PLANNING COMMITTEE 22nd June 2017...parking spaces would be at basement level, with a further 35 parking spaces at street level. 4.11 The car parking is at a ratio of less that 1:1

PLANNING COMMITTEE 22nd June 2017

[email protected]

References: P/2016/0717 00707/E/P110

Address: Park Road Allotments, Park Road, Isleworth, London

Proposal: Erection of eight blocks of three- and four- storey buildings to create 119 flats and eight houses with car parking at basement and street level and associated works.

This application is being taken to Planning Committee as a Major scheme with a Legal Agreement.

1.0 SUMMARY

1.1 The proposal is for the development of the allotment site at Park Road for housing. The proposed development comprises removal of the existing small garden shed structures associated with the current use of the site as allotments and erection of 127 dwellings, consisting of a mix of houses and flats, with parking, landscaping and other associated works.

1.2 The development would comprise Private Rented Sector (PRS) housing, to be retained in the long-term ownership and management of Northumberland Estates.

1.3 The scheme is considered to be a high design quality that would be well suited to the site and surroundings. The proposal offers a series of heritage benefits to Syon House which would carry significant weight in planning terms and the public benefit would outweigh the loss of Local Open Space. The revenue generated by the development would enable the conservation and refurbishment of the Grade I listed Syon House to be carried out. These works would be significant and would serve to restore part of this nationally important Grade I listed building.

1.4 The application is recommended for approval subject to conditions and the completion of a Section 106 Agreement.

2.0 SITE DESCRIPTION

2.1 The site is occupied by non-statutory allotment gardens. It is a roughly triangular plot, to the south west and outside of Syon Park. It fronts Park Road which forms its north-eastern boundary; its north-western boundary follows Snowy Fielder Waye; and its south-eastern boundary follows the plot lines of the properties on Church Street. The churchyard of All Saints Church abuts the site to the south and to the north-west is Charlotte House Car Home, with West Middlesex University Hospital beyond. Historic Old Isleworth lies to the south, with more modern housing along Snowy Fielder Waye to the north.

2.2 The site is on the opposite side of Park Road to the of Syon Park boundary wall. The Royal Botanic Gardens Kew World Heritage Site lies to the south of Syon Park on the opposite side of the River Thames. While the site lies within this historic setting, the character of Park Road itself has changed over time and is dominated by the modern hospital and housing. There are a number of Grade l, ll, and ll* listed buildings within Syon Park and in the general vicinity of the site.

2.3 The site currently comprises 37 non-statutory allotments which are managed by Northumberland Estates. The existing structures on the site consist of small garden sheds. A number of plots are vacant and many are overgrown such that their boundaries cannot be clearly delineated. There are a number of mature trees surrounding the site and an avenue of mature Lime trees beyond the site boundary that lead to the Church.

2.4 The site is located approximately 1.4 km south of Syon Lane Station. Isleworth Station is approximately 1.6 km to the north-west and Brentford Station is approximately 2.4km to the north-east. Several bus routes run

along Twickenham Road and London Road, providing services to Brentford, White City, Hammersmith, Hounslow and Heathrow.

2.5 There are a number of footpaths and footways surrounding the site, offering easy access to Syon Park and strategic roads, including Twickenham Road and London Road.

2.6 The site is in the Isleworth Riverside Conservation Area. It is designated as Local Open Space. It is also on an Archaeological Priority Zone. The site is close to the Royal Botanic Gardens Kew World Heritage Site Buffer Zone and the boundary of Syon Park, a Grade l listed historic park and garden.

3.0 HISTORY

00707/E/P93 Erection of a 155-bedroom hotel & health spa, covered walkway, glass house, creation of service access from London Road, the reinstatement of the historic landscape at Syon Park including formal and informal landscaping reconfiguration of car parking and garden centre storage areas and demolition of various buildings.

Approved: 08/03/2004

00707/E/P97 Erection of a temporary marquee for five years for daytime and evening private/corporate events from 1st May to 30th September for each year period for 2009, 2010, 2011, 2012, and 2013.


00707/E/P98 Alterations to the approved and substantially completed approved scheme (reference 00707/E/P93) for the erection of a 155-bedroom hotel involving use of the second floor roof loft area of the bedroom wing as guest lounges and a servery kitchen, together with formation of a roof terrace on the single storey conference wing and alterations to room layouts.


00707/E/P99 Construction of a temporary (3 years) single storey garden centre sales building.


00707/E/P100 The refurbishment of existing adventure warehouse and the construction of an outdoor maze.


00707/E/P105 Refurbishment of existing adventure warehouse and construction of an outdoor maze.


00707/E/P106 Change of use of garden to erect a temporary marquee every year for 10 years between 1st May and 30th September for daytime and evening private/ corporate events from 2014 to 2023 Inclusive.


00707/E/P107 Variation of condition 1 of approved planning permission 00707/E/P106 dated 29/07/2013 to read as follows: The permission hereby granted shall be for a limited period of nine years for the erection of the marquee from 1st May to 30th September for each consecutive year and the permission shall expire on 30th September 2023 when the use shall cease and the marquee removed within one week of that date. For 2015 only, the erection of the marquee will be extended to 31st October to cater for seven events relating to the 2015 Rugby World Cup. The site of the marquee shall be made good, levelled and laid to grass no later than one month after its removal for each yearly period.


00707/E/P111 Formation of a new allotment area with associated infrastructure.

On this agenda

4.0 DETAILS

4.1 The proposal is to develop the allotment site at Park Road for residential accommodation. The development would comprise the removal of the existing small garden shed structures associated with the current use as allotments and erection of 127 dwellings, consisting of a mix of houses and flats, with parking, landscaping and other associated works.

4.2 The residential development would comprise Private Rented Sector (PRS) housing, which would be retained in the long-term ownership and management of Northumberland Estates.

4.3 The scheme would incorporate a range of dwelling sizes, from one bedroom units suitable for small households to three bedroom family units. The proposed mix of units is as follows:

Number of Bedrooms Unit Total Percentage

Studio 2 1.57%

One-bedroom 39 30.70%

Two- bedroom 73 57.48%

Three-bedroom 13 10.24%

Total 127 100%

4.4 The residential development would be provided in a number of blocks: Block A, B1, B2, B3, C1, C2, C3, D1, D2 and D3.

4.5 The scheme would include 13 wheelchair accessible units (10%) and all homes would meet Lifetime Homes standard.

4.6 The development would range in height from two to three storeys (with further dormer accommodation in the roof space creating a fourth storey). All of the buildings would have a pitched roof except those that line the central crescent, where green roofs are proposed. The development has been designed to relate carefully to the surrounding area. Smaller scale development is located in the south of the site, closest to Old Isleworth, with the scale increasing towards the north of the site (with the exception of Block A which is two storeys high).

4.7 To the north of the site, Blocks A, B1, B2, B3, C1, C2 and C3 would provide a mix of one-bedroom, two-bedroom and three-bedroom units, with private balconies and shared amenity areas. Blocks D1, D2 and D3 to the south of the site comprise three-bedroom family dwellings (in the form of town houses) with private gardens.

4.8 The density proposed is 309 habitable rooms per hectare (hr/ha) (net) based on 359 habitable rooms across a 1.16 ha site.

4.9 The design is based on a simple and robust palette of high quality materials which reflect the surrounding context, through its use of brick and dark metalwork. The texture and scale of the roof material also reflect the surrounding highly textured materials. The architecture includes arches, crescent, pitched roofs and dormer elements.

4.10 There would be 139 car parking spaces. These would be located at both ground and basement levels, with parking bays along the site access roads, and in two basement car parks, under Blocks B and C. A total of 104 car parking spaces would be at basement level, with a further 35 parking spaces at street level.

4.11 The car parking is at a ratio of less that 1:1 for the apartments and at 2:1 for the townhouses. Of the 139 car parking spaces, 7 (6%) would be dedicated for visitor parking, 16 (11.5%) would be disabled bays and one bay would be allocated specifically for loading purposes. 20% of the parking spaces in the basement would be equipped with electric vehicle charging points. The parking has been design so that the spaces for the apartments are unallocated, with car parking spaces provided at street level to the south of the site dedicated to the town houses.

4.12 The development would also include 217 dedicated cycle spaces comprising a mix of Sheffield stands (50%) and bike lockers (50%). The cycle parking would be at a ratio of one space for the one-bedroom apartments and two for units with more than one bedroom. Additionally, two Sheffield stands, providing four visitor cycle spaces would be located close to the concierge building.

4.13 One new vehicle crossover and two new vehicle accesses are proposed for the development. The crossover to the north of the site would allow access between Snowy Fielder Waye and the substation facilities located next to Block A. The two new access roads would connect the western side of the site to Snowy Fielder Waye. The northern point would provide vehicle access to the site’s northern street-level parking bays, as well as the two basement car parks. The southern point would provide vehicle access to

further street-level parking bays via an on-site roundabout. The existing access on Park Road would be retained to provide vehicle and pedestrian access to the Church.

5.0 CONSULTATIONS

5.1 Neighbouring residents and local action and amenity groups were notified on 08/03/2016. Site and press notices were posted on 18/03/2016. Sixty-seven responses were received.

Comment Response

Objection

Increased traffic, congestion and demand for parking.

See paragraph 7.92 – 7.108.

Loss of local open space. See paragraph 7.9 – 7.14.

Loss of habitat and diversity. See paragraph 7.122 – 7.129.

Increased pressure on services/infrastructure.

The development generates a Community Infrastructure Levy of 1,182,720 for the Borough.

Concerns over the potential for flooding.


Out of scale, overdevelopment. See paragraph 7.22 – 7.56.

Designated an Asset of Community Value.

Not a planning consideration.

Concerns in relation to the financial need.


Concerns in relation to ground contamination.

See paragraph 7.142 -7.149.

Loss of view. Not a planning consideration.

Likely to be an extension of the Isleworth Plague Pit.

No evidence of this.

Harm to the character of the area.


Loss of daylight/sunlight. See paragraph 7.86 – 7.91.

Lack of public consultation. Consultation event undertaken January 2017.

Impact on air pollution. See paragraph 7.150 – 7.156.

Increased overlooking. See paragraph 7.86 – 7.91.

Impact on archaeology. See paragraph 7.159 – 7.164.

Failure to provide costed plans to support the case that development will raise funds for work on Syon House and gardens.

Information contained with Enabling Development Case prepared by Nathaniel Lichfield & Partners dated 1 January 2017.

In support

Accommodation would be of interest to key worker groups.

Noted.

5.2 The following responses were received from local action and amenity groups:

The Isleworth Society (Linked to Planning Application 00707/E/P111)

5.3 “We consider the proposal to build 127 housing units on the existing allotment site would be overdevelopment of a green open space which contributes to the rural nature of this particular area of Old Isleworth, and forms an integral part of the context and character of the Isleworth Riverside Conservation Area. Where there are now allotments, trees, shrubs and grass there will instead be buildings and concrete and the views from Park Road, the properties in Snowy Fielder Waye and from Charlotte House will be completely different.

5.4 The allotment site falls within the Isleworth Riverside Conservation Area, conservation being the operative word. As the main purpose of conservation area designation is to acknowledge the special character of an area, it is therefore vital that the allotments and the open green space on which they stand are retained. To erect buildings on this site would be detrimental to the character of the Isleworth Riverside Conservation Area and would devalue its status as a whole;

5.5 Hounslow’s Local Plan, recently approved by the Planning Inspectorate, does not designate this space for building

5.6 The estate maintain that they have to replace the Park Road Allotment site with housing in order to provide a long term income stream for necessary repair work to Syon House. To justify this proposal then this application and the application for relocating the allotments to within Syon Park (Ref:07707/E/P111) are integral to each other. As such the state should provide a costed schedule of necessary work to Syon House and details of how they propose to ring fence the rent from the new houses on the Park Road site in order to fund this. The National Planning Policy Framework (NPPF) states that harm caused to heritage asset may be outweighed by the public benefits of the proposal; funding a long term repair programme for Syon House and other listed buildings and structures within the grounds may be used as a public benefit and must be taken into account during the planning process. No evidence is given in either application of public benefit.

5.7 The proposed new allotment site will have severe restrictions imposed upon it and prospective allotment holders, which is contrary to the requirements of the NPPF for equivalent or better.

5.8 As to the location proposed, Syon Park is designated as Metropolitan Open Land (MOL). The parkland was designed by Lancelot ‘Capability’ Brown; the Lion Gates were designed by Robert Adam and are Grade 1 listed. These gates were designed as the 18thC entrance to the main carriageway drive. Thus the site proposed is not suitable for allotments, not least in light of the adverse effect on vistas and sight lines both within the estate and from the London Road. This is evidenced in the Landscape and Visual Assessment Report by the many references to the need to minimise and screen the proposed allotment site to reduce impact. The suggested measures will in no way entirely obviate this impact and are insufficient to maintain the openness, setting and visual amenity of the existing MOL.

5.9 On suitability for allotments, it is acknowledged one role of great estates such as Syon was to provide produce. This was usually within kitchen gardens and in less prominent parts of a designed landscape. The walled kitchen garden at Syon was to the north of London Road and subsumed by residential developments in the mid-20thC. The proposed allotment site is within an area historically designed as parkland and intended to support the impression of the status and importance of the landowner, indicated architecturally by the entrance gate. These listed gates and the parkland setting make an important contribution to the estate both in architectural terms and historic value. The development of allotments within this part of

the Historic England registered parkland would very obviously change the character of the landscape and thereby harm the contribution it makes both as part of the park and also as part of the setting to the gate and the house.

