References: 01106/B/P137 P/2020/3100

Address: Tesco Osterley, Syon Lane, TW7 5NZ

Proposal: Outline planning application with all matters reserved except access for the demolition of existing building and car park and erection of buildings to provide residential homes, plus flexible non-residential space comprising commercial, business and service space, and/or learning and non-residential institution space, and/or local community space, and/or public house/drinking establishment, and/or a mobility hub, along with associated access, bus turning, car and cycle parking, and landscaping arrangements.

This application has been referred to Planning Committee as major planning application that would require a legal deed if approved, and due to significant public interest.

Application received: 22 September 2020

1.0 SUMMARY

1.1 The application proposes the redevelopment of the Tesco Osterley site with a residential –led mixed-use proposal, comprising up to 1,677 homes (35% affordable), flexible non-residential uses and new public spaces. The proposal includes a series of tall buildings that range in height from 2 to 17-storeys. The proposal also includes residential parking, landscaping, public open space, and areas of new public realm. This application seeks outline planning permission.

1.2 The proposal is integrally linked with a concurrent planning application for the redevelopment of the existing Homebase site which is nearby with a mixed-use proposal providing a large format retail store and 473 homes, of which 164 are affordable. Relocation of the existing Tesco supermarket to the Homebase site would enable the comprehensive development of the Tesco site and together the schemes are a major strategic regeneration opportunity for the Borough.

1.3 The mixed-use, high density proposal is consistent with objectives promoting the regeneration of the Great West Corridor Opportunity Area through optimising use of previously developed land with new, high quality buildings, the delivery of new high-quality publicly accessible squares and open spaces and public realm including new and improved footpaths and cycleways.

1.4 The scheme optimises the use of an existing under-utilised site and provides new housing and commercial uses, which will help to meet the strategic housing need in the borough, including the provision of affordable housing, and will promote and sustain local economic activity and employment.

1.5 The proposal includes up to 1,677 new homes, which equates to over 9% of the minimum housing requirement for the Borough over the next ten years (17,820, 1,782 per annum). This is a very significant contribution towards meeting the strategic housing need in the borough. 35% of the new homes would be affordable equating to over 500 new affordable homes for the Borough. The proposal also

includes new employment opportunities, and is highly sustainable achieving a minimum 60% reduction in emissions over Building Regulations Part L compliant baseline.

1.6 The development would transform the site and deliver a high quality residential-led scheme, with active ground floor uses and new public spaces, within a landscaped setting. The height and massing of buildings has been moderated to be smaller towards more sensitive neighbouring development. The proposed development is submitted on the basis of a series of Parameter Plans that set the physical framework including plot locations, the positions and maximum heights of buildings, the location of different uses, the location of public open spaces and public realm and the network of routes through the site for vehicles, pedestrians and cyclists.

1.7 Owing to the step change in the overall height and massing of the buildings proposed, the development will significantly change the character of the area and there are some harmful impacts to the significance of certain heritage assets through change to their setting. In respect of the significance of the harm identified to heritage assets, officers consider this is to be less than substantial harm, though this does not mean that less than substantial weight should be afforded to that harm. The government’s advice is that where a development proposal will 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.

1.8 The scale of the development and number of new dwellings also has some adverse implications for the local environment, through increased noise and disruption in the area, especially during construction and there would be some adverse effects on some neighbours from overshadowing though in general environmental impacts on the surrounding area are acceptable and would be able to be mitigated through conditions and obligations.

1.9 Expected transport impacts are acceptable with the proposal significantly improving conditions for walking and cycling in the area, aiding the transition to more sustainable travel, whilst the effects on the highway network from traffic and parking impacts are considered satisfactory, with the cumulative car parking numbers across the Homebase and Tesco Sites being substantially reduced from the existing parking provision. New and improved bus infrastructure would be provided on site to replace the existing, and contributions towards improved bus services, in addition to major junction and public realm improvements are proposed.

1.10 Appropriate, relevant, reasonable and necessary planning conditions and planning obligations are proposed to ensure that the development is acceptable in planning terms and the environmental, and socio-economic impacts are mitigated.

1.11 As such the proposal has the potential to result in major benefits to the economic, social and environmental well-being of the area, consistent with its inclusion in the Great West Corridor Opportunity Area in the London Plan and as a location for significant housing and employment growth as set out in the Hounslow Local Plan, and the emerging Great West Corridor Local Plan Review.

1.12 Given the harmful effects of the development, it is necessary to consider the public benefits of the scheme, to consider if these outweigh the harm. Importantly, where a

proposed development would harm designated heritage assets such as the setting of a listed building, garden or the character or appearance of a conservation area, the harm must be given considerable importance and weight and there is a strong presumption against planning permission being granted unless this harm is outweighed by other material planning considerations of sufficient significance and weight to do so.

1.13 Taking all these matters into account, and balancing the benefits of the development against the harm, approval is recommended, as the positive social, economic and environmental impacts would outweigh the harmful effects of the development.

1.14 Following the Council’s decision, the application must be referred to the Mayor of London for him to determine whether he is content for the Council to determine the application, direct its refusal, or if he wishes to determine it himself.

2.0 SITE

2.1 The application site “the Site” is an irregular shaped plot with an area of approximately 5.45 hectares. It is located on the north side of Syon Lane, and the west of Grant Way. The site encompasses part of Macfarlane Lane and an area of land on the west of MacFarlane Lane backing onto the properties on Oaklands Avenue.

2.2 At present the site contains a three storey supermarket building at the north of the site, with the south and west of the site utilised for car parking. The existing building has a floor area of 11,582 sqm, overall there are 625 parking spaces. A single storey petrol filling station is positioned at the south of the site and a car wash area and associated buildings are at the east of the site. At the north-eastern end of the site is a landscaped garden area known as the Water Garden which provides a public pedestrian link between Grant Way and MacFarlane Lane. Trees and shrubs are found along the frontages of the Site with Syon Lane and Grant Way. Vehicular access is from Syon Lane via a roundabout.

2.3 Oaklands Avenue and Gower Road to the west of the site, as well as the residential streets of Stags Way, Wyke Close and Crowntree Close on the southern side of Syon Lane are part of the Wyke Estate Controlled Parking Zone (“CPZ”) with resident permit holder parking only on Monday-Friday between 9.30am to 5.30pm.

2.4 Syon Lane station is located approximately 600m to the southeast of the site, across the A4 with access from Syon Lane. This railway operates services to London Waterloo with 4 direct services an hour on weekdays. Osterley station (Piccadilly Line) is around 1.9km to the west on the A4. Various bus services are located within walking distance of the site including the H28 providing a route to West Middlesex Hospital, Hounslow town centre and Cranford, and the H91 a route to Osterley Station and Hammersmith. The Site includes a bus stop and stand for the H28 bus route. The existing Public Transport Accessibility Level (“PTAL”) of the Site is 2 on a scale of 0-6b, where 6b is highest, which is poor.

Figure 1: Application site

2.5 The Site is not allocated in the Hounslow Local Plan (“HLP”). It is identified as having

previous industrial history. The part of the Site located on the western side of MacFarlane Lane is located within The Osterley Park Conservation Area. There are no Listed Buildings on the Site itself.

2.6 The current London Plan (“LP”) identifies the Site and wider area along the A4/M4 corridor (Great West Corridor) as an ‘Opportunity Area’ with future opportunities for intensification and employment and housing growth, as well as transport and environmental improvements.

Surrounds

2.7 The locality has a mix of uses including commercial and residential development. There are two-storey semi-detached houses on the southern side of Syon Lane, opposite the site, as well as to the west along both Syon Lane and Oaklands Avenue. There is also a small shopping parade on Syon Lane.

2.8 To the north of the site lies an area of Metropolitan Open Land and Sports Ground hosting the Goals Soccer Centre and Grade II listed Centaurs RFC Pavilion and Club House building. The new Bolder Academy School would be located to the north at the end of MacFarlane Lane. To the north-east and east lies the Sky Campus.

2.9 Further to the North East lies Osterley Park, the latter being a Grade II* registered park with listed buildings and forming part of the Osterley Park Conservation Area and designated as MOL.

2.10 Immediately to the east of the Site, extending along Syon Lane is the landmark Gillette Factory, a large 1930s brick factory and office building with a tall brick clocktower. This building is Grade II listed. Adjacent and nearby are other listed buildings and structures including the former Natwest Bank building (Grade II), lamp standards and phonebox/ kiosk . Further east lies commercial and industrial development and the Great West Road. Commercial buildings including a number of Art Deco style listed buildings are found along the Great West road heading east

2.11 To the south of the Gillette building and on the opposite side of the Great West Road is the Homebase site. Other development on the north side of the Great West Road includes a former office complex, ‘New Horizons Court’ which is being converted to housing under permitted development, and commercial buildings including the Sky Campus.

2.12 Syon Park, a Grade I registered park and garden with many listed buildings and designated as Metropolitan Open Land (“MOL”), lies to the south of London Road, around 1km away, with the listed Syon House set within. This area is part of the Isleworth Riverside Conservation Area. Further south, across the Thames around 1.7km to the southeast of the site is the Royal Botanic Gardens at Kew, a World Heritage Site (“WHS”). Part of the WHS buffer zone includes Syon Park.

Emerging Planning Framework

2.13 The Site is allocated for development in emerging Hounslow Local Plan review (‘Site Allocations – Local Plan Review Volume 2 Submission’, September 2020). The allocation proposes a mixed-use development with new housing and small retail with an enhanced public realm. The minimum quantum of development is:

Retail and Business – (540 sqm) Housing – 1,030 homes

3.0 PLANNING HISTORY

Application Site

3.1 The site was open fields, until the Imperial Biscuit Works was built in 1931 and it remained an industrial site until the existing Tesco building was built in the 1990s. Planning permission 01106/B/P82 was granted in 1993 for the demolition of existing offices and erection of 70,000 ft2 superstore (Tesco), petrol station, access road, servicing and highway alteration and car park. Since it was built there have been various consents for minor alterations and advertisements at the Site.

Significant Development Proposals on Nearby Sites

3.2 Gillette Factory – Gillette ceased production of products in 2006 and subsequently sold their building. In 2007 planning permission (00505/AP/P74) was granted for the comprehensive redevelopment of the site with the conversion and extension of the main building to a 505 room hotel with ancillary conference facilities, 624 parking spaces and new buildings to the rear and fronting the Great West Road (4 to 6-storey) for office and light industrial; use. This permission was extended in 2010 for a

further three years but it was not implemented and it has expired. The building is currently used for film production.

3.3 Sky Campus – The Sky campus lies to the north of the site, this was originally approved under 00558/A/P51 which granted approval for an Outline application for the demolition of existing buildings and structures and the development for a media broadcasting and production campus of up to 104,670 sq m (GIA) (now reduced to 95,934 sq m - excluding parking floorspace) comprising office (Class B1a), studio production and research and development facilities (Class B1b) and warehouse/storage (Class B8); hard and soft landscaping; reconfigured and new vehicle and pedestrian accesses and works to the public highway; the provision of parking; and all necessary ancillary and enabling works, plant and equipment. There have been numerous applications since for reserved matters and alterations, the most pertinent are:

00558/A/P64 - Variation of condition 7 (approved plans) to allow for B8 use within Parcel D, reallocation of parking and changes to Parcel D height parameters along with pedestrian and vehicular access and accessible space to planning permission dated 2 April 2015 for Section 73 application seeking a minor material amendment to planning permission 00558/A/P55 which granted approval for a section 73 application seeking minor material amendment (reduce site boundary, reduction of B1 floor space, reallocation of parking, changing position of link road and changes to parameters of plots) to planning permission 00558/A/P51 which granted approval for an Outline application for the demolition of existing buildings and structures and the development for a media broadcasting and production campus of up to 104,670 sq m (GIA) (now reduced to 95,934 sq m - excluding parking floorspace) comprising office (Class B1a), studio production and research and development facilities (Class B1b) and warehouse/storage (Class B8); hard and soft landscaping; reconfigured and new vehicle and pedestrian accesses and works to the public highway; the provision of parking; and all necessary ancillary and enabling works, plant and equipment

00558/A/P69 - Reserved matters (layout, scale, access, landscaping and appearance for Parcel F) application for the erection of two buildings comprising a single storey pavilion and a ground plus three storey building office and ancillary food and beverage with associated landscaping, servicing, plant and all ancillary enabling works within Parcel F following approval of an outline application ref 00558/A/P64 dated 18/08/2015 for variation of condition 7 (approved plans) to allow for B8 use within Parcel D, reallocation of parking and changes to Parcel D height parameters along with pedestrian and vehicular access and accessible space to planning permission dated 2 April 2015 for Section 73 application seeking a minor material amendment to planning permission 00558/A/P55 which granted approval for a section 73 application seeking minor material amendment (reduce site boundary, reduction of B1 floor space, reallocation of parking, changing position of link road and changes to parameters of plots) to planning permission 00558/A/P51 which granted approval for an Outline application for the demolition of existing buildings and structures and the development for a media broadcasting and production campus of up to 104,670 sq m (GIA) (now reduced to 95,934 sq m - excluding parking floor space) comprising office (Class B1a), studio production and research and development facilities (Class B1b) and warehouse/storage (Class B8); hard and

soft landscaping; reconfigured and new vehicle and pedestrian accesses and works to the public highway; the provision of parking; and all necessary ancillary and enabling works, plant and equipment.

3.4 Former Syon Gate Service Station, Land at South of Gillette Corner, Great West Road – A proposal for a mixed-use development of the former petrol station site, providing 102 homes and self-storage in a building of between 4 to 11-storeys was refused permission in 2017 (00505/AF/P27). Reasons for refusal were its harmful effect on the character of the area and setting of heritage assets and an unacceptable affordable housing offer. Planning permission (00505/AF/P28) was subsequently granted in 2020 for a new building for self-storage and office use, of up to five-storeys (36.3m – 37.65m AOD), and 25 car parking spaces.

Homebase Site Planning Application

3.5 The proposal is integrally linked with a concurrent planning application for the redevelopment of the existing Homebase site which is nearby (00505/H/P19). That scheme proposes a mixed-use proposal providing a large Supermarket (which is a replacement for the existing Tesco store) and 473 homes. The new homes would sit above a podium containing the supermarket and car park, in a series of tall buildings that range in height from 4 to 17-storeys. There are also small community and retail spaces, as well as residential parking, landscaping and areas of new public realm.

3.6 The relocation of the existing Tesco supermarket to the Homebase Site would enable the comprehensive development of the Tesco site.

4.0 PRE-APPLICATION PROCESS & CONSULTATION

Planning Performance Agreement

4.1 The Council and applicant entered a Planning Performance Agreement (“PPA”) in 2019. The agreement sought to provide pre-application advice to assist the preparation of an application and establish key issues and procedural requirements. The process did not involve a full assessment of the proposals and comments made were without prejudice to formal consideration of any planning application.

4.2 The PPA meetings identified the main issues to be considered, including the townscape and heritage impacts, transport and parking impacts, walking and cycling improvements, environmental issues, affordable housing and housing quality, infrastructure, and impacts on neighbours. The applicant also consulted the Mayor of London and Transport for London during this process.

4.3 The PPA confirmed an Environmental Impact Assessment (“EIA”) was required, and the Council issued a formal Scoping Opinion on the applicant’s EIA Scoping Report on 11 October 2019.

Community consultation

4.4 The applicant has undertaken pre-application consultation comprising public exhibitions, newsletter drops, online surveys and meetings with local stakeholders. The latter included establishing a ‘community liaison group’ (CLG) comprising of residents from local community groups and interested residents. Early on in the

process, an architects selection panel was held with the local community for the Osterley site in October 2019, as well as door knocking & two walk & talk events in November 2019 to understand residents aspirations for the sites & surrounding area.

4.5 Separate consultation has been carried out directly with:

Greater London Authority

Transport for London

Historic England

Hounslow Chamber of Commerce

North West London Clinical Commissioning Group

Nishkam School

4.6 The applicant held three public consultation events, advertised as ‘drop in’ consultations with information posted on local websites, in the local newspaper and via 3,500 flyers distributed locally. Key members of the applicant’s design team including architects attended to explain the scheme. The dates of the physical consultation events, which were all held at the Marlborough Primary & Nishkam Schools are as follows:

1st Consultation Event: 3rd & 8th October 2019

2nd Consultation Event: 27th and 29th February 2020

3rd Consultation (Virtual): Two weeks between 14 August and 28 August.

4.7 Alongside the exhibition events, a number of other consultation events were undertaken:

Introductory presentation to ward councillors and residents groups

Walk & talk sessions

Door knocking

Establishment of CLG

Community Christmas events & Pop-Up stalls

Regular updates through community newsletters & website updates

Engagement with local schools and youth groups

4.8 The application undertook three rounds of online surveys in conjunction with the public exhibition events; The first round of took place in October 2019 with the second round taking place in February 2020 & with the final feedback round in October 2020. Each round lasted for three weeks and generated over 3,500 pieces of detailed feedback.

4.9 For the established Community Liaison Group, ‘CLG’ and held regular meetings; a total of eight local residents and seven local organisation groups joined the CLG. Between December 2019 and August 2020 Six CLG meetings were held, each focusing on a different discussion topic, Dates for these are as follows:

CLG 1: Community and Local Identity 6th December 2019

CLG 2: Traffic and Transport 17th December 2019

CLG 3: Open Space & Plan 14th January 2020

CLG 4: Public Exhibition Preview 25th February 2020

CLG 5: Architecture and Landscape 18th June 2020 (VIRTUAL)

CLG 6:Pre-Submission Update 13th August 2020 (VIRTUAL)

4.10 Alongside these formal consultation events, the applicant undertook a number of community activities; in December 2019 St Edward hosted two community Christmas events (a Christmas Film screening event and Santa’s Grotto at the Tesco store) and in October & November 2020 pop-up coffee stalls were held at the Tesco store to engage with local residents and interested parties. There was also a programme of youth engagement in February 2020, running skills and CV workshops with Nishkam School and Hounslow Youth Council.

4.11 Information was sent to local ward members and the Planning Committee. A proposal was presented to members of the Planning Committee for comments by the developer at the ‘Planning Development Proposals Forum’ on 28th July 2020.

5.0 DETAILS OF THE PROPOSAL

5.1 The application seeks outline planning permission for the redevelopment of the site to provide a mixed use residential led scheme comprising up to 1,677 homes, flexible non-residential space, a bus turnaround, publically accessible open space and associated car and cycle parking, refuse stores and plant. All matters are reserved except access.

5.2 The proposed development comprises:

- Demolition of existing buildings and structures - Up to 1,677 homes (use Class C3), with 35% affordable housing by unit - Between 3,000 and 5,000 sqm flexible non-residential floor space - Minimum of 20,000 sqm publically accessible open space - Minimum of 8,000 sqm of communal amenity space - Minimum of 5,000 sqm play space - Enhancements to the existing Water Gardens, including retaining a public

route - Up to 400 car parking spaces (including 10 car club bays and electric vehicle

charging points) - Cycle parking - A new bus turning facility and welfare facilities - A mobility hub - All ancillary infrastructure (including an energy centre) and hard/soft

landscaping - Buildings between 2 and 17 storeys (to a maximum height of 79.8 metres

AOD).

5.3 The development comprises 9 development plots that will accommodate new buildings ranging in height from 32.5m AOD (approx. 2 storeys) to 78.9m AOD (approx. 17 storeys). There would also be a single storey mobility hub. The proposals include provision for basements in the development parcels, these would provide ancillary areas there would be no habitable accommodation within the basements. The basements would be limited to 19.3m AOD. The arrangement of the development parcels across the Site is shown below:

Figure 2: Maximum Development Parcels

5.4 The proposed maximum heights, with indicative storey heights are shown in the table below:

Block Maximum Heights (m AOD) Indicative Number of storeys

A +32.5 to +73.9 2-15

B +64.1 to +70.4 10-14

C +32.5 to +56.6 2-9

D +32.5 to +56.1 2-9

E +43.5 4-5

F +43.2 to +58.9 5-10

G +63.6 to +73.0 12-15

H +32.5 to +79.8 2-17

J +32.6 2

Mobility hub

(1 or 2)

+27.3 1

Table 1: Proposed Maximum Building Heights

5.5 The maximum heights include rooftop plant and lift overruns.

5.6 The floor areas for the proposed uses are shown in the table below.

Land Use Area sqm (GIA*)

Residential (C3)

(excluding ancillary facilities)

146,700

Shops, financial and professional services, cafes and restaurants, (E) Public house/drinking establishment (sui generis)

1,000 min.

Business, research and development (E)

1,000 min.

Healthcare, gym, leisure, community, crèche (E)

1,000 min.

Total 149,700

Table 2: Proposed Uses *Gross Internal Area

5.7 The application proposes up to 1,677 homes in a mix of studio, one, two, three and four bedroom flats and houses. Overall, the development will provide 35% affordable housing.

5.8 The application has been submitted for outline permission. The parameter plans provide details of the maximum scale, massing and footprint proposed and are supported by a development specification document which sets maximum and minimum limits on the quantum of development, as well as confirming other key elements such as housing tenures, residential quality, open space, play space and other transport and environmental standards which would be achieved by future Reserved Matters Applications. A Design Code has also been submitted which sets out mandatory requirements and further guidance for the later detailed design of the scheme.

5.9 The Environmental Statement that has been submitted in conjunction with this application tests the parameter plans to ensure that the worst case scenario, in terms of environmental effects, is tested.

5.10 As all matters are reserved except means of access, an illustrative masterplan has been shown in the supporting documents to demonstrate the type of scheme that would be compliant with the maximum parameter plans. This has been used to enable testing of the proposed residential quality.

5.11 The Illustrative scheme shows how 1,623 homes could be distributed across nine blocks ranging from two to seventeen storeys in height. The lowest height (2 storeys) will be located along the west side of McFarlane Lane with a terrace of houses (Block J), blocks proposed along the southern boundary of the site will be 2-9 storeys in height. The height of the blocks will step up through the site towards the north and along other strategic points. The tallest seventeen storey block will be located towards the centre of the site.

Figure 3: Illustrative masterplan

5.12 The illustrative masterplan shows how the scheme could deliver 1,623 homes within the scope of the parameter plans and design code, and is just one possible manifestation of the scheme.

Access

5.13 Access is the single matter submitted in detail at this stage with all other matters being reserved, therefore details of the means of access from the public highways into the site have been submitted by the applicant. For the avoidance of doubt the detailed design of internal roads and access to individual plots and buildings will come forward as part of the corresponding reserved matters application.

5.14 The main point of access to the site will be from Syon Lane to the south of the site. The existing roundabout would be removed and this new access would be the primary vehicle access to the application site, a connection to McFarlane Lane will be provided in the north west corner of the site however this would be restricted to refuse vehicles.

5.15 A new bus turning facility, bus stops and stands will be provided for the E1 and H28 routes, as well as bus welfare facilities.

Environmental Impact Assessment

5.16 The application includes an EIA. Before determining the application the Council must consider the environmental information contained in the Environmental Statement (“ES”), including the further information submitted, as well as representations from consultees about the environmental effects of the development.

5.17 The ES assesses likely environmental impacts from the development including its construction and operation, cumulative impacts from other ongoing developments including the proposals for the Homebase site. The ES identifies the existing (baseline) environmental conditions, and the likely environmental impacts (including magnitude, duration, and significance) and also identifies measures to mitigate any adverse impacts. A summary of potential positive and negative residual effects remaining after mitigation measures is also given.

5.18 The ES itself does not necessarily consider compliance with planning policies and so planning permission does not have to be granted or refused based on its findings, but these are material considerations. Where significant adverse effects are found, consideration will need to be given to mitigation proposed and then ultimately to whether the remaining impact warrants refusal or if such harm is outweighed by other benefits.

