PLANNING COMMITTEE 4 July 2019 Melek Ergen [email protected]References: P/2019/1530 00981/1-2/P1 Address: Units 1 and 2 and Parts Garage, Rennels Way, TW7 6NA Proposal: Proposed mixed use redevelopment comprising, demolition of existing buildings and construction of two buildings up to seven storeys to provide 653 square metres (Use Class B1) of commercial floor space, and 53 dwellings (1 studio, 24 one- bedroom, 22 two-bedroom, 5 three-bedroom and 1 four-bedroom) with associated access and highway works, amenity areas, cycle and disabled car parking and refuse/recycling stores This application is being taken to Planning Committee as a Major Scheme with a Legal Agreement 1.0 SUMMARY 1.1 The applicant seeks planning approval for demolition of existing industrial units to provide 653 square metres commercial floor space (Use Class B1) and two up to seven-storey buildings to provide 53 flats with car and cycle parking and amenity spaces. 1.2 The proposed buildings would be either side (north and south) of Rennels Way, five to seven storeys high, behind the recently consented schemes along the 1 to 7 St John’s Road to the east and railway to the south. 1.3 The proposed buildings would be brick with stepped columns and elevations that reflect their principle residential purpose. The proposal would enhance pedestrian connectivity into the site and providing public realm improvements. 1.4 The proposed commercial space would be on the ground floors of both buildings and part of the first floor of the north block, with separate accesses. There would be an active street frontage, a play space on the ground floor and private and communal amenity spaces for the flats. 1.5 The proposal would be a car-free scheme with five disabled persons’ car parking spaces and a loading bay for deliveries. There would be enough cycle parking spaces for the commercial and residential and easily accessible refuse storage areas. The application is recommended for approval subject to safeguarding conditions and legal agreement.
References: P/2019/1530 00981/1-2/P1Address: Units 1 and 2 and Parts Garage, Rennels Way, TW7 6NAProposal: Proposed mixed use redevelopment comprising, demolition of
existing buildings and construction of two buildings up to seven storeys to provide 653 square metres (Use Class B1) of commercial floor space, and 53 dwellings (1 studio, 24 one-bedroom, 22 two-bedroom, 5 three-bedroom and 1 four-bedroom) with associated access and highway works, amenity areas, cycle and disabled car parking and refuse/recycling stores
This application is being taken to Planning Committee as a Major Scheme with a Legal Agreement
1.0 SUMMARY
1.1 The applicant seeks planning approval for demolition of existing industrial units to provide 653 square metres commercial floor space (Use Class B1) and two up to seven-storey buildings to provide 53 flats with car and cycle parking and amenity spaces.
1.2 The proposed buildings would be either side (north and south) of Rennels Way, five to seven storeys high, behind the recently consented schemes along the 1 to 7 St John’s Road to the east and railway to the south.
1.3 The proposed buildings would be brick with stepped columns and elevations that reflect their principle residential purpose. The proposal would enhance pedestrian connectivity into the site and providing public realm improvements.
1.4 The proposed commercial space would be on the ground floors of both buildings and part of the first floor of the north block, with separate accesses. There would be an active street frontage, a play space on the ground floor and private and communal amenity spaces for the flats.
1.5 The proposal would be a car-free scheme with five disabled persons’ car parking spaces and a loading bay for deliveries. There would be enough cycle parking spaces for the commercial and residential and easily accessible refuse storage areas.
The application is recommended for approval subject to safeguarding conditions and legal agreement.
2.0 SITE DESCRIPTION
2.1 The site accommodates three single storey commercial buildings. The two larger ones were formerly used for storage (B8 use class) and light industrial (B2 use class) purposes at the entrance to a light industrial estate – the Metro Centre. The small unit is used as car repair centre (B2 use class) and for vehicle storage. The larger buildings face Rennels Way and the third is to the north of them behind two houses - 1 and 2 Floriston Villas on St Johns Road. The two large buildings have been vacant for nearly three years.
2.2 The site has an industrial History but has no allocations in the Local Plan.
2.3 The site has a public transport accessibility level (PTAL) rating of 3 which is ‘moderate’. Isleworth Station, which provides rail services to Central London, is within a three minute walk from the site and there are bus routes travelling along London Road and St Johns Road.
2.4 The surrounding area comprises a mix of land uses and building forms. To the immediate west is the Metro Industrial Estate providing number of B Class buildings. Beyond these are Thornbury Park and terraced houses in Sidmouth Avenue.
2.5 To the east, the site is bounded by 1 and 2 Floriston Villas semi-detached houses fronting St John’s Road and south of them, a pair of maisonettes and a semi-detached building containing an empty shop on the ground floor with flats above. The shop site benefits from a recent planning approval (00981/AI/P2) for demolition of existing units and redevelopment to provide a part three-, part five-storey building to accommodate thirty one flats and two shops with associated car parking, cycle parking and landscaping.
2.6 The site is not in a conservation area, but St Johns Road borders the Spring Grove Conservation Area.
2.7 To the south east, 7 St John’s Road is a vacant office in the process of being converted into 39 flats under ‘Prior Approval’ (ref no: 00981/B7/PA2) and two additional storeys have been approved for a further eight flats (ref no: 00981/B7/P6) raising this building to 18 metres in height. To the immediate south, is a railway line with heavy tree planting along its embankment.
3.0 HISTORY
None relevant. The industrial buildings are long established.
4.0 DETAILS OF PROPOSAL
4.1 The proposal is to demolish the existing buildings on site to enable redevelopment with B1 (industry/office/research and development, but described specifically as offices on the plans) commercial space and 53 flats in two blocks either side of Rennels Way.
Ground floor plan
4.2 The southern plot would comprise a part five-, six- and seven-storey building, which steps down towards Rennels Way. The northern plot would comprise a part five- and part six-storey building, which steps down towards London Road.
4.3 The scheme would provide one studio, 24 one-bedroom. 22 two-bedroom, five three-bedroom, and one four-bedroom dwellings - in total 53 flats.
4.4 The scheme would provide 653 square metres of B1 floor space across the two buildings.
4.5 The office space on the ground floor of both buildings and part of first floor of the north block would provide a more active street frontage than exists now. This would enliven the public realm and provide fit-for-purpose employment space. The flats would be above the offices and look over the roof of industrial buildings on adjacent sites. . Residential and commercial uses would have their own separate accesses.
Access into the site
4.6 The scheme would sit behind the consented developments at 1-5A St John’s Road and 7 St John’s Road and would only be visible with limited views from anywhere other than Rennels way and the properties surrounding the site.
4.7 The proposal would have its highest seven-storey element adjacent to the railway to the south in the south block. This block’s height would reduce to five storeys adjacent to Rennels Way. The north block is six storeys and reduced to five storeys towards London Road to the north. See the following images.
View from London Road
East Elevation (Behind 1-7 St John’s Road)
4.8 The buildings would use two different brick types of soft red and light honey brown, metal painted balustrade/balconies, metal window frames and perforated metal mesh detailing to the windows. This is shown in the following illustration.
External Materials
4.9 All of the flats would benefit from private balconies and there would be a ground floor play area available to all residents and further communal amenity spaces on the fifth floors of both blocks.
4.10 There would be five accessible car parking spaces, 81 secure long-stay and four short-stay cycle parking spaces. A dedicated loading/refuse bay is proposed off Rennels Way, adjacent to the southern building.
5.0 CONSULTATIONS
5.1 A site notice was posted on 30 April 2019, and the application was advertised in the local press on 3 May 2019.
5.2 450 residents/businesses, St Johns Residents Association, Isleworth Society and Osterley and Wyke Green Residents Association (OWGRA) were notified on 25 April 2019; 31 objections were received as follows.
Comment Response
Too high, will tower over the entire district and will affect our access to sunlight; our gardens will be overlooked, our privacy would be eroded.
The proposed seven storey height would be adjacent to the railway and the proposal would be behind the consented schemes along the St Johns Road and would not be easily visible.A sunlight/daylight report was submitted which shows that there would be no unacceptable loss of light to neighbours. Due to the distances involved, there would be no harm to neighbours’ privacy.
Out of character with the area. The proposal would be an improvement to the current environment and positively responds to the area.
Overdevelopment. Whilst the density is above the London Plan density matrix, density range is only an indication and not to be used rigidly. The proposal complies with internal and amenity space provisions, and would deliver new housing for the area and optimise the potential of the site
Parking is a problem as we waited years to get a CPZ [controlled parking zone] in the area and now we have enough parking, but not enough for an additional 53 flats. There would be no parking spaces in the area. This development with insufficient parking should not be accepted.