5.10 The NPPF states that harm caused to a heritage asset may be outweighed by the public benefits of the proposal Justification of the proposal to relocate the allotments from the Park Road Allotment Gardens to within Syon Estate, requires the estate to provide a costed schedule of necessary work to Syon House with details of how they propose to ring fence the rent from the new houses on the Park Road site in order to fund this. This has not been demonstrated in the application. It is also noted the Northumberland Estate is appealing against LBofH’s decision to grant Asset of Community Value to the existing Park Road site. This raises doubts as to the Northumberland Estate’s future long term intentions in regard to that land.

5.11 In summary, the proposal does not meet the very special circumstances criteria to allow development on MOL nor does it provide sufficient justification that the harm caused to the historic landscape by the development is clearly outweighed by other considerations. It should therefore be refused.”

The Old Isleworth Four Road Residents’ Association

5.12 “We fully support the objection letter submitted by The Isleworth Society.” The Kew Guild

5.13 “The setting aside of land for use as allotments arose from the Inclosure Awards. The passing of the Commons Act of 1876 created a general law relating to this matter. At that time, they were seen as being of recreational benefit, aside from their main purpose of food production.

5.14 In highly urbanized areas, allotments provide space for people to grow their own food, to work with nature and to enjoy the open space around them. In recent years a number of studies, including some by the NHS, have supported the many benefits, both mentally and physically, arising from being close to green areas and enjoying their obvious benefits.

5.15 In our cities and towns such areas of undeveloped land are becoming increasingly rare and it is essential that we make every effort to ensure they remain for the benefit of the local community. They act as reserves for birds and wild life and enable people, even when just passing by to appreciate nature and the part it plays in our local environment.

5.16 I think most people understand the need for more housing, but we must be able to make a distinction between natural areas and

brown field sites. There are still many of these brown field areas in our cities that could be developed, instead of building on allotments.

5.17 The Trustees and I strongly support the community’s work to protect these allotments and to preserve them for future generations.” External Statutory Consultation Responses

5.18 The following external bodies were notified of the application and their response are detailed where these have been received:

Transport for London

5.19 No objection – conditions requested.

Environment Agency

5.20 No objection – No conditions requested.

5.21 Historic England (GLASS)

5.22 No objection - It is for the Council to decide whether a proposal should be considered ‘Enabling Development’. The proposed allotments would cause minor harm to the significance of the Grade l registered park, but this minor harm could be outweighed by public benefits, in this case the securing of long term funding for the repair of the Grade l listed house. The proposed heritage works are necessary for to secure the long term future of the heritage asset; are acceptable in principle; and the costed schedule of repairs are broadly reasonable and representative of the level of work involved.

5.23 Historic England (GLASS)

5.24 No objection – conditions requested.

Natural England

5.25 No objection – conditions requested

6.0 POLICY

Determining applications for full or outline planning permission

6.1 The 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 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 Local Plan documents can be viewed on the Planning Policy pages of the Hounslow website.

6.5 Relevant London Plan Policies

3.3 Increasing Housing Supply

3.4 Optimising Housing Potential

3.5 Quality and Design of Housing Developments

3.6 Children & Young People’s Play & Informal Recreation Facilities

3.8 Housing Choice

3.9 Mixed and Balanced Communities

3.11 Affordable Housing Targets

3.12 Negotiation Affordable Housing on Individual Private Residential and Mixed Use Schemes

3.16 Protection and Enhancement of Social Infrastructure

5.2 Minimising Carbon Dioxide Emissions

5.3 Sustainable Design and Construction

5.6 Decentralised Energy in Development Proposals

5.7 Renewable Energy

5.9 Overheating and Cooling

5.12 Flood Risk Management

5.13 Sustainable Drainage

5.21 Contaminated Land

6.3 Assessing Effects of Development on Transport Capacity

6.9 Cycling

6.12 Road Network Capacity

6.13 Parking

7.4 Local Character

7.5 Public Realm

7.6 Architecture

7.8 Heritage Assets and Archaeology

7.14 Improving Air Quality

7.15 Reducing and Managing Noise, Improving and Enhancing the Acoustic Environment and Promoting Appropriate Soundscapes

7.18 Protecting open space and address deficiency

7.19 Biodiversity and access to nature

7.21 Trees and woodlands

8.2 Planning Obligations

8.3 Community Infrastructure

6.6 Local Plan

SC1 Housing Growth

SC2 Maximising the Provision of Affordable Housing

SC3 Meeting the Need for a Mix of Housing Size and Type

SC4 Scale and Density of New Housing Development

SC5 Ensuring Suitable Internal and External Space

CC1 Context and Character

CC2 Urban Design and Architecture

CC4 Heritage

GB2 Local open space

GB4 The Green Infrastructure Network

GB7 Biodiversity

GB8 Allotments, Agriculture and Local Food Growing

EQ1 Energy and Carbon Reduction

EQ2 Sustainable Design and Construction

EQ3 Flood Risk and Surface Water Management

EQ4 Air Quality

EQ5 Noise

EQ8 Contamination

EC2 Developing a Sustainable Local Transport Network

IMP1 Sustainable Development

7.0 PLANNING ISSUES

The acceptability in principle

7.1 The National Planning Policy Framework (NPPF) sets out the planning policy guidance from central government to be used by all local authorities in England when preparing development plans. A key principle underpinning the NPPF is a presumption in favour of sustainable development, which should be seen as a golden thread running through both plan-making a decision-taking.

7.2 Local Plan Policy IMP1 (Sustainable Development) states that the Council will take a plan-led approach to all growth and development within the borough that is considered to be in accordance with the principles of sustainable development as set out in the NPPF, with a balance of social, environmental and economic dimensions. Loss of allotments

7.3 Local Plan policy GB8 (Allotments, Agriculture and Local Food Growing) states that the Council will encourage continued use of allotments and agriculture land, and promote new, innovative uses of green space for local food growing, including community farming, garden and orchards, and commercial food production. The Council will achieve this by:

Retaining the existing allotments and resisting their loss unless in accordance with the Borough’s Allotment Strategy;

Protecting agricultural land;

Working with partners and local communities to identify sites with potential for local food growing and supporting projects that promote community gardening, farming and orchards; and

Supporting initiatives for commercial food production.

7.4 The Council will expect development proposals to

Be consistent with and positively contribute to the open space and/or nature conservation designation of the land;

Retain allotments and the best and most versatile agriculture land, unless it can be demonstrated that they are no longer required or viable for such purposes. In the event that such land is no longer required, the feasibility of appropriate alternative open space uses which allow the site to maintain its value for growing food such as community gardens or orchards, should be considered first; and

Avoid adverse impacts on adjacent allotments or agricultural land. 7.5 It is proposed to relocate the existing allotments to a new facility within the

grounds of Syon Park, between the Lion Gate and the Serpentine Lake. The site is currently part of open parkland and is used for grazing. The relocation of the allotments is subject to a separate planning application which has been submitted in parallel to this application. As such, the development of the existing allotments would not result in the loss of the allotment facility.

7.6 The new allotment site would have easy vehicle and pedestrian access as it would be accessed via the existing main entrance to Syon Park, on Park Road. The relocated allotments are close to the existing allotments and would therefore be easily accessible on foot to the local community and the community more widely. Parking would be available for allotment holders in the main car park which is close to the relocated allotments and there would also be a dedicated drop off facility. In addition, the proposed allotments would be close to other facilities in the Park, including the Garden Centre. This is a significant improvement upon the existing situation.

7.7 The relocated allotments would provide the same number of plots as the existing, albeit some of them are of a small scale, and would provide a far better quality of facility than currently exists. The new allotments would offer improved facilities for allotment holders, including access to parking and toilets and, importantly, the security of allotment gardens on a sunny site. They would be managed by Northumberland Estates, supported by a team of on-site specialise gardening and horticultural staff.

7.8 This demonstrates that there is no loss of allotments in accordance with Local Plan Policy GB8 (Allotments, Agriculture and Local Food Growing). The above also demonstrates that there are clear planning benefits arising from providing a better quality facility within the grounds of Syon Park. Loss of Local Open Space

7.9 Local Plan policy GB2 (Open Space) states that the Council will protect and

enhance Local Open Space. The Council will achieve this by:

Designating and protecting Local Open Space as shown on the Policies Map, in line with the NPPF and the London Plan;

Protecting and enhancing Local Open Space, addressing deficiencies in quality, quantity and access;

Maintaining the supply of Local Open Space to meet the needs of the borough’s growing population, by expecting on-site provision of publicly accessible open space, particularly in major new developments in areas of deficiency.

Encouraging the provision of an appropriate balance and mix of open space types specific to meet needs in different parts of the Borough, with specific reference to increasing the provision of parks and gardens;

Protecting quiet and tranquil areas of Local Open Space that are relatively undisturbed by noise and are valued for their recreation amenity attributes; and

Working with partners, friends groups, other stakeholders and the general public to improve and enhance the quality of an access to Local Open Space.

7.10 The Council will expect development proposals to:

Protect existing Local Open Space from development, especially where it would lead to a deficient in publicly accessible open space, unless it satisfies the criteria for such development in the NPPF in that: it has been assessed as clearly surplus to requirements; or it would be replaced by equivalent or better provision in a suitable location; or the development is for alternative sports and recreational provision, the need for which clearly outweighs the loss;

Avoid the loss of or encroachment upon Local Open Space, or intrusion into an open aspect. Development ancillary to the open space use must preserve its predominantly open character; and

Enhance the provision of publicly accessible Local Open Space in the Borough, especially in areas of open space deficiency as identified on an annual basis through Annual Monitoring Reports. Major developments should achieve this through onsite provision wherever possible, particularly in areas of substantial change and intensification.

7.11 The Council’s Open Space Strategy (2013) identifies the borough as having “well above the average level of public open space in comparative boroughs” (para. 3.14), and Isleworth as having the highest provision of public space within the Borough (para. 3.10). Isleworth has provision of all three typologies of open space (Parks & gardens, Nature Conservation Areas and Amenity Greenspace) which is above the borough average (para. 3.12).The starting point for assessment is that there is no deficiency of open space or public open space in this area of Hounslow. Syon Park is opposite the site and provides a very significant amenity for the local community.

7.12 Notwithstanding this, the proposed development would result in a loss of Local Open Space. The site is not public open space but allotment holders obviously have access to it and it does form a visual amenity to the local community and others who pass along Park Road or around the site.

7.13 The proposed development would maintain the leafy and verdant quality of Park Road, with the proposed residential blocks set back from the boundary line which enables the blocks to be experienced as ‘gables in trees’, rather than a continuous building frontage. The boundary would also be outlined by a visually permeable railing and significant mature trees would be retained. Beyond this, there would be a combination of low level planting and screening along with new trees to maintain the high level canopy and so maintain some of the visual amenity of the site as an open space. Further, the buildings are arranged in a collection of courtyards, with a tree lined crescent running through the centre. This arrangement means that, within the proposed development itself, the open space is partially retained through the provision of a number of shared/private amenity spaces.

7.14 The loss of Local Open Space is contrary to policy but must be considered in the context of the improved allotment facility that would be provided in Syon Park, the proposed development’s sensitive design and the significant green landscaping proposed on the site. The impact of the loss of Local Open Space is limited and that visual amenity is partly replaced. In addition,

the loss of Local Open Space also needs to be balanced against other benefits arising from this development (as set out below). Housing Supply

7.15 The NPPF seeks to boost the supply of housing significantly. Paragraph 49 of the NPPF states that housing applications should be considered in the context of the presumption in favour of sustainable development. Paragraph 50 supports delivery of a wide choice of high quality homes, widening opportunities for home ownership and the creation of sustainable, inclusive and mixed communities.

7.16 London Plan Policy 3.3 recognises the need for more homes in London in order to promote opportunity and provide a real choice for all Londoners. For Hounslow, the London Plan sets a housing delivery target of a minimum of 8,222 new homes between 2015 and 2025 (822 per annum), an increase from 470 per annum in the previous planning period.

7.17 Local Plan Policy SC1 seeks to maximise the supply of additional housing in the Borough in a manner consistent with sustainable development principles, and to ensure it is built at a rate of that will meet the London Plan annual completion targets for the relevant period. The Council will seek to ensure that during the period 2015 to 2030, a minimum of 12,330 additional dwellings will be completed, therefore exceeding the London Plan annualised completion targets. The Council will achieve this by supporting proposals for new homes in the context of the presumption in favour of sustainable development. The policy commits the Council to work with stakeholders and promoters of development to maintain this rate of new housing completion.

7.18 London Plan Policy 3.8 recognises that the planning system should take a positive approach to enabling the Private Rented Sector (PRS) to contribute to addressing housing needs and increasing housing delivery. The Mayor sees that attracting institutional investment into London’s PRS would be new investment into London’s housing supply and could play a significant role in helping increase the overall level of housing, as well as accelerating the completion of existing large scale developments.

7.19 The proposed development would be for PRS housing which would be retained in the long-term ownership of Northumberland Estates. Policy at all levels acknowledges that the PRS has a significant role to play in helping deliver London’s housing need. The nature and deliverability of this development would contribute positively and actively to meeting the overall housing requirement for Hounslow over the Local Plan period 2015-2025. The proposed PRS scheme would in itself meet housing needs within a market sector which is recognised as important.

7.20 It is therefore considered that the proposal is acceptable in principle, notwithstanding the other planning issues that will be discussed in turn.

7.21 The other main planning issues to be considered are:

Design and Appearance

Heritage

Housing Mix and Tenure

Standard of Accommodation

Impact on Neighbouring Uses

Transport Considerations

Sustainability

Landscaping and Arboriculture

Ecology

Flood Risk and Drainage

Land Contamination

Air and Noise Quality

Archaeology

Planning Obligations

Design and Appearance

7.22 The NPPF states that good quality design is an integral part of sustainable development and that decision takers should always seek high quality design. It states that achieving good design is about creating places, buildings or spaces that work well for everyone, look good, will last well, and adapt to the needs of future generations, with good design responding in a practical and creative way to both the function and identity of a place, putting land, water, drainage, energy, community, economic, infrastructure and other such resources to the best possible use. The NPPF also says permission should be refused for development of poor design that fails to take the opportunities available for improving the character and quality of an area and how it functions. It is proper to seek to promote or reinforce local distinctiveness.