5.19 The ES contains analysis of impacts for the following topics:

• Alternatives and Design Evolution • Demolition and Construction • Socio-Economics • Transport and Accessibility • Air Quality • Noise and Vibration • Wind Microclimate • Daylight, Sunlight and Overshadowing • Townscape and Visual Effects • Built Heritage

• Cumulative Effects • Summary and Residual Effects

5.20 Officers are satisfied the ES (taken together with the other application documents) has adequately considered the potential environmental impacts of the development.

5.21 An Environmental Statement Addendum was submitted in January 2021, to reflect amendments made to the application following consultation which resulted in revisions to the parameter plans, development specification and design code. The structure of the addendum follows that of the original ES and should be read alongside that document, it clearly highlights where updates have been made to the original document but the conclusions have not been altered. The ES Addendum has adequately considered the potential environmental impacts of the development.

6.0 CONSULTATION

6.1 The application is accompanied with an ES, with publicity and consultation being carried out in accordance with the Town and Country Planning (Environmental Impact Assessment) Regulations 2017 and Planning (Conservation and Listed Buildings) Act 1990.

6.2 A site notice and a press notice advertised the application, and copies of the ES and other application documents were made available on the Council’s website, in accordance with the temporary publicity requirements due to the coronavirus (COVID-19) pandemic.

6.3 Consultation letters were sent to statutory consultees, neighbouring boroughs and local amenity societies, and to over 2,700 properties within the surrounding area.

6.4 The application was included on the Pending Decisions List (20-27 November 2020) sent to ward members of Isleworth and Brentford and to a number of amenity societies and posted on the Council’s website for information. A request to consider the application at Planning Committee was received from Members.

6.5 Following preliminary assessment of the application, further information was provided by the applicant in response to comments from officers and consultees.

6.6 Further site and press notices advertised the application and receipt of further information and a second consultation was undertaken, with letters sent on 25 January to all original consultees and those people that had made a submission.

Responses

1st Consultation

6.7 Apart from responses from statutory consultees and local bodies and amenity groups, there were 506 objections, 1 neutral response and 22 responses in support from individuals.

6.8 2nd Consultation

6.9 There were a further 330 objections, 1 neutral response and 1 response in support from individuals, including responses from people that had already objected.

6.10 Responses from individuals, amenity groups and statutory consultees to the consultations are summarised below.

Objections

6.11 Heritage

Gillette grade 2 building will be dwarfed by buildings up to 17 storeys

these proposals will sandwich grade 2 listed Gillette between 2 large developments and would look ridiculous

Gillette is a key landmark, buildings should not be taller or obscure

Impact on Osterley Park Conservation area.

Negative impact on the heritage character of the area and the heritage buildings nearby

Visual impact seen from the south western parts of Kew Gardens and from the river walk possibly very significant

Substantial harm to the setting of the Royal Botanic Gardens, Kew, which is a World Heritage Site (WHS) and also Grade I Registered, and the Grade I Syon Park which forms part of the buffer zone for the WHS

The development would damage to an unacceptable degree the historic setting of internationally significant ‘Capability’ Brown designs at Syon Park-Kew and the significance of the two landscapes will be compromised by the substantial harm

There is a substantial likelihood of the Kew WHS being put on the ICOMOS At Risk list of WHS

It causes ‘substantial harm’ to the setting of heritage assets , including Gillette building (Grade II)

Would dwarf Syon Clinic (Grade II), Natwest Bank (Grade II)

Harm to views from Osterley Park (Grade II*) and Syon Park (Grade I).

Overwhelm and hide from view ‘Goals Soccer’ Pavilion.

Would dwarf the surrounding heritage assets

Poor relationship to existing heritage

Should not higher than the Gillette Clock Tower which is an iconic landmark

6.12 Design and Townscape

Buildings are too tall for the area and would dominate the skyline

Too big

High-rise buildings are out of keeping with the scale and character of the surrounding suburban houses

The building heights (up to 17-storeys) are excessive and overbearing

Development should be smaller

Loss of visual amenity

Area is know for open space and this will destroy the overall look of the area

Inappropriate and poorly considered

Materials, appearance and general design of the development is out of character

Ugly

Would dramatically change the appearance and character of the area

Design, appearance and materials do not fit the local area

Excessive bulk

Out of character and context

Would be an eyesore, blot on the landscape

Massive overdevelopment

Should be houses, not flats

Houses with gardens and outdoor space are what’s needed

Should be no higher than 4 to 6-storeys

Imposing from pavements and roads, create intimidating approach

Impact on Metropolitan Open Land, on top of previous developments

Need more open spaces rather than buildings

Agree with many of the recommendations from Hounslow’s Design Panel.

Development far exceeds the appropriate density and does not balance the needs of the local area with an improved design

6.13 Environmental and Amenity Issues

Extra people will increase the footprint on the existing ‘green’ space in Osterley, in particular the NT property Osterley Park, only a small part of which is limited access to members or ticket holders. Already this park shows all the signs of overuse. Other such areas in the vicinity offer limited access (Grand Union Canal) or limited space (Boston Manor Park, also already trampled and even vandalised) or are not open to the public. The little ‘water garden’ offered by the developer at ‘Osterley Place’ looks attractive in their picture but is pathetically small and will be crowded with people on a sunny day in summer

Concern with safety/hooliganism/anti-social behaviour from increased population

Increase crime rates

Loss of green space

ruining the surrounding environment and infrastructure

should maintain current living standards for existing residents

The spaces marked out for green space are squashed between high-rise apartment blocks, difficult to know what would be planted with such insufficient light and space

Existing quiet residential area should remain

Harm to the quality of life of the existing neighbouring residents

Disruption from construction activity including dust, unacceptable noise levels, heavy goods vehicle construction traffic

Overlooking and loss of privacy from new housing

Increased air pollution

Increased noise pollution

Adverse health effects from air pollution including asthma

Loss of daylight to neighbours

Loss of skyline

Loss of privacy, daylight and sunlight, particularly to Oaklands Avenue, Syon Lane & possibly Syon Park Gardens

Overshadowing to neighbours

What will the quality of life be for all these thousands of people where the majority are only going to see concrete and little light from their windows?.

What is going to be the impact on mental health and the welfare of families and especially kids living in these crammed flats and spaces?

Worsen air quality

Removal of trees, loss of biodiversity

Concerns over fire safety in tall buildings

Homes are not zero carbon

Use of gas boilers

Not sustainable

No justification for demolishing Tesco and Homebase instead of reuse

Does not meet Zero Carbon targets and Climate Emergency measures

Has nothing been learnt from COVID –people need space

Renewable Energy sources not fully exploited

Concrete foundations and a steel framework constitute significant pasrt of CO2 emissions

Use of carbon off set should not be permitted

Llack of privacy due to close proximity of other blocks of flats

Some areas would be affected by inadequate sunlight and wind.

High rise development is likely to create a wind tunnelling effect

Increased noise, carbon emissions, visitors and traffic pollution, especially during the proposed long construction time,

will have an effect on the limited wildlife in the area and at Osterley Park

Loss of views of horizon over low lying development

Effects on bats

Possible adverse effect on employment at nearby businesses from construction work

6.14 Housing and density

Too many units

Flats are not required in the area

Should be two-storey houses

Too dense; overcrowding

Need family housing

Housing too dense as density is 20 times the rest of the ward

Only 9% are 3 bedroom

46% studio or 1 bed

Overambitious and highly unreasonable

Already overburdened population density off Osterley/Isleworth/Hounslow

Inappropriate type of housing

Amenity space/ gardens, overlooked by blocks of flats

Inadequate area of amenity space for new residents

Some amenity at ground floor but substantial amounts at podium and roof levels

High density will lead to future mental and physical health problems

High density creates more problems than it solves

Not proper affordable housing for local families

Will be bought by investors

Should not increase in population or have smaller units due to coronavirus

Adverse social impact from density

The duty to provide additional homes must not be at the expense of the incumbent population

6.15 Transport

Increased traffic

Traffic generation would exacerbate existing traffic congestion

Gillette Corner, the intersection of Syon Lane with the Great West Road (A4) is already an overloaded and dangerous crossing, much in use by the ambulances to and from West Middlesex Hospital nearby.

The existing rail service at Syon Lane station, though improved with a lift, is full to capacity at rush hour.

Plans for a Golden Mile station close to the SKY TV complex seem unlikely to materialize soon given the loss sustained by TfL as a result of the COVID-19 outbreak. There are no nearby London Underground stations and only one commuter-relevant bus line, the H91 along the Great West Road into London (Hounslow West -- Hammersmith).

Increased congestion at peak hours at Syon Lane, London Road and Gillette corner

Traffic already bad due to schools and Grasshoppers sports ground

Syon Lane is narrow/single carriage road and will not be able to sustain the impact of all the extra cars.

A4 is already notorious for serious accidents.

Area already suffering from traffic of the Great west Road, with pick up and drop off to Nishkam School, building works at Bolder academy and traffic to Tesco

No evidence for claim of reduced traffic

Previous traffic forecasts (Nishkam School) underestimated reality

Not enough public transport

Currently most parents of school children park in the present Tesco carpark – where will they park, will they also be crossing to the new car park or just causing more traffic buildup in Syon Lane.

Loss of Tesco car park as a drop off

Lack of a right turn phase in the traffic lights for southbound traffic approaching the junction from Syon Lane and wanting to turn right into the GWR.

Road safety would be decreased

Inadequate public transport and no new transport proposed

Cars travel at unacceptable/dangerous speeds along Syon Lane, will this continue

The only petrol station left will be Shell causing more problems queuing

Overflow parking in area where it is free

No funding is available for the proposed Southall Rail Link or West London Orbital Link, or improvements to Hounslow Loop or Piccadilly line.

New development should only be considered in the light of Golden Mile station actually being built and not in advance of it

Impact on Syon Lane station that has restricted carriages that can be used due to small platforms; trains too small and infrequent

Lack of parking in the area

Lack of parking for development

No additional bus/train services

Bus and trains are already at capacity and overcrowded

Adverse impact on elderly and families from reduced Tesco store parking

Overspill parking onto neighbouring residential streets including overnight parking in CPZ area

On street parking in locality is already congested

Transport Assessment was carried out prior to local road changes which has led to more congestion especially in rush hours. The TA should be updated to take into account the congestion caused and provide suitable mitigation measures

Impacts from construction traffic on local roads

Reduction in parking for Tesco unacceptable

Bolder academy has not opened yet and will have even more negative impact to the area

6.16 Infrastructure

Lack of sufficient infrastructure; increased need for public transport, schools, hospitals, retail facilities and more.

Nearest High Street is Brentford – people will travel by car

Competition for schools already difficult and will become worse

Primary education provision inadequate

Proposed retail too small for the population

Does not fulfil the requirements of a 15-minute neighbourhood

The density of the residential development will put too great a strain on the transport and social infrastructure of the locality.

Extra 1,100- 1,500 residents cannot be accommodated

Addition of 5,000-6,000 residents on the Tesco site will overwhelm local services, transport and infrastructure

Adverse impact on health services including GPs and West Middlesex hospital

Increased pressure on emergency services

Insufficient school places for new residents

Insufficient GP places for new residents, and pressure on services

No guarantee of doctor’s surgery referred to

GP should be on Homebase Site because of better public transport and parking

Cumulative impacts on infrastructure with Homebase Site proposal

Lack of water supply

What provisions are in place to serve the 1,677 residents with local amenities, green spaces and parking.

Negative impact on social infrastructure and current residents

6.17 Policy and Uses

Existing Tesco is very convenient

Current Tesco very busy, how will it cope with increased population

Additional space should be specified as to purpose.

Contrary to Local Plan policies for design, housing, heritage

Fails to comply with the Council's own Local Plan and Great West Corridor Plan.

There is a need for a swimming pool and gym in the area

No proposal to build a petrol station on the new Tesco site, meaning the Shell garage at Gillette Corner will need to fulfil the needs of a hugely increased number of customers, causing tailbacks and long waiting times

6.18 Other

Inadequate consultation

Publicity material not representative of the proposal and did not show true density and height

Consultation responses ignored

The Council need to consider borough wide development, already substantial development in Brentford area

Community Liasion group wate of time – didn’t take notice of concerns

The applications are not independent, they are connected and cannot proceed without the other

Meaningful consultation has not happened

Support 6.19 Regeneration and Economic Activity

Will boost local economy

Will provide jobs and affordable homes

Create jobs and homes

Pleased with regeneration project

Extra jobs

Investment this development will bring to the local area and the Borough should contribute substantially to the community, particularly welcome given the current economic downturn.

Converting car parks to green spaces, homes and jobs is a fantastic opportunity for the regeneration of the Golden Mile

Will help catalyse the regeneration of the Golden Mile that is critical to the future of our local area.

More green spaces and new commercial hub

Will bring great amenities such as restaurants, coffee shops all of which are needed

As a local business facing the toughest economic climate in decades due to COVID19 we particularly look forward to the employment opportunities arising from the scheme

The exponential rise in unemployment in the Hounslow area will require new investments to create job opportunities in the local area.

The creation of construction jobs will provide much needed apprenticeship opportunities for local people in the construction industry

Employment and Skills Plan to help maximise local employment opportunities and improve local skills levels through school and further education engagement in the local area

6.20 Townscape and Design

Site is currently run down; development can only be beneficial

Having places to gather

Like what Berkeley have done elsewhere in West London

High quality, well designed homes with smart landscaped areas

Enhances the appearance of the locality which currently is dominated by a massive car park and warehouse style building

6.21 Transport and Infrastructure

Improves the junction at Gillette corner

New and safer pedestrian and cycle routes to be delivered

Supporting new local bus routes and delivery of mobility hub

Proposed improvements to the local road network

Improvements to the local roads and other infrastructures that come with the new development will also benefit all sporting venues as well as the Bolder and Nishkam schools

Green and friendly to cyclists.

6.22 Environment and Amenity

Having nice places to go will benefit the area

Better community life

Pleased by the inclusion of some community amenities and provisions

New public open space

A commitment to our green economy supporting carbon positive and sustainable practise from construction to the operational phase

It is very important to insist upon things like LED lights, rain water capture for irrigating gardens, solar panels, wind used to produce power

6.23 Other

Welcome new affordable housing

Much needed new homes

35% affordable housing

Will enhance the demographic mix of the local population bringing much needed mix of families and young professionals to the area with additional spending power for all local businesses and a future source of available workforces as and when the economy revives.

Demographic mix will provide a substantial opportunity to support membership of local sports club.

Will help make the area more residential which will encourage more cafes and restaurants to open in the local area

Great plans to upgrade to the future, promoting excellence.

Flyers listing concerns/negative claims conflict with proposal

Hounslow Chamber of Commerce Support (both schemes)

Support the proposal which will provide 12% of LB Hounslow’s ten-year housing requirement in the London Plan with around 725 affordable homes, more than twice as many affordable homes as any other development in Hounslow in the last 15 years.

Welcome new public open space and improvements to transport and connectivity

New village square and mixed-use space (Tesco Site) will provide much-needed jobs and activity.

Converting this large car park site to deliver green spaces, homes and especially jobs is a fantastic opportunity for the regeneration of the Golden Mile.

Financial injection the developments should contribute substantially to the community, particularly important given the current economic downturn.

Construction period will bring a multitude jobs and spending to the area whilst supporting a variety of apprenticeships, work placements and training

Brentford Voice Objection

Appreciate that the bar is set very high for sustaining refusal on the grounds of prematurity. However, the National Planning Policy Framework supports this approach in the context of the current stage of the Great West Corridor Local Plan Review. Paragraph 49 of the NPPF states that:

"49. However in the context of the Framework – and in particular the presumption in favour of sustainable development – arguments that an application is premature are unlikely to justify a refusal of planning permission other than in the limited circumstances where both:

a) the development proposed is so substantial, or its cumulative effect would be so significant, that to grant permission would undermine the plan-making process by predetermining decisions about the scale, location or phasing of new development that are central to an emerging plan; and

b) the emerging plan is at an advanced stage but is not yet formally part of the development plan for the area."

We believe that approval of these planning applications at this stage would "undermine the plan-making process" and that "the emerging plan is at an advanced stage".

The levels of housing development currently proposed greatly exceed those

postulated for these sites in the Draft GWC Local Plan Review. The proposed total of 2,150 homes on the sites would constitute almost 30% of the indicative total of 7,500 homes for the entire Great West Corridor over the period 2019-2041, as set out in The London Plan (March 2021).

The primary objectives of the forthcoming Public Examination are to ensure that the submitted GWC Local Plan Review meets the tests of soundness defined in the NPPF, and that it is legally compliant.

The granting, at this stage, of planning permission for these proposals on the Tesco and Homebase sites would gravely constrain the Public Examination's consideration of the soundness of the Plan, in particular the need to ensure that the Plan is "positively prepared".

The Isleworth Society Objection

Overdevelopment

Too dense, too high and out of character with the surrounding areas.

Buildings soar over existing residential properties, mainly two-storey houses, and in some instances causing loss of privacy, daylight and sunlight.

Too many flats with a lack of private amenity space.

Need more family homes with gardens, social housing and affordable housing which is actually ‘affordable’.

Heritage

Buildings substantially deflect from the important heritage aspects, namely the remaining art deco commercial buildings on the famous Golden Mile,

Detrimental by cause of overshadowing to the unique structure of the Grade ll Gillette building.

Traffic

Traffic, where Syon Lane crosses the A4, is extremely dangerous for drivers.

More cars from the proposed site will cause a critical situation to become untenable. Public Transport

Great West Road A4 has poor public transport especially the bus routes which are limited and infrequent.

Infrastructure such as doctors’ surgeries and primary school provision not considered.

Osterley and Wyke Green Residents’ Association

Objection

Community Engagement

Inadequate consultation process

Major concerns about excessive height, transport and traffic largely ignored. Context and Character of Surrounding Area

Bulk and height up to 17-storeys would be wildly out of character with the surrounding area and would dwarf and dominate its suburban and historic surroundings of mainly 2-storey houses.

Negative impact on the context and character of the area.

Building Heights, Massing and Design – the Design Code

The proposals would have a detrimental effect on surroundings, and would overpower and intimidate with their mass, bulk and height.

10 instances where the distance between buildings is less that the prescribed minimum recommended distance of 18m

The design echoes the area’s commercial and industrial buildings of some 3-5 storeys but is disproportionate at heights of 2-17 storeys.

Housing Density

Too dense, 20 times higher than the rest of Osterley

Offers a poor quality of life for future residents and exceeds approved Local Plan Site Allocation 2.

This makes for an unacceptable step change in comparison with the surrounding built environment.

Housing Type, Quality and Size of Accommodation

Lack of privacy and overlooking given other buildings’ proximity.

Few (9%) 3 bed homes

Almost half single aspect only, poor outlook, balconies above lead to poor daylight below.

Daylight, Sunlight & Overshadowing

The scale and density of development would have an adverse effect on neighbouring homes through close proximity, overshadowing and loss of privacy.

Housing Needs and Affordability

Hounslow Council's Housing Strategy document (2019-2024) states that there is a desperate and growing need for “larger family homes” (3-4 bedroom homes) to prevent forecast overcrowding in a glut of smaller-sized properties.

Fails by a large margin to meet objectively assessed local housing needs, as only 9% of dwellings would have 3 bedrooms.

The Council’s own objectively measured assessment shows that the combined need for larger family homes in the Market and Affordable sectors combined is 57%.

The proposed smaller sized flats are not only unsuitable for families, but also very unlikely to be affordable on the private sale market, by the average family in Hounslow.

Transport, Traffic & Parking

Only proposed improvement to public transport would be one additional bus route from Osterley to Ealing Broadway (E1).

There is no funding for much needed improvements to rail services (Hounslow Loop, Piccadilly line upgrade, Southall Rail Link, West London Orbital).

Existing PTAL 2 (poor), which is wholly inadequate for developments on this very significant scale.

The national financial crisis eliminates hopes for future funding.

The developer and TfL don’t agree on whether traffic will increase or decrease at Gillette Corner in the future; the developer opts for a reduction in traffic with no evidence

Apart from the proposal for an additional right turn lane from the A4 eastbound into

Syon Lane southbound, which is designed to enhance access to the Homebase site development, the two developments provide nothing else to address their combined impacts on the already congested Gillette Corner.

Parking provision at 0.25 spaces per dwelling is much lower than the recommended 1 space per dwelling in PTAL 2, which is unacceptable with no significant improvements to public transport in the foreseeable future.

Environmental Aspects, Sustainability, Climate Emergency & Ecology

Does not comply with the Climate Emergency declared by the GLA and L B Hounslow

Renewable Energy sources are not exploited, and a substantial proportion of heating and hot water would come from fossil fuels.

Only a very modest 36% of the energy consumed will be Zero Carbon, with the remainder provided by fossil fuel, using gas-fired boilers. This completely undermines L B Hounslow’s pledge to be Carbon Neutral by 2030.

The proposed design fails to achieve true Zero Carbon, as the resultant Residual Carbon emissions is substantial (957 Tonnes CO2 per year) and is mitigated by paying into a Carbon Offset Fund.

Tall buildings are not environmentally friendly, due to their intensive use of concrete and steel, which constitute a significant part of CO2 emissions.

No allowance is made to further reduce Carbon emissions as required by the London Plan.

Thermal design of buildings and type of heating and ventilation systems used do not reflect the step-change needed for high standard of sustainability.

No justification for demolishing the “Tesco Extra” building, as part of addressing the Circular Economy, which is an integral part of sustainability, particularly in the current economic climate.

Significant damage to local biodiversity will occur as 150 of the existing 177 trees on site will be removed. It will take many years for biodiversity to recover from this avoidable damage.

Infrastructure

The location does not fulfil the requirements of a 15-minute neighbourhood as many of the amenities are further than 15 minutes’ walk.

Local infrastructure is already bursting at the seams, before the addition of thousands more residents, causing a negative impact on social infrastructure.

Local Heritage

The proposals would overwhelm and hide from view Grade II Listed buildings, the Gillette Building and Tower and the ‘Goals Soccer’ Pavilion.

Education

There is inadequate provision of primary school places in the area, this problem has not been addressed in the planning application.

There are probably sufficient secondary school places.

Landscaping & Amenity Space

The amenity space proposed is less than the area required in the Local Plan, and much of it would be at podium and roof level

Lack of privacy due to close proximity of other blocks of flats. Some areas would be

affected by inadequate sunlight and wind Additional response Housing Mix

There has been a small reduction in the number of studio and 1-bed flats and a small increase in the number of 3-bed homes, but studio, 1 and 2 bed flats would still account for 82% of homes. This still does not meet the dire shortage of family-sized homes (3-4 bedrooms) in Hounslow.

Height, Scale Massing

Remains inappropriate New Heart of Osterley

Density too great to allow a new community to enjoy leisure facilities proposed, very small numbers of new residents could be accommodated simultaneously, otherwise dangerous overcrowding

Density, Form and Character of Housing compared to other development onn similar sites

Much higher density of the proposals at Tesco and Homebase to what exists and new proposals elsewhere

Protection of Heritage

site constraints mean listed buildings close by will be obscured by the bulk and mass of the proposed development, plus protected views from the World Heritage Site in Kew will be lost

Energy & Sustainability

The target for Zero Carbon and other energy saving measures have been improved to but they still fall significantly short of achieving Zero Carbon.

Shortfall in achieving Zero Carbon emissions is mitigated by paying into Hounslow’s Carbon Offset Fund which is meant to be a very last resort, if all other carbon saving solutions are exhausted. There is no evidence that this has been done.

The developer’s shortfalls of 49% and 41% occurring in 2021, are at a significant variance with London Borough of Hounslow’s pledge to be Carbon Neutral by 2030.

