Land North of Westfield Shopping Centre, Ariel Way in the London Borough of Hammersmith & Fulham Planning Application No

planning report PDU/2826/01 2 November 2011 Land North of Westfield Shopping Centre, Ariel Way in the London Borough of Hammersmith & Fulham planning application no. 2011/02940/OUT

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

The proposal Outline application with all matters reserved for a mixed use retail-led scheme, consisting of additions and alterations to the existing Westfield London shopping centre and the erection of 6 new blocks ranging from 5-20 storeys, to provide retail, restaurant, cafe, office, community and leisure floorspace, along with up to 1,646 residential units, 1,479 car parking spaces, landscaping and public realm improvements.

The applicant The applicant is Westfield Shoppingtowns Limited, and the architect is Allies & Morrison.

Strategic issues The principle of development is in line with the draft White City OAPF and newly adopted LB Hammersmith & Fulham Core Strategy. The provision of retail is welcomed however further assessment of the impact is required. The density of the development is appropriate, and revisions to the mass and height following submission are an improvement over the current application.

The proposal raises concern over the limited amount and location of affordable housing, lack of private family sized housing and housing quality. The principle of a tall building is accepted, however the commitment to design quality must be secured.

The applicant must demonstrate how principles of inclusive access will be incorporated, for the retail, public realm, and residential uses. Further information and commitment to carbon reductions and sustainable drainage is required. Further discussions are required with regards to transport modelling, car parking and transport impact mitigation strategies.

Recommendation

That Hammersmith & Fulham Council be advised that the application does not comply with the London Plan, for the reasons set out in paragraph 181 of this report; but that the possible remedies set out in paragraph 183 of this report could address these deficiencies.

page 1 Context

1 On 26 September 2011 the Mayor of London received documents from Hammersmith & Fulham 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 4 November 2011 to provide the Council with a statement setting out whether he considers that the application complies with the London Plan, and his reasons for taking that view. The Mayor may also provide other comments. This report sets out information for the Mayor’s use in deciding what decision to make.

2 The application is referable under Categories 1A, 1B and 1C of the Schedule to the Order 2008:

 Category 1A. Development which comprises or includes the provision of more than 150 houses, flats, or houses and flats.

 Category 1B: Development which comprises or includes the erection of a building or buildings outside Central London and with a total floorspace of more than 15,000 square metres.

 Category 1C: Development which comprises or includes the erection of a building more than 30 metres high and outside the City of London

3 Once Hammersmith & Fulham 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 environmental information for the purposes of the Town and Country Planning (Environmental Impact Assessment) (England and Wales) Regulations 1999 has been taken into account in the consideration of this case.

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

6 The 9.4 hectare site is located in the London Borough of Hammersmith and Fulham, and within the White City Opportunity Area. The site is partially within and immediately adjacent to the Shepherd’s Bush town centre which is identified as a metropolitan centre in the London Plan.

7 The site is bound to the north and north-west by a viaduct for the Hammersmith & City London Underground line; to the east by the West London Overground Line and the West Cross Route (A3220); to the south by the Westfield London Shopping Centre; and to the west by Wood Lane (A219). The Royal Borough of Kensington and Chelsea is immediately to the east of the site, with the West Cross Route marking the borough boundary.

8 The site is split into two by Ariel Way which runs east-west across the site, from Wood Lane in the west to the access onto the elevated West Cross Route in the east.

9 The southern part of the site provides car park and servicing access to the existing shopping centre from both east and west, as well as access to the White City Bus Station and the Grade II listed DIMCO buildings, which provide a bus layover for London Buses as well as a substation for London Underground. All of these functions require an extensive road network that occupies a significant portion of the site.

page 2 10 To the north of Ariel Way the site is occupied by the White City Industrial Estate, which comprises several single-storey industrial and warehouse buildings, as well as a 7-storey office block called Network House. Beyond the Hammersmith & City Line to the north are industrial and warehouse buildings of 2-3 storeys. Beyond the dual carriageway of the West Cross Route to the east the landscape is varied, comprising a recently completed office development with several 8- storey buildings along the West Cross Route, recent 4-6 storey housing, and several 20-storey Council blocks. To the west of the site on Wood Lane is a multi-storey car park along with a terrace of 2-storey Victorian cottages.

11 The site is not in a conservation area, although the Wood Lane Conservation Area extends directly north and west of the site, beyond the Hammersmith & City Line viaduct. The conservation area includes the Grade II listed BBC Television Centre which lies to the northwest of the site.

12 The site is within easy walking distance of White City, Wood Lane and Shepherd’s Bush Underground stations, served by the Hammersmith and City Line and the Central Line, Shepherds Bush Overground station, together with two bus stations and numerous other bus stops. Public transport accessibility levels (PTAL) are recorded as very good with a range from 3 in the northeast corner to 6 (excellent) in the western parts of the proposed development.

Details of the proposal

13 The applicant is seeking outline permission with all matters reserved including means of access within the site, layout, scale, appearance, and landscaping. The application proposes the comprehensive redevelopment and regeneration of the site to provide a retail extension to the existing Westfield London shopping centre, 1,646 residential units, a leisure facility and community uses, 1,479 car parking spaces, areas of public realm and pedestrian routes through the site to provide connections to RBKC to the east as well as passive provision for connections north through the Hammersmith & City Line viaduct.

14 The overall quantum of uses proposed are as follows:

Use Maximum quantum (use class) (Gross External Area) Retail (A1, shops) 52,0891 sq.m. Retail (A3-A5, restaurants/cafes, hot food takeaways) 5,167 sq.m. Residential (C3) 1,646 units Community/Health/Cultural uses (D1) 1,600 sq.m. Offices (B1) 600 sq.m. Leisure (D2) 1,850 sq.m. Table 1: Quantum of uses proposed

15 This will be accommodated in six development plots (A-F). The proposed height parameters range from 4-20 storeys above ground, with some buildings connected to the 2-storey high podium that would be built over the roads and servicing infrastructure below. Ground floor frontages, whether above the podium or at ground level, would generally be active with retail, office and community uses, with mostly residential above. Car parking would be provided in a dedicated car park below the podium.

16 Plot A comprises an extension to the north elevation of the existing Westfield Centre, which is an 8-storey block with 2-3 storeys of housing above and set back. The lower floors will be an extension of the mall shopping from the Westfield Centre, with housing on upper floors.

page 3 A F C C B E D

Figure 1: The general disposition of uses. (Source: Allies & Morrison)

17 Plot B features an 8-storey perimeter block with 2-4 storey upper elements. The block will contain an anchor store, supermarket, other mall retail, and housing above. A bridge connects the retail uses in blocks A and B.

18 Plot C, which is closest to the West Cross Route, features three 11-storey blocks set back from the West Cross Route, interspersed with two 16-storey towers and one 20-storey tower. The rest of the plot contains an 8-storey perimeter block with 2-3 storey upper elements, and 6-storey blocks in the centre of the perimeter block. The block will feature retail and other active uses where it meets the podium or White City Green to the north, with residential uses in the rest of the block and along the West London Line frontage.

19 Plot D, which is closest to Wood Lane Station, is an 8-storey building with part-2, part-4 storey roof elements.

20 Plot E is an 8-storey residential block on Wood Lane to the west of the DIMCO building, with retail uses at ground floor.

21 Plot F is a 5-storey block with a 1-storey setback that is attached to the western façade of the Westfield Shopping Centre, with retail uses at ground floor and residential above.

22 The applicant proposes to plant a minimum of 150 new trees and retain five existing London Plane trees, as well as 17,000 sq.m. of soft landscaping. The scheme includes a 25-metre wide green space running along the Hammersmith & City Line viaduct, part of the wider ‘White City Green’ proposed in the White City OAPF to the north of the anchor store and residential blocks. A small square is proposed between plots B and D, and the fully pedestrianised podium level will feature landscaping around all blocks. The residential blocks will have communal amenity spaces on the roof of the base buildings.

23 The proposals provide a new east-west link from the West Cross Route to Wood Lane on axis with the BBC Television Centre, as well as several north-south routes from the shopping centre to the Hammersmith & City line viaduct.

24 To facilitate the development, the existing road network in the southern part of the site will be decked over to allow existing vehicular and servicing access routes to remain and to also serve the new development, with new floorspace provided at a podium level.

page 4

Figure 2: The public realm created by the podium. (Source: Allies & Morrison)

25 The application is supported by an Environmental Statement and Impact Assessment that require some parameters to be fixed as a ‘maximum’ for testing purposes. These parameters have been illustrated in parameters plans which have been submitted for approval. The details in the 17 parameters plans include development plot locations at ground and podium level, building lines, building heights, general areas of pedestrian routes and open spaces and land uses. Although the application seeks to reserve matters relating to access, the parameters plans include two fixed points of access from Wood Lane and the West Cross Route. Any planning permission at this stage would be limited by condition requiring reserved matters applications to adhere to the details set out in these parameter plans.

