planning report PDU/2757b/01 26 September 2012 Reynard Mills Trading Estate, in the Borough of planning application no.P/2012/2147

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 An outline application for demolition of the existing buildings and a redevelopment of the site to provide 229 residential units, with all matters other than access and layout reserved for future consideration. The applicant The applicant is LP (Brentford) Ltd and the architect is Hindle Architecture + Design.

Strategic issues The application raises a number of strategic matters including the loss of industrial land and employment, housing mix, affordable housing provision, urban design and housing quality, density; children’s play space, inclusive access, sustainable development, flood risk management, employment and training; and transport.

Recommendation That Hounslow 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 114 of this report; but that the possible remedies set out in paragraph 115 of this report could address these deficiencies.

Context

1 On 16 August 2012 the Mayor of London received documents from Hounslow 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 26 September 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 1A of the Schedule to the Order 2008: “Development which comprises or includes the provision of more than 150 houses, flats, or houses and flats.”

page 1 3 Once Hounslow Council has resolved to determine the application, it is required to refer it back to the Mayor for his decision as to whether to direct refusal; take it over for his own determination; or allow the Council to determine it itself.

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

5 The roughly rectangular site is approximately 2.41 hectares in size and situated behind a row of terraced house along the B452 Windmill Road in north Brentford. It is occupied by a number of old industrial/warehouse buildings with ancillary offices, all except two of which are presently vacant. It is also parallel to, but set back from Windmill Road, with both orientated in a north-west to south-easterly direction.

Figure1: Site location plan - Source: Tate Hindle Architecture and Design.

6 The ‘backland’ site has no direct frontage onto any road and is bounded on all sides by built development, comprising the premises of Catholic School for Boys on the north- west; the rear gardens of a row of two-storey terraced houses fronting Windmill Road on the north-east; St Faith’s Church Hall and Vicarage abuts the south east; whilst the three-storey apartment blocks of Manor Vale, the premises of Our Lady and St John’s Roman Catholic primary and nursery school, and a modern block of flats that form part of Thames Valley University’s Paragon campus separate the site from Boston Manor Road on its south-western side.

7 There are two access points to the site off Windmill Road (B452); one in the north east and one in the south east corner of the site. The A4 (Great West Road) is a short distance away, providing access to the M4 and beyond.

page 2 8 The surrounding area is predominantly residential in character, interspersed by a mixture of playing fields, schools and a few small-scale business/commercial uses. The elevated section of the is situated south of the application site, providing a link between Central London to the east and Heathrow Airport to the west.

9 The nearest Transport for London Road Network (TLRN) is the A4 Great Western Road, located approximately 250m south. The nearest Strategic Road Network (SRN) is the High Street A315, located 700m to the south.

10 The bus route E2, providing services between Brentford to the south and Greenford to the north serves Windmill Road with stops in close proximity to the site. Rail services can be accessed from Brentford Rail station, 800m to the south, providing direct links towards Waterloo to the east and Twickenham to the west. The closest (LU) station is Northfields () which is approximately 1km from the site to the north. Further bus services can be accessed from Little Lane / Northfield Avenue and Boston Manor Road. It should be noted that these bus services and Northfields LU station are outside the respective public transport accessibility level (PTAL) threshold distances. As such, the PTAL of the site is 2, on a scale where 1 is lowest and 6 is highest.

Details of the proposal

11 Outline permission is sought for the principle, access and layout of a residential development of up to 229 dwellings. All other matters are reserved for future consideration.

12 The planning statement states that as an outline application is submitted, the exact number of residential units, including the proposed quantum and mix of affordable housing, to be delivered on site is yet to be finalised. For the purposes of assessment it is anticipated that the overall number of dwellings will not exceed 229.

13 The application proposes amendments to a scheme that was previously refused (see case history below).

14 The planning statement states that the key changes in the revised scheme are as follows:

 One storey reduction on three apartment block buildings;

 Removal of a terrace of eight houses

 Expanded area of public open space, creating an open, green and welcoming entrance to the site from the southern access

 Reduced street level car parking Case history

15 There is an extensive planning history relating to the application site.

16 At the end of 2011, an outline application was submitted for demolition of the existing buildings and a redevelopment of the site to provide 275 residential units, with all matters other than access and layout reserved for future consideration. The application was considered by the Deputy Mayor in January 2011 as a Stage 1 (PDU/2757a/01) and the scheme did not fully comply with the London Plan. Possible remedies were suggested in relation with employment relocation and skills training strategy, independent review on the level of affordable housing, urban design, sustainable development, transport, inclusive design and a separate pedestrian access.

page 3 17 Hounslow Council refused the application in April 2012 on five grounds, density and excessive amount of development and the relationship of the site to neighbouring properties, internal street scenes that are dominated by car parking and the scheme fails to provide sufficient areas of good quality amenity space, failure to provide adequate levels of off-street parking, the fourth and fifth reasons for refusal were related to the absence of a completed legal agreement. This application does not appear to have been referred back to the Mayor, as required by Article 5 of the Order 2008.

