planning report PDU/0230b/01 15 August 2012 Twyford Abbey, in the London Borough of planning application no. P/2012/2620

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

The proposal Partial demolition of grade II listed building of Twyford Abbey (existing post war extensions detached ancillary structure) Repair, refurbishment and conversion of grade II listed building of Twyford Abbey and redevelopment of the Abbey grounds to provide 92 residential units comprising 25 within Twyford Abbey and 66 new build ranging in height between two and four storeys to provide houses and flats; and refurbishment and use of gatehouse to provide 1 dwelling; repair and refurbishment of grade II walled garden; Repair and refurbishment of former dairy for community use; and associated landscaping/boundary treatment including pedestrian/cycle access from North Circular, car parking, provision of allotment and area of public open space.

The applicant The applicant is Twyford Abbey Properties Ltd and the architect is PRP Architects.

Strategic issues The principle of the restoration and re use of the Abbey is accepted; however further information is needed before enabling development on Metropolitan Open Land can be accepted. Further information is also required with regards to affordable housing, housing mix, residential quality, density, childs play space, urban design, inclusive access, air quality and transport.

Recommendation

That Ealing Council, be advised that the application does not comply with the London Plan, for the reasons set out in paragraph 130 of this report; but that the possible remedies set out in paragraph 132 of this report could address these deficiencies. The application does not need to be referred back to the Mayor if the Council resolves to refuse permission, but it must be referred back if the Council resolves to grant permission.

Context

1 On 9 July 2012 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

page 1 the Mayor has until 17 August 2012 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 3D of the Schedule to the Order 2008:”Developemnt – (a)on land allocated as Green Belt or Metropolitan Open Land in the development plan, in proposals for such a plan, or in proposals for the alteration or replacement of such a plan and (b) which would involved the construction of a building with a floorspace of more than 1,000 square metres or a material change in the use of such a building”

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 or allow the Council to determine it itself, unless otherwise advised. In this instance if the Council resolves to refuse permission it need not refer the application back to the Mayor.

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

Site description

5 The 5.4 hectare site is bounded by the North Circular to the north, Twyford Abbey Road and West Twyford Primary School to the south, by residential properties along Iveagh Avenue to the east and residential properties along Brentmead Gardens to the west.

6 The Abbey is centrally placed within the site with landscaped gardens to the west, a landscaped former pasture area to the south, a listed walled garden to the north and an overgrown meadow is located in the north-eastern portion of the site. The main vehicular and pedestrian entrance to the site is from Twyford Abbey Road through a gated access with a lodge. There is a second entrance to the east also off Twyford Abbey Road, adjacent to the primary school.

7 The site is bounded by the A406 , part of the Transport for London Road Network (TLRN), to the north, Iveagh Avenue to the west, Twyford Abbey to the south and finally Brentmead Gardens to the west. The nearest Strategic Road Network (SRN) is the A404 Harrow Road, located 1.4km to the north east of the site.

8 The nearest bus stops is the southbound stop, serving the 112 onwards towards and Ealing Broadway, are located on the A406 North Circular Road immediately adjacent the site. The northbound stop, serving the 112 is located approximately 400m and an 8 minute walk away to the west of the site.

9 Bus service 226, operating between Ealing Broadway and can be accessed from Bodiam Way with stops located approximately 360m to the south of the site. In addition, bus service 224, providing access to and Willesden Junction is available from stops located on Twyford Abbey, approximately 500m from the proposed development.

10 As stated earlier in this report, London Underground stations; Hanger Lane (Central), Park Royal (Piccadilly) and Stonebridge Park (Bakerloo and Rail) are located between 1,050m and 1,500m away from the site, equivalent to approximately a 13 to 18 minute walk from the centre of the site. Neither of these stations are captured within the Public Transport Accessibility Level (PTAL) assessment as such, the site has been estimated to have a PTAL of two, on a scale of one to six, where six is most accessible.

page 2 11 In terms of strategic policy, the site is designated as Metropolitan Open Land and is also located in the Park Royal Opportunity Area Planning Framework. The gardens of Twyford Abbey form part of the opportunity area’s strategic network of open spaces and strategic connections.

12 The Council’s identifies the site as being an area of Nature Conservation Area and Heritage Land.

13 The surrounding character is a varied mix of significant post war development. To the south of the site is the first phase of the First Central masterplan development comprising three storey houses and apartment blocks with 4 storey frontage onto Twyford Abbey Road.

14 Residential areas to the east and west along Iveagh Avenue and Brentmead Gardens respectively, are predominantly 2 storey semi-detached houses dating from the inter war period. In the wider area, further east are industrial uses, two, nine storey hotels and office buildings presenting a significant landmark along this stretch of the North Circular.

15 To the west along Brentmead Gardens is St Mary’s Church, West Twyford, which is a modern brick built extension to the original church. The church to the east of the extension still maintains its historical relationship to the medieval manor house

Description of Listing Building

16 The vacant Abbey and its walled garden are statutory listed grade II and the Abbey itself is on English Heritage’s Register of Buildings at Risk; in terms of condition the building is graded as ‘very bad’ and in terms of priority it is graded category C (defined as “Slow decay; no solution agreed”).

