planning report D&P/2310b/01 27 October 2015 Site, Southall in the London Borough of Ealing planning application no. PP/2015/4682

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

The proposal Section 73 application for minor amendment to vary condition 3 to amend the outline scheme drawings pertaining to the 2010 masterplan in respect of outline approval for demolition of 22 houses; the remediation of the land and the redevelopment of the site to deliver a large mixed use development including residential, non-food retail, food retail, restaurants, bars and cafes, hotel, conference and banqueting, cinema, health care facilities, education facilities, office/studio units, car park, sports pavilion, an energy centre, multi-storey car park and associated car and cycle parking, landscaping, public realm, open space and children's play space.

Full application: new access roads from the Hayes-By-Pass and Southall town centre to the application site for vehicle, cycle and pedestrian access, including drainage and a flood relief pond. Widening of South Road across the railway line, for the creation of a bus lane and three new accesses onto Beaconsfield road. Two bridges over the Grand Union Canal and Yeading Brook to provide pedestrian and cycle access to the Minet Country park and Springfield Road application reference P/2008/3981-S dated 29 September 2010.

The quantum of development remains the same as the original scheme with the exception that the proposed development now includes a police facility and public toilets. In summary the proposed amendments to the scheme are: (1) re-distribution of public realm; (2) re-configuration of the internal street network; (3) re-positioning of the Civic Square; (4) re-locating the primary school; (5) improvements to the canal side; (6) re-configuration of buildings around the retained land; (7) alignment of western entrance on the gasworks site; (8) provision of a commercial access.

The applicant The applicant is St James West London Ltd and the architects are John Thompson & Partners.

Strategic issues At stage 1 this application raises issues in relation to housing mix, affordable housing, density, children & young person’s play, urban design, access, sustainable energy and transport.

page 1 Recommendation That Ealing 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 83 of this report; but that the possible remedies set out in that paragraph could address these deficiencies.

Context

1 On 18 September 2015 the Mayor of London received documents from Ealing 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 27 October 2015 to provide the Council with a statement setting out whether he considers that the application complies with the London Plan, and his reasons for taking that view. The Mayor may also provide other comments. This report sets out information for the Mayor’s use in deciding what decision to make.

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

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

1B: 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.

3 Once Ealing 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 Southall Gasholders development site is 36.5 hectares, the majority of which is located in Ealing on the boundary with the London Borough of Hillingdon, however the proposals subject to the pre-application discussion fall wholly within the London Borough of Ealing.

7 The site it is bounded to the south by the Great Western railway line, to the north west by the Grand Union Canal, beyond which is the Minet Country Park, and to the north east by Beaconsfield Road, which forms part of the wider Victorian housing to the north of the site.

8 The site retains three operational gasholders and associated facilities including below- ground high-pressure lines with easements above. Industrial and transportation uses once filled the site and Southall has developed around it. Some industrial uses and airport car parking currently remain on the site but would be replaced by this proposal, as would two of the operational gasholders. Southall station is opposite the eastern site entrance and will be served by . Yeading Brook is located approximately 50 metres from the western side of the site boundary, running parallel with the Grand Union Canal.

page 2 9 The site falls within the Southall Opportunity Area, which has a planning framework adopted in 2014. The site has an existing planning consent for residential, retail, hotel, health, education and leisure uses as detailed in the case history section below. This was granted by the Mayor of London in September 2010.

10 Although the site is within the London Borough of Ealing, access from the west will require a new route across land within the London Borough of Hillingdon.

11 Southall station, which already benefits from Great Western Railway and Heathrow Connect services and will be served additionally by Crossrail trains from 2019, is at the eastern end of the site, or a 10-minute walk from its centre. Also at the eastern end of the site, six bus routes run along South Road and a further four bus routes are available from stops on Southall Broadway. Southall Broadway itself has been the subject of recent public realm improvements, partly funded by TfL. The nearest London Underground station is at Osterley (Piccadilly Line), 3.2km away. The site’s Public Transport Access Level (PTAL) currently ranges from 0 at the western end (which indicates no public transport within walking distance) to 4 at the eastern entrance (on a scale of 1 - 6b where 1 is the lowest).

12 Approximately 240 metres west of the site’s western boundary (the Grand Union Canal) is the A312 which forms part of the Transport for London Road Network (TLRN) although there is currently no vehicular access from this direction. There are three existing vehicular access points into the site, via Brent Road to the south, the Straight to the east and Beaconsfield Road to the north.