The Council encourages car-free schemes all over the borough and in order to ensure the scheme remains car-free, a travel plan would be secured by a S106 agreement and the future residents would be excluded from obtaining residential permits. The location is very sustainable, close to the Station.
Traffic congestion and constant block up from the lights with London Road would get worse.
As the scheme is car-free, there would not be any noticeable increase to local traffic.
The primary schools reached their capacity and infrastructure would not support this development. Hospital and buses are not enough for more developments in the area.
The scheme would be Community Infrastructure Levy (CIL) liable to cover infrastructure costs.
Air quality and noise would get much poorer.
The submitted Air Quality report confirms that the scheme would be ‘Air Quality Neutral’ and there would be no increased impact in terms of pollution. There would be no increase of noise expected due to the proposal.
The developer should fund enhancements to Thornbury Park and lighting through the estate.
The proposal cannot provide funding for improvements to the park itself as this is covered under CIL, but there would be a S106 contribution to improve the access to the park, which can be related directly to the development as is required in such cases.
A master plan and comprehensive development including whole industrial estate needed.
The Metro Industrial Estate is not a designated site with a high occupancy rate and provides employment to the borough. There is no plan or need for a master plan for the whole estate.
5.3 St John’s Residents’ Association: We object to the proposal for the following reasons:
Overdevelopment: The density is excess of London plan and 6/7 storey development is considered bulky in part; we wish for a reduction in the number of units to stay within the maximum of the range, whilst the PTAL levels are good, local bus frequencies have been reduced, (Paragraphs 7.45 to 7.50)
Lack of master plan: This is a piecemeal development, access to Thornbury Park is an identified issue with poor public realm links but no mitigation or improvement is proposed, (note: there are no plans to include Metro Industrial Estate for future development as it provides employment; the applicant would provide contribution to improve access into Thornbury Park)
Parking and servicing: Car free approach recommended citing the CPZ as a reason which does not operate in the late evening or at weekends; where will the residents park and what measures to prevent parking on the private land on the industrial estate, what are the provisions for deliveries and parking bays for B1 units, parking survey needs updating and should include late night and weekends, family units aggravate this and people still be able to park outside of CPZs operational hours. (note: as the scheme is car free, there would be a travel plan to ensure future resident would not own a car; as the Metro Industrial Estate is private land (although it is likely that the owners of the estate would want to), the Council cannot ensure no parking on private land; there are provisions for deliveries within the scheme).
6.0 POLICY
Determining applications for full or outline planning permission
6.1 Determination must be made in accordance with the development plan unless material considerations indicate otherwise. Local finance considerations must also be assessed. The National Planning Policy Framework
6.2 The National Planning Policy Framework (NPPF) came into force on 27 March 2012 and the revised version was published on 19 February 2019 and has replaced national policies and guidance formerly contained in Planning Policy Statements and Planning Policy Guidance notes and some other documents. The Local Planning Authority (LPA) considers that, where pertinent, the NPPF is a material consideration and as such, it will be taken into account in decision-making as appropriate.The Development Plan
6.3 The Development Plan for the Borough comprises the Council's Local Plan (adopted by the Council on 15 September 2015), the West London Waste Plan and the London Plan Consolidated with Alterations since 2011.
6.4 The draft New London Plan was published on 29 November 2017, for consultation from 1 December 2017 to 2 March 2018. The policies of the draft Plan are capable of being a material consideration in planning decisions. Its policies will gain more weight as it moves through the examination process to adoption; however the weight given to it is a matter for the decision maker. At this stage only limited weight is to be given to the draft Plan due to it being only in the initial stages of consultation.
6.5 The Council are currently undertaking two Local Plan Reviews; the West of Borough Local Plan review and the Great West Corridor Local Plan review. Neither review is relevant to this case.
6.6 The adopted Local Plan and emerging Local Plan Review documents can be viewed on the Planning Policy pages of the Hounslow website.
Relevant London Plan Policies2.16 Potential Strategic Outer London Development Centre3.3 Increasing Housing Supply3.4 Optimising Housing Potential3.5 Quality and Design of Housing Developments3.8 Housing Choice3.11 Affordable Housing Targets3.12 Negotiating Affordable Housing on Individual Private Residential
and Mixed Use Schemes3.13 Affordable Housing Thresholds4.1 Developing London’s Economy4.2 Offices5.1 Climate Change Mitigation5.2 Minimising Carbon Dioxide Emissions5.3 Sustainable Design and Construction5.7 Renewable Energy5.9 Overheating and Cooling5.13 Sustainable drainage5.15 Water use and supplies6.3 Assessing effects of development on transport capacity6.9 Cycling6.10 Walking6.13 Parking7.1 Lifetime Neighbourhoods7.2 An Inclusive Environment7.4 Local Character7.6 Architecture7.14 Improving air quality7.15 Reducing and managing noise, improving and enhancing the
acoustic environment and promoting appropriate soundscapes7.19 Biodiversity and access to nature8.2 Planning Obligations8.3 Community Infrastructure Levy
6.7 Draft London Plan Policies
GG2 Making the Best Use of LandGG4 Delivering the Homes Londoners NeedD2 Delivering Good Design
D3 Inclusive DesignD4 Housing Quality and StandardsD5 Accessible HousingD6 Optimising Housing DensityD13 NoiseH1 Increasing Housing SupplyH2 Small SitesH5 Delivering Affordable HousingH7 Affordable Housing TenureH12 Housing Size MixE1 OfficesE2 Low-cost business spaceE3 Affordable workspaceSI1 Improving Air QualitySI2 Minimising Greenhouse Gas EmissionsSI5 Water infrastructureSI7 Reducing Waste and Supporting the Circular EconomySI12 Flood Risk ManagementT4 Assessing and Mitigating Transport ImpactsT5 CyclingT6 Car Parking
6.8 Local Plan
CC1 Context and CharacterCC2 Urban Design and ArchitectureCC4 HeritageSC1 Housing GrowthSC2 Maximising the Provision of Affordable HousingSC3 Meeting the Needs for a Mix of Housing Size and TypeSC4 Scale and Density of New DevelopmentSC5 Ensuring Suitable Internal and External SpaceED1 Promoting Employment Growth and DevelopmentED2 Maintaining the Borough’s Employment Land SupplyED4 Enhancing Local SkillsEQ1 Energy and Carbon ReductionEQ2 Sustainable Design and ConstructionEQ3 Flood risk and surface water management
EQ4 Air QualityEQ5 NoiseEQ7 Sustainable waste managementGB7 BiodiversityEC1 Strategic transport connectionsEC2 Developing a sustainable local transport networkIMP1 Sustainable developmentIMP3 Implementing and monitoring the Local Plan
7.0 PLANNING ISSUES
The principle of the proposed development
Loss of commercial floorspace and employment
7.1 The National Planning Policy Framework (NPPF) states that new applications should be considered in the context of a presumption in favour of sustainable development. It goes on to state (see Paragraph 111) that planning policies and decisions should encourage effective use of land by re-using previously developed (brownfield) land, provided it is not of high environmental value.
7.2 London Plan Policy 4.1 promotes the continued development of a strong, sustainable and increasingly diverse economy in London, and Policy 4.2 supports the management and mixed use development of office provision to improve London’s competitiveness.
7.3 Policy ED1 (Promoting Employment Growth and Development) of the Local Plan aims to secure business opportunities and directs new offices to the Borough’s town centres and industrial development to Strategic Industrial Sites (SIL), Locally Significant Industrial Sites (LSIS) sites. It expects developments to provide flexible space within dwellings that can be used for home working and start-up space wherever feasible; and to provide incubator space appropriate for start-up businesses as part of employment related or town centre mixed use development proposals, subject to demand and viability considerations.
7.4 Policy ED2 (Maintaining the Borough’s Employment Land Supply) states that where a loss of B1a, B1b, B1c, B2 or B8 or similar employment uses is proposed outside of SILs and LSISs the applicant should provide:
i. Evidence of active marketing of the site for employment uses for a period of at least one year in other than Key Existing Office locations;
ii. An assessment demonstrating that the introduction of non-employment uses is necessary to achieve sufficient viability to deliver a development scheme. Preference will be given [in such cases] to the provision of new employment uses, followed by a mix of employment. Non-employment uses will only be considered once the retention of employment uses has been shown to be unviable; and
iii. Evidence that surrounding employment uses/sites will not be undermined.
7.5 The site is not allocated Strategic Industrial Land (SIL) or part of a designated Locally Significant Industrial Site (LSIS) and therefore in accordance with Policy ED2, a minimum 12 months’ marketing evidence is needed to demonstrate that there is no longer a need for the existing use if it is proposed to replace it. The loss of the existing industrial uses have been justified in this instance with marketing evidence for a period of over 18 months between June 2015 and November 2016 and further between August 2017 and August 2018 totalling 13 months. The applicant also provided supporting evidence from another commercial property consultancy to confirm the present premises would not be suitable for long-term letting/investment due to low eaves height, lack of services within, being in need of refurbishment.