17 The existing building on the site dates back to 1807-1809; the original two storey dwelling (south west part) built on the site of a former medieval manor house was designed by William Atkinson as an early 19th century Gothic revival building. In the mid- 19th century the dwelling was extended to the north and east. The Abbey was occupied as a single family house until the beginning of the 20th century when the house was converted into a home for the infirm. The building was considerably extended in 1904-5 by the provision of the northern western wing reflecting the Gothic appearance of the earlier building as well as extensions to the north and east of the building. More recent additions include a three storey infill between the original early 19th Century building and the Alexian Gothic extension on the north western side of the building replacing a former single storey conservatory and a three storey wing to the east built in the 1960’s. In addition to this, a Tree Preservation Order covers all trees on the site.

Details of the proposal

18 The applicant proposes the partial demolition of the grade II listed Abbey (the existing post war extensions detached ancillary structures and proposes to repair, refurbish and convert the grade II listed building and redevelop the wider site to provide for 92 residential units in total; 25 within the converted Twyford Abbey and 66 new build units in the abbey grounds. Case history

19 In March 2001, the former Mayor was consulted on an application for 121 residential units (PDU ref 0230/01); it was concluded that the application was contrary to strategic policy concerning development in MOL and local policy as a departure from the appropriate land uses identified in the UDP. The former Mayor was minded to direct refusal of the scheme.

page 3 20 In 2005 the former Mayor was consulted for another scheme involving the creation of 317 residential units, comprising 29 apartments within the converted Abbey and 288 additional units of which 222 would be affordable (PDU ref 0230/a/01). This application was subsequently refused by Ealing Council. Strategic planning issues and relevant policies and guidance

21 The relevant issues and corresponding policies are as follows:

 Housing London Plan; Housing SPG; Interim Housing SPG; draft Housing SPG; Housing Strategy; draft Revised Housing Strategy; Providing for Children and Young People’s Play and Informal Recreation SPG; draft Providing for Children and Young People’s Play and Informal Recreation SPG;  Affordable housing London Plan; Housing SPG; Interim Housing SPG; draft Housing SPG; draft Affordable Housing SPG; Housing Strategy; draft Revised Housing Strategy; draft Early Minor Alteration to the London Plan  Density London Plan; Housing SPG; Interim Housing SPG; draft Housing SPG  Urban design London Plan;  Parking London Plan; draft Early Minor Alteration to the London Plan; the Mayor’s Transport Strategy  Green Belt/MOL London Plan  Biodiversity/Geodiversity London Plan; the Mayor’s Biodiversity Strategy; draft Tree and Woodland Strategies; London’s Foundations (Geodiversity) SPG  Historic Environment London Plan; World Heritage Sites SPG; Circular 07/09  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

22 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 saved polices from the 2004 Ealing Unitary Development Plan, the 2012 Ealing Development (Core) Strategy and the 2011 London Plan.

23 The following are also relevant material considerations:  The National Planning Policy Framework and Technical Guide to the National Planning Policy Framework  The Early Minor Alteration to the London Plan

 The Park Royal Opportunity Area Planning Framework

 Ealing Development Sites DPD (publication version, 2011)

 Ealing Development Management and Policies Map DPD (publication version, 2011)

page 4 Principle of Development

Heritage Asset

24 Paragraph 128 of the NPPF states that in order to understand the impact of changes to the historic environment, applicants must first provide an assessment of its significance and an understanding of the heritage assets in question; heritage significance is emphasised as a common thread that occurs throughout section 12 of the document and is defined in NPPF, Annex 2. 25 In relation to heritage, London Plan policy 7.8 makes it clear that in planning decisions, where appropriate, development should conserve, restore and re- use heritage assets. 26 Twyford Abbey and its walled garden (separately listed) are included in the Statutory List of Buildings of Architectural and Historic Merit (Grade II). As noted in paragraph 16 of this report, the Abbey is identified on the English Heritage’s ‘Heritage at Risk’ register. 27 As part of the planning submission, the applicant has submitted a heritage statement which assesses the significance of Twyford Abbey and its setting. This document makes it clear that Twyford "Abbey" is not a monastic building, but it does stand on a medieval moated site that has associations with the nearby Church of St Mary. It dates from the Georgian period, and is the work of a notable architect, William Atkinson. The Abbey is part of a small estate containing a walled garden, an entrance Lodge, and other ancillary structures. The listed Abbey, the church and the walled garden have interrelated settings that extend throughout the estate. 28 The heritage assessment concludes that the buildings are of significant historical, evidential, communal and aesthetic value, and are of special interest and as a group, they are worthy of preservation. The current poor condition of the Abbey in particular is an indication that a scheme of conversion, restoration and enabling development is required in order to save its fabric. 29 The heritage significance of the Abbey has been clearly shown and within this context alone the principle of development relating to the restoration and re use of the listed building would be acceptable in strategic planning terms; however, with regards to principle of development, there are further strategic considerations which are set out the paragraphs 31 to 49 below. 30 Notwithstanding the above, the NPPF makes it clear that where there is evidence of deliberate neglect of or damage to a heritage asset, the deteriorated state of the heritage asset should not be taken into account in any planning decision. The applicant has not included any maintenance information within the planning submission and the Council will need to be satisfied in this regard. Metropolitan Open Land (MOL)

31 London Plan Policy 7.17 states that “the strongest protection should be given to London’s Metropolitan Open Land (MOL) and inappropriate development refused, except in very special circumstances, giving the same level of protection as in the Green Belt. Essential ancillary facilities for appropriate uses will only be acceptable where they maintain the openness of MOL.”