18 Whilst the applicant does not agree with these reasons for refusal, and an appeal has been submitted (appeal reference APP/F5540/A/12/2177852), the applicant has put forward the current application to provide a scheme which positively responds to the Council’s concerns.

19 A similar outline planning application for redevelopment of the site to provide up to 315 dwellings (PDU/2757/01) was considered by the Mayor in August 2011, which raised the following issues: the need for an independent review of the affordable housing proposal, a children’s play strategy, an employment strategy for any displaced employees, additional transport provisions and further information on energy provisions. Subsequently, the application was withdrawn.

20 The site has a history of continuous commercial (predominantly industrial and storage) usage dating back to the mid 1930s. The planning history indicates that it was subsequently used for the storage of film archives by the BBC from 1978 until recently, when the corporation vacated the site following an estate-restructuring programme. The site is predominantly vacant at present. Strategic planning issues and relevant policies and guidance

21 The relevant issues and corresponding policies are as follows:

 Principle of development London Plan  Loss of employment London Plan; Industrial Capacity SPG; draft Land for Industry and Transport SPG  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  Density London Plan; Housing SPG; Interim Housing SPG; draft Housing SPG  Urban design London Plan;  Access London Plan; Accessible London: achieving an inclusive environment SPG; Planning and Access for Disabled People: a good practice guide (ODPM)  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  Transport/parking London Plan; the Mayor’s Transport Strategy; Land for Transport Functions SPG, draft Land for Industry and Transport SPG

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 2003 Hounslow Unitary Development Plan (including

page 4 Adopted Alterations 2001), the 2008 Hounslow Employment Development Plan Document, the 2009 Brentford Area Action Plan 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 Hounslow Core Strategy Development Plan Document, July 2011 - (Preferred Options Stage, with limited weight)  The draft Revised Early Minor Alteration to the London Plan Land use / residential use and loss of employment

24 The site has no specific land use designation in the London Plan. It is entirely within the boundary of the Brentford Area Action Plan, but has no specific designation in that document. It is also subject to the policies of the Hounslow Employment DPD, which supersede the Council’s UDP employment policies and provide at policy EP 8 that changes of use from industrial, warehousing and related uses on sites not identified as a Preferred Industrial Location, Industrial Business Park or Local Significant Industrial Site (Refer to Annex 1 and Proposals Map) would be acceptable, provided they fulfil the following criteria:

 The existing use of the site for industrial/warehousing uses is detrimental to the amenity of the surrounding area.

 Evidence is provided of the active marketing of the site for industrial and warehousing uses for a period of at least one year.

 The site does not contribute significantly to industrial supply and economic diversity, either individually or cumulatively.

 Surrounding industrial sites are not undermined for industrial uses.

25 The policy indicates that housing, education and/or community uses would be considered as alternative uses in the first instance, provided the above criteria are met.

26 This land-locked site abuts the boundaries of sensitive residential and school users. Whilst the last predominant but unique use of the site by the BBC did not require frequent 24-hour access by HGVs or other large vehicles, there is potential that an alternative industrial or warehousing use may require a wider access or greater manoeuvrability into the site for potentially noisy or dust- generating operations, detrimental to the amenity of surrounding residential and educational premises. The continued use of the site for such purposes could, therefore, be harmful to the amenity of neighbouring occupiers.

27 The application is supported by a full marketing report prepared by a locally based chartered surveyor on behalf of the applicant. The report provides clear evidence that several units on the premises have been marketed since 2007, at rents favourably comparable to those of more modern and better located stock in the Brentford area; together with evidence of the poor demand for the dated industrial accommodation which is wholly unsuited to contemporary business requirements.

28 By reason of its small size (2.41 hectares), poorly accessible location and the lack of potential for servicing and other business generation, the application site makes little or no significant contribution to the borough’s healthy supply of industrial land, which relates predominantly to Heathrow Airport and where research by Savills National Development indicates

page 5 an availability equivalent to over five years’ supply at the 2009 take-up rate. A similar level of availability is reported within the wider vicinity of the site itself, where 51 industrial units offer more than five years’ supply excluding potential future additions. For the borough as a whole, the research estimates some four years’ supply from 209 units at 2009 take-up rates. It is evident from this that there is a good supply of industrial land at local and borough levels, and that the release of the Reynard Mills Estate would not affect the strategic reserve of such land.

29 Relocation strategy: The applicant has submitted a statement for the two remaining businesses within the Reynard Mills Trading Estate to relocate. In this statement it is stated that Units RM+1 and RM+2 are twin brick built office/technology buildings. They are each 554.16sqm (NIA). The buildings contain office spaces, meeting rooms and technology areas. The buildings have been occupied since late 2010 by Guided Ultrasonics. The company uses the accommodation predominately for research and development and associated offices. The applicant in its relocation strategy report provided a study of alternate sites (in appendix 3 & 4 of that report), and demonstrated that there are a number of local buildings available into which the current tenants of Reynard Mills Trading Estate could relocate. The Council should ensure that the proposed relocation strategy is acceptable.