7.6 Furthermore, the existing site comprises 758 square metres of B2 (general industry)/B8 (storage and distribution) floorspace and according to the Housing and Communities Agency (HCA) Employment densities guide, this amount of B2 floorspace would typically generate approximately 21 jobs, and same amount of B8 floorspace would generate seven to ten jobs. The proposal would re-provide 653 square metres of B1 floorspace and according to the HCA guide, the proposed commercial floorspace would be expected to generate between 49-80 jobs, depending on the nature of the B1 use. Therefore, the applicant has demonstrated that the current uses are not fit for purpose and cannot be let, this has been verified by an independent review of the initial evidence. In addition, the proposal would not result in a loss of employment and so would be acceptable in principle in this respect.
Housing
7.7 The NPPF paragraph 59 identifies as one of the strategic policies as ‘Government’s objective of significantly boosting the supply of homes’ and paragraph 123 states ‘where there is an anticipated of existing shortage of land for meeting identified housing needs, it is especially important that planning policies and decisions avoid homes being built at low densities, and ensure that the developments make optimal use of the potential of each site’.
7.8 In relation to new housing, the London Plan encourages high quality schemes for housing developments that make more efficient use of land. It states that good design should contribute positively to making places better for people. Design which is inappropriate in its context, or which fails to take opportunities available for improving the character and quality of an area and the way it functions, should not be accepted.
7.9 London Plan Policy 3.3 (Increasing London’s Housing Supply) recognises the need for more homes in London so as to promote opportunity and provide a real choice for all Londoners in ways that meet their needs affordably.
7.10 Policy 3.4 (Optimising Housing Potential) states that, taking into account local context and character, the design principles outlined in Chapter 7 of the Plan and public transport capacity, development should optimise housing output for different types of location.
7.11 Draft London Plan Policy H1 would increase the Borough’s Housing Target to provide for 21,820 homes over the plan period (2019/20-2028/29). Draft Policy H2 proposes a specific target for new homes delivered on small sites over the plan period. For Hounslow this would be 6,800.
7.12 The Government, Mayor of London and the Council place great importance on the need to optimise sites so as to provide high quality affordable homes for local people. It is considered that this site could sustainably help meet the need to provide additional housing in the Borough.
7.13 In light of this, the housing element of the proposal would be acceptable in principle accordance with NPPF, London Plan policy 3.3, Draft London Plan policy H1 and Local Plan policy SC2, provided it complies with other planning issues.
7.14 Although acceptable in principle, the development must take account of the following policy requirements before it could be approved:
- Affordable housing- Height, design, layout- The impact on neighbouring residents - Standard of proposed accommodation- Highways, transport, access- Energy and sustainability- Environmental considerations; and- Planning obligations.
Affordable Housing
7.15 London Plan policy 3.12 also states that, in negotiating affordable housing in private schemes, Boroughs should seek the maximum reasonable amount of affordable housing.
7.16 London Plan policy 3.12 also states that, in negotiating affordable housing in private schemes, Boroughs should seek the maximum reasonable amount of affordable housing Local Plan Policy SC2 refers to a strategic borough-wide target of 40% of all new housing as affordable. The policy seeks “the maximum reasonable amount of affordable housing” in new developments providing ten or more homes. The expected tenure mix of affordable housing is 60% affordable rent and 40% intermediate housing.
7.17 The financial viability assessment submitted with the application has been reviewed by an independent consultant on behalf of the Council. The applicants initial affordable housing offer was for 40% affordable housing which comprised of 21 shared ownership homes for sale. The Council currently has a high housing need for social rented units therefore further negotiations took place to address this need. Officers negotiated an offer which comprises of 16 family sized homes to be provided at London Affordable Rent (LAR) levels.
7.18 This equates to 30% affordable housing across the scheme. It should be noted, that the viability of this proposal has been reviewed and it is accepted 16 homes at LAR would have a negative impact on the development viability and currently exceeds the maximum reasonable level of affordable housing which can be provided. The rented units would assist the Council to house 16 eligible families from its housing waiting list. A comparison of London Affordable Rent levels against current Local Housing Allowance (LHA) levels is shown in below table:
£/Per week 1 Bed 2 Bed 3 Bed 4 Bed
LAR 2019/20 Benchmark
155.13 164.24 173.37 182.49
LHA June 2019
186.44 243.64 280.68 337.37
London Affordable Rent levels vs Local Housing Allowance levels
7.19 The proposal of 16 units would amount to the whole of the South Block (adjacent to railway) being an affordable rented housing block out of this 53 flats scheme. Whilst this results in 30% affordable housing on site, the compliance with the Council’s strategic objective of providing 40% affordable housing with a 60-40% tenure split would achieve 13 rental and 8 shared ownership units and only remove 13 families from the Council’s waiting list. The negotiated proposal offers six larger family homes of three or more bedrooms, one of which would be adaptable for a wheelchair user. The mix of the 16 affordable rented units is shown in below table.
Housing unit mix
Bed size/ No. Persons
1B/2P 2B/3P 3B/4P 3B/5P 4B/5P
Number of units
5 5 1 4 1
Affordable rented homes mix
7.20 As this proposal is not securing the Council’s strategic target of 40% affordable housing as outlined in policy SC2 requirement at the outset of the scheme, an additional review would be applied at the outturn to ensure the maximum reasonable level of affordable housing would be provided upon completion of the scheme. Should the level of affordable housing increase to 40% before project completion this outturn review would not be required.
7.21 The current proposal would assist the Council to house 16 families within good quality accommodation supported by the Council’s housing team. The Council would secure its nomination right to the affordable housing at LAR levels in perpetuity through a s106 agreement.
Height, design and layout7.22 The NPPF requires that development should achieve good design, respond
to local character and history, and reflect the identity of local surroundings, including materials, and prevent harm or loss to designated heritage assets, while not preventing or discouraging appropriate innovation. It goes on to say (Paragraph 60) that planning decisions should not attempt to impose architectural styles or particular tastes and they should not stifle innovation,
originality or initiative through unsubstantiated requirements to conform to certain development forms or styles. It is, however, proper to seek to promote or reinforce local distinctiveness.
7.23 That said, it makes clear that planning permission should not be refused for buildings and infrastructure that promote high levels of sustainability because of concern about incompatibility with an existing townscape, provided it is of good design.
7.24 The degree to which new development reflects and responds to the character and history of its surrounds is a key element of good design as defined in the NPPF. Developing a design solution that works with its context should not prevent or discourage appropriate innovation.
7.25 London Plan Policy 7.4 (Local Character), Local Plan Policy CC1 (Context and Character) and Local Plan Policy CC2 (Urban Design and Architecture) interpret these requirements in a local context.’
7.26 In addition, Local Plan Policy SC4 (Scale and Design of New Housing Development) seeks new development that balances the need to make efficient use of land, to achieve high quality design and accessibility, to respect local context and character while protecting existing residents’ living conditions.
7.27 The site would not be directly visible from the St Johns Road Conservation Area as the proposed blocks would sit behind the 7 St Johns Road and recently approved 1-5A St Johns Road residential developments.
7.28 Nevertheless, the proposal has been designed to high specifications and the height of the south and north blocks are carefully considered. The south plot would have the highest, seven-storey element facing the railway line and would step down towards Rennels Way. The north block similarly steps down towards London Road. The visual impact of the higher element has been reduced due this context.
Section
7.29 The building heights respond to the height of the buildings along the St Johns Road, including those which have recently been approved, as well as taking advantage of adjacent railway.
7.30 The site lies between the housing to the east and industrial to the west, in a space of transition, and it is considered that the building’s height would provide a good relationship between them. In this case, the proposal’s position, size, scale, height and appearance, are considered appropriate in scale and character given approved and existing development locally and would comply with policies CC1 and CC2.
View from London Road with proposed scheme in background
7.31 The provision of office space at ground floor level would activate the street frontage and would assist in ‘passive surveillance’ for the area to enhance security.
Ground floor plan
7.32 Pedestrian walkways, combined with public realm would create an open landscaping access for the north block. A communal amenity space/play area would be sited to the north of the site. Details of landscaping would be subject to condition (9).
7.33 The building would be in brick with double layers of soldier course bricks to articulate the floor slabs and four layers of soldier course bricks separating the ground floor commercial units from the above residential use. There would be full height metal framed windows in a colour to match with balustrade and perforated mesh details. The elevations are articulated throughout to ensure an interesting, building.