26 The applicant has also submitted Design Codes for each plot and the public realm, and provided an illustrative design within the Design and Access Statement, which shows one way in which the development could be brought forward within the above parameters. The applicant proposes that the application be subject to condition that any reserved matters applications be brought forward in accordance with the relevant Design Code. Case history

27 The applicant has engaged in formal pre-planning application meetings on energy, design and retail matters on 4, 18 and 24 August 2011. The applicant has also engaged regularly with GLA, TfL and Council officers from the earliest stage of scheme development from December 2010 and as key stakeholders in the development of the White City OAPF. Strategic planning issues and relevant policies and guidance

28 The relevant issues and corresponding policies are as follows:

 Regeneration London Plan; the Mayor’s Economic Development Strategy  Retail/town centre uses London Plan; PPG13, PPS4  Housing London Plan; PPS3; Housing SPG; Providing for Children and Young People’s Play and Informal Recreation SPG, Housing Strategy; Interim Housing SPG; Housing SPG EiP draft

page 5  Affordable housing London Plan; PPS3; Housing SPG, Housing Strategy; Interim Housing SPG; Housing SPG EiP draft  Density London Plan; PPS3; Housing SPG; Interim Housing SPG; Housing SPG EiP draft  Urban design London Plan; PPS1  Historic Environment London Plan; PPS5  Tall buildings/views London Plan; RPG3A, Revised View Management Framework SPG  Access London Plan; PPS1; Accessible London: achieving an inclusive environment SPG; Planning and Access for Disabled People: a good practice guide (ODPM)  Sustainable development London Plan; PPS1, PPS1 supplement; PPS3; PPG13; PPS22; draft PPS Planning for a Low Carbon Future in a Changing Climate; the Mayor’s Energy Strategy; Mayor’s draft Climate Change Mitigation and Adaptation Strategies; Mayor’s draft Water Strategy; Sustainable Design and Construction SPG  Biodiversity London Plan; the Mayor’s Biodiversity Strategy; PPS9; draft PPS Planning for a Natural and Healthy Environment  Transport London Plan; the Mayor’s Transport Strategy; PPG13; Land for Transport Functions SPG  Parking London Plan; the Mayor’s Transport Strategy; PPG13

29 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 2011 Hammersmith & Fulham Core Strategy and the 2011 London Plan.

30 The following are also relevant material considerations:  The Hammersmith & Fulham Development Management Policies Development Plan Document (Submission Stage).  The draft White City Opportunity Area Planning Framework (WCOAPF), which underwent consultation in April-May 2011. Land Use Principles and Regeneration

31 The London Plan identifies that the site lies in the west London sub-region (Policy 2.5), in Inner London (Policy 2.9) and in the White City Opportunity Area (Policy 2.13). Annex One of the London Plan sets out a minimum guideline for new housing of 5,000 homes and an indicative estimate of employment capacity of 10,000 jobs over the plan period 2011 – 2031. The London Plan identifies Shepherd’s Bush as a ‘Metropolitan Centre’. Policy 2.15 of the London Plan seeks to sustain and enhance the vitality and viability of such centres, through intensification of uses, including housing.

32 The strategic policy direction for the White City Opportunity Area states that: “There is potential for mixed density housing and a focal point for office development at and around the tube stations at White City and Wood Lane with other commercial, leisure, open space, education and retail uses of appropriate scale to support the local community. This will be facilitated by de- designation of the historic strategic industrial location complemented by provision for waste and other industrial functions in the Park Royal Opportunity Area. The scope to improve connectivity with the wider area should be explored and development should be related to improvements in public transport capacity. Housing-led intensification should support local regeneration, enable estate renewal and seek a mixed and balanced community. There may be scope to enhance

page 6 education and research capabilities in the area linked in particular to healthcare and bio- technology. Development should promote the vitality of the town centre, particularly in the Shepherd’s Bush market area, and complement the viability of other west and central London centres.”

33 The Hammersmith & Fulham Core Strategy identifies the application site as being within the White City Opportunity Area, which is subject to Strategic Policy WCOA. The strategic policy states that “Major leisure activities and major retail that cannot be located within the town centre may be appropriate north of Westfield on the edge of the existing town centre boundary." This matter is addressed in the ‘Retail’ section below.

34 The Core Strategy identifies three strategic sites within the Opportunity Area, one of which is Strategic Site WCOA 1 – White City East, which includes this site. It sets out that White City East “should be redeveloped for a mix of housing, employment and community uses, establishing a creative industries hub, primary school, major leisure facilities, and a local centre with supporting uses (e.g. local shopping, restaurants and community facilities).”

35 The Core Strategy also states that “There must be a comprehensive approach to the development of the area which provides high quality places for living and working that are well integrated with, and respect the setting of, the surrounding area;" and that "all separate sites must individually contribute proportionally to achievement of the objectives and policies for the area; and, to the overall provision of social and physical infrastructure, affordable housing, and any necessary improvements to the transport infrastructure that are together necessary to enable the area to be developed to its potential."

36 The Core Strategy also holds that development proposals for the site must deliver affordable housing that enables local estate regeneration. This matter is addressed in the ‘Housing’ section below.

37 The draft WCOAPF reflects the land use policies of the London Plan and Hammersmith & Fulham Core Strategy. It proposes the expansion of the Shepherds Bush Metropolitan town centre boundary to the Hammersmith & City line viaduct, and notes that proposals on this site should seek to improve permeability and connections to the Town Centre. The draft WCOAPF also identifies a need for a mix of uses, housing, leisure, social infrastructure, public realm and support for the establishment of a creative hub on this site.

38 This scheme proposes retail, housing, leisure, office and amenity space on the edge of the town centre and close to main public transport nodes, whilst improving connections to the town centre. The proposed land uses would be consistent with London Plan polices 2.9, 2.13, 6.2 and the draft WCOAPF. Retail

39 London Plan policy 2.15 sets out that development proposals in town centres should accommodate economic growth through intensification and selective expansion in appropriate locations, and should enhance the competitiveness, quality and diversity of town centre retail, leisure, arts, public and consumer services, but that any expansion should also be in scale with the centre. London Plan policy 4.7 establishes that development should be focused on sites on the edges of centres that are, or can be, well-integrated with the existing centre and public transport, if sites within the town centres are unavailable. It also notes that proposals for extensions to existing town centres will be subject to an assessment of impact.

page 7 40 The draft WCOAPF notes that extension of retail and town centre uses (especially major leisure) to the north of Westfield allowing for a gradual transition from the town centre and retail to more community, leisure and residential uses would support the commercial hub proposed in the draft OAPF and help improve the entire area. It also notes that retail and major leisure uses are well-suited to addressing the physical challenges of the site, but that any new retail development should be seen as distinct from the indoor mall environment of the existing Westfield centre and as an integrated part of the local area and would be subject to a Retail Impact Assessment.

41 A West London Joint Retail Needs Study (WLJRNS) was prepared for Ealing, Hounslow and Hammersmith & Fulham Councils in May 2010 and formed part of the Council’s evidence base for the Core Strategy as well as for the draft WCOAPF. The study projected a need for 41,400 sq.m. (gross) of further comparison retail floorspace in Shepherds Bush town centre to 2021, along with a need for 4,300 sq.m. of convenience floorspace. Whilst the Council’s Core Policy expects that any identified retail need should be provided primarily within the town centre, it does note that there may be physical scope for some additional retail to be located as part of a mix with substantial leisure facilities and residential as part of a development that would link the existing Westfield London with land to the north.

42 The applicant has proposed a level of retail floorspace that exceeds the projected need to 2021 for all of the town centre. Of the 52,081 sq.m. (gross) of class A1(retail) floorspace proposed, 48,072 sq.m. would be comparison retail floorspace and 4,009 sq.m. would be convenience retail floorspace. The scheme would also incorporate 5,167 sq.m. of class A3-A5 floorspace (restaurants and hot food takeaways). As a point of comparison, the existing Westfield London shopping mall currently provides for 106,264 sq.m. (gross lettable) class A1 floorspace, with permission for a further 20,468 sq.m. class A3 floorspace. This proposal represents a 50% increase in the existing mall.

43 The applicant has submitted a retail statement which among other things presents an analysis to demonstrate that the need identified in the WLJRNS could not be accommodated within the existing town centre, in order to justify the provision of the retail floorspace directly north of the town centre boundary. The statement also sets out that neighbouring centres would still all see growth of approximately 40-45% over the next ten years, even with this development likely taking between 0.7 and 3.7% of potential growth from them.

44 The majority of the comparison and supermarket retail would be provided in blocks A and B, with convenience and restaurant/café uses at ground level of almost the other blocks. The only retail proposed within the town centre would be at the base of block F, which would be attached to the western elevation of the existing mall. The appropriateness of this location for retail is at the moment unconvincing, given the lack of interest in occupying the retail spaces in this location as part of the existing centre, although this may well change as development of the wider White City Opportunity Area comes forward, which would generate additional footfall on Wood Lane.