32 The policy guidance of paragraphs 79-92 of the National Planning Policy Framework (NPPF) on Green Belts applies equally to Metropolitan Open Land (MOL) in London. The (NPPF) states that the Green Belt serves five purposes:

 to check the unrestricted sprawl of large built-up areas;

 to prevent neighbouring towns merging into one another;

 to assist in safeguarding the countryside from encroachment;

page 5  to preserve the setting and special character of historic towns; and

 to assist in urban regeneration, by encouraging the recycling of derelict and other urban land.

33 Paragraph 87 of the NPPF states that inappropriate development is, by definition, harmful to the Green Belt and should not be approved except in very special circumstances. In addition, paragraph 89 of the NPPF states that ‘a local planning authority should regard the construction of new buildings as inappropriate in Green Belt’ and lists exceptions to this.

34 The application site is in designated MOL; the existing Abbey is located within the centre of the site and the listed walled garden to the north of this. There are no other hardstanding areas on the MOL site.

35 The applicant is proposing to develop, 66 new residential units (44 houses and 22 flats - up to four storeys) within the un-developed northern areas of the application site in order to negate the development costs associated with the restoration, conversion and reuse of the listed Abbey.

36 Residential development as proposed within the MOL is regarded as inappropriate development; however, the applicant considers that the enabling development needed to restore the Grade II listed Abbey as a heritage asset is regarded as ‘very special circumstances’ where development would be permitted.

37 In this regard, paragraph 140 of the NPPF states that local planning authorities should assess whether the benefits of a proposal for enabling development, which would otherwise conflict with planning policies but which would secure the future conservation of a heritage asset, outweigh the disbenefits of departing from those policies.

38 As published in the Park Royal OAPF, Twyford Abbey and its grounds are not publically accessible. The documents highlights that some enabling development would help deliver the objectives of this framework, including public access through the site, a better connection of spaces and the restoration of the listed building.

39 This is a finely balanced issue, concerning preservation of both a listed building and the character and qualities of metropolitan open land against the need to find a viable use to secure the future of both building and land and deliver the aspirations of the OAPF.

40 The problem which enabling development typically seeks to address is that the cost of maintenance, major repair or conversion to the optimum viable use of a building is greater than the resulting value to its owner or in the property market. This means that a subsidy to cover the difference, the ‘conservation deficit’, is necessary to secure its future. Enabling development will by definition involve a scheme which would otherwise be unacceptable in planning terms but is the only practicable means of generating the funds needed to secure the future of the heritage asset in question. It should also be the minimum amount of development required to restore the heritage asset.

41 In principle, the aim of identifying suitable land uses for enabling development should be to identify the optimum viable use that is compatible with the fabric, interior and setting of the historic building. This may not necessarily be the most profitable use if that would entail more destructive alterations than other viable uses.

42 In terms of demonstrating viable uses for enabling development the applicant has carried out a number of studies which have been included as part of the planning submission.

page 6 43 An initial hotel appraisal has been undertaken by the applicant as part of the planning submission. The report concludes that the appeal of a hotel in this location would be severely constrained by the accessibility and visibility issues; however, there are a number on concerns with the report’s robustness as set out below.

44 The report indicates that an assessment of the number of new bedrooms that may be required in the local area over a specified time period was not undertaken. The report also fails to identify any clear analysis between local hotel bedspace demand and number of assumptions in the report are made in the absence of evidence. The report also fails to undertake any viability testing for a such use.

45 The applicant has carried out a development and asset strategy which considers different land uses (healthcare, educational, employment retail and residential) for the Abbey and their associated development costs.

46 The report illustrates that without public subsidy (e.g. for some form of community use) or public purchase as, for example a Free School site, there is no use that could provide for a viable restoration of Twyford Abbey itself in isolation and that a residential development is likely to minimise the requirement for enabling development.

47 In terms of analysis of a hotel use, this report relies entirely on the initial hotel appraisal which is not considered to be robust. In addition, although a care home use has been considered as a future use, different types of residential development such as retirement homes and extra care accommodation or a mix of a number of uses has not been considered in the assessment.

48 The applicant has provided a viability assessment which explains that the rationale for the enabling development calculations upon which the development proposals for Twyford Abbey are based. The report establishes a conservation deficit based on the costs of restoring the listed building, walled garden and grounds and the gross development value derived from the restored Abbey following conversion to provide 25 new apartments and restoration of the gatehouse to provide a house. This figure is -£7,485,000 (rounded). The applicant has advised that in order to provide a viable scheme it will be necessary to provide a minimum of 66 enabling residential units of which 11 units (approximately 17%) can be affordable.