7.23 However 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, if mitigated by good design (unless the concern relates to a designated heritage asset and its impact would harm the asset or its setting which is not outweighed by the proposal’s economic, social and environmental benefits).

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. This relationship should be considered throughout the design process, and should inform the positioning, massing, height, and materiality of development proposals. Developing a design solution that works with its surrounding context should not prevent or discourage appropriate innovation.

7.25 The London Plan requires all large scale proposals to be of the highest quality design especially in terms of impact on views, the wider and local

townscape context and local environmental impact. The achievement of high quality urban design is also highlighted as a key factor in achieving a more attractive and green city.

7.26 London Plan Policy 7.4 (Local Character) sets out that buildings should provide a high quality design response to the urban grain, street pattern, natural features, human scale and the historic environment and is supported by Policy 7.6 (Architecture) which seeks to promote high architectural and design quality appropriate to its context.

7.27 Local Plan Policy CC1 (Contact and Character) and CC2 (Urban Design and Architecture) state that the Council will recognise the context and varied character of the borough’s places and seek to ensure that all new development conserves and takes opportunities to enhance their special qualities and heritage. They seek to retain, promote and support high quality urban design and architecture to create attractive, distinctive, and liveable places.

7.28 The proposed buildings range between two and three storeys with further dormer roof accommodation in some locations creating a fourth storey. The maximum height is contained towards the centre of the site away from sensitive receptors. All the buildings would have a pitched roof except those which line the central crescent where green roofs are proposed.

7.29 The buildings have been designed so there is a clear distinction between top (bronze cladding) and bottom (brick) parts. The roofs with their dormer elements are proposed as low eave elements that break down the massing of the buildings. In addition the brick elements are punctuated by deep inset galleries and balconies, to break up the massing further and provide a depth to the elevations to emphasis the quality of the buildings.

7.30 The development would maintain a leafy and verdant quality along Park Road with new buildings set back from the boundary with the highway. Buildings fronting Park Road are arranged to create a rhythm of narrow gables with extensive landscaped courtyard gardens, to reflect the form and grain of existing development rather than create a continuous building frontage.

7.31 The proposed development follows the curved geometry of Snowy Fielder Waye and would create a legible street edge, providing passive surveillance and enclosure to this side of the street, strengthening the boundary and quality of landscaping along Snowy Fielder Waye.

7.32 The proposal includes a new east-west tree-lined crescent through the centre of the development which provides a visual clue and physical connection to the existing bridle path route to All Saints Church and the Thames Path beyond. Access to the residents’ courtyards and basement parking are provided here as well as visitor parking spaces, ensuring activity and animation in a shared surface setting.

7.33 There are three landscaped residential courtyard gardens – two in the north adjacent Park Road and one toward the south of the site. All three are

shared, semi-private spaces providing visual amenity and a high quality setting for recreation and play.

7.34 Entrances to the buildings and upper floor circulation face the landscaped courtyards in the form of arched cloisters. The relationships between internal and external spaces are here deliberately overlapped to provide a colonnaded, ‘collegiate’ quality to the shared circulation spaces.

7.35 The courtyard houses are arranged as a small cluster around a shared surface courtyard. There is a gradual reduction in scale – height, massing and footprint - to respond to the neighbouring houses. Back gardens to the courtyard houses are arranged to abut existing rear boundaries, therefore securing these edges and providing good distances between windows.

7.36 The development has been sensitively designed to relate carefully to the surrounding context. The proposal would use traditional materials and building forms, including masonry, pitched roofs, dormer windows and vertical window proportions. However, these have an arrangement and detail which is contemporary in appearance. The material palette of the architecture reflects the surrounding context through use of brick, dark metalwork and textured roofing.

Heritage

7.37 The NPPF recognises (paragraph 126) that heritage assets are an irreplaceable resource that should be conserved in a manner appropriate to their significance. When determining planning applications, local planning authorities should require applicants to describe the significance of any heritage assets affected, including any contribution made by their setting. The level of detail should be proportionate to the asset’s importance (paragraph 128).

7.38 With regard to conservation areas, NPPF paragraph 137 encourages new development to preserve those elements of the setting that make a positive contribution to or better reveal the significance of the conservation area.

7.39 London Plan Policy 7.8 states that development should value, conserve, restore, re-use and incorporate heritage assets where appropriate. Policy 7.10 states that development in World Heritage Sites and their settings, including any buffer zones, should conserve, promote, make sustainable use of and enhance their authenticity, integrity and significance and Outstanding Universal Value. Development should not compromise a viewer’s ability to appreciate these characteristics.

7.40 Local Plan Policy CC4 states that development will be expected to conserve and take opportunities to enhance any heritage asset and its setting in a manner appropriate to its significance. It continues that the Council will preserve and enhance the character or appearance of existing conservation areas by ensuring that any development within or affecting them area preserves or enhances their character and appearance. Development should respect the character of the existing architecture in scale, design and materials, and take account of relevant conservation area guidelines.

7.41 A Heritage, Townscape and Visual Impact Assessment (HTVIA) and Historic Environment Assessment (HEA) were submitted in support of this application.

7.42 The HTVIA considers the potential impacts of the proposal on local townscape and visual amenity, as well as the effects on the setting of heritage assets in the area. The HTVIA concludes that the existing allotments do not contribute to the historic value of the Isleworth Riverside Conservation Area, and no historic value would be lost through their redevelopment. The redevelopment of the site would, however, change the character of the Conservation Area immediately around Snowy Fielder Waye, Park Road and around the churchyard to the Church of All Saints. The existing soft landscaping and allotment infrastructure would be replaced with a new series of well designed residential blocks, in a soft landscaped setting. The proposal is of a comparable scale and height to the domestic properties that characterise the Conservation Area, and it maintains the existing townscape hierarchy which is crowned by the Church, both as the tallest building and the most clearly visible within its own space.

7.43 The proposed elevations are faced with materials characteristic of the Conservation Area and the massing and spacing of the residential blocks create an urban grain which is compatible with the finer urban grain along Church Street. Due to the proposed building heights, the development would be screened from views further afield, including from Syon Park, from Church Street, and from the River Thames, preserving the historic silhouette and rustic appearance of the medieval village. The proposed pedestrian routes would enhance the Conservation Area, by enhancing and augmenting the formal pedestrian approach to the Church from Snowy Fielder Way, and the increased planting at the southern perimeter would preserve the verdant character of the churchyard that surrounds the Church of All Saints to the north.

7.44 The picturesque composition of the Church of All Saints, and the landmark silhouette of the tower would not be affected by the proposed development. The sense of increased enclosure would be limited due to the scale and height of the proposed blocks, their spacing within their surrounding landscaping, and due to the intervening churchyard landscape which runs approximately 30-50 metres from the Church to the site boundary.

7.45 The development would have no effect on the architectural or historic value of the Porter’s lodge at the entrance to Syon Park. The new frontage to Park Road would not diminish the experience of arrival at the entrance to Syon Park, replacing the rather incoherent feel of the allotments in the wider setting of the lodge with a designed and landscaped street scene. The development would be screened from views of the Syon Park Pavilion seen from the River, and the effect on that listed building would be neutral. The historic and architectural value of the boundary wall to Syon Park would not be affected. The development would improve the aesthetic setting of the listed wall, lining Park Road with a frontage comprised of well designed gables interspersed with green spaces behind the existing street trees.

7.46 Due to the narrow width of Church Street, the development would not be visible behind the historic properties from within Church Street itself. In longer views towards Isleworth from the river, the development would be just

perceptible beyond The Church of All Saints churchyard, but the effect on the historic palette and silhouette would be negligible and not negative.

7.47 In terms of Syon Park itself, due to the density of the existing tree cover just inside the western boundary of the Park, the development would not be visible from within it. The proposal would create a well-designed new frontage to Park Road, enhancing its approach and so improving its setting.

7.48 The effect on the Royal Botanic Gardens, Kew World Heritage Site would be neutral as the proposed development would be screened from views within the buffer zone.

7.49 The development would have a direct effect on the Isleworth Riverside character area. There would be some loss of openness experienced along Park Road and Snowy Fielder Waye, due to the replacement of the allotments with new residential blocks. However, the soft landscape character of the area would be largely preserved through the well-spaced layout of the apartments and the surrounding courtyard gardens, landscaping and boundary planting. Existing street trees would shroud the development, as experienced along Park Road.

7.50 The amenity value of the allotments would be replaced off-site nearby, and a series of substantial heritage benefits are offered by the applicant to offset the harm arising from the loss of a Local Open Space.

7.51 The scheme would introduce a well-designed new residential enclave to the character, providing new public pedestrian routes and architecture that would complement the architectural heritage found along Church Street. On balance, it is considered that there would be a moderately beneficial effect on the character area, taking into account the quality of the scheme and the very limited contribution which the local open space makes to the characteristics and quality of the character area.

7.52 The effects on the character of the West Middlesex University Hospital and Syon Park character areas would be minor beneficial, arising from an improvement to their immediate settings. There would be a negligible effect on the Surrey bank of the Thames, due to the visual containment of the site behind the churchyard of All Saints Church.

7.53 In summary, the proposal would replace an existing open space of no historic interest with a well-designed contemporary residential scheme. The development has been composed with careful reference to the scale, massing architectural style and materials found across the Isleworth Riverside Conservation Area, and would enhance its existing architectural character and appearance. Retention of a number of existing mature trees, along with the proposed green landscaping and boundary treatment would preserve the verdant character of the Conservation Area as experienced on Snowy Fielder Waye, and Park Road, and from within the All Saints Churchyard.

7.54 It is considered that the proposal would preserve the character and appearance of the Isleworth Riverside Conservation Area, and that its

significance as a designated heritage asset would be conserved. Similarly, the settings of the surrounding listed buildings would be preserved.

7.55 Furthermore, the proposal also offers a series of heritage benefits to Syon House, which would carry significant weight in planning terms (see the ‘Enabling Development’ section below). The revenue generated by the development would enable internal conservation and refurbishment works to the state rooms of Syon House to be carried out. These works would be significant and would serve to restore part of this nationally important Grade I listed building.

7.56 It is clear that the heritage benefits associated with the restoration of the nationally important Grade I listed building are a significant material consideration and should be given weight in the determination of this application. It is considered that the proposed development would clearly enable the preservation of the Grade I listed Syon House and preserve the special architectural and historic interest of Syon Park.

Housing Density, Mix and Tenure

Density

7.57 The London Plan promotes efficient use of urban land and the optimisation of housing potential in new development to help meet the strategic challenges of population growth and the pressing need for new homes. Policy 3.4 states:

“Taking into account local context and character, design principles and public transport capacity, development should optimise housing output for different types of location within the relevant density range shown in Table 3.2.”

7.58 Local Plan Policy SC4 states that the Council will ensure the scale and density of new housing development balances the need to make efficient use of land and achieves high quality design and accessibility, whilst responding to and reflecting local context and character and protecting existing residents’ amenity. The Council will achieve this by having regard to the density ranges in London Plan Policy 3.4 to help guide the design and scale of new housing developments. For a ‘Suburban’ site such as this with a public transport accessibility level (PTAL) of 2, the suggested density is 150 – 250 hr/ha and up to 95 units per hectare. The density proposed is 309 hr/ha (net) based on 359 habitable rooms across the 1.16ha site of 1.16ha.

7.59 Notwithstanding this suggested density, where opportunities to maximise housing densities on suitable larger, Council policy is that these should be explored where all other planning policies can be fully satisfied to achieve sustainable development. There have been numerous cases where London Plan suggested maximum densities across London have been exceeded in decisions on planning applications.

7.60 The proposed amount and density is a function of the design-led approach to the scheme. It represents a positive and responsive townscape solution, with high quality landscaping and amenity space which would be subject to long term management. Further, the site is approximately 1.4 km (18 minutes walking distance) south of Syon Lane Station and several bus routes run

along Twickenham Road and London Road, providing services to Brentford, White City, Hammersmith, Hounslow and Heathrow. There are also a number of footpaths and footways near the site, offering easy access to Syon Park and strategic roads including Twickenham Road and London Road.

7.61 Based on the design-led approach to the scheme and the proximity of the site to sustainable transport methods, it is considered that the amount and density of the proposal is acceptable in this case in accordance with Local Plan Policy SC4 and London Plan Policy 3.4. the following sections give more analysis of this.

Mix

7.62 Policy 3.8 of the London Plan requires that new developments offer a range of housing choices, in terms of the mix of housing sizes and types, taking account of the housing requirements of different groups and the changing roles of different sectors, including the PRS, in meeting these.

7.63 Local Plan Policy SC3 seeks to meet local housing need by securing a mix of new housing types, sizes and tenures across the Borough. The Council expects proposals to use its schedule of housing mix requirements as a starting point for consideration of all housing proposals. In accordance with this policy, a full schedule of the housing accommodation size and tenure accompanies this application.

7.64 The dwelling mix has had regard to the Council’s preferred dwelling mix, while responding to agency advice and the demand for PRS housing in this location. Agency advice indicates that this development would not be particularly attractive to families. Notwithstanding, a proportion of 3 bedroom apartments (4%) and 3 bedroom townhouses (9%) are provided within the development. 5.24 The scheme includes a good overall dwelling mix which is balanced in terms of unit size and type. The proposed mix of units is as follows.

