SPD for RAF Bentley Priory

Sustainability Appraisal On behalf of: <a href="/tags/London/" rel="tag">London</a> Borough of Harrow In respect of: <a href="/tags/Bentley_Priory/" rel="tag">Bentley Priory</a> Supplementary Planning Document Date: September 2007 Reference: 804006/ R0007 DM London Borough of Harrow , <a href="/tags/Stanmore/" rel="tag">Stanmore</a> CONTENTS 1.0 Summary 2 2.0 Introduction 7 3.0 The SPD 9 4.0 Appraisal Methodology 16 5.0 Policies, plans, programmes and strategies 17 6.0 Sustainability Context and Issues for Bentley Priory 21 7.0 Planning Policy Review 24 8.0 Implications of Planning Policy Framework 44 9.0 Cultural Heritage Baseline Assessment 47 10.0 Landscape Baseline Assessment 63 11.0 Ecology Baseline Assessment 79 12.0 Developing and refining options and assessing effects 92 Achieving the Landscape Vision 100 13.0 Predicting and appraising effects of the draft SPD 106 1London Borough of Harrow , Stanmore 1.0 Summary 1.1 This report sets out the Sustainability Appraisal of the Bentley Priory Supplementary Planning Document. Sustainability Appraisal of Development Plan Documents is a requirement of the 2004 Planning and Compulsory Purchase Act. Bentley Priory is located in the north green belt fringe of the London Borough of Harrow. 1.2 Bentley Priory currently accommodates on RAF station used now principally for training purposes. This is a use which has been associated with the site since the 1920's. The site is steeped in history ranging from its Saxon origins through to its key role in the <a href="/tags/Battle_of_Britain/" rel="tag">Battle of Britain</a> as the headquarters of fighter command. The Priory building is listed grade II* and the surrounding grounds are registered as a grade II historic park and garden reflecting the historical interest of the wider site. 1.3 The RAF are vacating the site in 2007 and because of this the London Borough of Harrow have commissioned the preparation of an SPD for the future use and development of the site to secure it's sensitive heritage, landscape and ecological value in the context of possible future development. 1.4 A vision for Bentley Priory has been developed by Harrow Council which has the following objectives: • Safeguarding the historic character of the site through provision of a Battle of Britain museum and training centre; • Safeguarding the fabric of an important listed building and maintaining the character of an historic park; • Promoting increased access and linkage to Bentley priory Open Space; • Protecting the ecological and nature conservation value of the site including an SSSI, Site of Nature Conservation importance and Statutory Local Nature Reserve; • Protecting the visual amenity of the <a href="/tags/Harrow_Weald/" rel="tag">Harrow Weald</a> area of special landscape character; and • Maintaining the character of the Metropolitan Green Belt. 2London Borough of Harrow , Stanmore 1.5 Sustainable development – In the context of the green belt, listed building and historic park and garden setting it is vitally important that any future development conforms with the objectives set out within 'PPS1 – Delivering Sustainable Development'. 1.6 Distinct areas - Due to the historical development of Bentley Priory there are several distinct areas of the site with differing sensitivities in terms of historical, landscape and ecological factors. There are clear opportunities to improve the general environment of the site which benefit the setting of the listed building, benefit the historic parks and gardens setting and improve the ecological properties at the site, whilst also allowing the development of less sensitive areas which principally (or previously) accommodate older buildings, hard standings and modern RAF buildings. 1.7 The Battle of Britain and public access - The public consultation exercise revealed the strong sense of importance that people place upon the Priory's RAF associations with specific reference to the Battle of Britain. It is clear that there is a general public feeling alongside specialist veterans and interest groups, that support the preservation of the most important buildings or parts of buildings associated with this most recent history. The parts of the Priory of most interest are in the downstairs suite of rooms including Dowding’s office. It is therefore important that some form of public access to the areas which relate to the Battle of Britain is secured as well as safeguarding the potential for ceremonial use of the key rooms and terrace associated with its RAF history. 1.8 Bentley Priory Open Space and public access – The Council wish to see increased linkage between the site and the Bentley Priory open space (SSSI) to the south. 1.9 Bentley Priory wider history - In historical terms it is also important that any potential development respects the wider history of the Priory with its historical associations harking back to Saxon times. 1.10 Bentley Priory’s Green Belt status - Given Bentley Priory’s ‘Major Developed Site’ status in green belt terms it is important that any potential future 3London Borough of Harrow , Stanmore development accords with the guidance set out within annex C to PPS2. It is important that any future use or development on the site accords with this guidance to maintain its green belt character and function. 1.11 Landscape - The site is situated on a prominent position of the Harrow Weald ridge giving views of London to the south. This landmark setting of the site should be enhanced through appropriate landscape management schemes and supported with sensitive development/ redevelopment/ conversion of the built fabric on the site. 1.12 The ODPM summarises the aim of Sustainability Appraisal as follows: “The purpose of sustainability appraisal is to promote sustainable development through the integration of social, environmental and economic considerations into the preparation of…new or revised Development Plan Documents (DPDs) and Supplementary Planning Documents (SPDs).1” 1.13 In terms of a definition of sustainable development, Securing the Future2, the government’s new sustainable development strategy for the UK, states that sustainable development: “aims to enable all people throughout the world to satisfy their basic needs and enjoy a better quality of life without compromising the quality of life of future generations”. 1.14 The UK sustainable development strategy is based on five principles – the first three are particularly relevant at the local level in the UK. These five principles help to define and understand the sustainability agenda: • Living Within Environmental Limits; • Ensuring a Strong, Healthy and Just Society; • Achieving a Sustainable Economy; • Promoting Good Governance; • Using Sound Science Responsibly. 1.15 The Sustainability Appraisal of the Bentley Priory SPD aims to ensure that as 4London Borough of Harrow , Stanmore far as possible the plan contributes to sustainable development locally and globally. 1.16 Sustainability objectives for the development of Local Development Documents within the London Borough of Harrow have been set out within 'Sustainability Appraisal: Scoping report for the Harrow Local Development Framework (November 2006)'. 1.17 The scoping report identifies 16 objectives which state: SEA/SA Overarching SEA/SA Objective Objective No. 1 To make the most efficient use of land and buildings. 2 To protect the quality, quantity and accessibility of open spaces in the Borough. 3 To conserve and enhance biodiversity in the Borough. 4 To restrict development which can negatively affect the landscape and streetscape and design of historic, archaeological sites (listed buildings and conservation areas) or culturally important features. 5 To ensure air quality continues to improve through reducing air pollution and address the causes of climate change through reducing emissions of greenhouse gasses and other pollutants (including air, water, soil, noise, vibration and light). 6 To reduce pollution of land (soil) and ensure that contaminated land is remediated. 7 To improve water quality and reduce the risk and impact of flooding. 8 To promote development that ensures the sustainable use of energy. 9 To discourage the production of waste and promote further the waste hierarchy of minimisation, reuse, recycling and composting. 10 To facilitate the development of a dynamic and diverse economic sector which attracts growth. 11 To improve the education and skills of the Borough. 12 To ensure all groups have access to decent, appropriate and affordable housing that meets the needs of Harrow's residents. 13 To reduce social exclusion and facilitate the development of mixed and balanced communities. 14 To improve the health and wellbeing of Harrow residents and reduce inequalities in health. 15 To improve the competitiveness, vitality, viability and adaptability of town centres in Harrow. 16 To reduce crime, fear of crime and anti social activity. 5London Borough of Harrow , Stanmore 1.18 The SPD has been drafted in accordance with the above mentioned sustainability objectives, however, there are some instances where the sustainability objectives conflict with the objectives for Bentley Priory set out by the Council and these have been addressed within the report. 1.19 Overall the sustainability appraisal process has served to clarify the key sustainability issues and to outline the wider sustainability agenda. Some issues which are pressing locally and nationally e.g. improving the competitiveness, vitality, viability and adaptability of town centres– is inappropriate to address within the SPD. The Sustainability Appraisal process will ensure that the effects of the plan on such issues are monitored. The inclusion of appropriate sustainability objectives in terms of “development principles” for Bentley Priory will ensure that these issues are on the planning agenda during implementation of the plan. 1.20 The Sustainability Appraisal has been used to inform the production of the SPD during the consultation phase of the documents preparation and subsequent alterations in accordance with comments made by both organisations and individuals. 6London Borough of Harrow , Stanmore 2.0 Introduction 2.1 This document reports on the sustainability appraisal of the draft supplementary planning document (SPD) for the future use of Bentley Priory. 2.2 Once adopted, the draft will from part of the London Borough of Harrow's Local Development Framework and will be a material consideration in decisions made by the Council at Bentley Priory. 2.3 The SPD provides detailed guidance for any future development at the site. 2.4 The Planning and Compulsory Purchase Act 2004 requires that a sustainability appraisal (SA) is carried out as part of the preparation of new plans, including SPDs. The purpose of a SA is to assess whether or not, and to what extent, a plan meets objectives for achieving a sustainable community. In addition, the SPD falls within the definition of a ‘plan or programme’ under European Directive 2001/42, because the SPD is likely to have significant environmental effects, it must also undergo a Strategic Environmental Assessment (SEA). The main purpose of an SEA is to predict what the likely significant effects of a draft plan will be on the environment and identify ways in which any negative effects can be overcome. Ways, in which the actual effects of the plan will be measured and monitored, should it be adopted, are also identified as part of the SEA. The council has undertaken a SEA of the draft SPD as part of the sustainability appraisal. 2.5 Throughout this report, where reference is made to sustainability appraisal (SA) or the SA report, it denotes sustainability appraisal under the 'Environmental Assessment of Plans and Programmes Regulations 2004', incorporating the requirements from the European SEA directive 2001/42. 2.6 Taken together, the SA/SEA processes enable the social, environmental and economic implications of a plan to be assessed while it is being prepared, ensuring that sustainability is considered throughout the plan making process. 2.7 The SA takes forward the principles of sustainable development as set out 7London Borough of Harrow , Stanmore within PPS 1: Delivering Sustainable Development, which states at paragraph 24 that: 'Planning authorities should ensure that sustainable development is treated in an integrated way in their development plans. In particular, they should carefully consider the inter-relationship between social inclusion, protecting and enhancing the environment, the prudent use of natural resources and economic development' 2.8 Guidance for undertaking sustainability appraisals is set out within the following Government publications: • Sustainability Appraisal of Regional Spatial Strategies and Local Development Documents- ODPM (November, 2005); and • A Practical guide to the Strategic Environmental Assessment Directive- ODPM (September, 2005). 2.9 The report represents stage C of the process as such it will set out the steps undertaken during the preparation of the SPD in accordance with the SA guidelines. 8London Borough of Harrow , Stanmore 3.0 The SPD 3.1 The SPD has been prepared to guide future development on the Bentley Priory site due to the RAF's scheduled de-commissioning of the base in 2008. As a result the Council have sought the preparation of the SPD because of the heritage, landscape and ecological assets associated with Bentley Priory. 3.2 The site is situated to the north of London Borough of Harrow’s jurisdiction approximately 1.5 kilometres north east of Stanmore District Centre and 2.2 kilometres west of junction 4 of the M1, it is approximately 22.9 hectares in area. It can also be noted that the site is close to the boundary with Hertsmere’s Council’s jurisdiction which is approximately 1km to the north. The site is illustrated on the plan below: 9London Borough of Harrow , Stanmore 3.3 In terms of surrounding land use the site is characterised by its Green Belt location with dispersed residential dwellings, parkland and woodland’s. The site and surrounding area are subject to a number of Local Plan designations including: ƒ Historic park and Garden; and ƒ Area of Special Landscape Character. and adjacent to the site: ƒ Site of Special Scientific Interest; and ƒ Site of Nature Conservation Importance. 3.4 In terms of access the site is serviced by a single vehicular and pedestrian point to the north of the site off the A4140. Historically the site would have had several access points, however, they have been removed largely due to the development of residential properties around the site and security issues relating to its RAF usage. The Site 3.5 Within the site the majority of the existing built form is situated across a belt from east to west roughly in line with the Priory building in the south eastern areas of the site. The buildings contain a mixture of accommodation and office blocks for use in association with the RAF’s operation. In terms of descriptions of the individual buildings on site for the purposes of this report we shall use the existing numbering for the units devised by the RAF to avoid confusion with the various documents that have been produced on the area. Accordingly a plan illustrating the built form is attached at appendix 2, while each building is dealt with in turn below: Building Date Built number Use (approximate) Building Description Single storey building with pitched 17 Vehicle Maintenance 1998 roof constructed of concrete blocks 10London Borough of Harrow , Stanmore 270 Guard Room 1963 Single storey brick built building Single and two storey building with pitched roof constructed of concrete 2 Sergeants Mess 1998 blocks Two storey building with pitched 16 Junior ranks accommodation 1998 roof constructed of concrete blocks Two storey building with pitched 14 SNCOs accommodation 1998 roof constructed of concrete blocks Small hut brick built with pitched 259 SAA Store 1940's roof Two Storey building with pitched 11 Officer's quarters 1909 - 1923 roof and rendered elevations Single storey property with pitched 10 Offices 1909 - 1923 roof and rendered elevations Single storey property with pitched 9 Dental and Medical Centre c1865 roof and rendered elevations Single storey building with flat roof 7 Senior Officer's Quarters c1884 constructed of red brick Three storey building with pitched 267 Senior Officer's Quarters 1958 roof constructed of stone blocks Original Georgian Villa c1766, remodelled by Sir <a href="/tags/John_Soane/" rel="tag">John Soane</a> 18th Single, two and three storey century with 19th property with pitched roof and 20th Century constructed of stone blocks. Includes 1 Officer's mess additions building 112 to the north c1940, refurbished 262 SAA Store c1990 Brick built hut Single storey concrete construction 88 Air handling plant c1940 in association with the bunker Concrete construction largely hidden 1940 enlarged in underground with some plant and 85 Bunker 1982 access points visible Three storey stone clad office block 263 Air staff block 1958 with flat roof Single storey pre fabricated office 258 Office 1941 block with flat roof Two storey brick built office building 274 Office c1998 with pitched roof Single storey brick and concrete 87 Back up power plant c1940 construction 11London Borough of Harrow , Stanmore Built 1958 Two storey building with flat roof 266 Air historical branch refurbished in 2001 constructed of concrete blocks Single and two storey brick built 264 Plant c1940 plant building Two storey building with flat roof 268 Tech block 1962 constructed of concrete blocks Single storey brick built plant 272 Plant c1940 enclosure 3.6 In terms of footprint a recently undertaken survey by Halcrow Yoles in April 2007 states that there is 11,620 m2 of built footprint including all buildings except the command bunker. 3.7 Splitting the site into three zones namely: northern (from the building line of 272, 268 and 266 northwards), western (from the eastern building line of 1 westwards) and eastern (the remainder of the site to the east) the general characteristics of the site are described below: ƒ Northern- This area is open in nature with considerable amounts of mature vegetation along the boundary treatments. Open views towards the Priory are blocked by bunds surrounding a large hard surface car park to the south of the zone, which can accommodate approximately 147 parked cars. Adjacent to the south of the car park are telecommunications masts while to the south east corner of this section there are marked playing fields and small built units accommodating plant machinery. ƒ Western- From the west elevation of building 11 this part of the site is characterised by modern accommodation blocks inter dispersed by tree planting and hard standing areas. The western boundary treatment has thick mature vegetation obscuring any views out the site while the southern boundary affords glimpse views into the parkland to the south. The security fencing is more pronounced to the south because of thinning of some sections of the vegetation. To the east of building 11 looking from the south the building line is roughly in line with the Priory and there are a variety of architectural styles leading up to the Priory building. In front of the Priory Building to the south are the Italianate gardens and it is clear from planting around the gardens boundary that this area is a semi private part of the site. 12London Borough of Harrow , Stanmore Turning now to the northern side of building 11 looking towards the east the building line is more erratic and the immediate area before the Priory is characterised by hard standing and office buildings. The Priory entrance itself is more pronounced and opposite the entrance are two replica World War II fighter planes. ƒ Eastern- The eastern section of the site looking directly north east from the Priory building is once again characterised by hard standing and office accommodation. Adjoining the office accommodation to the east is the bunker complex which is largely hidden under grass and shrub planting, there are several concrete protrusions from the ground around the bunker complex which are associated with air handling plant and entrances/exits. The boundary treatment to the north and east of this section is less mature than that afforded to the north of the site, however, views into adjoining residential properties are largely obscured. The southern boundary also has some mature vegetation while the topography of the bunker and surrounding area screens any of the office accommodation in this section from view. 3.8 The site accommodates a large number of existing structures built during various phases of the original Priory’s construction and later additions associated with the hotel, school and RAF usage. However, due to the existing planting screens along the boundary to the site the various structures are largely hidden from sight, as such there are only glimpse views available from outside the site. In the original setting of the Priory several views would have been available across the site particularly towards the south and the urban area of Harrow. These views are discussed in more length within the following Heritage and Landscape sections. 3.9 The vision for the SPD sets out a number of key objectives set out below: 1. Sustainable development – In the context of the green belt, listed building and historic park and garden setting it is vitally important that any future development conforms with the objectives set out within 'PPS1 – Delivering Sustainable Development'. 2. Distinct areas- Due to the historical development of Bentley Priory there are several distinct areas of the site with differing sensitivities in terms of historical, landscape and ecological factors. There are clear opportunities to 13London Borough of Harrow , Stanmore improve the general environment of the site which benefit the setting of the listed building, benefit the historic parks and gardens setting and improve the ecological properties at the site, whilst also allowing the development of less sensitive areas which principally or previously accommodate older buildings, hard standings and modern RAF buildings. 3. Bentley Priory wider history- In historical terms it is also important that any potential development respects the wider history of the Priory with its historical associations harking back to Saxon times. 4. The Battle of Britain and public access- The consultation exercise revealed a strong sense of importance people placed upon the sites RAF associations with specific reference to the Battle of Britain. It is clear that there is a general public feeling which supports the preservation of the most important buildings or parts of buildings associated with this most relevant history. These are most apparent today in the downstairs suite of rooms at the Priory including Dowding’s office. It was also clear from the consultation process that the public would like some form of access to the areas which relate to the Battle of Britain. 5. Site of Scientific Special Interest and public access- Another issue that generated significant comment in the consultation process was the need to protect the special nature of the Site of Special Scientific Interest (SSSI) to the south of the site. This was most apparent in the response to the proposed footpath links to the south of the site and their management, which clearly indicate that the public would not support any more intensive use of the existing footpath system which could affect the flora and fauna established on the SSSI. 6. Bentley Priory’s Green Belt status- Given Bentley Priory’s ‘Major Developed Site’ status in green belt terms it is important that any potential future development accords with the guidance set out within annex C. It is important that any future use or development on the site accords with this guidance to maintain its green belt setting. 