Conclusion

30 From a strategic planning perspective, it is clear from the foregoing that there are no policy objections to the loss of employment-generating uses on this predominantly vacant site; similarly the proposals are considered to fulfil the local policy criteria for a change of use from industrial, warehousing and related uses on a sites not identified as a Preferred Industrial Location, Industrial Business Park or Local Significant Industrial Site. The principle of a residential redevelopment of the site is, therefore, acceptable. Housing

Targets

31 London Plan policy 3.3 (Increasing housing supply) affirms the Mayor’s determination to work with relevant partners to increase London’s housing supply by an average 32,210 net additional homes to meet the need identified in the plan, enhance the environment, improve housing choice and affordability, and to provide better quality accommodation for Londoners. To achieve that figure, the London Plan indicates a target of 4,750 new homes for Hounslow over the ten-year period from 2011 to 2021, with an annual target of 470 units.

32 More specifically the Brentford Area Action Plan makes provision for the delivery of 2,100 additional homes within its boundary by 2018, including development on major new sites along the Great West Road during that time.

33 The delivery of 229 homes on the application site represents almost half of the strategic yearly target for the borough as a whole and is therefore supported in London Plan policy terms.

Density

34 The scheme now provides 229 residential units, equating to a unit per hectare density of 95 and a habitable room per hectare density of 308. It fits comfortably within the density guidance of the London Plan, for a site which has an urban setting and a PTAL 2. In the previous (refused) scheme the density was 114 units (or 367 habitable rooms) per hectare. Therefore, the reduction in density is welcomed.

page 6 Housing quality/space standards

35 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 meet the minimum 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 interim Housing Design Guide (July 2009) and the draft replacement Housing SPG (December 2011), provides further guidance on the implementation of these policies.

Table: Residential accommodation schedule of the development (Source: applicant’s planning statement)

36 A reasonably high proportion of dual-aspect dwellings are proposed within the development and all dwellings would be provided with private outdoor space, either as a garden, terrace or balcony.

37 The total internal space for different units types, together with the indicative floorplans suggest that individual units will meet the minimum space standards set out in Table 3.3. However, given the outline nature of the scheme the Council should secure by condition, that the minimum space standard for each unit is met.

page 7 Housing choice

38 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, the draft revised Strategy sets out that 36% of affordable rented homes allocated funding in 2011-15 will have three or more bedrooms.

39 The planning statement states that as the application for redevelopment is being submitted in outline, an indicative affordable housing dwelling mix is not provided at this stage.

40 That said, in the application form it is indicated that the proposals will have the following housing mix:

Unit type Market Social Intermediate Total unit % Housing Rented Housing type

Flats (1-bed) 45 11 8 64 28 Flats (2-bed) 62 18 15 95 41.5 Flats (3-bed) 16 0 8 24 10.5 Houses (3-bed) 46 0 0 46 20 Total 169 29 31 229 100

41 The proposal includes a total of 70 family-sized dwellings (46 townhouses and 24 three bedroom apartments), ensuring that a significant level of larger, family-sized units is delivered. This is over 30% of the overall development. However, only 13% of the affordable units are family sized and all of these are intermediate. This requires further discussion with Council and applicant to determine whether this best meets the Council’s housing needs. That said, the affordable housing document suggests a different mix (see the affordable housing section), this will need to be clarified.

42 Furthermore as this is an outline application an appropriate unit mix should be secured by condition. Children’s play space

43 Policy 3.6 of the London Plan sets out that “development proposals that include housing should make provision for play and informal recreation, based on the expected child population generated by the scheme and an assessment of future needs.” Using the methodology within the Mayor’s supplementary planning guidance ‘Providing for Children and Young People’s Play and Informal Recreation’ it is anticipated that there will be approximately 57 children within the development. The guidance sets a benchmark of 10 sq.m. of useable child play space to be provided per child, with under-5 child playspace provided on-site. As such the development should make provision for 570 sq.m. of play space.

44 This development proposes specific play areas located in the south eastern play park and on the southern deck. These spaces have a combined area of approximately 900sqm, with different characters and providing distinct play destinations. Additionally, play lawns of around 700sqm, are set over the deck and include sculptural play elements; informal ‘LAP’ (Local Area for Play) type play zones. This is welcomed and acceptable.

page 8

Affordable housing

45 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%.

46 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.

47 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.

48 It is understood that the Council’s target is for 50% of these new homes to be affordable although this may be affected by the need to deliver larger family units.

49 The applicant’s position on affordable housing is unclear. The application form suggests that 26.2% will be affordable with a tenure split of 48:52 social: intermediate, with no affordable rent.

50 However, in the planning statement (page 8) it is stated that as an outline application is submitted, the exact number of residential units, including the proposed quantum and mix of affordable housing, to be delivered on site is yet to be finalised. An indicative unit mix is given to aid assessment and better articulate the proposal, but this does not identify and affordable split. The applicant states that the amount of affordable housing will be negotiated and agreed with Hounslow Planning Officers. Then in (page 29) of the planning statement it is stated that the proposal provides 25% affordable housing by habitable room and 26% affordable housing by unit.