Number of Bedrooms Unit Total Percentage

Studio 2 1.57%

1 Bedroom 39 30.70%

2 Bedroom 73 57.48%

3 Bedroom (apartments) 5 3.94%

3 Bedroom (town houses) 8 6.30%

Total 127 100%

7.65 This proposed mix of dwelling sizes would help to create a balanced housing

development, in accordance with the London Plan and the Local Plan which both promote development that offers genuine housing choice.

Affordable Housing and Viability

7.66 Government policy in the NPPF, supported by the London Plan, requires all housing developments in the Borough capable of providing ten or more dwellings to provide on-site affordable housing. The current demand for affordable housing is spread over a variety of types. The 2015 London Plan Housing SPG (Supplementary Planning guidance) defines affordable housing as including social rented and intermediate housing, provided to specified eligible households whose needs are not met by the market. This is also reflected in emerging Local Plan policy SC2.

7.67 In April 2011 the Government introduced a new affordable rent product, intended to meet the same housing need as social rent. It is intended to allow affordable homes to be made available to tenants at up to a maximum of 80% of the gross market rent (taking account of the service charge for that property, where applicable) and allocated in the same way as social housing. The London Plan Housing SPG (2015) advises Boroughs that, rather than using the definitions from London Plan paragraph 3.11, in order to conform with the NPPF this definition of affordable rented housing should be used alongside more established definitions of social rented housing and intermediate housing, with all three products falling within a general affordable housing definition.

7.68 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 having regard to their affordable housing targets, the need to encourage rather than restrain residential development and the individual site circumstances. Local Plan Policy SC2 sets a target for 40% of on-site delivery of affordable housing at a tenure split of 60% affordable/ social rent and 40% intermediate. This is reflected in London Plan policy 3.11. This policy also states that when financial viability assessments demonstrate that current market conditions will support less than 40% affordable housing, a review mechanism upon partial or full completion of a development will be employed.

7.69 The development would not provide any dwellings that meet the London Plan and the adopted London Plan Housing SPG (2012) definitions of affordable housing.

7.70 However, the development proposals are considered ‘Enabling Development’ – the merits of this are discussed below. Enabling Development is development that would be unacceptable in planning terms but for the fact that it would bring public benefits sufficient to justify it being carried out, and which could not otherwise be achieved. The key public benefit to significant places is usually the securing of their long-term future.

7.71 In order for Enabling Development to be acceptable it must be demonstrated that the amount of development proposed is the minimum necessary to secure the future of the place, and that its form minimises harm to other public interests. The merits of this are considered later in this report. The amount of development is considered the minimum necessary to provide a financial income to fund the heritage works linked to this application. As

such, an affordable housing contribution cannot be offered. If an affordable housing contribution were offered, the scheme would not be considered the minimum amount of development necessary to secure the future of the heritage asset and as such would not be considered Enabling Development. Such a proposal could not be supported.

7.72 That said, it is recommended that members agree a review mechanism, secured through the Section 106 agreement, to capture any uplift in viability with a profit share arrangement between the Council and the developer in order to deliver a financial contribution towards off-site provision. The principle of this review mechanism has been agreed with the developer.

Standard of Accommodation

Minimum Space Standards

7.73 Local Plan Policy SC5 (Ensuring Suitable Internal and External Space) seeks to ensure suitable internal and external space in housing developments. In particular, it reinforces a number of standards set out in the London Plan.

7.74 In respect of external amenity space, Policy SC5 details that in accordance with the London Plan, where flatted developments are proposed, the provision of a minimum of five square metres of private outdoor space for all one- to two-person dwellings, with an additional square metre required for each additional occupant, typically as balconies. The balconies should be designed as an integral part of the building’s elevation to ensure a beneficial aspect, and avoid positions that result in unacceptable overlooking and loss of privacy to proposed or existing nearby dwellings. For houses with five or more habitable rooms, 75 square metres of amenity space should be provided. Communal external space should also be provided.

7.75 The policy also requires arrangement of external amenity space across the site to be carefully considered to ensure an appropriate balance of public, communal and private space. In family sized units, there should be direct and easy access to a good sized private garden.

7.76 London Plan Policy 3.6 and its Shaping Neighbourhoods: Play and Informal Recreation SPG (2012) set out for children’s play-space in new development.

7.77 This proposal includes a comprehensive landscape strategy designed to maximise usable private and communal amenity space. All of the proposed flats in the scheme would have dedicated private amenity space in the form of balconies. In total, the scheme would provide 1,012 square metres of private space in the form of balconies and terraces for the flatted development; and 619 square metres of private amenity space would be provided as private garden space, split between the town houses. The scheme would also provide 112 square metres of communal amenity space in the form of balconies/terraces and 4,631 square metres of communal amenity space in the form of podiums/gardens, including an appropriate level of children’s play space.

7.78 Four of the eight townhouses would have substandard provision of private amenity space (54 square metres, 55 square metres, 64 square metres and

66 square metres). It is considered that the amount of communal amenity space, the provision of on-site children’s play space and the proximity to Syon Park help to offset this shortfall.

7.79 Minimum internal space standards are set by Table 3.3 of the London Plan (Policy 3.5), to which new development should conform. All units exceed the minimum unit and room size targets set out in the London Plan.

7.80 The proposed development is therefore in accordance with Local Plan Policy SC5, London Plan Policies 3.5, 3.6 and the Shaping Neighbourhoods: Play and Informal Recreation SPG (2012).

Daylight and Sunlight

7.81 The daylight and sunlight assessment submitted with the application demonstrates that the proposed dwellings would provide a good standard of daylight and sunlight for future residents and the open space within the scheme. It is therefore concluded that the proposed development is acceptable in this respect in the context of the BRE guidelines and relevant planning policy.

7.82 The scheme has been designed to ensure acceptable levels of privacy and private amenity for users, as required by Local Plan Policy SC4.

Accessibility and Inclusive Design

7.83 London Plan Policy 3.8 and Local Plan Policy SC5 require developments to provide at least 10% provision of wheelchair accessible homes and encourage the creation of inclusive and equitable environments. The development has been designed in accordance with this objective. Of the proposed units 13 (10%) would comprise wheelchair accessible or easily adaptable units. London Plan Policy 3.8 also requires development to be built to ‘The Lifetime Homes’ standard, which proposed development does.

7.84 The communal spaces and new areas of public realm proposed as part of would have level access to ensure they are accessible by all.

7.85 The proposed development therefore accords with policy in terms of accessibility and would provide an inclusive environment for all occupants.

Impact on Neighbouring Uses

7.86 Local Plan Policy SC4 requires development proposals to apply Local Plan design standards to ensure the delivery of high quality developments that will not harm neighbours’ living conditions.

7.87 The scheme’s height and layout has been designed to ensure that daylight and sunlight levels in neighbouring properties and gardens space are acceptable.

7.88 The daylight assessment shows that the development would not cause any unacceptable effects on neighbouring properties’ daylight. The overall level of compliance with the guidance is very good for a development in London

(c. 94% of windows assessed would comply) and any breaches of the guidance are isolated and marginal. On this basis, and having regard to the inherent flexibility of the Building Research Establishment (BRE) guidance, the effects on neighbours’ daylight are considered acceptable.

7.89 The proposed development is also considered acceptable in terms of the sunlight levels that would be experienced by neighbours with the development in place. It would not result in any materially noticeable effects on sunlight and overshadowing levels in neighbouring gardens.

7.90 In summary, it is considered that the proposed development would not result in any unacceptable daylight and sunlight effects in relation to neighbouring properties. It is therefore concluded that the proposal is acceptable in this respect in the context of the BRE guidelines and relevant planning policy.

7.91 The scheme has been designed to ensure that acceptable levels of privacy for adjacent occupiers are provided, as required by Local Plan Policy SC4.

Transport and Highways

7.92 The NPPF (section 4) states that transport policies have an important role to play in facilitating sustainable development but also in contributing to wider sustainability and health objectives. Paragraph 32 of the NPPF states that ‘development should only be prevented or refused on transport grounds where the residual cumulative impacts of development are severe’.

7.93 Policy EC2 of the Local Plan requires proposals to demonstrate that adverse impacts on the highway network are avoided, including preparation of a Transport Assessment for major schemes. Travel Plans are also required for developments likely to have a significant impact on transport. This is supported by London Plan Policy 6.3 which requires that proposals ensure that the impacts on the transport capacity and network are fully assessed.

7.94 At all levels of planning policy, there is a strong presumption in favour of reducing the need to travel by private car and encourage more sustainable modes of travel. Policy EC2 requires proposals to demonstrate that they are located appropriately with regard to public transport, road capacity and access to good quality walking and cycling networks. A minimum number of cycle parking spaces and an appropriate maximum number of car parking spaces should be provided consistent with London Plan standards.

Access

7.95 Two new vehicle accesses are proposed from Snowy Fielder Waye, with the access from Park Road retained. The verge on the east side of Snowy Fielder Waye is not adopted by the Council. Access to the site from Snowy Fielder Waye is therefore predicated on the grass verge being adopted as public highway. This process is currently ongoing.

7.96 Vehicle access onto Park Road would be limited to servicing and delivery only. This would be achieved through use of a telescopic bollard which would be monitored and managed by the on-site concierge team. Full details of the management of the bollard and the vehicles permitted to use this access

route would be included in the Delivery and Servicing Plan via condition.

7.97 All accesses to the site would include raised entry treatments. A new footway would be constructed on the eastern side of Snowy Fielder Waye.

Car Parking

7.98 Residential car parking is proposed at a ratio of less than 1:1 for the one- and two-bedroom apartments and with a ratio of 1.5:1 for the larger houses. Additionally, visitor parking would be provided. Overall it is proposed to provide 139 resident and visitor spaces, including seven for visitors (6%), 16 spaces suitable for disabled use (12%) and one for loading purposes only.

7.99 The census data shows that the car ownership in the area is below 1 space per dwelling. The car parking is therefore considered to be acceptable.

7.100 20% of all spaces must be for electric vehicles with an additional 20% passive provision for electric vehicles in the future.

7.101 The internal roads are to be managed and kept clear of inconsiderate parking by the on-site concierge team. Full details of the operations, monitoring and enforcement of both the internal road network and the car parking areas would need to be incorporated within the Car Park Management Plan which would be secured by condition. The Car Park Management Plan would also need to include full details of electric charging points (and specifications), disabled parking and controlled access to the car park area.

Cycle Parking

7.102 The current configuration of the cycle parking is not acceptable. No specifications have been provided to demonstrate the type of cycle parking and the markings on the plan do not appear to be to scale. Further to this, a number of the bays are in parts of the car park that cannot be accessed when a vehicle is parked in front of them. Full details of the access to the cycle parking, its specification and designation would need to be provided before construction. This would be secured via condition.

Refuse Collection

7.103 The refuse strategy relies on the on-site concierge team to wheel the bins into a suitable location for collection; as such full details of the management of the bins would need to be included in the Delivery and Servicing Plan. The information should relate to the number of bins, their storage and collection location, as well as any additional machinery needed to trundle the bins to the pick-up location.

Trip Generation

7.104 Trip generation (TRICS) data has been provided using other sites to establish the trip generation associated with the proposed development.

7.105 Two of the selected sites are outer London, with similar PTAL, parking and dwelling numbers as the proposal. These sites are acceptable in principle.

7.106 The assessment that has been run results in an additional 19 two-way vehicle trips in the AM peak, 23 two-way trips in the PM peak and a total of 218 two-way trips over the 12 hour period.

7.107 The access junctions have been shown to be well within capacity.

Travel Plan

7.108 A Draft Travel Plan has been provided as part of the proposal; a full Travel Plan is secured via legal agreement. This shall include (but not be limited to) all measures outlined within the Draft Travel Plan.

Sustainability

7.109 Sustainability underpins many London Plan and Local Plan policies. These require developments to be sustainable in transport terms, to minimise waste, include energy efficiency measures and promote use of renewable energy, and not significantly increase the requirement for water supply or surface water drainage.

7.110 London Plan policy 5.2 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

7.111 Local Plan policy EQ1 (Energy and Carbon Reduction) states that the Council will move towards being a low carbon borough, by minimising the demand for energy and promoting renewable and low carbon technologies. The Council expect development proposals to meet the carbon emission reduction requirements set out in the London Plan and for major developments to assess the feasibility and viability of achieving this performance via connection to existing or future district energy networks or via combined heat and power systems.

7.112 Local Plan policy EQ2 (Sustainable Design and Construction) states that the Council will promote the highest standards of sustainable design and construction in development to mitigate and adapt to climate change. The Council expect development proposals to:

Incorporate established principles for design and construction as set out in the London Plan, including passive solar design, water efficiency standards, sustainable urban drainage, the reuse and recycling of construction materials, green roofs and urban greening;

Be assessed against the standards for sustainable design and construction set out in Table EQ2.1 and submit relevant documentation to demonstrate that minimum specified levels are met or meet any national standards that subsequently supersede these; and

Prepare a sustainability statement, in the case of major developments.

7.113 An Energy Statement has been submitted to support this application. It explains how the development would achieve the CO2 emission reductions required by these policies and meet the other sustainability criteria they set.

Landscape and Arboriculture

7.114 London Plan Policy 7.5 (Public Realm) states that landscape treatment, street furniture and infrastructure should be of the highest quality, have a clear purpose, maintain uncluttered spaces and should contribute to the easy movement of people through the space. In addition, opportunities for greening (such as trees and soft landscaping) should be maximised wherever possible.

7.115 London Plan Policy 7.21 (Trees and Woodlands) states that existing trees of value should be retained and any loss as the result of development should be replaced following the principle of ‘right place, right tree’. Furthermore, wherever appropriate, the planting of additional trees should be included in new developments, particularly large-canopied species.