7. Landscape- The site is situated on a prominent position of the Harrow Weald ridge giving it views of London to the south. This landmark setting of the site should be enhanced through appropriate landscape management schemes and supported with sensitive development/ redevelopment/ conversion of the built fabric on the site. 14London Borough of Harrow , Stanmore 3.10 In terms of the key points of guidance set out within the SPD they cover the four main theme topics for the site, which are: • Heritage • Landscape • Ecology • Development Opportunities 15London Borough of Harrow , Stanmore 4.0 Appraisal Methodology 4.1 The information required for the SA is set out at Annex 1 of European Directive 2001/42/EC, which states: 1. an outline of the contents, main objectives of the plan or programme and relationship with other relevant plans and programmes; 2. the relevant aspects of the current state of the environment and the likely evolution thereof without implementation of the plan or programme; 3. the environmental characteristics of areas likely to be significantly affected; 4. any existing environmental problems which are relevant to the plan or programme including, in particular, those relating to any areas of a particular environmental importance, such as areas designated pursuant to Directives 79/409/EEC and 92/43/EEC; 5. the environmental protection objectives, established at international, Community or Member State level, which are relevant to the plan or programme and the way those objectives and any environmental considerations have been taken into account during its preparation; 4.2 In the context of the legal assessment process that must be followed as set out by directive 2001/42/EC, the report clearly identifies where the issues have been addressed in accordance with Article 5(1), (2) and (3) of the directive. 16London Borough of Harrow , Stanmore 5.0 Policies, plans, programmes and strategies 5.1 During stage A of the SPD's preparation other policies, plans, programmes and strategies were identified which give the document its context, this is in accordance with part a) of Annex 1 of European Directive 2001/42/EC. 5.2 As such the following tables set out the policies, plans, programmes and strategies within the Bentley Priory context at the national, regional and local levels: International European Sustainable Development Strategy European Diversity Study (EBS) European Spatial Development Perspective EU Sixth Environmental Action Programme (ESDP) Framework Waste Directive (Directive Water Framework Directive (2000/60/EC) 75/442/EC) Waste Electrical and Equipment Directive Environmental Noise Directive (2002/49/EC) (2002/96/EC) Landfill Directive (99/31/EC) Air Quality Framework Directive & Daughter Directives (Directive 1996/62/EC) European Habitats Directive- The Directive on Energy White Pape, 'Our energy future – Conservation of Natural Habitats and of Wild creating a low carbon economy' 2003 Flora and Fauna (92/43/EEC) Noise Directive (86/188/EEC) National Securing the Future – Delivering UK PPG2: Green Belt Sustainable Development Strategy (2005) Waste Strategy 2000 PPS3: Housing PPS1: Delivering Sustainable Development PPG4: Industrial, Commercial Development and Small firms PPS6: Planning for Town Centres PPS7: Sustainable Development in Rural Areas PPG8: Telecommunications PPG13: Transport PPS9: Biodiversity and Geological PPG14: Development on unstable land Conservation PPS10: Planning for Sustainable Waste PPG15: Planning and the Historic Management Environment PPS12: Local Development Frameworks PPG17: Planning for Open Space, Sport and Recreation 17London Borough of Harrow , Stanmore PPG16: Archaeology and planning PPG19: Outdoor Advertisement Control PPG18: Enforcing Planning Control PPS22: Renewable Energy PPG21: Tourism Section 17 Crime and Disorder Act 1998 Considerations 1998 PPS23: Planning and Pollution Control PPG24 Planning and Noise PPS25: Development and Flooding risk Planning (Listed buildings and Conservation Areas) Act 1990 London Historic Environment Forum Environment Agency North London River publication Capital Values 2006 Restoration Strategy Colne, Brent and Crane catchment flood Countryside and Rights of Way Act 2000 management plans (CROW act) Countryside Character Series (South East & Landscape Chracter Assessment Guidance for London, Chracter Areas in London Volume 7) <a href="/tags/England/" rel="tag">England</a> and Scotland (Publication Reference CA13) 1999 English Heritage Buildings at Risk Regional The <a href="/tags/London_Plan/" rel="tag">London Plan</a>: Spatial Development Housing- The London Plan Supplementary Strategy for London Planning Guidance The Mayor's Transport Plan The London Plan Draft Industrial capacity SPG The Mayor's Air Quality Strategy The London Plan SPG London View Management Framework Rethinking Rubbish in London: The Mayor's The London plan SPG Sustainable Design and Municipal waste management strategy Construction The Mayor's Energy Strategy The London plan SPG Accessible London: Achieving an inclusive environment The Mayor's Biodiversity Strategy The Mayor's Childcare Strategy The Mayo's Ambient Noise Strategy The Mayor's Cultural Strategy The Mayor's Children and Young People's The Mayor's Older People Strategy Strategy Mayor's Draft Food Strategy Mayor's Rough Sleepers Strategy Mayor's Economic Development Strategy <a href="/tags/Greater_London/" rel="tag">Greater London</a> Biodiversity Action Plan (2005) Partnership for Health: Challenges for Action London Cultural Capital: Realising the 2006 – 2008 LHC potential of a World Class City 2004 Success through diversity. London's Economic Development Strategy Sub Regional West London Sub- Regional Development West London Tourism Strategy and Action 18London Borough of Harrow , Stanmore Framework Plan Building Communities a Housing Strategy for West London – Draft Municipal Waste West London Management Strategy Improving the Evidence Base for the Waste Development Plan Document Process in West London Local A Community Strategy for Harrow Harrow Private Sector Housing Renewal Strategy Harrow Unitary Development Plan 2004 Harrow Economic and Regeneration Strategy 2003 – 2010 Harrow SPG Designing New Development Harrow's Transport Local Implementation Plan Harrow SPG Extensions: A Householders Harrow Town Centre Development Strategy Guide Harrow SPG <a href="/tags/Harrow_on_the_Hill/" rel="tag">Harrow on the Hill</a> Station Harrow Tourism Strategy Planning Brief Harrow Council Access for all SPD (LDF) Draft Harrow Sport, Recreation and Open Space Strategy 2006 – 2016 Harrow Council Accessible Homes SPD Harrow's Green Belt Management Strategy 2006 – 2011 Harrow Community Engagement Strategy Harrow Children and Young People's plan 2006 – 2009 Harrow Corporate Plan 2005 – 2006 <a href="/tags/Harrow_School/" rel="tag">Harrow School</a> Organisation Plan 2003 – 2008 Harrow's Cultural Strategy 2003 – 2008 Harrow's Air Quality Action Plan 2004 Harrow Black & Minority Ethnic (BME) Safe Harrow: Crime, Drugs and Disorder Housing Strategy 2004 – 2007 Strategy 2005 – 2008 Harrow Housing Strategy 2002 – 2007 Harrow Retail Strategy (Donaldsons – March 2006) Harrow Learning Disability Housing Strategy Harrow Homelessness Strategy 2003 2003 – 2006 Harrow Conservation Area policy Statements Harrow Containment Land Strategy 2003 and Appraisals and Management Plans Harrow Statement of Community Harrow Core Strategy (LDF) Involvement (LDF) Harrow Site Specific Proposals (LDF) Harrow Sustainability Appraisal: Scoping Report for the Harrow Local Development Framework 19London Borough of Harrow , Stanmore Council Studies/ Research currently in progress London Borough of Harrow Employment Land Harrow in Business Review Study (URS) Business Mapping Incubator Study Phase 1 Harrow Economic Development and Creative Business Research Regeneration Review 20London Borough of Harrow , Stanmore 6.0 Sustainability Context and Issues for Bentley Priory 6.1 The Council have undertaken an SA scoping report for the Local Development Framework which was produced in November 2006. The scoping report was prepared to be applied to the preparation of all Local Development Documents (LDD's) programmed for preparation within the Local Development Scheme (LDS). 6.2 Stage A3 of the SA process involves identifying the sustainability issues and problems facing the area in question. The requirement to identify sustainability problems arises from the SEA Directive: 'any existing environmental problems which are relevant to the plan or programme including, in particular, those relating to any areas of a particular environmental importance, such as areas designated pursuant to Directives 79/409/EEC and 92/43/EEC.' 6.3 In preparing Harrow Councils Sustainability Appraisal: Scoping Report for the Harrow Local Development Framework a study was undertaken to look at baseline information for the area. The baseline exercise considered the following subject areas: • A Contextual Introduction to the London Borough of Harrow • West London and sub-regional context • Population and social profile of Harrow • Housing • Economy employment/ education and skills levels • Tourism • Transport • Community Safety and Crime • Health • The Environmental and Heritage bas of Harrow • Waste Planning • Energy and Renewables 21London Borough of Harrow , Stanmore • Climate Change • Air Quality 6.4 During analysis of the baseline information the following issues were identified following external verification from Scott Wilson against which the potential effects of DPD's and SPD's can be identified. The list is set out below SEA/SA Overarching SEA/SA Objective Objective No. 1 To make the most efficient use of land and buildings. 2 To protect the quality, quantity and accessibility of open spaces in the Borough. 3 To conserve and enhance biodiversity in the Borough. 4 To restrict development which can negatively affect the landscape and streetscape and design of historic, archaeological sites (listed buildings and conservation areas) or culturally important features. 5 To ensure air quality continues to improve through reducing air pollution and address the causes of climate change through reducing emissions of greenhouse gasses and other pollutants (including air, water, soil, noise, vibration and light). 6 To reduce pollution of land (soil) and ensure that contaminated land is remediated. 7 To improve water quality and reduce the risk ands impact of flooding. 8 To promote development that ensures the sustainable use of energy. 9 To discourage the production of waste and promote further the waste hierarchy of minimisation, reuse, recycling and composting. 10 To facilitate the development of a dynamic and diverse economic sector which attracts growth. 11 To improve the education and skills of the Borough. 12 To ensure all groups have access to decent, appropriate and affordable housing that meets the needs of Harrow's residents. 13 To reduce social exclusion and facilitate the development of mixed and balanced communities. 14 To improve the health and wellbeing of Harrow residents and reduce inequalities in health. 15 To improve the competitiveness, vitality, viability and adaptability of town centres in Harrow. 16 To reduce crime, fear of crime and anti social activity. 22London Borough of Harrow , Stanmore 6.5 Taking account of the above mentioned issues baseline assessments were made of Bentley Priory in planning, heritage, landscape and ecological terms. The following sections set out the baseline assessment which guided the preparation of options for the SPD. 23London Borough of Harrow , Stanmore 7.0 Planning Policy Review 7.1 The following planning policy review will look at extracts from National Guidance, Regional Guidance and Local Planning Policy in the context of the Bentley Priory Site. Regard has been taken for policy designations at the site such as Green Belt, Historic Parks and Gardens and the Priory Listed Building in extracting relevant sections of national and regional guidance. National Planning Guidance PPS 1- Delivering Sustainable Development (2005) 7.2 This Planning Policy Statement sets out the Governments commitment to the principals of sustainable development. In the introduction PPS1 states: ‘Good planning ensures that we get the right development, in the right place and at the right time. It makes a positive difference to peoples lives and helps to deliver homes, jobs and better opportunities for all whilst protecting and enhancing the natural and historic environment, and conserving the countryside and open spaces that are vital resources for everyone.’ 7.3 In planning for sustainable development PPS 1 sets out the following key factors to focus upon in achieving the sustainable development objective: ƒ Social Cohesion and Inclusion; ƒ Protection and Enhancement of the Environment; ƒ Prudent Use of Natural Resources; ƒ Sustainable Economic Development; and ƒ Integrating Sustainable Development in Development Plans. 7.4 With specific reference to conservation and environmental designations at the Bentley Priory site particular attention should be made towards ‘Protection and 24London Borough of Harrow , Stanmore Enhancement of the Environment’. The Governments objectives are clear at paragraph 17 on this point which states: ‘The Government is committed to protecting and enhancing the quality of the natural and historic environment, in both rural and urban areas. Planning policies should seek to protect and enhance the quality, character and amenity value of the countryside and urban areas as a whole. A high level of protection should be given to most valued townscapes and landscapes, wildlife habitats and natural resources. Those with national and international designations should receive the highest level of protection.’ 7.5 PPS1 also deals with design stating at paragraph 33 that: ‘Good design ensures attractive usable, durable and adaptable places and is a key element in achieving sustainable development. Good design is indivisible from good planning.’ 7.6 As well as promoting good design to ensure the quality of proposals PPS1 also notes that all those involved in the development process should have the objective of delivering good design, stating at paragraph 35 that: ‘High quality and inclusive design should be the aim of all those involved in the development process. High quality and inclusive design should create well-mixed and integrated developments which avoid segregation and have well-planned public spaces that bring people together and provide opportunities for physical activity and recreation. It means ensuring a place will function well and add to the overall character and quality of the area, not just for the short term but over the lifetime of the development. This requires carefully planned, high quality buildings and spaces that support the efficient use of resources. Although visual appearance and the architecture of individual buildings are clearly factors in achieving these objectives, securing high quality and inclusive design goes far beyond aesthetic considerations. 25London Borough of Harrow , Stanmore Good design should: ƒ address the connections between people and places by considering the needs of people to access jobs and key services; ƒ be integrated into the existing urban form and the natural and built environments; ƒ be an integral part of the processes for ensuring successful, safe and inclusive villages, towns and cities; ƒ create an environment where everyone can access and benefit from the full range of opportunities available to members of society; and, ƒ consider the direct and indirect impacts on the natural environment.’ PPG 2- Green Belts (1995) 7.7 Paragraph 1.4 of PPG 2 sets out the intentions of the governments Green Belt guidance which states: ‘The fundamental aim of Green Belt policy is to prevent urban sprawl by keeping land permanently open; the most important attribute of Green Belts is their openness. Green Belts can shape patterns of urban development at sub-regional and regional scale, and help to ensure that development occurs in locations allocated in development plans. They help to protect the countryside, be it in agricultural, forestry or other use. They can assist in moving towards more sustainable patterns of urban development (see paragraph 2.10).’ 7.8 In terms of the re-use of buildings within the Green Belt paragraph 3.8 of the document sets out the criteria by which proposals would be acceptable, which states: 26London Borough of Harrow , Stanmore ‘The re-use of buildings inside a Green Belt is not inappropriate development providing: (a) it does not have a materially greater impact than the present use on the openness of the Green Belt and the purposes of including land in it; (b) strict control is exercised over the extension of re-used buildings, and over any associated uses of land surrounding the building which might conflict with the openness of the Green Belt and the purposes of including land in it (eg because they involve extensive external storage, or extensive hardstanding, car parking, boundary walling or fencing); (c) the buildings are of permanent and substantial construction, and are capable of conversion without major or complete reconstruction; and (d) the form, bulk and general design of the buildings are in keeping with their surroundings. (Conversion proposals may be more acceptable if they respect local building styles and materials, though the use of equivalent natural materials that are not local should not be ruled out).’ 7.9 In the context of the site in question annex C of PPG2 sets out guidance for major developed sites in the green belt which includes within its description ‘military establishments’ such as Bentley Priory. The annex states: ‘Future Of Major Developed Sites In The Green Belt C1 Green Belts contain some major developed sites such as factories, collieries, power stations, water and sewage treatment works, military establishments, civil airfields, hospitals, and research and education establishments. These substantial sites may be in continuing use or be redundant. They often pre-date the town and country planning system and the Green Belt designation. C2 These sites remain subject to development control policies for Green Belts, and 27London Borough of Harrow , Stanmore the Green Belt notation should be carried across them. If a major developed site is specifically identified for the purposes of this Annex in an adopted local plan or UDP, infilling or redevelopment which meets the criteria in paragraph C3 or C4 is not inappropriate development. In this context, infilling means the filling of small gaps between built development. Infilling C3 Limited infilling at major developed sites in continuing use may help to secure jobs and prosperity without further prejudicing the Green Belt. Where this is so, local planning authorities may in their development plans identify the site, defining the boundary of the present extent of development and setting out a policy for limited infilling for the continuing use within this boundary. Such infilling should: (a) have no greater impact on the purposes of including land in the Green Belt (paragraph 1.5) than the existing development; (b) not exceed the height of the existing buildings; and (c) not lead to a major increase in the developed proportion of the site. Redevelopment C4 Whether they are redundant or in continuing use, the complete or partial redevelopment of major developed sites may offer the opportunity for environmental improvement without adding to their impact on the openness of the Green Belt and the purposes of including land within it. Where this is the case, local planning authorities may in their development plans identify the site, setting out a policy for its future redevelopment. They should consider preparing a site brief. Redevelopment SHOULD: (a) have no greater impact than the existing development on the openness of the Green Belt and the purposes of including land in it, and where possible have less; 28London Borough of Harrow , Stanmore (b) contribute to the achievement of the objectives for the use of land in Green Belts (paragraph 1.6 - see also paragraph 3.13); (c) not exceed the height of the existing buildings; and (d) not occupy a larger area of the site than the existing buildings (unless this would achieve a reduction in height which would benefit visual amenity). C5 The relevant area for the purposes of (d) is the aggregate ground floor area of the existing buildings (the "footprint"), excluding temporary buildings, open spaces with direct external access between wings of a building, and areas of hard standing. C6 The character and dispersal of proposed redevelopment will need to be considered as well as its footprint. For example many houses may together have a much smaller footprint than a few large buildings, but may be unacceptable because their dispersal over a large part of the site and enclosed gardens may have an adverse impact on the character of the Green Belt compared with the current development. The location of the new buildings should be decided having regard to the openness of the Green Belt and the purposes of including land in it, the objectives for the use of land in Green Belts, the main features of the landscape, and the need to integrate the new development with its surroundings. For instance it may be more appropriate to site new development closer to existing buildings. C7 The site should be considered as a whole, whether or not all the buildings are to be redeveloped. The test of area in paragraph C5 relates to the redevelopment of the entire site; any proposals for partial redevelopment should be put forward in the context of comprehensive, long-term plans for the site as a whole. C8 Proposals should be considered in the light of all material considerations, including for example visual amenity (see paragraph 3.15 of this PPG) and the traffic and travel implications of redevelopment (see PPG13). C9 Where buildings are demolished rather than being left in a semi-derelict state 29London Borough of Harrow , Stanmore pending decisions about their redevelopment, it will be necessary to keep suitable records for the purposes of paragraph C5. These should be agreed between the local planning authority and the landowner. C10 In granting any planning permission local authorities may wish to consider whether to impose conditions to ensure that buildings which are not to be retained permanently are demolished as new buildings are erected, thus keeping the total developed area under control. Architectural and historic interest C11 Suitable re-use is to be preferred to redevelopment where the buildings are of architectural or historic interest. Any proposals for altering or demolishing listed buildings or which affect their settings should be considered in the light of the advice in Planning Policy Guidance 15: Planning and the Historic Environment. C12 Local planning authorities should have regard to the desirability of preserving gardens and grounds of special historic interest. The English Heritage register of historic gardens lists sites of particular importance (see PPG15). Public expenditure C13 Redevelopment should not normally require additional expenditure by the public sector on the provision of infrastructure, nor should it overload local facilities such as schools and health care facilities. Local planning authorities should take account of any additional infrastructure requirements (eg roads) which may have significant adverse effects on the Green Belt. Adequate financial provision should where necessary be made for the future maintenance of landscaped areas (taking account of advice in DoE Circular 16/91, Planning Obligations).’ PPS 3- Housing (2006) 7.10 PPS3 sets out the planning policy framework for delivering the Government’s 30London Borough of Harrow , Stanmore housing objectives. The Government’s strategic housing objective is set out at paragraph 9, which states ‘The Government’s key housing policy goal is to ensure that everyone has the opportunity of living in a decent home, which they can afford, in a community where they want to live. To achieve this, the Government is seeking: To achieve a wide choice of high quality homes, both affordable and market housing, to address the requirements of the community. To widen opportunities for home ownership and ensure high quality housing for those who cannot afford market housing, in particular those who are vulnerable or in need. To improve affordability across the housing market, including by increasing the supply of housing. To create sustainable, inclusive, mixed communities in all areas, both urban and rural. 7.11 PPS3 also takes note of the high quality design objectives set out within PPS1 and at paragraph 12 states: ‘Good design is fundamental to the development of high quality new housing, which contributes to the creation of sustainable, mixed communities.’ PPG 13- Transport (2001) 7.12 The General objectives of PPG13 are set out at paragraph 4, that states: ‘1. promote more sustainable transport choices for both people and for moving 31London Borough of Harrow , Stanmore freight; 2. promote accessibility to jobs, shopping, leisure facilities and services by public transport, walking and cycling, and 3. reduce the need to travel, especially by car.’ PPG15- Planning and the Historic Environment (1994) 7.13 PPG 15 details the Government’s policies for the identification and protection of historic buildings, conservation areas, and other elements of the historic environment. It explains the role played by the planning system in their protection. 7.14 In terms of Listed Building control paragraph 3.4 of the document sets out the broad assessment that is required by applicants for Listed Building Consent, which states: ‘Applicants for listed building consent must be able to justify their proposals. They will need to show why works which would affect the character of a listed building are desirable or necessary. They should provide the local planning authority with full information, to enable them to assess the likely impact of their proposals on the special architectural or historic interest of the building and on its setting.’ Regional Planning Policy London Plan (2004) 7.15 The London Plan is prepared by the Greater London Authority (GLA) and sets out the strategic plan for development in London, Harrow falls within the West London sub-region. In general the strategy set out in the London Plan would not have any major influences upon the future use of the Bentley Priory. However, the document does include policies of relevance with regards to affordable housing, the green belt and heritage and the built environment. 32London Borough of Harrow , Stanmore 7.16 The existing site has a number residential units and its development potential includes that for residential purposes. As such it is appropriate to highlight the affordable housing targets set out within the London Plan which state at Policy 3A.7 that: ‘UDP policies should set an overall target for the amount of affordable housing provision over the plan period in their area, based on an assessment of all housing needs and a realistic assessment of supply. In setting targets boroughs should take account of regional and local assessments of need, the Mayor’s strategic target for affordable housing provision that 50 per cent of provision should be affordable and, within that, the London wide objective of 70 per cent social housing and 30 per cent intermediate provision, and the promotion of mixed and balanced communities. They should take account of the most robust available assessment of housing capacity, and of potential sources of supply, such as: ƒ local authority developments, including estate renewals ƒ Registered Social Landlords’ developments ƒ low-cost market housing, where it can be shown to be affordable ƒ private residential development negotiations secured through planning agreements or conditions ƒ vacant properties brought back into use ƒ provision from non-self-contained accommodation.’ 7.17 With regards to the Green Belt the Mayor supports its protection at policy 3D.8 in accordance with PPG2, stating: 33London Borough of Harrow , Stanmore ‘Policy 3D.8 Green Belt The Mayor will and boroughs should maintain the protection of London’s Green Belt and proposals for alterations to Green Belt boundaries should be considered through the UDP process in accordance with government guidance in PPG2. There is a general presumption against inappropriate development in the Green Belt, and such development should not be approved except in very special circumstances.’ 7.18 In terms of the built heritage the London Plan notes two thousand years of history which have left layers of history, illuminating London’s social, political and economic heritage. The Policies of note set out within the plan deal with issues of London’s built heritage (4B.10), Heritage conservation (4B.11) and Historic conservation-led regeneration (4B.12), which state: ‘Policy 4B.10 London’s built heritage The Mayor will work with strategic partners to protect and enhance London’s historic environment. UDP policies should seek to maintain and increase the contribution of the built heritage to London’s environmental quality, to the economy, both through tourism and the beneficial use of historic assets, and to the well-being of London’s people while allowing for London to accommodate growth in a sustainable manner. Policy 4B.11 Heritage conservation Boroughs should: ƒ ensure that the protection and enhancement of historic assets in London are based on an understanding of their special character, and form part of the wider design and urban improvement agenda, and that policies recognise the multi-cultural nature of heritage issues ƒ identify areas, spaces and buildings of special quality or character and adopt policies for their protection and the identification of opportunities for their 34London Borough of Harrow , Stanmore enhancement, taking into account the strategic London context ƒ encourage and facilitate inclusive solutions to providing access for all, to and within the historic environment. Policy 4B.12 Historic conservation-led regeneration The Mayor will, and boroughs should, support schemes that make use of historic assets and stimulate environmental, economic and community regeneration where they: ƒ bring redundant or under-used buildings and spaces into appropriate use ƒ secure the repair and re-use of Buildings at Risk ƒ help to improve local economies and community cohesion ƒ fit in with wider regeneration objectives ƒ promote inclusiveness in their design.’ Local Plan Policy 7.19 The adopted Local Plan is the Harrow Unitary Development Plan (July, 2004), the site has a number of designations within the UDP which shall be addressed in turn below. 7.20 The site lies within the Green Belt and as such policy SEP5 sets out which structural features should be sought for protection and enhancement, and states: 35London Borough of Harrow , Stanmore ‘THE COUNCIL WILL SEEK THE PROTECTION AND ENHANCEMENT OF THE FOLLOWING STRUCTURAL FEATURES:- AREAS OF SPECIAL CHARACTER; GREEN BELT; METROPOLITAN OPEN LAND; GREEN CHAINS; PUBLIC OPEN SPACE, HISTORIC PARKS AND GARDENS; PRIVATE OPEN SPACE; EDUCATIONAL OPEN SPACE; ALLOTMENTS; CEMETERIES; INFORMAL OPEN SPACE; TREE MASSES AND SPINES; REAR GARDEN INTERFACES; AREAS EXHIBITING A HIGH QUALITY OF STREETSIDE GREENNESS AND FORECOURT GREENERY; WATERCOURSES, RIVER CORRIDORS, WETLANDS AND OTHER WATER FEATURES; AND SITES OF SPECIAL SCIENTIFIC INTEREST (SSSI’S) AND OTHER SITES OF NATURE 36London Borough of Harrow , Stanmore CONSERVATION IMPORTANCE, NAMELY THE COUNTRYSIDE CONSERVATION AREA, SITES OF LOCAL AND METROPOLITAN IMPORTANCE AND SITES PENDING SUCH DESIGNATION. IN CONSIDERING PROPOSALS WHICH AFFECT A STRUCTURAL FEATURE, AN ASSESSMENT WILL BE UNDERTAKEN OF THE CONTRIBUTION THE SITE MAKES TO THE DISTRIBUTION OF LAND USES AND PHYSICAL CHARACTER OF THE LOCALITY AND TO THE CUMULATIVE VALUE OF THE CATEGORY OF THE STRUCTURAL FEATURE IN WHICH IT FALLS.’ 7.21 Other than the Green Belt designation of the site other structural features within the site are: ƒ Area of Special Character and; ƒ Historic Parks and Gardens designations. 7.22 The site is also adjacent to the following structural features: ƒ To the south- Site of Special Scientific Interest (SSSI) and; ƒ To the east and south- Sites of Nature Conservation Importance. 7.23 With regards to the Green Belt setting of the Bentley Priory site it has also been identified as a major developed site in the green belt within Policy EP35, as such the Council are required to provide a development brief. In terms of providing a development brief for Bentley Priory as set out in EP35 the Council have noted the importance of management plans for individual sites in the Green Belt within Policy EP41, that states: ‘IN CONSIDERING PLANNING APPLICATIONS IN THE GREEN BELT, THE COUNCIL WILL TAKE THE MANAGEMENT PLANS OF INDIVIDUAL SITES OR AREAS INTO 37London Borough of Harrow , Stanmore ACCOUNT.’ 7.24 The following Green Belt Policies are also included within the UDP to aid with the development process and development control decisions: ƒ EP32 Green Belt-Acceptable Land Uses; ƒ EP33 Development in the Green Belt; ƒ EP34 Extension to Buildings in the Green Belt; and ƒ EP37 Re-Use of Existing Buildings in the Green Belt. 7.25 Turning now to the Area of Special Character structural designation Policy SEP6 of the UDP deals with the issues of appropriate land uses for the Areas of Special Character considerations for proposals on such sites. Policy SEP6 states: ‘THE COUNCIL WILL IDENTIFY APPROPRIATE USES ON LAND DESIGNATED AS AN AREA OF SPECIAL CHARACTER, GREEN BELT OR METROPOLITAN OPEN LAND. IN CONSIDERING DEVELOPMENT PROPOSALS IN THESE AREAS, THE COUNCIL WILL ENSURE THAT SUCH DEVELOPMENTS HAVE NO SIGNIFICANT ADVERSE IMPACT ON THE INTEGRITY, CHARACTER, APPEARANCE, AMENITY AND NATURE CONSERVATION VALUE OF THE SITE AND THE SURROUNDING AREA, OR ON PUBLIC ACCESS AND ENJOYMENT OF THE COUNTRYSIDE.’ 7.26 In terms of criteria for proposals within Areas of Special Character Policy EP31 sets out tests for determination, which states: ‘WITHIN THE AREAS OF SPECIAL CHARACTER, AS SHOWN ON THE PROPOSALS MAP, THE COUNCIL WILL:- 38London Borough of Harrow , Stanmore RESIST THE LOSS OF, OR DAMAGE TO, FEATURES WHICH CONTRIBUTE TO THE AREA OF SPECIAL CHARACTER; PRESERVE ARCHITECTURAL AND HISTORIC FEATURES WHICH CONTRIBUTE TO THE CHARACTER OF THE AREA; PROTECT SKYLINES AND VIEWS FROM INTRUSIVE DEVELOPMENT; AND ENSURE THAT REDEVELOPMENT SCHEMES PRESERVE OR IMPROVE THE CHARACTER AND APPEARANCE OF THE AREA.’ 7.27 The Priory building is a Grade II* listed property and in dealing with this the Historic Parks and Gardens designation Policy SD2 sets out the following objectives: ‘THE COUNCIL WILL PRESERVE OR ENHANCE THE CHARACTER OR APPEARANCE OF CONSERVATION AREAS, PRESERVE THE SPECIAL INTEREST OF LISTED BUILDINGS AND PROTECT SITES OF ARCHAEOLOGICAL IMPORTANCE AND HISTORIC PARKS AND GARDENS.’ 7.28 With regards to the Priory building Policy D11 sets out the criteria by which it will protect listed properties which states: ‘THE COUNCIL WILL ENSURE THE PROTECTION OF THE BOROUGH'S STOCK OF LISTED BUILDINGS BY:- 1. ONLY PERMITTING DEMOLITION IN EXCEPTIONAL CIRCUMSTANCES; 2. ONLY PERMITTING ALTERATIONS AND EXTENSIONS THAT PRESERVE THE CHARACTER AND SETTING OF THE LISTED BUILDING AND ANY FEATURES OF ARCHITECTURAL OR HISTORIC INTEREST WHICH IT POSSESSES, BOTH 39London Borough of Harrow , Stanmore INTERNALLY AND EXTERNALLY; 3. ONLY PERMITTING DEVELOPMENTS WITHIN THE CURTILAGE OF LISTED BUILDINGS, OR ADJOINING BUILDINGS, THAT DO NOT DETRIMENTALLY AFFECT THEIR SETTING; 4. ENCOURAGING THE MAINTENANCE AND RESTORATION OF LISTED BUILDINGS BY:- 1. ADVISING OWNERS AND OCCUPIERS ON REPAIRS AND ALTERATIONS TO THEIR LISTED BUILDINGS AND ON FINANCIAL AND TECHNICAL HELP WHICH MAY BE AVAILABLE; 2. USING ITS POWERS UNDER SECTIONS 47-50 AND 54-55 OF THE PLANNING (LISTED BUILDINGS AND CONSERVATION AREAS) ACT 1990, WHERE APPROPRIATE, TO SECURE THE REPAIR OF LISTED BUILDINGS; AND 3. WHEN RESOURCES PERMIT, PROVIDING FINANCIAL AID FOR RESTORATION WORK, UNDER SECTION 57 OF THE PLANNING (LISTED BUILDINGS AND CONSERVATION AREAS) ACT 1990.’ 7.29 The Policy extract above deals with the criteria by which Listed Buildings will be protected. The Local Plan also identifies that it may be acceptable for changes of use to a Listed Building if it is required to reserve that building within Policy D13, which states: ‘WHERE IT CAN BE CLEARLY DEMONSTRATED TO THE COUNCIL'S SATISFACTION THAT A CHANGE OF USE OF A STATUTORILY LISTED BUILDING IS REQUIRED TO PRESERVE THAT BUILDING, AND WHERE ALTERATIONS REQUIRED FOR THE NEW USE DO NOT DIMINISH THE ARCHITECTURAL OR HISTORIC VALUE OF THE BUILDING OR ITS SETTING, SUCH A PROPOSAL MAY BE CONSIDERED TO OVERRIDE OTHER PLAN POLICIES AND BUILDING CONTROL STANDARDS IN APPROPRIATE CASES.’ 40London Borough of Harrow , Stanmore 7.30 With regards to the Historic Parks and Gardens Policy D18 of the UDP sets out the Council’s position in terms of conservation, which is set out below: ‘THE COUNCIL WILL RESIST DEVELOPMENT PROPOSALS WHICH WOULD ADVERSELY AFFECT THE CHARACTER OR APPEARANCE OR THE SETTING OF PARKS AND GARDENS OF SPECIAL HISTORIC INTEREST.’ 7.31 The site is situated upon the Weald Ridge which is highly visible from south. The UDP identifies a number of views and landmarks including those that look from Harrow town in the South towards the site and surrounding Weald Ridge, protection is afforded to these views by Policy D31, that states: ‘THE COUNCIL WILL RESIST DEVELOPMENT THAT HAS AN ADVERSE IMPACT ON IMPORTANT LOCAL VIEWS, PANORAMAS AND PROSPECTS, AND WILL SEEK TO ENSURE THAT PUBLIC ACCESS TO IDENTIFIED VIEWPOINTS IS MAINTAINED AND ENHANCED.’ 7.32 Turning now to general UDP policy the site currently has a large amount of accommodation associated with the RAF usage, as such it is appropriate to set out the Council’s affordable housing requirements. Policy H5 states: ‘THE COUNCIL WILL SEEK THE MAXIMUM REASONABLE PROPORTION OF AFFORDABLE HOUSING ON SUITABLE SITES OF 0.5 HECTARES OR MORE, OR ON DEVELOPMENTS OF 15 OR MORE DWELLINGS. PROVISION SHOULD NORMALLY BE ON-SITE. IN AGREEING THE LEVEL AND FORM OF AFFORDABLE HOUSING PROVISION ON ANY INDIVIDUAL SITE, THE COUNCIL WILL HAVE REGARD TO:- A) BOROUGH-LEVEL, SUB-REGIONAL AND REGIONAL TARGETS (SEE POLICIES SH1 AND H6); AND B) INDIVIDUAL SITE COSTS AND ECONOMIC VIABILITY, INCLUDING THE 41London Borough of Harrow , Stanmore AVAILABILITY OF PUBLIC SUBSIDY AND OTHER PLANNING OBJECTIVES. THE COUNCIL CONSIDERS THAT THE LIKELY MINIMUM PERCENTAGE OF AFFORDABLE HOUSING TO BE NEGOTIATED ON SUITABLE SITES SHOULD BE 30%. THE COUNCIL WILL ENSURE, THROUGH THE USE OF PLANNING OBLIGATIONS, THAT THE OCCUPATION OF AFFORDABLE HOUSING IS RESTRICTED TO PEOPLE WHO ARE REGARDED BY THE COUNCIL AS IN NEED OF AFFORDABLE HOUSING. THE AFFORDABLE HOUSING PROVIDED SHOULD BE AVAILABLE TO PROSPECTIVE OCCUPANTS (TO BOTH INITIAL AND SUBSEQUENT OCCUPIERS). THE REQUIREMENT SET OUT IN THE LAST TWO PARAGRAPHS ABOVE WILL BE DEEMED TO HAVE BEEN MET IF THE AFFORDABLE HOUSING IS TRANSFERRED TO A REGISTERED SOCIAL LANDLORD APPROVED BY THE COUNCIL.’ 7.33 With regards to general design guidelines policy D4 of the Local Plan sets out the Council’s standards. Policy D4 states: ‘THE COUNCIL WILL EXPECT A HIGH STANDARD OF DESIGN AND LAYOUT IN ALL DEVELOPMENT PROPOSALS. THE FOLLOWING FACTORS WILL BE TAKEN INTO ACCOUNT WHEN CONSIDERING PLANNING APPLICATIONS FOR DEVELOPMENT: A) SITE AND SETTING; B) CONTEXT, SCALE AND CHARACTER; C) PUBLIC REALM; D) ENERGY EFFICIENCY, RENEWABLE ENERGY, SUSTAINABLE DESIGN AND CONSTRUCTION; 42London Borough of Harrow , Stanmore E) LAYOUT, ACCESS AND MOVEMENT; F) SAFETY; G) LANDSCAPE AND OPEN SPACE; AND H) ADEQUATE REFUSE STORAGE. THE COUNCIL WILL REQUIRE PLANNING APPLICATIONS FOR NEW-BUILD DEVELOPMENT TO INCLUDE A SUPPORTING DESIGN STATEMENT. Local Development Framework (LDF) 7.34 In terms of Harrow’s LDF preparation the timetable for producing the Local Development Documents is currently being revised. Hertsmere Local Plan (2003) 7.35 There are no site specific policies within the Borough of Hertsmere’s Local Plan that would affect the Bentley Priory Site. In terms of the Area of Special Landscape Character identified by Harrow Council, Hertsmere do not have a similar wholesale designation. However, there is a small section of land which abuts Stanmore Common which has a Wildlife Site designation (Policy E2). 7.36 In terms of strategic objectives set out within Hertsmere’s local plan there are no policies of note that contradict with Harrow’s principles for the area in general. 43London Borough of Harrow , Stanmore 8.0 Implications of Planning Policy Framework 8.1 As noted in the above mentioned Planning Policy Review section there are several on site and adjacent planning policy considerations that would have to be addressed in respect of any development proposals at the site. Green Belt 8.2 Dealing firstly with PPG2 the thrust of the policy is to maintain the open nature of designated areas to prevent urban sprawl and ensure that development takes place within areas identified on development plans. PPG2 does not rule out the re-use of properties within Green Belts, however, it establishes that strict controls should be exercised over proposals within this designation. 8.3 Annex C pf PPG2 sets out criteria for major development sites such as Bentley Priory in respect of both ‘Infilling’ and ‘Redevelopment’, this allows for major developed sites within the Green Belt to promote appropriate development in accordance with the criteria set out within C3 and C4 of the annex. Principal considerations set out within the criteria include issues of impact, height of buildings, proportion of development and site area of development, it can be noted that area in these terms means aggregate ground floor area i.e. footprint not overall floorspace. The annex also takes account of buildings which have architectural and historic interest and favours re-use rather than development of buildings associated to this designation. 8.4 In terms of regional guidance the London Plan also supports the approach adopted by PPG2. 8.5 Turning now to Harrow’s UDP, policy SEP5 supports the protection and enhancement of the green belt, however, it makes note that the Council will have regard to any proposal within the green belt on sites with management plans under policy EP35. Bentley Priory is designated as a major developed site within the green belt accordingly it is identified for a management plan, which reflects the developed nature of the site. In accordance with this designation PPG2 provides the criteria by which potential development of the site should be 44London Borough of Harrow , Stanmore assessed. The Historic Environment 8.6 PPG15 sets out clear guidance for the retention of listed buildings and their character, as such any proposals for the site would have to take account of the Priory’s Grade II* setting. The protection and enhancement of heritage asserts are further reinforced within Regional Guidance and Local Planning Policy. It would be necessary for any future development proposals that would affect the setting of the listed building or the building itself to include sufficient robust justification to do so. In terms of the context of the site the Priory building has been central to its development in the wider parkland now designated as a historic park and garden. As such it is not only the immediate area around the Priory that must be addressed in terms of heritage assets but it is also the site as a whole. An SPD will allow for the general themes of development in the context of the historic assets of the site to be set out, however, this must be taken forward at the detailed stage to provide justification. Protected views 8.7 Whilst the view is only recognised within Local Planning Policy, its context can also be found in the development of the parkland around the Priory, therefore it also has a historic perspective. The views afforded the site have localised impacts because due to topography and planting on the site it means that much of the built development here is barely visible resulting in the open countryside setting favoured within Green Belt policy. It is important therefore that any future development areas highlighted take account of this characteristic because of the importance in terms of views, heritage assets and the green belt setting. Accessibility 8.8 PPG13 places emphasis upon the promotion of travel by public transport and also stresses a need to reduce transport by private car. Bentley Priory is a poor location in these terms because it is not well connected by public transport. This also has an impact upon delivering sustainable development at the site in respect of PPS1. Therefore there would be a general presumption against a development use at the site that would generate large amounts of visitors. 45London Borough of Harrow , Stanmore 46London Borough of Harrow , Stanmore 9.0 Cultural Heritage Baseline Assessment Introduction 9.1 This section of the report assesses cultural heritage value of the buildings and structures as found on site today and their relationship with the historic landscape setting. Section 5 can be read in accordance with the Heritage Assets and Extent of Listed Buildings Plan attached as appendix 2. 9.2 Use of existing survey and assessment work1 provides a comprehensive audit of what remains on site today with indicators of what is considered to be of value in architectural, archaeological and historical terms; the nature and extent of the ‘listing’ and the value of its setting today. These documents supported by further research where appropriate and extensive site survey form the basis for this baseline assessment of the heritage value of the buildings and site, which in turn provides the basis for identification of initial constraints and opportunities for re-use, restoration and redevelopment of the site. The results of this are fed into the draft masterplan, together with planning and landscape/ecological considerations to identify the development potential of the site and buildings. 9.3 This report focuses on the development of this site from the later part of the 18th century through to the early 20th century and the period of the RAF’s tenure of the site. 9.4 The report uses the Defence Estates numbering system for extant buildings when referring to individual buildings for ease of cross-reference with other documents. 