The Crest Academies, Neasden in the London Borough of Brent Planning Application No

Home , Dollis Hill, Neasden

planning report PDU/2842/02 17 October 2011 The Crest Academies, Neasden in the London Borough of Brent planning application no. 11/1698

Strategic planning application stage II 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 Full planning permission for the erection of temporary classrooms (2.5 years), the demolition of the existing school buildings and the phased construction of new school buildings (19,509 sq.m.) comprising 4 four-to six-storey blocks with four-storey linking structures. Also new access road from Dollis Hill Lane, 105 car parking spaces, 238 cycle parking spaces, a multi use games area and an all weather pitch. The applicant The applicant is Brent Council and the architect is Capita Symonds.

Strategic issues The Mayor previously raised a number of issues relating to, community facilities, inclusive design, transport (in particular preparation of a bus strategy and legal agreement between TfL and the council) and climate change. All these matters have now been satisfactorily resolved and the proposed application is acceptable in strategic planning policy terms.

The Council’s decision

In this instance Brent Council has resolved to grant permission. Recommendation That Brent Council be advised that the Mayor is content for it to determine the case itself, subject to any action that the Secretary of State may take, and does not therefore wish to direct refusal or direct that he is to be the local planning authority.

Context

page 1 “Development (other than development which only comprises the provision of houses, flats, or houses and flats) which comprises or includes the erection of a building or buildings (c)outside Central London and with a total floorspace of more than 15,000 square metres.”

2 On 21 September 2011 the Mayor considered planning report PDU/2842/01, and subsequently advised Brent Council that the application did not comply with the London Plan, for the reasons set out in paragraph 59 of the above-mentioned report; but that the possible remedies set out in paragraph 60 of that report could address these deficiencies.

3 A copy of the above-mentioned report is attached. The essentials of the case with regard to the proposal, the site, case history, strategic planning issues and relevant policies and guidance are as set out therein, unless otherwise stated in this report. Since then, the application has been revised in response to the Mayor’s concerns (see below). On 27 September 2011 Brent Council decided that it was minded to grant planning permission and on 10 October 2011 it advised the Mayor of this decision. Under the provisions of Article 5 of the Town & Country Planning (Mayor of London) Order 2008 the Mayor may allow the draft decision to proceed unchanged, direct Brent Council under Article 6 to refuse the application or issue a direction to Brent Council under Article 7 that he is to act as the Local Planning Authority for the purposes of determining the application and any connected application. The Mayor has until 21 October 2011 to notify the Council of his decision and to issue any direction.

4 The decision on this case, and the reasons will be made available on the GLA’s website www.london.gov.uk.

Update

5 At the consultation stage Brent Council was advised that London Plan policies on education and community facilities, urban design, inclusive design, climate change and transport were relevant to the application and that the application complied with some of these policies but not with others, for the following reasons:

 Education and community facilities: The proposed replacement of education and sports facilities and welcomed and comply with London Plan Policy 3.19. A definitive minimum level of community access should be agreed and secured via condition.  Urban design: The design broadly complies with London Plan design policy.  Inclusive design: The application does not comply with London Plan Policy 7.2. Further information and design alterations are required with regards to passenger lifts, accessible toilets and blue badge parking.

 Climate change mitigation: Further information is required to determine whether the application complies with London Plan climate change mitigation policy.  Climate change adaptation: The incorporation of green roofs and water conservation measures are welcomed and the application complies with London Plan climate adaptation policy.  Transport: Further information is required to determine whether the application complies with London Plan transport policy. 6 The Council was advised that the following changes might, however, remedy the above- mentioned deficiencies, and could possibly lead to the application becoming compliant with the London Plan:

page 2  Education and community facilities: A definitive minimum level of community access should be agreed and secured via condition.  Inclusive design: The applicant should provide the further information and design alterations required with regards to passenger lifts, accessible toilets and blue badge parking.  Climate change mitigation: The applicant should confirm what the residual emissions will be, expressed in tonnes of carbon dioxide per annum, after the cumulative effect of energy efficiency measures and renewable energy is taken into account. The overall savings, expressed in percentage and tonnes of carbon dioxide per annum terms, should similarly be provided.  Climate change adaptation: The 140 sq.m. green roof should be secured via condition.  Transport: A PERS assessment is required and contributions are sought to address bus capacity and bus stop facilities. A delivery and servicing plan, construction and logistics plan and a travel plan should also be submitted for review and secured by condition. Education and community facilities

7 At the consultation stage, the applicant was required to confirm a definitive level of community access and it was requested that this was secured by the Council via condition.