Details of the proposal

13 Section 73 application for minor amendment to vary condition 3 to amend the outline scheme drawings pertaining to the 2010 masterplan in respect of outline approval for demolition of 22 houses; the remediation of the land and the redevelopment of the site to deliver a large mixed use development including residential, non-food retail, food retail, restaurants, bars and cafes, hotel, conference and banqueting, cinema, health care facilities, education facilities, office/studio units, car park, sports pavilion, an energy centre, multi-storey car park and associated car and cycle parking, landscaping, public realm, open space and children's play space.

14 A full application for the following: new access roads from the Hayes-By-Pass and Southall town centre to the application site for vehicle, cycle and pedestrian access, including drainage and a flood relief pond. Widening of South Road across the railway line, for the creation of a bus lane and three new accesses onto Beaconsfield road. Two bridges over the Grand Union Canal and Yeading Brook to provide pedestrian and cycle access to the Minet Country park and Springfield Road application reference P/2008/3981-S dated 29 September 2010.

15 The quantum of development remains the same as the original scheme with the exception that the proposed development now includes a police facility and public toilets. The proposals would seek to make a number of amendments to the layout and orientation of the masterplan, including:

 Redistribution of public green space;

 Enclosure of National Grid retained land with buildings;

 Revised street network;

page 3  Setting back of buildings facing the canal to allow for a landscaped, public thoroughfare;

 Moving the town square further east, closer to South Road and Southall Station;

 Moving the primary school to the northern edge of the site, closer to existing residential development and further from National Grid retained land;

 Redesign of the western access route to overlook the canal and Minet Park; and

 Position more homes on the pedestrian route from Spencer Street.

16 As part of the amendment process, the applicant is also seeking to reduce the number of parameter plans to simplify the application. The result of the proposed amendments is that the masterplan would comprise three main mixed use hubs: commercial to the east, community to the north and convenience to the west. There would be a main greenspace in the centre of the site, linking to the Minet Park, with an additional park to the north of the site.

17 Within the three main hubs, the masterplan would be broken down into seven character areas:

 The eastern gateway: this would form the access from the north east of the site, comprising a plaza and a set of steps.

 The Emporium: this would contain a mix of leisure, retail, hotel and office space arranged around a public square to the east of the site.

 The Central Park: this would be a sixty metre wide green space stretching from the Emporium to the canal, lined with new homes and mixed use buildings and would provide playspace and water features.

 The Northern Quarter: this would be to the north of the site and would be primarily residential, with a primary school.

 Southall Mills: this would be a public space along the northern part of the canal, surrounded by cafes, community and office space.

 Minet Waterside: this would be a residential neighbourhood overlooking a landscaped park to the south west of the site.

 The western gateway: this would comprise two new bridges and would form the access to the south west of the site. Case history

18 The application was subject to the GLA pre-application process and a report was issued on 2 June 2015. The masterplan proposals have prior to this a long detailed case history and the GLA recently provided support for a compulsory purchase order to help facilitate the development delivery.

19 In 2005, five planning applications were submitted for the following:

page 4  An outline planning application for mixed-use development. Details for access to the north onto Beaconsfield Road were submitted for detailed consideration but all other matters regarding siting, design, landscaping and external appearance were reserved for future consideration. This application envisaged approximately 4,500 residential units.

 A full application for a proposed new link road from Springfield Road/Beaconsfield Road (Hayes) to the former gas works site, which involves crossing both the Yeading Brook and Grand Union Canal.

 A full application for a proposed new link road linking the former Southall Gas Works site to the Hayes By –Pass via Pump Lane. This involved a culvert over the flood relief channel and bridges over the Yeading Brook and Grand Union Canal.

 A full application for the proposed eastern link road between the former Southall Gas Works and a new gyratory in the vicinity of Southall station addressing the Glassy House junction. This also included a new link between The Crescent and Randolph Avenue.

20 In 2006 Hillingdon Council refused planning permission for the access applications and the applicant appealed against these decisions. The appeals were subsequently withdrawn in order for a fresh approach to the masterplan to progress. The main outline application was withdrawn in November 2006.

21 In October 2008 a hybrid application was submitted to both Ealing and Hillingdon Council’s for the following development:

 Outline application

o Demolition of 22 houses; the remediation of the land and the redevelopment of the site to deliver a mixed use development for up to: 320,000 sq.m. of residential, up to 14,200 sq.m. for non-food retail, up to 5,850 sq.m. of food retail, up to 1,750 sq.m. of restaurants, bars and cafes, up to 9,650 sq.m. of hotel, up to 3,000 sq.m. of conference and banqueting, up to 4,700 sq.m. of cinema, up to 2,550 sq.m. of health care facilities, up to 3,450 sq.m. of education facilities, up to 3,500 sq.m. of office/studio units, up to 390 sq.m. of sports pavilion, up to 600 sq.m. of energy centre, up to 24,450 sq.m. of multi- storey car park and associated car and cycle parking, landscaping, public realm, open space and children’s play space.

