 The application complies with some of these policies but not with others, for the following reasons:  Loss of employment land: No specific land use designation in the London Plan or Hillingdon Local Plan, but proposal complies with the town centre and regeneration objectives of the London Plan and is therefore acceptable from a strategic planning perspective. Hillingdon Council should, nonetheless, ensure that the potential loss of employment premises is acceptable in terms of the borough’s supply of industrial land.

 Affordable housing: In light of the low proportion of affordable housing (14% by unit), the Council is urged to commission an independent and robust review of the applicant’s financial viability appraisal, in order to ascertain that the contribution proposed is indeed the maximum reasonable amount that can be provided without compromising the delivery of this scheme.

 Housing mix: Notwithstanding the town centre location of the site, the GLA encourages the Council to negotiate an uplift in the proportion of three-bedroom apartments, relative to one and two-bedroom units, unless the current mix of dwellings has previous been agreed with the applicant to reflect a specific local need.

 Design: To enhance the levels of legibility, activity, surveillance, security and a sense of ownership for the central space, whilst fulfilling the strategic objectives set out in the London Housing Design Guide, the applicant is requested to reconfigure the design of the ground floor units looking out onto the central amenity space to ensure that each has its own individual entrance directly from the public realm.

 Transport: For the purpose of assessing the net impact of the development, TfL requests the applicant to confirm if the existing buildings have been vacant for over a

page 15 year and do not therefore generate any trips; and to clarify the methodology used in the calculating trip generation (as outlined in TfL’s letter dated 14 February 2013). The Council should secure implementation of the submitted travel plan by legal agreement, section 106 funding to implement works arising from the pedestrian audit and impose planning conditions to secure submission of a construction logistics plan and a delivery and servicing plan, as set out in the TfL section of this report.

 Energy: Whilst the energy provisions are broadly compliant with the London Plan, the following additional details are required to ensure that submitted strategy is sufficiently robust: a written commitment to ensure that the development would be designed to allow future connection to a district heating network whenever one becomes available; a drawing showing the route of the heat network linking all buildings on the site; written confirmation that the site heat network will be supplied from a single energy centre, together with the floor area and location of the energy centre; and a drawing showing the location, layout and area of the proposed photovoltaic panels.

87 On balance, whilst the application is broadly acceptable in strategic planning terms, it does not comply fully with the London Plan.

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] David Blankson-Hemans, Senior Strategic Planner (Case officer) 020 7983 4268 email [email protected]

page 16