8 The Council has attached a detailed condition requiring a Community Access Plan to be submitted which secures at least 30 hours community use each week, including at least one day at the weekend. It also requires details regarding: the facilities to be made available; promotion of the facilities; rates of hire; terms of access; the number and details of large community events; the number of late community events; and a mechanism for review after one year.

9 The application now complies with London Plan Policy 3.19. Inclusive design

10 Previously, the applicant was asked to provide the further information regarding the passenger lifts and an additional accessible toilet on each floor of the girls school was also requested. The applicant was required to redesign the existing blue badge parking bays to allow access on both sides and mark out additional bays in the Boys’ school car park for visitors arriving from Dollis Hill Lane.

11 The Council has attached a detailed condition (condition 36) which requires further information to be submitted in writing and approved by the Council including: confirmation that all lifts meet the recommended size set out in BB102; provision of a lift within the girls’ shared block which allows direct access from the ground floor to the sports hall; and an additional accessible toilet in the eastern section of the girls’ academy building.

12 Furthermore, another condition (condition 37) which requires the applicant to submit further details disabled parking bays to the Council including: the provision of additional bays in the car park that serves the Boys’ school; and the revision of the existing bays so that marked access zones are provided on both sides of the bays.

13 Whilst it is disappointing that there was insufficient time for the applicant to implement these changes prior to the application being referred back to the GLA, the conditions should ensure that the building is fully accessible and inclusive. The application now broadly complies with London Plan Policy 7.2 Climate change mitigation

page 3 14 At the consultation stage, the applicant was required to confirm what the residual emissions will be, expressed in tonnes of carbon dioxide per annum, after the cumulative effect of energy efficiency measures and renewable energy is taken into account. The applicant was also asked to provide the overall savings, expressed in percentage and tonnes of carbon dioxide per annum terms.

15 The applicant has now provided the required additional information and has confirmed that through energy efficiency alone, the development is estimated to achieve a reduction of 15 tonnes per annum (4%) in regulated carbon dioxide emissions compared to a 2010 Building Regulations compliant development. Furthermore, the applicant has now confirmed that it intends an overall reduction of 153 tonnes of carbon dioxide per year in regulated emissions compared to a 2010 Building Regulations compliant development, equivalent to an overall saving of 40%.

16 The application now complies with London Plan Policy. Climate change adaptation

17 At the consultation stage the applicant indicated that 140 sq.m. green roof could be provided and the Council were asked to secure this via condition.

18 A suitable condition has now been attached to the permission and the application now complies with London Plan Policy 5.11.

Transport

19 At the consultation stage, a number of issues were highlighted in relation to transport matters, specifically in relation to bus capacity, bus stop upgrades, a pedestrian environment review system (PERS) assessment, the School Travel Plan, the Delivery and Servicing Plan and the Construction and Logistics Plan.

20 The Travel Plan and PERS assessment have been secured via condition and this is supported. A Construction and Logistics Plan has been submitted and a Delivery and Servicing Plan will form part of the school’s Travel Plan which is secured by condition.

21 A condition has been agreed between TfL and the Council which requires preparation of a bus strategy prior to commencement of enabling works. The purpose of the bus strategy will be to identify bus stop improvement works and bus capacity enhancements. The strategy requires TfL and the developer to enter into a legal agreement to secure a scope of works to be agreed between the Council and TfL. The application now complies with London Plan Policy 6.2 and 6.7. This also addresses the issues raised in a letter to the applicant from TfL dated 28 September 2011.

22 In summary, the application now complies with London Plan transport policy. Response to consultation

23 In July, approximately 1200 local residents and businesses within 700 metres of the site were consulted by letter. A notice was displayed in the local paper and four site notices were posted. Local residents were re-consulted on 1 September 2011. The Council received a total of 68 representations all of which were objections to the application.

24 In addition, two petitions were sent to the Council prior to the application being submitted in May and June and these were signed by 71 and 30 signatories respectively. 39 pro-forma objections were also sent to the Council prior to the application being submitted.

page 4 25 Issues raised by objectors include: the scale and design of the development; impact of mobile phone antennae on historic and cultural nature of area; highways and transport concerns including parking, traffic, accidents and bus capacity; impacts on surrounding properties; impact on nearby conservation area; amenity and privacy concerns; environment concerns including noise, light and air quality; antisocial behaviour and security issues; hours of operation; commercial activities on site and community use; impact during build period; and procedural concerns regarding the consultation.