51 However, in the affordable housing document (dated July 2012 / Feb 2012), the applicant has proposed the following:

 25% affordable housing by habitable room, with a tenure split of 45:55 (by habitable room) in favour of shared ownership accommodation;  Affordable rent unit mix of 13 x 1 bed and 22 x 2 bed apartments; and  Shared ownership unit mix of 10 x 1 bed, 18 x 2 bed and 10 x 3 bed apartments.

52 As there are contradictions and confusions in the submitted documents, the applicant should submit unambiguous, clear and detailed information in regard to the level of affordable housing and tenure split. The level of affordable housing proposed should be verified by a clear and detailed viability appraisal that the provision is the maximum reasonable amount achievable. Further discussion/meeting (between the GLA officers and the applicant) is recommended in this

page 9 regard. Nevertheless, it should be clear that the viability of the scheme would be subject to an independent review. The provision of social rented housing is unlikely to be supported.

Urban design

53 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).

54 The proposal site is within the Brentford Area Action Plan (AAP), which the Mayor found to be generally compliant with the London Plan. Although there are no proposals specific to this site within the AAP, London Plan design principles are reflected within the AAP’s principles of good design and enhancement of character.

55 The proposal is broadly similar to the schemes reviewed by the Mayor in August 2011 and January 2012, but reductions in the number of units and other design changes have resulted in improvements with each iteration of the scheme. The site is a backland site with access limited to two locations in Windmill Road. Access across the north-west, south-west and south-east does not appear possible due to constraints created by existing development. The scale of development is now closer to that of surrounding, existing residential development, but is still larger in terms of comparable scale with development to the east, and as such must be justified through exceptional design that is sensitive to the context of the site and surrounding development. The positive response to advice offered by GLA officers at the pre-application stage, and the comments offered by the Mayor as part of the consultation on the previous schemes, has helped to achieve this.

Layout

56 The general principle of site-edge terraced housing with flatted blocks in the centre is acceptable. The three central flatted blocks are aligned in parallel with a reasonably proportioned ‘central space’ in the centre of the site, forming a focus for the site and a main entrance area for the flatted blocks. The substantial additional amenity space created within this application is welcomed. Although the central area podium would be 1.5m higher than the surrounding streets, the introduction of split-level through-core access assists in connecting the side streets with the central space. 57 The layout of the buildings around the entrance roads are supported, and notwithstanding the level changes around the site, routes around the site are logically set out and the entrance to the below-ground car park is well-placed at the rear of the site.

58 The one concern with the most recent changes to the application is that the deletion of homes creates a lack of surveillance of the entrance roads into the site, specifically the southern road, where there would be no potential for overlooking of the main site approach. The applicant should outline the measures that it intends to create, to provide a welcoming approach for residents. Scale and massing

59 Although the proposed development would not comprise any tall buildings as defined within the London Plan, the development responds to the existing cluster of tall buildings around

page 10 the M4 corridor. The revised London Plan places greater importance on the consideration of character than its predecessor. The main visual impact of the development’s scale would be from the suburban streets to the east, particularly Whitestile and Darwin Roads, although the reduction in height of the buildings in this application would reduce the impact on the suburban character of these streets, compared with the previous application. Although there would be some visibility of new buildings, this impact is not detrimental, and the AAP notes the existing disconnectedness of the scale of existing buildings to the west of Windmill Road, and the homogeneity of the suburban area to the east. The applicant notes that the scale of the proposal is a transitional response to the taller buildings to the east and the lower buildings to the west. The reduction in height of the flatted blocks in this application and the deletion of the southern block is supported, as this change of scale provides a better contextual response to the residential properties to the south.

Figure 2: Sketch aerial view of the proposed development – Source: Applicant’s design and access statement

60 The ‘breaking down’ of the flatted blocks at their ends and centres is supported, in an effort to soften the massing and reduce the impact of the scale, is supported.

Figure 3: North east elevation of the proposed development – Source: Applicant’s design and access statement

Appearance

61 Appearance is a reserved matter; however, the comments in this section are offered to assist the Council and applicant, on the basis of the illustrative material presented as part of the

page 11 outline application. The development would use three main materials: brick for the main structure, timber around the balcony areas, and grey glazed bricks around the cores. While the effect would appear modern and attractive, materials would be applied consistently to all blocks and terraced houses, and the effect could appear repetitive.

Figure 4: South west elevation of the proposed town houses – Source: Applicant’s design and access statement

62 The use of the differentiation in materials to pick out the entrance cores to the flatted blocks would be welcomed. The appearance of the main brick elements as a superstructure from which window and balcony elements have been punched is irregular, and this would help to add interest to individual blocks, as well as reduce the impression of massing along single facades.

63 The treatment of the visible areas of the podium walls, along the side streets below the flatted blocks, would need to be designed to provide a visual link between the street and the blocks, rather than appear as barriers with a limited contribution to the street scene.

Landscaping

64 Landscaping is a reserved matter, but the design and access statement provides indicative detail regarding the intended style. The mix of hard and soft landscaping within this the main central area would offer a focus for the scheme, and a range of areas for play and recreation. The creation of a new area of play space within the southern half of the development is welcomed, and the overlooking and surveillance of both this area, and the additional play area to the central western area of the site, is welcomed.