49 Before the principle of allowing enabling development on MOL can be deemed acceptable in strategic planning terms, further information regarding the justification that a purely residential scheme is the only viable use for enabling development on the site will need to be provided before the scheme is referred back to the Mayor at stage two.

50 In terms of quantum of development, the Council will need to independently assess the viability figures given and the applicant will need to provide evidence indicating that the 66 unit mix is indeed the minimum development in terms of footprint needed before the principle of developing 66 homes on MOL can be accepted.

In summary 51 The strategic policy context for Twyford Abbey is determined by its listed building status and the Metropolitan Open Land designation. The heritage significance of the grade II listed Abbey is acknowledged, the principle of restoring and re use of the building is accepted and the scheme would help to deliver the aspirations of the Park Royal OAPF; however provision of residential development on MOL is currently not acceptable. The provision of some enabling development on MOL could be acceptable once further information has been received regarding enabling development and calculations. In addition, the applicant will need to clearly show that 66

page 7 units as proposed, is the definitive minimum amount of development needed in terms of building footprint.

Housing 52 London Plan Policy 3.3, which seeks to increase London’s supply of housing and in doing so, sets a London-wide housing delivery target of 32,210 additional homes per year up to 2021. Table 3.1 sets borough housing targets, of which Ealing’s is 890 additional homes per year between 2011 and 2021. Policy 3.4 of the London Plan seeks to ensure that development proposals achieve the optimum housing output taking into account local context, the design principles of the London Plan and public transport capacity.

53 As set out in paragraph 50, currently the principle of residential development on this site is not acceptable.

Affordable housing

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

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

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

57 The Council has an overall affordable housing provision target of 50% as set out in the Council’s core strategy.

58 The applicant is currently proposing to deliver 11 affordable housing units, which in total equate to an overall affordable housing provision of 12 %, of which 5 units (2 x 2 bedroom units and 3 x 3 bedroom units) will be social rented accommodation and 6 x 1 bedroom units will be intermediate.

59 In order to comply with London Plan requirements, it is necessary to demonstrate that the maximum reasonable amount of affordable housing is being delivered. The applicant has submitted a financial viability report which will need to be independently assessed by the Council to confirm whether the applicant is providing the maximum reasonable amount of affordable housing in accordance with London Plan Policy 3.12. However given the priority in this instance to restore the listed building and the need to minimise the impact on the MOL, the GLA would

page 8 welcome a discussion with the Council and applicant to explore whether zero affordable housing would be appropriate in this instance.

Tenure split

60 London Plan Policy 3.12 seeks to ensure that 60% of the affordable housing delivered throughout the Plan period is social rented housing, and that 40% is intermediate provision. The Council, in its Core Strategy, establishes a broad tenure split for the affordable housing to be delivered over the plan period, seeking a 70/30 tenure split.

61 The applicant is proposing a 45.5/54.5 tenure split, which although is not policy compliant, in terms of numbers (5 and 6 units respectively), the difference a compliant scheme will deliver is not considered to be greatly different than the tenure mix currently put forward and therefore, on balance, the provision is acceptable. In addition, the applicant has appointed a preferred RSL for the scheme who have agreed to the current split.

Mix of Units

62 London Plan Policy 3.8 and the associated supplementary planning guidance promote housing choice and seek a balanced mix of unit sizes in new developments. The London Housing Strategy sets out strategic housing requirements and Policy 1.1C of the Strategy includes a target for 42% of social rented homes to have three or more bedrooms.

63 The overall proposed unit mix is given below:

Bed space Units proposed Total (%)

1 11 12

2 26 28.5

3 16 17.5

4 25 27

5 13 14

Total 91 100

64 As can be seen from the above table, overall the scheme is providing 58.5% family accommodation, which is supported; however, within the affordable element this percentage is 27%. In terms of strategic policy, the proposed housing mix is welcome, although the scheme currently fails to provide an adequate amount of affordable family accommodation. Before the application is reported back at Stage 2, the applicant will need to consider including an increase of affordable family units and any consequences on viability when doing so to meet London Plan policies 3.8, 3.11 and the Housing SPG.

65 Notwithstanding this, the applicant will need to demonstrate further, how the overall mix meet Ealing’s housing aspirations and reflects local demand.

page 9 Housing quality

66 Policy 3.5 of the London Plan introduces a new policy on the quality and design of housing developments. Part A of the policy states that housing developments should be of the highest quality internally, externally and in relation to the wider environment. Part C of the policy states that new dwellings should generally conform with the dwelling space standards set out in Table 3.3, have adequately sized rooms and convenient and efficient room layouts. Part E of the policy states that the Mayor will provide guidance on implementation of this policy including on housing design for all tenures. The reasoned justification provides further guidance and explanation. In particular, paragraph 3.32 makes clear that “Securing new housing of the highest quality and protecting and enhancing residential neighbourhoods are key Mayoral priorities”. The Mayor’s draft Housing Design Guide (July 2009) and the draft replacement Housing SPG (December 2011), provides further guidance on the implementation of these policies.