26 The majority of the concerns raised are of a local nature and have been addressed in the Council’s committee report. Those which raise issues of a strategic nature including scale and design of the proposal and transport have been addressed either in this report or the Mayor’s previous report on this proposal.

27 In addition to the representations sent to the Council, two representations have been sent directly to GLA officers. These reiterated the representations discussed above and raise particular concerns regarding the proposed access road from Dollis Hill Road and its impact on the privacy and amenity of the neighbouring properties.

Statutory consultees

28 Sport England - Sport England was consulted as a non-statutory consultee and has no objection to the scheme but requested that a condition requiring the submission of a community use plan be attached to the permission. This condition has been attached to the permission

29 Environment Agency – The Environment Agency originally objected to the scheme on the grounds that the Flood Risk Assessment did not comply with the requirements set out in PPS25. However, the applicant has now submitted further information and the Environment Agency has rescinded its objection, subjected to a condition that restricting the rate of surface water run-off to greenfield rates. This condition has now been attached to the permission.

30 English Heritage – English Heritage has requested a condition regarding archaeological works as the site may be of archaeological interest and this has been attached to the permission.

31 Natural England and Thames water have no specific comments to make in relation to the proposal. Article 7: Direction that the Mayor is to be the local planning authority

32 Under Article 7 of the Order the Mayor could take over this application provided the policy tests set out in that Article are met. In this instance the Council has resolved to grant permission with conditions and a planning obligation, which satisfactorily addresses the matters raised at stage I, therefore there is no sound planning reason for the Mayor to take over this application. Legal considerations

33 Under the arrangements set out in Article 5 of the Town and Country Planning (Mayor of London) Order 2008 the Mayor has the power under Article 6 to direct the local planning authority to refuse permission for a planning application referred to him under Article 4 of the Order. He also has the power to issue a direction under Article 7 that he is to act as the local planning authority for the purpose of determining the application and any connected application. The Mayor may also leave the decision to the local authority. In directing refusal the Mayor must have regard to the matters set out in Article 6(2) of the Order, including the principal purposes of the Greater London Authority, the effect on health and sustainable development, national policies and international obligations, regional planning guidance, and the use of the River Thames. The Mayor may direct refusal if he considers that to grant permission would be contrary to good strategic planning in Greater London. If he decides to direct refusal, the Mayor must set out his reasons,

page 5 and the local planning authority must issue these with the refusal notice. If the Mayor decides to direct that he is to be the local planning authority, he must have regard to the matters set out in Article 7(3) and set out his reasons in the direction. The Mayor must also have regard to the guidance set out in GOL circular 1/2008 when deciding whether or not to issue a direction under Articles 6 or 7. Financial considerations

34 Should the Mayor direct refusal, he would be the principal party at any subsequent appeal hearing or public inquiry. Government guidance in Circular 03/2009 (‘Costs Awards in Appeals and Other Planning Proceedings’) emphasises that parties usually pay their own expenses arising from an appeal.

35 Following an inquiry caused by a direction to refuse, costs may be awarded against the Mayor if he has either directed refusal unreasonably; handled a referral from a planning authority unreasonably; or behaved unreasonably during the appeal. A major factor in deciding whether the Mayor has acted unreasonably will be the extent to which he has taken account of established planning policy.

36 Should the Mayor take over the application he would be responsible for holding a representation hearing and negotiating any planning obligation. He would also be responsible for determining any reserved matters applications (unless he directs the council to do so) and determining any approval of details (unless the council agrees to do so). Conclusion

37 At the consultation stage, outstanding issues were raised in relation to community facilities, inclusive design, climate change and transport. As described in this report, these issues have now been satisfactorily addressed by the applicant. The application now complies with the London Plan.

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planning report PDU/2842/01 21 September 2011 The Crest Academies, Neasden in the London Borough of Brent planning application no. 11/1698

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

Full planning permission for the erection of temporary classrooms (2.5 years), the demolition of the existing school buildings and the phased construction of new school buildings (19,509 sq.m.) comprising 4 four-to six-storey blocks with four-storey linking structures. Also new access road from Dollis Hill Lane, 105 car parking spaces, 238 cycle parking spaces, a multi use games area and an all weather pitch.