7.116 Local Plan policy GB4 (Green Infrastructure Network) seeks to protect and enhance the green infrastructure networks throughout the Borough, particularly those that are part of the Mayor of London’s All London Green Grid. The network will be improved to maximise their diverse benefits and multiple functions, and improved public access to, and links between open spaces are encouraged. The Council expect development proposals to demonstrate that there will be no significant adverse impact on the borough’s green infrastructure.

7.117 Local Plan policy GB7 (Biodiversity) seeks to protect and enhance the Hounslow’s natural environment and to increase the quantity and quality of the Borough’s biodiversity. The Council will achieve this by encouraging the greening of the borough, through landscaping and tree planting, and protecting existing trees through Tree Preservation Order (TPOs).

7.118 An Aboricultural Impact Assessment (AIA) has been submitted to accompany the application. This assesses the impacts of the development on the existing tree stock. The AIA outlines that the proposal would result in the removal of a number of scattered trees and concludes that the arboricultural impact of the scheme on the existing tree stock would be negligible, as the majority of the trees which would be removed are of poor or low quality. Notwithstanding this, tree re-planting is recommended via condition to mitigate the loss of the trees and to complement both the proposed development and the wider environment.

7.119 The AIA recognises that the removal of these poor or low quality trees would provide an opportunity for high quality tree planting and sets out that in offering a new age cohort of diverse trees, including many more forms of tree, both in terms of species and provenance, the contribution to the overall quality of tree stock would be substantial. It is considered that this would result in a biodiversity gain.

7.120 The northern boundary would be reinforced with planting of typical hedgerow species and larger specimens, similar to those in Syon Park. The avenue leaving to All Saints Church would be continued along the central street through the development. The town houses would be set around a central humped ‘island’ with a large beech tree. New tree planting is also propsoed along the southern boundary to provide additional screening and habitat.

7.121 It is considered that the proposed landscaping works would enhance the sustainability and biodiversity of the site and help to strengthen the landscape character of the area. The proposed development therefore complies with policy NPPF Paragraph 58, London Plan Policies 7.5 and 7.21 and Local Plan Policy GB7.

Ecology

7.122 London Plan policy 7.19 (Biodiversity and Access to Nature) provides guidance on Sites of Importance for Nature Conservation and explains that development proposals should:

Give the highest protection to sites with existing or proposed international designations (SACs, SPAs, Ramsar sites) and national designations (SSSIs, NNRs) in line with the relevant EU and UK guidance and regulations.

Give strong protection to sites of metropolitan importance for nature conservation (SMIs). These are sites jointly identified by the Mayor and boroughs as having strategic nature conservation importance.

Give sites of borough and local importance for nature conservation the level of protection commensurate with their importance.

7.123 Local Plan policy GB4 (Green Infrastructure Network) states that the Council will protect and enhance the green infrastructure networks throughout the borough, particularly those identified as part of the Mayor of London’s All London Green Grid. The network will be improved to maximise the diverse benefits and multiple functions, and improved public access to, and links between open spaces will be encouraged. The Council expect development proposals to demonstrate that there will be no significant adverse impact on the borough’s green infrastructure.

7.124 Local Plan policy GB7 (Biodiversity) states that the Council will protect and enhance the Borough’s natural environment and seek to increase the quantity and quality of its biodiversity. The Council will achieve this by;

Permitting development only where it can be shown that significant adverse impact on biodiversity is avoided, mitigated, or as a last resort, compensated;

Protecting designated international, national and local nature conservation areas, as set out in Figure GB7.1 and supporting facts, and supporting designations;

Promoting the qualitative enhancement of biodiversity sites, including improvements to access, connectivity and the creation of new habitat;

Working with partners, including the Hounslow Biodiversity Partnership, the Crane Valley Partnership, the Brent Catchment Partnership and the Thames Landscaping Strategy to improve conditions for biodiversity;

and

Encouraging the greening of the borough through landscaping and tree planting and protecting existing trees through Tree Preservation Orders (TPOs).

7.125 The Council expects development proposals to:

Contribute to the greening of the borough, by incorporating green roofs and walls, landscaping, tree planting and other measures to promote biodiversity such as bat and bird boxes, through preparation of ecological plans and strategies where major developments are proposed, thereby resulting in a gain for biodiversity in the borough; and

Contribute to the action plans in the Hounslow Biodiversity Action Plan.

7.126 An Ecological Assessment has been submitted to support the application which assesses the impact of the proposal on the site’s ecological features. An extended Phase 1 Ecological Assessment was undertaken to ascertain the potential for protected species to be present within the site. A Phase 2 reptile and tree climb and inspect survey was subsequently undertaken in order to establish the presence of reptiles and roosting bats.

7.127 The Ecological Assessment confirms that there are two internally statutory designated sites within a 7 km radius of the site, three national statutory designated sites within a 2 km radius of the site and 19 non-statutory designated site of nature conservation within a 2 km radius of the site. The site itself consists of unmanaged semi-improved grassland interspersed with horticultural beds and species-poor hedgerow and scattered trees on the boundaries. The habitats on site are common and widespread and the site is therefore considered to be of low ecological value overall. Notwithstanding this, the site provides a suitable habitat for foraging and commuting bats and has the potential to support nesting birds. No reptiles were recorded as part of the Phase 2 survey and as such are considered absent from the site. A single tree on the site supports a bat box, whilst no other trees were recorded as having the potential to support roosting bats.

7.128 Despite the site having a low ecological value, due to the proposed removal of a number of scattered trees, the Ecological Assessment makes a number of recommendations to mitigate impact from the development and ensure that the site is enhanced for wildlife and a gain in biodiversity is achieved. The Ecological Assessment recommends the following:

The removal of trees should be undertaken outside the breeding season (March to August inclusive) or the habitat should be inspected by an ecologist immediately prior to removal to determine whether nesting birds are present;

New tree planting should be incorporated into the landscape proposals in order to offset the loss of trees as a result of the development;

The inclusion of new native species planting within the landscape. New areas of grass should comprise a native wildflower lawn mix;

To enhance the site, additional bat boxes could be installed on the retained trees;

The bat box erected on tree T36 should be inspected by a suitably qualified ecologist and relocated to a suitable retained tree along the northern boundary; and

A sensitive lighting scheme for the development should be installed to avoid disturbance on foraging and community bats. The lighting should comprise hooded luminaires directed away from vegetation.

7.129 The applicant’s Landscaping Strategy outlines in detail how the proposed development responds to these recommendations and, as previously explained, replacement tree planting/landscaping is proposed. This would be secured via condition. This is considered to result in an increase in the site’s ecological value and would introduce a variety of new plant species. It is therefore considered that the development would comply with the NPPF, London Plan Policies 5.3 and 7.19 and Local Plan Policies GB4 and GB7.

Flood Risk and Drainage

7.130 The EA flood map identifies the whole of the development site as being within Flood Zone 3, i.e. land having a risk of more than a 1 in 100 annual probability (1%) of river flooding. The site is also identified as being in an area at medium risk of flooding from rivers and seas. There is also an area along the western boundary which is identified as being at medium risk of surface water flooding, together with small areas along the eastern boundaries which are also identified as being at medium risk of surface water flooding.

7.131 Dwellings fall within the “More Vulnerable” category of development set out in Table 2 of the Planning Policy Guidance to the NPPF about flooding and therefore the sequential and exception tests must to be addressed.

7.132 In accordance with Local Plan Policy EQ3, a Flood Risk Assessment (FRA), prepared by Morgan Tucker, consistent with the requirements of the Environment Agency and the Strategic Flood Risk Assessment has been submitted in support of this application. The FRA determines the risks of flooding on the proposed development site and the likely impact of the development in terms of increased site runoff or drainage.

7.133 The aim of the sequential test is to steer new development toward areas with the lowest probability of flooding. Three comparative potential development sites were assessed however it was concluded these alternative sites were not sequentially preferable. It is therefore considered that the application site passes the sequential test and that:

there are no alternative sites available to the applicant; and

the proposed development would not increase the risk of flooding to the site or elsewhere in the catchment.

7.134 The exception test has also been applied to ensure that any risks have been properly assessed and that appropriate mitigation measures are provided as part of the proposed development. The FRA demonstrates that:

the development provides wider sustainability benefits to the community that outweigh flood risk; and

the development would be safe for its lifetime taking account of the vulnerability of its users, without increasing flood risk elsewhere.

7.135 This demonstrates that the proposed development is acceptable in flood risk terms and accords with the NPPF, PPG, London Plan Policy 5.12 and Local Plan Policy EQ3.

7.136 A Drainage Statement has also been prepared to accompany the application. It considers the existing and proposed drainage for the site (Surface Water and Foul Sewage).

7.137 Local Plan Policy EQ3 seeks to ensure surface water is managed through increased emphasis on sustainable drainage. Development proposals are expected to incorporate sustainable drainage systems and avoid non-permeable hard standings, with the aim of achieving greenfield run-off rates. London Plan Policy 5.13 also requires development to use sustainable drainage systems, unless there are practical reasons for not doing so.

7.138 Due to an unviable route to discharge to the nearest water course and very low permeability rates for the use of large soakaways, it is proposed that the surface water from the site would discharge directly into the Thames Water sewer network. However, as highlighted in the Drainage Statement, sustainable urban drainage systems (SUDS) would be implemented by including attenuation to limit discharge rates from the site. Details would be secured by condition. Whilst the surface water run-off rate would exceed greenfield rates associated with the site, the requirement to attenuate at least 50% of the undeveloped site surface water run-off at peak times would be met. The SUDS techniques to be incorporated in the scheme, include:

Permeable surfacing; and

Sub-surface storage.

7.139 The use of SUDS would ensure that surface water collected would receive an appropriate level of treatment prior to discharging to the public sewer.

7.140 The surface water flow would be restricted using attenuation and flow controls before discharging into the existing surface water network. The majority of the storage for surface water attenuation would be through the use of cellular storage, detention basins and within the build-up of permeable areas and swales. Some level of storage would also be provided in the proposed pipe network.

7.141 In terms of foul water drainage, there is an existing Thames Water 305 mm diameter foul water sewer under Park Road that the development would use.

Land Contamination

7.142 London Plan policy 5.21 (Contaminated Land) states that adequate measures should be taken to ensure that development on previously contaminated land does not activate or spread contamination.

7.143 Local Plan policy EQ8 (Contamination) states that the Council will ensure that contamination is properly considered and promote the remediation of land where development comes forward, consistent with the Council’s Contaminated Land Strategy and the NPPF. The Council will achieve this by:

Assessing development proposals to determine the suitability of the proposed use in relation to conditions on site;

Promoting remediation of contaminated of potentially contaminated land, and the improvement of land conditions and water quality in all areas, as regeneration takes place and development proposals come forward; and

Supporting the provision of infrastructure for decontamination and soil remediation.

7.144 The Council expect development proposals to:

Present adequate site investigation information, including assessment of the site’s history, potential contamination sources, pathways and receptors and, where appropriate, physical investigation, chemical testing, assessment of ground gas risks and of risk to groundwater;

Present proposals for the control of any risks from contamination there may be on site;

Show that contamination has not been caused during development, including demonstrating that imported materials are of suitable quality;

Have regard to the sustainability considerations where remediation is required, including controlling the quantities of material removed from or imported to the site;

Provide evidence to show that, following completion, the risks from contamination have been controlled effectively in accordance with the development proposals; and

Ensure that the contamination of water is avoided, and where possible include measures to improve water quality through sustainable design and construction.

7.145 A Geo-Environmental and Geotechnical Ground Investigations report has been submitted to support this application which determines the nature and where possible, the extent of contaminants potentially present at the site.

7.146 The ground investigation report highlights that elevated concentrations of benzo(b)fluoranthene, benzo(a)pyrene and dibenzo(ah)anthracine, as well as elevated levels of lead and mercury in the soils at a number of locations and these were found to exceed their respective 95th percentile upper confidence limit values. The report states that these contaminants are most likely associated with its current use as allotments and the continual use of

pesticides and herbicides, together with ash from bonfires and coal fires which was/is frequently used as a fertiliser. The report suggests that the elevated levels of contamination are located within the initial half metre depth of the soils and are above the water table; given the shallow depth, these soils are likely to be removed during construction.

7.147 Analysis of groundwater samples identified a number of polynuclear aromatic hydrocarbons (PAHs) above the assessment criteria, however these contaminants are generally low in concentrations and not considered a risk to site users as they are not likely to come into contact with the groundwater.

7.148 The report states that considering the proposed significant increase in hard cover on the site, the limited extent of the contaminants detected and the likely requirement to remove some shallow soils during construction, it is considered that the risk posed to controlled waters from the site is low.

7.149 The Council’s Land Quality team have reviewed the submitted information and recommend a Phased Contamination Condition to secure a scheme for removal of the risk from contamination identified on the site.

Air and Noise Quality

7.150 The NPPF says that planning decisions should ensure that any new development in Air Quality Management Areas is consistent with the local air quality action plan. It also requires the planning system to prevent both new and existing developments contributing or being put at unacceptable risk or being adversely affected by unacceptable levels of air pollution.

7.151 London Plan policy 7.14 (Improving Air Quality) aims to improve air quality in London and requires development to minimise exposure to existing poor air quality, make provision to address local air quality problems and promote the greater use of sustainable transport modes through travel plans, and ultimately be ‘air quality neutral’ through not leading to a deterioration of existing air quality.