Proposed detailed façade – North Block East Elevation
7.34 The details of materials would be conditioned (3) to ensure quality. In this light, the proposal is not considered harmful to its surroundings. These are illustrated in the diagram at Paragraph 48 of this report.
7.35 The proposal would deliver an interesting addition to the locality and would respond to and reflect the area’s character. It is considered that the proposal’s form and massing are appropriate and that its scale and design is suitable and that the landscaping to the frontages would be an improvement to the street. The scheme design is considered to accord with the NPPF, the London Plan and Local Plan Policies.
7.36 The development is acceptable for this site in view of its surroundings, providing a good pedestrian environment.
Impact on the neighbours
7.37 The NPPF requires sustainable development and, as part of this, development should aim to avoid harm to the local environment, which includes neighbouring amenity.
7.38 London Plan Policy 7.6 states that buildings should not unacceptably affect surrounding land and buildings, particularly residential buildings in relation to privacy, overshadowing, wind and microclimate.
7.39 Local Plan Policy CC2 (Urban design and architecture) states that new development should protect neighbours’ living conditions. Objectors have raised concerns about loss of light, privacy, noise and disturbance.
Distances from proposed scheme to office conversion at 7 St Johns Road and consented development at 1-5A St Johns Road.
7.40 The south block’s primary orientations are north and south and secondary orientations towards the east where there is no direct overlooking to the new flats at Coombe House (No 7).
7.41 The north block’s primary windows are to the north and away from the consented scheme at 1-5A St Johns Road where there are facing windows the separation distance would be over 20 metres.
7.42 In terms of existing flats along the London Road, block A would be over 30 metres away from their windows; Block B would be over 60 metres away from the houses along Aylett Road on the other side of the railway, therefore causing no unacceptable loss of light, sunlight, outlook or privacy.
7.43 The submission includes a Sunlight/Daylight Assessment to confirm compliance with Building Research Establishment (BRE) guidelines. It looks in detail at nearby dwellings such as 491-495 London Road, 498b London Road, 2-14 St John’s Road, 1 and 2 Floriston Villas, 1-5A St John’s Road, 7 Coombe House, 21 Sidmouth Avenue, 11 Crawford Close, 12 Crawford Close, 11 and 12 Wighton Close. It concludes that the analysis demonstrates that the development would leave the majority of neighbouring properties unaffected. Limited impact to recently consented schemes would occur due to the close proximity but no unacceptable effect would transpire.
7.44 Thus it is considered that the proposal would have an acceptable effect.
Standard of Proposed Residential Accommodation
Density
7.45 Local Plan policy SC4 (Scale and design of new housing development) seeks to balance the need to make efficient use of land and achieve high quality design and accessibility, whilst respecting local context and character and existing residents’ living conditions. It states that the density set by
London Plan policy 3.4 (Optimising housing potential) will help guide the design and scale of new housing, but that the Council expects developments to be responsive to the context and character of any site and its setting.
7.46 London Plan policy 3.4 refers to Table 3.2 and its density matrix. The expected development density varies according to location. Based on this site’s characteristics, it can be regarded as having an ‘urban’ setting, with a PTAL rating of 3. The matrix suggests that a range of 200-450 habitable rooms per hectare and 70-170 units per hectare is generally acceptable.
7.47 The scheme has a density of 628 habitable rooms per hectare and 238 units per hectare. However, the Mayor’s Housing Supplementary Planning Guidance acknowledges that the maximum density in the range should not be seen as a ‘given’. It indicates that there may be exceptional circumstances where densities outside the ranges may occur and that the table should not be applied mechanistically.
7.48 Whilst the development represents a higher density development than suggested by the existing London Plan, density is a useful tool in understanding site capacity and not in itself a reason for refusal, nor does it necessarily suggest a poor quality development.
7.49 Furthermore, the emerging London Plan removes the density matrix and places a clear requirement to maximise the potential of sites such as this, a brownfield site with PTAL 3, to address the shortage of homes in London. The plan also indicates that good site layout and design are more important factors than residential density.
7.50 The development would offer good housing, deliver new homes for the area and optimise the potential of the site in line with the intent of these policies.
Housing mix
7.51 The NPPF and the London Plan encourage new residential developments to provide a choice of housing with a mix of family and non-family housing that is needed to meet different community requirements. In addition to this housing mix need, developments of more than ten dwellings are expected to include a proportion of affordable homes as required by London Plan Policy 3.13 (see paragraphs 7.16-7.20 above). As the following table shows, the proposal would provide 53% family dwellings and this is considered an appropriate mix, in line with Local Plan policy SC3.
7.52 Local Plan Policy SC5 refers to minimum internal space standards, requiring all new housing to comply with the Nationally Described Space Standards. These are based on the minimum gross internal floor area (GIA) required for new homes relative to the number of occupants, whilst also taking account of commonly required furniture and storage spaces needed for different activities and for moving around, in line with ‘Lifetime Home’ standards.
7.53 The flats would comply with these standards and with the Council’s private amenity space standards as follows:
7.54 The provision of good quality, usable amenity space and children’s play areas is fundamental to good planning. The quality and quantity of the amenity space in developments of this size is important and should make adequate provision and accessibility for all residents. These spaces should be private and secure with safe and convenient access. For flatted schemes, communal areas are generally acceptable, although individual flats should have areas immediately adjoining private outdoor space for their sole use.
7.55 Thus, Local Plan policy SC5 (Ensuring Suitable Internal and External Space) states that a minimum of five square metres of private outdoor
space should be provided for each 1-2 person dwelling and an extra square metre for each additional occupant. This can be provided in the form of usable balconies, roof terraces or private garden space. Communal external space should be provided at no less than the following ratio;
Up to three habitable rooms 25 square metres per flatFour habitable rooms 30 square metres per flatFive habitable rooms 40 square metres per flat
7.56 The policy also states this can be reduced by the area of private space provided for each flat.
7.57 All the proposed flats would benefit from private amenity spaces that meet or exceed London Plan requirements and communal amenity spaces are provided at ground floor level (565 square metres), with communal roof terraces on the north block fifth floor (61 square metres), and south block fifth floor (176 square metres) totalling 802 square metres. All communal areas would receive good sunlight and daylight and the play area on the ground floor would provide good quality play space for the occupiers which details would be secured by condition (10).
Communal Amenity Space ProvisionArea (square metres)
7.58 The proposal requires 1365 square metres of amenity space to accord with policy SC5 and proposes a total of 1,372.3 square metres via private and communal amenity spaces. The proposal would thus meet the required amenity space provision. Moreover, the location is 130 metres from the entrance to Thornbury Park – just over a minute’s walk. The proposal is considered acceptable in terms of amenity space provision.
Sunlight/daylight
7.59 There are no single aspect flats or ones with only northern aspect. The submission includes an internal daylight assessment report which confirms that all the rooms have been tested in line with the BRE guidance for Average Daylight Factor (ADF), Daylight Distribution Analysis (DD) and Annual Probable Sunlight Hours (APSH).
7.60 The report confirms that the overwhelming majority of rooms tested would see full compliance with the BRE Report Guidelines both ADF and DD. The development is in an urban area and the daylight and sunlight analysis shows that the amenity afforded to future occupants is in line with and indeed exceeds expectations for developments of this type and concludes that the flats would receive appropriate natural light when assessed against the Guidelines.
Internal height
7.61 All flats would have a minimum internal floor to ceiling height of 2.5 metres in line with London Plan Housing Supplementary Planning Guidance.
Inclusive design
7.62 All flats would be accessible as there would be level access and lifts to all floors, with 90% meeting Building Regulations requirement M4(2) ‘accessible and adaptable dwellings’. The remaining 10% would meet Building Regulation requirement M4(3) ‘wheelchair use dwellings’ which are designed to be wheelchair accessible or easily adoptable for residents who are wheelchair users from the start. All flats proposed as wheelchair user dwellings would be on a single level.
Noise
7.63 As the proposed dwellings would be adjacent to the Metro Industrial Centre and above the new employment units, a noise assessment report is submitted with the application to ensure acceptable living conditions.
7.64 The submitted noise assessment confirms that the site falls into the medium category during the night and the low category during the day and the main noise source would be aircraft noise. The Council policy is to meet the requirements of BS8233 on the basis of WHO guidelines. In this case, the noise levels are considered to be significantly above day and night threshold and both would require mitigation against worst case scenarios.
7.65 To protect the future occupiers from aircraft and nearby commercial uses, details of necessary mitigation measures would be conditioned (21, 22).