Solar roof-mounted panels are now proposed. It is assumed that the solar panels will conflict with the beneficial use of the proposed rooftop landscaped areas and their local environment the amount of green space provided needs to be recalculated.

No information about exploiting the recycling of rainwater and greywater to deliver energy savings and reduce water demand.

No information provided on future proofing and impact of climate change, based on published data.

No information on the impact of COVID-19 on environmental and building design, including well-being issues, etc. Single aspect flats do not allow natural air flow.

Transport and Linked Vision

The only significant changes proposed are some minor tweaks to the layout of the north-south pedestrian and cycle crossing of the eastern side of Gillette Corner, which is wholly inadequate.

A number of options are proposed, some of which would retain the underpass.

Signalled pedestrian/cycle crossings are needed across all 4 arms of the junction, not just across the 2 arms of the A4.

The developer is still insisting that traffic volumes will decrease at Gillette Corner. The reasons given for reduced traffic lack logic.

Gillette Corner needs to be reconfigured to make it safer for all users of the junction (vehicular traffic, pedestrians and cyclists). The right hand turns from Syon Lane on to the A4 would remain dangerous (not controlled by filter light).

Altogether these measures are needed to ensure compliance with the Mayor’s Healthy Streets and Vision Zero policies.

Where are the improvements to infrastructure? Only one in four properties would have a parking space meaning that most new residents would be relying on public transport, which is poor (PTAL 2) and already overcrowded. The only improvement proposed is a direct bus route from Osterley to Ealing Broadway.

The lack of good transport connections and infrastructure should mean that such a densely populated development should not be permitted on this site.

This is in addition to the fact that there is no close town centre as required for tall buildings.

Agree with Hounslow Design Review Comments Further response

Note slight improvement from 59% to 60%

The changes to the Environmental and Sustainability Statements are very disappointing and of a very minor nature. They fail to mitigate against serious harm to the environment. The proposed developments do not address the fundamental issues and dire needs to achieve Zero Carbon, both in terms of quantum and timing to achieve substantial carbon reductions.

The revised energy and sustainability statements have not responded to previous comments and questions.

Kew Society Objection

Concerned about the impact of the proposed development from vistas within RBG Kew which will be intrusive and inappropriate building heights

Support the objections submitted from Brentford Community Council/Brentford Voice, the Osterley & Wyke Green Residents' Association and The Isleworth Society. In particular, the inappropriately tall buildings will harm the settings of nearby heritage assets (listed and non-listed) and overwhelm the predominantly two-storey character of the surrounding residential area.

We note and support Historic England's concerns about harm to heritage assets and request for additional views.

Applications represent massive and intrusive overdevelopments and should be rejected

There is insufficient information provided to arrive at a true assessment of the adverse visual impact from RBG Kew.

Harm to Syon Vista, Isleworth gate (Grade II) where it is crucial to keep this westward panorama unspoilt , particularly given, as the Historic England letter notes, that Syon Park 'forms an essential relationship with the Royal Botanic Gardens, Kew World Heritage Site, falling within its buffer zone and together forming a pair of substantially intact Brownian landscapes of the highest Blocks of tall buildings looming clearly on the horizon will have a materially adverse impact on the views westward from the Gardens.

The materially adverse impact on views westward from the Gardens over Syon Park and its meadows would contravene planning regulations.

Royal Botanic Gardens, Kew Objection

The proposal is contrary to policies in Hounslow’s Local Plan, including the Great West Corridor Masterplan.

Recent decisions relating to planning applications in the vicinity of Kew Gardens, such as the Chiswick Curve and Citroen site have ascribed a degree of harm to the Kew WHS as “less than substantial”. In our view the current application brings a similar or greater degree of harm as these other recent developments, due to the unspoilt character of the area affected.

The International Council on Monuments and Sites (ICOMOS) sent letters of objection relating to the Chiswick Curve, Citroen and Albany Riverside developments. Given the very high level of significance of the Kew Gardens WHS and the impact this development would have on attributes of OUV, we recommend that the view of ICOMOS be sought on the application via the UK state party.

The Syon Vista and Riverside Lawns, the Ha-ha (within Kew) and Syon Park and the Thames (in the setting of Kew) have a “very high” level of significance (A). The grounds of the Queen’s Cottage and the Towpath have a “high” level of significance (B). Isleworth Gate and the Gillette Tower have a “medium” level of significance (C).

Syon Park is assessed as being subject to a “major” scale change, resulting in a “very large” magnitude of impact. The Syon Vista and Riverside Lawn, the Ha-ha, the Towpath and the River Thames are assessed as being subject to a “moderate” scale of change, resulting in a “large” magnitude of impact

The principal harms affect Attribute 1 of the Outstanding Universal Value of the WHS: A rich and diverse historic cultural landscape providing a palimpsest of landscape design.

More specifically these harms are as follows: - Visual intrusion into the Victorian garden layout, in particular a new cluster of

buildings seen from the outlook from Syon Vista and Lawn. - Visual intrusion into the surviving Capability Brown landscape including Brown’s Ha-

ha and the visual connection to the Thames and to Syon Park, which are “of a piece” with Kew.

- Visual intrusion into one of the least altered reaches of the Arcadian Thames Landscape, which is in itself a heritage asset of high significance.

- Harm to the setting of individual heritage assets as seen from Kew, in particular Syon House and the Great Conservatory.

- The loss of the sense that this part of Kew Gardens as a “world apart” due to the visual intrusion of a cluster of buildings overtopping the current tree screen.

- Night time light outspill from the cluster of buildings into what is currently a dark zone.

Cumulative harm - The proposed development - could set a precedent for further invasive developments at Syon Lane. In particular, the concurrent outline application for the Tesco site, although lower and further away, will broaden the cluster formed by the Homebase development to the right of Syon House.

Brentford Community Council/Brentford Voice - Joint

Objection

The BCC and BV fully support the views adopted by OWGRA. This application is a

major over-development and departure from the approved development planning framework

Support the principle of development on this site but look for an appropriate alternative application which is consistent with the development plan and the guidance emerging for the Great West Corridor. This planning application represents a gross overdevelopment of a site in an essentially suburban location.

Community Consultation - The proposals fail to address the fundamental concerns that have been raised by

the community.

Affordable Housing and the Housing Mix - The proposed affordable housing provision falls well short of policies in the

adopted development planning framework. The mix of proposed dwelling types fails to reflect the need for larger family homes.

Heritage, Townscape and Visual Impact - Proposals would result in significant harm to heritage assets and that they would

not be outweighed by the public benefits.

Transport and Accessibility - Improvements to public transport infrastructure in the Great West Corridor must

precede, or at worst proceed in parallel with, the implementation of major development proposals. This proposal is premature in advance of any clear practical and financial commitment to such improvements.

Design, Scale and Massing - The ideas in the proposal would have merit if they were applied to a scheme

containing 25% of the amount of accommodation. Most of the problems would disappear, and the site could be developed in a family-friendly, human-scaled environment that would harmonise with its surroundings

The parameter plans - Particular consideration muse be given to the parameter plans that accompany this

planning application. Our experience with similar large-scale outline applications is that the parameter plans become almost immutable when a reserved matters application is submitted

Energy and Sustainability - The applicant should be asked to re-submit theirEnergy Statement using the SAP

10 factors so that their plans can be scrutinized properly. The applicant should be required to submit detailed evidence that it is not feasible to generate 100% of heat from heat pumps.

Thames Landscape Strategy Objection

Concerned that views from river will be affected and from some viewpoints the building will sit directly above Syon House and be visible above the mid ground tree line.

Request the applicant provide further verified views from the Thames Path so that the visual impact of both schemes can be more clearly seen.

Heston Residents’ Association Objection

The proposed development is fundamentally out of character with surrounding housing in terms of its size, massing and design; is too high, dominating the local street scene and existing residential build.

The proposed housing density is significantly at variance with the surrounding housing

and the London Plan Guidelines.

This site is on a minor road which will be unable to cope with the additional traffic generated by the new development.

The site already suffers from dangerously high levels of pollution due to the proximity to the M4 motorway. The current pollution levels already exceed the maximum permitted by European legislation. The proposed development will expose the local community to levels of pollution that could be considered to be both reckless and actionable.

The residential development does not meet the council’s requirement in respect of sustainable energy and zero carbon emission.

The site does not have good access to public transport with a PTAL of 2 (low). Inadequate provision for car parking for proposed residential build; 400 parking spaces for 1677 housing units will be totally inadequate.

Failure to include more family accommodation, eg 3 and 4 bedroom apartments together with the need for more houses; the proposed development would only provide 151 family-sized homes out of 1677 new dwelling units. The development does not address the chronic shortage of family-sized homes in the borough.

In combination the developments involve a population increase of c.5,000 - equivalent to a small town e.g. Datchet, Bude, Bagshot etc, but on an extremely small footprint. It is essential that the necessary improvements to roads and public transport is completed prior to building the new developments.

Failure to recognise the need for more / improved public transport; the essential Improvements to roads and public transport will require investment from the public sector. Given the impact of the current pandemic, the necessary public sector funds will not be available. The contribution in the form of CIL by the developer will be totally inadequate.

The development will have a significant impact on health and leisure services. Failure to recognise possible need for more primary school places. The development proposal fails to address this issue adequately.

Resultant loss of privacy and sunlight / daylight for existing properties.

Design / appearance of and materials used for proposed new build not in keeping with existing local area, failing to add any beneficial visual impact on the context / character of the immediate area.

Detrimental impact on local environment - noise (additional traffic movements) and air pollution.

Concern about adequacy of local utility services to meet the increase in demand, particularly the demand for water supply and disposal of waste water / sewage

West Thames College Support

Support the investment and economic opportunities, notably:

Safeguarding and creating 650 permanent jobs

New and safer pedestrian and cycle routes to be delivered

Proposed improvements to the local road network

Employment and Skills Plan to help maximise local employment opportunities and improve local skills levels through school and further education engagement in the local area.

Hounslow Cycling Object

The proposed Tesco Osterley and Homebase Brentford development create unacceptable levels of car traffic unless access routes for pedestrians and cyclists are materially improved. The development could be an environmentally friendly way of building much needed new homes if adequate investment is made in active travel.

Pedestrian and cyclist access is currently poor and public transport not much better. The development will significantly increase the use of cars in the area, potentially contradicting the Hounslow Local Improvement Plan, the Mayor’s Transport Strategy and other Hounslow and London policies relating to air quality, climate change and road safety.

Residential car parking provision and cycle parking should comply with the quantitative limits in the London Plan. Cycle parking should be of good quality - accessible, well lit, dry and secure. This will help to address car dependency from the outset.

Developer should fund adequate investment in better pedestrian and cycle routes by London Borough of Hounslow (‘LBH’) and Transport for London (‘TfL’):-

Gillette Corner lies to the SE of the site. The surface level crossings are slow and frustrating to use, with cattle pens of limited capacity in the central reservation. The only satisfactory crossing for pedestrians and cyclists is the subway that runs from the N corner to the E corner. That is only 7'6" wide. The access ramps are also narrow and the southern end currently emerges four steps higher than the car park. We believe that TfL should budget for a wider tunnel, with attractive entrance treatments and reassuring CCTV and lighting.

Syon Lane crosses the Piccadilly Line about 600m NW of the site. All traffic must pass through this pinch point.This stretch of road is dangerous for cyclists as the carriageway is wide enough to encourage car drivers to overtake but too narrow for them to do so safely. The footway is on one side of the road only, and it is unattractive due to the speed and volume of passing traffic. LBH should estimate the cost of this route, including the Hounslow Loop and Piccadilly Line crossings, and budget accordingly.

Osterley tube station is around a mile from the site, to the W. Boston Manor tube station is less than a mile from the site as the crow flies, to the NE. Either tube station can thus be reached by cyclists using the existing bike lane along the N pavement of the A4. Suggest that TfL should budget for the upgrade of that bike lane from Osterley to Boston Manor road.

Responses from statutory bodies

Greater London Authority (Mayor) Stage I report

Stage 1 Response: Advises that while the scheme is broadly acceptable in strategic planning terms, the application does not fully comply with the London Plan. The Mayor considers that the application does not fully comply with the London Plan, for the reasons set out in the response but that the potential remedies also set out in that paragraph of the report could address those deficiencies. Principle of development: The comprehensive residential-led mixed use redevelopment of this out of town retail park site within an opportunity area is strongly supported.

Housing and affordable housing: 35% affordable housing by habitable room, comprising 66% intermediate housing and 34% London Affordable Rent. The cumulative affordable housing offer across this application and the linked Homebase application would ensure 35% affordable housing provision with a 50:50 tenure mix (by habitable room). The proposed tenure mix across both sites has been agreed with Council and GLA officers and complies with the Intend to Publish London Plan. The sites would be formally linked via S106 agreement. As such, the application is considered eligible for the Fast Track Route. Phasing and affordability levels should be set out and secured, together with an early stage review mechanism, grant funding provisions and off-site play space provision. Urban design and heritage: The density, design and layout, residential quality and proposed height and massing is supported, subject to the design code and landscape strategy being appropriately secured. The application would cause less than substantial harm to the setting and significance of the Grade I listed Registered Syon Park, the Grade II* listed Registered Osterley Park and the Grade II listed Former Gillette Factory. The overall cumulative harm caused to these designated heritage assets could be outweighed by the proposed public benefits, subject to these being secured and detailed at Stage 2. Climate change: The energy, drainage and urban greening strategies are generally supported subject to further information being provided on the energy strategy. Transport: Further work is required on the modelling of highway options to ensure that a preferred option can be identified and agreed. A bus contribution of £1,700,000 is required for both development sites to mitigate the impact on bus capacity. Further detail on the public realm, site access and walking and cycling improvements is required to ensure these are safe and meet the requirements of the Healthy Streets. The pedestrian and cycle connections between the two development sites should be improved. Car parking is acceptable and complies with the maximum standard in the Intend to Publish London Plan. Cycle parking would also meet the quantitative standard required in the Intend to Publish London Plan. Compliance with the London Cycling Design Standards (LCDS) should be secured. Further details are required on the Delivery and Servicing Plan.

Transport for London

Highways Impact The redevelopment of the Tesco Osterley site is predicted to generate 142 two-way vehicle trips in the AM peak hour and 138 during the PM peak hour (excluding service vehicle trips). This results in a net reduction of vehicle trips of - 244 trips in the AM peak hour and - 570 in the PM peak hour. But there will be a net increase in the weekday peak periods when the sites are combined. In order to test the impacts of the vehicle trips generated by both the Homebase and the Tesco Osterley sites, detailed junction modelling using VISSIM microsimulation modelling software has been undertaken. A number of different design options were modelled to mitigate the impacts of development traffic and to provide pedestrian and cycle improvements in line with the Healthy Street approach. Design Option 2a, has initially been identified as the preferred mitigation option. Design Option 2a includes a new traffic signal control junction for the Homebase site and the addition of a second right turning lane on the A4 for traffic turning into Syon Lane (towards the new Homebase site access) from the west. This option also includes the relocation of the existing bus stop layby on the A4 Great West Road (Westbound) further east to extend the cycle lane. Option 2a also includes a new at grade toucan crossing on the A4, to the east of Syon Lane. It retains a double right turn from the A4 into Syon Lane North. Option 2a also retains the pedestrian underpass beneath the A4 However, prior to the

implementation of Option 2a, the applicant will be required to undertake further detailed design and highway modelling work to establish if in addition, a direct pedestrian and cycle crossing can be delivered on Syon Lane, to be incorporated within the Gillette Corner junction. If feasible, this revised design Option will be delivered via a s278 agreement as part of the Homebase site. Further to the above, the applicant is also required to undertake further feasibility work on Design Options 5 and 6 prior to the implementation of the Tesco Osterley site to ensure that pedestrian and cycle facilities are delivered on all arms of Gillette Corner. This will be secured via the s106 agreement. Healthy Streets and Vision Zero The Healthy Streets approach aims to create a high quality, attractive and inclusive environment in which people choose to walk cycle and use public transport. The dominance of vehicles should be reduced by using design to ensure slower speeds and safer driver behaviour, in line with the Mayor’s Vision Zero ambition. The proposed development will generate a significant increase in pedestrian and cycle trips to / from the site and the local area. The redevelopment of the site will require the relocation of the existing bus terminus. The original proposal (Option 1) provided its replacement on Grant Way. This facility would include a new bus stop, bus stand; and a new bus turn around and bus driver welfare facilities. TfL had agreed the principle to Option 1 subject to the detailed design. However, an alternative option (Option 2) was proposed by the applicant as part of the re-consultation, which would route buses through the residential development. TfL are not supportive of this proposal, holding several concerns over its operation. Therefore, it is TfL’s view that the requirement for Option1 should be secured in the s106 agreement. However, TfL are happy to explore alternative options to Option1, prior to implementation. Whatever option is taken forward, the continuation of bus services as well as provision of bus facilities throughout the redevelopment of the site, is imperative and should also be secured in the s106, along with the Heads of Terms for the lease of the proposed bus driver welfare facilities.Any costs associated with relocating the bus terminus and new bus infrastructure will need to be fully funded by the applicant. The applicant has confirmed that the proposed ‘Mobility Hub’ will include a range of facilities designed to enhance access to local transport options including a cycle hub, delivery lockers, information board/maps, information regarding the site’s Car Club; and a bus driver welfare area. The Mobility Hub should be secured via the s106 agreement. The applicant has confirmed that a 3m wide segregated cycleway and 2m wide footway will be provided on the site frontage. The implementation of highway design Option 2a, which will be delivered as part of the Homebase redevelopment, will provide a new at-grade crossing across the A4 improving connections for pedestrians and cyclists. The applicant has also agreed to improve and repair the underpass, including repairing/cleaning lights and mirrors and installing corduroy tactile paving on subway steps. The redevelopment of the Tesco Osterley site will significantly increase pedestrian and cycle demand along the A4 towards Osterley LU Station. The ATZ assessment and accident data identifies a need for pedestrian and cycle improvements at all junctions along this link. In order to enhance the active travel, reduce car dependency and to ensure the development is aligned to the healthy streets aspirations, it is recommended that a review of the junction design at the A4 junctions with Syon Park Gardens, Wood Lane, Leigham Drive, St Mary’s Crescent and Thornbury Road is undertaken to improve the safety and priority for pedestrians and cyclists. The review should be undertaken, and the designs submitted with the first reserved matters application and improvements delivered prior to first occupation. This should be secured through the s106 agreement.

Car Parking TfL have no additional comments to make concerning car parking. Cycle Parking TfL have no additional comments to make concerning cycle parking. Trip generation and modal split TfL have no further comments on the trip generation assessment. Buses A bus capacity contribution of £1,700,000 for both development sites has been agreed. The contribution will be for general service enhancements, rather than to specific routes and adapted to local conditions upon site occupation. London Underground An assessment of station capacity at Osterley Station has been undertaken. The assessment still requires further work before TfL can determine if a contribution is required. However, given the Tesco Osterley site generates the greatest demand for underground trips it, is recommended that an updated assessment of station capacity and line loading capacity at Osterley Station is with the first reserved matters application. The underground trips generated by the Homebase site will also need to be included in this assessment. Delivery and Servicing A revised Framework Delivery and Servicing Plan (DSP) has been provided and whilst the service vehicle trip generation has been revised, it still only predicts 386 two-way daily trips which TfL maintains is still an underestimation given the size of the development. The full DSP will need to ensure that the service vehicle trip generation is robust, and should be secured by condition. Travel Plan The Framework Workplace and Residential Travel Plans have been provided. The Travel Plans should be secured, enforced, monitored and reviewed by as part of the s106. Construction A Construction Logistics Plan (CLP) will be required by condition and discharged in consultation with TfL. Summary Subject to securing the recommended conditions and obligations the application is now considered to be in general accordance with the transport policies of the London Plan 2021.

6.24 Highways England – No comments received at time of writing.

6.25 London Fire Brigade – No objection. The London Fire Commissioner (the Commissioner) is the fire and rescue authority for London. The Commissioner is responsible for enforcing the Regulatory Reform (Fire Safety) Order 2005 (The Order) in London. The Commissioner has been consulted with regard to the above-mentioned premises and makes the following observations: The Commissioner is satisfied with the proposals in regard to B5 access.

6.26 Environment Agency – No objection. There are no environmental constraints that fall within our remit as a statutory consultee at this site and therefore we would have no comments to make on this planning application.

6.27 NATS Safeguarding (airport traffic approach) – The proposed development has been examined from a technical safeguarding aspect and does not conflict with our safeguarding criteria. Accordingly, NATS has no safeguarding objection to the proposal

6.28 Heathrow Airport – No objection subject to conditions regarding restrictions on heights, including crane heights, construction management, SuDs, and bird hazard management plan being secured.

6.29 Cadent Gas and National Grid - No objection to the planning application at Tesco Superstore Syon Lane Isleworth as the HP gas pipeline in the vicinity will not be affected

6.30 Design Out Crime Officer (Police) - No objection subject to a condition regarding ‘Secure By Design’ Accreditation being secured.

6.31 Thames Water – Request for conditions regarding Foul Water and Surface Water Drainage.

6.32 Hounslow CCG – The developments will give rise to a need for additional primary healthcare provision, to mitigate impacts arising from the development a contribution towards primary health care is sought. An either/or scenario, where the council secures, within a legal agreement, that the developer either provides a facility on site to meet CCG needs or provides a contribution can also be considered. This would be secured in the S106.

6.33 Historic England - The connected landscapes of Syon and Kew are of global historic and artistic interest, meriting the highest possible heritage designations. The views provided illustrate harm to the significance of the Royal Botanic Gardens, Kew World Heritage Site, Syon House and Syon Registered Park and Garden (all Grade I), and Osterley Registered Park and Garden (Grade II*). The proposals are contrary to the Development Plan, including the new London Plan, which sets out a robust framework for ensuring the conservation highly designated heritage asset. This harm attracts very high weight and has not been clearly and convincingly justified. Historic England strongly recommends that planning permission should be refused.

6.34 Historic England (Archaeology) – The proposal is unlikely to have a significant effect on heritage assets of archaeological interest. The site does not lie within an

Archaeological Priority Area and is unlikely to cause harm because of the lack of recorded archaeological finds in the immediate vicinity and likely extensive disturbance from modern development. No further assessment or conditions are therefore necessary.

6.35 The Gardens Trust – Objects owing to impact on setting of heritage assets, in particular Osterley Park and Syon Park owing to the damaging effect on important views. By tall buildings resulting in permanent visual intrusion into what until now has been a largely unspoilt setting on the edge of London be permitted, it will set an unwelcome precedent for further commercial development to be allowed to cause damage in similar manner. The loss of significance to these unique and irreplaceable heritage assets is in no way compensated by public benefit. Endorse concerns about impacts on views from the riverside by the Royal Botanic Garden, Kew and request further views analysis in order to obtain a full and objective understanding of the effects on these landscapes.

6.36 The Woodland Trust - Holding objection to the proposed development on account of likely detrimental impact to T81, a veteran oak tree recorded on the Ancient Tree Inventory (ATI no: 97848). Within the documentation provided T81 will be subject to new hardstanding within the Root Protection Area (RPA) as well as the construction of a ramp. Furthermore, T81 has not been afforded an RPA befitting a veteran tree. Natural England’s Standing Advice recommends the following: “A buffer zone around an ancient or veteran tree should be at least 15 times larger than the diameter of the tree. The buffer zone should be 5m from the edge of the tree’s canopy if that area is larger than 15 times the tree’s diameter.” As such, the applicants should look to remove the proposed infrastructure from the root protection area of the veteran tree and also re-calculate the RPA in accordance with Natural England’s Standing Advice.