7.152 Alongside the Council’s Air Quality Supplementary Planning Documents (SPD), Local Plan policy EQ4 (Air Quality) states that the Council will seek to reduce the potential air quality impacts of development and promote improved air quality across the borough, in line with the Air Quality Action Plan. The Council will expect development proposals to:

Carry out air quality assessments where major developments or change of use to air quality sensitive uses are proposed, considering the potential impacts of air pollution from the development on the site and neighbouring areas, and the potential for end users to be exposed to air pollution, consistent with requirements established in the Air Quality SPD, the London Plan and in government and European policy are met;

Incorporate mitigation measures where air quality assessments show that development could cause or exacerbate air pollution, or where end users could be exposed to air pollution.

7.153 Current Local Plan policy and government advice sets out guidance on reducing and assessing the air quality implications of development and providing mitigations as appropriate rather than prescribing the acceptability of development in areas where air quality is currently poor, unless mitigation is not practical.

7.154 The site is within the Air Quality Management Area (AQMA) that covers the whole Borough and by definition suffers from poor air quality. AQMA’s do not differentiate levels of pollution between different areas and, in reality, there are differences on the ground. Whilst the designation of an AQMA is indicative of a certain level of air quality, this in itself does not prevent development in such areas.

7.155 Local Plan policy EQ4 (Air Quality) states that the Council’s objective is to seek to reduce the potential air quality impact of development, in line with the Air Quality Action Plan, and that development proposals are expected to include air quality assessments for major developments and consider the potential impacts of air pollution from the development on the site and neighbouring areas and incorporate mitigation measures where air quality assessments show that developments could cause or exacerbate air pollution, or where end users could be exposed to air pollution.

7.156 An Air Quality Assessment (AQA) has been submitted in support of this application. It concludes that the impact of additional emissions from road sources to sensitive receptors is considered negligible and the development would achieve Air Quality Neutral classification.

7.157 Local Plan policy EQ5 (Noise) states that the Council will seek to reduce the impact of noise from aviation, transport and noise-generating uses, and require design of new development to include mitigation of these impacts, on new users and surrounding uses according to their sensitivity.

7.158 A Noise Impact Assessment (NIA) has been submitted with the application. It considers the impact of air traffic noise on all sides of the proposed dwellings and the noise impact of the proposed mechanical plant. The use of proprietary glazing, sound insulation of building façades and appropriate noise attenuation measures with regard to the proposed mechanical ventilation heat recovery units, would ensure acceptable living conditions for future occupiers.

Archaeology

7.159 The NPPF (Section 12) and London Plan policy 7.8 (Heritage Assets and Archaeology) emphasise that conservation of archaeological interest is a material consideration in the planning process. Paragraph 128 of the NPPF says that applicants should submit desk-based assessments and, where appropriate undertake field evaluation, to describe the significance of heritage assets and how they would be affected by a proposed development. This information should be supplied to inform the planning decision. If planning consent is granted, paragraph 141 says that applicants should be required to record and advance understanding of the significance of any heritage assets to be lost (wholly or in part) and to make this evidence publicly available.

7.160 Local Plan policy CC4 (Heritage) states that the Council will identify, conserve and take opportunities to enhance the significance of the borough’s heritage assets as a positive means of supporting an area’s distinctive character and sense of history. The Council expect development proposals to have regard to any harm to, or loss of, the significance of a non-designated heritage asset, including from both direct and indirect effects. Non-designated heritage assets include locally listed buildings, Archaeological Priority Areas and areas of special local character.

7.161 The site is within an Archaeological Priority Area and therefore a Historic Environment Assessment (HEA) has been supported in support of this application which assesses the archaeological potential of the site and its significance. The HEA details that the site has a high potential to contain palaeoenvironmental remains as the site lies within the projected location of a palaeochannel and therefore would contain alluvium. Within the alluvium there is a high potential for insect, plant and mollusc remains that can be used to reconstruct past local environments. This would be of low or medium heritage significance depending on the type of the remains.

7.162 The report also details that the site has a moderate to high potential to contain archaeological remains dating to the prehistoric period. The site lies 30 metres to the east of a past archaeological investigation under Snowy Fielder Waye, which revealed a significant assemblage of Bronze Age and Iron Age artefacts, including an early Iron Age cremation. The significance of the remains would depend on their nature, extent and preservation, but could be of medium or high significance, derived from the evidential value of the remains. The potential for archaeological survival on the site is considered to high in the absence of deep ground disturbances in the past and its current use as allotments.

7.163 The potential for archaeological remains from other periods is likely to be low given that historically the site has been open field land on the outskirts of the historic riverside village of Isleworth. Human remains are not anticipated to be present.

7.164 Historic England have reviewed the submitted information and state “It is clear from the evaluation that the site has the potential for evidence of prehistoric activity; however the remains are not of high enough significance to require preservation in situ. The impacts to the archaeological resource could be appropriately mitigated through the implementation of a programme of archaeological investigation in accordance with an archaeological condition”. Officers recommend such a condition.

Enabling Development

7.165 ‘Enabling development’ is development that would be unacceptable in planning terms but for the fact that it would bring public benefits sufficient to justify it being carried out, and which could not otherwise be achieved. The key public benefit to significant places is usually the securing of their long-term future. Enabling development that would secure the future of a significant place, but contravene other planning policy objectives, should be unacceptable unless the proposals comply

with the seven criteria set out in Historic England’s ‘Enabling Development and the Conservation of Significant Places’ (2008) document (see paragraphs 7.174 – 7.197). An Enabling Development Case has been submitted in support of the application and the linked planning application for the formation of a new allotment area in Syon Park reference number 00707/E/P111.

7.166 Syon House and Syon Park belong to the Duke of Northumberland and it is his family’s historic London residence. Syon House is Grade l listed and the park is included on Historic England’s Register of Historic Parks and Gardens as Grade l. Both are important, national statutory designations. The cost of maintaining and repairing Syon House and its grounds is considerable. A number of important works need to be undertaken comprising the internal conservation and refurbishment of the state rooms and repairs to the stone façade, and the restoration of Lion Gate and its Lodges. The Estate’s objective is therefore to secure the long term funding for the ongoing maintenance, conservation and restoration of this heritage asset so that it can continue to remain as a unique example of a rural estate located in a major conurbation, to be enjoyed by future generations.

7.167 To generate the funding necessary, Northumberland Estates is therefore proposing to build 127 dwellings on land that it owns on Park Road. This land is occupied by allotment holders and, as such, it is proposed that replacement allotment gardens are provided in the grounds of Syon Park. The residential development would comprise high quality Private Rented Sector (PRS) housing, to be retained in the long-term ownership and management of Northumberland Estates. This would ensure a long-term income stream is generated so it is able to fund a schedule of costly dilapidations, thereby ensuring the long-term sustainable future of this nationally significant heritage asset. These are important works which the Northumberland Estates intends to undertake over a period of 25 years.

7.168 Based on current estimates of the repair programme the Estate needs to invest £9,562,625 in conservation and repair works. The façade repairs to Syon House is a very important project as it would protect the house from further deterioration and water ingress. If the Estate does not undertake these repairs, it is anticipated that the rate of deterioration could accelerate and that this could cost more to repair in the long run. The façade repairs have been costed at £6,330,000.

7.169 The State Rooms have seen very little recent conservation work, with the exception of works to the Great Hall undertaken in 2009. Over the years there have been a number of problems with the fabric of the rooms due to water penetration through defective roof finishes and rainwater disposal systems, and through defects in the stone façade. This has resulted in the delamination of ceiling and wall finishes and some structural defects. Whilst the defects to the roof and rainwater disposal system have been addressed, the legacy of this remains, and as such a number of the state rooms are in need of significant and important repairs. This work will amount to £3,059,000.

7.170 The Lion Gate and its Lodges are also in need of refurbishment. The associated cost of these repair works will amount to £173,625.

7.171 The accounts submitted with the Enabling Development Case set out the financial position in respect of the Syon Estate, demonstrating that the Northumberland Estate does not have surplus funds to support the required heritage works. Northumberland Estates has therefore explored whether there are potential granted/funding sources that could be used, including Historic England Grant, Heritage Lottery Fund and Private/Charitable Fundraising, however none of these is suitable.

7.172 Given this, the only way that these long-term maintenance costs can realistically be met, and for the Northumberland Estates to be financially self-sufficient and sustainable in heritage terms is to deliver additional income-generating developments.

7.173 The proposed PRS housing on the Park Road site would generate an annual income of £1,887,840 (the net annual income would amount to £1,038,312, taking into account taxation). It is estimate that the rental income from the units, deducting the finance (borrowing costs) for the development, taxation on income and management costs would provide a minimum assured income stream from which the Estates can commit £400,000 per annum to the scheduled heritage repairs.

7.174 The Enabling Development Case considers the proposals against the seven criteria in Historic England’s Enabling Development Policy:

a) It will not materially harm the heritage values of the place of its setting.

7.175 The proposed development on the Park Road site would secure heritage benefits to Syon House which carry significant weight in planning terms. The revenue generated by the development would enable internal conservation and refurbishment works to the state rooms and works to the stone façade of the Grade I listed Syon House to be carried out. These works would be significant and serve to restore part of this nationally important Grade I listed building. It is submitted by the applicants that the Park Road proposal would at least preserve, but also enhance the character and appearance of the Conservation Area, and its significance as a designated heritage asset would be conserved. Similarly, the settings of the surrounding listed buildings would be preserved.

7.176 Due to the density of the existing tree cover just inside the western boundary of Syon Park, the Park Road proposals would not be visible from within it and, as such, would not affect the setting of the House or Park.

b) It avoids detrimental fragmentation of management of the place.

7.177 The development would not result in the detrimental fragmentation of management of the place. The Park Road development lies outside of the Grade l registered Park and Garden and does not form part of the

setting of Syon House. The development would be retained in Northumberland Estates’ long term ownership.

c) It will secure the long-term future of the place and, where applicable, its continued use for a sympathetic purpose.

7.178 The underlying principle of the proposals is to secure the long term future not only of Syon House but also the remainder of the Estate so that it can continue to be accessible to the public, as it has been for many years. The proposed development would fund the restoration of the State Rooms, the stone façade to Syon House and the restoration of the Lion Gate and its Lodges. As such, the enabling development would make a significant contribution to the longer terms preservation of Syon Park.

d) It is necessary to resolve problems arising from the inherent needs of the place, rather than the circumstances of the present owner, or the purchase price paid.

7.179 The proposed heritage repairs are a direct response to the need to carry out significant conservation and restoration work to the State Rooms, the stone façade of Syon house and the Lion Gate and its Lodges to ensure that their fabric is maintained in good condition. As such, the project is driven solely by the heritage needs of the house and wider estate and not by the circumstances of the owner, The Trustees of the 10th Duke’s Will Trust. Furthermore, the proposed works bear no relationship to the price of the house, which was acquired in 1594 by Henry Percy, 9th Earl of Northumberland (1564-1632), and has remained in the family since this time.

7.180 Condition surveys and reports have been submitted in support of the application which explain the need for the heritage works to be undertaken, which make clear the enabling development is necessary to deal with problems directly associated with Syon Park.

7.181 The Estate is a responsible custodian of this Grade l listed building and is looking to invest £9,562,625.00 to safeguard its future. The façade repairs to Syon House is a very important project for the Estate as it would protect the house from further deterioration and water ingress for the longer term future. If the Estate does not undertake these repairs, it is anticipated that the rate of deterioration could accelerate and that this could cost more to repair. Moreover, further deterioration of the façade could give rise to increased water penetration and health and safety concerns, which could jeopardise public access to the building. This would compromise an important income stream from the Estate and would make on-going repairs and maintenance more difficult and costly to achieve.

e) Sufficient subsidy is not available from any other source.

7.182 Northumberland Estates has explored whether there are potential grant/funding sources that could be used, including Historic England

Grant, Heritage Lottery Fund and Private/Charitable Fundraising, however none of these is suitable. No subsidies are therefore available from any other source to finance these works.

f) It is demonstrated that the amount of enabling development is the minimum necessary to secure the future of the place, and that its form minimises harm to other public benefits.

7.183 The proposed heritage works have been costed at £9,562,625 at 2016 prices, which includes the works to Lion Gate and its Lodges. The breakdown is as follows:

Work to Stone Façade: £6,330,000

Work to State Rooms: £3,059,000

Work to Lion Gate and Lodges: £173,625

Total: £9,562,625

7.184 A Business Plan has been submitted in support of the application which identifies a sum of £13,447,000 for heritage works which includes not only the £9,562,000 identified above but other major works which are required to heritage property over the coming years but which will be financed out of the Estates’ existing revenue streams for Syon Park, including the hotel. The Business Plan demonstrates the Estates’ actual and planned income and expenditure over the period of 2011/12 to 2016/17. This shows that Northumberland Estates does not have a surplus of funds sufficient to fund the proposed heritage works.

7.185 Northumberland Estates intend to build out the development to generate a rental income stream to support the heritage estate in the long term. It is estimated that the rental income from the units, deducting the finance (borrowing costs) for the development, taxation on income and management costs, will provide a minimum assured income stream from which the Estates can commit £400,000 per annum to the scheduled heritage repairs.

7.186 There is no surplus funding generated by the Park Road development that is not accounted for over the lifetime of the project. Reducing the scale of the development would result in a lesser income, which would compromise the delivery of the heritage works that are required. In light of the above, the proposed development is considered the minimum necessary to secure the proposed heritage works over a 25 year period and as such, the long term future of the Syon estate.

7.187 The proposed development has been carefully assessed as part of the planning application and it is considered that there is no harm arising with respect to other public interests. This is considered further below. g) The public benefit of securing the future of the significant place

through such enabling development decisively outweighs the disbenefits of breaching other public policies.

7.188 There are significant public benefits arising from the proposed

development which decisively outweigh the disbenefits of breaching other public policies.