45 The overall approach of increasing retail provision in this location is supported by the draft WCOAPF and should be the key to unlocking the wider development of the area, subject to further testing. The Council has commissioned an independent assessment of the retail statement to ensure that it meets all of the tests set out in PPS4 with regards to potential adverse impacts and the sequential approach for site location, which will allow the evaluation of the proposals in full and an assessment of whether any anticipated impacts could be acceptable. The applicant should further discuss this matter with the local authority and GLA officers and ensure that the proposal would be consistent with London Plan Policy 4.7 and the draft WCOAPF.

page 8 Housing

46 The application proposes a maximum development of 1,646 residential units. The proposed housing mix set out in the table below:

Affordable (Social Affordable Private Total Rented) (Intermediate) Studio - - 71 71 (4%)

1 bed 13 27 476 516 (31%)

2 bed 26 54 821 901 (55%)

3 bed 26 54 78 158 (10%)

Total 65 (4%) 135 (8%) 1446 (88%) 1646 Table 2: Proposed housing mix

47 Following submission, the applicant has undertaken a review of the proposals to respond to officer concerns relating to design, scale and mass, and has reduced the overall number of residential units by 124 to 1,522. The applicant will be re-submitting further information to illustrate these changes in the coming weeks, which will likely involve a change to the housing mix set out above.

Affordable housing

48 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 current and future requirements for affordable housing at local and regional levels, its own overall target for affordable housing provision, and the need to encourage rather than restrain residential development.

49 London Plan Policy 3.11 states that borough targets should take account of matters including current and future housing requirements, the strategic targets and priority accorded to affordable family housing, the need to promote mixed and balance communities, and the viability of future development, and that within those targets 60% of affordable housing should be for social rent, and 40% for intermediate rent or sale.

50 The affordable housing polices in the Council’s adopted Core Strategy include a borough- wide target for affordable housing of 40% of all additional dwellings. The Core Strategy sets out a preference that all additional affordable housing be intermediate and affordable rented housing unless a proportion of new social rented housing is necessary to enable proposals for the regeneration of council or housing association estates, or the replacement of unsatisfactory accommodation, particularly in accordance with policies for the regeneration areas set out in the Core Strategy. The latter is the case with the application site.

51 This site is identified as forming part of Strategic Site WCOA 1 – White City East, within the White City Opportunity Area. The Core Strategy states that approximately 25% of housing provided in WCOA Strategic Site 1 “should be social rented in sizes and types that enable local estate regeneration.”

52 The application proposes a total of 1,646 residential units of which 1,446 (88%) would be private and 200 (12%) would be affordable. Of the 200 proposed affordable housing units, the

page 9 applicant proposes 65 would be rented units (4%) and 135 intermediate units (8%), corresponding to a 40:60 split between rented and intermediate affordable accommodation.

53 The applicant has not specified whether the rented units would be affordable rent or social rent units, but notes that to date the Council has not put forward firm proposals requiring the relocation of estate residents and therefore has no apparent requirement for social rented units. The applicant has therefore not specified the nature of the rented accommodation, but has welcomed further discussion with the Council to agree a suitable provision.

54 The overall level of affordable housing falls well short of the targets set out in the London Plan and the Core Strategy, as does the proposed mix of affordable tenures. The applicant has not submitted a financial viability assessment to support the proposal. Consequently it is not possible at this stage to confirm whether the proposal would provide the maximum reasonable amount of affordable housing in accordance with London Plan Policy 3.12, or comment on the financial justifications for deviations from policy advanced by the applicant. The Council will be commissioning an independent assessment of the viability assessment which will allow the evaluation of the proposals in full.

55 The affordable housing is proposed to be delivered in Block C at the north-eastern corner of the development, accessed directly from ground level, and with no access to the amenity space on the podiums. The applicant has asserted that the proposed approach is necessary for management reasons, and to limit the potential for service charges to be levied on affordable housing residents.

56 This location is furthest from public transport, located opposite the West London Line and West Cross Route dual-carriageway road. The White City OAPF notes the new social rented housing should provide opportunities for those living in less than ideal environmental conditions on the estates, such as those living along a major dual-carriageway road, to move to a home in the new development. The positioning of all the affordable housing against another dual-carriageway road, with limited shared amenity space, is at odds with the aspiration set out in the OAPF to provide better quality housing for estate residents.

57 The terms of the section 106 agreement for the application will need to appropriately codify all aspects of the affordable housing provision to the satisfaction of GLA officers.

58 Depending on the outcome of this review and the timing of the implementation of phases under each scenario it may be appropriate to put in place provisions for the re-appraisal of scheme viability and the associated level of affordable housing, as suggested in paragraph 3.75 of the London Plan.

59 In summary the proposal is currently not in accordance with London Plan policies 3.11 or 3.12.

Mix of units

60 London Plan Policy 3.11 accords priority to family housing within affordable housing provision. In addition, London Plan Policy 3.8 requires developments to provide a range of housing sizes and types. This is supported by the London Plan Housing Supplementary Planning Guidance, which seeks to secure family accommodation within residential schemes, particularly within the social rented sector, and sets strategic guidance for councils in assessing their local needs. Also relevant is Policy 1.1C of the London Housing Strategy, which sets a strategic target for 42% of social rented homes to have three or more bedrooms.

page 10 61 The White City OAPF seeks to exceed the Mayor’s Housing Strategy Requirement in terms of family housing, seeking at least 20% of private market, 20-30% intermediate, and 40% social rented housing proposed to be 3 bedroom or more.

62 Overall the proposal includes a mix of 31% 1-bed, 55% 2-bed and 10% 3-bed dwellings. Within the affordable rented and intermediate categories, the proposals incorporate 20% 1-bed, 40% 2-bed, and 40% 3-bed dwellings. Although the proportion of social rented and intermediate 2 and 3-bedroom units complies with the OAPF, however the proposal falls short of the aspiration for large private market units. As the affordable provision is relatively low, the overall balance in the proposal is heavily in favour of 1 and 2 beds overall. The OAPF is clear that family housing should be delivered across all tenures, and consequently, the limited provision of larger private units is disappointing.

63 The ongoing financial viability assessment may result in changes to the proposed mix. The applicant should further discuss this matter with the local authority and GLA officers and is strongly encouraged to revisit the mix to ensure that the proposal would be consistent with London Plan Policy 3.8, and also addresses housing quality issues as set out in paragraph 71.

Housing density

64 London Plan Policy 3.4 requires development to optimise housing output for different locations taking into account local context and character, the design principles in Chapter 7 and public transport capacity. Table 3.2 is a residential density matrix with density ranges which would allow developments to achieve a sustainable level of provision. The public transport accessibility level (PTAL) of the site ranges between 6a (at the western end) and 3 (at the eastern end) on a scale where 6 is high and 1 is low.

65 The site lies in a Central setting, as defined by the London Plan. Table 3.2 sets out a range of 140-405 units per hectare (u/ha) where the PTAL is 4 – 6 and 65-240 u/ha where the PTAL is 2 – 3. Development with a higher proportion of family housing would be expected to rate in the lower end of this range.

66 Using the ‘Greenwich’ calculation method, the proposed density of the scheme would be 250 dwellings per hectare. Given the variation in public transport accessibility within the site, the proposal is variously at the middle or higher end of the appropriate range, and is therefore consistent with London Plan policy 3.4 and the wider aspirations of the draft WCOAPF.

Housing quality

67 London Plan Policy 3.5 promotes quality in new housing provision and sets out minimum space standards at Table 3.3. The Mayor will produce a new Housing SPG (a draft of which was put before the London Plan EIP), on the implementation of Policy 3.5 for all housing tenures, drawing on his London Housing Design Guide.

68 The applicant has stated that all the proposed housing will be designed at reserved matters stage to meet Lifetime Homes standards and the Mayor’s Housing Design Guide. Dwelling sizes will accord with the requirements of the London Plan, including the minimum space standards at Table 3.3. 10% of the dwellings will be designed for occupation by wheelchair users or adaptable to be so.

69 The Design and Access Statement includes indicative/typical floorplans which provide a brief overview of the internal layouts of the flats. The indicative design demonstrates how regular entrances to the residential blocks and multiple cores could be implemented, allowing for no more

page 11 than 8 units per floor to be served by a core, which reflects the guidance in the Mayor’s Housing Design Guide.

70 The approach to the upper storeys of the blocks along the West Cross Route ensures almost no single-aspect flats facing onto the West Cross Route elevation, except for the ground- level maisonettes which will face a landscaped strip in front of a new 3m wall. The wall will be lower than the 2-storey maisonettes which are single aspect, so the applicant should explain how these flats will be protected from the acoustic and environmental effects above 3m.

71 In the rest of the development, there are a high proportion of single aspect flats. Although the applicant has proposed dual-aspect maisonettes in certain blocks to avoid providing single- aspect north-facing units, there are single-aspect south, east and west-facing flats proposed on both the base buildings and upper setback elements for all other blocks. Whilst the provision of north-facing single aspect flats has been avoided, it is still disappointing that there is such a high predominance of single-aspect units, particularly facing Wood Lane and the Hammersmith & City line, where the acoustic and environmental conditions will not be ideal for opening windows. Achieving an increase in the proportion of larger units as set out in paragraphs 62-63 would be likely to necessitate more dual aspects units in the development, and the applicant is strongly encouraged to revisit these elements of the scheme.

72 The Design Codes allow for all flats to have private amenity space in the form of balconies, private gardens or loggia. On blocks that have semi-private courtyards on top of the base buildings, access to the courtyards will be through the communal cores, although the applicant has suggested that residents in the affordable housing will not have access to these. The applicant should confirm the access arrangements to the shared amenity space for all residents.