65 As a result of the linear layout of the three main flatted blocks, there would be two routes leading from the central area to the entrances of each of these buildings. The detailed landscape design will need to ensure that these spaces are given a purpose, rather than becoming leftover areas in which the only purpose is access. Landscaping could also offer differentiation between the two routes, to assist legibility. The provision of defensible space at ground floor level within the flatted buildings is welcomed. The delineation of public and private space is clear, but the transitions from private space will need to be carefully managed within the detailed landscaping plan, to contribute to the overall character and attractiveness of the public spaces.

66 Surface parking would be located on the two main internal east-west roads. The revision of site levels around the site provides a better environment for these routes, and better interaction with the flatted blocks, than the previous scheme. There is still a concern that regardless of the indicative tree planting locations, parking would remain the dominant feature of these streets, and they do not appear to incorporate any home zone or shared surface principles, both of which would be appropriate in this setting. This should be remedied at the detailed design stage.

67 The outline proposals do not indicate many positive contributions to the Windmill Road entrance areas, although opportunities for landscaping would be possible. The detailed landscaping plans should offer proposals to improve the legibility of the site from Windmill Road, and offer an attractive entrance while preserving or improving the character of existing development.

68 With the deletion of dwellings in the current version of the application, there is more landscaping space, but the detailed landscaping plan will need to be clear as to their ownership and whether they are public or private spaces, so as to prevent them from becoming neglected, ‘leftover’ spaces.

page 12 69 In summary, there are no strategic design concerns. However, due to the deletion of homes a lack of surveillance of the entrance roads into the site is created; specifically the southern road, where there would be no potential for overlooking of the main site approach. The treatment of the visible areas of the podium walls, along the side streets below the flatted blocks, would need to be designed to provide a visual link between the street and the blocks. These concerns should be addressed. There is still a concern that parking would remain the dominant feature of these streets and that home zones or shared surface principles have not been incorporated. Access

70 London Plan policy 7.2 'An Inclusive Environment' seeks the highest standards of accessibility and inclusion in new developments. London Plan policy 7.1 also stresses the importance of extending these inclusive design principles to the neighbourhood level by meeting Lifetime Neighbourhoods criteria. This can help to ensure that the public realm, parking areas, routes to the site and links to adjacent public transport and local services and facilities are accessible, safe and convenient for everyone, particularly disabled and older people.

71 The applicant has confirmed that they will be providing 100% of the homes to lifetime homes standards, and 10% (rounded up to 11%) of the homes will be wheelchair accessible units. They state that these units will be designed in accordance with the ‘wheelchair housing design guide’, however for reasons of clarity the applicant should confirm whether the wheelchair accessible units will be designed in accordance with the ‘wheelchair housing design guide’ or the best practice guidance ‘wheelchair accessible housing’ i.e. will be ‘easily adaptable’.

72 The floor plan which illustrates a 2 bed 3 person wheelchair accessible flat layout appears acceptable. It does not mention certain aspects i.e. window heights etc. and the applicant’s attention should be drawn to this; however in terms of manoeuvring spaces etc. this layout is acceptable.

73 3% of the units are to be 2 bed 3 person wheelchair accessible flats. Other wheelchair accessible units are to be: 1 bed, 2 bed 3 person and 3 bed 4 person. Typical floor plans for these wheelchair accessible units would also be appreciated. It is also not clear from the floor layouts provided how each of the 16 lifetime homes criteria is satisfied in the general accommodation design, again further information should be provided.

74 All of the wheelchair accessible units appear to be flats located on the ground floor. This restricts the choice of wheelchair users and should be rectified to include upper floor flats and the townhouses.

75 The design and number of blue badge parking bays (25 spaces) is acceptable. The wheelchair accessible units are to be ‘easily adaptable’ it may be acceptable to have some of the parking bays associated with these flats large enough to be used as or marked up as disabled persons parking bays if required at a later date, and the management of these bays (to ensure that they are available at a later date) should be highlighted in the parking management plan.

76 The surface disabled persons parking bays should be provided for disabled visitors, and blue badge holders who use a hi-top vehicle or roofbox to transport their wheelchair, which require extra height to the parking bays. The disabled persons parking bays which are illustrated at surface level all appear to obstruct the pedestrian pathways with their hatched transference zones. This overlap should not occur as it could cause significant problems for pedestrians, including blind and partially sighted people. The applicant should also show how the Lifetime Homes criteria in terms of parking have been satisfied again, the potential widening of any bays in accordance with lifetime homes criteria should not have an impact on pedestrian routes around this site.

page 13 77 The proposals appear to introduce a level change to the site to accommodate the underground car parking. This should not have a negative impact on the access around this site for pedestrians, including disabled people. Footpath gradients should be kept to a minimum and should not exceed 1:20 at any point. Confirmation of the pedestrian route gradients should be provided.