1 An Historical Assessment of RAF Bentley Priory, Defence Estates, July 2004. Historic Building Quadrennial Inspection, Bentley Priory, The Conservation Practice, May 2001. The Buildings of England, London 3: North West, Bridget Cherry and Nikolaus Pevsner MoDel Disposal Sites Information Pack, RAF Bentley Priory, April 2005 Bentley Priory, A Provisional History, Jennifer Potter 25 March 1994. Sir John Soane and the Country Estate, Ptolemy Dean, Ashgate, 1999. An Illustrated History of RAF Bentley Priory, RAF. The Bentley Priory Battle of Britain Trust, Brochure. 47London Borough of Harrow , Stanmore 9.5 Heritage Designations 9.6 The principal building, Bentley Priory is included on the statutory list of buildings of special architectural or historic interest at grade II*, denoting the outstanding architectural or historic interest of the building2. The listed building comprises any object or structure fixed to the building and any object or structure within the curtilage which has formed part of the land since before 19483. There should be a general presumption in favour of the preservation of listed buildings4 except where a convincing case can be made out against the criteria in PPG15 for alteration or demolition. 9.7 The building is set within historic parkland (only part of which forms the site of the RAF base today) which is registered at grade II on the English Heritage Register of Parks and Gardens of Special Historic Interest. Whilst no additional statutory controls flow from the inclusion of a site on the Register, local planning authorities should protect registered parks and gardens in preparing planning policy and in determining planning applications5. 9.8 The site is not within a designated Archaeological Priority Area and does not include any scheduled monuments. However, a number of features are recorded on the Greater London Sites and Monuments Record within the site and immediate vicinity. These include extant surviving above ground structures (Central block of Bentley Priory House, garden pavilion in the grounds of Ad Astra), findspots (Roman coins and coin hoards, Roman cinerary urns and lamp) and landscaped layers. The C18th brick-lined water cisterns uncovered to the northwest of the Priory are being considered for statutory protection and may incorporate or re-use an earlier spring or cistern. This area (defined by the geophysical survey report carried out by GSB Prospection Limited on behalf of Defence Estates) is an area of constraint and the features should be preserved in situ whether protected or not. 9.9 The whole site is considered as having archaeological potential and ground intervention is likely to result in an archaeological response. Given the potential 2 PPG15, para. 3.6. 3 s.1(5) Planning (Listed Building and Conservation Areas) Act 1990 4 PPG15, para. 3.3 5 ibid, para. 2.24 48London Borough of Harrow , Stanmore for the presence of features of archaeological interest and it is likely that site investigations would be required prior to development. If features of interest are identified, then measures to protect them or to ensure their proper recording would be required in accordance with the policy and guidance of PPG16. Brief History of Bentley Priory and Estate 9.10 Located on the highest point in the historic county of <a href="/tags/Middlesex/" rel="tag">Middlesex</a> it is possible that the site was occupied in ancient times. Coins and cremation burials from the Roman period have been found within and adjacent to the RAF estate. The name “Bentley” is of Anglo-Saxon origin and suggests the immediate area will have had an established agricultural population by at least the late Saxon period. (P6 MOD est report). Establishment of an Augustinian Priory 9.11 This history of the estate can be traced back to 1170 when the original Augustinian Priory was founded by Raulf De Glanville. Nothing remains of the abbey and it was sited in the southern part of the parkland, outside the boundary of the Priory site today. James Duberly 9.12 In more recent times James Duberly (a clothier made wealthy through supply to the army) bought the Priory buildings and the 329 acre estate in 1776. It is reported that Duberly demolished the ruins of the Priory and built his house on higher land within the site to benefit form views south to St Mary’s Church at Harrow on the Hill and towards London. These views remain an important characteristic of the site today with potential for enhancement. The original house was incorporated within the Soane scheme (see below) and survives today albeit obscured and much altered by later additions and fire in the 20th century. A walled garden was built at this time, although only the gateway survives today forming part of building 10 to the west of the main house. 49London Borough of Harrow , Stanmore The Marquis of Abercorn 9.13 Architecturally, it is the work of Sir John Soane, for the Marquis of Abercorn which is of most significance and particularly warrants the grade II* listing. Three campaigns of work during 1789-94 and 1798-9 quadrupled the extent of the original house, the work being one of Soane’s most costly country house commissions6. The importance of the client and resulting associations of the house with leading political and artistic figures of the early 1800s such as Wordsworth, Scott and much of the Tory party of the time also give the house further national significance in terms of C19th historical association. 9.14 The challenge for Soane was to create something of classical simplicity working with a demanding client and the existing buildings. Today, both the interior and exterior of the principal building are of recognised importance as part of Soane’s canon of work. 9.15 The client, however, invited Sir Robert Smirke, to make alterations to the house around 1810 but it is not clear what work was undertaken. At this time the wider parkland setting of the house was established with carriageways, that running from Common Road to the north still present today, providing an important approach to the building, originally through a woodland entrance, then parkland, to arrive at the port-cochere of the Priory. Dowager Queen Adelaide 9.16 The Marquis died in 1818 leaving the Priory to his 7 year old grandson James Hamilton, who is known to have corresponded with William Sawrey Gilpin, a notable landscape designer, in 1822. He leased the property to the Dowager Queen Adelaide, widow of William IV, between 1846 -1849 who died at the property. There is a Victorian decorated ceiling in a Renaissance style in what is know today as Queen Adelaide’s Room. Sir John Kelk 6 Ptolemy Dean, op cit, p55 50London Borough of Harrow , Stanmore 9.17 In 1852 Sir John Kelk, a prominent engineer and contractor, purchased the property. He added the portico to the south elevation, a conservatory (now demolished – the site occupied by a 3 storey accommodation block) and clock tower to the west and laid out the Italian terraced garden, significantly altering the southern aspect. Extensive greenhouses and an indoor tennis court were built in the estate together with further greenhouses and a stable block to the west. Significant trees remain from this period and it is believed that this is the time that Soane’s music room, to the north side of the house, was demolished. Fredrick Gordon 9.18 In 1882 Frederick Gordon purchased the Priory estate and the building was converted into a hotel. The principal additions at this time were a billiard and smoking room (the current mess and dining room) and a new accommodation block sited between the conservatory and a tennis court on the site of a connecting corridor built by Kelk. He also built a dwelling for himself, Glenthorn, to the west of the Priory. This has since been demolished and the area developed for the army and later the RAF in the 1950s and 1960s. The Girl’s School 9.19 In 1908 the Priory was sold again following the failure of the hotel and leased by Stanmore Estates Ltd for use as a girl’s school. Few structural changes were required, though two new buildings were constructed, now offices and the Officers’ quarters (Buildings 10 & 11) adjoining immediately to the west of the tennis court and gym buildings (Buildings 8 and 9). The <a href="/tags/Royal_Air_Force/" rel="tag">Royal Air Force</a> 9.20 In 1926 the Air Ministry bought the Priory and 40 acres of the surrounding parkland. As a result only one of the principal carriageways has remained (in use today), a number of buildings were erected obscuring the principal approach and the park became obscured by planting and security measures. Whilst of historical interest, the architectural quality of these different phases varies significantly. Importantly, from 1936 to 1968 the Priory served as the headquarters of Fighter Command. 51London Borough of Harrow , Stanmore 9.21 During World War II Kelk’s conservatory was demolished and was eventually replaced with a new accommodation block in 1958. The Priory itself was initially used as offices, but more importantly during 1939-40 as the Operations Room, before the completion of a new underground bunker late in 1940. Air Chief Marshal <a href="/tags/Hugh_Dowding/" rel="tag">Hugh Dowding</a> chose the south facing library as his office, preserved to this day. 9.22 During the war, Bentley Priory and the Bunker (built in its original form in 1939/40) played a central role in the fight against the <a href="/tags/Luftwaffe/" rel="tag">Luftwaffe</a>. Particularly poignant war time episodes associated with Bentley Priory include the command and control during the Battle of Britain and the planning and monitoring of the D-Day landings (also using other buildings nearby). 9.23 A variety of timber and brick offices, motor transport, power, operations and general quarters buildings are shown on plans of 1939, 1961 and 1962 and clearly illustrate the development of the RAF establishment. There were numerous phases of demolition and development during the post-war period. 9.24 Fighter Command remained at Bentley Priory until 1968 when it was amalgamated into Strike Command to become HQ 11 (Fighter) Group. During this period Bentley Priory played a central role in countering the threat posed by the USSR and the Warsaw Pact nations. The principal RAF structure of historic interest from this time is the Bunker. Whilst this formed the operational headquarters of Fighter Command during the Battle of Britian, it was substantially rebuilt in 1982 and much of its original form was lost. This structure is understood to be the subject of review by English Heritage to assess whether statutory protection would be appropriate. 9.25 By the 1990s the Cold War was coming to an end, and in 1996, 11 Group was amalgamated with 18 Group with responsibility for air defence and maritime air operation with RAF Strike Command. Latterly, the site and buildings have been used for administrative, training and storage facilities with significant amounts of barracks accommodation. 52London Borough of Harrow , Stanmore 9.26 There was a programme of demolition and rebuilding of offices in the 1950s and 1960s, none of which are considered to be of specific architectural or historic interest with many impacting on the setting of the principal listed building. In the 1970s there was a comprehensive programme of demolition of former World War II structures and in the 1990s extensive new living and mess facilities were built to the west of the Priory. 9.27 Specific work to the Priory included the building of the accommodation block immediately to the west of the Priory in the late 1950s (Building 267), the extension of the dining room including a new roof and kitchen extension and fire damage repairs were also undertaken to the Ante Room (when the original ornate ceiling was lost)7. 9.28 Serious dry rot was discovered in the building in the mid 1960s and after further investigation in the mid 1970s resulted in part of the building being declared unsafe. Work had commenced on a major scheme of renovation of the Priory in June 1979 when a major fire broke out which destroyed most of the building to the west and the upper floor and roof8. A redecoration programme in 1990 involved the restoration of the painted ceiling to the entrance hall and the reinstatement of decorative details to the upper ground floor. 9.29 Summary of historical associations • Marquis of Abercorn: artistic and political circles which surrounded him • Sir John Soane: architect of the Priory one of his largest country house remodelling projects • Dowager Queen Adelaide: lived and died at the Priory, 1846 to 1849. • Air Chief Marshall Dowding: was fighter command for Battle of Britain from 1936 onwards 7 Op cit, Quadrennial Survey, May 2001 8 op cit Quadrennial Survey, May 2001. 53London Borough of Harrow , Stanmore • Eisenhower, Churchill and the King and Queen: visited at key moments during WWII. Historical Summary 9.30 The main architectural significance of the Priory today relates to the work of Soane. Later additions by Kelk and Gordon in the nineteenth century are also of note and contribute to the impressive ensemble of buildings as found today. Whilst no specific buildings aside from the bunker of special architectural or historical interest appear to remain from the period relating to World War II, the Priory has very important historical links with key events – principally Dowding, Fighter Command and the Battle of Britain and more latterly the Cold War. Special Architectural or Historic Interest 9.31 The principal building consists of the Soane mansion (incorporating the 1775 house built for Duberly) with later additions by Smirke and those that took place under the ownership of Sir John Kelk in the 19th century. These are considered to be the key elements of the building that are of special architectural or historic interest. Sir John Soane’s work 9.32 Born in 1753 John Soane is recognised as one of Britain’s most inventive architects. He undertook much work for country house owners, the significance of which has been more fully recognised in recent times9. His experience from theses projects influenced many of his larger new-build projects. 9.33 The existing building on the site and the client’s requirements constrained Soane’s designs and the implementation of a simple symmetrical composition. He was never proud of his exteriors at Bentley Priory and at a Royal Academy lecture in 1814 suggested that they “indicate the exterior of an hospital or extensive Manufactory”10. Despite setting the axis of the extensions on the existing house it is unlikely that Soane expected this to stay (it was not shown 9 Sir John Soane and the Country Estate, Ptolemy Dean, Ashgate 1999. 10 Ibid. 54London Borough of Harrow , Stanmore in any of the second stage drawings). However, in the third and final phase of his works in 1798 he built out a new entrance vestibule to conceal as much of the northern elevation as possible which also reinstated and improved upon his processional route through to the Tribune – the planning of which was fundamental to the first phase of works. 9.34 It is in the external appearance of the property that the differing phases of work are most evident. The main Soane building is the eastern part of the Priory complex as seen today. In an Italianate style and finished in cement render with rusticated quoins it is of three storeys above a basement which is exposed to the south and faces out to the Italian Garden terrace. To the west is a 1950s basement level extension (the billiard room), which detracts from the appearance of the listed building. To the east is the ‘cleanest’ elevation of the remodelled 1775 house that formed the starting point for Soane’s scheme. 9.35 Soane’s southern elevation is symmetrically composed around the projecting three central bays with curved ends and a bottle balustrade parapet, with three bays to either side. The altered face of the original house is evident to the west with the tower from Kelks phase of works rising above. Kelk also introduced the portico which replaces a much simpler veranda by Soane. 9.36 The northern elevation comprises a central 3 bay element, remodelled for Kelk with an upper colonnade with recessed pierced screens. On either side are Soane’s recessed three bay wings. To the west are the port-cohere, from Soane’s third phase of works and beyond this the later 19th century additions, the most visible being the clock tower and the sweeping screen wall. Externally, some of the original Soane work still exists to the south elevation, although the entablature has been mostly lost. To the north side the port- cochere and the three arched upper floor openings exist in their original state. The roof over part of the main building is now comprised of steel trusses, having being rebuilt after the 1979 fire. 9.37 Soane was able, in the third phase of development, to provide his signature 55London Borough of Harrow , Stanmore processional route through the ground floor of the building. This sequence of rooms and the main staircase to the first floor (enlarged in Victorian times) which have been extensively restored, are nevertheless the principal interior elements of special interest today. Notable fittings include Soane fire places in the in the tribune, drawing and dining rooms. 9.38 Internally, the entrance hall, long drawing room and rotunda or tribune are likely to be the only parts in anything like their original condition. The main staircase retains the original Portland stone steps and some timber panels have survived the 1979 fire. Newels, handrails, posts and strings have all been carefully reconstructed in oak, incorporating the gilded metal fretted panels which were salvaged from the fire. The upper balcony and balustrade are similarly reconstructed. 9.39 This series of principal rooms to the ground floor form an impressive ensemble and typify Soane’s approach to the design of country houses and remain impressive features today. In other areas, whilst the principal structural form of the building remains legible, interior spaces have been sub-divided and partitioned, indicating a significant degree of reconstruction and repairs in the latter part of the 20th century as a result of the serious fire in 1979. These areas are of less significance but nevertheless comprise part of the overall architectural integrity of the building. The RAF 9.40 The RAF has been in residence for over 70 years and there are numerous items of historic interest relating to both the RAF and the Priory. Of greatest historic importance is the former library, used by Dowding for his office. The future of these spaces and objects, particularly those considered to be fittings and fixtures, will need to be given careful consideration as part of any proposals for a future use for the Priory building. The House and Landscape 9.41 Whilst the immediate setting of the former country house has been eroded 56London Borough of Harrow , Stanmore over time, significant elements remain and the relationship between the house and the designed landscape is an important part of its character as a building of special architectural or historic interest. There is significant potential to reunite the house with aspects of this landscape and to restore the overall relationship of the building to its setting. The Extent of Listing and Extent of Special Interest 9.42 The building was included on the statutory list of buildings of special architectural or historic interest at grade II* on the 25 May 1983. The list description11 whilst primarily for identification purposes refers rather vaguely to the ‘Central Entrance Block to Bentley Priory’. However, the list description does not exclude any of the connected and attached buildings or curtilage buildings and structures. Thus all structures attached to the principal listed building or those constructed prior to 1948 in the curtilage, should, subject to the advice of PPG15 in light of case law, be properly considered as part of the ‘listed building’, as the starting point for listed building control. 9.43 However, the nature and extent of the architectural or historic interest of any such buildings or structures and the contribution that they make to the overall special interest of the principal listed building, will inform the judgement regarding their retention or possible demolition. On this basis, the assessed extent of listing is illustrated at appendix 2. In summary, the ‘listed building’ is considered to comprise: 11 Grade II* THE COMMON 5016 Stanmore Central entrance block to Bentley Priory THE COMMON 1. 5016 Stanmore Central entrance block to Bentley Priory TQ 19 SE 2/5 II* 2. By Sir John Soane, 1789-90. Enlargement by Robert Smirke 1810-18. Entrance lobby, long drawing room and circular boudoir are probably the only parts by Soane in anything like their original condition. The external facades are quite changed by iron balconies and other C19 additions. Some fragments of older work remain. The house was, for the last year and a half of her life, the home of the Dowager Queen Adelaide, who died here in 1849. It was also the home of the Marquesses of Abercorn and Lord Aberdeen in C19. Gutted by fire 1979. Of historical interest as the headquarters of Fighter Command during the Battle of Britain and until 1968. (DRUETT, W W "Stanmore and Harrow Weald Through the Ages" 1938 pages 130 to 137; IREMONGER, Lucille "Lord Aberdeen" 1978 pages 25 and 26). 57London Borough of Harrow , Stanmore ƒ The 1775 house incorporated within the Soane extensions and the attached clock tower and buildings immediately to west added by Kelk, the attached 1950s billiard room (to south west corner of Soane house) (Bldg 1). ƒ The attached 1954 kitchen extensions to north of dinning room (Bldg 112), original building constructed c.1885, flat roof and lower single storey extension reconstructed 1960. ƒ The attached 1958 accommodation block (Bldg 267) ƒ The attached accommodation building (Bldg 7) built by Gordon in the 1880s ƒ The attached tennis court (Bldg 9) and adjoining building (Bldg 8) originally built by Kelk ƒ The attached buildings from early decades of the 1900s (BLdgs 10 & 11). Bldg 8 incorporating the former walled garden gateway ƒ The 1941 prefabricated office (Bldg 258) and two 1940s brick sheds (Bldgs 259 and 262) in the curtilage ƒ Curtilage garden structures, statues and walls (where they date prior to 1948). 9.44 However, the 1958 accommodation block (Bldg 267), 1950s billiard room extension and 1954 single storey kitchen extension (Bldg 112) are not considered to be of any specific special architectural or historic interest due to their utilitarian form and appearance. 9.45 The 1910/20s buildings (bldg 10) with classical gable end adjoining the tennis court and that forming the far western end of the listed building (bldg 11) are similarly not considered to be of any specific special architectural or historic interest. Bldg 10 is noted as being of interest in order to ensure due weight is given to the remaining gateway of the former walled garden in the consideration of the future of this building. 9.46 The tennis court (Bldg 9), built by Kelk and accommodation building (Bldg 7) built by Gordon in the 1880s have historic links to the post Marquis of Abercorn use of the house and display some external architectural interest. The direct link to the principal building, via Kelks conservatory (demolished by the RAF) has been replaced by the 1958 accommodation block. The tennis court has 58London Borough of Harrow , Stanmore undergone external alterations including replacement windows (interiors not inspected though subdivisions are evident). 