73 The Design Codes and Design and Access Statement provide the foundations for achieving an acceptable standard of design that generally meets the emerging housing design guidance above. The Council should ensure the appropriate conditions are attached to the permission to allow for more detailed scrutiny of the future detailed proposals as they come forward, having regard to the standards in place at the time of submission of reserved matters applications.

Children’s play space

74 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 296 children within the development, of which 149 would be under 5. The guidance sets a benchmark of 10 sq.m. of useable child play space to be provided per child, with under-5 child play space provided on-site. As such the development should make provision for 1,494 sq.m. of play space as a mimimum, although given the scale of the site, the proposal should also be able to provide for play space for older children as well.

75 A Landscape and Public Realm Strategy illustrates locations where playable space might be provided on the illustrative masterplan, and demonstrates that 4,770 sq.m. of ‘doorstep’ playable space could be achieved on the internal podium. This is three times the minimum requirements for the youngest age group, and is supported. However, to ensure all reserved matters proposals comply with London Plan policy 3.6, the Council should ensure this space is secured via legal agreement, as this is not illustrated in the parameters plans.

page 12 76 The Landscape Strategy suggests that a pocket park on the podium and the green space along the Hammersmith & City line viaduct would provide sufficient play space for older children, although the illustrative design does not suggest that these spaces would be compatible with the types of spaces promoted in the London Plan and SPG on Children’s Play. The draft WCOAPF includes the delivery of a new park, the ‘White City Green’ as a key aspiration, and this space is likely to be more appropriate location to provide play space for older children. As well as providing on-site amenity and play space, the applicant would be expected to contribute to the delivery of the park beyond their site boundary, in response to the priorities set out in policy 3.6.

Social infrastructure

77 The draft WCOAPF included an initial analysis of likely social infrastructure needs across the opportunity area to support the 4,500 new homes and other development. A Development Infrastructure Funding study (DIFs) is currently under way, to establish in more detail the exact social infrastructure needs including transport, public realm, open space, and social infrastructure provision. The intention is that the study will identify a level of financial contributions that will be required from all landowners and developers to enable delivery of critical infrastructure for the entire Opportunity Area, based on a standard charge per square metre of commercial floorspace and per residential unit, and this will inform the delivery strategy of the WCOAPF.

78 Whilst this application is likely to be determined prior to the publication of the final WCOAPF, the DIFs will have been concluded by the time the Council would be finalising any section 106 agreement with the applicant. The Council should therefore ensure that any planning obligations take into account the conclusions of the DIFs to ensure that the applicant makes a sufficient contribution to social and other infrastructure in the Opportunity Area. Design

79 Good design is central to all objectives of the London Plan (2011) and is specifically promoted by the policies contained within chapter seven which address both general design principles and specific design issues. London Plan Policy 7.1 sets out a series of overarching design principles for development in London. Other design polices in this chapter and elsewhere in the London Plan include specific design requirements relating to maximising the potential of sites, the quality of new housing provision, tall and large-scale buildings, built heritage and World Heritage Sites, views, the public realm and the Blue Ribbon Network. New development is also required to have regard to its context, and make a positive contribution to local character within its neighbourhood (policy 7.4).

80 The draft WCOAPF sets out that development on this site should “deliver variation in scale, grain and built form to make a successful transition from the shopping mall typology to a high street typology more suitable to the mixed/commercial/residential uses.”

81 The applicant has submitted a Design & Access Statement (DAS) that sets out the general principles of the proposal, as well as an illustrative scheme that describes how the general masterplan and parameters set out in the outline application might be built out. The applicant has also submitted a landscape masterplan which sets out outline principles for the public realm that would be developed as part of reserved matters applications, as well as Design Codes that elaborate the detail of the parameters plans. These codes cover massing, appearance, materials and courtyard design, and set standards in these areas to allow the Council to establish a minimum standard of design.

page 13 Local context and site layout

82 The railway arches of the Hammersmith & City Line viaduct form the northern boundary to the site; the West London Line Overground railway and the West Cross Route form the eastern boundary, with a prominent H-junction coming into the site from the West Cross Route. The large-scale Westfield Shopping Centre and BBC multi-storey car park combined with the domestic scale of the nearby housing and aggressive transport infrastructure create a very mixed context for development.

83 The draft WCOAPF notes in section 4.5.2 that the site “is dominated by commercial servicing, roads into the car park, bus and taxi dropoff area, which all render the area inhospitable for pedestrians. Future development of the site allows the opportunity to facilitate greater north- south movement, to address the poor quality public realm to the north of the existing shopping centre by creating a human-scaled, street based active frontage and high quality public realm.”

84 As noted above, the site is not in a Conservation Area, although the Wood Lane Conservation Area is directly the north and west of the site, running along the Hammersmith & City line viaduct from the West Cross Route to Hammersmith Park in the West, and includes the Grade II listed BBC Television Centre. The only listed building on site is the Grade II listed DIMCO building, which was refurbished and brought back into use as a bus layover and substation, as part of the Westfield London development. The Grade II listed BBC Television Centre is across the street from the site on the opposite side of Wood Lane.

Figure 3: Proposed massing of illustrative scheme (Source: Allies & Morrison)

85 The proposal comprises six blocks of development as described above in the ‘Details of the proposal,’ with active frontages for mixed uses at ground floor level and residential uses on upper floors. The blocks are largely perimeter blocks with residential shared gardens on the rooftops of the base blocks, with servicing and car parking accommodated below a podium level.

86 The scheme features several new streets at ground level, a 25-metre wide green landscaped area running along the Hammersmith & City line viaduct, and smaller open spaces to the south of

page 14 the tallest building and to the north of the DIMCO building. The latter space is intended to provide a setting from which to appreciate the DIMCO building.

87 Central to the proposals is a raised deck or podium upon which much of the development is set. This podium has been incorporated in the design to minimise the impacts of the servicing and vehicular routes described above, and to manage the change in ‘ground’ level from the shopping mall to the development areas to the north of the viaduct. The podium acts as ground level for half of the site, as the main access for the mall extension and the new shopping area is from the podium level, along with some of other residential and commercial uses. The podium is publicly accessible, with main access points from ground level to the east, west, and north. This approach to decking the existing service infrastructure and managing the level transitions across the site is supported by the draft WCOAPF.

88 Three primary north-south routes are proposed, leading from the existing shopping centre to the proposed landscaped area along the Hammersmith & City line viaduct. The central route leads from the shopping centre at podium level, between the anchor store block and the residential block, and continues down stairs towards the north and to the main green space. The other two are at entirely at ground level, one leading from the DIMCO building to the Hammersmith & City line viaduct, the other running along the West Cross Route boundary to the bus station at Shepherds Bush. Whilst the plan does not have a central north/south avenue as set out in the draft WCOAPF indicative masterplan, the proposed layout will still deliver the principles of good north/south connection via the park.

89 Two strong east-west connections are also proposed: a northern one that runs along the landscaped area next to the Hammersmith & City Line viaduct, leading from Wood Lane Station in the west to the north-eastern corner of the site, where the draft WCOAPF proposes a bridge link over to RB Kensington & Chelsea. This link is strongly supported by the RB Kensington & Chelsea in its Core Strategy, the Council and the GLA in the draft WCOAPF, as it will provide an essential east/west connection for the wider area. The proposal notes that such a bridge link could be accommodated within the proposed layout, but does not propose any details of how this link might be achieved. Mechanisms for the delivery of the bridge link are being considered as part of the DIF study, which the applicant will be required to contribute to.

90 The second connection starts at ground level to the west of the DIMCO building, and rises east onto the podium towards the elevated H junction with the West Cross Route. This latter route is on axis with the BBC Television Centre to the west of the site, and is promoted in the draft WCOAPF to improve the legibility and appreciation of the Grade II listed landmark, although this key visual axis is interrupted by the proposed retail bridge linking blocks A and B. The applicant should therefore revisit and remove the bridge link between the blocks to ensure the proposal meets the aspiration of the draft WCOAPF with regards to ensuring the development is arranged ‘around streets and squares rather than an internal, mall environment [to ensure the development] creates a distinct identity from Westfield London.’ The applicant should also ensure that the retail units along the northern edge of block A and the southern elevation of block B are oriented to open onto the public realm and main external routes and not the interior of shopping mall, to ensure active frontages are provided along the entire east-west link.

91 The site layout largely conforms to the principles set out in the draft WCOAPF, however to ensure the scheme reflects the aspirations in the WCOAPF for improved connectivity and human scale development, the applicant must reconsider the bridge link between blocks A and B, to ensure the strong visual link through the site to the Grade II listed BBC television centre is not compromised and a distinct identity separate from the shopping mall is maintained.

page 15 Height, Scale and Mass

92 As set out in the draft WCOAPF, buildings of up to 9-10 residential storeys would be appropriate on this site, with the potential for one building of 11-15 storeys subject to design quality and further townscape analysis. The preferred typology is of mansion blocks, perimeter blocks and/or commercial buildings similar in scale to the nearby Monsoon/Accessorize and Talk Talk headquarters buildings in RB Kensington & Chelsea. The draft WCOAPF also notes that new development must ensure a variety of scale, massing and architecture is delivered.