6.37 Since this response amended plans have been submitted, which revise Block F in relation to this tree. No further response has been received.

6.38 London Borough of Ealing – No Objection.

7.0 POLICY

Determining applications for full or outline planning permission

7.1 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

7.2 The National Planning Policy Framework (NPPF) was revised on 19 February 2019. The National Planning Practice Guidance (NPPG) is an online guidance resource that supports the NPPF. The NPPF and NPPG are material considerations.

The Development Plan

7.3 The Development Plan for the Borough comprises the Council’s Local Plan (adopted by the Council on 15 September 2015) (HLP), the West London Waste Plan and New London Plan (2 March 2021). (LP).

7.4 The Council is undertaking Local Plan Reviews; the West of Borough Local Plan review, the Great West Corridor Local Plan review and the Site Allocations Local Plan review. These plans have been submitted to the Secretary of State for examination, however their policies are afforded little weight at this stage.

7.5 The adopted Local Plan documents and emerging Local Plan Review documents can be viewed on the Planning Policy pages of the Hounslow website.

London Plan

GG1 Building strong and inclusive communities GG2 Making the best use of land GG3 Creating a healthy city GG4 Delivering the homes Londoner’s need GG5 Growing a good economy GG6 Increasing efficiency and resilience SD2 Opportunity Areas SD6 Town centres and High Streets SD7 Town centres: development principles and Development Plan Documents D1 London’s form, characteristic and capacity for growth D2 Infrastructure requirements for sustainable densities D3 Optimising design capacity through the design led approach D4 Delivering good design D5 Inclusive design D6 Housing quality and standards D7 Accessible housing D8 Public realm D9 Tall buildings D11 Safety, security and resilience to emergency D12 Fire safety D13 Agent of change D14 Noise H1 Increasing housing supply H4 Delivering affordable housing H5 Threshold approach to applications H6 Affordable housing tenure H7 Monitoring of affordable housing H10 Housing size mix S4 Play and informal recreation E11 Skills and opportunities for all HC1 Heritage conservation and growth G1 Green infrastructure G4 Open space GB5 Urban greening G6 Biodiversity and access to nature G7 Trees and woodland SI1 Improving air quality

SI2 Minimising greenhouse gas emissions SI3 Energy infrastructure SI4 Managing heat risk SI5 Water infrastructure SI12 Flood risk management SI13 Sustainable drainage T1 Strategic approach to transport T2 Healthy Streets T3 Transport capacity, connectivity and safeguarding T4 Assessing and mitigating transport impacts T5 Cycling T6 Car parking T6.1 Residential parking T6.5 Non-residential disabled persons parking T7 Deliveries, servicing and construction T9 Funding transport infrastructure through planning DF1 Delivery of the Plan and planning obligations

London Plan Supplementary Planning Guidance (“SPG”)

Affordable Housing and Viability SPG 2017 Housing SPG 2016 Accessible London SPG 2014 Character and Context SPG 2014 Shaping Neighbourhoods Play and Informal Recreation SPG 2012 World Heritage Site

7.6 Hounslow Local Plan Policies

Spatial Strategy Brentford/ Chiswick TC1 Town and neighbourhood centre network TC2 Ensuring the future vitality of town centres TC3 Managing the growth of retail and other main town centres uses TC4 Managing uses in town centres ED4 Enhancing local skills SC1 Housing growth SC2 Maximising the provision of affordable housing SC3 Meeting the need for a mix of housing type and size SC4 Scale and density of new housing development SC5 Ensuring suitable internal and external space CC1 Context and character CC2 Urban design and architecture CC3 Tall buildings CC4 Heritage GB7 Biodiversity EQ1 Energy and carbon reduction EQ2 Sustainable design and construction EQ3 Flood risk and surface water management EQ4 Air quality EQ5 Noise

EQ6 Lighting EQ8 Contamination EC1 Strategic transport connections EC2 Developing a sustainable local transport network IMP1 Sustainable development IMP3 Implementing and monitoring the Local Plan

Emerging Planning Framework

7.7 The Council has now submitted the ‘Great West Corridor Local Plan Review’ (2020) and the ‘Site Allocations Local Plan Review’ (2020) to the Secretary of State, with these scheduled to be examined in 2021. Once adopted the GWC Local Plan and Site Allocations will form part of the Development Plan and they will guide development in the Opportunity Area.

8.0 ASSSESSMENT

8.1 The application is a major development, which is the subject of an EIA, and proposes the redevelopment of the Site for a mixed-use park, comprising up to 1,677 homes, 35% being affordable, flexible non-residential floorspace and new public realm.

8.2 The application has been considered concurrently with a separate planning application proposing redevelopment of the existing Homebase site, which relocates the existing Tesco store to the Homebase site and proposed 473 homes. Taken together the proposals involve a wider strategic opportunity for development in the Great West Corridor Opportunity Area.

8.3 The key planning issues are considered to be as follows:

A. The principle and Impacts of the Proposed Uses

Sustainable development and regeneration context

Principle of the Proposed Uses

Other Socio-economic Impacts of the Uses

Alternatives

Conclusion B. Affordable housing

Affordable Offer and Proposed Tenure Mix

Fast Track

Conclusion C. Sustainability

Sustainable Design

Sustainability Assessment

Conclusion D. Urban Design and Impacts on the Townscape

Design Policy Context

Urban Design and Townscape Impact Assessment

Conclusion E. Built and Landscape Heritage

Heritage Policy Context

Effects on Heritage Significance

Archaeology

Conclusion F. Housing Quality

Quality Standards

Housing Mix

Density

Conclusion G. Transport

Introduction

Public Transport Accessibility

Trip Generation

Traffic Impact

Traffic Modelling options testing

Review of Traffic Modelling

Access

Public Transport

Car Parking

Cycle parking

Deliveries and Servicing

Active Travel, Road Safety and Public Realm

Construction

Conclusion H. Impacts on Neighbours

Outlook and privacy

Daylight, Sunlight and Overshadowing

Glare

Wind

Noise and other disturbance

Conclusion I. Other Environmental Matters

Air quality

Flooding and Drainage

Contaminated Land

Noise and vibration

Ecology

Wind

Conclusion

J. Planning Balance

Public Benefits

Conclusion

Compliance with Development Plan A. Regeneration and the principle of the proposed uses

Sustainable development and regeneration context

National Policy and Guidance

8.4 The National Planning Policy Framework (“NPPF”) emphasises that the three

overarching objectives of sustainable development, relating to economic, social and

environmental conditions, should be pursued together. Planning policies and

decisions should play an active role in guiding development towards sustainable

solutions, but in doing so should take local circumstances into account, to reflect the

character, needs and opportunities of each area.

8.5 The NPPF sets out policies in relation to key planning principles including building a strong economy, promoting sustainable transport, delivering a sufficient supply of homes, making the most effective use of land, achieving well-design places, promoting healthy communities, conserving the historic environment, and meeting the challenge of climate change. The associated National Planning Practice Guidance (“NPPG”) adds further context to the policies of the NPPF.

London Plan

8.6 The new London Plan sets out strategic policies for planning across London. Key

principles guiding policies that apply to new development are set out in the plan’s

‘Good Growth’ objectives. These objectives require high quality design that optimises

the use of land to support housing and workspaces, and promote higher density

development in locations that are well-connected to jobs, services, infrastructure and

amenities without relying on car travel. Addressing climate change, safety and

infrastructure needs are also important.

8.7 Policies require new development to make the best use of land by using brownfield

sites, particularly by more intense development in Opportunity Areas. The ambitious

delivery of more good quality homes, including affordable housing, new jobs, and an

environment that encourages a more active and healthy lifestyle activity with better

access to green spaces and safer walking and cycling are all strongly promoted.

8.8 The Plan states1 that “…if London is to meet the challenges of the future, all parts of London will need to embrace and manage change”, and that “… the areas that will see the most significant change are identified as Opportunity Areas”. The Plan defines Opportunity Areas as “…significant locations with development capacity to accommodate new housing, commercial development and infrastructure (of all types), linked to existing or potential improvements in public transport connectivity and capacity”.

8.9 London Plan policy SD2 sets out how the regeneration and growth potential of Opportunity Areas will be met through the planning framework. The Plan includes the ‘Great West Corridor Opportunity Area’, which encompasses the mostly commercial and industrial development extending along the A4 corridor from Gillette Corner to Chiswick Roundabout, and includes the Site and the existing Homebase site. This Opportunity Area is identified as having an indicative capacity for at least 7,500 homes and 14,000 jobs over the period of the new Plan.

8.10 In considering the potential for growth in the corridor, the Plan identifies the importance of ensuring capacity accounts for existing and planned infrastructure. The plan also recognises that the Art Deco architecture of the Great West Road has created a distinctive local character whilst the surrounding area has many natural and historic assets, and that the opportunities to integrate and draw inspiration from the area’s heritage should be fully explored.

Hounslow Local Plan

8.11 Policies of the current Hounslow Local Plan (“HLP”) are consistent with these national and London-wide strategic and spatial planning objectives for regeneration and growth. HLP policy IMP1 says 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 objectives.

8.12 In respect of growth and development, the HLP says that:

“Brentford will benefit from high levels of growth over the next 15 years, which will deliver much needed housing and jobs, as well as improved infrastructure, retail and leisure”2.

8.13 Aligning with the Opportunity Area designation of the new London Plan, the HLP had already identified the Site as a part of a wider area suitable for regeneration and more intense use. HLP policy SV1 of relates to the ‘Great West Corridor’ and sets out that the Council will prepare a partial Local Plan review to explore and identify the potential capacity for additional employment-led mixed use development along the Great West Corridor, and it will progress its designation as an Opportunity Area through the review of the London Plan. This policy says that the Local Plan Review will, amongst other things, identify sites with suitability for tall buildings.

Great West Corridor Local Plan

1 2.0.3 and 2.0.4 pg 30 London Plan

2 2.50 (pg 40)

8.14 The Council has now submitted the ‘Great West Corridor Local Plan Review’ (2020) (“GWC Local Plan”) and the ‘Site Allocations Local Plan Review’ (2020) (“Site Allocations”) to the Secretary of State, with these scheduled to be examined in 2021. Once adopted the GWC Local Plan and Site Allocations will form part of the Development Plan and they will guide development in the Opportunity Area. These plans are positive and aspirational, and set out a range of strategic and places policies, and allocate sites for development, aiming to enable the successful delivery of thriving places that are well connected and which support job creation, housing delivery, and new infrastructure with this conforming to the London Plan’s ‘Good Growth’ focus. The extent of the Opportunity Area is shown below.

Figure 4: Great West Corridor Opportunity Area

8.15 The GWC Local Plan recognises the area along the Great West Road corridor is underperforming in a range of areas with its environment traffic dominated and fragmented, with low quality public realm and poor access to transport in some areas. Overall it lacks a clear identity and it has limited amenities and poor links to surrounding residential areas and town centres, with these deficiencies restricting its ability to sustain and compete with changing business and industrial needs. It also has large sites that are underutilised and which provide development opportunities.

8.16 The overall vision of the GWC Local Plan is to transform the area designated as an Opportunity Area through regeneration and improving the environment into a place that is better for living and working, as well as for community and recreational uses. This will be achieved by making the best use of brownfield land, introducing a more vibrant mix of uses including housing, enhancing access to public transport, creating new green spaces, and making it more attractive for people to walk and cycle. New development should also acknowledge the corridor’s role as a gateway into central London and look to promote this sense of arrival and also draw on its rich history of bold architecture, whilst also accounting for the important heritage assets found within the corridor and the wider region.

8.17 The GWC Plan and the Site Allocations both identify the Site and the Homebase Site as being suitable for significant residential led mixed-use development and support their comprehensive redevelopment with high quality mixed-use schemes that can animate and improve the western entrance to the Opportunity Area. The Site Allocations allocates the Site for a mixed-use development with new housing and small retail with an enhanced public realm. The minimum quantum of development is 1,030 homes and 540 sqm of retail and business floor space.

8.18 The GWC Local Plan is supported by the ‘Great West Corridor Masterplan and Capacity Study’ 2020 (“Masterplan”). The Masterplan has undertaken an analysis of potential capacity for sites and looks to provide spatial and design guidance, taking into account the strengths and weaknesses of the area. It has an illustrative masterplan for development sites in the Opportunity Area which shows how the development could be provided on a site-by-site basis to deliver objectives for growth. The Masterplan comments that the relocation of the existing Tesco superstore to the Homebase Site, with housing above, in combination with redevelopment of the Tesco Site, “…will deliver a step change to the area and act as an important catalyst for other development to follow”3. The image below from the Masterplan shows illustrative proposals for the Site and other sites to be allocated for development, including the Homebase site, showing the expected transformation of the area.

Figure 5: GWC Masterplan - Illustrative Development Proposal (pg 183)

8.19 At this stage, although both the GWC Local Plan and the Site Allocations have been submitted for examination, they are yet to be independently examined and so they have limited weight. However, both documents provide a strong indication of the general direction of travel for future development for the Opportunity Area with more intense development that makes better use of brownfield land, with much more housing and a better amenity offer, and enhancing economic activity and active travel all being major priorities.

8.20 Overall, the national, London and local planning policy framework strongly supports the principle of the comprehensive regeneration of the Site as this would make a substantial contribution towards achieving strategic planning aims to optimise use of previously developed land, deliver housing and enhance the environment in

3 Pg 97 of GWC Masterplan 2020

particular. Given this broad context of support for significant regeneration and noting the new London Plan confirming the corridor’s status as an Opportunity Area where there should be substantial housing and employment growth, some weight, albeit limited as discussed above, may be afforded to the emerging plans.

8.21 As such, the adopted HLP still provides the basis for local policies of the Development Plan that will apply to this assessment, provided they are consistent with the later NPPF and new London Plan. The proposal is also not considered to undermine the future plan making process in respect of the GWC Plan and Site Allocations as the regeneration of the Site and significant housing growth in the area is consistent and strongly supported by the policies of the adopted HLP and its Opportunity Area status and related objectives from the new LP. Additionally, the full assessment of the proposal will consider whether any adverse impacts of the proposal would significantly and demonstrably outweigh the benefits.

Principle of the Proposed Uses

8.22 The Site presently contains a large food retail store with associated car parking and petrol station. It is not allocated for any use in the HLP though it is within the area recognised within its Spatial Strategy as a potential Opportunity Area, and as noted above, this status has now been confirmed by the new London Plan. The proposed mixed-use development would replace the existing Tesco food retail store with housing, smaller commercial and community spaces plus residential car parking.

Housing Delivery

8.23 Chapter 5 of the NPPF concerns the delivery of sufficient homes, with paragraph 59 noting the government’s support for schemes that significantly boost the supply of housing. Paragraph 117 of the NPPF says planning decisions should promote the effective use of land to meet the need for homes and other uses, while safeguarding and improving the environment and ensuring safe and healthy living conditions, in a way that makes as much use as possible of previously-developed land.

8.24 Paragraph 118 of the NPPF says planning decisions should, give substantial weight to the value of using suitable brownfield land for homes and other needs, and support the development of under-utilised land, especially if this would help to meet identified needs for housing where land supply is constrained and available sites could be used more effectively (for example space above shops, and building on or above service yards, car parks, lock-ups and railway infrastructure).

8.25 New London Plan policy H1 sets 10 year housing targets for local authorities across London. For Hounslow the target equates to 1,782 homes to be delivered each year, which is more than double the target of the adopted HLP which is 822 homes per year (a 116% increase). This policy also says that to ensure the 10 year targets are achieved local authorities should allocate sites for development, enable the delivery of housing capacity identified in Opportunity Areas, and optimise the housing delivery on suitable brownfield sites and encourages, in particular, the mixed-use redevelopment of car parks, low density retail sites, and supermarkets.

8.26 HLP policy SC1 seeks to maximise the supply of housing in the Borough to meet housing need in a manner that is consistent with sustainable development principles.

8.27 The Borough has a good record of housing delivery, with the former annual target of 822 homes per year met in each of the last three years and the Borough passing the government’s Housing Delivery Test4. The 2020 test showed Hounslow delivered 911, 1,264 and 1,525 homes over the last three year period; however these are all below the new target of 1,782 homes per year. The GWC Local Plan and Site Allocations have been prepared in anticipation of the new London Plan target, and both the Site and the Homebase Site form part of the Council’s housing supply pipeline.

8.28 The proposal for up to 1,677 new homes would make a very significant contribution towards the Borough’s housing target and the objectives of the Opportunity Area, and will help meet the identified housing need, with this equating to 94% of the Borough’s annual housing target. The redevelopment and intensification of the use of the Site, which includes a large area of car parking and a retail unit, with a mixed-use housing led proposal of mix-tenure, would also be consistent with the following strategic objectives to make the most effective use of underutilised brownfield sites within the Opportunity Area as set out in the GWC Plan5:

• Strategic Objective 3 - To provide new homes in sustainable locations where

residents can walk and cycle to local jobs, amenities and green space.

• Strategic Objective 4 - To provide high-quality housing at sizes, tenures and

types which are affordable to local residents and helping London meet its needs.

• Strategic Objective 5 - To ensure new homes support good growth by integrating with business, shops, and community uses in order to promote mixed and inclusive communities and deliver lively and liveable places.

8.29 More detailed consideration of the quality of housing and effect on the environment are discussed below, but in terms of land use and housing delivery the proposal is a very significant opportunity to provide much needed housing in an appropriate location, and so the principle of housing at the Site is strongly supported. The related development of the Homebase Site, which enables this proposal, adds further to this strategic opportunity, with that scheme proposing 473 homes, which is over 26% of the Boroughs annual target.

Non-residential Uses

8.30 The existing Tesco store has a floor area of approximately 11,500 sqm and provides a full range supermarket with a café, clothing and homewares and includes a pharmacy and optician, with this use serving the wider suburban area. The proposal includes the removal of the existing Tesco supermarket from the Site, through its relocation to the Homebase Site, approximately 260m away; this relocation provides the opportunity to redevelop the Site with a mixed-use proposal.

8.31 The proposal includes the provision of between 3,000 and 5,000sqm non-residential floorspace on the Site, to include commercial, employment, education, non-residential institution, community, public house/ drinking establishment use, mobility

4 Housing Delivery Test January 2021 – LB Hounslow achieved 154% of requirement.

5 GWC Plan – Housing Growth pg 40

hub. The development specifications provide minimum floor space for categories of uses, although the use is flexible within those. This provides a range of uses at a local scale which seek to meet the demand generated by the new homes, whilst also providing a more diverse offer to the existing community and aims to draw on the potential synergies with the adjacent Sky Campus.

8.32 The proposed new Tesco (on the Homebase Site) would re-provide its main uses within a more efficient store layout and proposes a reduction of 1,032 sqm in floorspace from the existing store. Given the proximity of the two sites and that the new store would retain its main uses it is considered that this would still serve the catchment and cater for the needs of the community as the existing store does.

8.33 The two planning applications are integrally linked through the proposed relocation of the Tesco store, and it is proposed that if permission were granted, there would be a restriction on the opening of the retail use on the Homebase Site to ensure the new premises is only a replacement store and not an additional store. There wold also be a restriction to ensure the existing Tesco Store cannot be demolished until trading at the replacement store has commenced to ensure there is continuity of provision of the retail store. It is noted the proposed Site Allocations refer to a mixed use incorporating new housing, local retail and community uses and an enhanced public realm, proposing a reduction in retail floor space on the Site. The proposed uses, linked to the relocation of the supermarket to the Homebase Site, would therefore generally accord with the Site Allocations and satisfies policy GWC1 of the GWC Plan which requires retail proposals to have regards to site allocations.

8.34 Policy GWC1 also supports opportunities to intensify and make more efficient use of

employment land by co-locating employment with residential uses, and encourages

a more diverse retail and food offer to encourage a more vibrant economy.

8.35 The proposed non-residential floor space comprises main town centre uses, and given the Site is not within a designated centre and the amount of floorspace proposed, it is necessary to carry out a sequential assessment to consider the appropriateness of the location, in line with HLP policy TC3, London Plan policy SD7 and paragraph 86 of the NPPF. These policies seek to locate main town centre uses in town centres as a first preference, then in edge-of-centre locations, and then only if there are no suitable sites available or expected to become available within a reasonable period, should out-of-centre sites then be considered.

8.36 The sequential test submitted with the application demonstrates that there are no suitable or available sequentially preferable sites or units in relevant centres in the walking catchment area for the local retail, commercial and community provision proposed.

8.37 In respect of retail impact, taken together the two developments would significantly reduce retail floorspace across the two sites (c. reduction of approximately 4,200 sqm). The current thresholds set out in HLP policies (being 500 sqm for retail and 2,500 sqm for other main town centre uses) distinguish between retail and other Town Centre uses, these are now combined in Use Class terms following changes to the Use Class Order. The Tesco Site development specification provides minimum floor space for certain categories within the wider Use Class definition, thereby

ensuring a mix of uses would be provided and that the overall policy thresholds for the categories of use proposed would not be exceeded. Additionally, the new Town Centre uses on the Site are proposed to primarily serve new residents of the housing, and the proposed Tesco store would be relocated on the existing Homebase Site only a short distance from its existing location

8.38 Nevertheless the applicant has undertaken a proportionate qualitative assessment to consider the impacts of the proposal on existing, committed and planned public and private investment, and on the vitality and viability of relevant designated centres and their catchments. This assessment shows none of the centres considered would be significantly adversely affected in terms of investment and delivery of proposed schemes, as the proposed uses are intended to provide walkable local retail, commercial or community facilities for the homes proposed on the application sites, and serves a different role to the major town centre regeneration schemes that are underway in Hounslow and Brentford or planned development in other centres. The assessment also shows that there would not be significant adverse impacts on the vitality and viability of these centres as the proposed limited local retail and community floorspace is intended to primarily support the new residents in the (up to) 1,677 proposed new homes and therefore its trading overlap and impact with surrounding defined centres will be very limited.

8.39 The assessment also specifically considered the impact that the inclusion of a potential gym within the range of proposed uses on the Site would have on other centres, and concluded, due to the distance to existing facilities and likely catchments, that there would be no significant adverse impacts arising as a result of this.

8.40 Therefore the principle of the proposed uses on the Site is acceptable, subject to a planning obligation that ensures the new Tesco cannot open until the existing Tesco store has closed, and the development specification setting minimum floorspace requirements to ensure a range of uses, and that these are local in scale. The overall reduction in retail floorspace on the Site, and cumulatively with the development on the Homebase Site, is supported given it is not located within a town centre or any other designated centre and HLP policies TC1 and TC3 and London Plan Policy SD7 set out a town centre first approach.

8.41 It is also necessary to restrict permitted development rights which enable non-residential uses to convert to residential, to protect these uses and retain as approved and contribute to the intended character of the development, this would be secured by condition.

Other Socio-economic Impacts of the Uses

8.42 The proposed housing and commercial uses would intensify the use of the Site. The

ES that accompanies the application has provided information on the socio-

economic impacts of these uses on the area. This information considers the impacts

from employment and economic activity, and on health and education needs arising

from the increased population from people living in the new homes including

cumulative development. Potential impacts on other community infrastructure in

respect of open space and transport are considered separately later in this report.

8.43 HLP policy SC1 expects housing proposals to be completed in balance with existing

and planned infrastructure, and to contribute to the provision of further infrastructure

to achieve sustainable development and sustainable mixed communities.

Consideration needs to be given to the location, scale and timing of new housing,

and the quality, capacity and accessibility of existing health and social care facilities

to meet this growth and to infrastructure needs arising from development. The GWC

Plan has considered these considerations and incorporates infrastructure capacity

planning to meet the expected strategic and local growth needs with an

Infrastructure Delivery Plan (“IDP”).