9.47 None of the three 1940s curtilage buildings which comprise part of the ‘listed building’ are considered to be of any architectural or historic significance and their removal could enhance the setting of the principal listed building. Bldg 258 sits in the group of buildings immediately to the east of Bentley Priory and is a prefabricated office building believed to have been erected in 1941. Bldgs 259 and 262 are brick shed structures from the 1940s that sit within the grounds to the south of Bentley Priory. 9.48 Whilst other post-war buildings which do not comprise part of the ‘listed building’ are not considered to contribute to the character of the principal building, as one of special architectural of historic interest, they do have some resonance in reflecting <a href="/tags/The_More/" rel="tag">the more</a> recent history of the site. Should these buildings be removed it may be appropriate to seek an appropriate level of recording commensurate with their importance. 9.49 Other structures and landscape features of note include: ƒ The flint and brick vaulted structure, known as the Ice House, believed to be of mid 19th century origins. Whilst restored in the late 1990’s it retains signs of antiquity. It is similar in construction to the south wall of the terrace gardens so may be contemporary to Kelk’s improvements of the 1860’s. ƒ The former gateway in the north elevation of Bldg 10, survives as a remnant of the walled garden laid out in 18th century for Duberley. ƒ Various garden structures, including walls, obelisks, the fountain, planting urns, and steps located primarily in and around the Italian terraced garden. ƒ The subterranean C18th or earlier brick-built water cisterns to the west of building 268 are of considerable interest. The Historic Landscape and Setting of the Listed Building 9.50 As with most great houses the landscape setting must be seen as an integral part of the whole. The setting of a listed building is often an essential part of the building’s character, especially if a garden or grounds have been laid out to 59London Borough of Harrow , Stanmore complement its design and function12. The RAF site is the northernmost part of the wider registered parkland that, until 1926, formed the estate for the Bentley Priory House. The merits of the landscape of the wider setting are discussed elsewhere in this report. 9.51 The historic park and garden is noted13 as an C16th estate enlarged and improved in the late C18th by James Hamilton, ninth Earl and first Marquess of Abercorn who corresponded with Sir Uvedale Price (an acquaintance of Repton). Price and William Sawrey Gilpin influenced the design of the park in the early part of the C19th. 9.52 In summary, much of the perimeter of the original estate has been sold off for building in the 1920s and the greater part was bought by Middlesex County Council and became public open space. This area surrounds the Summerhouse Lake, an artificial water body in the picturesque style. 9.53 There remain key historic elements which are important in providing the setting for the listed building and in contributing to its character. It is also apparent that some of the significant areas of built form, associated with RAF use of the building and site, to the east and west of the listed building are largely visually self contained and do not impact unduly on the setting of the building. However, some buildings, particularly to the northwest of the principal listed building serve to obscure key views of the Priory and their removal would enhance the setting. 9.54 Whilst much of the site is now comprised of access roads and hard standings, part of the site to the east has been significantly remodelled to accommodate the Cold War bunker, and significant new buildings added, sufficient features remain to provide a framework for restoring aspects of the listed building’s setting. Similarly, whilst the relationship of the house to its former parkland to 12 PPG15, para. 2.16 13 Bentley Priory, entry on the Register of Parks and Gardens of Historic Interest, English Heritage, June 2001. 60London Borough of Harrow , Stanmore the south has been eroded, opportunity exists for reinstating physical and visual links to its wider landscape setting to the south and the greater whole of the registered park. Extant Primary Historic Landscape Features 9.55 The original alignment of the carriage drive from the north survives, although its context of passing first through woodland and then pleasure grounds and parkland as the house came into view, has been eroded. 9.56 The Italian Terrace Garden survives to the south of the house, consisting of upper and lower terraces, steps, pathways, seats, bedding areas and the dominant circular basin and fountain, retaining simplified elements of its C19th design. 9.57 The garden is now separated from the park to the south by double security fences and C20th screen plantings of rhododendrons and conifers which serve to block the view across the parkland. 9.58 Commentary on other surviving aspects of the historic landscape is provided in chapter 6 of this report. Summary of Baseline Findings 9.59 The findings of the baseline assessment of cultural heritage aspects of the site can be summarised as follows: • The inclusion of the principal listed building, Bentley Priory, on the list of buildings of special architectural or historic interest at grade II* denotes outstanding importance. The principal building provides a significant example of a work by a major British architect, Sir John Soane, for an important client, the Marquis of Abercorn. The building has historical associations with eminent C19th Tory politicians and literary figures and important historical 61London Borough of Harrow , Stanmore significance in relation to the RAF and in particular poignant episodes such as the Battle of Britain. • Despite alterations and additions over time and significant rebuilding after serious fire in 1979, the principal building retains considerable architectural and historic interest. However, this interest, particularly internally, varies from great (the restored ground floor Soane rooms) to more modest (areas largely rebuilt in more utilitarian manner after fire). The architectural importance of the ground floor rooms and their historical association with the RAF and in particular the Battle of Britain, suggests that public access should be encouraged. • The extent of listing comprises other attached and curtilage buildings, which whilst technically listed, vary in their architectural or historic interest suggesting that their removal would not harm the character of the principal listed building. • Although the house is now largely divorced from its historic parkland setting and its immediate grounds have been reduced in extent and altered by significant new building during the tenure of the RAF, sufficient features remain to allow restoration and recreation of some key elements. • Whilst the site has been significantly developed with buildings and structures during the RAF’s tenure, many of these are sited to the east and west of the listed building in largely visually enclosed areas. However, some other buildings and structures have served to obscure and unduly cramp the visual and spatial setting of the listed building, detracting from its overall character. • Opportunity exists through selective removal of built elements of less interest and conversion of parts of the listed building of less significance for appropriate re-use of the building for uses which would secure a viable future and preserve its special architectural or historic interest. • Opportunity exists through appropriate redevelopment of unimportant buildings and structures to preserve and enhance the setting of the listed building. • Opportunity exists to reunite the listed building, both visually and physically to its wider historic landscape setting and to preserve and enhance its immediate historic park and garden setting. 62London Borough of Harrow , Stanmore 10.0 Landscape Baseline Assessment Introduction 10.1 Aspect Landscape Planning was appointed by Harrow Council to prepare a landscape and visual assessment relating to the preparation of a Supplementary Planning Document for future development at RAF Bentley Priory near Harrow. 10.2 This chapter provides details of the methodology and significance criteria used in the appraisal; describes the existing baseline conditions; and assesses the significance and sensitivity of the landscape and visual receptors. This chapter does not attempt to set out any potential effects or impacts of redevelopment on the landscape and visual receptors as this can only be assessed once the proposals are known. The chapter should be read in conjunction with plan drawings and photographs (ASP1 - ASP7) attached as appendix 3. Methodology 10.3 The method/process for assessing landscape issues has been devised to ensure that the potential effects of a proposed redevelopment of a site of this scale are made aware of. The primary guidance for requirements and content of Landscape and Visual Impact Assessments is the DETR publication ‘Environmental Assessment – A Good Practice Guide’ (1995). This document requires the Environmental Assessment (EA) to consider both the impact on landscape character, and the visual impact. The publication also outlines the method of assessing these impacts and requires the EA to predict the significance of the impact as a result of the development. 10.4 The Landscape Institute and the Institute of Environment Assessment jointly published ‘Guidelines for Landscape and Visual Assessment’ (2002 2nd Edition), and ‘Landscape Character Assessment Guidance’ is published by The Countryside Agency. The assessment has taken on board the above documents. Desktop Appraisal 63London Borough of Harrow , Stanmore 10.5 An initial desktop appraisal was carried out to identify the character of the area, using the baseline assessment of the Countryside Agency’s ‘Landscape Character of England’ map. The ordnance survey map was used to identify potential visual receptors, public footpaths, topography, land use and linkages. Site Survey 10.6 A site survey was carried out in December 2006 to confirm and expand on the initial desktop appraisal. A local character assessment was carried out to identify broadly homogenous zones that can be categorised in terms of quality and character. This is necessary in order to assess the potential impact that change will have on a particular landscape. The landscape character areas identified are illustrated on Plan ASP6. 10.7 The site visit also identified the visual envelope of the site from publicly accessible viewpoints in the surrounding landscape. Photographs have been taken of the internal nature of the site (ASP3), adjacent views (ASP4), and long distance views (ASP5). The photographs have been taken using a 35mm film format with a 50mm focal length of the lens, as recommended in the 'Guidelines for Landscape and Visual Impact Assessment 2nd Edition' (2002). A series of overlapping photographs have been taken from the same viewpoint, and have been 'stitched' together using Adobe Photoshop to create a panoramic view. The minimum cropping has taken place to retain as much of the original view as possible. Sensitivity Analysis 10.8 This section of the chapter identifies the sensitivity of the Landscape Character Areas and Visual Receptors. An impact assessment has not been carried out as the proposals are not yet known, however, the Sensitivity of Landscape Characters and Visual Receptors can be assessed at this stage based on the existing site. The following tables explain the classification of sensitivity, and identify three categories: High, Medium and Low. Visual Receptor Sensitivity High High degree of exposure to view over significant period. Receptors would include residential properties. 64London Borough of Harrow , Stanmore Medium Medium degree of exposure to view over moderate period. Receptors would include footpath users. Low Low degree of exposure to view over limited period. Receptors would include road users. Landscape Sensitivity High Landscape of particular importance or distinction, sensitive to small changes. Medium Landscape of moderate quality, less sensitive to change. Low Landscape of low quality, tolerant of change. 10.9 The information relating to sensitivity has been mapped to illustrate the sensitivity of the site. This information is illustrated on Plan ASP7. Site Survey The Wider Setting 10.10 RAF Bentley Priory lies to the north of the main urban area of Harrow. Stanmore and Harrow Weald lie closest to the site to the south east and south respectively. The site lies within the Green Belt, however due to its past uses is identified as a Major Development Site within the Green Belt. 10.11 To the north east and north west the site is bound by residential development comprising large detached properties set within maturing, established grounds, refer Plan ASP1. To the north east, the properties are separated from Stanmore Common by the A4140 which is a primary road connecting the urban areas of <a href="/tags/Bushey/" rel="tag">Bushey</a> and <a href="/tags/Watford/" rel="tag">Watford</a>, to the wider urban area of Harrow to the south east. Stanmore Common comprises an extensive area of broadleaf woodland, which helps create a substantial landscape buffer between the site and the M1, which lies some 1.5km to the north east. 10.12 Extensive parkland lies to the south of the site and forms part of the wider Bentley Priory estate. The Parkland is bound to the north by the RAF Bentley Priory site, to the east and south by residential development associated with 65London Borough of Harrow , Stanmore Harrow East and Stanmore and to the west by the A409 which connects Harrow Weald in the south, with Bushey. This parkland plays an important role in the setting of the RAF site, ensuring a substantial degree of visual containment between the site and the wider urban areas to the south east and south and ensuring a minimum degree of intervisibility between the site and its wider setting. To the west, the site is bound by an area of woodland associated with the wider parkland setting. This mature treescape ensures that views into the site from the A409, which lies to the west, are limited. The urban area of Bushey lies to the north west of the site. The site is separated from this area by the established, low density residential development which lies immediately to the north west of the boundary, and also the established vegetation, ensuring that the site is well screened and afforded a degree of separation from the town. 10.13 The site lies on the south facing side of a plateau affording it an elevated position above the main urban area of Harrow. Despite this potentially prominent location, the established parkland and treescape, which form the setting of the site, ensure that a high degree of visually containment is afforded, with only the house visible within some longer distance views. The woodland, which lies beyond the site to the north and west, forms a substantial green backdrop to the site and main house ensuring that the skyline of the plateau is formed by mature treescape. 10.14 There are some public rights of way within the wider setting of the site, however views into the site from these paths are limited due to the intervening established planting. The Site 10.15 The existing site comprises a number of buildings of varying quality ranging from the high quality, established main house, to the low quality, modern accommodation blocks. This built form is set within parkland which is of varying quality due to previous owners and land uses. The main elements of the site are located within an established treescape setting, ensuring a compartmentalised character within the site itself, refer Plan ASP2. 10.16 Much of the development on the site is centred around the main house, which 66London Borough of Harrow , Stanmore lies within the southern part of the site. The main house is listed and, in parts, dates back to the late 18th century. More recent built form associated with the MOD is located to the north, east and west of the main house and comprises a variety of buildings. The higher quality buildings lie to the north and immediately to the east of the main house, while the remainder of the buildings to the north, east and west are of limited architectural merit. There is also an underground bunker on the site which lies to the east of the main house. Much of the built form on site is screened from the wider setting by the existing mature treescape associated with the site, ensuring that built form is not prevalent within views towards the site. 10.17 There is an established vegetation structure on site which links back to the historic parkland. To the north of the main house the vegetation structure comprises individual or small groups of mature trees. Established treescape lines the boundaries of the site affording a degree of separation between the site and adjoining land uses and reinforcing the compartmentalised character of the site. A degree of mature planting exists within the context of the built form creating tall vertical elements which help integrate the buildings into the parkland setting and also ensure that the newer built form is visually contained within longer distance views. To the south of the main house lies the terraced garden which has declined from its former glory and is now largely laid out as lawn. Certain elements and fixtures remain ensuring the area maintains a degree of quality and provides an appropriate setting for the main house. To the south of the terrace the historic parkland extends south into the adjoining nature reserve. Within this area extensive tree planting exists creating a substantial landscape buffer to the site and ensuring that the built elements of the site are largely contained from the wider visual envelope. Much of the land immediately to the south of the main house is covered by a covenant protecting it from development. 10.18 The site is generally flat in nature, with the landscape sloping away to the south of the main house. The flat character ensures that the vegetation structure on and around the site creates tall, vertical landscape features which ensure a substantial degree of integration and visual containment for the built form on site. 67London Borough of Harrow , Stanmore 10.19 This site is accessed from the A4140 via a drive which largely follows the route of the original Bentley Priory drive. Extensions and additions to the drive provide access to much of the southern part of the site, linking the various buildings. At present there is no public access onto the site. Historic Background 10.20 The development at Bentley Priory can be dated back to medieval times when the site was largely agricultural. The site was turned from agricultural use to ornamental around 1775, when the house was built. It was during the period between 1788 and 1852 that the estate gained prominence, when the grounds were laid out on Picturesque principles. During this period the driveway was set out; trees were planted singly, in plantations and single avenues, the creation of the lakes; the introduction of a formal terrace to the southern elevation of the house; and the development of elaborate gardens, known as the Cedar Gardens, to the north. During the period between 1852 and 1926, the estate had a number of owners. During the early part of this period, the grounds, notably the terrace garden, were transformed into an example of high Victorian style. After 1926, the estate was broken up into three parcels. The Cedar Gardens were lost to development, they were situated where the residential development associated with Priory Drive is located, and the terrace gardens were largely laid to lawn. A number of trees within the immediate setting of the house were removed by the RAF to provide an all round field of fire for anti-aircraft guns further degrading the setting of the house. The land to the south of the terrace gardens, containing the ornamental lake, is now an area of ecological interest being covered by SSSI and LNR. 10.21 The grounds at Bentley Priory are listed in the Historic Parks and Gardens register. This designation covers the site and the nature reserve to the south which previously formed part of the wider estate. As has been described, the parkland which forms the setting of the Listed building was previously a high quality landscape which has been neglected over the past century, resulting in the setting of the house becoming less notable. There are opportunities to improve the parkland setting of the Listed building by retaining key trees and strategic new planting which will reinstate the parkland character of the site and create an enhanced landscape setting for the site. 68London Borough of Harrow , Stanmore Arboricultural Assessment 10.22 A broad overview of the trees on the site has been carried out to identify the key groups. There are many trees growing within and immediately adjacent to the site and several trees are of value in terms of their size, visibility, screening, and contribution to the setting of the listed building. These trees are to be found in the following areas: 1. In the north east corner of the site surrounding the existing maintenance building and associated car parks. There are approximately 30 trees in this area, all of some size and many of them readily visible from the two adjacent roads, Common Road and The Common. Those that are not adjacent to the road are of less value for obvious reasons. 2. On the west side of the main driveway to the south of the maintenance area there is a row/belt of trees, some of which are growing in the rear gardens of adjacent residential properties. These provide significant screening between the site and these properties, and some are likely to be visible in backdrop views from Common Road to the west. 3. There is a dense group, almost woodland, of trees in the south western corner of the site, some of which are on the Common Road frontage and some of which (on the northern side) screen the site from the school. Hence some of these trees (but not all) are of significant visual and screening value. 4. There is a collection of five or six significant individual trees growing around and to the west of the existing bowling green. These include oak, Scots pine and a cedar. These appear to be trees of some age and quality, but none are likely to be major features in views from outside the site. 5. There is a belt of trees, almost a woodland, growing along the southern boundary to the east of the bowling green. This extends northwards to between the bowling green and the horseshoe-shaped car parking area to the east of it. This group of trees is likely to be 69London Borough of Harrow , Stanmore visible from outside the site in views from the south and is likely to have significant screening value alongside the southern boundary. The eastern end of this woodland contributes to the setting of the Priory itself and to views south westwards from the terrace. 6. Directly to the south of the house there are two rows of tall conifers which tunnel views from the terrace towards the distant spire on Harrow Hill. Whilst these trees do guide the eye towards the spire they are strangely out of character with the setting of the south side of the Priory and are in stark contrast to the other native trees growing in this area. 7. There are very few trees of merit in the south eastern corner of the site, mostly groups of young planted specimens. 8. To the east of Bentley Priory there is a single wellingtonia tree and directly to the north, a single cedar growing between the hurricane and spitfire on the main grass area. These are large trees, likely to be visible but not major features, from outside the site. However, they are entirely in keeping with, and complementary to, the setting of the listed building. 