78 The access points into and out of the site should incorporate dropped kerbs which are designed in accordance with the DfTs ‘Guidance on the use of tactile paving surfaces’. Again, confirmation of this should be provided. Sustainable development

79 London Plan policies 5.2, 5.6 and 5.7 focus on mitigation of climate change and require a reduction in a development’s carbon dioxide emissions through the use of passive design, energy efficiency and renewable energy measures. The London Plan requires developments to make the fullest contribution to tackling climate change by minimising carbon dioxide emissions, adopting sustainable design and construction measures and prioritising decentralised energy, including renewables.

Overview of proposals

80 The applicant has broadly followed the energy hierarchy. Sufficient information has been provided to understand the proposals as a whole.

BE LEAN

Energy efficiency standards

81 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 heat recovery (MVHR) applied where necessary. The demand for cooling will be minimised through solar control glazing.

82 The applicant should state the savings in regulated carbon dioxide emissions in tonnes per annum resulting from energy efficiency measures and commit to the development exceeding 2010 Building Regulations compliance through energy efficiency alone.

BE CLEAN

District heating

83 The applicant should carry out an investigation to determine whether there are any existing or planned district heating networks (DHN) within the vicinity of the proposed development. If a DHN is available the applicant should prioritise connection to this. If a DHN is proposed the applicant should provide a commitment to ensuring that the development is designed to allow future connection.

84 The applicant is proposing to install a site heat network. However, the applicant should confirm that all apartments and non-domestic building uses will be connected to the site heat network. (A drawing showing the route of the heat network linking all buildings on the site should be provided.)

page 14 85 The site heat network will be supplied from a single energy centre. Further information on the floor area and location of the energy centre should be provided

Combined Heat and Power (CHP)

86 The applicant if proposing to install a 70kWe gas fired CHP unit as the lead heat source for the site heat network. The applicant should confirm that the CHP is sized to provide the domestic hot water load, as well as a proportion of the space heating.

87 The applicant should calculate and state the reduction in regulated carbon dioxide emissions in tonnes per annum that will be achieved through this second part of the energy hierarchy.

BE GREEN

Renewable energy technologies

88 The applicant has investigated the feasibility of a range of renewable energy technologies and is proposing to install 820sqm solar photovoltaic (PV) panels.

89 A reduction in regulated carbon dioxide emissions of 55 tonnes per annum will be achieved through this third element of the energy hierarchy.

OVERALL CARBON SAVINGS

90 The applicant should state the estimated regulated carbon emissions of the development in tonnes of carbon dioxide per annum before (baseline) and after the cumulative effect of energy efficiency measures, district heating and CHP has been taken into account and at each interim stage of the energy hierarchy.

91 The applicant should present the information required in the format set out in Tables 1 & 2 of the document ‘Energy Planning - GLA Guidance on preparing energy assessments – September 2011’ which is available on the GLA website.

Climate change adaptation

92 London Plan policy 5.3 Sustainable Design and Construction seeks to ensure future developments meet the highest standards of sustainable design and construction. Specific policies relate to overheating (5.9), green roofs (5.11), urban greening (5.10), flood risk (5.12) and sustainable drainage (5.13), water (5.14 and 5.15) and waste (5.17). Further guidance is provided in the London Plan Sustainable Design and Construction SPG.

Flood risk management

93 The applicant has submitted a flood risk assessment (FRA) commissioned by Glanville Consultants. The FRA states that the site is located in Flood Zone 1, an area considered to be at low risk of fluvial flooding and it highlights known issues with the surcharging of sewers in Windmill Road. The drainage systems for the proposed development will be designed in such a way as not to exacerbate existing problems. Anecdotal evidence confirms that flooding from surface water sewers has affected Windmill Road and the site in the past. The available evidence appears to suggest that the main mechanism of flooding to the site has been through the surcharging of the private drainage network as a result of water backing up from the overloaded public sewer in Windmill Road.

page 15 94 The FRA proposes that non return valves will be fitted to the outlet of the proposed surface water drainage system to the public sewer in order to prevent surface water flows within the public sewer in Windmill Road entering into the proposed pervious pavement system. As a recommendation, it states that further work should be undertaken prior to detailed design so that the residual risk of overland flood routes from Windmill Road can be assessed and any mitigation measures proposed.

95 The FRA suggests that mitigation measures may include the introduction of ramps within the access from Windmill Road to the proposed development, and introduction of flood defence barriers at the access to the basement parking area. Alternatively consideration may be given to a general raising of levels across the site. Surface water runoff from the proposed development will be restricted to discharge rates meeting minimum requirements based on the existing drainage conditions of the site and ensuring existing discharge rates are not increased as a result of redevelopment. Systems for disposing surface water include pervious paving for the access roads and parking areas, and green roof construction for the structural deck area to the basement car park. In addition, sustainable urban drainage systems will be designed to attenuate runoff with controlled discharge to the local sewer network. Flows into the receiving sewer are expected to fall significantly as a result of proposals. The use of these systems should also offer significant benefits in terms of water quality.