8.44 Policy GWC7 of the GWC Plan addresses how development would be required to

contribute proportionately towards necessary infrastructure provision identified in the

IDP, at a rate and scale sufficient to support the area’s development and growth.

This policy recognises that the Community Infrastructure Ley (“CIL”) and section 106

contributions are important means of funding and securing infrastructure through the

development process.

Education and Health Care

8.45 HLP policies C12 and C13 seek to meet the education and health needs of the

existing and future population and ensure the health and well-being of residents is

maintained and improved, and impacts from development are mitigated.

8.46 Taking into account size, mix and tenure, the proposal is expected to accommodate approximately 3,515 new residents by full occupation of the development in 2035. This is based on the assumed tenure and unit mix within the illustrative masterplan, which presents a total of 1,623 units. It is acknowledged that the proposed development specifications stipulate a maximum of 1,677 units would be delivered; however, this maximum number is only deliverable based on a larger percentage of small unit types. The unit mix assessed, whilst reflecting a smaller number of units, is the assumed reasonable worst-case unit and tenure mix. The update to the development specification to include some four bedroom properties would be an insignificant change in this regard, and therefore would not materially change the conclusions in the ES.

8.47 The ES has forecast the impact of the scheme on social infrastructure, including primary and secondary schools and healthcare facilities, taking into account the existing and future demand, capacity and cumulative effects from other committed and proposed developments including the Homebase site proposal.

Schools

8.48 Using the assumed reasonable worst-case unit and tenure mix and the child yield

figures generated from the GLA Population Yield Calculator6, the ES has estimated

that the development will result in 707 additional children.

6 GLA, 2019. Population Yield Calculator. Available: https://data.london.gov.uk/dataset/population-yield-calculator

8.49 The ES has used these figures to calculate that the development would

accommodate 308 primary aged pupils and 85 secondary aged pupils. Using

available data the ES identified that there is an existing modest surplus of primary

school places within the relevant area but that by 2023/24 there is a forecast to be a

deficit of primary places. For secondary school places the ES identified that there is

currently a large surplus pupil places, but that this will reduce but there would still be

a good surplus by 2025/26. The proposal along with other cumulative schemes

including Homebase Site would have up to total of 2,538 dwellings, this equates to a

need for approximately 397 primary school places and in the region of 268

secondary places should all the developments be implemented.

8.50 As such the ES considers that there would be a need for mitigation to provide for

additional primary school places and a negligible effect that requires no mitigation for

secondary places.

8.51 The Council has examined the impact at borough and planning area levels for both

primary and secondary places, for the applications proposed on the Site and the

Homebase Site. This found that there would be no significant impact for secondary

school places from the proposal itself or cumulatively with the Homebase Site

proposal.

8.52 This examination identified four existing Primary schools that fall within a mile radius of the developments and within three (of the five) Hounslow Primary Place Planning areas. Three of these schools currently have a significant surplus of places. In addition, if needed, there is opportunity within adjacent planning areas to make use of available capacity that is not currently in use. It is also noted that applications to schools are based on parental preference and therefore parents can, and often do, apply to any school regardless of distance.

8.53 Currently Brentford schools are experiencing a level of surplus beyond that which

was projected. For the 2020/21 academic year, factors influencing the surplus in

Brentford schools include a knock-on impact from surplus in the Chiswick planning

area resulting from changes in the patterns of applications to Chiswick primary

schools (e.g. economic effects of Covid and independent schools). Similar patterns

in Brentford are expected beyond 2020/21, resulting in a further surplus.

8.54 In the long term, projections indicate at Borough level there is sufficient capacity for

an increase in pupil numbers, however in the Brentford Planning Area the forecast

indicates a shortfall; this in contrast to the other four planning areas which are

showing a long-term surplus. This situation is being kept under review but it is noted

that the Borough’s IDP and new Site Allocation and GWC Local Plan identifies a site

in Layton Road, Brentford, for a new primary school.

8.55 For this development, where a future deficit in primary places eventuates, a contribution towards additional pupil places through expansion or the new school at Layton Road would be able to be made from the CIL payment for the development.

Local Health Care

8.56 The ES has considered local health services within the locality, with GP practices and their ability to accommodate additional patients reviewed. The numbers of both patient lists and GPs does fluctuate and since 2015 GP’s have been free to register people from outside the boundary of their practice area.

8.57 There are no GP surgeries within 1.2 km of the site boundary; this distance was used as it is considered a reasonable walkable distance within which residents can access healthcare facilities. However there are three GP surgeries (with a total of 13 GP’s) located just beyond this at 1.3 km and so these were considered. The ES concluded there was not capacity to accommodate the needs of the development when using the NHS London Healthy Urban Development Unit’s (HUDU) benchmark of 1,800 patients per GP. The ES also concludes that cumulatively with the Homebase Site (473 homes and approximately 1,249 people) and other committed development; the demand for additional GP places cannot be accommodated. As such the ES considers that there would be a need for mitigation.

8.58 The Hounslow Clinical Commissioning Group (“CCG”) has considered the capacity of existing GPs and confirmed there is no available capacity to accommodate the additional population for the Tesco or Homebase development, with patient to GP ratios above the recommended ratio of 1 GP per 1,800 people.

8.59 As with education needs, the IDP has considered the health infrastructure needs arising from future housing growth in the GWC Plan area. It notes that the primary mechanism for Hounslow health services comes from central government capital funding. Some funding from strategic Community Infrastructure Levy payments from development is also able to support growth in services. The CCG which is responsible for planning and buying health services in the area and works with the NHS is planning to establish six health hubs in the Borough including in Chiswick Health Centre, Brentford Health Centre, West Middlesex Hospital, and Heart of Hounslow. The CCG has requested a contribution towards the primary care capital cost to improve Brentford Health Centre and Thornbury Road Health Centre. The GWC Local Plan identifies the need for additional healthcare capacity in the area and supports improvements to primary care facilities and expansion of existing health facilities into health hubs. The GWC Local Plan GWC7 supports the use of s106 contributions where necessary to make the development acceptable in planning terms. The CCG advise that although there s106 contributions have already been allocated towards Brentford Health Centre, there remains a funding gap and the need for further developer contributions to deliver the project.

8.60 In this instance the CCG requirement and the need arising from the development itself, and cumulative impacts with other developments, would need to be met by planned social infrastructure within the local area through government funding and use of section 106 contributions in line with the IDP.

8.61 The applicant has proposed a commitment to offering a new healthcare facility within the development to the CCG. The CCG’s preference would be to secure s106 contributions for improvements to Brentford Health Centre and Thornbury Road Health Centre, however they are prepared to consider an offer of a facility on site if it

is suitable for their needs. Given this position and that the application is at outline stage, it is considered the option can be secured through a planning obligation.

8.62 Therefore an obligation is recommended which requires a contribution towards primary health care, or the provision of an on-site facility to the satisfaction of the CCG.

8.63 Employment

8.64 The development will result in the removal of the existing Tesco store from the site; however this application is integrally linked to that for the re-development on the Homebase Site which proposes to relocate the Tesco store. The existing store has 290 FTE7 jobs, these would be transferred to the new store on the Homebase Site. It is proposed that if permission were granted, there would be a restriction on the demolition of the existing Tesco store until trading commences at the replacement store on the Homebase Site; this would ensure that there would be no loss of employment opportunities.

8.65 The development includes the provision of a minimum of 3,000 sqm non-residential uses on the Site, which would provide employment opportunities. Given the outline nature of the application and the flexibility of the new Use Classes order, there is limited information available at this time with regard to the exact uses and end users cannot be identified, however the illustrative masterplan envisages a range of uses and the Development Specification and Heads of Terms will ensure this. Consequently the ES has utilised the job density ratios set out in the HCA Employment Densities Guide 20158 to estimate the number of jobs generated by the proposal and tested a range, reflecting the assumed reasonable worst-case scenario and a mix reflecting the minimum development quantums set out in the Development Specification.

8.66 Taking this into account, the proposal has the potential for between 46-155 FTE jobs in the worst case scenario. Additionally, there is likely to be further employment opportunities at the Site from services such as cleaning, gardening, and maintenance etc. This is consistent with policy GWC1 of the GWC Plan which seeks to provide employment in the Opportunity Area in a format which optimises the use of land and re-provides and incorporates existing businesses.

8.67 The commercial uses proposed on the related Homebase Site would provide between 296 and 300 FTE jobs, so cumulatively the two developments will provide up to around 450 FTE jobs.

8.68 In addition to permanent employment, the construction of the development would also create many temporary jobs. It is estimated that over the 10 year construction period, an average of 317 FTE jobs per year would be created directly and indirectly through the construction activity and associated employment from expenditure.

Spending

7 FTE = Full Time Equivalent

8 Homes and Communities Agency, 2015. Employment densities guide 2015. Third Edition Available:

https://www.kirklees.gov.uk/beta/planningpolicy/

pdf/examination/national-evidence/NE48_employment_density_guide_3rd_edition.pdf

8.69 The new housing would add to the local population. The ES estimates that from this there will be an increase in overall spending of £6m from consumer spending as new residents use on-site and local shops and services to meet their day to day needs.

Skills and Training

8.70 London Plan policy E11, HLP policy ED4 and policy GWC1 of the GWC Plan all seek to secure employment and training initiatives for local residents where major development is proposed. This helps increase local skills and economic well-being of local people and enables more sustainable patterns of travel to work.

8.71 The development provides an opportunity to secure opportunities for construction training and possibly job brokerage to enhance skills and opportunities for local people, and obligations in this regard would be recommended.

Alternatives

8.72 The ES has outlined reasonable alternatives to the development proposed considered by the applicant and reasons the submitted scheme is the preferred proposal. The alternatives discussed included a ‘do nothing’ scenario, alternative locations and uses, and an alternative design and layout for the proposal.

8.73 A ‘do nothing’ alternative was not accepted as this would not make the most efficient use of the Site, which offers capacity for intensification. This would not deliver housing or employment opportunities or other environmental improvements. Alternative sites were not considered as the applicant has an interest in the Site. Additionally, the Site is allocated for a significant regeneration with a mixed-use development in the emerging Local Plan (GWC Plan and Site Allocations), and is a major site in the Great West Corridor Opportunity Area where significant housing and employment growth is proposed.

8.74 In respect of alternative designs, the proposal looked to ensure the development delivered a residential led, mixed use development with local scale commercial offering and improved public realm. The design of the development evolved through the pre-application process and consultation with various building heights and massing being considered. It is therefore concluded the appropriate alternatives were considered.

Conclusion

8.75 Overall the proposed uses are acceptable in principle and in accordance with the objectives of the NPPF and policies of the London Plan and HLP to encourage higher density, housing led, mixed-use development in accessible locations. The proposal is a major opportunity for regeneration of an underutilised brownfield site bringing a mix of uses that would meet objectives for the enhancement and supporting of employment and economic activity in the Great West Corridor Opportunity Area. The up to 1,677 homes would make a very significant contribution towards the Borough’s housing need and would be consistent with the emerging policies of the GWC Local Plan and Site Allocations.

8.76 The intensification of the use of the Site is compatible with the planning policy objectives for the Opportunity Area and will optimise the use of the out-of-centre retail site and its car park to deliver housing through mixed-use regeneration. Impacts on the local community infrastructure would be acceptable or would be able to be satisfactorily mitigated through funding from CIL, or provision of on-site facilities secured in the legal agreement where necessary. The resultant employment and training opportunities and spending would have a positive effect on the economy and economic well-being of the Borough.

8.77 Therefore the proposal complies with London Plan policies for ‘Good Growth’ (GG1-GG6), SD2, SD7, E11 and H1, HLP policies IMP1, SV1, TC3, SC1 and ED4, and is consistent with the emerging GWC Plan and Site Allocations, and the NPPF.

B. Affordable Housing and Tenure Mix

8.78 Paragraph 62 of the NPPF says where a need for affordable housing is identified, planning policies should specify the type of affordable housing required and that it should be normally provide on-site.

8.79 The LP emphasises9 that “…affordable housing is central to allowing Londoners of all means and backgrounds to play their part in community life. Providing a range of high quality, well-designed, accessible homes is important to delivering ‘Good Growth’, ensuring that London remains a mixed and inclusive place in which people have a choice about where to live

Affordable Housing Policy

8.80 LP policies GG4 and G5 says that to create a housing market that works better for all Londoners, more homes must be delivered, a strategic delivery target for 50% of all new homes to be genuinely affordable is supported, and that development should create mixed and inclusive communities, with good quality homes that meet high standards of design and provide for identified needs, including for specialist housing. LP policy SD1 seeks to ensure that that Opportunity Areas maximise the delivery of affordable housing and create mixed and inclusive communities.

8.81 LP policies H4, H5, H6 and H10 provide the framework setting out the requirements and approach to provision and assessment of affordable housing within developments. All major development with 10 or more homes are to provide affordable housing on-site through the threshold approach, which includes provision for a ‘Fast Track’ route to considering development viability.

8.82 LP policy H10 says that schemes should consist of a range of unit sizes depending on local need and demand, the nature and location of the site, the aim to optimise housing potential, and the role of one and two bed units in freeing up family housing.

8.83 HLP SC2 sets a strategic target that 40% of additional housing delivered across the borough between 2015 and 2030 be affordable. Schemes are expected to deliver a mix of 60% affordable/social rented and 40% intermediate tenures with an appropriate mix of housing size and tenure in accordance with housing need. This

9 Paragraph 1.4.2

policy predates the ‘Fast Track’ approach set out in the Mayor’s Affordable Housing and Viability Supplementary Planning Guidance (2017) and the policies of the published LP (2021).

Fast Track

8.84 LP policy H5 explains the ‘Fast Track’ approach to viability. It sets out that eligible planning applications are not required to submit viability information. Such applications need to:

1) Meet or exceed the relevant threshold level of affordable housing (35%) on site without public subsidy.

2) Be consistent with the relevant tenure split. LP policy H6 details the recommended affordable tenure split requirements with this being 30% affordable/social rent, 30% intermediate and the remaining 40% to be determined by the borough.

3) Meet other relevant policy requirements and obligations to the satisfaction of the borough and the Mayor where relevant.

4) Demonstrate that they have taken account of the strategic 50 per cent target in Policy H4 Delivering affordable housing and have sought grant to increase the level of affordable housing.

8.85 The threshold approach, including the ‘Fast Track’ route was first introduced in the Mayor’s Affordable Housing and Viability SPG in 2017. It aims to move away from protracted viability debates, create certainty in terms of affordable housing requirements, embed the requirements into land values, and offer a clear incentive for developers to increase affordable housing delivered through the planning system above the level in planning permissions granted in recent years. The supporting text to the LP says10 applicants are strongly encouraged to take the ‘Fast’ Track route by providing the threshold level of affordable housing and meeting other Development Plan requirements to the satisfaction of the Borough.

8.86 As fast tracked applications do not require a viability assessment at the application stage, the approach obliges submission of an Early Stage Viability Review if an agreed level of progress on implementation is not made within two years of permission being granted, in order to ensure an applicant fully intends to build out the permission.

8.87 Policy GWC2 of the GWC Local Plan is aligned with the new LP. It sets a strategic target of 50% of new housing to be affordable. It permits use of the Fast Track approach where applications propose at least 35% affordable housing, with the affordable housing to have tenure split of 70% London Affordable Rent or social rent and 30% intermediate. Where these conditions are met, the viability of the development would not be tested at the application stage, and there will not be any late stage review of viability.

Affordable Offer and Proposed Tenure Mix

10

Paragraph 4.5.1

8.88 This application is integrally linked to the Homebase Site application, with it intended that the existing Tesco store is relocated to the Homebase Site, freeing this Site for redevelopment, but only once the new replacement Tesco Store is completed. Both applications qualify for the threshold approach for applications under LP policy H5. They both provide a minimum of 35% affordable housing by unit, with the tenure mix agreed by the Borough. This means there is no requirement for a viability assessment from the applicant. This approach is consistent with policy GWC2 of the GWC Local Plan.

8.89 The application proposes 35% affordable housing by unit with a mix of 50% London Affordable Rent(LAR)/ Social Rent(SR) and 50% intermediate housing across both the Site and the Homebase Site developments. The application on the Homebase site is a full application proposing 100% of the affordable housing to be at London Affordable Rent / Social Rent and is to be delivered first out of the two sites. This application is in outline and would deliver the remaining affordable housing provision, meaning the remaining 15% LAR/SR and the 50% intermediate of the total affordable offer across the sites.

8.90 This is an outline application and therefore parameters for the development are set out, including the maximum number of homes, in this case up to 1,677 homes, as well as the percentage of affordable, in this case 35%. However the final numbers and a break down would be fixed at detailed design stage as part of any reserved matters application, consequently at this stage an overall range for the housing mix is proposed. Any subsequent reserved matters application would need to comply with this, and propose a mix within the relevant ranges.

8.91 The proposed housing offer including tenure and range of mix is show in the table below.

Table 3: Proposed Housing Tenure and Mix range

8.92 The proposal would provide 35% affordable housing on the Site, with a tenure split to result in no less than 50% London Affordable Rent by habitable room cumulatively across both Tesco and Homebase Sites. This is supported by the Councils

Proposed Housing (Tesco Site)

Bed

size/

No. of

persons

Market Intermediate Social/affordable

Min-Max Min-max Min-Max

Studio 5% - 9% 0% -6% 0%-0%

1-bed 30% - 36% 30% - 35% 22-26%

2-bed 42% - 48% 58 – 64% 41-45%

3-bed 12% -16% 0-5% 33-37%

4-bed 0% - 0% 0% - 0% 3-5%

Affordable Housing team, and is a result of negotiations with the developer which increased the offer from the initial position, where both sites were originally providing 35% by habitable room, with a mix 70% intermediate housing and 30% London Affordable Rented homes.

8.93 The table captures a range of mixes, to ensure any future application includes a mix of tenure types and unit sizes to meet the Borough’s housing challenges, including larger family housing. The mix range has been subject to negotiation resulting in an increase in the larger family homes, and is supported by the Council’s Affordable Housing Team. The provision of 35% affordable housing on this Site would be a substantial positive contribution towards the Council’s affordable housing targets, whilst the exact number of homes and tenure is to be determined; the illustrative masterplan includes over 560 affordable homes.

8.94 In addition the scheme would deliver 10% wheelchair user dwellings (Building Regulation M4(3) standard), with the remainder designed to be accessible and adaptable dwellings (M4 (2)) in accordance with LP polices D5 and D7 and HLP policy SC5. These requirements would be secured at outline stage through the control documents (development specification and design code); however the location, size and tenure of the wheelchair dwellings would be assessed and controlled through the reserved matters submissions.

8.95 The affordability of the affordable homes would be secured by section 106 obligations. There would also be an obligation that requires an Early Stage Viability Review to be undertaken if an agreed level of progress on implementation is not made within an agreed timescale, given that this scheme is linked to the development in the Homebase Site and that development would not be able to commence on this Site until the new Tesco store has opened on the Homebase Site, it is appropriate for this time period to be longer than the usual two years from permission being granted.

8.96 The GLA Stage I response has confirmed that the proposed affordable housing offer complies with the criteria for the ‘Fast Track’ route, and states that an early stage viability review mechanism should be secured, in accordance with LP policy H5, together with provision for the applicant to fully explore grant funding to be incorporated to provide additional affordable housing beyond the baseline level of affordable housing.

Conclusion

8.97 The proposed 35% affordable housing on Site and tenure split would deliver a significant number of affordable homes. The proposed Fast Track approach is appropriate subject to further exploration of grant funding to potential increase the level of affordable housing, with regard to the 50% strategic affordable target of the LP and GWC Local Plan, with this requirement and the proposed tenure and mix range for the affordable units to be secured by a s106 agreement.

8.98 The strategic opportunity provided by the related redevelopment of the Homebase Site, which facilitates this proposal is also acknowledged, with this providing early delivery of 164 100% LAR/SR units, as part of the comprehensive affordable offer over the two linked sites.

C. Sustainability

8.99 At the heart of the NPPF is a ‘presumption in favour of sustainable development’, which requires local authorities as part of any plan-making or decision-making to provide clear guidance on how the presumption should be applied locally. In addition, the NPPF states

‘The planning system should support the transition to a low carbon future in a changing climate, taking full account of flood risk and coastal change. It should help to: shape places in ways that contribute to radical reductions in greenhouse gas emissions, minimise vulnerability and improve resilience; encourage the reuse of existing resources, including conversion of existing buildings; and support renewable and low carbon energy and associated infrastructure.’

8.100 The LP and HLP encourage sustainable development through many policies including promoting the use of energy efficient building design and materials, re-use of previously developed land and existing buildings, and location of development in or close to town centres and areas with good public transport.

Sustainable Design

8.101 LP policy SI2 relates to minimising greenhouse gas emissions and states major development should be net zero-carbon. The policy sets out the energy hierarchy, and that this should inform the design, construction and operation of new buildings, with the priority to minimise energy demand and then address how energy will be supplied and renewable technologies incorporated. All developments should maximise opportunities for on-site electricity and heat production from solar technologies (photovoltaic and thermal) and use innovative building materials and smart technologies.

8.102 A minimum on-site reduction of at least 35% beyond Building Regulations is required and developments are expected to achieve carbon reductions beyond Part L from energy efficiency measures alone to reduce energy demand as far as possible. Residential development should achieve 10 per cent and non-residential development should achieve 15 per cent over Part L.

8.103 The emissions reduction target should be achieved in accordance with the following energy hierarchy:

o be lean: use less energy and manage demand during operation

o be clean: exploit local energy resources (such as secondary heat) and supply

energy efficiently and cleanly

o be green: maximise opportunities for renewable energy by producing, storing

and using renewable energy on-site

o be seen: monitor, verify and report on energy performance

8.104 Where it is clearly demonstrated that the zero-carbon target cannot be fully achieved on-site, any shortfall should be provided either through a cash in lieu contribution to the borough’s carbon offset fund, or off-site provided that an alternative proposal is identified and delivery is certain.

8.105 In addition, the whole life-cycle carbon emissions of a development should be calculated through a nationally recognised Whole Life-Cycle Carbon Assessment and actions taken to reduce life-cycle carbon emissions should be demonstrated.

8.106 LP Policy SI3 relates to Energy infrastructure, and states major development proposals within Heat Network Priority Areas should have a communal low-temperature heating system with the heat source for the communal heating system selected in accordance with the following heating hierarchy:

a) connect to local existing or planned heat networks

b) use zero-emission or local secondary heat sources

c) use low-emission combined heat and power (CHP)

d) use ultra-low NOx gas boilers

8.107 LP Policy SI4 relates to managing heat risk states that major development proposals should demonstrate through an energy strategy how they will reduce the potential for internal overheating and reliance on air conditioning systems in accordance with the cooling hierarchy.

8.108 These policies are also supported by other policies of the LP such as SI5 Water infrastructure, SI12 Flood risk management, SI1Sustainable drainage and G5 Urban Greening to maximise the sustainability of development, with environmentally sustainable practices to be incorporated in designs including achieving internal water use of 105L/Person/Day or less and sustainable material standards.

8.109 Policy EQ1 of the HLP says all development should meet the carbon dioxide emission reduction requirements of the LP, and major developments should consider additional energy reduction measures. Policy EQ2 relates to Sustainable Design and Construction and states developments should incorporate established principles for sustainable design and construction as set out in the LP. Non-residential development should be assessed against BREEAM and meet a rating of Excellent.

Sustainability Assessment 8.110 The application was accompanied by a detailed Energy Statement and Sustainability

Statement, in accordance with LP policy SI2. The submitted documents show an onsite reduction in emissions of 60% below baseline.