 Full application

o Pump Lane link road- new access road from the Hayes bypass to the application site for vehicle, cycle and pedestrian access, including drainage and a flood relief pond.

o Eastern access- new access road from Southall centre to the site, including lands currently occupied by properties on The Crescent.

o Minet Country Park footbridge- central pedestrian and cycle access to the Minet Country Park, bridging over the canal and Yeading Brook.

o Springfield Road footbridge- northern pedestrian and cycle access to Minet Country Park and Springfield Road.

page 5 o Widening of South Road across the railway line- widening of South Road over the railway line for the creation of a bus lane.

o Three accesses onto Beaconsfield Road.

15 These applications were initially considered by the Mayor on 9 December 2008 (PDU/2310/01), when a number of strategic concerns were raised. The Mayor considered a further report (PDU/2310/02) on 23 September 2009 following receipt of additional information. On 4 November 2000 Ealing Council resolved to refuse permission and on 10 December 2009 Hillingdon Council resolved to refuse permission. On 22 December 2009 the Mayor determined that he should become the planning authority under Article 7 of the Order 2008 (PDU/2310/03). On 25 March 2010 the Mayor held a representation hearing and, following consideration of a further report (Stage III) and addendum (PDU/2310/04), resolved to grant permission subject to prior completion of a Section 106 agreement. On 29 September 2010 the Mayor issued planning permissions to Ealing and Hillingdon Councils, following completion of the Section 106 agreement.

22 The GLA has issued its Compulsory Purchase Order powers on third party interests, in order to facilitate the proposals. A CPO inquiry was held on 30 June 2015. Strategic planning issues and relevant policies and guidance

23 The relevant issues and corresponding policies are as follows:

 Mix of uses London Plan  Density London Plan; Housing SPG; draft Interim Housing SPG  Housing London Plan; Housing SPG; Housing Strategy; Shaping Neighbourhoods: Play and Informal Recreation SPG;  Affordable housing London Plan; Housing SPG; draft Interim Housing SPG; Housing Strategy;  Employment London Plan; Land for Industry and Transport SPG  Urban design London Plan;  Tall buildings/views/WHS London Plan,  Regeneration London Plan; the Mayor’s Economic Development Strategy  Transport London Plan; the Mayor’s Transport Strategy; Land for Transport Functions SPG, draft Land for Industry and Transport SPG  Parking London Plan; the Mayor’s Transport Strategy  Access London Plan;  Sustainable development London Plan; Sustainable Design and Construction SPG; Mayor’s Climate Change Adaptation Strategy; Mayor’s Climate Change Mitigation and Energy Strategy; Mayor’s Water Strategy  Ambient noise London Plan; the Mayor’s Ambient Noise Strategy;

24 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 September 2010, Ealing Core Strategy, Ealing Managing Development Document (April 2013), the 2011 London Plan and The London Plan Consolidated Alterations since 2011.

25 The following are also relevant material considerations:

 The National Planning Policy Framework and Technical Guide to the National Planning Policy Framework

page 6  Southall OAPF 2014  Draft Minor Alterations to the London Plan (2015)

Principle of development

26 The principle of the development has been established through the existing consent and is supported by the Southall OAPF. As set out above, the proposals seek to amend the parameter plans in terms of layout and the overall housing numbers would remain at 3,750 dwellings. Given that the proposals are the same as the consented scheme in terms of use and quantum, the principle of the amended scheme is supported.

Housing

Housing mix

27 London Plan Policy 3.8 requires different sizes and types of dwellings to meet different needs. London Plan Policy 3.11 sets out that priority should be given to family affordable accommodation.

Table 1: Overall illustrative housing mix comparison

Section 73 Consent no. % no. % Studio 446 12 - 0 1 bed 1,140 30 695 20 2 bed 1,579 42 1,559 45 3 bed 412 11 874 25 4 bed 173 5 347 10 Total 3,750 100 3,475 100

28 In this instance condition 8 of the extant consent provides a steer in relation to proposed housing mix in the section 73 application, this states:

‘Prior to Commencement of Development the following site wide strategies shall be submitted to and approved in writing by the London Borough of Ealing as the local planning authority, unless otherwise agreed in writing by the London Borough of Ealing as the local planning authority.

a) Housing to cover mix, tenure, density and phasing of affordable housing delivery.’