9. There are no trees of any consequence directly to the north of Bentley Priory except those growing offsite within the grounds of The Cedars and other offsite properties. Unsurprisingly perhaps, they do include cedar trees which are of a significant size, and despite their distance from the Priory, they do contribute to the setting of this building. 10. The trees within the centre of the site are all small and unlikely to be visible from outside the site. They are therefore of low value or appear to be of low quality, with several seeming to have had their tops removed in the past, and several appearing to be infected with wood-decaying fungi or to have areas of wounding on their main trunks. Visual Analysis 70London Borough of Harrow , Stanmore 10.23 A number of photographs have been take to illustrate the site from within or adjacent to the boundary, and from the surrounding landscape. Internally (ASP3), the site covers a significant area including the Priory buildings, MOD residential buildings, woodland, parkland and open spaces. Views are generally contained by the vegetation and topography, due to the mature context of the site and the plateaux location. The buildings are interspersed with green open spaces and areas defined by mature treescape to the boundaries. 10.24 A public footpath to the south of the site provides localised external views of Bentley Priory and the surrounding parkland (plan ASP4). Views are mainly glimpsed through the dense boundary vegetation to the open space, or the Main House. The topography drops away to the south and provides longer distance views of the surrounding landscape. The established vegetation structure associated with the parkland ensures a degree of visual containment ensuring that views in and out of the Green Belt are limited. 10.25 Longer distance external views are available from the south, from a public footpath adjacent to the built up area of Harrow East, and from a high point on Belmont Golf Course. The main building of Bentley Priory is visible from the golf course in the context of the built form in the surrounding urban areas. From Harrow East, the site is not readily visible due to the screening nature of the rising landform and the densely vegetated landscape. Landscape Character Assessment 10.26 Aspect has carried out an assessment of the character of the local area in order to establish broadly homogenous areas that reflect the broad make up and components within the vicinity of the site. This is carried out in order to assess the suitability of the site to accommodate change without causing harm to individual character areas. This assessment identified five individual character areas which are defined by elements such as land use, development and vegetation. 10.27 The character areas are: Bentley Priory Estate; Residential Areas; Parkland; Stanmore Common; and Open Land. These areas are identified on Plan ASP6. Bentley Priory Estate 71London Borough of Harrow , Stanmore 10.28 This area comprises the site and can be broken up into a number of individual sub-character areas which make up the wider Bentley Priory character area. Generally, the boundaries of this character area are well vegetated creating a green landscape buffer and ensuring a degree of separation between this area and the wider Green Belt setting. These sub-areas are identified on Plan ASP6 and denoted by letters A – G. 10.29 Area A – This area lies in the northern part of the site and comprises an area of parkland which is bound to the east and west by the adjoining areas of residential development and to the south by the area of hard standing and earth mounding. This area is characterised by a number of large individual trees, which run along the driveway and relate to the parkland setting, and also the mature vegetation structure associated with the boundaries of this area, which create a degree of enclosure. The earth mounding and area of hard standing to the south together with the modern guardhouse detract from the character of this area. The existing elements related to the MOD occupation of the site detract from the character of this area, however the existing established treescape ensures that this area is of low-moderate quality and less sensitive to change. 10.30 Area B – This area comprises the area of hard standing and earth mounding which lies to the north of the main house and breaks up the main area of parkland within the site. This area breaks up the parkland character and detracts from the setting of the main house ensuring that this area is of low quality and tolerant to change. 10.31 Area C – This area comprises the larger area of parkland immediately to the north of the main house. This area is characterised by an expansive open area of grass with some established individual trees and tree groups which follow the drive towards the main house. There is some built form within the southern part of this area which forms the immediate setting for the main house. These buildings are integrated into this character area by the established vegetation structure, ensuring that built form does not dominate this area. There are also a couple of tennis courts within this area. The character of this area is open in nature with established vegetation largely restricted to the edges. The quality of this area is moderate and, due to its setting, less sensitive to change. 72London Borough of Harrow , Stanmore 10.32 Area D – This area comprises the main house and the buildings which form its immediate setting. The terrace gardens also lie within this area as they form part of the high quality setting of the listed building. This area is dominated by built form, and primarily the listed building, which forms the focus of this area. There is a degree of mature vegetation structure within this area which creates key landscape elements and provides an established setting for the newer built elements within this area and also creates a degree of visual separation between the listed building and the adjoining areas of lower landscape quality. Of note, in terms of treescape, are the wellingtonia and cedar which sit close to the main house and date back to the establishment of the parkland, enhancing the historic landscape context of the listed building. The high quality built form and the historic gardens, which form the setting of the listed building, ensure that the quality of this area is high, and would be sensitive to small changes. 10.33 Area E – This area lies to the west of the main house and is characterised by low quality built form set amongst an established treescape. The built form within this area comprises of a number of residential blocks built by the MOD which are of no architectural merit and do not contribute positively to the character of this area or the wider site. The mature vegetation structure within this area provides a significant degree of visual containment and ensures that the built form is largely screened from the wider setting and does not negatively affect the sensitive setting of the listed building. As a result of the built form within this area, the quality of the landscape is low and would be tolerant of change. 10.34 Area F – This area lies just to the north east of the main house and comprises two large blocks built by the MOD set within an established vegetation structure. The northernmost block within this area is of limited architectural merit, while the building to the south contributes more positively to the setting of the main house and the character of this area. The established vegetation structure provides a degree of enclosure and separation between this area and the adjoining area associated with the listed building. The low quality built form ensures that the quality of this character area is low, and together with the degree of enclosure ensures that this area is tolerant of change. 10.35 Area G – This area lies to the east of the house and comprises the Cold War 73London Borough of Harrow , Stanmore bunker and its immediate setting. There is little evidence of the actual bunker within this area, with the exception of the entrance, and there is limited built form within this localised area. there are limited areas of hard standing associated with the approach to the bunker and around the entrance, but the rest of this area is largely set to grass. There is a degree of vegetation structure within this area which helps break up the space, however this is of limited landscape merit due to its immaturity. The key vegetation structure lies around the boundaries of this area. This mature planting creates a green edge to this area and provides a degree of enclosure between the adjoining areas. The quality of this area is moderate and would be less sensitive to change. Residential 10.36 This area is characterised by large, detached properties set within extensive, established grounds. Mature treescape forms a characteristic element within this area ensuring that the built form is largely screened and is integrated within the landscape without being conspicuous. Parkland 10.37 This area comprises much of the former Bentley Priory estate which was separated from the main site in 1926, and is characterised by extensive, mature vegetation structure. This mature planting forms a substantial landscape edge to the site and ensures that longer distance views of the site are contained. The vegetation structure within this area creates a compartmentalised character which reinforces the enclosed nature of this area and the wider Green Belt setting. Existing elements related to the historic parkland still exist within this area, such as the ornamental lake, and provide some interest. The SSSI designation and Bentley Priory Local Nature Reserve cover much of this area, due to its ecological value. Stanmore Common 10.38 This area lies to the north of the residential area and is characterised by an extensive area of broadleaf woodland. This area acts as a buffer separating the residential area and site from the more open landscape and motorway corridor to the north east. Open Land 74London Borough of Harrow , Stanmore 10.39 This area lies to the north west of the parkland and land uses include horse grazing and golf development. This area is separated from the site by the mature treescape associated with the parkland, which forms a green backdrop to the land to the north west. Sensitivity Analysis 10.40 The following table describes the sensitivity of the potential visual receptors associated with the site, as illustrated on Plan ASP7: Visual Sensitivity Comments Receptor 1 High Views towards the site are limited due to the woodland Residential and tree boundaries. However, the sensitivity of the areas properties is considered to be High due to their close adjacent to proximity, the quality of the setting and due to the fact site that they are residential uses. 2 Medium Views from the Retirement Home are heavily filtered by Retirement the existing woodland and topography. Due to the existing Home to setting and that the receptors are residential the sensitivity south west of is Medium. site 3 Medium Some views into the site are available from the footpath, London Loop but the site is well contained by existing boundary National Trail vegetation. Due to the existing setting, its topography and Footpath woodland features, the sensitivity can be said to be Medium. 4 Medium Limited views into the site as existing vegetation structure Bentley Priory associated with the boundaries creates a degree of visual 75London Borough of Harrow , Stanmore SSSI/LNR containment. Due to the existing vegetation structure and topography, the sensitivity is considered to be Medium. 5 Low Both road corridors are detached from the site apart from Users of the A4140 onto which the site access road joins. Road Notwithstanding the relationship of the access road onto Corridors: the A4140, the sensitivity is low due to the short term A4140 and presence whilst passing along the road. A409 10.41 The following table describes the sensitivity of the various Landscape Character Areas associated with the site as illustrated on Plan ASP7: Landscape Character Sensitivity Comments Area Bentley Priory Listed High The Listed building and the grounds which form Building and Immediate its immediate setting are key features within the Setting site and are therefore afforded a high degree of (Red) importance within the site. The terraced garden and the parkland which extends to the south form the setting of the main house and are therefore considered to be of high value within the site. Poorly designed development could detract from the character and setting of the Listed building and the historic gardens. This area is therefore considered to be of High sensitivity. 76London Borough of Harrow , Stanmore Areas of Parkland Within Medium These areas provide the wider setting for the Vicinity of the Listed Listed building and also the approaches to the Building and Driveway site. The parkland character means that these (Orange) areas are more open in character, however, the established vegetation structure associated with the site affords these areas a degree of enclosure. Opportunities for enhanced parkland planting within these areas would mean that the impact of development could be contained. It is considered that the sensitivity of these areas is Medium. Areas of Limited Low These areas largely comprise of low quality built Landscape Importance and landscape elements associated with the RAF (Yellow) occupation of the site ensuring a low quality landscape character. These areas do however benefit from a high degree of visual containment resulting from the existing mature treescape which surrounds them. These areas could therefore accommodate development, with the existing vegetation structure ensuring that the impact does not detrimentally affect the wider setting. The sensitivity of the character of these areas is therefore considered Low. Summary of Landscape Baseline Findings 10.42 As an overview, the site benefits from an established vegetation structure which affords a high degree of visual containment. This treescape also creates a compartmentalised character both within the site and within the wider Green Belt context. This compartmentalised character means that there are areas within the site which are less sensitive to change and would provide opportunities for future development. 77London Borough of Harrow , Stanmore 10.43 The site contains a high degree of important treescape which forms the setting of the Listed building and enhances the quality of the landscape associated with the site. This vegetation structure should be retained and enhanced to ensure that the quality of the landscape character, the visual containment and landscape heritage of the site are preserved and enhanced. 10.44 As stated earlier, this report should be followed up with a full Landscape and Visual Assessment once the development proposals are known so that an impact assessment can be carried out. The landscape and visual appraisal contained within this chapter should be used to inform the design of proposed development on the site, using the baseline information provided. 78London Borough of Harrow , Stanmore 11.0 Ecology Baseline Assessment Background 11.1 Aspect Ecology was commissioned by Harrow Council in October 2006 to conduct an ecological study of a site at Bentley Priory, Stanmore, Greater London (see Plan ECO1 attached as appendix 1). Site Characteristics 11.2 The site is located adjacent and south of the A4140 in the village of Stanmore, Greater London (see Plan ECO1 attached as appendix 1). To the east and west the site is bound largely by gardens associated with existing residential properties, while Bentley Priory Site of Special Scientific Interest (SSSI) and Local Nature Reserve (LNR) abuts the southern boundary. 11.3 The site itself comprises largely of hard standing, buildings, areas of woodland and amenity grassland. A number of trees are present throughout the site occurring as standards or in small groups. Other habitats at the site include a water body, rank grassland, a dry ditch, areas of scrub and tall ruderal. Baseline Survey and Ecological Appraisal 11.4 This document examines the ecological interest of the site as a whole. The importance of the habitats and any faunal species present within the site is evaluated. In addition, where appropriate, a brief appraisal of the immediate surroundings is presented so as to set the site in its local context. Survey & Assessment Methodology 11.5 The methodology utilised for the survey work can be split into 3 main areas, namely desk study, habitat survey and faunal survey. These are discussed in more detail below. Desk Study 11.6 In order to compile background information on the site and its immediate surroundings Aspect Ecology contacted the Greenspace Information for Greater London (GIGL) Biodiversity Records Centre. Information received from this source is reproduced in Appendix 3 and Plan ECO2 attached as appendix 5, 79London Borough of Harrow , Stanmore where appropriate. 11.7 Additional information was obtained and reviewed from the London Ecology Unit (LEU) handbooks and from the previous Phase 1 report written by Entec dated April 2005. 11.8 Further information on ecological designations from a wider search area was obtained from the online Multi-Agency Geographic Information for the Countryside (MAGIC) database and Nature on the Map which utilises data provided by Natural England. Information received from these sources is reproduced in Appendix 6 and on Plan ECO2 attached as appendix 5 where appropriate. Habitat Survey 11.9 Survey work was carried out in December 2006 to ascertain the general ecological value of the land contained within the boundaries of the site and to identify the main habitats and ecological issues. 11.10 The site was surveyed based on Phase 1 survey methodology, as recommended by Natural England. This technique provides an inventory of the basic habitat types present and allows identification of areas of greater potential which require further survey. Any such areas identified can then be examined in more detail. Using the above method, the site was classified into areas of similar botanical community types. 11.11 Due to security reasons and the operational use of the site by the RAF, the full extent of the site could not be surveyed in detail. However, it is considered that sufficient information was gathered in order to identify the main habitats and allow a robust assessment of any potential ecological issues present. Faunal Surveys 11.12 General faunal activity, such as birds or mammals observed visually or by call during the course of the surveys was recorded. Specific attention was paid to the potential presence of any protected, rare, notable or Biodiversity Action Plan species. 80London Borough of Harrow , Stanmore Ecological Features 11.13 The following main habitats/ecological features were identified within the site: ƒ Broad-leaved Woodland ƒ Standard Trees ƒ Water Body ƒ Dry Ditch ƒ Rank Grassland ƒ Japanese Knotweed ƒ Buildings and Hard standing ƒ Other habitats 11.14 Each habitat is described in more detail below. However, in summary, the habitats within the site comprise mainly of buildings and hard standing and well maintained areas of amenity grassland and planting, with the majority of the semi-natural habitat confined to the southern part of the site. Broad-leaved Woodland 11.15 Several small areas of semi-mature to mature broad-leaved woodland are located throughout the site, occurring mainly towards the southern and western margins (see Plan ECO3 attached as appendix 7). The canopies of these areas are largely formed from Oak Quercus robur, with occasional other species including Sycamore Acer pseudoplatanus, Sweet Chestnut Castanea sativa and Silver Birch Betula pendula also recorded. In these areas the understorey is comprised largely of Hawthorn Crataegus monogyna, Elder Sambucus nigra and Dogwood Cornus sanguinea. The ground layer is dominated by tall ruderal in the form of Stinging Nettle Urtica dioica, along with extensive patches of Bramble Rubus fruticosus agg. The woodland appears semi-natural in form but numerous non-native/introduced species reveal its “parkland” setting. In addition, areas of plantation/amenity planting comprising a mixture of ornamental and native species was recorded throughout the site, particularly in the south eastern corner. Standard Trees 11.16 A number of semi-mature to mature trees are present throughout the site 81London Borough of Harrow , Stanmore occurring in small groups or alone as standards. Species recorded include Oak, Sycamore, Silver Birch, London Plane Platanus hispanica, Horse Chestnut Aesculus hippocastanum and occasional Giant Redwood Sequoia giganteum and Scots Pine Pinus sylvestris. It was noted that a good number of large, mature specimens occur at the site, which have evidently been present for some considerable time. Water Body 11.17 A single water body was recorded within an area of broad-leaved woodland in the south of the site (see Plan ECO3 attached as appendix 7). The water body is essentially a small rectangularly shaped reservoir (see Photograph 1, please note all photographs are attached as appendix 8) which appears to have overflown into a small adjacent natural depression (see Photograph 2). The reservoir is of a brickwork construction with a concrete base and held a reasonable level of standing water at the time of survey. It is approximately 0.75m in depth and contains little to no aquatic/emergent vegetation. The marginal vegetation was largely comprised of Bramble with some patches of Pendulous Sedge Carex pendula also present, particularly in the overspill area. Dry Ditch 11.18 A ditch was recorded within the area of broad-leafed woodland which lies at the south of the site (see Plan ECO3 attached as appendix 7). The ditch was dry at the time of survey and appeared not to have held any water for some time. Rank Grassland 11.19 An area of rank grassland is present in the south western corner of the site and is interspersed with scattered scrub and tall ruderal (see Photograph 3 and Plan ECO3 attached as appendices 8 and 7 respectively). The grassland appears unmanaged allowing a tall sward to develop and appears to have a moderate species diversity. Japanese Knotweed 11.20 Several stands of the invasive exotic species Japanese Knotweed Fallopia japonica were recorded at the time of survey located predominantly within the areas of broad-leaved woodland around the water body area (see Plan ECO3 82London Borough of Harrow , Stanmore attached as appendix 7). Buildings and Hard standing 11.21 A number of buildings and associated hardstanding in the form of existing roads, car parking, etc are located throughout the site. These comprise Bentley Priory itself and numerous other structures currently used by the Royal Air Force. Other Habitats 11.22 Other habitats recorded during the survey visit include areas of amenity grassland, scrub and tall ruderal. Background Records 11.23 The Greenspace Information for Greater London (GIGL) biodiversity records centre did not identify records of any protected, rare or notable floral species within or immediately adjacent to the site. By contrast, Bentley SSSI contains a number of species uncommon or rare to the Greater London area such as Imperforate St John’s-wort Hypericum maculatum. Faunal use of the site 11.24 General observations were made during the surveys of any faunal use of the site with specific attention paid to the potential presence of any protected, rare or notable species. Mammals 11.25 Bats 11.26 Roosts. An abundance of natural roosting opportunities is provided by numerous mature trees throughout the site, which were recorded to contain cracks, fissures and rot holes. In addition, the roof of Bentley Priory was noted to have some gaps within the raised ridge tiles which may provide access to loft voids often favoured by roosting bats. Furthermore, gaps were recorded between the horizontal wooden slats on the side of the clock tower of Bentley Priory providing further potential roosting opportunities for this group. 