93 The scale of block A is largely sympathetic and appropriate to its context, although the building is quite close to the DIMCO building and would benefit from being pulled back to ensure it provides an appropriate setting for the listed building.

94 Block B has a base equal to 8 residential storeys, with 3 and 4-storey upper setback elements along the Hammersmith & City Line viaduct and along the eastern and western elevations. The podium is two storeys high, resulting in 6 storeys of the base block appearing above podium level. Block C has a similar approach except for the eastern side of the block which is separated a bit from the base building and features one 20-storey building, two 16-storey buildings and three 11-storey blocks along the eastern boundary of the site. Block D also features an 8-storey base with 4-storeys above, but is triangle shaped to respond to the site geometry, with the 4-storey element only following the eastern elevation.

95 The robust scale and form of the taller blocks in block C has been designed to provide a buffer to the noise and environmental conditions created by the railway and motorway directly opposite. However, the scale as submitted is still excessive in the context of the draft WCOAPF guidance, and the technical study of areas that would be in permanent shadow as a result of the development indicated that the 16-storey blocks also create significant overshadowing to the internal courtyards in block C. In response to officer concerns, the applicant has agreed to reduce the two 16-storey blocks of block C to 9 storeys, thereby reducing the visual impact of the blocks and improving the conditions in the courtyard. This proposed change is welcomed and will form part of a submission for re-consultation in the coming weeks.

96 The applicant has also agreed following submission to reduce the height and prominence of the northernmost upper setback blocks on blocks B, C and D by 1-2 storeys as officers considered them to be overbearing and out of proportion with the base of the building in key views from Wood Lane, the open space to the north of the Hammersmith & City Line, and the West Cross Route. The reductions in scale across blocks B, C and D result in a reduction of approximately 124 flats; the total number of proposed units would therefore be 1,522.

97 Block E is a single 8-storey block with no upper level setbacks, and given the scale of the multi-storey car park opposite, is appropriate to its context and will provide a strongly defined edge and frontage to Wood Lane. Block F is a 5-storey ‘laminate’ applied onto the western elevation of the existing Westfield shopping centre with the top level set-back. The principle of this block is welcomed, and represents a more appropriate response to the 2-3 storey housing opposite.

98 The longer-term vision for DIMCO involves the addition of a lightweight structure of 1-2 storeys around the base of the smaller of the two sheds, which would house retail facilities and cafes. This proposition raises some concern, and would require much more consideration to ensure it is an appropriate and sensitive response that fully takes account the significance of the listed building.

page 16 99 Provided that the revisions proposed following submission are secured, the approach to height, mass and scale is generally acceptable, however the extent of block A should be reviewed to ensure it provides an appropriate setting to the DIMCO building, as should the proposals to add a structure to the DIMCO building itself.

Tall buildings

100 London Plan policy 7.7 sets out that tall and large buildings ‘should be part of a plan-led approach to changing or developing an area by the identification of appropriate, sensitive and inappropriate locations.’ The draft WCOAPF suggests that a taller building of 12-15 storeys may be appropriate to the north of the Westfield Centre on axis with the East Tower of the BBC Television Centre to assist with orientation and to highlight the crossing point in to the Royal Borough of Kensington & Chelsea. The draft WCOAPF and London Plan also require that all taller buildings be of exceptional design quality. The draft WCOAPF requires proposals for tall buildings to be justified with full planning, environmental and design appraisals.

101 The proposal incorporates a 20-storey building the southeastern corner of block C, as well as two 16-storey buildings along the eastern elevation of block C. Following submission, the applicant has agreed to reduce the height of the two 16-storey buildings to 9 storeys. This amendment would be welcome, as it would allow the taller building to act as a strong, singular piece of architecture, and the reduced buildings to present a more sensitive response to the boundary with the RB Kensington & Chelsea.

102 As this is an outline application with all matters reserved, the DAS includes an illustrative façade design for the tall building, accompanied by principles on internal layout, form, façade composition and materials set out in the Design Code. The Code also sets out general principles regarding the importance of the building being appreciated in the round, having an active ground level, a clearly defined top, and compatibility with the context. The applicant expects that these mechanisms which will inform the design of the building at reserved matters will provide sufficient control over the design to ensure that any reserved matters application delivers on the requirement for a high quality building.

103 The DAS includes an illustrative façade detail that illustrates a potential response to the requirements of the Design Code, and aims to present an elegant but simple form, providing a ‘quiet’ response to the rest of the development, and distinguished from other buildings on site by subtle differences in composition, materials, and orientation. The illustrative elevation features repeating bays of windows with carefully detailed, vertically oriented, angled and folded white metal perforated panels which would provide both solar shading and visual richness to the façade. These panels would extend to double height above the top of the building envelope to frame views of the sky, and the vertical emphasis of the panels would be balanced by a horizontal shelf that cuts across each floor.

104 Whilst the illustrative design of the building shows the potential for a detailed design to achieve a high quality building within the parameters set by the Design Code, the Code does not go to the level of detail or specificity that inspires the confidence that its eventual interpretation at reserved matters stage will result in a building of the illustrated quality. The requirements in the Code are deliberately flexible, setting out vague requirements such as the requirement to achieve balance between vertical and horizontal elements, a clearly defined base, allowing any materials or colours to be used as long as there are only two of each, for example. This is not sufficient to demonstrate to officers that the Design Code, if used by a different firm of architects, would be sure to achieve the level of quality implied in this submission.

page 17 105 The applicant and the Council must ensure that the quality suggested in the illustrative design that forms part of the DAS is secured through legal agreement and use of conditions. The Design Code should to be amended to provide a greater level of detail and commitment to aspects of the illustrative design, to provide the confidence that the development at reserved matters will meet the standard put forward in the illustrative design. The applicant should also demonstrate a commitment to working with the current architects or architects of a similar calibre and reputation to those who have prepared the Design Code, to provide further confidence that the quality of design proposed will be delivered at reserved matters stages.

Landscape and public realm

106 The proposal is accompanied by a Landscape and Public Realm Strategy and a Public Realm Design Code, which sets out some outline principles for the public realm, and an illustrative masterplan for some of the key areas, including ‘Relay Square,’ ‘Silver Street,’ ‘Pocket Park,’ and the edge of the Hammersmith & City line viaduct. The Design Code sets out further aspirations that echo many existing policy and best practice guides, but does not provide an in-depth information of some of the features proposed. It also includes discussions of sustainability and a play strategy, but only sets out principles – it does not demonstrate how the principles or aspirations will be achieved on site.

107 The applicant has submitted a diagrammatic circulation plan of main vehicular and pedestrian routes as one of the parameters plans, but this does not illustrate clearly how these will be implemented in the landscape and public realm. This level of detail must be provided to demonstrate how movement around the site will be co-ordinated and designed, going beyond the diagrammatic indications in the parameters plan.

108 The applicant has not provided information on how this proposal will address one of the most fundamental challenges of the scheme: how the transition from ground level to podium level will be achieved, and how the environment underneath the podium will be designed to ensure it does not become a liability and an area of concern with regards to safety and security in particular, but also as a high quality space in its own right. The only information provided on the access onto the podium has been one sketch drawing per access point. Much more detail of how these elements of the podium is achieved, including addressing accessibility issues, and the quality of the public realm and areas around the podium base must be submitted at this stage.

109 The Strategy sets out a long term vision for the area around DIMCO, including an aspiration to relocate the White City Bus Station to allow the area to become a pedestrianised square. Whilst the Strategy illustrates how this aspiration might be implemented, the relocation of the bus station does not form part of this proposal. Given this context, the applicant must provide much more detail on the proposed approach to the landscape and public realm around DIMCO as currently is, and what strategies the applicant will employ to improve the current condition for pedestrians in particular. For example, it is unclear what the interface between the existing bus access route and building A will be at ground level; it currently appears that the route runs directly along and under the extension, but the detail has not been provided. Other illustrations suggest that there will be a wall between building A and DIMCO, blocking access along the eastern elevation of DIMCO, which would not be supported. Much more information must be provided about how this proposal aims to improve the pedestrian experience around DIMCO in the existing context must be addressed as part of this application.

110 The landscape masterplan proposal for Relay Square features ‘flexible event space’ and some new trees, but fails to address the implications of the draft WCOAPF desire to introduce a second entrance for the Wood Lane Station in this location. The text discusses this space as providing ‘a principal pedestrian link between the station and the development’, however the

page 18 illustrative design does not demonstrate how this is achieved or promoted; instead it appears that benches, trees and planters are proposed directly in front of where the second entrance could be located. Further detail and consideration must be given to this area.

111 Of further concern is the absence of analysis of the capacity of the site to provide for children’s play space, as noted above, or how the proposal intends to respond to the requirement to achieve greenfield surface water runoff rates, discussed below in climate change adaptation. The current proposal for the Relay Square in particular appears to rely on a predominance of hard paving and raised planters, which is disappointing, given that the draft WCOAPF emphasises the urgent requirement to address the capacity problems in the Counters Creek sewer, not least by encouraging the incorporation of permeable surfaces where feasible to encourage natural drainage. This approach should be revisited to ensure that opportunities to incorporate permeable surfaces and contribute to sustainable urban drainage are maximised.