29 This condition allows for flexibility in the future housing mix due the scale of the outline application up to 3,750 dwellings and the extended timescale of their delivery. However, the indicative housing mix does show a substantial up-lift in smaller units (studio and one bed) and an equally substantive reduction in larger 3-4 bed units. The applicant is strongly encouraged to target an increase in larger 3 bed+ units and this should be subject to further discussion between the applicant and Ealing council as this sets a benchmark for the evolving housing mix.

page 7 Affordable housing provision

30 The proposed affordable housing figures are for 30% affordable housing units, in a 50:50 tenure split between social/affordable rent and intermediate. This is in line with the consented scheme.

31 The section 73 application does not seek to alter the number of residential units from the consented scheme and seeks only to amend and rationalise the layout of the proposals. In light of this, the approach to affordable housing as remaining consistent with the consented scheme this is acceptable. It should also be noted that the original section 106 agreement does not include a review mechanism, and it would therefore be unreasonable to request the applicant to revisit the level of affordable housing through an amendment to the consented application. There is however a need for Ealing Council to pursue a higher proportion of larger affordable units than the indicative housing mix currently proposes.

Density

32 The density of the proposals has been established through the existing consent. As the proposed quantum of residential units would be unchanged, the density of the proposals remains appropriate to the site.

Children’s play space and amenity space

33 The applicant has completed a calculation of child yield and produced a target for playspace provision in line with the Mayor’s ‘Shaping neighbourhoods: Play and recreation’ SPG, providing ten sq.m. of playspace per child on site. The proposals result in a decrease in child yield but does increase play space provision from 1.27 ha to 2.5 ha and this increase is welcome in context of the flexibility required due to the housing mix not being fixed and possibility that the scheme will need to accommodate the a possible higher child yield than currently estimated.

Table 2: comparison of playspace provision

S73 Proposal Consented scheme Child yield (no.) 1,151 1,216 Play space provision (ha) 2.5 1.27

34 The applicant has set out details of the location and design of communal amenity and children’s playspace provision in its design and access statement, including a clear indication of levels and accessibility which are as follows:

 0-5 doorstep play: 0.39 hectares all within plot landscape area including podium and roof areas.

 0-11 local playable space and neighbourhood play space of 0.76 hectares.

 12+ youth space of 1.35 hectares.

35 The applicant is committed to the phased delivery of play provision including provision of temporary playspace as the scheme phases are implemented to ensure sufficient is provided for the population of each development phase. Whilst the playspace strategy is supported, GLA officers require that Ealing Council include conditions that secure the quantum and details of playspace provision.

page 8 Other uses

36 The principle and the quantum of the commercial, retail, leisure, health and education uses have been established through the previous consent. The proposed revised layout would rationalise the locations of these uses, which is welcomed. In particular, the relocation of the primary school to integrate better with the existing residential development is welcomed. The enclosure of the retained National Grid land is also supported, and the relocation of the town square is appropriate. Urban design

Layout & strategic context

37 The reassessment of the consented masterplan is welcomed and the applicant has taken the opportunity to amend its layout to provide an improve the distribution of green spaces alongside rationalising the site’s street network, including the relocation of the main vehicular route to run alongside the railway line. These changes result in a more legible and accessible east- west pattern of pedestrian movement through the centre of the site and improved access and outlook to green spaces for the majority residential blocks. The definition of the north-south link between the proposed canal footbridge and the railway underpass has also been improved through the reconfiguration of residential blocks, resulting in an increase in passive surveillance which will help to support street based activity. Key pedestrian routes have been aligned to link in with the established street network, which is welcomed.

38 Other positive amendments include: The changes to the repositioning of the ‘town square’ commercial hub, the wrapping of the National Grid land with residential blocks and the relocation of the school result in a much improved layout which would collectively improve on legibility, access and the overall quality of the pedestrian environment.

39 The amendments to the canal edge which involve the setting back of the building line of blocks (from 7.5 metres to twenty metres) to allow for the inclusion of a pedestrian route/shared surface street is supported as this brings the canal into the scheme rather being a peripheral feature at the rear of blocks in the 2010 illustrative masterplan. This approach with continued provision of two pedestrian crossings bridging the canal will further enhance the accessibility of the towpath and is strongly supported.

40 The applicant has provided sufficient information on the Canal Side character area to demonstrate that the layout will provide a high degree of passive surveillance and a feeling of enclosure and security for pedestrians. Potential issues with over-shadowing due to north face massing have been avoided through the aforementioned setting back and the reduction in height in the central sections of the north end of blocks. Sufficient detail has been provided to understand the quality of the environment created on the canal side through sections and massing studies that establish how active edges to the public realm interface can evolve.