83London Borough of Harrow , Stanmore 11.27 Foraging. The woodland areas within the site provide suitable foraging habitat for bats and the edges of these areas may also potentially act as navigational features. 11.28 Background Records. No specific records of any bat roosts within the site or immediately surrounding area were returned from the desktop study. However, sightings of Common Pipistrelle Pipistrellus pipistrellus bats have been recorded within 0.5km of the site boundary. Other Protected Mammals 11.29 Generally, the lack of semi-natural habitat within the site affords suboptimal opportunities for mammals and indeed no evidence of any other protected rare, or notable mammal species was recorded during the survey visit. Furthermore the desk study returned no records of any other such species within a 3km grid square surrounding the site. Amphibians 11.30 Great Crested Newts 11.31 The water body within the site is lined with concrete, has vertical brick walled embankments and supports little to no aquatic or emergent vegetation. As such, it is unlikely to provide breeding habitat for any protected amphibians such as Great Crested Newts. The adjacent depression has some potential to support Great Crested Newts, albeit suboptimal in nature. A further offsite water body, located approximately 100m from the southern site boundary may potentially to support this species. The woodland areas, scrub and tall ruderal within the margins of the site provide potential terrestrial habitat for this species. 11.32 Background Records. The desk study returned records of Great Crested Newts approximately 1.5km west and south west of the site (see Appendix 5). Reptiles 84London Borough of Harrow , Stanmore 11.33 The area of rank grassland interspersed with scattered scrub and tall ruderal located in the south western corner of the site is considered to have the potential to support common reptiles. 11.34 Background Records. The desk study has returned records of Grass Snake Natrix natrix and Common Lizard Lacerta vivipara approximately 800m to the south of the site. Birds 11.35 The woodland areas, standard trees and patches of scattered scrub within the site are likely to support a number of common bird species and indeed several such species were recorded during the general faunal survey, including Magpie Pica pica, Wood Pigeon Columba palumbus, Robin Erithacus rubecula, Wren Troglodytes troglodytes Green Woodpecker Picus viridis, Nuthatch Sitta europaea, Redwing Turdus iliacus and Jay Garrulus glandarius. 11.36 Background Records. No records of any specially protected bird species within the site were returned from the desktop study (see Appendix 4). Several specially protected bird species such as Barn Owl Tyto alba and Kingfisher Alcedo atthis are recorded in the surrounding area (see Appendix 4). Invertebrates 11.37 The site is expected to support a number of common invertebrate species but is not considered to be of any special invertebrate interest. The threatened species Southern Wood Ant Formica rufa is apparently known to occur in the local area but the habitats within the site are generally considered to be suboptimal for this species and indeed no evidence was found during the survey work. Other Species 11.38 Other mammals 11.39 A number of common small mammal species such as Rabbit Oryctolagus cuniculus, Wood Mouse Apodemus sylvaticus and Common Shrew Sorex araneus are likely to inhabit the site. 85London Borough of Harrow , Stanmore Ecological Evaluation The Principles of Site Evaluation 11.40 The methods and standards for site evaluation within the British Isles are based on principles such as size, diversity, naturalness, rarity and fragility, while additional secondary factors such as typicalness, potential value, intrinsic appeal, recorded history and the position within the ecological/geographical units are also incorporated. With respect to London, particular regard is given to the assessment criteria contained within the draft document ‘Criteria for surveying and evaluating the nature conservation of urban sites’ published by the Greater London Authority. 11.41 Levels of importance can be graded at the National, County or Local level and in terms of low, medium or high value. Designated Sites 11.42 Statutory Designations. There are no statutory designations of nature conservation value within the site. The nearest statutory designation is Bentley Priory Site of Special Scientific Interest (SSSI) and Local Nature Reserve (LNR), which abuts the southern boundary of the site (see Plan ECO2 attached as appendix 5). Bentley Priory SSSI and LNR comprises an intricate mosaic of unimproved neutral grassland, ancient and long-established woodland, scrub, wetland and open water, which is an uncommon combination of habitats in Greater London. Several breeding bird and plant species, which are rare or scarce in Greater London, are present within this designation. The next nearest statutory designation is Stanmore Common LNR, which lies approximately 0.2km to the north east of the site. 11.43 Non-statutory Designations. The nearest non-statutory designation to the site is <a href="/tags/Harrow_Weald_Common/" rel="tag">Harrow Weald Common</a>, a Site of Metropolitan Importance, which lies to the west of the A409 (see Plan ECO2 attached as appendix 5). Site Habitats 11.44 Broad-leaved Woodland. The areas of broad-leaved woodland at the site are semi-natural in form and have a moderate species diversity, comprising a mixture of native and non-native species. Overall, this habitat is considered to 86London Borough of Harrow , Stanmore be of relatively high ecological value at the site level. 11.45 Trees. A range of semi-mature to mature trees occur in small groups or alone as standards throughout the site and comprise a number of species. Several of the mature standard trees are of some ecological interest at the site level. 11.46 Water Body. The water body has brick walled embankments and concrete base combined with the lack of aquatic and emergent vegetation and as such it is considered to be of negligible ecological value. The overspill area is of slightly more interest, although of no more than low interest at the site level. 11.47 Dry Ditch. The ditch within the site was dry at the time of survey and appeared not to have contained any water for some time. As such it is considered to be of low to negligible ecological interest. 11.48 Rank Grassland. The small area of rank grassland is interspersed with scattered scrub and tall ruderal and appears to comprise a moderate species diversity. As such it is considered to be of low to medium interest at the site level. 11.49 Japanese Knotweed. A number of stands of Japanese Knotweed were recorded at the site. Japanese Knotweed is listed under Schedule 9 (part 2) of the Wildlife and Countryside Act 1981 (as amended), which makes it an offence to spread it in the wild. 11.50 Buildings and hardstanding. The buildings within the site are considered to be of negligible ecological value. 11.51 Other habitats. The areas of amenity grassland, scrub and tall ruderal within the site are common in the local and national context and as such are considered to be of little to no ecological value. Summary 11.52 No rare habitats or habitats of principal importance exist within the site save for lowland mixed deciduous woodland, which is listed in respect of section 74 of the Countryside and Rights of Way Act (2000). In addition, woodland is a 87London Borough of Harrow , Stanmore listed habitat under the London Biodiversity Strategy. 11.53 Species Evaluation Mammals 11.54 Bats. All bats are protected under UK and European legislation. In addition, bats are listed under the London Biodiversity Strategy. Evaluation 11.55 Roosts. Numerous mature trees located throughout the site were recorded to contain substantial cracks, fissures and rot holes and accordingly are considered to have the potential to act as bat roosts. Bentley Priory also provides potential roosting opportunities for bats. Overall, the site is assessed as having a moderate to high potential for supporting roosting bats. Further survey work at an appropriate time of year would be required to establish presence/absence of bat roosts at the site. 11.56 Foraging. The woodland areas provide suitable foraging and navigational features for bats, albeit these are of no special value within the local context. Amphibians 11.57 Great Crested Newts. Great Crested Newts are protected under UK and European legislation. In addition, they are listed under the London Biodiversity Strategy. Evaluation 11.58 The water body within the site is lined with concrete, with vertical brick walled sides and supports little to no aquatic or emergent vegetation. As such, it is unlikely to provide suitable aquatic habitat for any protected amphibians such as Great Crested Newts. The adjacent damp depression has slightly more potential to support Newts but is still considered to be sub-optimal. In addition, offsite water bodies within the local area may potentially support Newts, although the nearest record returned under the desk study was located approximately 1.5km west and south west of the site. 88London Borough of Harrow , Stanmore 11.59 Some of the terrestrial habitats within the site, namely the woodland areas, scrub and tall ruderal within the margins of the site provide some cover and foraging opportunities for this species. Further survey work at an appropriate time of year would be required to establish presence/absence of Great Crested Newts at the site. Reptiles 11.60 Common reptile species receive partial protection under UK legislation. 11.61 The habitats present within the site are unsuitable for supporting the rarer species namely Sand Lizard and Smooth Snake, which have specific habitat requirements comprising sandy heaths and dunes and as such are highly restricted in their distribution. 11.62 Evaluation. The small area of rank grassland with tall ruderal and scrub located in the southwestern corner of the site as shown on Plan ECO3 (attached as appendix 7) provides a vegetation structure, which is potentially suitable to support common reptiles. Further survey work at an appropriate time of year would be required to establish presence/absence of common reptiles at the site. Birds 11.63 All wild birds receive general protection in the UK whilst nationally rarer and uncommon species receive special, i.e. greater, protection. 11.64 Evaluation. The woodland, standard trees and scrub within the site provide suitable nesting opportunities for common bird species. No specially protected birds were recorded at the site during the general faunal survey save for Redwing Turdus iliacus which is included on Schedule 1 of the Wildlife and Countryside Act 1981 (as amended). All species recorded are common in the context of the locality and of the habitats present within the site. The Redwing were most likely on migration and are not an uncommon sight in the winter months. Other Species 89London Borough of Harrow , Stanmore 11.65 Other mammals. The common small mammals which likely inhabit the site are locally and nationally common and do not receive statutory protection and are of no significant conservation interest. Summary 11.66 No evidence of any protected, rare or BAP listed faunal species was recorded during the survey work, save for common birds, which are protected during the nesting season, albeit the potential presence of bats, Great Crested Newts and reptiles has been identified. Summary and Conclusions of Ecological Baseline Findings 11.67 Aspect Ecology was commissioned by Harrow Council in October 2006 to conduct an ecological study of a site at Bentley Priory, Stanmore, Greater London. 11.68 Designations. There are no statutory designations of nature conservation value within the site. The nearest statutory designation is Bentley Priory Site of Special Scientific Interest (SSSI) and Local Nature Reserve (LNR), which abuts the southern boundary of the site. 11.69 The nearest non-statutory designation to the site is Harrow Weald Common, a Site of Metropolitan Importance, which lies to the west of the A409. 11.70 Surveys. The site was surveyed in December 2006 based around Phase 1 habitat survey methodology, as recommended by Natural England. In addition, general faunal activity, such as birds or mammals observed visually or by call during the course of the surveys, was recorded. The site was also appraised for its potential to support any protected species. 11.71 Habitats. Much of the site is comprised of hardstanding and buildings, well managed amenity grassland and areas of woodland. The other main habitats/features noted at the site were a number of trees occurring in groups or alone as standards, a water body, rank grassland and some areas of scrub and tall ruderal. The woodlands and mature standard trees are of relatively 90London Borough of Harrow , Stanmore high ecological interest within the context of the site. The remaining habitats/features are of more limited to negligible ecological interest. 11.72 Faunal species. No evidence of any protected faunal species was recorded during the survey work, save for common birds, which receive general protection whilst nesting. However, the habitats at the site provide potential opportunities for bats, Great Crested Newts and common reptiles. 11.73 Conclusion. In summary, the majority of the site is dominated by buildings and hardstanding; habitats that are considered to be of negligible ecological interest. Habitats that are considered to be of relatively higher ecological interest are largely restricted to the southern part of the site. The habitats at the site have the potential to support faunal species protected under European and National legislation, albeit further survey work is required in order to confirm presence/absence. 91London Borough of Harrow , Stanmore 12.0 Developing and refining options and assessing effects 12.1 Following the baseline assessments of the site in planning, heritage, landscape and ecological terms an analysis of the future options for the site was made. 12.2 The analysis was undertaken in the context of key Council objectives for the site: 1. Sustainable development – In the context of the green belt, listed building and historic park and garden setting it is vitally important that any future development conforms with the objectives set out within 'PPS1 – Delivering Sustainable Development'. 2. Distinct areas - Due to the historical development of Bentley Priory there are several distinct areas of the site with differing sensitivities in terms of historical, landscape and ecological factors. There are clear opportunities to improve the general environment of the site which benefit the setting of the listed building, benefit the historic parks and gardens setting and improve the ecological properties at the site, whilst also allowing the development of less sensitive areas which principally or previously accommodate older buildings, hard standings and modern RAF buildings. 3. Bentley Priory wider history - In historical terms it is also important that any potential development respects the wider history of the Priory with its historical associations harking back to Saxon times. 4. The Battle of Britain and public access – The importance of the Battle of Britain in the context of the allies' victory during World War II has been widely noted by historians. By association with its role as the headquarters of fighter command Bentley Priory is a key component in the historical assets of the battle. Therefore the Council seeks the preservation of key rooms associated with the Battle of Britain and the provision of public access to these rooms. 92London Borough of Harrow , Stanmore 5. Site of Special Scientific Interest (SSSI) and public access – Anther initial objective is to provide public access through the site creating a link between the Bentley Priory SSSI to the south and Stanmore Common to the north of the site. This would create permeability through the site to the benefit of the public providing glimpse views of points of interest within the site such as the Italianate Gardens and front elevation of the Priory building. 6. Bentley Priory’s Green Belt status - Given Bentley Priory’s ‘Major Developed Site’ status in green belt terms it is important that any potential future development accords with the guidance set out within annex C. It is important that any future use or development on the site accords with this guidance to maintain its green belt setting. 7. Landscape - The site is situated on a prominent position of the Harrow Weald ridge giving it views of London to the south. This landmark setting of the site should be maintained and enhanced through appropriate landscape management schemes and supported with sensitive development/ redevelopment/ conversion of the built fabric on the site. 12.3 The above mentioned objectives were tested against the Council's SEA/ SA objectives and a matrix formed concerning their compatibility with each other, which is set out below: SEA/ SA Compatible - √ Objective Incompatible- x No Links - Blank SPD 1 2 3 4 5 6 Objective 1 √ √ √ √ √ √ 2 √ √ √ √ √ √ 3 √ √ √ √ √ √ 4 √ √ √ √ √ 5 √ √ √ √ 6 √ √ √ 7 8 √ √ √ 9 √ √ √ 10 x x x 93London Borough of Harrow , Stanmore 11 √ √ √ 12 √ 13 √ 14 15 16 SPD 1 2 3 4 5 6 Objective SEA/ SA Objective 12.4 A brief analysis was also undertaken in terms of what would happen to the site if the SPD did not exist in accordance with guidance set out at paragraph 4.3.6 of 'Applying Sustainability Appraisal to Supplementary Planning Documents' (ODPM, 2005). The resultant potential risks have been set out below: • The potential for future development to harm the special nature of the site including factors such as the listed Priory building and designated scheduled park and garden status. • Development on the site that would harm its wider historical associations dating back to its Saxon origins. • Loss of the special nature of the site associated with the Battle of Britain and loss of public access to this national heritage asset. • Potential for future development that would harm the SSSI to the south of the site. • Development out of keeping with the Green Belt location of Bentley Priory. • Opportunities lost to re-instate some of the landscape setting of the Priory in accordance with its historic park and garden designation. • Loss of opportunity to link Glenthorne site to Bentley Priory Open Space. • Loss of access to areas of land that could be opened to the public. 12.5 In accordance with the Council's objectives and baseline assessment of Bentley Priory an issues and options document was drawn up for submission to key stakeholders for comment and for a period of informal public consultation. 12.6 Two phases of public consultation took place, a list of the key stakeholders 94London Borough of Harrow , Stanmore invited to the events is set out below: 1. Landowners and Potential Owners/Tenants VSM (Vinci St Modwen) Defence Estates Bentley Priory Battle of Britain Trust 2. Statutory Consultees (as part of SPD process) English Heritage Natural England Environment Agency 3. National Organisations The Victorian Society The Georgian Group The Garden History Society English Partnerships 4. Regional organisations Greater London Authority (includes Ecology Unit and Planning Unit) Government Office for London London & Middlesex Archaeological Society (LAMAS) <a href="/tags/Hertfordshire/" rel="tag">Hertfordshire</a> & Middlesex Wildlife Trust London Wildlife Trust (possible overlap with the HMWT) 5. Local organisations Stanmore Society Stanmore & Harrow Historical Society Harrow Heritage Trust Bentley Priory Residents Association Priory Drive Residents Association Aylwards Estate Residents Association Bentley Way Association Cottesmore Tenants & Residents Association Owner of Heriots on The Common and the deer park to the east of the Open Space Friends of Bentley Priory Nature Reserve Bentley Priory Nature Reserve Management Committee Harrow Agenda 21 Environment Forum Harrow Nature Conservation Forum Harrow Natural History Society Hertsmere Borough Council (N.B. Hertfordshire County Council are the Highways Authority within Hertfordshire) 6. Councillors Stanmore Park Ward 95London Borough of Harrow , Stanmore Members of Bentley Priory Management Committee Portfolio Holder for Planning Leader of the Council Local Development Framework Panel 7. Miscellaneous The John Soane Museum (links to the Soane Supporters Circle). Can be consulted at any stage. 8. Local residents All residents residing within 400 metres of the site. 12.7 The options identified within the SPD are set out below: 12.8 Achieving the Heritage Vision 12.9 The principal Grade II* listed building consisting of the mansion altered and remodelled by Sir John Soane with later C19th additions by Sir John Smirke is the key element of the site which should be retained and restored. Appropriate re-use for purposes that accord with its special architectural or historic interest, both externally and internally, specifically Soane’s suite of rooms with their later RAF related historical interest, will be crucial to this. 12.10 The following heritage opportunities should be sought in planning any potential development or redevelopment on the site. Opportunities 12.11 Retention of ground floor suite of rooms for public access Re-use of the suite of ground floor rooms of the main building, as existing, for public purposes that respect and retain their special interest, with limited potential for sensitive alteration. Given the architectural importance of Soane’s work and the historic importance of the RAF’s use in World War II, the opportunity for public access must be secured. 12.12 Sensitive conversion 96London Borough of Harrow , Stanmore Sensitive conversion within the overall structural plan form of the basement and first floor spaces of the main building, for appropriate alternative uses, to either support the use of the ground floor or as a discrete, independent use. 12.13 Restore the historic fabric Removal of the 1950s billiard room and restoration of the retained fabric and other improvements to the historic parts of the building, such as restoration of the fenestration to the southern elevation to the original pattern. 12.14 Development potential The opportunity exists to refurbish, redevelop or demolish the attached 1928 accommodation block (building 267) with the potential to create a more subservient building-line in relation to the principal listed building. Buildings 7 to 11 have some architectural merit but redevelopment may be possible, subject to the appropriate design of any new building. The former Gateway to the walled garden (part of building 8) should be retained or relocated elsewhere on site. There may be scope for benefits to be derived from some limited development within the courtyard area to the west of building 1 and north of building 7 and 267, again, subject to appropriate design and other planning considerations. 