7.189 First, via a section 106 legal agreement it would secure important

restoration works to Syon House and Lion Gate and its Lodges both of

which are Grade 1 listed buildings. This will secure the long term future of this important national, Grade 1 registered heritage asset.

7.190 Second, it would safeguard Syon Park as a nationally important visitor attraction, thereby enhancing its contribution to tourism strategies.

7.191 The Estate provides extensive public access - both paid and unpaid - to Syon Park and it is estimated that some 750,000 people come to or pass through the estate annually to visit Syon House and its gardens, the Garden Centre, the Hilton Hotel, the Snakes & Ladders Adventure Playground or simply to enjoy the open space and parkland from the main drive area and the Duchess Gate path. Its contribution towards tourism strategies both local and nationally should not be underestimated. Many areas are freely available without charge although the Estate still has the obligation and responsibility to maintain these areas. It is estimated that approximately 10% of visitors to the Park pay to visit the House or Gardens and directly support their maintenance.

7.192 Thirdly, it would deliver 127 dwellings for the Borough. This would help to meet an urgent need for housing in the Borough and boost the supply of housing as encouraged by the National Planning Policy Framework (para. 47).

7.193 Paragraph 134 of the National Planning Policy Framework (NPPF) advises that where a development proposal would lead to less than substantial harm to the significance of a designated heritage asset, this harm should be weighed against the public benefits of the proposal, including securing its optimum viable use. The test as set out in the NPPF is similar to criterion ‘g’ of Historic England’s enabling development policy.

7.194 In relation to the proposed housing on the Park Road site, the proposed development anticipates the abovementioned relocation of allotment gardens and secures this provision for allotment holders. Whilst there would be a net loss of Local Open Space, the site is not within an area of deficiency. Syon Park is opposite the site and provides a very significant amenity for the local community of this area as set out above. The development would replace a Local Open Space with a high quality housing scheme which has been designed to complement the existing quality, character and appearance of the Isleworth Riverside Conservation Area, and the settings of the surrounding heritage assets. The loss of Local Open Space is therefore decisively outweighed by the significant heritage and public benefits made possible as a result of the proposed developments.

7.195 It is acknowledged that the proposed development would result in the loss of Local Open Space. However, this impact or disbenefit, is decisively outweighed by the significant heritage and public benefits, which carry considerable weight in planning terms.

7.196 For the avoidance of doubt, the heritage benefits comprise the works to the State Rooms and the stone façade of Syon House, the restoration of Lion Gate and its Lodges plus the reinstatement of historic tree planting in the vicinity of Lion Gate. This would safeguard the future of this nationally important Grade 1 listed building. Other public benefits include the important contribution that Syon House and Park makes to tourism in London and which would be cemented via the proposed works; allotment holders being provided with new and improved allotment gardens with associated utilities; and the provision of 127 new homes, to help meet the Borough’s housing need.

7.197 As set out above, the heritage benefits would safeguard the investment of £9,562.625.00 in a nationally important Grade I heritage asset and enable the restoration of the State Rooms and remedial works to the façade of Syon House over a 25 year period. This would be secured via a section 106 legal agreement. If these important works are not planned for and undertaken, the defects could deteriorate at an accelerated rate, which could result in more costly repairs. Moreover, there is a risk that if the works are not undertaken and the fabric of the house is left to deteriorate further that this could jeopardise public access currently afforded to the house.

Planning Obligations

7.198 The National Planning Policy Guidance provides advice 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.

7.199 Local Plan policy IMP3 (Implementing and monitoring the Local Plan) states that the Council would ensure that new development in the borough contributes towards the provision of infrastructure needed to support growth and would achieve this by supporting the delivery of infrastructure through the use of Hounslow CIL receipts and planning obligations and expecting development proposals to mitigate the impacts of the development on the area through a section 106 agreement, where necessary and appropriate.

7.200 The Council’s SPD 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.

7.201 If approval were to be considered, the main areas listed below are to be included in any legal agreement:

To undertake repairs to the stonework/facades to Syon House.

To undertake repairs to the State Rooms to Syon House.

To carry out the works in accordance with the programme in a period not exceeding 20 years following first occupation of the development.

To undertake transport works as set out in the Residential Travel Plan, dated February 2016.

Highway works (works to be undertaken under a s278 agreement including accesses, etc) agreed prior to commencement and works completed prior to occupation of the development. This would comprise new/amended vehicle assess to Park Road and Snowy Fielder Waye and the construction of a footway along the eastern side of Snowy Fielder Waye.

To make provision for construction employment/training during the duration of the construction of the development.

Viability uplift review mechanism to contribute to affordable housing need.

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.

9.2 CIL is payable on m2 of new floor space or where a new dwelling is created or the net floor area increase exceeds 100 m2.

Mayors £35 per m2

Hounslow: Housing:

East £200m2

Central £110m2

West £70m2

Supermarkets, superstores and retail warehousing:

£155 m2

Health care, education and emergency services facilities: £0

All other

uses: £20m2

9.3 This proposal would be liable to pay Community Infrastructure Levy.

9.4 10,752m2 of new chargeable residential floorspace would be created. This creates a CIL charge of £376,320 for the Mayor and £1,182,720 for Hounslow.

10.0 CONCLUSION

10.1 The proposals are broadly compliant with the statutory development plan, however, where there are areas of non-compliance this must be balanced against the significant planning and heritage benefits arising.

10.2 In relation to the loss of Local Open Space, the site is not within an area of deficiency. Syon Park is opposite the site and provides a very significant amenity for the local community of this area. The loss of Local Open Space is contrary to policy but must also be considered in the context of the improved allotment facility that would be provided in Syon Park and the proposed development’s sensitive design and the significant green landscaping proposed on site. The impact of the loss of Local Open Space is

limited and that visual amenity is partly replaced. In addition, the loss of Local Open Space also needs to be balanced against the other benefits arising from this development.

10.3 In particular, the proposal offers a series of heritage benefits to Syon House that would carry significant planning weight. The revenue generated by the development would enable conservation and refurbishment of the Grade I listed Syon House. These works would be significant and serve to restore part of this nationally important Grade I listed building. When considered against the statutory provisions above, the proposed development would clearly enable the preservation of the Grade I listed Syon House.

10.4 The proposed development would result in a high quality PRS development which sits sympathetically in surrounding context. Policy at all levels recognises that the PRS has a role to play in helping meet London’s housing need and the nature and deliverability of the development would contribute positively and actively to meeting the overall housing requirement for Hounslow over the Local Plan period 2015-2025.

10.5 Further, the development, through introducing a comprehensive landscape strategy and a variety of new plant species, would enhance the sustainability of the site, enhance biodiversity within, and supported by, the tree stock and would help strengthen the landscape character of the area.

10.6 It is therefore considered that, on balance, the proposed development is an appropriate response to the planning framework and is acceptable.

11.0 RECOMMENDATION: APPROVE

11.1 That planning permission be granted subject to the following conditions and securing the abovementioned planning obligations by prior completion of a satisfactory legal agreement or unilateral undertaking under Section 106 of the Town and Country Planning Act 1990 and/or other legislation (including any agreements under Section 278 or Section 38 of the Highways Act 1980), the exact terms of which shall be negotiated by appropriate officers in the Department of Regeneration, Economic Development & Environment on the Head of Governance’s advice.

11.2 The satisfactory legal agreement or unilateral undertaking outlined above shall be completed and planning permission issued by 30th September 2017 or such extended period as may be agreed in writing by appropriate officers within the Department of Regeneration, Economic Development & Environment or Head of Governance’s Office.

11.3 If the legal agreement or unilateral undertaking is not completed by the date specified above (or any agreed extended period), then the Executive Director Regeneration, Economic Development & Environment or Director – Community Safety, Environment and Regulatory Services, Chief Planning Officer or the 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 described above.

11.4 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 Executive Director Regeneration, Economic Development & Environment or Director – Community Safety, Environment and Regulatory Services or the Head of Development Management is hereby authorised (in consultation with the Chair and upon the advice of the Head of 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.

11.5 If planning permission is refused, the Executive Director Regeneration, Economic Development & Environment or Director – Community Safety, Environment and Regulatory Services or the Head of Development Management (in consultation with the Chair) is hereby authorised to approve any further application for planning permission or listed building consent validated within 12 months of the date of refusal of either application, provided that it (a) duplicates the earlier 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 Limit

The 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 (as amended).

2 B4 Samples of Materials

No development (except demolition, archaeological investigations, ground condition investigations and intrusive site surveys and other enabling works: site clearance; soil storage; remedial works in respect of any contamination or any other adverse ground conditions; erection of any temporary means of enclosure and land raising) shall take place until details and samples of all facing materials to buildings relevant to that Phase are submitted to and approved in writing by the Local Planning Authority. The samples and details shall include: a. brick/stonework (including brick/stone and mortar on-site

sample panel min. 2m x 2m); b. cladding materials (including system specifications/details

and on-site samples (where relevant); c. window treatment (including sections/reveals and on-site

sample); d. all privacy measures, (including obscure glazing details -

including where separation distances between habitable room windows are less than 18m - privacy screens - including those to the first floor roof terraces on the Mews Houses - etc.);

e. balustrading treatment (including etails/sections/materials for each balcony type); and

f. any other materials/details to be used including extract vents, boiler flues, etc.

Each phase of the development shall then be carried out in accordance with the approved details and maintained as such thereafter. Reason: In order to safeguard the visual amenity of the area and building in particular and to satisfy the requirements of policies CC1, CC2, CC3 and SC4 of the Local Plan and London Plan Policy 7.6.

3 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 and approved by the Local Planning Authority, or as shall have been otherwise agreed in writing by the Local Planning Authority.

Reason: To ensure the development is carried out in accordance with the planning permission.

4 C5 Restriction of Permitted Development Rights

Notwithstanding the provisions of the Town and Country Planning (General Permitted Development Order) 1995 (or any order revoking or re-enacting that order) no enlargement of the premises or any additional structures/buildings within the curtilage of the site shall be carried out.

Reason: In order not to prejudice the amenities of the adjoining properties and in order that the Local Planning Authority is able to exercise control over future development of the site.

5 C29 Hours of Construction/Demolition No demolition or construction work shall take place on the site except between the hours of 8am to 6pm on Mondays to Friday and 8am to 4pm on Saturdays and not at all on Sundays and Public Holidays. Reason: In order to safeguard the amenities of adjoining residents and the amenities of the locality in accordance with

Local Plan policies CC1, CC2 and EQ5 and Policies 7.15 (Reducing noise and enhancing soundscapes) and 5.3 (Sustainable design and construction) of the London Plan.

6 E1 Landscape design proposals

No development shall take place until full details of both hard and soft landscape works 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 (proposed finished levels or contours; means of enclosure; car parking layouts; other vehicle and pedestrian access and circulation areas; hard surfacing material; minor artefacts and structures (eg. furniture, play equipment, refuse or other storage units, signs, lighting etc); proposed and existing functional services above and below ground (eg drainage power, communications cables, pipelines etc. indicating lines, manholes, supports etc); retained historic landscape features and proposals for restoration, where relevant).

Soft landscape works 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).

Reason: To ensure a satisfactory appearance of the site and improve the visual amenities of the locality.

7 E16 Existing trees which are to be retained

In this condition "retained tree" means an existing tree which is to be retained in accordance with the approved plans and particulars; and paragraphs (a) and (b) below shall have effect until the expiration of (5 years¹) from (the date of the occupation of the building for its permitted use).

(a) No retained tree shall be cut down, uprooted or destroyed, nor shall any retained tree be topped or lopped other than in accordance with the approved plans and particulars, without the written approval of the local planning authority. Any topping or lopping approved shall be carried out in accordance with British Standard [3998 (Tree Work)] or any other BS replacing.

(b) If any retained tree is removed, uprooted or destroyed or dies, another tree shall be planted at the same place and that tree shall be of such size and species, and shall be planted at such time, as may be specified in writing by the local planning authority.

(c) The erection of fencing for the protection of any

retained tree shall be undertaken in accordance with the approved plans and particulars before any equipment, machinery or materials are brought on to the site for the purposes of the development, and shall be maintained until all equipment, machinery and surplus materials have been removed from the site. Nothing shall be stored or placed in any area fenced in accordance with this condition and the ground levels within those areas shall not be altered, nor shall any excavation be made, without the written consent of the local planning authority.

Reason: To enable the Local Planning Authority to ensure the retention of the maximum number of trees on the site and their protection from damage, in the interests of visual amenity.

8 J12 Contaminated Land Before the development hereby permitted commences: a. A scheme for removal of the risk from contamination identified on 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: b. 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: c. 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.

9 Construction Management

No development shall take place until a Construction Management Plan (CMP) and Construction Logistics Plan (CLP) have been submitted and approved by the Local Planning Authority. The CLP shall cover as a minimum:

a site plan (showing the areas set out below)

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

provision for the parking of vehicles of site operatives and visitors

provisions for loading, unloading and storage of plant and materials within the site

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

details of vehicle routeing from the site to the wider strategic road network

the erection and maintenance of security hoarding including decorative displays and facilities for public viewing, where appropriate

provision of wheel washing facilities at the site exit and a commitment to sweep adjacent roads when required and at the reasonable request of the council

a scheme for recycling/disposing of waste resulting from demolition and construction works

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

commitment to liaise with other contractors in the vicinity of the site to maximise the potential for consolidation and to minimise traffic impacts

avoidance of network and school peak hours for deliveries and details of a booking system to avoid vehicles waiting on the public highway

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

details of the construction programme and a schedule of traffic movements

All construction and demolition works shall be undertaken in accordance with the approved CMP and CLP. Reason: In order to protect the environmental quality of the surrounding area and to ensure that deliveries to the site during construction are managed effectively so as to minimise impact upon the road network and to safeguard the amenities of residential properties in the locality and in the interest of road safety, in accordance with Local Plan policies CC1, CC2, EQ5, EQ4, EQ6 and EC2 of the adopted Local Plan Policy and Policies 7.15 (Reducing noise and enhancing soundscapes), 7.14 (Improving air quality) and

5.3 (Sustainable design and construction) of the London Plan.