112 The landscape strategy includes an illustrative design for a larger green space to the north of the Hammersmith & City Line viaduct, reflecting the aspiration set out in the draft WCOAPF for a wider ‘White City Green’ along both sides of the viaduct. While it is encouraging to see how the current proposal may complement and contribute to the delivery of this strategic aspiration, the applicant must ensure that sufficient public open space is provided within the current application site to support and complement the proposal in its own right, especially in the early stages of development. This is particularly important as the long-term implementation and delivery of the White City Green has not yet been secured, although it does remain a key, strategic aspiration for both the Mayor and the Council, one which the applicant would be expected to contribute to.

113 The DAS includes an indicative phasing plan that indicates that the final phases, D, E and F, would not be delivered before 2029; the applicant should consider how it might be able to provide public amenity space on site D until the later stages of development, to provide an alternative public space until delivery of the White City Green is secured.

Summary

114 Whilst the proposal currently does not comply with London Plan policies 7.1, 7.4, 7.5, 7.6, 7.7, 7.8 and 7.9., the broad principles set out in the WCOAPF are reflected in the proposal and the result of positive engagement of the applicant with the White City OAPF process. The applicant has proposed further amendments to the height and mass of blocks B, C and D, which is welcomed.

115 Taking into account the encouraging revisions put forward since submission, some concerns remain regarding the detail of the proposals, including the proposed bridge link between blocks A and B, the transition and relationship between ground level and podium, as well as detail of the conditions below the podium. The tall building has the potential to be a high quality design, however the applicant must provide comfort that the design quality as illustrated can be secured at this stage. The landscape and public realm strategy sets out high-level principles and vision, but more detail is required on key areas, not least the condition around the DIMCO buildings, to ensure that a high quality and sufficient quantity of public realm is provided to support the intensity of development.

116 GLA officers welcome the applicant’s continued engagement and expect that ongoing discussions and further information will allow the applicant to address the above points to resolve outstanding issues prior to the proposal returning to the Mayor at stage 2.

page 19

Access

117 London Plan Policy 7.2 seeks to ensure that proposals achieve the highest standards of accessibility and inclusion (not just the minimum). The Design and Access Statement (DAS) should explain the design thinking behind the application and demonstrate how the principles of inclusive design, including the specific access needs of disabled people, have been integrated into the proposed development and how inclusion will be maintained and managed.

118 The DAS submitted with this proposal highlights a number of principles that the development should adhere to but fails to demonstrate how these principles have been met. This is despite the substantial challenges of the current proposal given that a significant part of the development is located on a podium six metres above street level, creating substantial level changes across the site.

119 Some of the statements within the inclusive access element of the DAS are not consistent with other parts of the submission – for example, the DAS sets out on page 113 that an accessible car parking space will be provided for each of the 164 wheelchair accessible dwellings proposed but this is contradicted by the transport assessment that provides for only 30 accessible residential car parking spaces, resulting in a deficit of 138 blue badge spaces.

120 Although a meeting has been held with the local access group (HAFAD) the access statement fails to state what their concerns were and how they have been overcome. Given the challenges to ensuring that this scheme can meet inclusive design principles, the nature of the extension to the adjacent shopping centre and the successful experience of working with a strategic access forum at the applicant’s Stratford City shopping centre – Stratford City Consultative Access Group (SCCAG) – it is recommended that an access forum along similar criteria to SCCAG is set up as soon as possible to work with the designers and developers on the detailed design of this proposal. An initial meeting with the access consultant, the GLA's access adviser and Hammersmith's Access Officer is recommended before the scheme comes back at stage 2.

Residential

121 The applicant confirmed that all residential units will be designed to the Lifetime Homes standard and of these 10% will be wheelchair accessible units. This is welcomed and is in line with London Plan Policy 3.8 Housing Choice. However, the applicant still needs to demonstrate that the design of the residential units meets the sixteen Lifetime Home standards (see www.lifetimehomes.org.uk), and that the 10% of new wheelchair accessible homes meet the standards set out in the GLA's Best Practice Guide on wheelchair accessible housing (see http://www.london.gov.uk/strategy-policy/accessible-london-achieving-inclusive-environment).

122 Typical flat layouts and plans of the wheelchair accessible homes and the Lifetime Homes units should be submitted to illustrate the relevant features. It should be clear on the plans where the wheelchair accessible flats are located and how many there are. These should be distributed across tenure types and flat sizes to give disabled and older people similar choices to non disabled people (unless the council through their Accessible Housing Register work can advise on the need in this part of the borough for a particular size of wheelchair accessible unit).

Public Realm

123 Much of the proposed public realm can only be accessed by lift or very large flights of stairs. This is not an easy environment for many older people, disabled people and people with

page 20 small children in pushchairs. Therefore, further clarification of the routes through the site and how access can be assured at all times must be provided by the applicant. It would therefore be appropriate to undertake a full access audit of all the routes to and into the site given the level changes to identify any other barriers to easy and convenient access for disabled and older people.

124 The applicant should consider how the proposal can extend the Lifetime Home concept to the neighbourhood level, and should ensure that the public realm, the parking areas, the routes to the site and links to adjacent public transport and local services and facilities are also designed to be accessible, safe and convenient for everyone, particularly disabled and older people(see http://www.lifetimehomes.org.uk/pages/lifetime-neighbourhoods.html). The Design Code should address these criteria and have regard to other best practice standards in achieving inclusive access.

125 The design of the landscaping and the public realm is crucial to how inclusive the development is for many people. The proposals should ensure that the routes from the public transport facilities to the new homes are legible and that wayfinding is easy with clearly identified entrances at street level to make access easy, safe and comfortable, particularly for disabled people. The DAS does not currently demonstrate how disabled people access each of the buildings safely, does not clarify where there are ramps or other changes of level. The applicant should address these deficiencies in the submission and also provide details of levels, gradients, widths and surface materials of the paths, how they are segregated from traffic and turning vehicles, and how any level changes on the routes to and within the residential courtyards will be addressed.

126 Further explanation of how the existing shopmobility scheme is to be extended to service the new retail units is required.

127 The proposals currently do not comply with London Plan policies relating to access and inclusion. Further information is required, as well as revisions to the proposals to ensure that the scheme meets the requirements of London Plan policies 3.8, 6.13 and 7.2. Sustainable Development

128 The London Plan climate change policies set out in Chapter 5 collectively require developments to make the fullest contribution to the mitigation of, and adaptation to, climate change, and to minimise carbon dioxide emissions. London Plan Policy 5.2 Minimising carbon dioxide emissions sets out an energy hierarchy for assessing applications, London Plan Policy 5.3 Sustainable design and construction ensures future developments meet the highest standards of sustainable design and construction, and London Plan Policies 5.9-5.15 promote and support effective adaptation to climate change. Further detailed policies on climate change mitigation and adaptation are found throughout Chapter 5 and supplementary guidance is also given in the London Plan Sustainable Design and Construction SPG.

129 The proposal is designed to achieve BREEAM Very Good and a Code for Sustainable Homes rating of 4.

Climate change mitigation

130 The applicant has broadly followed the energy hierarchy. Sufficient information has been provided to understand the proposals as a whole. The proposals are broadly acceptable; however, further information is required before the carbon savings can be verified.

Energy efficiency standards

page 21 131 A range of passive design features and demand reduction measures are proposed to reduce the carbon 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 features include energy efficient lighting and mechanical ventilation with heat recovery. The demand for cooling will be minimised through the use of solar shading and high performance glazing.

132 Based on the information provided, the proposed development will meet 2010 Building Regulations compliance through energy efficiency alone.

District heating

133 The applicant has identified that the development is within the vicinity of the proposed district heating network for the White City Opportunity Area and is proposing to connect to the network when it becomes available. Connection to the White City heat network should continue to be prioritised and evidence of correspondence with the steering group taking forward the implementation of the network should be provided.

134 The applicant has also provided a commitment to ensuring that the development is designed to allow future connection to the White City network should timescales prove incompatible in the initial stages. The energy strategy references and takes into account the draft White City OAPF technical appendix TA9.

135 The applicant is proposing to install a site heat network with all residential and non- domestic building uses connected to the site heat network. A drawing showing the route of the heat network linking all buildings on the site has been provided.

136 The site heat network will be supplied from a single energy centre. This will be approximately 1,000 sq.m. and located in a building at ground floor level north of the ramp leading down from the H junction. The 1,000 sq.m. minimum floor area of the energy centre should be secured by condition.

137 The applicant has investigated and discounted linking to the existing Westfield centre as the current anchor stores use individual heat pumps systems to supply their base heat load.

Combined Heat and Power

138 The applicant is proposing to install 2.6MWe of gas fired CHP capacity as the lead heat source for the site heat network. Back-up gas boilers will provide top up heat. The CHP is sized to provide the domestic hot water load, as well as a proportion of the space heating. Load profiles have been provided. The CHP will be run for a relatively short number of hours per annum to meet 70% of the development’s load. Therefore, once the development connects to the wider OAPF network, it will be possible to increase operating hours and export significant quantities of heat from the development. The 2.6MWe of CHP capacity should be secured by condition.