The applicant The applicant is Brent Council and the architect is Capita Symonds.

Strategic issues The principle of the development is supported as the proposed development will result in a high quality educational facility and an increase of sports facilities. Further information is required however, regarding urban design, access, climate change mitigation and transport.

Recommendation That Brent Council be advised that while the application is generally acceptable in strategic planning terms the application does not comply with the London Plan, for the reasons set out in paragraph 59 of this report; but that the possible remedies set out in paragraph 60 of this report could address these deficiencies.

Context

1 On 22 August 2011 the Mayor of London received documents from Brent Council notifying him of a planning application of potential strategic importance to develop the above site for the above uses. Under the provisions of The Town & Country Planning (Mayor of London) Order 2008 the Mayor has until 30 September 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.

page 7 2 The application is referable under Category 1B of the Schedule to the Order 2008:

3 “Development (other than development which only comprises the provision of houses, flats, or houses and flats) which comprises or includes the erection of a building or buildings (c)outside Central London and with a total floorspace of more than 15,000 square metres.”

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

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 3.6 hectare site is located within largely residential area in Neasden, Brent.

7 The site is in the centre of a residential perimeter block and it is largely surrounded by two- storey terrace and semi detached housing with the exception of the former Post Office Research Station which is located on the southwest boundary and its part of the Dollis Hill Estate redevelopment. It currently has vehicular access from Crest Road to the north and pedestrian access from Dollis Hill Lane to the south.

8 The site is currently occupied by the existing Crest Academy Girls School and the Crest Academy Boys school (Previously John Kelly Girls Technology College and John Kelly Boys technology college), comprising two main buildings which date from the 1950s and 14 additional buildings and temporary buildings between one and four storeys in height. There are no formal sports pitches.

9 The academies teach children from year seven to thirteen (11-18 years of age). There are currently 1552 students enrolled but the school has capacity for around 1750 pupils. The boys Academy’s deprivation indicator places it within the most deprived 15% of schools nationally whilst 49% of students at the Girls’ Academy are eligible for free school meals.

10 The site is surrounded by suburban residential streets. The nearest Transport for London road network route is the A406 North Circular, approximately 450 metres north of the site. There are no strategic road network routes within the immediate vicinity of the site. The nearest London Underground station is Neasden on the Jubilee Line located approximately 1.6 kilometres south of the site. There are no national rail services located near the site. Five bus routes serve the nearest bus stops that are located on Crest Road. The Public Transport Accessibility Level of the site is two (where one is low and six is high). This equates to a poor level of access to public transport.

Details of the proposal

11 The applicant is seeking full planning permission for the phased construction of new school buildings comprising 4 four- to six-storey blocks with four-storey linking structures.

12 The applicant is seeking permission to erect temporary classrooms (2,673 sq.m.) on the northeast portion of the site for no more than two and half years. The existing temporary accommodation will then be decanted and demolished. The new school buildings (19,509 sq.m.) will then be constructed on the west of the site and the existing school will be demolished and the temporary accommodation removed.

13 The proposal also includes:

page 8  Formation of a new access road from Dollis Hill Lane.  A multi use games area and all weather pitch, which will be accessible to the community.  105 car parking spaces of which six are wheelchair accessible.  238 cycle parking spaces.  Hard and soft landscaping. Case history

14 There is no relevant case history. Strategic planning issues and relevant policies and guidance

15 The relevant issues and corresponding policies are as follows:

 Education London Plan; Ministerial statement July 2010  Playing fields London Plan; PPG17, draft PPS Planning for a Natural and Healthy Environment  Urban design London Plan; PPS1  Inclusive design London Plan; PPS1; Accessible London: achieving an inclusive environment SPG; Planning and Access for Disabled People: a good practice guide (ODPM)  Climate Change 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

16 For the purposes of Section 38(6) of the Planning and Compulsory Purchase Act 2004, the development plan in force for the area is the, 2011 Brent Core Strategy, the 2004 Brent Unitary Development Plan and the London Plan (2011). Education and community facilities

17 London Plan Policy 3.19 ‘Education facilities’ supports development proposals which enhance education and skills provision, including new builds and expansion of existing facilities. It states that proposals for new schools should be given positive consideration and only be refused where there are demonstrable negative local impacts. Furthermore, the policy encourages development proposals which include the co-location of services between schools and colleges in order to maximise land use, reduce costs and develop the extended school or college’s offering.