67 The 25 new apartments in the retained Abbey building manage to generally comply with the residential standards, despite also retaining much of the internal fabric of the building. This is supported. Both the converted and new-build dwellings exceed the space standards as set out in table 3.3. Given that all dwellings would be accessed from a single, winding street, a clear on-site legibility strategy should be set out.

68 Not withstanding this, the applicant will need to provide a clear definitive figure as to the total amount of single aspects units which will be delivered on site. The applicant will also need to demonstrate how good levels of ventilation, daylight and privacy will be provided in each habitable room where single units are proposed and that no single aspect units contain three or more bedrooms in order for the scheme to be considered policy compliant in strategic terms.

69 The main residential quality concern is the likelihood of noise amenity issues to residential dwellings, emanating from the North Circular. Pre-application design changes resulted in the revision of some layout details, and an acoustic screen is proposed along the northern boundary. This solution is less preferable than ‘designing out’ the problem through additional llayout and landscape changes. The Mayor will need to be certain that the proposed barrier, which will exceed 1.8m height, will not have a detrimental impact on the character of the site. Details of materials should be provided.

Density

70 London Plan Policy 3.4 requires development to optimise housing output for different locations taking into account local context and character, design principles set out in London Plan Chapter 7 and the public transport capacity; London Plan Table 3.2 provides density guidelines in support of this. The site has a public transport accessibility level (PTAL) of two on a scale of one - six, where six is most accessible. The site lies in a primarily suburban setting, as defined by the London Plan and therefore a density range of 150-250 habitable rooms per hectare should be applied to the scheme as indicated by Table 3.2.

71 The applicant has not given any density figures; the applicant will need to supply such information before the scheme is referred back at stage two to ensure compliance with London Plan policy 3.4.

Children’s play space

72 Policy 3.6 of the London Plan sets out that “development proposals that include housing should make provision for play and informal recreation, based on the expected child population generated by the scheme and an assessment of future needs.” Using the methodology within the Mayor’s supplementary planning guidance ‘Providing for Children and Young People’s Play and

page 10 Informal Recreation’ it is anticipated that there will be approximately 43 children within the development. The guidance sets a benchmark of 10 sq.m. of useable child playspace to be provided per child, with under-5 child playspace (190 sq. m.) provided on-site. As such the development should make provision for 430sq.m. of playspace.

73 The scheme includes the provision of a generous area of public open space to be located in the meadow on the south side of Twyford Abbey. The applicant has stated that the scheme will provide for opportunities for incidental play on landscaped features located around the site.

74 Despite this, the applicant has not prepared a play strategy or indicated specific figures for child play space provision; therefore currently the proposals do not meet policy 3.6 and should be addressed accordingly by the applicant.

Urban design

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

76 As set out in paragraph 50 of this report, the restoration of the main listed building (the Abbey and its attached buildings) is welcomed in principle, and the provision of a sustainable reuse of the building, to ensure its protection and maintenance in the future, is supported. Likewise, maintenance of the surrounding lands and restoration and enhancement of important aspects and views will be supported.

77 Arguably the most important views of the main listed building are those from Twyford Abbey Road and within the site from the south, with the front facade of the oldest part of the building as the focus. The development does preserve these views. The visual relationship between the Abbey and the adjacent church is also retained. However, there are concerns that the impact of the new buildings and landscaping has not been sufficiently demonstrated within the application to have no detrimental impact on the views. Specifically, the new residential buildings (those which are closest to the listed building to its north-west and north-east) should be shown in a composite image viewed from the south, taking into account new landscaping (in both summer and winter states) and parking. This modelling is required to ensure that the Mayor is satisfied that the most important feature of the site retains its visual integrity.

Layout

78 The proposal does not lay out the new terrace rows in full streets, and offers front-to-back layouts in some instances. However this is necessary to provide a suitable setting to the walled garden, including its approach and main axes through the site. The siting of back gardens against existing external boundary back gardens is welcomed.

79 The layout of the proposed development, notwithstanding the concerns relating to residential quality, is acceptable. It is noted that other layout options would push residential development closer to the North Circular, and that this would have residential quality (noise) implications. The retention of the historic single access route is welcomed.

page 11 80 There are some initial concerns regarding the scale of the new buildings and their relationship with the retained listed building; although storey heights of original buildings are substantially greater than those of the new buildings (for example, the two storey elements of the retained building are 11.5m, and the three storey elements 14.2m), surrounding buildings would be 3 storeys (approximately 10m). The concerns relate to whether these buildings were suitably deferential to the primacy of the main listed building. The relatively simple appearance compared with the ornamentation and style of the retained building, and identifiably different massing of the new buildings do set them apart; however additional visual material further demonstrating the relationship between old and new buildings, to the benefit of the protection of the character and the setting of the listed building, would be welcomed.