10 Delivery and Servicing Plan

No development shall take place until a Delivery and Servicing Plan (DMP) has been submitted to and approved in writing by the Local Planning Authority. The development shall be carried out in accordance with the approved details. The DMP shall cover as a minimum:

- Full details of the management of the bollard and the vehicles permitted to access the through route off Park Road.

- Full details of the refuse strategy.

Reason: In the interests of road safety, in accordance with Hounslow Local Plan Policy EC2.

11 Car Park Management Plan

Prior to the occupation of the development, a Car Park Management Plan shall be summited to and approved in writing by the Local Planning Authority. The development shall be carried out in accordance with the approved details.

Reason: In the interests of road safety, in accordance with Hounslow Local Plan Policy EC2.

12 Cycle Storage

Prior to the completion of the frame of any building, details of the provision to be made for cycle parking, including which cycle stores will be allocated to which blocks (relating to the number of dwellings in each block), shall be submitted to and approved in writing by the Local Planning Authority. The cycle parking shall be provided in accordance with the approved details before the residential units are occupied and shall thereafter be retained solely for its designated use. Reason: To ensure that secure cycle spaces are provided and retained for the occupiers of the residential accommodation, in accordance with Hounslow Local Plan Policy EC2 and London Plan Policy 6.9.

13 Waste and Recycling

(A). Development shall not commence (except demolition, archaeological investigations, ground condition investigations and intrusive site surveys and other enabling works: site clearance; soil storage; remedial works in respect of any contamination or any other adverse ground conditions; erection of any temporary means of enclosure and land raising) until a scheme for the storage and collection of waste and materials to be recycled in that Residential Block has been submitted to and approved by the Local Planning Authority. (B). No Block shall be occupied until the waste and recycling facilities approved under Part (A) of this condition have been provided and

made available for use by residents of that Block. Such facilities shall remain throughout the lifetime of the development and shall be used for no other purposes. Reason: To ensure that refuse can be properly stored and removed from the site as soon as the building is occupied in accordance with Local Plan Policies CC1, CC2 and EQ7.

14 Accessible and Adaptable Units 90% of residential units shall meet M4(2) Building Regulations as shown on the hereby approved plans. Reason: To ensure a socially inclusive and sustainable development in accordance with Local Plan Policy SC5 and policies 3.5 (Quality and design of housing developments) and 7.2 (Creating an inclusive environment) of the London Plan.

15 Wheelchair Housing Units A minimum 10% ‘Wheelchair User Dwellings’ built to Building Regulations M4(3) standard shall be provided. Reason: To ensure a socially inclusive and sustainable development in accordance with Local Plan Policy SC3 and policies 3.5 (Quality and design of housing developments) and 7.2 (creating an inclusive environment) of the London Plan.

16 Residential Acoustic Design Strategy (A). No development (except demolition, archaeological investigations, ground condition investigations and intrusive site surveys and other enabling works: site clearance; soil storage; remedial works in respect of any contamination or any other adverse ground conditions; erection of any temporary means of enclosure and land raising) shall take place until a scheme of acoustic insulation and any other necessary means of ventilation provided, taking into consideration the recommendations of the Noise Impact Assessment dated February 2016 by Acoustic Plus, is submitted to and approved by the Local Planning Authority. Such a scheme shall include details of measures to ensure the residential accommodation does not exceed the ‘good’ limits contained in BS8233. Any works that form part of such a scheme shall be completed as approved before any part of the development within the relevant phase is first occupied. (B). Prior to the development being occupied, sound insulation test reports demonstrating compliance by that Phase with the scheme approved under Part A of this condition, shall be submitted to and approved in writing by the Local Planning Authority. Reason: To ensure satisfactory environmental conditions for the

occupiers of the proposed building in accordance with Local Plan Policy EQ5.

17 Energy Statement 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 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 first occupation of the building(s) evidence (e.g. photographs, installation contracts and As-Built certificates under the Standard Assessment Procedure should be submitted to the Local Planning Authority and approved in writing 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.

18 Water Efficiency Prior to construction, evidence will be submitted to the Local Planning Authority and approved in writing to demonstrate that the internal water consumption of the development will not exceed 105 litres/person/day in line with The Water Efficiency Calculator for new dwellings from the Department of Communities and Local Government. Prior to first occupation of the building(s) evidence (schedule of fittings and manufactures literature) should be submitted to the Local Planning Authority and approved in writing to show that the development has been constructed in accordance with the approved internal water use calculations. Reason: in order to protect and conserve water supplies and resources in accordance with London Plan Policy 5.15 and the London Borough of Hounslow Local Plan Policy EQ2.

19 Sustainable Materials Prior to first occupation of the building(s), evidence shall be submitted to the Local Planning Authority and approved in writing to show that the residential development has been constructed with materials that have secured the following sustainability standards:

(A) At least three of the key elements of the building envelope (external walls, windows roof, upper floor slabs, internal walls, floor finishes/coverings) achieve a rating of A+ to D in the Building Research Establishment’s (BRE) ‘The Green Guide of Specification’. (B) At least 50% of timber and timber products are sourced from accredited Forest Stewardship Council (FSC) or Programme for the Endorsement of Forestry Certification (PEFC) schemes. (C) No construction or insulation materials are 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.

20 Surface Water Run-Off (Details) Prior to commencement of works (except demolition, archaeological investigations, ground condition investigations and intrusive site surveys and other enabling works: site clearance; soil storage; remedial works in respect of any contamination or any other adverse ground conditions; erection of any temporary means of enclosure and land raising), final detailed drainage designs (including drawings, calculations and an updated Drainage Assessment Form) shall be submitted to and approved by the Local Planning Authority, in consultation with the Lead Local Flood Authority, which demonstrate the surface water drainage and flood risk management proposals for the site will aim to restrict runoff rates to no more than the greenfield runoff rate, for all storm events up to and including the 1 in 100 year plus climate change (40%) return period, through the use of a sustainable drainage system including rainwater harvesting and above ground landscaped features. Evidence must be submitted to confirm Thames Water’s approval for the detailed proposals. An associated detailed maintenance plan for each drainage feature component proposed must also be submitted and must include all routine maintenance tasks (including frequencies) and confirmation of the body/bodies responsible for undertaking the maintenance. 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.

21 Surface Water Run-Off (Installation)

Prior to first occupation of any part of the development, the applicant must submit for review and approval by the Lead Local Flood Authority evidence that the drainage system has been built as per the final detailed drainage designs through the submission of photographs and copies of installation contracts, and written confirmation that the drainage features will be managed as per the detailed maintenance plan for the lifetime of the development. Reason: To ensure that the methods to mitigate the risk of surface water flooding have been constructed as agreed and that the drainage system is suitably managed.

22 Archaeology (Historic England)

No demolition or development shall take place until a written scheme of investigation (WSI) has been submitted to and approved by the local planning authority in writing. For land that is included within the WSI, no demolition or development shall take place other than in accordance with the agreed WSI, which shall include the statement of significance and research objectives, and A. The programme and methodology of site investigation and recording and the nomination of a competent person(s) or organisation to undertake the agreed works B. The programme for post-investigation assessment and subsequent analysis, publication & dissemination and deposition of resulting material. This part of the condition shall not be discharged until these elements have been fulfilled in accordance with the programme set out in the WSI. Reason: The area is the site of archaeological interest and the Local Planning Authority would wish to protect the site from any damage which might occur whilst carrying out the development hereby permitted.

23 Ecology Prior to the completion of the frame of any building, a Biodiversity Enhancement Strategy, incorporating the recommendations of the Ecological Assessment dated February 2016 by Ecosa, shall be submitted to and approved in writing by the Local Planning Authority. The approved Biodiversity Enhancement Strategy shall be implemented as far as relevant prior to any building within that phase being first occupied. Any enhancement measures shall be maintained throughout the lifetime of the development or in accordance with the strategy set out in the Landscape Management Plan. Reason: To promote biodiversity and ecological enhancements to the site and surrounding area in accordance with Local Plan policies CC1, CC2 and GB7 and Policy 7.19 of the London Plan.

24 External Plant (Approved)

Any fixed external plant shall be designed and installed to ensure that noise emanating from such plant is at least 10dB below the background noise levels when measures from the nearest sensitive receptors. Plant shall be set in from the roof boundaries by a minimum of 2m. No further fans, louvres, ducts or other external plant shall be installed without the written prior approval of the Local Planning Authority. Reason: To protect the amenities of existing and future residents and ensure that the development provides a high quality design in accordance with Local Plan policies CC1, CC2 and EQ5.

25 External Plant (Additional)

Prior to installation, details of any external ventilation equipment for any Phase, including ducting and any necessary noise attenuation measures, shall be submitted to and approved in writing by the Local Planning Authority. The works shall then be carried out in accordance with the approved details before that Phase is first occupied. Reason: To protect the amenities of existing and future residents and ensure that the development provides a high quality design in accordance with Local Plan policies CC1, CC2 and EQ5.

26 Dewatering Methodology (Natural England)

During the course of the development, the Local Planning Authority shall be notified immediately if higher volumes of groundwater are encountered during basement excavations. A competent person shall assess the higher volumes of groundwater, shall consult with Natural England and submit appropriate amendments to the dewatering methodology in writing to the Local Planning Authority for approval in writing before any work on that aspect of development continues. Reason: To protect features of special interest for which Syon Park SSSI is notified.

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 Supporting notes for Condition 8: 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. Subsequently remediation and verification reports for works identified during

the site investigation have also been submitted. However further site investigation was carried out on site and identified additional remediation works are required. The scheme for decontamination shall provide details of how each potential pollutant linkage will be made safe.

b. In some instances the LPA may require work on site to be ceased whilst the nature of additional contamination is investigated fully.

c. The validation report shall revisit the site conceptual model/additional works identified, 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.

d. 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.

3 The written scheme of investigation will need to be prepared and

implemented by a suitably qualified professionally accredited archaeological practice in accordance with Historic England’s Guidelines for Archaeological Projects in Greater London. This condition is exempt from deemed discharge under schedule 6 of The Town and Country Planning (Development Management Procedure) (England) Order 2015.

4 We collect the Mayor of London’s Community Infrastructure Levy (CIL) at the rate of £35 per sq.m of new floor space. Hounslow’s Community Infrastructure Levy (CIL) came into force on the 24th July 2015. 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.pdf

5 This development is liable to pay the Community Infrastructure Levy. A Liability Notice will follow shortly. For further information please view our CIL web page: http://www.hounslow.gov.uk/index/environment_and_planning/planning.htm or the planning portal web page: http://www.planningportal.gov.uk/wps/portal

6 If you are creating a new unit, please visit http://www.hounslow.gov.uk/index/transport_and_streets/roads_and_highways/street_naming_numbering.htm and complete the Street Naming and Numbering application form.

Drawing Numbers: 012_PL_001, 012_PL_002, 012_PL_003, 012_PL_011, 012_PL_100, 012_PL_101, 012_PL_102, 012_PL_103, 012_PL_105, 012_PL_106, 012_PL_110, 012_PL_111, 012_PL_112, 012_PL_113, 012_PL_114, 012_PL_115, 012_PL_116, 012_PL_120, 012_PL_121, 012_PL_122,

http://www.hounslow.gov.uk/community_infrastructure_levy_preliminary_draft_charging_schedule_march_2013.pdf

http://www.hounslow.gov.uk/community_infrastructure_levy_preliminary_draft_charging_schedule_march_2013.pdf

http://www.hounslow.gov.uk/index/environment_and_planning/planning.htm

http://www.hounslow.gov.uk/index/environment_and_planning/planning.htm

http://www.planningportal.gov.uk/wps/portal

http://www.hounslow.gov.uk/index/transport_and_streets/roads_and_highways/street_naming_numbering.htm

http://www.hounslow.gov.uk/index/transport_and_streets/roads_and_highways/street_naming_numbering.htm

012_PL_123, 012_PL_201, 012_PL_202, 012_PL_301, 012_PL_302, 012_PL_303, 012_PL_304, 012_PL_305, 012_PL_306, 012_PL_307, 012_PL_308, 012_PL_309, 012_PL_310, 012_PL_311, 012_PL_312, 012_PL_313, 012_PL_314, Design and Access Statement dated February 2016, Air Quality Assessment dated February 2016, Arboricultural Report dated February 2016, Drainage Strategy dated February 2017, Energy Statement dated February 2016, Historic Environment Assessment dated February 2016, Statement of Community Involvement dated February 2016, Ecological Assessment dated February 2016, Geo-environmental and Geo-technical Assessment (Ground Investigation Report) dated February 2016, Noise Impact Assessment dated February 2016, Transport Assessment dated February 2016. Received: 23/02/2016. 012_PL_004 Rev. B. Received: 08/03/2016. Planning Statement dated February 2016. Received: 09/03/2016. LBH Drainage Clarification dated 30th March 2017. Received: 12/04/2017. Long Term Storage Calculations – Excess Volume. Received: 12/05/2016. Viability Assessment Report dated 28 April 2016. Received: 20/05/2016. Transport Response Note dated 22nd June 2016. Received: 01/07/2016. A Written Scheme of Investigation for an Archaeology Evaluation dated September 2016. Received: 24/09/2016. SUDS Maintenance Schedules. Received: 18/10/2016. Archaeological Evaluation Report dated October 2016. Received: 13/01/2017. Syon Park Projects Enabling Development Case dated 1 January 2017. Received: 14/02/2017.