18 On 15 August 2011 the Secretary of State for Communities and the Secretary of State for Education released a Policy Statement setting out the Government’s commitment to support the development of state-funded schools and their delivery through the planning system. It states “There should be a presumption in favour of the development of state-funded schools” and that “local authorities should make full use of their planning powers to support state-funded schools applications.”

page 9 19 The existing school buildings are generally of a poor quality and rely on temporary buildings to accommodate the existing pupils. The buildings do not meet modern standards for educational buildings and it does not have any formal sports pitches. The school has 1552 enrolled students for 2011 but the capacity for 1750 pupils.

20 The proposed development will, in principle, enhance education provision and provide modern facilities for teaching and increase the student capacity by around 300 places to 2050 and is therefore supported. It will also allow formal sports pitches to be accommodated on the site, which is welcomed.

21 Policy 3.19 also encourages proposals which maximises the extended or multiple use of education facilities for community or recreational use. The applicant has prepared a community use agreement which set a target of a minimum of 30 hours community use each week, with community use encouraged between 6.30pm and 9.30pm. It also intends to allow student and community access during the weekend between 8am and 9.30pm and similar access during the school holidays (with the exception of the Christmas holidays).

22 The proposed level of community access and use of the sports facilities is welcomed; however, to ensure these community benefits in perpetuity, the minimum proposed targets and intend level of access should be secured by condition as definitive agreement rather than targets or intentions.

23 The proposed replacement of education and sports facilities are welcomed and comply with London Plan Policy 3.19. A definitive minimum level of community access should be agreed and secured via condition. Urban design

24 Good design is central to all objectives of the London Plan, in particular the objective to create a city of diverse, strong, secure and accessible neighbourhoods to which Londoners feel attached whatever their origin, background, age or status. Policies contained within Chapter 7 set out a series of overarching design principles for development to achieve this by addressing its layout, height and massing and elevations.

25 The site of the proposed development is embedded within a residential perimeter block. The only part of the site that interfaces with the public realm is the access, which is narrow and well integrated into the built fabric. This approach is strongly supported as it prevents the development from braking up the continuous active frontages provided by the existing houses.

26 Whilst the location of the site ensures the development will not have much of an impact on how the surrounding streets and spaces work, it is likely to impact on the quality of the houses surrounding it. The location of the school at the southern corner of the block minimises the amount of overshadowing on to surrounding blocks and is welcomed.

27 The height of the development and the change in levels through the site results on the building being visible from a number of locations around the area. Whilst this is not a concern, particular consideration needs to be given to the elevations that can be seen from surrounding streets and spaces as this will have an impact in the character of the area.

28 The application broadly complies with London Plan design Policy.

page 10 Inclusive design

29 Inclusive design principles if embedded into the development and design process from the outset help to ensure that all of us, including older people, disabled and deaf people, children and young people, can use the places and spaces proposed comfortably, safely and with dignity. The aim of London Plan Policy 7.2 is to ensure that proposals achieve the highest standards of accessibility and inclusion, not just the minimum. The applicant should therefore seek to design a scheme that is exemplary in terms of inclusive access. The design and access statement submitted with the application should explain the design rationale 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 from the outset and how inclusion will be maintained and managed. Furthermore, educational establishments have a duty under the Equalities Act 2010 to ensure that their facilities and services are accessible for disabled students.

30 The site is challenging in terms of inclusive access due to the substantial level changes across the site. The new pedestrian entrance route from Dollis Hill Lane cannot be made wheelchair accessible due to the steep hill and even within the site some of the level changes achieved are 1 in 20, which is still a steep slope. The Design and Access statement does not provide any substantial detail on the routes into and around the site for disabled people and given the challenges the site presents it would be advisable to appoint a specialist access consultant to review the proposals and assess whether any further improvements can be made. There are a number of areas where the proposal fails to meet the highest level of access and inclusion and this is discussed below.

31 Whilst it is accepted that due to the steep slope down to Dollis Hill Lane, it is not possible to provide level access for pedestrians, additional Blue Badge parking should be provided in the southern car park, as it may be more convenient for users of the Boys School. The Boys School is a considerable distance from the blue badge bays at the Crest Road entrance. Furthermore, the applicant should provide marked access zones on either side of each blue badge parking bays, rather than on just one side as is currently shown on the plans, to accord with BS 8300:2010.