81 The layout of the new residential zone is acceptable and appears open, as a result of the good level of open space. As mentioned above, consolidation of this area would likely have noise amenity implications, given the proximity of the North Circular. The renovation of the walled garden and its setting at the centre of the new residential zone is welcomed. Further information on the impact (visibility) of the new buildings from within the walled garden, and the resulting impact on its character, should be submitted before the scheme is referred back to Mayor at stage two in order to meet London Plan policies 7.1 and 7.6.

82 The proposed appearance and landscaping details are generally sympathetic with the character of the site and the retained buildings.

Inclusive access

83 London Plan Policy 7.2 seeks to ensure that proposals achieve the highest standards of accessibility and inclusion (not just the minimum) to ensure that developments can be used safely, easily and with dignity by all regardless of disability, age, gender, ethnicity or economic circumstances. Policy 3.8 requires that all new housing is built to Lifetime Homes standards and that 10% of new housing is designed to be wheelchair accessible or easily adaptable for residents who are wheelchair users.

84 The applicant has committed to achieving Lifetime Homes standards for all units proposed which is supported and is in accordance with London Plan Policy 3.8. The Council should secure compliance with Lifetime Homes Standards through planning condition.

85 The applicant states that the proposals meet the 10% wheelchair accessible unit requirement. Whilst this commitment is welcomed, it is not clear specifically where these units are located, how many there are and therefore it cannot be seen if the provision is distributed across tenure types and unit sizes to ensure disabled and older people have similar choices to non- disabled people. Further detail should be provided before the scheme is reported back at Stage 2 in order to demonstrate the 10% requirement is achievable in order to fully satisfy Policy 3.8.

Climate change

86 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.

page 12 Climate chance mitigation

87 The London Plan climate change policies as set out in chapter 5 collectively require developments to make the fullest contribution to tackling climate change by minimising carbon dioxide emissions, adopting sustainable design and construction measures, prioritising decentralised energy supply, and incorporating renewable energy. The policies set out ways in which developers must address mitigation of, and adaptation to, the effects of climate change.

88 Policy 5.1 and 5.2 of the London Plan seek to achieve an overall reduction in London’s carbon dioxide emissions through a range of measures including using less energy, supplying energy efficiently and using renewable energy, improving on Building Regulations targets by 25% in the period 2010-2013.

Energy efficiency standards

BE LEAN 89 A range of passive design features and demand reduction measures are proposed to reduce the carbon emissions of the proposed development. Both air permeability and heat loss parameters will be improved beyond the minimum backstop values required by building regulations. Other features include energy efficiency lighting. The demand for cooling will be minimised through the use of mechanical extract ventilation.

90 Based on the information provided, the proposed development does not achieve any carbon savings from energy efficiency alone compared to a 2010 Building Regulations compliant development.

91 The applicant should model additional energy efficiency measures and commit to the development exceeding 2010 Building Regulations compliance through energy efficiency alone.

District heating BE CLEAN 92 The applicant has carried out an investigation and has identified that there are no suitable existing or planned district heating networks within close enough vicinity of the proposed development. The Brentford Dock Estate district heating network is the nearest network to the site; direct connection to this network is not currently viable die to the considerable distance from the site.

93 The applicant should provide a commitment to ensuring that the development is designed to allow future connection to a district heating network should one become available.

94 The applicant has discounted implementing an onsite heat network. This is contrary to London Plan policies. The applicant should commit to an onsite heat network linking all apartments served from a single energy centre. A drawing showing the route of the heat network linking all buildings on the site should be provided. Details of the floor area and location of the energy centre should be provided.

Combined Heat and Power (CHP) 95 The applicant has investigated the feasibility of CHP. Due the scale of the development and intermittent nature of the heat load, CHP is not proposed. This is accepted in this instance. Details of the how the development will be heated should be provided.

page 13 BE GREEN Renewable energy technologies 96 The applicant has investigated the feasibility of a range of renewable energy technologies and is proposing to install approximately 800 sq. m. (86 kWp) of photovolatics (PV) across all buildings.

97 A reduction in regulated carbon dioxide emissions of 35 tonnes per annum (27%) will be achieved through this third element of the energy hierarchy.

98 In summary, the estimated regulated carbon emissions of the development are 96 tonnes of carbon dioxide per year after the cumulative effect of energy efficiency measures, CHP and renewable energy has been taken into account.

99 This equates to a reduction of 32 tonnes of carbon dioxide per year in regulated emissions compared to a 2010 Building Regulations compliant development, equivalent to an overall saving of 25%. The carbon dioxide savings meet the targets set within Policy 5.2 of the London Plan.

Climate change adaptation

100 The London Plan Policies 5.9 – 5.15 promote the key principles of climate change adaptation including overheating and cooling, urban greening, green roofs and water management.

101 Policy 5.9 seeks to deal with the issue of overheating and sets out a cooling hierarchy. Policy 5.10 promotes urban greening. Policy 5.11 seeks major developments to incorporate living roofs and walls where feasible. Policy 5.13 seeks to ensure that surface water run-off is managed as close to its source as possible and sets out a hierarchy of preferred measures to achieve this. Policy 5.15 seeks to ensure that new development has proper regard to the impacts on water demand and existing capacity by minimising the use of treated water and maximising rainwater harvesting. Further guidance on this policy is given in the London Plan supplementary planning guidance ‘Sustainable Design and Construction’.