96 Whilst the above proposed mitigation measures should be agreed by the Environment Agency and the Thames Water and secured through appropriate conditions, the applicant is required to provide further information with regard to what further climate change adaptation measures are proposed (e.g. water use reduction and rainwater harvesting). Employment and training

97 Continued investment in the skills of London's current workforce will ensure that skills and training provision is tailored to meet current employer demand. The GLA is committed to develop the skills that London needs to sustain economic growth, improving individual's employability skills in order to create a positive impact on the skills levels within all of London's communities.

98 In accordance with the London Plan 2011 Policy 4.12 ‘Improving opportunities for all‘, the applicant should confirm that the proposals will deliver a number of employment opportunities for local residents as required by the London Plan. The proposed scheme should incorporate construction training. These should be secured by the s106 agreement. Transport for London’s comments

Car parking

99 Compared to the refused scheme (01217/C/P37), the overall parking ratio has been increased from 0.77 spaces per unit (275 units and 211 spaces) to 0.96 (229 units and 220 spaces). The total is however inclusive of 2 car club spaces, 18 visitor spaces and 25 blue badge spaces, in addition the 46 town houses can accommodate a wheelchair compatible space. Electrical vehicle charging points are proposed across the site in line with London Plan standards which is supported.

100 Taking into consideration the low PTAL of the site and mix of units, the level of car parking proposed to serve the occupiers is considered reasonable. Nevertheless, the London Plan car parking standards does not include reference to visitor car parking and therefore TfL requests the 18 visitor spaces be removed to ensure full conformity with London Plan Policy 6.13 ‘Parking’. This would also help to reduce the dominance of parking in the street scene.

page 16 101 A high level of car parking stress within the local area has been indentified within the transport assessment (TA). It may therefore be appropriate for the Council to consider introducing a local controlled parking zone (CPZ) with the consequent exemption for future occupiers of this development from the eligibility to purchase a permit. A contribution towards this should be secured within the s106 agreement.

Highway impact

102 TfL acknowledges that the proposed development would only result in a small increase in vehicular trips to/ from the site compared with its existing use if it had been fully occupied. However it is noted that the direction of flow would be reversed given the existing use on site. TfL is currently making highway improvements along the A4 corridor, including measures to smooth traffic flow and improve conditions for pedestrians and cyclists. However it is considered the additional traffic from the proposed development could adversely impact the road network, resulting in longer queues on Windmill Road or delay to traffic on the A4 for example.

103 As such, an s106 contribution of £100,000 payable to TfL was previously requested towards the delivery of junction, signalling, pedestrian/cyclist improvements and bus stop upgrades on the Windmill Road / A4 junction. Taking into consideration the reduced quantum of development proposed TfL will accordingly be seeking a reduced contribution of £83,000 to be paid upon commencement of any work on site to ensure conformity with London Plan policies 6.9, 6.10, 6.11 and 6.12.

Cycle parking

104 A total of 307 cycle spaces are proposed to serve the 229 residential units. Cycle parking will be provided in individual storage solutions to serve the houses. The remainder will be located within the basement of the apartment block. A further 8 visitor cycle spaces will be located within the public realm of the site. TfL considers these proposals are satisfactory and in line with London Plan policy 6.9 ‘Cycling’.

Pedestrian environment assessment

105 A PERS style audit has been undertaken which is supported. The issues identified on the A4 included the length of cycle time at the signal, possible conflict between cyclists and users of bus stops and deficiencies in bus stop infrastructure. TfL considers this could be reviewed as part of wider improvements planned on this part of the TLRN and delivered using the £83,000 s106 contribution detailed previously in line with London Plan policy 6.7 ‘Better streets and surface transport’.

Servicing, deliveries and construction

106 A construction and logistics plan (CLP) will be secured by either planning condition or as part of the s106 agreement. General servicing and delivery requirements during occupation will be considered through a delivery and servicing plan (DSP) as part of the full travel plan. The proposals are therefore considered to be in conformity with London Plan policy 6.14 ‘Freight’

Travel plan

107 A Framework travel plan has been prepared which is welcomed however a full travel plan must be submitted for TfL and council approval prior to the occupation of the site. Tangible measures to encourage mode shift are required within the travel plan such as a financial contribution towards car club membership for occupants, pre-paid Oyster cards upon occupation and vouchers towards the purchase of bicycles.

page 17 108 To ensure conformity with London Plan policy 6.3 ‘Assessing effects of development on transport capacity’ the full travel plan should be secured, monitored, enforced, reviewed and funded as part of the s106 agreement, and assessed with the online travel plan assessment tool ‘ATTrBuTE’.

Community Infrastructure Levy (CIL)

109 In accordance with London Plan policy 8.3, Community Infrastructure Levy, the Mayor agreed to commence CIL charging for developments permitted on or after 1 April 2012. It is noted that the proposed development is within the London Borough of Hounslow, where the Mayoral charge is £35 per square metre Gross Internal Area (GIA). The levy will raise £300 million towards the delivery of Crossrail. Further details can be found at: http://www.london.gov.uk/publication/mayoral-community-infrastructure-levy.