12.15 Ancillary supporting development Potential for some limited redevelopment in defined areas, close/linked to the house, to provide any necessary ancillary accommodation/facilities required to support re- use of the main house, subject to improving the overall setting of the listed building. 12.16 Removal of unlisted buildings Potential exists to remove ancillary unlisted buildings, structures, hardstandings and access roads, mainly to the east and west of the listed building (Buildings: 2, 3, 8, 14, 16, 17, 27, 33, 36, 87, 88, 263, 264, 266, 268, 270, 272, 274) to both improve the immediate setting of the listed building and release areas for redevelopment in parts of the site previously developed by the RAF, and discreet areas to the north, east and west. 97London Borough of Harrow , Stanmore 12.17 Improving the setting There are three curtilage structures which are considered to be listed as they date from the first part of the 1940s and fall within the curtilage of the principal listed building. They are not, however, considered to be of any significant architectural or historic interest and their removal could enhance the setting of the principal listed building. (Bldg 258, a prefabricated office to the east of the listed building and buildings 259 and 262, simple shed-like structures sited in the grounds to the south). Listed Building Consent would be needed for the removal of these structures. 12.18 Creating space around the principal listed building Redevelopment adjacent to the principal listed building should (i) improve the overall ‘setting’ space between new built form and the listed building; (ii) respect the character and appearance of the listed building; (iii) be located no further south than the existing building line of the listed building; and, (iv) ensure that the north elevation of the listed building remains dominant in its new landscape setting particularly as seen in the approach along the original carriage driveway (see below). Similarly, aspects of the historic landscape which provide the immediate setting for the listed building are capable of repair and reinstatement, improving the relationship of the buildings to the designed landscape. Specifically: 12.19 Historic approaches Retain and enhance the formal approach from the north, through reinstated woodland and then open parkland to the porte-cochere of the listed building. Reinstatement of the initial woodland approach would offer the opportunity to screen a discreet area for development and include removal of the ‘station car park’ and associated bunds, the communication tower and the tennis courts. 12.20 Garden restoration Restoration of the Italian Terrace Garden to an appropriate scheme from the later C19th, research has been undertaken into the historic gardens and reference should be made to the report prepared by Jennifer Potter on behalf of the Architectural 98London Borough of Harrow , Stanmore Association. It should be noted that there are numerous historic garden objects within the terrace area, many of which will be listed in connection with the principal listed building. 12.21 Restoring wider views of the listed building and Italian terrace and links with Bentley Priory Open Space Restore views from the listed building and Italian Terrace Garden to Bentley Priory Open Space and Harrow on the Hill. Providing a visual link with the former parkland setting of the house. Strengthen the links between the listed building and Bentley Priory Open Space through improving the nature of the boundary treatment between the two, enhancing visual connections and reducing the C20th screen planting. 12.22 Cold War bunker English Heritage has investigated the bunker in terms of potentially scheduling the structure as an ancient monument or designating as a listed building, and has recently determined that the bunker is not suitable for either designation. The bunker will therefore be decommissioned and sealed when the RAF vacate the site. This will be carried out to a scheme agreed with the Council to ensure its continuing presence does not prejudice any future use of the site. 12.23 Design quality Achieving a high design quality, based on a full understanding of the site and its character and history, will be a key consideration in any future proposal. This will need to acknowledge the particular characteristics of distinct areas within the site, not least the area around the principal listed building. Development should also be in accordance with Harrow Council’s UDP policies on design and with guidance in PPS1 and PPS3. 12.24 Archaeology Any proposals will need to be sensitive and sympathetic to the archaeological potential of the site and should take full account of the requirements of PPG16. 99London Borough of Harrow , Stanmore Due to the above mentioned opportunities inherent with the principal listed building and historic park and garden, the Council will require that any future development proposals are supported with justified statements and conservation plans dealing with the effects upon the historic fabric of the site and design. Achieving the Landscape Vision 12.25 In respect of the Historic Park and Garden setting of Bentley Priory there are a number of potential landscape benefits the Council would seek to secure from any future development of the site. These are set out below with the aid of the landscape plan attached to the end of the report: 12.26 Potential for development within areas of high visual containment The established vegetation structure affords a high degree of enclosure ensuring views into the site from the wider setting are limited. The existing treescape will also create a significant degree of integration and visual containment for proposed development ensuring that views into and out of the wider Green Belt setting are not detrimentally affected. Potential areas for future development have been identified at section 11. 12.27 Potential for development within areas influenced by existing built form. The key buildings to be retained provide an established setting for any proposed development ensuring that new built form sits within an existing built environment. As such any development proposals should not encroach upon existing green areas on the site, or mature trees subject to a Tree Preservation Order (TPO). 12.28 Restore the parkland and woodland setting to the north of the main house The removal of the existing car park, earth mounding and the modern evergreen tree screen around the car park will open up vistas towards the main house when approaching along the driveway from the north. Together with the introduction of new planting, the reinstatement of the parkland and woodland landscape to the north of the main house will enhance both the setting of the listed building and any new 100London Borough of Harrow , Stanmore development and also enhance the approaches to the site from the north along the drive. This would restore the parkland and woodland setting to the north of the main house in accordance with the original layout of the Priory’s grounds. The Council wishes to see the removal of the two telecommunication masts that currently detract from the wider landscape and historic setting. 12.29 The key trees within the site should all be retained. There are a substantial number of mature trees within the site which create the setting for the historic house and park. Key trees will be identified by any potential developer and retained in line with British Standard 5837 to ensure that the character of the parkland and its setting is maintained. This treescape will also create a high quality setting for new development. It should be noted that the Council will be confirming four tree preservation orders to cover individual trees, groups and woodland areas. 12.30 Introduce a parkland management scheme to the area to the south of the listed building 12.31 Proposals for the development of the site will be expected to be accompanied by management schemes to include tree removal and replacement to enhance the setting of the listed building and also enhance intervisibility between the main house and the wider setting including the original park that now lies beyond the sites boundaries. 12.32 The management of the vegetation structure to the south of the main house will enhance views towards Bentley Priory Open Space and to Harrow beyond from the listed building and terrace garden. The main house forms a key element within the wider context, the management of this planting would ensure that the listed Bentley Priory building remains part of the wider visual envelope. Retention of key vegetation structure will ensure that the integrity of the parkland setting is maintained. 12.33 Following development it is important that the parkland, formal gardens and areas of woodland and new woodland plantings are properly managed. The management agreement will be secured through a section 106 agreement that will oblige future owners and occupiers of the site to continue to support the management of the wider 101London Borough of Harrow , Stanmore site. Planning obligations and section 106 agreement issues are discussed in more length at section 12. 12.34 Footpath links around Bentley Priory Open Space There are opportunities to provide greater public access between the site and the adjoining Bentley Priory Open Space. The London Loop runs to the south of the site through the Bentley Priory Open Space and there are opportunities to improve visual access to the Priory site from this footway. Limited footpath links between the site and the Open Space could be created in the south-east corner, but any footpath would not give access to the wider grounds of Bentley Priory which will remain restricted. These areas would only be open to the public as part of a visit to the main house. The location of the footpath links will be dependent on their impact upon existing and proposed elements within the Bentley Priory site, while the links to existing footpaths will ensure compatibility with the adjoining Bentley Priory Open Space. Care needs to be taken in balancing the advantages of greater public access with the need to protect and maintain the ecological value of the designated SSSI. 12.35 Public access in the context of the proposed development areas is dealt with in more detail at paragraph 11.31 of section 11. 12.36 Potential to re-establish link with Glenthorne site (UDP proposal site 23) There is potential for planning gain monies to be used for off site improvements in the landscape linkage between the Glenthorne site and Bentley Priory Open Space. This would help re-establish links with the Glenthorne site which has in the past played a role in both the landscape and heritage setting of Bentley Priory as a whole. The Glenthorne site is illustrated on a plan attached to the end of the report. and will be included within and added to the Bentley Priory Open Space in accordance with the proposed use for Glenthorne set out by the Council's adopted UDP. 12.37 Command bunker The area of land around the Cold War bunker at the eastern end of the site should be opened to the public and an out-door interpretive display provided to explain the 102London Borough of Harrow , Stanmore origin and purpose of the bunker. A commuted sum for the ongoing maintenance and upkeep of this area as part of the wider Bentley Priory open space will be required as part of the section 106 agreement relating to development of the wider site.. Achieving the Ecological Vision The Council will seek the retention and enhancement of existing ecological assets on and around the site. The following factors set out the issues that should be addressed within detailed schemes for the site by way of management agreements, planning condition or section 106 agreements and should be read in association with the ecology plan attached to the end of the report.: 12.38 Designations Part of the southern boundary of the site is constrained by the Bentley Priory Open Space and the Site of Special Scientific Interest (SSSI), Local Nature Reserve (LNR) and Site of Nature Conservation Importance (SNCI) which receive, protection under national legislation. Best practice will need to be strictly adhered to during the construction phase of any future proposals and the ongoing future use of the site in order to avoid any damaging impacts on the special interest features of these statutory and non statutory designations. Any increase in usage of the SSSI/ LNR as a result of development will be balanced against the benefits that may be derived from encouraging greater public access to the open space and RAF Bentley Priory. Recreation space for residents within the redeveloped RAF site would relieve pressure on the SSSI. 12.39 Habitats In habitat terms, the site is relatively unconstrained with the majority of habitat areas considered to be of low to negligible ecological interest. However, there is the opportunity for nature conservation features to be enhanced in line with PPS 9 (Biodiversity and Geological Conservation) The areas of scrubland and broad-leaved woodland in the south of the site and a number of mature trees are of ecological interest and any future proposals should protect, retain and enhance these features. Habitats also exist within certain trees and buildings, ponds and rank grassland within and adjacent to the site and should be protected, retained and enhanced where appropriate. 103London Borough of Harrow , Stanmore 12.40 The highly invasive species Japanese Knotweed is present within the site (see Ecological plan). Best practice should be followed during any activities that could potentially cause the further spread of this undesirable species. Any future development must take measures to eradicate this plant from the site, which should be included within ongoing management plans. 12.41 Species The baseline survey work has identified that the trees & buildings; ponds; and rank grassland; within/adjacent to the site have the potential to support bats; Great Crested Newts; and common reptiles, respectively. Bats and Great Crested Newts are fully protected under European and national legislation, while common reptile species receive partial protection at the national level. Significant species may also exist within the woodland and scrubland areas around the site. Further survey work is needed at the planning application phase to establish the precise extent to which protected species would constrain any future development and to determine the need for any mitigation. It is also noted that common bird species occur at the site, which receive protection while nesting. 12.42 Location of enhanced access to Bentley Priory Open Space Greater public access between the site and the existing pathways within the adjoining Bentley Priory Open Space is sought. This measure would facilitate the public’s enjoyment and appreciation of the natural features of the Open Space and LNR, in line with the objectives of this ecological designation. Linking in to existing pathways must ensure compatibility with the SSSI’s ecological interest features and the exact positioning of the new access points will need to be carefully considered so as to respect and protect the existing interest. The provision of targeted access to/from the site, together with the provision of new areas of nature conservation interest within the site, will potentially act to divert some of the existing recreational use from the SSSI. Specific access requirements are dealt with in more detail at paragraph 11.31 of the report. 12.43 Habitat creation 104London Borough of Harrow , Stanmore New habitat areas of benefit to nature conservation, which will enhance the existing and adjacent ecological setting are included within the SPD. Such areas could include enhancements such as wildflower planting, appropriate woodland planting and a number of species specific measures, e.g. the erection of bat and bird boxes. In addition, with the erection of interpretative panels these areas could function as an educational resource as well as areas for informal recreation. Subject to establishing the financial and physical feasibility and the prioritisation of Section 106 funding, this site could provide a location for an ecology/environment centre. Details for the nature conservation enhancement of areas identified on the SPD are to be set out within planning proposals for the site including management for their future maintenance. 12.44 Management The sensitive management of the woodland at the site, including selective thinning and new native planting together with the other retained and newly created habitats will enhance the ecological interest of the site. In addition, the removal of Japanese Knotweed within the woodland and elsewhere within the site will provide an ecological enhancement. The Council seeks future proposals for the site to include ecological assessments for selective thinning of woodland to the south of the Priory including management plans for their future maintenance. Opportunities for future development at Bentley Priory 12.45 Section 11 of the SPD sets out guidelines for the future development of Bentley Priory. 105London Borough of Harrow , Stanmore 13.0 Predicting and appraising effects of the draft SPD 13.1 In terms of predicting and appraising the effects of the draft SPD this has been set out in a table below: Effects over time + positive – negative 0 neutral ? uncertain Can the +/– minor effect be ++/– – Comments/ SA Objective Targets quantified major explanations To make the Development in Yes + Any possible most efficient accordance with future use of land and PPS2 annex C in development buildings. terms of footprint could not of new increase the development. footprint of the site compared to the existing 1 buildings. To protect the Insertion of two Yes ++ This policy quality, quantity public access option ensures and accessibility points from the that access to of open spaces creation of one the Borough's in the Borough. open area, one open spaces is public footpath increased and public access while to the house maintaining its museum and quality. terrace with management 2 plans. To conserve and No development Yes ++ The enhance on areas management biodiversity in adjacent to or on of a further the Borough. areas identified two areas of which are nature important in conservation biodiversity enhancement terms. Insertion on the site will of two areas of be of a benefit nature to the conservation biodiversity on 3 enhancement. the site. 106London Borough of Harrow , Stanmore To restrict The development Yes ++ The potential development areas have been to enhance which can identified in the setting of negatively affect relation to the the setting of the landscape setting of the the grade II* and streetscape grade II* listed listed Priory and design of Priory building, building, historic, grade II historic grade II archaeological park and garden, historic park sites (listed archaeological and garden, buildings and features on the archaeological conservation site and its features on areas) or association with the site and its culturally the Battle of association important Britain. The SPD with the Battle features. also identifies a of Britain will number of be a major potential benefit to the development and borough, landscape particularly in initiatives to be terms of the secured through future development of conservation the site which and vitality of would enhance the site. the setting of 4 these features. To ensure air Development of Yes + Promotion of quality the site would sustainable continues to use resources energy improve through impacting upon efficient reducing air the environment development pollution and and climate. of the site will address the reduce the causes of short and long climate change term impacts through upon the reducing environment. emissions of greenhouse gasses and other pollutants (including air, water, soil, noise, vibration 5 and light). To reduce Would be dealt Yes Unknown N/A pollution of land with by planning (soil) and ensure condition, section that 106 agreement contaminated or building land is regulations on remediated. any future 6 development. 107London Borough of Harrow , Stanmore To improve Development Yes ++ In accordance water quality could result in with PPS25 and reduce the increased any potential risk and impact probability of development of flooding. flooding. would need to undertake flood risk assessment which would illustrate any potential problems and necessary mitigating measures to reduce any adverse 7 impacts. To promote This objective N/A N/A N/A development would be dealt that ensures the with at the sustainable use detailed design of energy. stage of any potential future 8 development. To discourage Potential Yes ++ Promotion of the production development of sustainable of waste and the site would development promote further result in the in terms of the the waste production of design, access hierarchy of waste products. and usage of minimisation, the site can reuse, recycling ensure that and composting. waste production is kept to a 9 minimum. To facilitate the Potential Yes ++ It is of vital development of development importance a dynamic and could include that any diverse commercial potential economic sector development. commercial which attracts development growth. is viable to help maintain the special characteristics of the site. The Council would be seeking an open book approach in this respect to ensure that 10 potential 108London Borough of Harrow , Stanmore commercial development is dynamic and diverse. To improve the Museum- Yes ++ Museum education and educational would act as skills of the facility & living Borough. interpretive educational feature on facility. 11 bunker site. To ensure all Any potential Yes ++ In the context groups have future residential of the likely access to decent, development residential use appropriate and would be of areas of the affordable developed in site this is a housing that accordance with potential meets the needs the Council's benefit in of Harrow's affordable relation to the residents. housing policies SA objective. 12 and objectives. To reduce social Potential Yes ++ In accordance exclusion and residential with facilitate the development of affordable development of the site would housing policy mixed and create a and balanced significant sustainable communities. addition to the design any existing potential community in the development immediate area. can deliver a mixed and balanced 13 community. To improve the N/A N/A N/A N/A health and wellbeing of Harrow residents and reduce inequalities in 14 health. To improve the N/A N/A N/A N/A competitiveness, vitality, viability and adaptability of town centres 15 in Harrow. To reduce crime, The opening up Yes ++ Good access fear of crime and of the site will and design of anti social result in public any potential activity. use of the area development and potential for can promote 16 crime and anti low crime 109London Borough of Harrow , Stanmore social behaviour. incidents and help reduce anti social behaviour. 13.2 In terms of assessing the effects of the SPD upon the Bentley Priory site in accordance with the Council's SA objectives it is important monitoring of the content of the SPD and implications it has for the site is undertaken at regular intervals. 110

SPD for RAF Bentley Priory

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