41 It is recognised that relocating the vehicular access to residential units along the site edges and removal of the previous diagonal road that cut through masterplan centre means that the two reconfigured green links (Minet Waterside and he Central Park) running through the site become key masterplan structuring features and can be fully utilised for public and residential amenity space. The indicative masterplan landscaping strategy provides sufficient information to demonstrate that a clear delineation between publically accessible areas and private residential zones along the edges of the repositioned blocks can be achieved. The adoption of wrapping podium car parking areas with duplex units with individual entrance points is welcomed as this

page 9 indicates that thought has been given to removing potential dead frontages by encouraging street- based activity along the northern edge of the site.

42 Both Minet Waterside and Central Park are wide enough to provide space for a range of activities and is particularly suited to activities such as games courts and skate parks. The applicant has provide indicative plans, sections and illustrations that demonstrate the potential quality of these spaces. Elsewhere, the configuration of perimeter blocks is supported as this provides an effective means of defining private amenity spaces from the public realm and maximises the amount of active street facing frontages.

43 Overall the amended S73 masterplan is an improvement on that proposed by the consented application.

Height, massing & scale

44 The scale and massing of development is broadly supported and is aligned with that of the consented scheme. The rationalising of the extant masterplan enables a clear sequence of character areas to be introduced, each including blocks of varying scale directly relating to their immediate context with a predominant courtyard form being adopted with massing increasing in height from the lower rise transition blocks on the Northern Quarter that interfaces with existing terraces of Beaconsfield Road.

45 The inclusion of taller elements around the civic square is supported and this has the potential to contribute to local way-finding, denoting the beginning of the linear park on the approach from the station. Sufficient information has been provided to indicate strategic level design quality will provide a basis for the design of free standing tall buildings this places importance articulating the three parts of tall buildings the top-middle base, the need to activate all parts of the ground floor and the importance of prominent lift cores and this is welcome.

Parameter Plans and design coding

46 The section 73 application seeks to amend and simplify the existing parameter plans by replacing them with the following plans: composite development area (00781_PP_000), Public and Private Realm (00781_PP_001), Predominant Ground Floor Uses (00781_PP_002), Predominant Upper Floor Uses (00781_PP_003), Plot Vertical Parameters (00781_PP_006), Plot Horizontal Parameters (00781_PP_007), Road Layout Deviation (00781_PP_004), Bus and Cycle Networks (00781_PP_005)

47 These proposed parameters plans translate the location of the main structuring public spaces and the individual development blocks into fixed development plots. The illustrative masterplan demonstrates that each of the blocks can accommodate the proposed development form, the road and pedestrian network and the size of public spaces provided and are viewed as sufficient to secure the overall layout out of the masterplan. The simplification from the extant consent parameters plans is supported as these previous plans appear over prescriptive and mechanistic down to and individual building width and depth removing flexibility in built form.

48 The applicant has provided a residential compliance schedule (Appendix C of the design & access statement) which provides a comprehensive list of standards from the Mayor’s Housing SPG. Whilst this is a welcome addition indicating the design quality to be achieved by the masterplan it omits the design ambition that residential units should have a minimum a minimum floor to ceiling height of 2.5 metres and this should be added to schedule. The residential compliance schedule should be secured by condition with the parameter plans to ensure development phases that are dealt with through reserved matters comply with the London Plan policy and Housing SPG.

page 10 Access

49 The applicant has set out in some detail in its design & access statement and the residential compliance schedule how London Plan and Housing SPG policy relating to inclusive design will be integrated into the masterplan. It has included an access plan for the overall masterplan that demonstrates how pedestrians, including those with mobility impairments, would access and move around the site and this is welcome. The eastern gateway design however should be more inclusive in its design as the indicative proposals show steps leading to and down from the plaza.

50 The applicant’s residential compliance schedule includes a comprehensive list inclusive design standards contained in Housing SPG which includes 10% wheelchair accessible units or easily adaptable for residents. The schedule should also include blue badge parking and electric vehicle charging points will be required in line with updated guidance in the London Plan (March 2015) as a standard and as previously stated the residential compliance schedule should be secured by condition. Sustainable Energy

51 The applicant has broadly followed the energy hierarchy and sufficient information has been provided to understand the proposals as a whole. Further revisions and information are required before the proposals can be considered acceptable and the carbon dioxide savings verified.

52 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 mechanical ventilation with heat recovery and low energy lighting.