Air Quality
7.66 The Council’s Air Quality Action Plan (AQAP) designates the whole Borough as an Air Quality Management Area (AQMA), and identifies road transport as the major source of air pollution, giving rise to nitrogen dioxide and particulate matter which can cause respiratory illnesses and other adverse health effects.
7.67 Policy EQ4 of the Local Plan requires an air quality assessment where major developments or change of use to air quality sensitive uses are proposed. It requires developments to incorporate mitigation measures where air quality assessments show that developments could cause or exacerbate air pollution, or be exposed to air pollution. The London Plan includes similar provisions particularly where people vulnerable to poor air quality, such as old people and children would be affected.
7.68 An Air Quality Assessment has been submitted in the application. It concludes, based on local authority monitoring and the London Air Background maps that pollution levels at the site are expected to be acceptable provided that mitigation measures stated in the report are implemented. There would be a condition (23) to require this.
Parking, servicing and access
7.69 Local Plan Policy EC2 seeks to promote a more sustainable local travel network and maximise opportunities for walking, cycling and using public transport. Developments should provide at least a minimum number of cycle spaces and an appropriate maximum number of car spaces consistent with London Plan standards.
7.70 The proposal would not provide car parking other than accessible spaces and would be an essentially car-free development. Whilst the site is within a moderately accessible location, it is within three minute walk of Isleworth station and of several bus routes to Hounslow and Brentford Town Centres. Furthermore, future occupiers would be restricted by s106 from obtaining residents’ parking permits. In addition the main incentive would be the scheme’s travel plan which would be also secured via S106 to encourage sustainable transport choices by future residents.
Parking
7.71 The application proposes five disabled persons’ parking bays, the number is considered acceptable. The transport statement states that 20% of proposed parking spaces shall be for electric vehicles with the remaining spaces accommodating passive provision. However, details of electric vehicle charging provisions would be secured by condition (12).
Highway Layout
7.72 The proposed highway layout is considered suitable in principle as it would improve safety for pedestrians and the visual quality of the area. The arrangement would provide a raised table between the south and north plots, providing a safe crossing point for pedestrians.
7.73 The Transport Statement states that only nine servicing vehicles are expected
daily. Suitable restrictions or management arrangements would be established at the site to ensure that the loading bay would not be misused. Further details would be secured in the Delivery and Servicing Plan condition (13).
Proposed ground floor layout
7.74 There is a footway provided through the industrial estate to the east of the site. This continues past Coombe House and provides a formal pedestrian route towards Thornbury park. The approved 1A-5 St Johns Road development would provide a footway along the north side of Rennels Way which would further enhance pedestrian connections through the site to the wider industrial estate.
7.75 The proposed site layout does not include any tactile paving provision. This is needed for all pedestrian crossing points and a condition (7) can ensure this is done before occupation of the development.
Cycle provision
7.76 The application proposes that the commercial accommodation would be constructed as ‘shell and core’ without detailed fit out, with long-stay cycle parking to be provided later by the occupants. As proposed the current scheme would be in line with the London Plan and its guidelines. Further details for cycle parking would be conditioned (11) to ensure this compliance with the end user.
7.77 To ensure adequate pedestrian safety a Road Safety Audit would be required by condition (7).
Travel Plan
7.78 The proposed travel plan and the associated methods are considered acceptable. Details of the Site Travel Plan Coordinator (TPC) would be provided to the Council once appointed. The method of undertaking travel survey and plan implementation of the proposed action measures should be agreed with the Council once the site occupiers are known. In addition, a full
Workplace Travel Plan would be provided by the occupants of each commercial units. The Travel Plans would be secured as a S106 obligation.
Construction Logistics Plan
7.79 The submitted Construction Logistics Plan (CLP) is considered suitable in principle. However, because a contractor is yet to be appointed, the CLP would have to be reviewed and developed by the contractor, once appointed. An updated CLP therefore would be secured by pre-commencement condition (8).
Sustainability
7.77 London Plan Policy 5.2 seeks to ensure reduction in CO2 emissions. Local Plan policy EQ1 supports this and seeks to minimise the demand for energy and to promote renewable and low-carbon technologies. Local Plan policy EQ2 seeks to promote the highest standards of sustainable design and construction in development to mitigate and adapt to climate change. The Local Plan seeks to ensure that refurbishments meet a BREEAM rating of ‘Excellent’.
7.78 Sustainability underpins many London Plan and Local Plan policies. These require development to minimise waste, include energy efficiency measures, promote the use of renewable energy, and not significantly increase the requirement for water supply or surface water drainage.
7.79 As a comprehensive redevelopment of the site, the proposal can make a substantial contribution to sustainable development in the Borough and it is important that it recognises and adopts sustainable development principles.
7.80 London Plan Policy 5.2 (Minimising carbon dioxide emissions) requires developments to make the fullest practicable contribution to minimising CO2
emissions following this energy hierarchy:
Be Lean: use less energy Be Clean: supply energy efficiently Be Green: use renewable energy
7.81 It continues that major development proposals should include a detailed energy assessment to show how the carbon reduction dioxide emissions targets it outlines are to be met within the framework of the energy hierarchy. It states that where it is clearly shown that the specific targets cannot be fully achieved on-site, the shortfall may be met off-site or through a ‘cash in lieu’ contribution to the Borough, to be ring-fenced to secure the delivery of carbon dioxide savings elsewhere.
7.82 In addition, the Mayor aims to ensure that major developments reduce carbon dioxide emissions from buildings, by reaching higher than the Target Emission Rate (TER) outlined in the national Buildings Regulations, leading to zero carbon residential buildings from 2016.
7.83 Policy EQ1 supports these objectives.
7.84 The applicant has submitted an Energy and Sustainability Statement. It sets out how the development would achieve the CO2 emissions target required and meet the other sustainability criteria set out in these policies.
7.85 The proposal would achieve on-site emissions 35%below Building Regulation requirements (Part L 2013).
7.86 A BREEAM ‘Excellent’ rating can be achieved in respect of the construction of the commercial units in line with the policy, to be secured by condition (19).
Environmental Considerations
Contaminated land
7.80 Owing to the history of uses the site is highly likely to be contaminated. The NPPF advises where evidence suggests there may be some contamination, planning permission may be granted subject to condition that development may not start before site investigation and assessment have been done and that the development itself will incorporate any remedial measures necessary.
7.81 Policy 5.21 (Contaminated Land) of the London Plan and Local Plan Policy EQ8 (Contamination) reflect this. The applicant submitted a Phase 1 Desk Study which is satisfactory; however there would be a further condition (4) to ensure that the development can be implemented and occupied with adequate regard for public and environmental safety.
Flooding and drainage
7.82 There would be conditions to ensure the surface water management is in line with current planning policy and guidance requirements.
Ecology
7.83 The NPPF states that the planning system should contribute to and enhance the natural and local environment by:a) Protecting and enhancing valued landscapes, geological conservation
interests and soils;b) Recognising the wider benefits of ecosystem services;c) Minimising impacts on biodiversity and providing net gains in
biodiversity,where possible contributing to the Government’s commitment to halt the overall decline in biodiversity, including by establishing coherent ecological networks that are more resilient to current and future pressures;”
7.84 London Plan Policy 7.19 (Biodiversity and access to nature) states that “development proposals should wherever possible make a positive contribution to the protection, enhancement, creation and management of biodiversity” and Local Plan Policy GB7 (Biodiversity) applies this in a local context.
Ground Floor Landscaping Plan
7.85 The nature and location of the site limits its ecological value. However, the submission includes detailed public realm strategy and landscaping plans for the ground floor and terraces showing the enhanced streetscape and quality of amenity spaces. There would be a planning condition (9) to ensure the implementation of these details.
Noise
7.86 The noise from the proposed uses would not harm neighbours’ living conditions (B1 uses are, by definition ones that would not be unacceptably noisy). Construction noise would be mitigated by a condition (5). Legal Agreement (s106)
7.87 Local Plan Policy IMP3 seeks to ensure that development proposals fully mitigate the impacts of development on the area through a Section 106 agreement, where necessary or appropriate, having regard to supplementary planning document and that they provide the Community Infrastructure Levy (CIL) payments required by any charging schedule, including the Mayor of London’s CIL. A payment or other benefit offered in a Section 106 agreement is not material to a decision to grant planning permission and cannot be required unless it complies with the provisions of the Community Infrastructure Levy Regulations 2010 (regulation 122), which provide that the planning obligation must be:
necessary to make the development acceptable in planning terms
directly related to the development; and
fairly and reasonably related in scale and kind to the development.