102 Design standards are summarised in Annex 2.1 of the Mayor’s draft Housing SPG which states that all new residential development should accord with Code for Sustainable Homes Level 4 in line with London Plan policy 5.3. In particular, part 2 of the draft SPG, that affordable housing should meet Code for Sustainable Homes Level 4 from 2011.

103 It is understood that the applicant commits to achieving Code for Sustainable Homes (CfSH) “Level 4” which is supported and the scheme complies with London Plan policy 5.3 and strategic guidance.

104 Further information is needed as to how the scheme will reduce surface water run-off and provide for measures to ensure water efficiency.

Air quality

105 London Plan policy 7.14 seeks to ensure that development proposals aim to be air quality neutral and not lead to further deterioration of existing poor air quality; that offsetting should be used to ameliorate negative impacts associated with development proposals, and that increased exposure to existing poor air quality should be minimised.

106 The Mayor's Air Quality Strategy (Dec 2010) and the London Plan aims to ensure that new developments shall as a minimum be 'air quality neutral' through the adoption of best practice in the management and mitigation of emissions. Mitigation measures could include, but is not limited

page 14 to: best available technologies in managing emissions to air, local air quality management support (financial contribution to borough local air quality management activities), travel plan, vehicle retrofits/alternative fuel use. Low and zero carbon energy supply for London should not be significant in terms of local air quality impact and should create opportunities to improve local air quality.

107 The applicant has submitted an amended air quality assessment which is found to be in line with London Plan policies. The assessment indicates that the scheme will be air quality neutral once the development is operational. The scheme has also been designed taking into account issues of air quality in relation to the traffic along the North Circular.

108 The application site is located in an area which is already designated as an AQMA and therefore it can be said that provision of residential uses in this location will expose future residents to poor air quality. The applicant should consider appropriate mitigation measures before the scheme is referred back to the Mayor.

Transport

Transport assessment

109 Details of the TRICS and TRAVL sites chosen are required to allow TfL to determine whether a robust assessment has been undertaken in line with London Plan policy 6.3. Furthermore, considering that the TRAVL database is recognised as the most common and often most useful source of travel survey data in London, justification is required for the use of the TRICS database.

Modelling

110 TfL has concerns with regards to the LINSIG Models for the Abbey Road and Twyford Abbey Road junction. The models show that the degree of saturation is over 100% for this junction, this is not technically possible and therefore further discussion is required with the applicant to ensure that the correct methodology has been adopted.

111 In addition, taking into consideration that this junction is already operating close to capacity the applicant is encouraged to engage with TfL, Ealing Council and Brent Council to identify mitigation measures to ensure that the development will have nil detriment to the local highway network.

Car parking

112 A total of 130 car parking spaces and will be provided to serve the 92 residential units. This is equivalent to a car parking ratio of 1.3 spaces per unit.

113 Before TfL can consider whether this level of provision is in line with London Plan policy 6.13, clarification is required how spaces will be allocated between the spectrum of unit sizes. In addition, further information is required regarding the proposed provision and location of the disabled parking on site.

114 Electric vehicle charging points (EVCPs) are also required on site, the applicant will need to demonstrate to TfL how the London Plan standards can be pragmatically applied across the site to ensure that the EVPCS will be fully accessible to all units.

page 15 Cycle parking

115 Cycle parking is proposed on site however confirmation is required regarding both their quantum and location before TfL can consider whether the application complies with London Plan policy 6.9.

Walking

116 To ensure conformity with London Plan policy 6.10 ‘Walking’ it is recommended that an audit of the pedestrian environment is undertaken in order to assess the current provision for pedestrians and to identify any areas in need of improvement to be secured via the s106 agreement. Any deficiencies such as lack of dropped kerbs, tactile paving or appropriate pedestrian crossing facilities at junctions should be highlighted so that an appropriate contribution can be set to address the deficiencies that are identified.

Buses

117 Given the scale of the proposed development TfL considers that any impact on the bus network will be negligible and that there is sufficient capacity to cope in the minor uplift in bus passenger trips.

118 However to comply with London Plan policy 6.7 and to promote inclusive accessibility to all users of the proposed development, the applicant is required to undertake an audit of the two closest bus stops to the site (bus stops ‘BP209’ and ‘BP208’ located on Tudor Estate) and identify any schedule of works required to bring them up to current accessibility standards as per TfL Bus Priority Team Technical Advice Note BP1/06 available from TfL’s website: http://www.tfl.gov.uk/assets/downloads/businessandpartners/accessibile_bus_stop_design_guid ance.pdf. Upon TfL’s receipt of the audit, a capped contribution of £10,000 per bus stop maybe requested to ensure full compliance with accessibility guidelines.

Construction, deliveries and servicing

119 Refuse vehicles will serve the residential units on site. TfL is satisfied that the provided swept path analysis demonstrates that all vehicular movements can be undertaken safely without any detrimental impact on the local highway network.