53 The applicant has stated that as the application is at outline stage passive measures are not yet specified. Whilst it is acknowledged that there is limited scope for assessing passive design measures at this outline stage, the applicant should however outline the approach that will be followed in order to ensure that there will not be significant overheating risks and that the cooling demand will be minimised in line with Policy 5.9. For instance, it is expected that dynamic overheating assessments will be undertaken during the detailed design. The applicant should also confirm the proposed ventilation strategy for the various building uses i.e. whether comfort cooling is intended to be included. The development is estimated to achieve a reduction of 250 tonnes per annum (2%) in regulated carbon dioxide emissions compared to a 2013 Building Regulations compliant development.

54 The applicant has carried out an investigation and there are no existing or planned district heating networks within the vicinity of the proposed development. However, the applicant has determined that the site is situated within a district heating opportunity area. A number of heat mapping studies have been undertaken in the area, which has identified the proposed site as in a focus area for a new district heating network providing energy for other developments in the area. The applicant has also stated that a further study is currently being carried out by Ealing in to whether future projects could be connected to the proposed network and energy centre at the Southall Waterside site.

55 As outlined in the latest GLA energy assessment guidance, large-scale developments, which have the potential to become a catalyst for an area wide network, must investigate the feasibility of including additional space within the energy centre and capacity within the site heat network to supply heat to nearby developments and existing buildings (where applicable). The applicant

page 11 should therefore contact the local borough energy officer to discuss the potential for including additional provisions within the energy centre, including additional space, to facilitate the development of the heat network currently being investigated by the London Borough of Ealing. Evidence of correspondence should be provided.

56 Investigations into development of a heat network in the Southall area indicate the gasworks site is of strategic significance in development of a wider network. The GLA would strongly encourage the provision of heat network pipework to the eastern edge of the site’s boundaries (the Eastern Gateway) and supports Council’s continued work to secure this outcome. This would be considered to support the development’s compliance with London Plan policy 5.6.

57 The applicant has, however, provided a commitment to ensuring that the development is designed to allow future connection to a district heating network should one become available. The applicant is proposing to install a site heat network that will connect all apartments and non- domestic building uses. The site heat network will be supplied from a single energy centre. The energy centre will be 630 sq.m. in size and located in Phase E. The applicant should provide further information on the on the construction timescales of the energy centre and the heat demand will be met earlier phases i.e. whether temporary energy centres are required.

58 The applicant is proposing to install a 2 MWe gas fired CHP unit as the lead heat source for the site heat network. The CHP is sized to provide the domestic hot water load, as well as a proportion of the space heating. A reduction in regulated carbon dioxide emissions of 2,178 tonnes per annum (20%) will be achieved through this second part of the energy hierarchy.

59 The applicant has investigated the feasibility of a range of renewable energy technologies and is proposing to install 17,280 sq.m. of roof mounted photovoltaic (PV) panels. An indicative roof layout plan has been provided to demonstrate the potential locations of the PV panels. Given the large roof area required for the proposed PV array the applicant should ensure that detailed design of the roof layout is developed with the proposed PV array in mind. A reduction in regulated carbon dioxide emissions of 1,351 tonnes per annum (13%) will be achieved through this third element of the energy hierarchy.

60 Based on the energy assessment submitted at stage I, the proposals would result in a reduction of 3,779 tonnes of carbon dioxide per year in regulated emissions compared to a 2013 Building Regulations compliant development is expected, equivalent to an overall saving of 35%. The carbon dioxide savings meet the target set within Policy 5.2 of the London Plan. However, the comments above should be addressed before compliance with London Plan energy policy can be verified. Transport

Trip generation, distribution and mode split

61 The transport assessment confirms that as the quantum of development and the level of car parking is not changing, the trip generation and modal split figures from the original application still apply. This approach is acceptable to TfL and is consistent with other modelling work in the area.

Development impact

62 The study area is the one used for the original application and again this is acceptable to TfL. Following advice from TfL a figure for background growth was included as in the original Transport Assessment. TfL accepts that for the purposes of the section 73 application there is no

page 12 requirement for any new capacity analysis of the study network because the proposed revision to the parameter plans will not generate any additional vehicle traffic above the one already agreed within the approved scheme. TfL can also confirm that there will be no requirement for a review of the impact on other modes of transport.

Access and site layout

63 The section 73 application does not seek to make changes to the external access arrangements which were approved at the time of the outline planning consent for the site as a whole. The exceptions will be a new alignment of the western entrance on the gasworks site and provision of a commercial access.