7.88 The National Planning Policy Guidance (NPPG) provides guidance on use of planning obligations, which may impose a restriction or requirement, or provide for payment to make acceptable development proposals that might otherwise not be acceptable in planning terms. The Council’s Supplementary Planning Document on Planning Obligations (adopted March 2008) contains guidance on imposition of planning obligations in compliance with such guidance. These obligations may offset shortfalls in the scheme or mitigate a development’s impacts.
7.87 The following draft Heads of Terms are likely to form the basis of the Section
106 agreement, all of which are considered to satisfy three Regulation 122 tests referred to above:
i) On-site affordable housing provision of 16 London Affordable Rent (LAR) units (South Building)
Initial review (ensuring start on site)
Outturn review due to less than policy 40% AH. This will not be triggered if units are flipped to AH before project completion.
ii) £20K Contribution for Access Improvements to Thornbury Parkiii) Restriction on parking permits prior to occupationiv) Travel Plan for both residential and commercial elements prior to
occupationv) Considerate Contractors Scheme
It is appropriate that the developer registers with the Considerate Contractors Scheme. All sites registered with the Scheme are monitored by an experienced industry professional to assess their performance against the eight point Code of Considerate Practice which includes the categories Considerate, Environment, Cleanliness, Good Neighbour, Respectful, Safe, Responsible and Accountable.
vi) Construction trainingIn accordance with the Council’s Planning Obligations & CIL SPD either in-house or £35,750 contribution.
8.0 EQUALITIES DUTIES IMPLICATIONS
8.1 In response to its Equalities Duties and the Equality Act 2010 it is considered that there are no relevant implications that the Council needs to assess further in this case and that, in determining this application, the Council has complied with its duties.
9.0 COMMUNITY INFRASTRUCTURE LEVY
9.1 Some new developments granted planning permission will be liable to pay Community Infrastructure Levy (CIL) to the Mayor of London and Hounslow.
Existing lawful floor space
Demolished floor space
CIL liable floor spaceFloor space
(sqm)709 709 3,999
9.2 The proposal would be subject to the CIL charge for 3,999 square metres (existing area to be demolished 709, proposed area 4,708 including 653 for commercial floor space). £239,940 for the Mayor and £381,120 for Hounslow. However, the social housing floor space would be excluded from this amount.
10.0 RECOMMENDATION: APPROVAL with legal agreement
1. That planning permission be granted subject to the following conditions (subject to any minor variation of condition wording) and securing the above mentioned planning obligations by the prior completion of a satisfactory legal agreement or unilateral undertaking made under Section 106 of the Town and Country Planning Act 1990 and or other appropriate legislation, the exact terms of which shall be negotiated by appropriate officers within the Housing, Planning and Communities Department on the advice of the Assistant Director Corporate Governance.
2. The satisfactory legal agreement or unilateral undertaking outlined above shall be completed and planning permission issued by 04/02/2020 or such extended period as may be agreed in writing by appropriate officers within the Housing, Planning and Communities Department or within Legal Services.
3. If the legal agreement or unilateral undertaking is not completed by the date specified above (or any agreed extended period), then the Chief Planning Officer or Head of Development Management is hereby authorised to refuse planning permission for the reason that the proposal should include planning obligations required to make the development acceptable in planning terms in accordance with Regulation 122 of the Community Infrastructure Levy Regulations 2010, development plan policies and the Planning Obligations SPD, as described in this Report.
4. Following the grant of planning permission, where (a) requested to enter into a deed of variation or legal agreement in connection with the planning permission hereby approved and by the person(s) bound by the legal agreement authorised in paragraph 1 above, and (b) where the planning obligations are not materially affected, and (c) there is no monetary cost to the Council, , the Chief Planning Officer or Head of Development Management is hereby authorised (in consultation with the Chair of the Planning Committee and upon the advice of the Assistant Director Corporate Governance) to enter into a legal agreement(s) (deed of variation) made under Sections 106 and/or 106A of the Town and Country Planning Act 1990 and or other appropriate legislation.
5. If planning permission is refused, the Chief Planning Officer or Head of Development Management (in consultation with the Chair of the Planning Committee) is hereby authorised to approve any further application for planning permission validated within 12 months of the date of refusal of planning permission, provided that it (a) duplicates the planning application, and (b) that there has not been any material change in circumstances in the relevant planning considerations, and (c) that a satisfactory legal agreement or unilateral undertaking securing the obligations set out in the Report is completed within any specified period of time.
Conditions:
1 A1A Time LimitThe development hereby permitted shall be begun before the expiration of three years from the date of this permission.Reason: To accord with the provisions of Section 92(1) of the Town and Country Planning Act 1990.
2 B5 Detailed Applications The proposed development shall be carried out in all respects in accordance with the proposals contained in the application and the plans submitted therewith (279-P-000; 279-P-001 Rev B; 279-P-010 Rev A; 279-P-100 Rev D; 279-P-101 Rev E; 279-P-102 Rev D; 279-P-103 Rev D; 279-P-104 Rev D; 279-P-105 Rev D; 279-P-106 Rev D; 279-P-107 Rev D; 279-P-108 Rev D; 279-P-110 Rev B; 279-P-111 Rev B; 279-P-112 Rev B; 279-P-113 Rev B; 279-P-114 Rev B; 279-P-115 Rev B; 279-P-116 Rev B; 279-P-120 Rev B; 279-P-121 Rev B; 279-P-122 Rev B; 279-P-123 Rev B; 279-P-124 Rev B; 279-P-125 Rev B; 279-P-126 Rev B; 279-P-127 Rev B; 279-P-200 Rev D; 279-P-201 Rev D; 279-P-202 Rev D; 279-P-203 Rev D; 279-P-205 Rev D; 279-P-210 Rev D; 279-P-211 Rev D; 279-P-212 Rev D; 279-P-213 Rev D; 279-P-215 Rev D; 279-P-220 Rev A; 279-P-221 Rev A; 279-P-222; 279-P-223; 279-P-224; 279-P-225; 279-P-226; 279-P-230; 279-P-231; 279-P-300 Rev A; 279-P-301 Rev A; 279-P-310 Rev A; 279-P-311 Rev A; 279-P-312 Rev A; 279-P-500; 279-P-501; 279-P-502; 279-P-503; 279-P-510; 279-P-511; 279-P-512; 279-P-513; 279-P-514; 279-P-515; 279-P-516; 279-P-517; 279-P-518; 279-P-900 Rev B; 279-P-910 Rev C; Design and Access Statement; Unit Mix & Amenity Requirements; Accommodation Schedule; Daylight and Sunlight Report; Preliminary Bat Roost Assessment; Drainage Strategy; Air Quality Assessment; Noise Impact Assessment; Preliminary Ecological Appraisal; Phase 1 Environmental Assessment; Planning Statement; Sustainability and Energy Statement; Public Realm Strategy; TOWN701(08)5001; TOWN701(08)5002; Transport Statement; Viability Assessment; Received 25/04/2019; CGIs; Received 17/05/2019; 279-P-902B; Received 19/05/2019; Transport Technical Note; Received 09/06/2019; Updated Viability Assessment; Received 21/06/2019.) and approved by the Local Planning Authority, or as shall have been otherwise agreed in writing by the Local Planning Authority before the building is used. Reason: To ensure the development is carried out in accordance with the planning permission.
3 B4 Materials – Samples Prior to the completion of substructure, samples of the materials to be used in the construction of the external surfaces of the development hereby permitted shall be submitted to and approved in writing by the local planning authority. Development shall be carried out in accordance with the approved details.Reason: In order that the Council may be satisfied as to the details of the development in the interests of the visual amenity of the area and to satisfy the requirements of Policy CC1 (Context and Character).
4 ContaminationBefore the development hereby permitted commences:
a. Details of further intrusive site investigation are required in addition to the phase 1 desk study previously submitted. These details shall be submitted to, and approved in writing by, the Local Planning Authority. The site shall be investigated by a competent person to identify the extent and nature of contamination. The report shall include a tiered risk assessment of the contamination based on the proposed end use of the site. Additional investigation may be required where it is deemed necessary.
b. A scheme for decontamination of the site shall be submitted to the Local Planning Authority, for written approval. The scheme shall account for any comments made by the Local Planning Authority before the development hereby permitted is first occupied.
During the course of the development:
c. The Local Planning Authority shall be notified immediately if additional contamination is discovered during the course of the development. A competent person shall assess the additional contamination, and shall submit appropriate amendments to the scheme for decontamination in writing to the Local Planning Authority for approval before any work on that aspect of development continues.
Before the development is first brought into use:
d. The agreed scheme for decontamination referred to in clauses b) and c) above, including amendments, shall be fully implemented and a written validation (closure) report submitted to the Local Planning Authority for approval.