8.111 The Report details how the development can secure an on-site carbon dioxide emissions reduction. In this regard the development addresses the energy reduction hierarchy as follows:

Be Lean

Demand reduction measures to be incorporated within the scheme include insulated building fabric with low air permeability, glazing with suitable U-value, g-value and daylight transmittance, mechanical ventilation with heat recovery and low energy lighting.

The building fabric performance (thermal transmittance and air permeability) is proposed to be in excess of the minimum standard required under Building Regulations to help reduce the heating and cooling demands of the development. The regulated carbon dioxide savings achieved from the application of ‘lean’ measures are calculated to be 12 % over the Building Regulations 2013 Part L notional base case for domestic properties and 18 % for non-domestic properties. Be Clean

Use of high temperature air source Heat Pumps, which can supply 100% of the energy demand meaning electricity is used as the fuel source. Gas boilers are provided as a backup only.

An Energy Centre will be located in Block H, this would contain the heat pump internal units, gas boilers, thermal stores and other ancillary plant.

Roof space will be utilised for the heat pump units and will all feed back to the single Energy Centre

The Energy Centre will be adaptable in the future for connection to an area-wide heat network should one become available that is appropriate to connect to. The potential for future connection has been incorporated into the design.

All residential dwellings will be connected to the heat network, with all non-residential units given connection points.

The use of CHP contributes savings of a further 46 % over the Part L 2013 base case for domestic properties and 39 % for non-domestic properties.

Be Green

Use of PV panels on available roof space.

The use of renewable technologies delivers savings of further 3% for domestic properties

Be Seen

Standard monitoring of the Energy Centre and heat network will be undertaken during operation. It is expected that the following will be metered:

o Resources used in the Energy Centre;

o Heat leaving the Energy Centre;

o Heat entering each block;

o Final customer heat consumption.

The metering and controls strategy will be further developed during the detailed design process.

8.112 Overall (domestic and non-domestic) 60.0 % CO2 emissions savings over the Part L 2013 notional base case is achieved.

8.113 Conditions and obligations are recommended to ensure that through the reserved matters and phasing the development would deliver a minimum of 60% reductions on a site wide basis, including achieving 12% reduction at Be Lean stage (obligation), as well as to secure appropriate water efficiency and sustainable sourcing of materials.

8.114 In addition the applicant has submitted a Whole Life Cycle Carbon Emissions Review to give early recommendations of how to minimise embodied carbon in the construction of the development. This includes encouraged reuse and recycling of materials, consideration of the building materials used for the development, as well as built form. Given the application is at outline, this would be finalised at reserved matters stage.

8.115 It is considered that the approach taken has maximised on site emission reductions; this is considered acceptable and fully supported. In order to achieve compliance with the ‘zero carbon’ standard, the applicant is required to make a financial contribution to the Council’s Carbon Offset Fund; this will be secured through the legal agreement (S106). The exact Carbon Offset Payment would be calculated based on the final detailed designs as part of reserved matters submissions.

8.116 The applicant proposes a 100% electric solution with Air Source Heat Pumps (ASHPs) providing heating and hot water.

8.117 The landscape led approach to the scheme ensures that a range of urban greening measures can be incorporated into the development, the illustrative masterplan shows planting and habitat areas around the proposed swale and the Water Gardens, together with tree planting and green podiums and roof terraces. This overall approach to urban greening is strongly supported. The potential for the scheme to accommodate urban greening and overall green cover should be maximized in the detailed design of the scheme, and conditions are recommended to ensure a site wide Urban Greening Factor (UGF) assessment is submitted at reserved matters stage, in accordance with Policy G5 of the London Plan.

3. Conclusion

8.118 The proposal includes measures to ensure the development is able to achieve high standards for energy efficiency and sustainable building design. Conditions and obligation are recommended to secure details of the various measures proposed. There is a shortfall in the CO2 emissions reduction that would be met through a contribution to the Council’s Carbon Offset Fund. With this contribution and the design mitigation inherent within the proposed buildings, the development would meet relevant objectives in regards to sustainable design.

D. Urban Design and Impacts on the Townscape

Design Policy Context

8.119 The NPPF states good quality design is a key aspect of sustainable development, creates better places in which to live and work and helps make development acceptable to communities. Decision takers should always seek high quality design, and should ensure developments:

a) will function well and add to the overall quality of the area, not just for the short term but over the lifetime of the development;

b) are visually attractive as a result of good architecture, layout and appropriate and effective landscaping;

c) are sympathetic to local character and history, including the surrounding built environment and landscape setting, while not preventing or discouraging appropriate innovation or change (such as increased densities);

d) establish or maintain a strong sense of place, using the arrangement of streets, spaces, building types and materials to create attractive, welcoming and distinctive places to live, work and visit;

e) optimise the potential of the site to accommodate and sustain an appropriate amount and mix of development (including green and other public space) and support local facilities and transport networks; and

f) create places that are safe, inclusive and accessible and which promote health and well-being, with a high standard of amenity for existing and future users; and where crime and disorder, and the fear of crime, do not undermine the quality of life or community cohesion and resilience.

8.120 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 the way it functions.

8.121 Two passages in the National Design Guide 11are particularly apt: “Well-designed tall buildings play a positive urban design role in the built form. They act as landmarks, emphasising important places and making a positive contribution to views and the skyline.” 12 and: “Today’s new developments extend the history of the context …representing the architecture & placemaking of the early 21st century”13.

London Plan

8.122 Chapter 3 of the London Plan has design policies that look to deliver the ‘Good Growth’ objectives of the plan. It notes14 that change is a fundamental characteristic of London and that respecting character and accommodating change are not mutually exclusive, and that an understanding of the character of a place should not seek to preserve things in a static way but should ensure an appropriate balance is struck between existing fabric and any proposed change.

8.123 Policies D2 and D3 seek to make the best use of London’s finite supply of land and find the most appropriate form, scale and land use for the site taking into account existing and planned infrastructure, the attributes of the site and its context, and its accessibility. These policies provide a range of urban design principles requiring the building form and character to be appropriate with high quality buildings,

11

MHCLG ‘National Design Guide’ January 2021 12

MHCLG ‘National Design Guide’ January 2021 pg 20, para 70 13

MHCLG ‘National Design Guide’ January 2021 pg 12, para 49 14

Paragraph 3.1.7 pg 106.

accommodation and spaces including public realm, inclusive and legible movement routes that promote walking and cycling, urban greening and high sustainability.

8.124 Policy D4 emphasises the importance of appropriate design scrutiny with the higher the density the greater scrutiny, including from planning, design and conservation officers, and Design Review. Policies D5, D6 and D7 set out standards for accessibility and good quality housing. Policy D8 promotes a ‘Healthy Streets Approach’ and looks to maximise high quality new public realm, especially to encourage walking and cycling and provide more attractive landscaping, greening and safety, and places for people to meet.

8.125 Policy D9 sets out how development proposals should address the visual, functional, environmental, and cumulative impacts of tall buildings. The supporting text15 to the policy says that:

“Whilst high density does not need to imply high rise, tall buildings can form part of a plan-led approach to facilitating regeneration opportunities and managing future growth, contributing to new homes and economic growth, particularly in order to make optimal use of the capacity of sites which are well-connected by public transport and have good access to services and amenities. However, they can also have detrimental visual, functional and environmental impacts if in inappropriate locations and/or of poor quality design”.

8.126 Tall buildings should be part of a plan-led and design-led approach, incorporating the highest standard of architecture and materials and should make a positive contribution to the existing and emerging skyline. There should be an appropriate transition in scale where sites adjoin buildings of significantly lower height. Buildings should aid legibility and wayfinding and include active ground floor uses to ensure such buildings form an appropriate relationship with the surrounding public realm.

8.127 They also need to be appropriately located in respect of the capacity of the area and its transport network in terms of access to facilities, services, walking and cycling networks, and public transport. Regeneration benefits should be maximised as a catalyst for further change in the area. However, tall buildings should not have an unacceptably harmful impact on their surroundings in terms of their visual, functional, environmental and cumulative impacts, including wind, overshadowing, glare, strategic and local views and heritage assets.

8.128 In respect of heritage, proposals should take account of, and avoid harm to the significance of London’s heritage assets and their settings. Proposals resulting in harm will require clear and convincing justification, demonstrating that alternatives have been explored and that there are clear public benefits that outweigh that harm. The buildings should positively contribute to the character of the area. Buildings in the setting of a WHS must preserve, and not harm, the Outstanding Universal Value of the WHS, and the ability to appreciate it. Detailed policies relating to heritage impacts are discussed further below.

8.129 Policy D11 and policy D12 require design considerations to include measures to deter crime and to incorporate appropriate fire safety standards.

15

Paragraph 3.9.1 pg 141.

8.130 Policy D13 and D14 look to ensure new development does not unduly affect existing neighbouring uses, and that potential impacts from noise are addressed in the design

Hounslow Local Plan

8.131 The current HLP has policies with similar objectives. HLP policy CC1 states that development proposals should have due regard to the Hounslow Context and Character Study 2014’ which analyses the urban character of the Borough and policy CC2 states that the Council will retain, promote and support high quality urban design and architecture to create, attractive, distinctive, and liveable places.

8.132 HLP policy CC3 outlines the Council’s approach to tall buildings. It says that to contribute to regeneration and growth, the Council will support high quality tall buildings in identified locations which accord with the principles of sustainable development. It goes on to list 12 criteria against which the Council would expect proposals for tall buildings to comply as follows:

“Be sensitively located and be of a height and scale that is in proportion to its location and setting, and carefully relate and respond to the character of the surrounding area;

Be of the highest architectural design and standards; be attractive, robust and sustainable;

Be of a scale that reflects their relevance and hierarchical importance when located within a grouping/cluster of tall buildings;

Be designed to give full consideration to its form, massing and silhouette including any cumulative impacts and the potential impact of this on the immediate and wider context;

Relate heights to widths of spaces to achieve comfortable proportions, and provide a positive edge to the public realm and a human scale through the careful treatment of ground floors and lower levels;

Provide for a comfortable and pleasant microclimate which minimises wind vortices and over-shadowing;

Provide for biodiversity within the building form and be sensitive to surrounding open spaces including waterways to ensure minimal impact;

Take opportunities to enhance the setting of surrounding heritage assets, the overall skyline and views;

Carefully consider the façade and overall detailing to ensure visual interest, vertical and horizontal rhythms, an indication of how the building is inhabited, internal thermal comfort and the visual break-up of the building visually at varying scales;

Use materials and finishes that are robust, durable and of the highest quality, with facades providing innate interest, variety and function;

Incorporate innovative approaches to providing high quality, usable, private and communal amenity space where residential uses are proposed; and

Comply with the requirements of the Public Safety Zone for London Heathrow Airport, where appropriate.”

8.133 In respect of MOL, HLP policy GB1aims to protect and enhance its openness, quality and permanence, and expects development to maintain the openness, setting and visual amenity where it is located near MOL, with particular attention given to the location, setting, design, materials, height and landscaping. There is also specific heritage policy CC4 discussed further below.

8.134 HLP policy SC4 says the scale and density of development will need to make efficient use of land to achieve high quality design and accessibility, whilst responding to and reflecting local context and character and protecting existing residents’ amenity.

GWC Plan and Site Allocations

8.135 As noted, although the GWC Plan and Site Allocations, and related Masterplan are emerging planning documents of limited weight given their current status, they are consistent with the objectives for growth and development within the Opportunity Area and indicate the direction of travel for more intense development in the corridor.

8.136 These emerging documents allocate the Site for a more intense mixed-use development with significant housing, local retail and enhanced public realm. They include recommendations in respect of appropriate building heights, including general height and massing and taller focal elements. However these heights are not a blueprint for proposed tall buildings, they are an indication of what may be appropriate. Whether or not they are acceptable would be the subject of detailed analysis and ultimately consideration of impacts and the overall planning balance. The Masterplan also acknowledges that it is unlikely that all new development will be designed so as to be invisible within the setting of nearby heritage assets such as conservation areas and listed buildings. Where acceptable levels of intrusion into important settings occur, they should be imaginative, of good design quality and appropriately scaled, and in respect of heritage assets any harm to their significance would need to be convincingly outweighed by public benefits.

8.137 GWC Plan Policy GWC4 focuses on Open Space and Green Infrastructure and expects developments to contribute towards improving the quality, function and offer of existing open spaces and the delivery of new high-quality publicly accessible squares and open spaces, including green public open space and water garden on the Site.

8.138 GWC Plan policies GWC5 and GWC6 focus on optimising redevelopment opportunities and enhancing the overall environment, especially public realm, whilst respecting the area’s distinctive character and heritage. Harm to the setting of heritage assets including Kew WHS should be avoided. The GWC Plan and the Masterplan indicate that general building heights at the Site should be from 6 to 8-storeys, plus possibly an additional 1 or 2-storeys above this if setback from the main part of the building, with height lower towards Syon Lane and MacFarlane Lane, and potential for a cluster of taller elements (up to 65.5m AOD; 10-14 storey) with the taller buildings in the north east of the Site.

8.139 GWC Plan policy P1 supports the comprehensive redevelopment of Tesco and Homebase sites with quality mixed-use schemes that enhance the townscape and connections to existing and new infrastructure including green spaces. Tall buildings are to be of an exemplary design and buildings should establish a strong sense of enclosure. High quality public realm improvements that improve conditions for walking and cycling, including enhancing the underpass at Gillette Corner, creating a segregated cycleway along the Great West Road, and providing a ‘clean air’ route parallel to the Great West Road.

Urban Design and Townscape Impact Assessment

Design and Access Statement

8.140 The applicant’s Design and Access Statement (“D & A”) provides information about the evolution of the design and the factors taken into consideration when preparing the scheme, which included the existing and emerging planning policy framework. It identifies site constraints and opportunities and explains the design approach, concepts and principles that underpin the proposed masterplan with the rationale for these.

Parameter Plans and Design Code

8.141 Matters such as the locations of blocks, the size of the block footprints, maximum heights of blocks and the distribution of different uses within each of the plots are set out in the Parameter Plans submitted for approval with the application.

8.142 The applicant’s Design Code sets out the key principles and standards to guide the detailed design of the scheme. Due to the outline nature of the application, the detailed design and appearance of the proposed buildings would be dealt with in subsequent reserved matters submissions if permission were granted.

8.143 The submitted Design Code document provides a clear framework to ensure that a high-quality development would be delivered, and that the ambition for the character for each of the building type would be realised and complement each other, as well as sitting within the emerging surrounding built environment. Each reserved matter submission will be expected to demonstrate how it complies with the parameter plans and Design Code document and this requirement would be secured by relevant planning conditions.

Townscape and Visual Impact Assessment

8.144 A Townscape and Visual Impact Assessment was submitted as part of the ES. This document also informs the applicant’s Heritage Statement that considers impacts of the proposal on the settings and significance of heritage assets in both the nearby streetscene and in long distance views including various listed buildings, conservation areas, registered parks and gardens and the Royal Botanic Gardens WHS. The impacts on the significance of heritage assets are considered separately below.

8.145 The ES assesses potential townscape impacts from agreed viewpoints that were selected in consultation with officers. Verified views provided in accurate visual

representations (“AVRs”) show the proposed development’s maximum parameters inserted as a wireline to demonstrate how the proposal would look from different locations. Such AVRs are static representations of how the proposal would be perceived, and views vary when moving around the site but it is impractical to evaluate every single point from where the development may be seen, however the selected views are considered to be the most representative and sensitive locations.

Townscape and Landscape Context

8.146 Immediate context – The Site lies to the North of Syon Lane and lies at a point of transition between the larger scale commercial development and suburban scale residential development. To the north and east lies the Sky Campus and West Cross Industrial Estate characterised by larger footprint buildings and a variety of buildings of differing ages and scales in a variety of commercial and industrial uses. The area to the south and west is residential and comprises predominantly two and three storey suburban properties. The properties to the West of the site including those in Oaklands Avenue are located within the Osterley Park Conservation Area with this area recognised as reflecting the suburban character of their time and particular merit in the integrity of roofs, architectural features and quality of materials. To the North West it is more open with sports pitches within an area of MOL.

8.147 Immediately to the east of the Site, extending along Syon Lane, is the listed landmark Gillette Factory and further east lies the Great West Road where commercial buildings are generally large but predominantly low rise though very tall buildings including the GlaxoSmithKline building are apparent in the townscape. There are some high quality historic Art Deco style buildings with positive street frontages, as well as more modern buildings that are setback from the road by car parking which also lack architectural merit. Poor quality footpaths and cycleways, and a lack of vegetation also detract from the townscape.

8.148 The existing Tesco building is set back from the street frontage with a large expanse of car park adjoining Syon Lane, the building itself has no particular architectural merit, wide green verges and the Water Garden seek to soften the site but its large areas of car parking and inactive frontage makes its overall townscape contribution a negative one and the site is underutilised.

8.149 Wider context – With tall buildings proposed, the development would be likely to be seen from considerable distances away in some viewpoints. Further away from the Site the general pattern of large commercial buildings continues east along the Great West Road with residential areas to the south. To the West the MOL continues with large open spaces including the golf course, and Osterley Park, a historic listed park and garden, both of which form part the Osterley Park Conservation Area. To the south east, across the Great West Road, more suburban scale housing is found and beyond this it opens out into another large open space and historic listed park and garden, Syon Park. Even further across the Thames, around 1.8km from the Site, is the Kew Gardens WHS, which is also a conservation area and registered park and garden. These historic listed parks and gardens also include various listed buildings including Osterley House and Syon House. As noted, the effects of the proposal on the significance of these heritage assets are discussed separately.

Design Scrutiny and Appraisal

8.150 In accordance with LP policy D4 the design of the proposal has been scrutinised by

the Council’s urban design, conservation and planning officers, and has been the subject of a process of independent design review. The design of the proposal has also been assessed by officers of the GLA.

Site layout & public realm

8.151 The proposal would transform the Site which presently has large areas of surface car parking with the existing building set well back from the street. The development is comprised of nine blocks and three focal, public, open spaces spaced across the Site. The blocks are located to frame the edges of the open spaces and the streets, both internal and external; the blocks are a mixture of courtyard style blocks with internal podium level communal amenity space, standalone blocks and terraced housing. The blocks do not extend to the site boundaries; a buffer is maintained around the edge of the site. The mixture of uses will bring more activity to the site, with the non-residential uses concentrated towards the eastern edge.

8.152 The overall masterplan for the site takes a landscape led approach and seeks to retain the existing green edges around the site, including the publically accessible Water Gardens in the North, and create two new areas of public open space within the Site, as part of substantial public realm provision. The blocks that form the overall development have been designed to maximise the connections through the site, paying consideration to the existing urban grain in the surrounding area, and forming a hierarchal street network consisting of a primary route from the vehicle access point, and secondary routes that provide connections between the public squares within the development. This layout assists with legibility and ensures a development that is permeable and provides connectivity with the surrounding areas. The blocks have been designed to create a north-south grain and maximise the east and west orientation of the new homes, as well as providing south facing courtyards, enabling sunlight to penetrate these communal spaces and the public realm.

8.153 The streets, spaces and blocks have been put into a hierarchy in terms of their location, size and function within the site, and these are set within the Parameter Plans and Design Code.

8.154 The layout proposes a large area of public open space (‘the Clearing’) towards the eastern edge of the site providing a focal point to the development; this is presented as a civic square with flexible performance/ event space. The layout of the blocks framing this space have been placed to allow views of the Gillette Tower, acknowledging this heritage asset and local landmark on the adjacent site, whilst providing a sheltered and enclosed public space. The provision of a mix of non-residential uses at ground floor surrounding the space would help to animate and activate it, and the location of the non-residential uses in this area will also help Grant Way, along the eastern boundary of the site, to become a more active street and increase surveillance. A mix of hard and soft landscaping is proposed in this area, with the Design Code securing a minimum area of 2,250 sqm and mandatory features such as the inclusion of a flexible performance/ event space, water feature, seating and planting.

8.155 The second public space to the west (‘the Meander’) would be a softer space incorporating play space and framed by residential buildings. This space would be well-integrated with the movement network and has also been designed to retain views of the Gillette Tower. It also provides a ‘green link’ through the site from Syon Lane to the MOL located to the north west providing an attractive route through the site with a space for relaxation away from the main routes through the site. Minimum separation distances between the buildings across this space are set in the parameter plans, and the Design Code sets out minimum area and mandatory features to be included.

8.156 Public access through the Water Gardens would be retained, with the space being transformed with a mix of residential and non-residential uses fronting onto the Gardens bringing activity to this edge of the site, increasing surveillance and taking advantage of this currently underutilised area. The landscape approach seeks to upgrade the water body and provide a wetland / habitat area, distinct from the other spaces on the site.

8.157 These spaces would help create a new character for the site, offering a range of spaces which are unique within the surrounding area and provide an opportunity to incorporate local identity, whilst at the same time providing highly durable and attractive spaces. The parameter plans and design code set out the location for the spaces, and criteria such as minimum separation distances for buildings framing the space, minimum area and mandatory features; all of which will ensure the final design provides high quality spaces.

8.158 It is considered that the treatments and connections between these spaces would also assist with way-finding through the site at a street level scale, these would be considered in detail at reserved matters stage but would need to demonstrate compliance with the Design Code. Overall there would be a minimum of 20,000 sqm publically accessible space.

8.159 The layouts restricts vehicle movement through one main access point from Syon Lane in the South, only essential vehicle access, including buses and refuse trucks, would utilise McFarlane Lane and Grant Way. The site is permeable for pedestrians and cyclists, with routes around and through the site and the street typologies proposed also follow the landscape-led approach with generous tree planting and verges. The east-west ‘Lanes’ would be more residential in character. The Design Code sets out the required design approach and key features of each of the key routes, the site layout and the distribution of frontages; this safeguards the design principles and ensures it will be upheld through future Reserved Matters applications.

8.160 Across the development, maisonettes and townhouses will provide frontages to the street, giving direct access and providing an active street frontage and an opportunity to integrate a sense of ownership to the landscaping through semiprivate and private spaces adjacent to these properties. It is considered that the layered approach of spaces throughout the development would help to maintain residents’ privacy at ground floor whilst also providing attractive pedestrian routes through the site.

8.161 The submitted Design Code provides a good level of detail to ensure that key design principles will be secured, and the highest quality of development is delivered. The indicative scheme that has been submitted by the applicant in support of the proposals demonstrate one way in which the scheme could come forward whilst complying with the requirements of both the Parameter Plans and the Design Codes.

8.162 The layout of the proposed development is supported by the GLA and Council Officers and has the potential to create a high quality development complementing the existing and emerging character of Great West Corridor.

Scale, massing & height

8.163 Hounslow’s adopted Local Plan Policy CC3 supports tall buildings along sections of the A4 Golden Mile frontage, subject to design and heritage criteria which require these to relate sensitively to surrounding residential areas and should not have a significant adverse impact on the setting of, or views from heritage assets including Gunnersbury Park, Royal Botanic Gardens Kew World Heritage Site, Syon Park and Osterley Park. It goes on to state that specific sites for tall buildings will be identified in the Great West Corridor Plan.

8.164 The proposed development is high density, and includes a series of tall buildings (defined in the HLP as those over 6-storeys or 20m tall) up to 17 storeys. The proposed building heights would be a step-change compared to the scale of existing development on the Site and its surrounding context. Consequently there would be a high magnitude of change to the local townscape, and owing to the height of the buildings, they would be able to be seen from longer distances and so potentially impact on the setting of heritage assets in the surrounding area. Parts of the development would be seen from within Osterley Park, upper floors of some blocks would be glimpsed in views from certain parts of the western side of Syon Park, and there are very limited points adjacent to Kew Gardens WHS where there are partial glimpses.