Summary

110 Overall, several issues raised need to be resolved, including the removal of the visitor car parking a contribution of £83k towards highways and public realm improvements to be secured within the s106 agreement, and in addition to a full travel plan inclusive of a DSP, to ensure full conformity with the London Plan. Local planning authority’s position

111 Hounslow Council officers have yet to confirm their position. Legal considerations

112 Under the arrangements set out in Article 4 of the Town and Country Planning (Mayor of London) Order 2008 the Mayor is required to provide the local planning authority with a statement setting out whether he considers that the application complies with the London Plan, and his reasons for taking that view. Unless notified otherwise by the Mayor, the Council must consult the Mayor again under Article 5 of the Order if it subsequently resolves to make a draft decision on the application, in order that the Mayor may decide whether to allow the draft decision to proceed unchanged, or direct the Council under Article 6 of the Order to refuse the application, or issue a direction under Article 7 of the Order that he is to act as the local planning authority for the purpose of determining the application and any connected application. There is no obligation at this present stage for the Mayor to indicate his intentions regarding a possible direction, and no such decision should be inferred from the Mayor’s statement and comments. Financial considerations

113 There are no financial considerations at this stage. Conclusion

114 London Plan policies on industrial employment land; housing density, housing mix and tenure split, housing quality and space standards; children’s play space; affordable housing; urban design; inclusive access provisions; sustainable development, flood risk management, employment and training; and transport are relevant to this application. In general, the application complies with some of those policies but not with others for the following reasons:  Land use / employment land: There are no policy objections to the loss of employment- generating uses on this predominantly vacant site, a site not identified as a Preferred Industrial Location, Industrial Business Park or Local Significant Industrial Site. The principle

page 18 of a residential redevelopment of the site is, therefore, acceptable. However, the Council should ensure that the relocation strategy submitted by the applicant is acceptable.  Housing density: The proposed density fits comfortably within the density guidance of the London Plan.  Housing mix: The overall provision of family units is good, however, the level of affordable family units is unlikely to be acceptable. The final unit mix needs to be secured by condition.  Housing quality and space standards: The applicant has demonstrated that minimum units sizes can be met, but this should be secured by condition.

 Affordable housing: There are conflicting proposals in different documents submitted by the applicant. The applicant should submit clear and detailed information in regard to the level of affordable housing and tenure split, which should be verified by a viability appraisal. Further discussion/meeting is required in this regard. The viability of the scheme should be subject to an independent review.

 Children’s play space: Sufficient play spaces and generous amenity areas are provided.

 Urban design: There are some concerns regarding surveillance, treatment of the podium walls and pre-dominance of street parking.

 Access: There are concerns in relation to the design and location of wheelchair accessible units and blue badge parking bays (obstructing the pedestrian pathways with their hatched transference zones). Confirmation is required on the pedestrian route gradients and that all access points into and out of the site incorporate dropped kerbs.

 Sustainable development: The applicant should provide the estimated regulated carbon emissions of the development in tonnes of carbon dioxide per annum before (baseline) and after the cumulative effect of energy efficiency measures, district heating and CHP has been taken into account and at each interim stage of the energy hierarchy. Further information is required in regard to what further climate change adaptation measures are proposed (e.g. water use reduction and rainwater harvesting).

 Flood risk management: The proposed mitigation measures should be agreed with the Environment Agency and Thames Water, and they should be conditioned.  Employment and training: The proposed scheme should incorporate construction training. This should be secured by the s106 agreement.

 Transport: The visitor car parking should be removed and a contribution of £83K towards highways and public realm improvements should be secured within the s106 agreement in addition to a full travel plan inclusive of a DSP to ensure full conformity with the London Plan. 115 The following changes might, however, remedy the above-mentioned deficiencies, and could possibly lead to the application becoming compliant with the London Plan:

 Housing mix: Clarify the unit mix, increase the proportion of affordable family units and secure the final mix by condition.  Affordable housing: Submit clear and detailed information in regard to the level of affordable housing and tenure split, which should be supported by a viability appraisal, to

page 19 be independently verified. The provision of social rented housing is unlikely to be supported.

 Urban design: Address the concerns in relation to a lack of surveillance of the entrance roads into the site, the treatment of the visible areas of the podium walls; and the dominance of the on-street parking.

 Access: Address concerns in relation to the design and location of wheelchair accessible units and blue badge parking bays (obstructing the pedestrian pathways with their hatched transference zones). Provide confirmation in regard to the pedestrian route gradients and that all access points into and out of the site incorporate dropped kerbs.

 Sustainable development: Provide the estimated regulated carbon emissions of the development in tonnes of carbon dioxide per annum before (baseline) and after the cumulative effect of energy efficiency measures, district heating and CHP has been taken into account and at each interim stage of the energy hierarchy. Submit further information in regard to what further climate change adaptation measures are proposed.

 Flood risk management: Agree to consult the Environment Agency and Thames Water on the mitigation measures proposed and that they should be conditioned.  Employment and training: Incorporate construction training. Agree that this be secured by the s106 agreement.

 Transport: Address concerns raised in the report including the removal of visitors’ car parking; a contribution of £83K towards highways and public realm improvements, a full travel plan inclusive of a DSP.

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] Tefera Tibebe, Case Officer 020 7983 4312 email [email protected]

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