139 A reduction in regulated CO2 emissions of 947 tonnes per annum (17%) will be achieved through this second part of the energy hierarchy.

Renewable energy technologies

140 The applicant has investigated the feasibility of a range of renewable energy technologies and is proposing to install 1,500 sq.m. of roof mounted photovoltaic panels. The applicant has provided roof drawings showing the potential location of the PV panels.

page 22 141 A reduction in regulated CO2 emissions of 98 tonnes per annum (2%) will be achieved through this third element of the energy hierarchy.

Summary

142 The estimated regulated carbon emissions of the development are 4,478 tonnes of CO2 per year after the cumulative effect of energy efficiency measures, CHP and renewable energy has been taken into account.

143 This equates to a reduction of 1,046 tonnes of CO2 per year in regulated emissions compared to a 2010 Building Regulations compliant development, equivalent to an overall saving of 19%.

144 The on-site carbon dioxide savings fall short of the targets within Policy 5.2 of the London Plan. However, running the proposed CHP plant for longer hours and exporting heat to the OAPF heat network provides the opportunity for significantly more carbon savings, for example an additional 1,000 tonnes of CO2 per annum, thus exceeding the savings targets in Policy 5.2. The minimum size of CHP plant proposed should therefore be secured.

Climate Change Adaptation

145 London Plan policy 5.10 Urban greening and 5.11 Green Roofs and Development Site Environs set out that development proposals should integrate green infrastructure, including tree planting and green roofs.

146 Brown roofs are proposed on at least 50% of the roof surfaces. Furthermore, a minimum of 150 new trees are proposed in the parameter plans, along with the retention of five existing London Plane trees, and a minimum of 17,000 sq.m. of soft landscaping. These elements, which will increase the biodiversity on site whilst also contributing to a high quality environment are welcomed and should be secured via planning condition.

147 London Plan policy 5.13 Sustainable Drainage seeks to ensure that sustainable urban drainage systems (SUDS) are used where practicable, and that developments should aim to achieve greenfield run-off rates by managing surface water run-off as close to its source as possible through attenuation and storm water management. The WCOAPF reiterates these policy objectives, and seeks to ensure that all new development in the Opportunity Area achieve these aspirations particularly in the context of the pressures on the Counters Creek sewer.

148 The proposed brown roofs and soft landscaping will reduce the amount of impermeable surfaces on the site, resulting in a commitment by the applicant to reducing the runoff rate by 50% on site at detailed design stage. The applicant notes however, that achieving the greenfield runoff rates to meet London Plan aspirations would not be feasible as there are limited other SUDS methods available.

149 Whilst the above proposed measures meet the minimum standards set out in the London Plan, it is disappointing that the scheme can not meet London Plan and WCOAPF aspirations of 100% attenuation. The Flood Risk Assessment notes that only 5% of the total available space on site which could be used for tanked systems to supplement the SUDS strategy will be used in their strategy, so it is not clear why the applicant can not meet the 100% attenuation with more extensive tanking. Further clarification should be provided to ensure compliance with policy 5.13.

150 London Plan policy 5.14 seeks to conserve water supplies by minimising use of mains water promoting the use of rainwater harvesting systems and greywater recycling programs and by requiring development to incorporate water saving measures and equipment. The proposal meets

page 23 the Mayor’s essential standards with regards to water conservation, but the applicant has only proposed to undertake a feasibility study into the use of these initiatives. A more concrete commitment to water saving measures would be welcome to ensure full compliance with policy 5.14. Transport

Trip Generation

151 TfL has concerns over the provided trip generation and does not currently accept the assumptions that have been presented. Subsequent to submitting the application, the applicant has met with TfL and has provided further analysis for the residential trip generation which TfL has accepted. However the applicant is expected to undertake additional detailed work related to retail trip generation, modal share and modelling.

Modal Share

152 There is a concern that the applicant has made a decision to reduce the car mode share from that contained in databases such as Census data. TfL would like to see the justification of this decision and preferably a worst case scenario with a higher mode share, to fully understand the impact on public transport and the highway network.

Modelling and Highway Impact

153 No digital traffic flow simulation models (SATURN and VISSIM) have been provided and there is no evidence that the provided model outputs are fit for purpose as set out in the agreed modelling methodology. TfL is concerned about the changes in journey times between average delays on the highway network as some of the results appear to be illogical. It is strongly recommended that the applicant enters into technical discussion with TfL to resolve this issue.

154 For Saturdays it is acceptable to use a LINSIG model instead of a VISSIM model, however, evidence needs to be provided that this model has been validated under TfL modelling guidance before further comments can be made.

155 It is recommended that an assessment is carried out on the junctions of Wood Lane/Uxbridge Road and Wood Lane/A40 to check whether or not there would be an adverse impact. An assessment should also be carried out on the queues on the off ramps at the “H” junction to ensure that the future queues do not cause tail back on to the West Cross Route. Once the agreed and above mentioned higher trip sensitivity tests have been carried out, TfL will provide further comments on the highway impacts.

156 After submitting the application, the applicant has entered into discussions with TfL and has agreed to carry out further work for TfL to fully understand the impact of the development on the highways.

Car Parking

157 A total of 1,479 car parking spaces are proposed by the applicant, of which 659 would be for residential use, corresponding to a ratio of 0.4 residential spaces per unit. Since the draft WCOAPF was published, TfL has carried out extensive further analysis to better understand the impact of proposed developments on the highway network. The conclusions are that only a ratio of 0.2 spaces per residential unit can be supported. Hence, TfL advises the applicant to reduce the number of residential parking spaces to 296 spaces.

page 24 158 820 car parking spaces are proposed for the retail use. The applicant has suggested that the proposed anchor store in this proposal will require its own parking, despite being only a short distance from the existing car park and servicing for the adjoining Westfield London shopping centre. As highlighted in the pre-application advice and based on the findings of the draft WCOAPF, no further increase of car parking will be supported. An assessment of the retail car park associated with the existing shopping centre has demonstrated that current utilisation of the existing car park is well below capacity. At pre-application stage, TfL suggested that parking could be provided for the new department store on the current application site provided that an equivalent number of spaces were removed from the existing car park, to ensure no net increase in parking. The applicant has not taken this approach.

159 The proposal provides for 26 blue badge car parking spaces for the residential units (1.5% of all residential units, or 4% of all residential car parking) and 30 disabled parking spaces for the retail units on site (4% of retail car parking). This approach is not compliant with London Plan policy 6.13, which requires one blue badge space to be provided per fully accessible residential unit.

160 Given the commitment that 10% of all residential units will to be fully accessible and all fully accessible units will have associated blue badge car parking, 164 blue badge spaces for residential use should be provided. London Plan policy also notes that 6% of all retail parking spaces should be designated as blue badge spaces for visitors, and additional provision should be made for disabled employees. The proposals fall short of the requirement for retail visitors, and appear to not provide for any employee blue badge spaces. The applicant must review the proposed provision and parking management plan to ensure compliance with the London Plan policy 6.13.

161 The proposal provides for 5 car club spaces, which are welcomed by TfL. 428 electric vehicle charging points (EVCPs) are proposed, of which 107 (66 residential and 41 shopping centre) are to be active and 321 (198 residential and 123 shopping centre) to be ‘passive’ points. This is not in accordance with advice given at pre-application stage, where TfL set out that 20% of any car parking must have electric vehicle charging provided and a further 20% must provide for passive charging provision, which corresponds to 295 passive and 295 active points. This provision should be secured within the s106 agreement.

Buses

162 The proposed development is close to a number of bus routes that provide a comprehensive local network in proximity to White City. Though there is spare capacity on some routes in the local area, the Uxbridge Road corridor is currently at capacity on routes 207, 260 and 607 and will still require mitigation in the form of increased capacity equating to £90,000 per annum over 5 years (£450,000 in total).

163 In addition, the surrounding bus stops must be reviewed for compliance with TfL accessibility standards and where alterations to bus stops are proposed these should be agreed with TfL and secured through the s106 agreement.

Rail

164 Rail services are currently close to capacity. The level of trips generated has been provided on the basis of observed survey information and a trip generation methodology that TfL does not agree with. TfL questions the correctness of the assumption that the development will only provide 100 extra trips per peak hour and that the development will not have a material impact on

page 25 Shepherd’s Bush Overground station; further analysis on the expected trip generation and mode share is required (see mode share above).

165 The Development Infrastructure Funding Study (DIFs, see below) has identified the need for platform lengthening on the West London Line to accommodate longer 8-car trains. Contributions will be sought from all developments in the area to lengthen platforms at Shepherd’s Bush Overground station.

Taxis

166 There is currently a busy taxi rank at the south-east side of the Westfield Shopping centre and also Private Hire set down and pick up facilities. Though the TA suggests that the proposed development is not expected to increase demand for taxi use, at peak times the current taxi rank does become oversubscribed. Hence TfL suggests that more work needs to be undertaken to provide additional space for taxis in the area to accommodate for the growth in demand.