64 In liaison with the highway authorities including TfL, detailed design work on the new accesses is continuing. The new western vehicle entrance from Pump Lane off the A312 Hayes bypass requires two new bridges and was approved as part of a separate application. TfL has recently reached an agreement with the applicant regarding adoption of the new highway structures to enable work to proceed. This could include the provision of a segregated cycle lane if a revised planning consent for the western access can be secured.

65 The section 73 application will not have any impact on these projects, although TfL supports early delivery of a completed western access which could relieve other junctions and address concerns about congestion in the Southall area. The new eastern vehicle access from South Road was also the subject of a separate application and TfL understands that non material changes including a shared pedestrian and cycle route have recently been approved by Ealing Council. Again, this is unaffected by the section 73 application.

66 The section 73 application seeks to make changes to the parameter plans including road layout deviations and routes for buses and cyclists. Although the detailed design of highways and routes through the site does not form part of the current application, TfL understands that design and engineering work regarding carriageway widths, junctions and the allocation of roadspace is ongoing and wishes to be closely involved in this process.

Bus routes and infrastructure

67 The submitted parameter plans indicate potential bus routes through the site. However they should more correctly be labelled as routes suitable for use by buses. There is no commitment by TfL to run bus services along all the routes shown, in particular along the Straight. Instead TfL supports the intention to provide a route for buses through the heart of the site along the Primary Road which will concentrate all bus services onto a single corridor and should enable all residents to be within 400 metres radius of a high frequency bus service. The submitted Parameter Plans will need to be amended to reflect this position.

68 The provision of a bus and taxi only route through the commercial area is supported by TfL. This area should accommodate bus stops, standing space and drivers’ facilities as well as facilities for taxis. Priority for buses emerging onto the primary route from the bus and taxi only road will need to be provided through physical design, road marking or signal control. Consideration should also be given to an advance stop line at the South Road eastern access.

Cycle and pedestrian routes

69 Although detailed design of the cycle and pedestrian routes lies outside the scope of the section 73 application, TfL has provided comprehensive advice to the applicant on how to apply

page 13 good practice. TfL would welcome further discussions to ensure that this advice is reflected in the detailed design for carriageways and routes through the site. TfL welcomes the applicant’s proposal for segregated facilities along the Primary Road and potentially along the Straight. However it will be important that the form of segregation is appropriate. TfL’s preference is for one way segregated cycle tracks of minimum 2 metres width to be provided on both sides of the Primary Road. Further guidance is available in the London Cycling Design Standards: https:// tfl.gov.uk/cdn/static/cms/documents/lcds-chapter4-cyclelanesandtracks.pdf

70 TfL welcomes the improved pedestrian and cycle connections over the canal. Cycling connections to the towpath along the canal should be excellent as well, as this is a strategic off- carriageway route within the cycling network of the area. TfL would also be keen to see improvement to the subways to provide better cycle access into the site from the south.

Servicing route

71 It is understood that in the revised site layout the Straight will provide a direct route alongside the rail tracks for servicing, deliveries and vehicle access to the commercial core. It is not TfL’s current intention that the Straight would be used by buses despite this being indicated on the Parameter Plan. TfL strongly supports the intention to provide physical traffic management measures to slow traffic and to strongly discourage use of the Straight as a through route. In particular the proposals for deviations in the route and the carriageway narrowing should be taken forward into the detailed design work. A 20 mph limit should be imposed and supported by measures that help to enforce this. Servicing of the commercial area should take place off carriageway to avoid delaying buses and taxis on the route through this area.

Through traffic

72 It will be important to provide physical or enforcement measures to ensure that in normal traffic conditions the internal route network does not create a rat run through the site which attracts through traffic. TfL would have concerns if the internal road layout were to encourage additional traffic onto the A312 Hayes bypass or South Road which is an important route for buses. It is important to note that assessment and design work on the new access junctions makes no allowance for through traffic. Additional measures may need to be considered including weight or height restrictions (apart from servicing vehicles and buses), physical design features, signage and enforcement. TfL would wish to engage further during the detailed design stage to ensure that the risk of encouraging rat running through the site is minimised.

Car parking

73 It is understood that the section 73 application does not affect the quantum of car parking approved as part of the outline application. However, taking account of guidance in the Southall OAPF, TfL would encourage the applicant and their consultants to consider areas in which car parking could be reduced below the maximum approved, particularly close to the Crossrail station and other parts of the site with good public transport access as well as in the commercial area. Blue Badge parking and electric vehicle charging points will be required in line with updated guidance in the London Plan (March 2015).