8.165 As set out above the site lies within the Great West Corridor Opportunity Area set out in the London Plan, and as such the area will undergo a transformation to achieve the strategic planning aspirations in terms of housing delivery and place-making. The emerging GWC Local Plan and Site Allocations, supported by the Masterplan, look to advance the regeneration of the Great West Corridor and will identify the preferred locations for tall buildings accounting for wider impacts including heritage. These documents suggest appropriate heights and massing, though as discussed above, they are not yet adopted and so have only limited weight. They envisage substantial change in the area, with more intense development which includes tall buildings (over 6-storeys).

8.166 The acceptability of tall buildings on this site should therefore be assessed against the criteria within LP policy D9 and current HLP Policy CC3, noting that the site does not fall within one of the areas identified as being suitable for ‘tall’ buildings given it does not front the A4 Golden Mile and the GWC Local Plan is not adopted.

8.167 The proposed development has sought to optimise the potential residential and non-residential development capacity and provide an appropriate mix of uses to support the wider regeneration objectives.

8.168 The new buildings would be prominent additions to the townscape. As noted the proposed blocks range from 2 to 17-storeys, including a series of 10, 12, 14, 15, 16 and 17-storey buildings, these are arranged around areas of public realm and have been designed to step up in height towards the centre and north of the site. A terrace of two storey houses line the western edge of the site, responding to the scale of properties on Orchard Avenue and the heights along Syon Lane are limited to 3, 4 and 5 to 6-storeys with shoulder heights maintaining a massing relationship with the Gillette Building, and taller elements set back into the site; this stepping down in scale towards the more sensitive boundaries is welcomed and would help bridge the transition in scale.

8.169 The proposed heights ensure the most efficient use of the site is made and advantage is taken of the relatively unconstrained northern part of the site. The massing and layout proposed also steps down the height of the linear middle elements of the blocks to maximise the potential for daylight and sunlight penetration within the scheme. The taller elements are fully integrated into the wider urban form and address the street, with the majority of them forming part of a courtyard block. The locations of the taller elements have been determined to help assist with legibility and way-finding through the site, marking key routes through the scheme and helping to frame ‘The Clearing’ whilst respecting the setting of the Gillette building, and maintaining views of its façade and tower along Syon Lane in both directions.

8.170 The proposal would undoubtedly significantly change the character of the Site and the wider townscape. It would be conspicuous in many views within the surrounding area and visible from some distance. However, it is noted that simply being able to see a new building does not make the design poor or its effect on its surroundings harmful. The location and heights of the taller elements have been refined to create a layered form which satisfactorily respects the transition in scale and character between the existing and emerging contexts, and an interest in the skyline. Furthermore, the architectural quality of buildings is a material consideration when assessing the quality of the design and as set out above the principles for this are established in the Design Code which is considered robust, and any future reserved matters would have to demonstrate compliance with this. A full assessment of the impact of the proposals on Heritage assets is given later in this report.

8.171 An assessment on microclimate and overshadowing has been undertaken and demonstrates that the proposed building heights would not have an unacceptable impact on amenity in this regard. This is discussed in detail in other sections relating to impact on neighbours and housing quality.

8.172 Green and brown roofs would be provided to a number of buildings across the development which would help promote biodiversity within the development. This is discussed in detail in other sections relating to sustainable development and biodiversity.

8.173 The impact of the development on residential amenity will be discussed in detail in the following section, however it is noted that the taller elements of the development, being located towards the centre of the site and away from adjoining residential properties, would minimise the level of impact on the amenity of these residents.

8.174 The visual impact of the proposed development on the Metropolitan Open Land (MOL) to the north has been considered. Whilst the blocks would be highly noticeable from within, and significantly change the wider setting and character of the MOL; the spatial openness would not be impacted, nor would the recreational value or use of the open space. The proposed stepped massing would create an interesting skyline and strong urban backdrop to the open space, which subject to high quality design, is acceptable in this instance.

8.175 The design of all buildings, but particularly the taller elements, will be essential to ensure they deliver the highest quality architecture and secure successful place making. The Design Code robustly secures the required design principles and allows for the resultant buildings to be expressed in different architectural shapes and forms. The Design Code would ensure that architects working on the future phases of the development secure a coherent scheme with each phase being compatible and complementary with each other as well as the surrounding existing and emerging context. Full compliance with the Design Code will be tested at the reserved matters stage.

8.176 The heights have been assessed in terms of their visual impact and whilst it is accepted that significant change will occur as part of the development of this and the Homebase Site it is considered that a suitable balance has been achieved between protecting the setting of existing heritage assets, the amenity of existing and future residents and the making of place.

8.177 It is considered therefore that the overall height and massing of this outline scheme in terms of townscape and urban design (sense of place, density, new public realm, landscaped areas and active frontages) would accord with the objectives of sections 12 of the National Planning Policy Framework, policies D3, D4 and D9 of the London Plan and would broadly accord with the design criteria established in adopted Local Plan Policy CC3. The architectural merit of the proposed taller buildings will be scrutinised at reserved matters stage to ensure they meet with the highest standards of design.

Materiality & typology

8.178 The proposal is based around five key building typologies that help to define the individual character areas within the development and build upon the hierarchical street network. There is guidance on the general form and character, façade character and architectural reference for each typology, as well as general principles to ensure a harmonious appearance and consistent design quality is delivered.

8.179 The building block typologies provide the opportunity to help reduce the mass of the development and provide a means to delineate the public realm from private spaces within the arrangement. Building frontage character relates closely to the type of route or space defined by that particular building (e.g. primary, secondary, The Clearing, Water Gardens). Whilst the architectural concept allows for each building block to have its own identity, where there is the opportunity, through materiality and other features (fenestration, balconies, etc.) to create a sense of uniformity within the development this would be taken to ensure that the proposal would be harmonious and not become overly complicated. The Deign Code includes key Built Form

principles applicable across the site, design principles for each development parcel and building typologies.

8.180 The proposal seeks to use the highest quality materials to make a positive contribution to the public realm, streetscape and wider townscape. Predominantly the development will consist of brick facades, helping to resonate with the local context, but also allowing for variation between blocks as well as introducing texture, longevity and consistency across the scheme.

8.181 All of the above is captured within the Design Code, which is considered to be robust and provide an appropriate range of design principles and requirements.

Design Review

8.182 LP policy D4 requires larger, higher density schemes to undergo additional design scrutiny with this to include independent design review. Applicants are also required to explain how they have considered and addressed the design review recommendations. The application (and the Homebase Site) was considered by Hounslow’s Design Review Panel (“DRP”) both prior to submission and post submission. Guidance on the role of such reviews is that they should not to dictate the design of a scheme or contradict planning policy, but look to guide better design outcomes instead.

8.183 The DRP’s initial review raised a range of issues about the amount of development and the overall strategy for the Site urging the Team to have a clearer ambition for the kind of place being created and how people might live their lives within it, and were unconvinced that the scheme yet succeeded in its ambition of being a ‘landscape driven masterplan’. The applicant reviewed their design as set out in the D&A accompanying this application to address some of these concerns. The post review DRP acknowledged the applicant had made changes but that these did not fully address the issues highlighted.

8.184 The latest DRP comments confirmed the Panel were on board with the refined strategic objectives of the scheme, liked the desire to create a hub for a mixed community on the Site, and commended the work done to develop a stronger character for both the buildings and the landscape with a variety of typologies which could create strong marker points to a brand new settlement. However, they retained concerns over the overall amount of residential accommodation and expressed concerns with the size of the public spaces and that these spaces may not function as intended. They were supportive of how the design distinguishes between taller elements with lower linking blocks, but there were concerns over the amount of development and distribution in relation to heritage, noting clusters of slender towers could help redistribute height and mass, subject to appropriate view testing. The concerns about the amount of development included the number of single aspect units.

8.185 To address comments from the DRP as well as comments from Council officers, revisions to proposal were made through the pre-application process and amendments were also made to the submitted proposal, particularly in relation to the proposed houses to the west of McFarlane Lane reducing their depth, amending the

development parcel for Block F and adding further detail into the parameter plans and Design Code in relation to residential quality and character of the typologies.

8.186 The changes have responded to comments and are positive improvements that will ensure effective parameters and appropriate design principles are embedded to enhance the quality of place and ensure a high quality detailed design is developed. Concerns regarding the overall amount of development are noted, however the overall layout and public realm, height and massing and design principles for the development provides an appropriate response to the requirements to optimise the use of the Site in the Opportunity Area, with this also noted by the GLA Stage I response.

Other design considerations

8.187 Additional matters that contribute to evaluation of design quality including housing standards, sustainability and environmental effects relating to wind, daylight and sunlight within the scheme and for neighbours, plus any necessary mitigation, are considered elsewhere in this assessment. The assessment has concluded the proposal is acceptable in each of these considerations.

Conclusion

8.188 It is considered that the development would deliver a high quality residential-led scheme, including a very significant number of new homes with active ground floor uses and new public spaces, within a landscaped setting. This would transform the currently underutilised site and create a new vibrant urban character. Whilst the development is of large scale and presents a significant step change from the existing Site and surroundings, it is considered that its form and massing responds appropriately to the local context and the opportunity the site presents. The layout and massing, as well as the location of taller elements has taken into account the surrounding context of the Site including the change in character from the Golden Mile to neighbouring residential areas, as well as the nearby buildings of character. It is considered that the parameter plans and Design Code are robust and would ensure that the detailed design would be of high quality.

8.189 Furthermore, whilst building heights and the overall scale of the development may be greater than those identified in the emerging Local Plan and Site Allocations, this should be seen in the context of the wider benefits of the scheme, in particular the delivery of much needed housing within the Borough, including a substantial proportion of affordable housing.

8.190 Therefore the urban design and townscape impacts of the proposal are acceptable, the development optimises the use of the Site in a manner that satisfactorily accounts for the context of the Site, creates new public spaces, enhances the public realm and encourages active travel, consistent with London Plan policies D2-D9, and HLP policies CC1-CC3 and GB1 and the direction of travel indicated in the GWC Local Plan. The heritage aspects of policies D9 and CC3 are considered in the following section.

E. Heritage

Heritage Policy Context

8.191 There are a range of designated heritage assets in the vicinity of the Site and the wider area that may be affected by the development, including the proposed tall buildings through change to their setting. The Council has also a relevant statutory duty under section s66(1) of the Planning (Listed Buildings & Conservation Areas) Act 1990, which requires that decision makers pay “special regard to the desirability of preserving” listed buildings or their settings.

8.192 In respect of this statutory duty case law from the Court of Appeal16 confirms that “preserving” means “doing no harm”. Further, it has been held17 that decision-makers should give “considerable importance and weight” to the desirability of preserving the setting of listed buildings when carrying out the balancing exercise in cases which involve heritage issues. This duty may be addressed through applying relevant policies of the Development Plan and the NPPF that consider effects of development on heritage.

National Policy and Guidance

8.193 Part 16 of the NPPF details policies for the conservation and enhancement of the historic environment. It states18 that heritage assets are an irreplaceable resource, and should be conserved in a manner appropriate to their significance, so that they can be enjoyed by future generations.

8.194 Paragraph 185 says that in determining applications, local authorities should take account of:

a) the desirability of sustaining and enhancing the significance of heritage assets and putting them to viable uses consistent with their conservation;

b) the positive contribution that conservation of heritage assets can make to sustainable communities including their economic vitality;

c) the desirability of new development making a positive contribution to local character and distinctiveness; and

d) opportunities to draw on the contribution made by the historic environment to the character of a place.

8.195 Paragraph 193 says:

“When considering the impact of a proposed development on the significance of a designated heritage asset, great weight should be given to the asset’s conservation (and the more important the asset, the greater the weight should be). This is irrespective of whether any potential harm amounts to substantial harm, total loss or less than substantial harm to its significance.”

16

Barnwell Manor Wind Energy Ltd v East Northamptonshire DC & Others ([2014] EWCA Civ 137) the

Court of Appeal 17

Ibid. 18

Paragraph 184 of the NPPF.

8.196 Paragraph 194 says that any harm to, or loss of, the significance of a designated heritage asset, including from development within its setting, should require clear and convincing justification.

8.197 Paragraph 196 says where a development proposal will 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 where appropriate, securing its optimum viable use.

8.198 ‘Significance’ in the context of heritage policy is defined19 as

“The value of a heritage asset to this and future generations because of its heritage interest. The interest may be archaeological, architectural, artistic or historic. Significance derives not only from a heritage asset’s physical presence, but also from its setting. For World Heritage Sites, the cultural value described within each site’s Statement of Universal Value forms part of its significance”.

8.199 Paragraph 201 notes that not all elements of a Conservation Area or a WHS will necessarily contribute to its significance.

8.200 ‘Setting’ in the context of heritage policy defined20 as:

“The surroundings in which a heritage asset is experienced. Its extent is not fixed and may change as the asset and its surroundings evolve. Elements of a setting may make a positive or negative contribution to the significance of an asset, may affect the ability to appreciate that significance or may be neutral”.

8.201 The NPPG explains why ‘significance’ is important in decision taking by advising21:

“Heritage assets may be affected by direct physical change or by change in their setting. Being able to properly assess the nature, extent and importance of the significance of a heritage asset, and the contribution of its setting, is very important to understanding the potential impact and acceptability of development proposals.”

8.202 In respect of assessing if a proposal causes substantial harm to a heritage asset, the guidance sets out that it is the impact on the significance of the heritage asset that matters, with significance deriving not only from the asset’s physical presence, but also from its setting. Whether there is substantial harm is a judgement for the decision taker. In general terms, substantial harm is a high test, so it may not arise in many cases. It is the degree of harm to the asset’s significance rather than the scale of the development that is to be assessed. The harm may arise from works to the asset or from development within its setting22.

Historic England

8.203 Historic England (“HE”) has guidance to inform planning decisions relating to heritage, including ‘Advice Note 2 – Managing Significance in Decision-Taking in the

19

NPPF Glossary (Annex 2) 20

NPPF Glossary (Annex 2) 21

Paragraph: 007 Reference ID: 18a-007-20190723 of NPPG. 22

Paragraph: 017 Reference ID: 18a-017-20140306 of NPPG.

Historic Environment’ (2015) , ‘Advice Note 3 - The Setting of Heritage Assets’ (2017), and ‘Advice Note 4 – Tall Buildings’ (2015).

8.204 HE advice note 3 sets out a process for understanding setting, and how it may contribute to the significance of heritage assets and allow that significance to be appreciated, plus advice on how views contribute to setting. A staged approach to taking decisions on setting is suggested to assess the contribution of views to the significance of heritage assets. It comments23

that:

“Consideration of the contribution of setting to the significance of heritage assets, and how it can enable that significance to be appreciated, will almost always include the consideration of views”. The also guidance refers to the NPPF and NPPG’s explanation of the setting of heritage assets.

8.205 This guidance continues24 that the importance of the setting lies in “…what it

contributes to the significance of the heritage asset or to the ability to appreciate that significance.”

8.206 And it considers25 effects from cumulative change, noting that where “…the

significance of heritage asset has been compromised in the past by unsympathetic development affecting its setting, to accord with NPPF policies consideration still needs to be given to whether additional change will detract further from, or can enhance, the significance of the asset”.

8.207 This guidance also discusses particular circumstances such as designed settings, where planned landscapes contribute to the significance of heritage assets. It notes26 that as well as development within the immediate vicinity of an asset “…development further afield may also affect significance, particularly where it is large-scale, prominent or intrusive”.

London Plan

8.208 London Plan policy D9 relating to tall buildings sets out matters to be considered when assessing tall buildings including immediate, medium and long distance visual effects, functional impacts, environmental effects and also cumulative impacts from impacts of proposed, consented and planned tall buildings in an area. It says proposals should take account of, and avoid harm to, the significance of London’s heritage assets and their settings. Proposals resulting in harm will require clear and convincing justification, demonstrating that alternatives have been explored and that there are clear public benefits that outweigh that harm. The buildings should positively contribute to the character of the area. The policy also says development in the setting of a WHS must preserve, and not harm, its Outstanding Universal Value (“OUV”), and the ability to appreciate it.

8.209 Policy HC1 says development proposals affecting heritage assets, and their settings, should conserve their significance, by being sympathetic to the assets’ significance and appreciation within their surroundings. The cumulative impacts of incremental

23

Views & Settings paragraph 5 Advice Note 3 - The Setting of Heritage Assets (2017) 24

Views & Settings paragraph 9 Advice Note 3 - The Setting of Heritage Assets (2017) 25

Ibid. (p4) 26

Ibid.(p5)

change from development on heritage assets and their settings should also be actively managed. Development proposals should avoid harm and identify enhancement opportunities by integrating heritage considerations early on in the design process.

8.210 Policy HC2 relates to World Heritages Sites and says that proposals in their settings should conserve, promote and enhance their OUV, including the authenticity, integrity and significance of their attributes, and support their management and protection. Where development proposals may contribute to a cumulative impact on a WHS or its setting, this should be clearly illustrated and assessed in the Heritage Impact Assessment. Finally, up-to-date WHS Management Plans should be used to inform the plan-making process, and when considering planning applications, appropriate weight should be given to implementing the provisions of the WHS Management Plan.

8.211 The Mayor’s WHS Supplementary Planning Guidance supports the London Plan and has guidance on the interpretation of setting and understanding its importance in contributing to an appreciation of OUV, and includes a methodology for assessing heritage impacts. It includes a requirement to consider cumulative impacts from incremental changes caused by past, present or potential developments with planning permission that cumulatively with the proposed development can have a significant impact on the setting of a WHS. The design of development proposals should be considered against their effect on the elements of setting of the WHS and the resultant degree of harm or benefit to the attributes of its OUV.

Hounslow Local Plan

8.212 HLP policy CC4 seeks to 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. This policy expects development proposals to:

Conserve and take opportunities to enhance any heritage asset and its setting in a manner appropriate to its significance;

Retain, conserve and reuse a heritage asset in a manner appropriate to its value and significance;

Demonstrate that substantial harm to or loss of a heritage asset is avoided, unless exceptional circumstances can be demonstrated, consistent with the NPPF;

Demonstrate that where a development proposal will lead to less than substantial harm to the significance of a designated heritage asset, this harm will be outweighed by the public benefits of the proposal, including securing its optimum viable use; or

Have regard to any harm to, or loss of, the significance of a non-designated heritage asset, including from both direct and indirect effects.

8.213 The supporting text to this policy says27 that the “…protection and enhancement of the historic environment is a core principle that as well a legal duty underpins sustainable development” and that the “...borough’s heritage assets are irreplaceable resources and are particularly sensitive to change and development, requiring special protection and careful treatment to sustain their value and importance for future generations”. It also notes that “development can impinge on the settings of the most important assets”. Policy CC3 also requires buildings to carefully relate to the surrounds including the wider context of sites. Conservation Areas that are described in the HLP are also the subject of conservation area statements and appraisals that explain the key elements of their heritage significance and also pressures and opportunities relating to their character and appearance.

Other considerations

8.214 Royal Botanic Gardens WHS, Kew – The Royal Botanic Gardens WHS has a Management Plan 2019-2025 (2020) This plan defines the WHS buffer zone and important sightlines and views within, to and from Kew Gardens. It also discusses the importance of vistas and visual envelopes extending outside the WHS buffer zone to the site’s OUV.

8.215 The Management Plan says the OUV of the Kew WHS comprises28:

a rich and diverse historic cultural landscape providing a palimpsest of landscape design;

an iconic architectural legacy;

globally important preserved and living plant collections;

a horticultural heritage of keynote species and collections; and

key contributions to developments in plant science and plant taxonomy.

8.216 This Plan states29 that the setting of Kew WHS makes a “…direct and important contribution to its significance as an evolved designed landscape representing key periods in garden history and royal history” and adds that “…this contribution has and remains under threat due to existing tall buildings and other development proposals”.

8.217 Thames Landscape Strategy (Hampton to Kew) – The Thames Landscape Strategy (“TLS”) has guidance aiming to conserve and enhance the Thames riverside landscape. The strategic role of such strategies is referred to in London Plan policy SI 14. The Hampton to Kew section of the Strategy recognises the verdant, rural views along this stretch of the Thames and the historic links between the landscape of Kew Gardens WHS and Syon House. Its objectives correspond with policies protecting the riverside character of the area and its heritage and views.

8.218 GWC Local Plan – The emerging plan is consistent with the above heritage policies. Policy GWC5 says the Council will optimise redevelopment opportunities whilst

27

Paragraph 6.13 of the Hounslow Local Plan. 28

Royal Botanic Gardens, Kew – World Heritage Site Management Plan (3.2 pg 25) 29

Royal Botanic Gardens, Kew – World Heritage Site Management Plan (3.3 pg 26)

respecting the historic environment, including heritage assets and their settings. Development is expected to avoid any further harm to the setting, views, significance, OUV and buffer zone of the Kew WHS, and other designated heritage assets and their settings including listed buildings, Registered Parks and Gardens and conservation areas.

Effects on Heritage Significance

8.219 There are no listed buildings on the Site. The part of the Site to the west of McFarlane Lane lies within the Osterley Park Conservation Area and therefore there would be a direct impact on this designated heritage asset. The remainder of the Site lies outside the Conservation Area.

8.220 The redevelopment of the Site and the loss the existing Tesco building and associated Petrol station are considered acceptable, the buildings themselves are of no particular architectural interest, being a common example of a large format supermarket, and the character of the Site with large areas of surface car parking and inactive building frontages makes a negative contribution to the townscape.

Heritage Approach

8.221 As noted above part of the Site lies within the Osterley Park Conservation Area, in addition there are a number of listed buildings in the immediate vicinity of the Site, in particular the Grade II listed Gillette building located on the east of the Site and the Grade II listed Pavilion and Club House building, used by Goals, located to the North West of the Site. There are also other listed buildings along the Great West Road.

8.222 In the wider district there are other heritage assets of the highest significance in the form of registered parks and gardens at Syon Park and Osterley, listed buildings such as Osterley House, Syon House and Boston Manor House, and the Kew Gardens WHS, which may have their setting affected by the tall and large buildings of the proposal owing to their setting forming part of their significance and with longer views across the landscape being possible.

8.223 Consideration has been given to the effects of the proposal on the setting of these assets with this including understanding the significance of each heritage asset and what contribution its setting makes to that significance, and the determining to what degree the proposed change to the setting causes harm to the significance of the asset. Cumulative effects with other development have also been considered.

8.224 The ES has a Heritage Statement, which is informed by the views analysis of a Townscape and Visual Impact Assessment, and this has considered the impacts on the settings and significance of heritage assets. The original assessment was supplemented by additional views to ensure it was comprehensive. In respect of the impacts on settings, it is noted that simply being able to see a new building does not make the design poor or its effect on the heritage significance harmful. Further, the architectural quality of buildings is a material consideration when assessing the quality of the design and its impact on the significance of a heritage asset. However, architectural quality does not necessarily negate harm as even high quality buildings may be located inappropriately.

Appraisal

8.225 The applicant’s own assessment concluded that that there is no harm to the significance of heritage assets from the development as it conserves the heritage assets whose setting its affects, stating:

“The scale of the proposed development is clearly greater than the listed buildings in the vicinity, and that of the Osterley Park Conservation Area, but the special interest of these designated heritage assets does not rely on a specific scale on the site, and their visibility along the A4 remains largely unimpeded. There will be a minimal effect on the setting of heritage assets further afield, such as Syon Park, Osterley Park and Boston Manor, and no effect on the Kew World Heritage Site. The proposed development will therefore, on balance, preserve the setting of heritage assets and not cause harm to their heritage significance, and will bring significant public benefits.”

8.226 The applicant has noted responses objecting to the development that consider the visibility of the proposed developments results in ‘less than substantial’ harm to various heritage assess, and considers that where less than substantial harm is identified, this is outweighed by the significant public benefits of the proposal.