32 It appears that there are three passenger lifts proposed. To improve inclusivity and to reduce the distance wheelchair users are required to travel, the applicant should considered an additional lift within the girls/shared facilities building, as routes to and from the sports halls in the basement can currently only be accessed by female students at ground floor by either entering the building through the visitor’s entrance or by travel up to the first floor across the building and then back down again. This is not considered to be an inclusive or convenient route. Furthermore, when lifts are out of service, this will provide more flexible and less time consuming routes for disabled users.

33 BS8300 requires that lifts suit the anticipated number of users and needs of disabled people. Building Bulletin 102 ‘Designing for disabled children and children with special educational needs’ states the minimum lift size of 1100 x 1400mm in primary schools but recommends a minimum lift size of 2000 x 1400mm in secondary schools. It is not clear from the plans the precise size of lift and whether they meet even the 1100 x 1400 minimum. The applicant should provide this information and increase lift sizes in necessary.

34 Furthermore, an additional accessible toilet should be provided in the bank of toilets in the eastern section of the girls school on each floor as they are over 40 metres from the nearest accessible toilets.

page 11 35 The application does not comply with London Plan Policy 7.2. Further information and design alterations are required with regards to passenger lifts, accessible toilets and blue badge parking. Climate change

36 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.

Climate chance mitigation

Energy efficiency standards

37 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 enhanced controls, speed controlled motors, maximising the use of day lighting and energy efficient lighting.

38 The development is estimated to achieve a reduction of 4% in regulated carbon dioxide emissions compared to a 2010 Building Regulations compliant scheme. The applicant should confirm what this equates to in tonnes of carbon dioxide per annum, as the current estimate of tonnes saved appears to be high.

District heating

39 The development is located in a low density residential area. Following investigative work the applicant has not identified any existing or planned district heating networks in close proximity to the site. However, the heating systems will be designed to allow future connection to a district heating network should the opportunity arise.

40 Heat pumps, in conjunction with boilers, will be used to provide the space heating and domestic hot water requirements of the site.

Combined heat and power

41 Due to the relatively short operating hours of the school buildings and the lack of a year round heat demand, combined heat and power is not proposed. This is accepted in this instance.

Cooling

42 A range of passive design features including the use of thermal mass and shading devices is proposed to minimise the need for active cooling. Night cooling is also proposed to minimise the need for comfort cooling. Comfort cooling is only required in server rooms and those rooms with information technology related heat gains.

Renewable energy technologies

page 12 43 The applicant is proposing to install heat pumps where the heat source for the heat pump is the warm air extracted from the building as part of the ventilation strategy. The applicant claims a reduction in regulated carbon dioxide emissions of 37% will be achieved through this third element of the energy hierarchy. As the percentage savings, as well as the tonnes of CO2 saved per annum, appear high, the applicant should provide further details of the assumptions and modelling used to determine the savings and, if necessary, provide new estimates of the savings.

Taking into account the comments above the applicant should confirm what the residual emissions will be, expressed in tonnes of carbon dioxide per annum, after the cumulative effect of energy efficiency measures and renewable energy is taken into account. The overall savings, expressed in percentage and tonnes of carbon dioxide per annum terms, should similarly be provided. Further information is, therefore, required to determine whether the application complies with London Plan climate change mitigation policy.

Climate change adaptation

44 London Plan Policy 5.11 ‘Green roofs and development site environs’ states that major development should incorporate living roofs and walls where feasible. Living roofs or walls have not been incorporated into the proposed development. The applicant states that the amount of roofspace that could be greened is limited because most is used as external learning spaces/ roof terraces or by plant equipment and this is accepted. The applicant has however, stated that a 140 sq.m. sedum mat green roof could be provided on the main entrance building. This is welcomed and should be secured via condition.

45 London Plain Policy 5.15 ‘Water supplies and resources’ seeks to protect and conserve water supplies and water resources. The applicant is incorporating a number of measures to reduce water usage in the proposed development, including leak detection and prevention systems, low- flow taps, toilets and showers, and rainwater harvesting.

46 The incorporation of green roofs and water conservation measures are welcomed and the application complies with London Plan climate adaptation policy. Transport

Car Parking

47 A total of 105 car parking spaces have been proposed which is considered acceptable given it is only an increase of eight spaces. Six spaces have been designated for blue badge holders only. While no standards are included within the London Plan for schools, TfL requests that all car parking on site includes a minimum of 10% active and 10% passive electrical vehicle charging points. These spaces should be secured by use of planning condition.