Reason: Contamination is known or suspected on the site due to a former land use. The LPA therefore wishes to ensure that the development can be implemented and occupied with adequate regard for public and environmental safety.
Supporting notes:
a. An initial phase 1 desk study has been submitted with the original application and is considered satisfactory. A phase 2 intrusive investigation has been submitted but it did not fully describe the conditions on the site and further investigation is needed. The further investigation to be submitted will include investigation into outstanding contamination issues to be communicated by the local planning authority and allow the development of a site Conceptual Model (CM), which identifies all potential pollutant linkages on the site. Risk assessments must adhere to current UK guidance and best practice.
b. The scheme for decontamination shall provide details of how each potential pollutant linkage, as identified in the conceptual model, will be made safe.
c. In some instances the LPA may require work on site to be ceased whilst the nature of additional contamination is investigated fully.
d. The validation report shall revisit the site conceptual model, and provide evidence that each aspect of the decontamination scheme was carried out correctly and successfully. This report shall prove that the development is suitable for its new use.
e. We request that site investigation reports or site plans be sent electronically to [email protected] or by post on a cd or dvd wherever possible.
5 C29 Hours of constructionNo construction work shall take place on the site except between the hours of 8am to 6pm on Mondays to Friday and 9am to 1pm on Saturdays and none shall take place on Sundays and Public Holidays without the prior agreement of the Local Planning Authority.Reason: To protect neighbours’ living conditions in accordance with adopted Local Plan Policy EQ5.
Notwithstanding the terms of the Town and Country Planning (General Permitted Development) (England) order 2015 and any successor legislation, the commercial units hereby approved shall be used only for business (B1 use class only) and for no other purposes without further approval from the Local Planning Authority obtained throught the submission of a planning application.
Reason: The Council is satisfied that the use hereby approved would be satisfactory but would wish to control future changes of use within the same Class to ensure no harm to nearby properties or conditions on the local highway.
7 Highway works prior to occupationBefore the development hereby permitted is first occupied or brought into use, the details of the highway works, supported by a Stage 2 Road Safety Audit (including the details of the raised table, loading pad, raised footways, dropped kerbs, and tactile paving) shall be submitted and approved in writing by the local planning authority. The approved details shall be implemented on site prior to the occupation of any part of the development.Reason: To confine vehicular access to the permitted points in order to ensure that the development does not prejudice the free flow of traffic or highway safety along the adjacent highway and to enhance the pedestrian environment; in accordance with Local Plan policies EC1 & EC2.
8 Construction Logistics PlanNo development shall take place, including any works of demolition, until a Construction Logistics Plan that conforms to current TfL guidance has been submitted to, and approved in writing by, the local planning authority. The approved Plan shall be adhered to throughout the construction period. The Plan shall include: i. a site plan (showing the areas set out below) ii. confirmation that a pre-start record of site conditions on the adjoining public highway will be undertaken with Hounslow Highways and a commitment to repair any damage caused by construction activity iii. provision for the parking of vehicles of site operatives and visitors iv. provisions for loading, unloading and storage of plant and materials within the site v. details of access to the site, including means to control and manage access and egress of vehicles to and from the site for the duration of construction including phasing arrangements vi. details of vehicle routeing from the site to the wider strategic road network vii. the erection and maintenance of security hoarding including decorative displays and facilities for public viewing, where appropriate
viii. provision of wheel washing facilities at the site exit and a commitment to sweep adjacent roads when required and at the request of the council ix. a scheme for recycling/disposing of waste resulting from demolition and construction works x. measures to ensure the safety of all users of the public highway especially cyclists and pedestrians in the vicinity of the site and especially at the access xi. commitment to liaise with other contractors in the vicinity of the site to maximise the potential for consolidation and to minimise traffic impacts. xii. avoidance of peak hours for deliveries and details of a booking system to avoid vehicles waiting on the public highway xiii. all necessary traffic orders and other permissions required to allow safe access to the site to be secured and implemented prior to commencement of construction xiv. details of the construction programme and a schedule of traffic movements xv. the use of operators that are members of TfL’s Freight Operator Recognition Scheme (FORS) Reason: To ensure highway safety is maintained and preserved in accordance with Policy EC2 of the Local Plan.
9 Landscape design proposalsPrior to the occupation, full details of soft landscape works shall have been submitted to and approved in writing by the local planning authority and these works shall be carried out as approved. These details shall include: planting plans; written specifications (including cultivation and other operations associated with plant and grass establishment); schedules of plants, noting species, plant sizes and proposed numbers/densities where appropriate; implementation programme and maintenance schedule. Any such planting which within a period of five years of implementation of the landscaping dies, is removed, or become seriously damaged or diseased shall be replaced in the next planting season with others of a similar size or species. The approved scheme shall be fully implemented prior to the first use of the building and the maintenance schedule adhered to thereafter. Reason: In the interest of biodiversity, sustainability, and to ensure that a satisfactory standard of visual amenity is provided and maintained in accordance with policies CC1 Context and character and CC2 Urban design and architecture of the adopted Local Plan.
10 Parking Management PlanPrior to the first use of the buildings hereby permitted, a Car Park Management Plan shall be submitted to and approved in writing by the Local Planning Authority that sets out how the site will be managed. The buildings shall thereafter operate in accordance with the approved details. Reason: In order that the Local Planning Authority may be satisfied as
to the details of the development and to ensure that parking spaces are available in accordance with Policy 6.13 of London Plan and policies CC1 (Context and Character), CC2 (Urban Design and Architecture) and EC2 (Car and Cycle Parking and Servicing Facilities for Developments) of the Local Plan.
11 Cycle Parking details Prior to the occupation of each part of the buildings hereby approved, the details of cycle parking facilities for the flats and commercial uses in the respective parts of the buildings shall be submitted and approved in writing by the local planning authority. The approved drawings shall be implemented prior to occupation and permanently retained thereafter. Reason: To ensure adequate cycle parking is available on site and to promote sustainable modes of transport in accordance with the London Plan Policy 6.9 and Local Plan Policy EC2.
12 EV charging baysBefore the development commences above first floor level, details of electric vehicle charging bays shall be submitted to and approved by the Local Planning Authority to confirm that 20% of the bays will be provided with an active provision and the submission shall also include a detailed specification for the passive provision to show how it will be installed and can be commissioned in future as required. The details shall be implemented as approved drawings and be provided and made available for use before first occupation of any part of the development.Reason: In order that the Local Planning Authority may be satisfied as to the details of the development and to ensure that parking spaces are available in accordance with Policy 6.13 of London Plan and policies CC1 (Context and Character), CC2 (Urban Design and Architecture) and EC2 (Car and Cycle Parking and Servicing Facilities for Developments) of the Local Plan.
13 Delivery and Servicing Plan Prior to first occupation, a Delivery and Servicing Plan (for both uses) shall have been submitted to and approved in writing by the Local Planning Authority. The details shall accord with current guidance such as that issued by Transport for London and shall show that peak times are avoided for deliveries and servicing and that articulated vehicles are not used. The Plan shall be carried out as approved. The approved measures shall be implemented before the first occupation of the development hereby permitted and shall be so maintained for the life of the development.Reason: In the interests of the safety of pedestrians and vehicles, to protect neighbours’ living conditions and to support sustainable transport objectives in accordance with adopted local plan Policy EC2.
14 The waste and recycled materials storage arrangements shown on the approved drawings shall be completed before any part of the accommodation hereby permitted is occupied.
Reason: To ensure that refuse can be properly stored and removed from the site as soon as the proposed use of these premises commences in accordance with policies CC1 Context and character, CC2 Urban design and architecture, EQ7 Sustainable waste management and WLWP (Recycling Facilities in New Developments) of the adopted Local Plan.
15 Energy Strategy
The development hereby permitted shall not commence until a finalised Energy Strategy (demonstrating how the targets for carbon dioxide emissions reduction are to be met in line with the Mayor's energy hierarchy) has been submitted to and approved in writing by the Local planning Authority.
The development shall be implemented in accordance with the approved Energy Strategy and shall not commence above ground until full Design Stage calculations under the Standard Assessment Procedure/National Calculation Method) have been submitted to and approved in writing by the Local planning Authority to show that the development will be constructed in accordance with the approved Energy Strategy, and any subsequent approved revisions.
Prior to the first occupation of each building hereby approved, evidence (e.g. photographs, installation contracts and As-Built certificates under the Standard Assessment Procedure/National Calculation Method) shall be submitted to and approved by the Local Planning Authority to show that the development has been constructed in accordance with the approved Energy Strategy, and any subsequent approved revisions.
Reason: To ensure that the development makes the fullest contribution to minimising carbon dioxide emissions in accordance with London Plan Policy 5.2 and the London Borough of Hounslow Local Plan Policy EQ1.