120 A delivery and servicing plan is required, this should be secured by condition and submitted to the planning authority for approval prior to occupation. The plan should be linked to the travel plan in line with TfL’s new travel plan guidance available from: http://www.lscp.org.uk/newwaytoplan/resources/file/Travel%20planning%20for%20new%20dev elopment%20in%20London.pdf

121 To ensure full compliance with London Plan policy 6.14 ‘Freight’ a construction and logistics plan (CLP) will be required. The CLP should be a standalone document that enables construction impacts to be managed, minimising impact on the highway network and transport system. This will need to be secured by condition and approved by Ealing Council in consultation with TfL prior to the commencement of any construction.

Travel planning

122 A draft travel plan has provided, this has passed the ATTrBuTE assessment and TfL therefore expects that Ealing Council to secure, enforce, monitor, review and ensure the funding of the travel plans through the s106 agreement to ensure conformity with London Plan policy 6.3.

page 16 123 In summary, the information provided within the TA relating to trip generation, car parking and cycle parking is limited, in addition the local modelling appears flawed therefore further information needs to be submitted to allow TfL to fully ascertain whether the proposals comply with London Plan policy. In addition, a local bus stop and walking infrastructure audit needs to be undertaken and a DSP and CLP should both be secured by condition.

Community Infrastructure Levy (CIL)

124 The Mayor has introduced a London-wide Community Infrastructure Levy (CIL) to help implement the London Plan, particularly policies 6.5 and 8.3. The Mayoral CIL formally came into effect on 1 April 2012, and it will be paid on commencement of most new development in Greater London that was granted planning permission on or after that date. The Mayor's CIL will contribute towards the funding of Crossrail

125 The Mayor has arranged boroughs into three charging bands. The rate for Ealing Council is £35sq.m. The required CIL should be confirmed by the applicant and council once the components of the development or phase thereof have themselves been finalised. See the 2010 regulations: http://www.legislation.gov.uk/ukdsi/2010/9780111492390/contents as amended by the 2011 regulations: http://www.legislation.gov.uk/uksi/2011/987/made

126 London borough councils are also able to introduce CIL charges which are payable in addition to the Mayor’s CIL. Ealing Council has yet to adopt a scheme.

Local planning authority’s position

127 Ealing Council’s position is unknown at this time.

Legal considerations

128 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. 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

129 There are no financial considerations at this stage.

Conclusion

130 London Plan policies on the principle of development, urban design, inclusive access, climate change and transport are relevant to this application. The application complies with some of these policies but not with others, for the following reasons:

 Principle of development: The principle of enabling residential development on MOL is contrary to policy 7.17 of the London Plan.

page 17  Affordable housing: In the absence of an independent appraisal of the applicant’s financial viability report regarding the affordable housing offer, the scheme fails to comply with policy 3.12 of the London Plan

 Housing mix: The current mix of units is unacceptable and needs to be reconsidered for the scheme to meet policy objectives set out in London Plan policy 3.8 and 3.11.

 Housing density: Further information is sought for the proposal to be consistent with London Plan Policy 3.4 and table 3.2.

 Urban design: Further information is sought for the proposal to be consistent with London Plan policies 7.1, 7.2, 7.4, 7.6 and 7.17.

 Child play space: The applicant should submit further information with regards to the children’s play space provision in order to ensure compliance with London Plan policy 3.6.

 Inclusive design and access: The applicant has committed to meeting Lifetime Homes standards and provides 10% wheelchair accessible units; however more information is needed before the scheme can be found to be acceptable and in line with London Plan Policy 7.2.

 Climate change mitigation and adaptation: The scheme is found to be in accordance to London Plan policy 5.2 and other chapter five policies of the London Plan.

 Transport: The scheme could be acceptable in transport terms; further work is required by the applicant in order to fully comply with the London Plan.

131 On balance, the application does not comply with the London Plan.

132 The following changes might, however, remedy the above-mentioned deficiencies, and could possibly lead to the application becoming compliant with the London Plan:

 Principle of development: Further justification is needed in order to demonstrate ‘very special circumstances’ to accept development on MOL.

 Affordable housing: An independent appraisal of the applicant’s financial viability report will need to be carried out before the application is reported back at Stage 2.

 Housing mix: The unit mix should be revised to provide an increased proportion of family-sized units within the affordable provision.

 Housing density: The applicant should submit density figures for the scheme.

 Urban design: The applicant will need to submit further information as set out in paragraphs 75 to 81 of this report.

 Child play space: The applicant will need to submit further information and a childs pay strategy in line with London plan policy 3.6.

 Inclusive design and access: Further information is needed before the scheme is reported back at Stage 2 to understand the location of the proposed wheelchair accessible units in line with London Plan Policy 7.2.

page 18  Transport: Further information needs to be submitted to allow TfL to fully ascertain whether the proposals comply with London Plan policy. In addition, a local bus stop and walking infrastructure audit needs to be undertaken and a DSP and CLP should both be 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] Lucy Bird, Case Officer 020 7983 5826 email [email protected]

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