Cycle parking

74 Cycle parking should be provided to meet the latest minimum standards set out in the London Plan (March 2015). This should be reflected in any detailed submissions or a variation to the section 106 agreement. TfL would welcome further discussions about the potential for cycle storage or cycle hire in and around the site which could be linked into proposals for cycle parking in association with Crossrail at Southall station.

page 14 Signage and wayfinding

75 TfL understands that proposals for signage and wayfinding are currently being developed for the site. TfL would urge the applicant to adopt the Legible London model for pedestrian signage which is a well understood, consistent and cost effective way to provide wayfinding. This will complement the Legible London signage already implemented in the town centre. TfL can provide internal contacts who can advise on the costs and specification for Legible London and how this can be applied to the site.

Travel Planning, construction, deliveries and servicing

76 TfL expects all requirements for supplementary documents, conditions and approvals to be carried forward unaffected by the section 73a application. Contributions Community Infrastructure Levy (CIL) and Section 106

77 Although the Mayor of London introduced his Community Infrastructure Levy (CIL) on 1 April 2012 TfL understands that the section 73 application will not trigger this requirement. The proposed development is in the London Borough of Ealing, where the charging rate is £35 per square metre of floorspace.

78 Due to the proximity to Southall station most of the site is also within the area where section 106 contributions for Crossrail would be sought in accordance with London Plan policy 6.5 and the associated Supplementary Planning Guidance (SPG) ‘Use of planning obligations in the funding of Crossrail’ (April 2013). Again TfL understands that the section 73 application will however not trigger this requirement .http://www.london.gov.uk/sites/default/files /Crossrail%20SPG%20April%202013.pdf

79 However, TfL understands that a deed of variation for the previously signed section 106 agreement is likely to be required as a result of the section 73a application. Proposed transport mitigation measures should be carried forward unless all parties agree that they are no longer justified due to changes that have occurred since the original agreement was signed. In this situation alternative mitigation measures will need to be discussed and agreed. Trigger dates will need to be reviewed to ensure that they are still appropriate in light of any changes. As a signatory to the section 106 agreement TfL welcomes the opportunity for further dialogue on this issue.

Local planning authority’s position

80 Unknown at the time of report preparation. Legal considerations

81 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

page 15 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

82 There are no financial considerations at this stage. Conclusion

83 London Plan policies on housing mix, affordable housing, density, children & young person’s play, urban design, access, sustainable energy and transport. Whilst the principle of development is strongly supported, a number of minor issues are raised, and consequently the application does not accord with London Plan Policy. The following could address these deficiencies:

 Principle of development: The principle of the development has been established through the existing consent and is supported by the Southall OAPF

 Density: The density of the proposals has been established through the existing consent. As the proposed quantum of residential units would be unchanged, the density of the proposals remains appropriate to the site.

 Housing mix: In this instance condition 8 of the extant consent provides a steer in relation to proposed housing mix in the section 73 application. This condition allows for flexibility in the future housing mix of up to given the scale of the outline application up to 3,750 dwellings and is accepted and as no review mechanism was required under the existing consent this is not required in this instance.

 Affordable housing: The section 73 application does not seek to alter the number of residential units from the consented scheme and seeks only to amend and rationalise the layout of the proposals. In light of this, the approach to affordable housing as remaining consistent with the consented scheme is accepted as being compliant with the London Plan. There is however a need for Ealing Council to pursue a higher proportion of larger affordable units than the indicative housing mix currently proposes.

 Children & young person’s play: The applicant has provided this strategy with child yield using the Mayor’s Shaping Neighbourhoods: Play and Recreation SPG (2012). Whilst the playspace strategy is supported, GLA officers require that Ealing Council include conditions that secure the quantum and details of playspace provision.

 Urban design: The amended masterplan is strongly supported and sufficient information has been provided to secure design quality. The simplification of parameter plans is supported but this guidance should also be secured by condition with the residential compliance schedule.

 Access: The applicant has set out in some detail in its design & access statement and the residential compliance schedule how London Plan and Housing SPG policy relating to inclusive design will be integrated into the masterplan, the latter schedule should also be secured by condition. The eastern gateway design however should be more inclusive in its design and the applicant should address this issue.

page 16  Energy: The carbon dioxide savings meet the target set within Policy 5.2 of the London Plan. However, further revisions and information are required before the proposals can be considered acceptable and the carbon dioxide savings verified.

 Transport: The applicant should respond and hold further discussions on issues raised by TFL in relation to access and site layout, bus routes and infrastructure, cycle and pedestrian routes, servicing route, car parking, and signage and wayfinding. As a signatory to the section 106 agreement TfL welcomes the opportunity for further dialogue on issues raised.

for further information, contact GLA Planning (Development & Projects): 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] Jonathan Aubrey, Case Officer 020 7983 5823 email [email protected]

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