16 BREEAM
(A). Within six months of works starting on site, a BREEAM Shell and Core Design Stage certificate and summary score sheet (or such equivalent standard that replaces this) must be submitted to and approved by the Local Planning Authority to show that an 'Excellent' (minimum score 70%) rating has been achieved.
B). Prior to the practical completion of the commercial floorspace hereby approved, a BREEAM Shell and Core Post- Construction Review certificate and summary score sheet (or such equivalent standard that replaces this) must be submitted to and approved by the Local Planning Authority to show that an 'Excellent' (minimum score 70%) rating has been achieved.
(C). Prior to commencement of the fit-out of the commercial floorspace a
BREEAM Refurbishment and Fit-Out (Parts 3&4) Design Stage certificate and summary score sheet (or such equivalent standard that replaces this) must be submitted to and approved by the Local Planning Authority to show that an 'Excellent' (minimum score 70%) rating has been achieved.
(D). Within 6 months of occupation of the commercial floorspace a BREEAM Refurbishment and Fit-Out (Parts 3&4) Post- Construction Review certificate and summary score sheet (or such equivalent standard that replaces this) must be submitted to and approved by the Local Planning Authority to show that an 'Excellent' (minimum score 70%) rating has been achieved.
Reason: To ensure a sustainable form of development in accordance with Local Plan policy EQ2.
17 Water usage
Prior to the first occupation of flats hereby approved, evidence (schedule of fittings and manufactures literature) shall be submitted to and approved by the Local Planning Authority to demonstrate that the development would achieve the internal 105 litres per person per year target.
Reason: In order to protect and conserve water supplies and resources in accordance with Local Plan policy EQ2 and London Plan policy 5.15 and the Local Plan policy EQ2.
18 Sustainable materials
The development shall not be occupied until evidence (e.g. photographs and copies of installation contracts) has been submitted to the Local Planning Authority to demonstrate that the development has been carried out in accordance with the approved sustainable sourcing of materials requirements.
- At least three of the key elements of the building envelope (external walls, windows roof, upper floor slabs, internal walls, floor finishes/coverings) are to achieve a rating of A+ to D in the Building Research Establishment (BRE) The Green Guide of specification.
- At least 50% of timber and timber products are to be sourced from accredited Forest Stewardship Council (FSC) or Programme for the Endorsement of Forestry Certification (PEFC) scheme.
- No construction or insulation materials are to be used which will release toxins into the internal and external environment, including those that deplete stratospheric ozone.
Reason: In order to ensure the sustainable sourcing of materials in accordance with the London Plan policy 5.3 and the Mayor of London's Sustainable Design and Construction SPG.
19 Thames Water
No piling shall take place until a piling method statement (detailing the depth and type of piling to be undertaken and the methodology by which such piling will be carried out, including measures to prevent and minimise the potential for damage to subsurface sewerage infrastructure, and the programme for the works) has been submitted to and approved in writing by the local planning authority in consultation with Thames Water. Any piling must be undertaken in accordance with the terms of the approved piling method statement.
Reason: The proposed works will be in close proximity to underground sewerage utility infrastructure. Piling has the potential to impact on local underground sewerage utility infrastructure. Please read our guide ‘working near our assets’ to ensure your workings will be in line with the necessary processes you need to follow if you’re considering working above or near our pipes or other structures.https://developers.thameswater.co.uk/Developing-a-large-site/Planning-your-development/Working-near-or-diverting-our-pipes. Should you require further information please contact Thames Water. Email: [email protected] Phone: 0800 009 3921 (Monday to Friday, 8am to 5pm) Write to: Thames Water Developer Services, Clearwater Court, Vastern Road, Reading, Berkshire RG1 8DB
20 Secure by Design
The development shall achieve 'Secured by Design' accreditation awarded by the Design Out Crime Officer Metropolitan Police Service Continuous Policing Improvement Command on behalf of the Association of Chief Police Officers (ACPO). No dwelling shall be occupied until accreditation has been achieved and evidence of such accreditation has been submitted to and approved in writing by the Local Planning Authority.
Reason: In pursuance of the Council's duty under section 17 of the Crime and Disorder Act 1998 to consider crime and disorder implications in excising its planning functions; to promote the well-being of the area in pursuance of the Council's powers under section 2 of the Local Government Act 2000, to reflect the guidance contained in the Council's SPG on Community Safety By Design and to ensure the development provides a safe and secure environment in accordance with London Plan (July 2011) Policies 7.1 and 7.3.
21 Noise 1
No occupation of units shall take place until details of a sound mitigation scheme designed to protect the future occupants (including sensitive internal spaces and external amenity areas) of the proposed development from noise emitted from aircraft and nearby sources has been submitted to the Local Planning Authority and approved in writing prior. The glazing and ventilation requirements shall be based on the Noise Impact Assessment by Cole Jarman ref: 19/0043/R1 with further details provided regarding the control of overheating within the
apartments. The details so approved shall be implemented before occupation.
Reason: In order to ensure that the future occupants of the units do not suffer an unreasonable level of noise and disturbance and to accord with Local Plan Policy EQ5.
22 Noise 2
Noise from fixed plant shall not at any time exceed levels more than 10 dB below background (L90) levels at the source of the plant. Noise levels shall be assessed by measurement or calculation based on the guidance presented within BS4142: 2014 or subsequent versions of this guidance.
Reason: In order to ensure that the future occupants of the units do not suffer an unreasonable level of noise and disturbance and to accord with Local Plan Policy EQ5.
23 Air Quality
The development hereby permitted shall follow the mitigation measures and recommendations in the Air Quality Assessment; received on 25 April 2019.
Reason: In the interests of sustainability in accordance with LocalPlan policy EQ4 (Air Quality).
24 Sustainable Drainage
Prior to commencement of the development hereby permitted (excluding demolition and site clearance), details of sustainable drainage measures/surface water run-off attenuation measures shall be submitted to and approved in writing by the Local Planning Authority. The submitted details shall: a) provide information about the design storm period and intensity, the method employed to delay and control surface water discharged from the site and measures taken to prevent pollution of the receiving groundwater and/or surface waters; b) include a timetable for its implementation; and, c) provide a management and maintenance plan for the lifetime of the development. The development shall only be carried out strictly in accordance with the approved details.
Reason: To prevent the risk of flooding to and from the site in accordance with relevant policy requirements including but not limited to London Plan Policy 5.13, its associated Sustainable Design and Construction SPG, the Non-Statutory Technical Standards for Sustainable Drainage Systems and Hounslow Council's Local Plan Policy EQ3.
25 SUDS Evidence
No building hereby permitted shall be occupied until evidence (photographs and installation contracts) is submitted to demonstrate that the sustainable drainage scheme for the site has been completed in accordance with the submitted details. The sustainable drainage scheme shall be managed and maintained thereafter in accordance with the agreed management and maintenance plan.
Reason: To comply with the Non-Statutory Technical Standards for Sustainable Drainage Systems, the National Planning Policy Framework (Paragraph 103), the London Plan (Policies 5.12 and 5.13) along with associated guidance to these policies and Hounslow Council's Local Plan Policy EQ3.
Informatives:
1 To assist applicants, the London Borough of Hounslow has produced planning policies and written guidance, which are available on the Council’s website. The Council also offers a pre-application advice service. In this case, the Council’s suggested improvements were adopted by the applicant.
2 We collect the Mayor of London’s Community Infrastructure Levy (CIL) at the rate of £60 per square metre of new floor space. Hounslow’s Community Infrastructure Levy (CIL) has been adopted. For details of the rates please refer to our web page:http://www.hounslow.gov.uk/community_infrastructure_levy_preliminary_draft_charging_schedule_march_2013.pdfThis development is liable for CIL. A Liability Notice will follow shortly. For further information please contact the CIL team on 0208583 4898/4895 or view our web page.
http://www.planningportal.gov.uk/wps/portal3 Thames Water will aim to provide customers with a minimum pressure of
10m head (approx 1 bar) and a flow rate of 9 litres/minute at the point where it leaves Thames Waters pipes. The developer should take account of this minimum pressure in the design of the proposed development.
4 A Groundwater Risk Management Permit from Thames Water will be required for discharging groundwater into a public sewer. Any discharge made without a permit is deemed illegal and may result in prosecution under the provisions of the Water Industry Act 1991. We would expect the developer to demonstrate what measures he will undertake to minimise groundwater discharges into the public sewer. Permit enquiries should be directed to Thames Water’s Risk Management Team by telephoning 02035779483 or by emailing [email protected]. Application forms should be completed on line via www.thameswater.co.uk/wastewaterquality.