Walking and Cycling

167 TfL is pleased that a PERS audit has been provided in the TA however from the assessment it appears that signage in the area needs improving. TfL strongly recommends that a wayfinding strategy is prepared and the applicant provides a Legible London signage scheme that is linked with other schemes in the area. In addition to the implementation of Legible London TfL would recommend considering improvements to the local pedestrian environment to ensure a high quality and accessible public realm is achieved in accordance with the draft White City OAPF. This will include convenient, legible and well lit cycle routes through the development that are well connected with surrounding neighbourhoods as well as other cycle facilities such as showers and storage for employees.

168 The Barclays Cycle Superhighway (CSH) Route 9 will run along the A315 Hammersmith Road, located approximately a 5 minute cycle to the south, and while not fixed, CSH Route 10 is expected to run even closer. Initial design work has commenced and development must promote and facilitate its completion in accordance with policy 6.9 of the London Plan. Consideration should therefore be given towards what improvements may be required to provide a safe and convenient cycle link from the proposed development to these routes, both of which would help facilitate cycling to and from the site in the future. Further discussion with regards to this would therefore be welcomed.

Development Infrastructure Funding Study/ s106 mitigation measures

169 As part of the White City OAPF, a DIFS is currently being undertaken, with the purpose of establishing a development tariff for the area. This is based upon the overall growth in homes, jobs and development floorspace and linked to the transport study which identifies a number of necessary transport interventions based on an assessment of all developments in the study area. Once the DIFS has been completed, it will recommend a range of contributions based on land uses for all essential transport infrastructure. TfL expects this to be the basis of s106 negotiations with the applicant although the borough may bring forward its own proposals for a community infrastructure levy in the future in addition to the Mayor’s CIL. In addition, TfL will also review the specific impact of this development and if mitigation over and above what has been agreed in the DIFS is required, contributions will be sought to cover any necessary mitigation.

Travel planning

170 Travel Plans for both the retail and the residential units have been prepared in support of this development and have passed the ATTrBuTE assessment. However, it is recommended that

page 26 additional information including details of the expected numbers of users, allocation of sufficient amount of time for a Travel Plan coordinator as well as the expected budget are included and secured though a s106 agreement.

Servicing and Delivering

171 The inclusion of a Delivery and Servicing Management Plan in the TA is welcomed. However, further information is required on how servicing will be rationalised with the aim of reducing the total number of trips made and to avoid critical times on the road network. TfL recommends that this information is included in the Framework Delivery and Servicing Plan and submission of the Plan for local authority’s approval prior to the occupation of the site should form part of s106 planning obligations.

Construction Impact

172 A Construction Management section has been included in the TA stating that the developer would seek to minimise highway and traffic impact to the highway network during construction. However, TfL requests that further information on how this will be achieved as well as measures to regulate construction vehicle movement in traffic and pedestrian sensitive areas are included in a standalone Framework Construction Logistics Plan.

173 Submission of the Construction Logistics Plan to TfL and local authority for approval prior to start of construction work on site should form part of the s106 obligations.

The Olympic Route Network (ORN) and Paralympic Route Network (PRN)

174 The Olympic Route Network (ORN), Paralympic Route Network (PRN) and Alternative Olympic Route Network (AORN) will operate during the Olympic and Paralympic Games period between June and September 2012. During this period, there will be an impact on construction works, utility works and highway licensed activities if they affect the roads designated as a part of the ORN/PRN/ AORN and some of the surrounding streets. The A40/Westway will form part of the ORN and West Cross Route, Goldhawk Road and Shepherds Bush Green will form part of the AORN during the period of the Olympic and Paralympic Games in 2012. As such, there will be restrictions on what highway works can be undertaken during this period, and the applicant should therefore consult with TfL prior to any works taking place on site which may impact on the ORN/ PRN or AORN. Other routes might also be affected and will also be required to be clear of any kinds of obstruction. These are not yet finalised, but will be advised as further information becomes available.

175 Further information and the latest news on the ORN/ PRN and AORN can be found on the London 2012 website at http://www.london2012.com/olympic-route-network/home.html.

Traffic Management Act

176 Should this application be granted planning permission, the developer and their representatives are reminded that this does not discharge the requirements under the Traffic Management Act 2004. Formal notifications and approval may be needed for both the permanent highway scheme and any temporary highway works required during the construction phase of the development.

Summary

177 Before the application can be accepted, TfL requires further discussions with the applicant over issues including the proposed trip generation, modal share, suggested improvements to the

page 27 pedestrian and cycling environment, level of car parking on site and mitigation, to ensure compliance with London Plan policies 6.1, 6.9, 6.10, 6.13 and 6.14.

Local planning authority’s position

178 The local planning authority’s position is not known. Legal considerations

179 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

180 There are no financial considerations at this stage. Conclusion

181 London Plan policies on land use, retail, town centres, housing, affordable housing, density, urban design, access, sustainable development, transport and parking are relevant to this application. The application complies with some of these policies but not with others, for the following reasons:  Land use principles and regeneration: The mix of uses would be consistent with London Plan policies and the draft White City OAPF.  Retail: The provision of further retail and leisure uses to strengthen the vitality of the town centre is welcomed, however further review of the retail assessment to ensure there is no adverse impact is required.  Affordable Housing: There is no justification for the low amount of proposed affordable housing. A viability assessment must be independently verified to ensure the proposal represents the maximum achievable affordable housing. The locations identified for the affordable housing must be reviewed with a view to providing a better mix and diversity of housing options and achieving a mixed community.

 Housing: The mix provided in the affordable housing complies with policy, however there is insufficient private family-sized housing. There is a significant proportion of single- aspect flats, which is disappointing, and it is unclear whether all residents will have access to communal amenity spaces. The provision of play space complies with the London Pan, but the Council should secure sufficient contributions to social and community infrastructure, taking into account the conclusions of the WCOAPF DIF study.

page 28  Density: The density proposed is appropriate to the local context and physical site constraints.

 Urban Design: Overall the layout conforms to the broad principles of the draft WCOAPF, however concerns remain regarding the bridge link between blocks A and B, the approach to the transition between ground level and podium levels, detail of the conditions below the podium, and how the circulation plan will be implemented in the landscape, including a 2nd entrance to Wood Lane station. The massing has been reviewed following submission to address officer concerns and the revisions proposed to date are encouraging. The tall building has the potential to be of high quality, however the applicant must provide comfort that the design quality as proposed can be secured in later stages. More detail is required relating to the public realm around the DIMCO building and the provision of public open space during early phases of development, and the east/west bridge crossing over the West London Line.

 Access: The proposal currently does not comply with London Plan policies relating to access and inclusion. The proposal commits to delivering all homes to Lifetime Homes standard and 10% as wheelchair accessible, but these are not illustrated in the Design & Access statement. The proposal does not demonstrate how the principles in the access statement will be implemented, and does not provide sufficient blue badge car parking. Further information is required, as well as revisions to the proposals to ensure that the scheme meets the requirements of London Plan policies 7.2, 3.8, and 6.13. The Council should secure all details via planning condition or at reserved matters stages.

 Sustainable Development: The proposals fall short of the targets within the London Plan policies relating to climate change mitigation, although there is potential for more carbon savings by sizing the CHP plant correctly. Further information should be provided before the carbon savings can be verified. New trees, brown roofs and soft landscaping are proposed. The applicant should seek to improve the anticipated reductions in surface water run-off rates, and to incorporate more ambitious water saving measures.

 Transport and Parking: Further discussions are required with regards to trip generation, modal share, suggested improvements to the pedestrian and cycling environment, level of car parking on site, amount and location of blue badge parking and mitigation. Insufficient blue badge parking is incorporated

182 Whilst the application is broadly acceptable in strategic planning terms, on balance, the application does not comply with the London Plan. 183 The following changes might, however, remedy the above-mentioned deficiencies, and could possibly lead to the application becoming compliant with the London Plan:  Retail: Verification of the retail statement to ensure there is no adverse impact on surrounding town centres.  Affordable Housing: Verification of the viability assessment to demonstrate that the proposal represents the maximum achievable affordable housing. Review of the proposed locations for the affordable housing.

 Housing: Review of family sized housing proposed for private sale. Review of design to address the high proportion of single-aspect flats. Clarification of amenity space access and provision for all residents.

page 29  Urban Design: Submission of revised massing as agreed with officers. Review of the bridge link between blocks A and B, and further information relating to public realm, the east/west crossing over the West London Line, landscaping, approach to the DIMCO building, delivery of high quality design for the tall building. Consideration of temporary public amenity space provision during early phases of development.

 Access: Further information is required, as well as revisions to the proposals to ensure that the scheme meets the requirements of London Plan policies 7.2, 3.8, and 6.13. The Council should secure all details via planning condition or at reserved matters stages.

 Sustainable Development: Commitment to CHP sizing to maximise carbon dioxide savings. Provision of further information relating to the heat network, energy centre and strategies for reducing of surface water run-off rates.

 Transport and Parking: Review of the trip generation, modal share, improvements to pedestrian and cycling environment and reduction in the levels of car parking on site, commitment to secure various mitigation elements via section 106 and planning conditions.

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] Alexandra Reitman, Case Officer 020 7983 4804 email [email protected]

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