Cycling

48 The provision of 238 cycle parking spaces is welcomed. All cycle parking must be safe, covered and secure with good lighting and CCTV in order to comply with London Plan Policy 6.9 ‘Cycling’.

49 In addition, showering and changing facilities also need to be provided for all employees on site together with visitor cycle parking, available in an accessible and convenient location.

Walking

page 13 50 A pedestrian environment review system (PERS) assessment is required, as discussed during the TfL pre-application meeting, to review the quality of footways, routes to bus stops and amenities within the vicinity of the site to comply with London Plan Policy 6.10 ‘Walking’. The results of this assessment and identified improvement may require works to be undertaken, for example improvements to the footways, de-cluttering of the streetscape and promoting access for all.

Public Transport

51 The increase in pupil numbers at the school will may have a negative impact on the already congested local bus network capacity, the level of congestion has been observed by TfL officers at a recent site visit. An additional journey is required on route 245 in the AM peak and therefore TfL require funding of £55,000 per year for three years to run an additional journey in order to mitigate the additional trips created by the development. TfL notes that the council will be unable to enter into a s106 agreement with itself to secure the funding.

52 To ensure the application complies with London Plan Policy 6.7 ‘Better streets and surface transport’, TfL requests that a contribution of £40,000 is secured to upgrade the two bus stops on Crest Road and the two bus stops on Dollis Hill Lane to ensure that they are in line with TfL’s Accessible Bus Stop Design Guidance. TfL notes that the council will be unable to enter into a s106 agreement with itself to secure the funding.

Servicing, deliveries and construction

53 The applicant should submit a delivery servicing plan and a construction logistics plan and both should be formalised through appropriate planning conditions to ensure the application complies with London Plan Policy 6.14 ‘Freight’.

Travel Plan

54 As was requested during pre application discussions, a travel plan should be provided for review prior to determination, the applicant should be in a position to use the existing travel plan to forecast travel patterns and to provide targets. The applicant is encouraged to include a range of travel planning measures, including but not limited to, cycle vouchers, educational and promotional events and cycle proficiency training for pupils. This is required to ensure the application complies with London Plan Policy 6.3 ‘Assessing effects of development on transport capacity’.

Summary

55 Overall, several issues need to be resolved or clarified. A PERS assessment is required and contributions are sought to address bus capacity and bus stop facilities. A delivery and servicing plan, construction and logistics plan and a travel plan should also be submitted for review and secured by condition. Local planning authority’s position

56 Brent Council’s position is unknown. Legal considerations

57 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

page 14 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

58 There are no financial considerations at this stage. Conclusion

59 London Plan policies on are relevant to this application. The application complies with some of these policies but not with others, for the following reasons:

 Climate change mitigation: Further information is required to determine whether the application complies with London Plan climate change mitigation policy.  Climate change adaptation: The incorporation of green roofs and water conservation measures are welcomed and the application complies with London Plan climate adaptation policy.  Transport: Further information is required to determine whether the application complies with London Plan transport policy. 60 Whilst the application is broadly acceptable in strategic planning terms, on balance, the application does not comply with the London Plan. The following changes might, however, remedy the above-mentioned deficiencies, and could possibly lead to the application becoming compliant with the London Plan:

 Education and community facilities: A definitive minimum level of community access should be agreed and secured via condition.  Inclusive design: The applicant should provide the further information and design alterations required with regards to passenger lifts, accessible toilets and blue badge parking.  Climate change mitigation: The applicant should confirm what the residual emissions will be, expressed in tonnes of carbon dioxide per annum, after the cumulative effect of energy efficiency measures and renewable energy is taken into account. The overall savings, expressed in percentage and tonnes of carbon dioxide per annum terms, should similarly be provided.

page 15  Climate change adaptation: The 140 sq.m. green roof should be secured via condition.  Transport: A PERS assessment is required and contributions are sought to address bus capacity and bus stop facilities. A delivery and servicing plan, construction and logistics plan and a travel plan should also be submitted for review and secured by condition.

for further information, contact Planning Decisions Unit: Colin Wilson, Senior Manager – Planning Decisions 020 7983 4783 email [email protected] Justin Carr, Strategic Planning Manager (Development Decisions) 020 7983 4895 email [email protected] Gemma Kendall, Case Officer 020 7983 6592 email [email protected]

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