8.227 Officers have considered the impacts on relevant heritage assets in line with the relevant statutory duties and applicable policies and guidance. This consideration has given account to the applicant’s assessment, as well as responses from Historic England and other interested persons, with this being summarised in the following sections. It is noted that the ES identified other heritage assets in the wider district, including listed buildings and locally listed buildings, where the proposal would clearly not affect their significance owing to there being no change to their setting (due to distance and intervening development), or as they are not as highly significant and are less sensitive to changes in their setting, and so no further comments are made in these instances where this is agreed.

Gillette Factory

8.228 This Grade II listed building (1937) sits at the junction of the Great West Road and Syon Lane to the east of the Site. A building of monumental scale, it is a local landmark and is representative of the industrial history and character of the Golden Mile. Its special architectural and historic interest is best appreciated in views of its principal elevation from in front of the building and along Syon Lane, including the south side of the Great West Road. Its tall clock tower is able to be seen more widely in glimpsed views along the Great West Road and open spaces to the north and south of the Site including Osterley Park and Syon Park. There are also four lamp standards outside the main entrance and a K6 telephone kiosk close to the pedestrian subway that are Grade II listed.

8.229 The Site is located to the east of the Gillette building; the proposal would introduce buildings to the rear of the Gillette building in views down Syon Lane from the south, though these would be set back in the background, allowing for the main façade and tower to remain distinct in the middle ground of the view. The height and massing of the proposal has been considered with the taller buildings set back into the site and located in the centre and towards the northern and eastern edges of the site. The

taller buildings have also been positioned and reduced in height to ensure that they appear below the clock tower when viewed from the south along Syon Lane. The heights of buildings along Syon Lane are limited and the Design Code requires the southern elevations of the primary elements to retain a massing relationship with the shoulder height of the Gillette Factory. Therefore viewers would still be drawn to the façade and clock tower of Gillette which would remain landmarks, and so this positioning, along with the massing and height parameters, would reduce impacts on the setting of the listed buildings. Overall the change to the setting would have a minor negative impact on the significance of the listed buildings, with this considered to be a low level of less than substantial harm. The detailing and materials for the proposed buildings would need to be carefully considered to minimise harm; these would be assessed at Reserved Matters Stage and would need to comply with the Design Code.

8.230 The Homebase Site proposal would introduce large and tall buildings opposite the Gillette Building significantly changing the setting when seen along Syon Lane (from north and south) and along parts of the Great West Road, however the position, height, massing and design reduce impacts on the setting of the listed buildings, helps to add to the significance of Gillette Corner and viewers would still be drawn to the façade and clock tower of Gillette which would remain landmarks. Cumulatively the Homebase Site would add to the harm identified from the proposal and this would remain in the range of low level of less than substantial harm.

National Westminster Bank

8.231 This Grade II listed building(1935) forms a form a group with the Gillette premises and its special interest is from its architectural design and relationship with the Gillette building and commercial development .of the Golden Mile. Its setting is formed by the larger Gillette building and the Great West Road, and its interest is best appreciated in views of its principal façade from Great West Road. The proposal would be visible but set well behind the site, and is considered to result in little change to its setting; this considered to be a low level of less than substantial harm. The Homebase proposal would introduce a more visually dominant building opposite the listed building but not in the best views of it, with this resulting in a minor negative impact on the significance of the listed building. Cumulatively this would remain at a low level of less than substantial harm.

Former Coty Factory

8.232 This Grade II listed building (1933) is located over 300m east of the Site on the Southern side of Great West Road with the Gillette Factory and Harlequin Avenue Industrial estate between. It is a remnant of a larger building that has been altered and has some group value with nearby buildings. It also has historic and architectural value from its design, architects, and its role in the development of the Golden Mile. Its setting relates to the Great West Road where it would be seen when passing. The proposal would not appreciably affect the setting of this building. The Homebase Site is located in much closer proximity and would substantially change the setting of this building when coming from the east forming a new backdrop in this view and looming above it, however the Coty building would remain distinct in the townscape and the harm is negligible as the Site does not contribute much its

significance through setting. Therefore cumulatively this would be a very low level of less than substantial harm.

Westlink House (Pyrene Factory)

8.233 This Grade II listed building (1928) is over 500m east of the Site on the Southern side of Great West Road and is one of the historic art-deco buildings along the Golden Mile. It is best seen front on or as it is approached from either direction along the Great West Road where its symmetry is appreciated. The proposal would not appreciably affect the setting of this building, given the separation distance and relationship. The Homebase Site makes little contribution to the setting of the building given the separating distance. Therefore there would be no impact on its significance.

Church of St Francis of Assisi

8.234 Located to the west of Gillette Corner on the southern side of the Great West Road, around 190m from the Site with the Housing along Syon Lane, Great West Road and Syon Lane gardens between, this is a Grade II listed building (1933-35) of Gothic design. The proposal would not appreciably affect the setting of this building. The development on the Homebase Site would result in a minor change to the setting of the Church as seen looking down the Great West Road from the west with the new buildings appearing in the background. However the Church would remain the dominant feature and there would be no effect on its significance.

Syon Park and House

8.235 Located around 1km away to the southeast of the Site, Syon Park is Grade I Registered Park and Garden, which also forms part of the Buffer Zone for the Kew Gardens WHS and is designated as part of the Isleworth Riverside Conservation Area. Within the site are a number of highly significant listed buildings including the Grade I listed Syon House (by Robert Adam) and the Lion Gate and lodges, as well as other Grade II buildings. This site has an area of around 80 hectares and is bounded to the north-west by London Road with residential and industrial developments form the boundary to the north. The River Thames provides the eastern boundary, with Kew Gardens on the opposite bank and Park Road the western boundary.

8.236 Areas of the landscaped grounds represent one of the most important examples of Lancelot ‘Capability’ Brown’s work because of their contribution to the Arcadian Thames landscape and because his design legacy on the parkland and its rural character is still recognisably intact, particularly in the area between Syon House and London Road.

8.237 The applicant’s assessment found no harm from the development. They acknowledged the pastoral element of the landscape has significance in its own right but that its significance relies less on specific views unlike other elements of Syon Park which are more ordered and geometrical. Historic England concluded to the contrary and found that some of the most important views of the building and the rural setting of the park would be further compromised by the proposal, and noted the setting of Syon is not pristine, which increases its vulnerability. They also found

harmful impacts from this development to the western part of the park. They found the impacts would cause a further moderate degree of less than substantial harm to the registered park. They also found the setting of the Grade I listed building Syon House would also be impacted indirectly, and therefore the level of harm is lower. Further harm would be incurred through the cumulative impact of the Homebase scheme which is also under consideration. They consider that this harm does not have clear and convincing justification, contrary paragraph 196 of the NPPF.

8.238 Officers conclude that in respect of Syon House itself and the Gatehouse, the effects of the proposal on their setting is limited and that the effect on their overall significance, which in the case of the House a large part is derived from its interior and historic fabric, and in respect of the Gatehouses are best seen as a group with the House and approach from the Lion Gate (to the north). Glimpses of the upper parts of the buildings amongst trees would be seen in the some views, more so in winter. Partial glimpses of the buildings to the side of Syon House would be apparent in a significant view (non-designated), from the southeast, across the Thames from parts of the towpath outside Kew Gardens WHS. The position of this view corresponds to an historic painting of Syon House by Canaletto (from 1749). Existing riverside vegetation and mature trees in the grounds of Syon Park helps screen most of the proposals with this effect being greater when trees are in leaf. The view would not be greatly changed with or without vegetation, the limited visibility of the proposed buildings at considerable distance not significantly affecting prominence of the listed building in the middle ground of the view and its relationship to the river and rural like setting. The most important riverside view, which is interrelated to the WHS, is not materially affected.

8.239 Overall there would be a very low magnitude of change to the setting of these assets but given the high significance of the listed buildings, the change would be harmful to their significance, with the cumulative impact of the Homebase Site proposal not having a materially greater effect and so this will comprise a low to mid-low level of less than substantial harm individually and cumulatively with other development.

8.240 There would be greater impacts on the historic parkland landscape to the west of the House, on parts of what is now the main approach road from Park Road where the upper parts of the proposed buildings would be visible above the existing background treeline, with this being more apparent in winter. These are distant kinetic views, with the Site around 1.5km from this area across the historic farmland and open rural landscape. The majority of the proposal would sit below the tree line within the background of this view. Cumulatively there are already some harmful impacts on significance from buildings within the setting of Syon Park, with these mostly at the eastern end, though in winter built development is visible along the northern edge of the park within and above the treeline. Visible modern intrusions include the Gillette tower. The introduction of new built forms within the setting of this highly significant heritage asset would be detrimental to the appreciation of its heritage significance. The magnitude of change would be low-moderate with this considered to be moderate harm low end, less than substantial harm. The Homebase Site proposal increases this harmful impact and cumulatively increases the harm to moderate, less than substantial harm. Refined massing will help to reduce harm as would design details being final for both the proposed schemes, but ultimately they would still be harmful additions.

Osterley Park and House

8.241 A Grade II* register park and garden, with extensive grounds which contains a number of Grade I listed buildings including Osterley House, as well as a range of Grade II and II* listed buildings set around the park. Osterley House (also by Robert Adam) is located centrally within a large area of farmland and design landscaping. It is located around 1.5km North West of the Site. Like Syon House, it is of high heritage significance mostly from its interior and historic fabric. The historic park has designed landscapes and pleasure grounds associated with the house. The park also forms the main focus of the Osterley Park Conservation Area, with the conservation area extending to include adjoining residential streets with good quality buildings. The Conservation Area’s primary special architectural and historic interest derives from Osterley House, its landscaped grounds and rural setting.

8.242 The applicant’s assessment found no harm from the development and that the significance of the heritage asset would remain wholly intact. They conclude that the arrangement of trees in the park, planted at various times, creates principal vistas in relation to the house, and that the proposed development would not appear in the principal designed views and not be visible at all from Osterley House. They acknowledge that, like at Syon, the pastoral element of the landscape has significance in its own right but that its significance relies less on specific views. Historic England concluded to the contrary and found that two of the main visitor approaches to Osterley House, as well as much of eastern area of the park, would see their Arcadian character diminished. While they note that the setting of Osterley has already been compromised, they found the impacts would cause a further moderate degree of less than substantial harm. They also found the setting of the Grade I listed building Osterley House would also be impacted indirectly, and therefore the level of harm is lower. Further harm would be incurred through the cumulative impact of the Homebase scheme which is also under consideration, although the harm from that development on this asset is considered a lower level.

8.243 Officers conclude that the proposal would not appear in any principal designed views in the landscaped grounds and would not be visible at all from Osterley House itself, with intervening trees and other development blocking views. The Homebase scheme would also not be visible within these views.

8.244 Glimpses of the buildings would be possible along the public right of way and the access road into Osterley Park around 1km from the Site, with this being more apparent in winter. The upper parts of the proposed buildings would be visible above the existing background treeline, from a footpath within the park to the east of the House, at around 1km from the Site as well as from Osterley Lane the bridleway within Osterley Park, approximately 1 km north east of the Site in the background of the gateway and lodges. Whilst some intrusions already exist, the introduction of new built forms within the setting of this highly significant heritage asset would be detrimental to the appreciation of the historic Arcadian landscape and thus its heritage significance. The proposal cannot be seen from house and it considered that there would be a very low/ negligible level of change to setting of listed building. The impact is greater from the grounds and wider park where there are outward views, and this is considered to be minor harm mid-level, less than substantial harm. As the scheme is outline the maximum parameters have been used, however the refined massing, detailing and materials for the proposed buildings would need to be

carefully considered to minimise harm; these would be assessed at Reserved Matters Stage. The Homebase Site proposal would be less apparent in these views and would not have a materially greater effect and so cumulatively this would remain at the low end of less than substantial harm.

Osterley Park Conservation Area

8.245 The main focus of the Osterley Park Conservation Area is Osterley Park with the conservation area extending to include adjoining residential streets with good quality buildings. The Conservation Area’s primary special architectural and historic interest derives from Osterley House, its landscaped grounds and rural setting. The Conservation Area Appraisal also notes that the houses surrounding the perimeter of the park reflect the suburban character of their time and references the integrity of roofs, architectural features and quality of materials.

8.246 The proposed development will step up from the lower scale of the conservation area to the northwest to an area of greater height closer to the Sky campus to the northeast. The part of the site which lies within the Conservation Area would be developed as two storey terraced housing with rear gardens, as set out in the Design Code, this is considered an appropriate response to the established two storey housing. The detailing and materials for these houses would be determined at reserved matters stage, but the scale and positioning is considered not to cause harm to the Conservation Area.

8.247 The remainder of the site lies outside the Conservation Area and it is considered that the character and appearance of the conservation area itself would not be appreciably changed and thus it is considered there would be negligible harm to the Conservation Area.

8.248 The Grade II listed Pavilion and Club House building, used by Goals lies within the Conservation Area and approximately 130m to the north west of the Site. This is listed for its structural interest and as an example of a private sports pavilion influenced by the Modern Movement. It is best appreciated on approach from Gower Road and from the sports pitches to the North. The assessment shows that the proposals for the Site would be highly visible to the east of this building, however it is not considered that this is detrimental to the significance of this heritage asset given the relationship to the open playing fields immediately surrounding it would remain and viewers would still appreciate this local setting.

8.249 However given that the Conservation Area includes Osterley Park itself and that harm has been found to that heritage asset, this is taken into account and cumulatively results in a minor level of harm to the Conservation Area as a whole; this remains at the low end of less than substantial harm.

Boston Manor

8.250 Boston Manor House, a Jacobean house that is sited amongst parkland, is a Grade I listed building. It also has various ancillary buildings that are Grade II listed. The building is around 960m to the northeast of the Site with the conservation area being around 550m away. The house and park and located with the Grand Union Canal and Boston Manor Conservation Area. The assessment shows that existing mature

trees effectively screen views of both the proposals for the Site and Homebase Site and that there would be no harm to the significance of heritage assets.

Kew Gardens

8.251 The Royal Botanic Gardens, Kew, is a WHS, which is also designated as a Grade I register park and garden, and a conservation area, is known internationally for its significant botanic collections and work, but also for the landscape and architectural design of the gardens and numerous high grade listed buildings, and it is of the highest heritage significance. The WHS is located southeast of the Site, around 1.7km away, across the Thames. Adjoining areas around the WHS are designated as a buffer zone with this WHS buffer zone including Syon Park. Together, Syon Park and Kew Gardens create a continuous parkland landscape character across the River Thames. More widely the tree-lined riverbank and neighbouring parks and gardens between Kew and Hampton Court form part of a landscape referred to as the ‘Arcadian Thames’. This stretch of the river has an idyllic rural character influenced by historic royal associations, grand houses and gardens set amongst water meadows and woodland. The proposed development is not located within the WHS buffer zone but owing to its tall buildings, it has the potential to affect the setting of the WHS beyond the buffer zone, and so indirectly it could affect the significance of the various heritage assets at Kew.

Syon Vista

8.252 The WHS buffer zone contains the focus of one of the most important vistas of the WHS, a view across the Thames towards Syon House and its associated landscape. Located at the end of the long Syon Vista, an open lawn area separated from the Thames path by a Ha-Ha provides a designed open view of the Thames and the ‘Capability’ Brown landscape and historic Syon House beyond. This is a key space in terms of maintaining and understanding the visual and historic connections between the WHS, Syon Park and the Thames.

8.253 Apart from the Syon Vista, the WHS is largely separated from the Thames by trees and shrubs along the western boundary alongside the river towpath, and on the whole the WHS is largely an internally-orientated landscape. The WHS Management Plan recognises that this vegetation performs a valuable screening function as well as a windbreak against prevailing winds funnelling down the Thames and that and preserving the integrity of this setting from external intrusions plays a fundamental role in supporting its OUV. The visibility of a number of existing external developments has already had a negative impact on the setting of the WHS.

8.254 Therefore the outwards views from the open lawn across to Syon Park are essential to appreciating the designed landscape. The setting of this vista is integral to the significance of the WHS and its OUV and so it is very sensitive to change. The further intrusion of urban development would be harmful to the setting of the WHS and its OUV. It is also important to consider any existing harm when determining the impact of proposed development, with any additional harm to be understood as being cumulative with existing harm. In terms of the attributes of the OUV that may be affected, in this location the proposal has the potential to affect its “rich and diverse historic cultural landscape providing a palimpsest of landscape design”.

8.255 Historic England and others have concluded that the development would harm the OUV through the introduction of large urban development that would disrupt the distinctive sense of an Arcadian landscape. This contributes significantly to the ability to appreciate the design intentions of the landscape. The proposed development would distract and effectively end the rural illusion, undermining the character of the historic landscape gardens (Kew and Syon). They consider the overall impact on OUV would be moderate which equates to low to moderate degree of less than substantial harm, this acknowledges that the nature of the harm is similar but less than the scheme on the Homebase Sitee. They also highlight the Inspector’s decision for the Chiswick Curve inquiry which said the presence of trees should not be relied upon to justify an impact, and so they do not accept the justification that the existing screening provides adequate mitigation and note that no consideration has been given to its potential removal.

8.256 Officers have reviewed the verified images and visited the WHS to consider the impacts from the development on the setting of the Syon Vista. The Syon Vista terminates in an open lawn that focusses on an axial view towards Syon House, the latter being orientated with its eastern elevation directly facing the aspect from the WHS. Either side of the vista there are trees and shrubs that help frame the view. The proposed buildings are effectively screened by vegetation in the foreground along the river bank but also mature trees further inside Syon Park. The seating and lawn areas that are arranged to provide extended views across to the rural landscape of Syon Park are where this key view is best appreciated and it is not considered the would be a perceivable change to the setting of the view.

8.257 There is no visibility of the proposal along the Syon Vista itself due to existing trees along its edges; this is also the case for the proposal on the Homebase Site. There would also be no visibility of the proposed development elsewhere within the WHS in this area. Very minor glimpses of the development on the Homebase Site would be possible further into the wooded area between trees to the periphery of the Syon Lawn area in an area adjacent to the ‘Woodland Walk’ in winter included near to the Isleworth Ferry Gate (also a Grade II listed building). However this area is generally heavily planted, and the public pathway moves away from the Thames to the south of the main open view, with the trees mostly enclosing the WHS from the Thames. The changes to the setting of the WHS from within this wooded area would be very minor to negligible. The impact would be similar to that of other tall buildings visible in Isleworth and the Great West Road which barely register in outward views owing to the thick vegetation on both sides of the Thames.

8.258 Although it is agreed the presence of trees and other vegetation does not necessarily justify development, both the WHS Management Plan and Syon Park’s masterplan note the role of screening vegetation and tree planting. Large scale removal of trees and shrubs within Syon Park that would expose the proposals on the Tesco and Homebase Sites would also reveal other urban development including the Syon Park Hotel and tall buildings on the Great West Road and so this is considered extremely unlikely. Replanting where trees were lost would also be expected to maintain the current landscape.

8.259 As such cumulatively there would be a very low magnitude of change to the setting of the WHS, inclusive of the Syon Vista and adjoining wooded area beside the Thames, and so the impact on the OUV will be negligible, which given the high

significance of the WHS would equate to a very low level of substantial harm to the WHS, the Registered Park and the conservation area

Isleworth Drawbridge and Ferry Gate

8.260 South of the Syon Vista the boundary of the gardens changes character with the open and outwards views towards Syon House from the lawn area and Ha-Ha at the end of the Syon Vista ending as the boundary becomes fenced and lined with woodland. Around 50m south of the Vista is the Isleworth Ferry Gate, a Grade II listed building. This gate once provided an entrance to the gardens but is no longer used. The gate is significant as it provides reference to the gardens relationship to the Thames and the Arcadian landscape beyond. As a listed building it is significant in its own right but it also contributes to the conservation area and the OUV of the WHS. In respect of the latter the proposal could affect the OUV through impacts on the WHS’s rich and landscape design and architectural legacy.

8.261 In winter the proposal would be party visible in the distance behind the gate in views from outside the gardens. In summer trees and shrubs would screen the proposal. The change to the view is very low. There is also a view towards Syon Park from the towpath outside the gate. This position does not provide a good view of Syon House owing to trees in the foreground on the opposite bank and this is not part of the Syon Vista or part of the WHS. Pedestrians in this view have views up and down the river where boundary planting to Kew WHS limits views into the gardens. Users of the path would be aware of modern development which is readily apparent in Brentford downstream. The best views of Syon House from the tow path in front of the gardens aligns with the Syon Vista where there riverside vegetation has been kept low and vegetation on the opposite bank and in Syon Park provide a thick screen that results in there being minimal visibility of the proposal. The effect on the setting of the listed building and WHS are very low. The proposals on the Homebase would be more visible but would still provide a very low level of change, therefore cumulatively this equates to low-medium less than substantial harm. Other views mentioned in objections including from around the Queen’s Cottage towards the Site would be screened by existing vegetation.

Archaeology

8.262 LP policy HC1 says development proposals should identify assets of archaeological significance and use this information to avoid harm or minimise it through design and appropriate mitigation. HLP policy CC4 says regard with be given to the significance of Archaeological Priority Areas.

8.263 The Site is not located within an Archaeological Priority Area (APA), and the proposals have been reviewed by the Greater London Archaeological Advisory Service (GLAAS) who have confirmed that the Site was subject to archaeological evaluation in 1994 prior to the construction of the present Tesco supermarket. No significant archaeological remains were found and no new information has come forward since then to change the conclusion that the site has low archaeological potential. The proposal is unlikely to have a significant effect on heritage assets of archaeological interest, consequently no further assessment or conditions are necessary in this instance.

Conclusion

8.264 The proposed development would result in some harmful impacts on the significance of a number of highly sensitive heritage assets through effects on setting, but in each case the harm is well below what would be considered ‘substantial harm’ having regards to paragraph 195 of the NPPF.

8.265 In summary the effects on the setting of the various listed buildings in the vicinity of the Site would be at the low end of less than substantial harm. Impacts on Osterley Park and its Listed Buildings equate to low level of less than substantial harm, and a low level of harm to the Registered Park and Garden by itself and cumulatively with the Homebase Site proposal. The impact on Syon Park equates to a low level of less than substantial harm for the proposal by itself and moderate harm cumulatively with the Homebase Site proposal. The impacts on Kew Gardens are very low, but the cumulative harm identified to the setting would harm its OUV, the Registered Park and the conservation area at a level of low-medium less than substantial harm. Overall the development would cause a moderate level of less than substantial harm to heritage, with the cumulative impact being a little more but still in the moderate range and not close to substantial harm.

8.266 Importantly, less than substantial harm is not to be treated as a less than substantial objection to the grant of planning permission, and any harm to a listed building or its setting gives rise to a strong presumption against the grant of planning permission. Paragraph 193 of the NPPF is clear that great weight should be given to the asset’s conservation (and the more important the asset, the greater the weight should be).

Mitigation

8.267 The positioning and heights of the proposed buildings have been considered in the context around the Site to minimise the harm to heritage assets, in particular the step up in height towards the centre and north of the site and the requirements within the Design Code to maintain a shoulder height massing relationship with the Gillette Factory. Architectural detail and materials, which will help reduce the overall bulk of the buildings and maintain key views towards the Gillette building would come forward as part of the reserved matters and be fully assessed at that time.

Balancing Exercise

8.268 In accordance with paragraph 196 of the NPPF, where a development will lead to less that substantial harm to the significance of a designated heritage asset, as is the case in each instance in this case, this harm should be weighed against the public benefits of the proposal. The exercise to weigh the harm to heritage assets against the public benefits of the proposal is carried out in the planning balance section below.

8.269 Given the harm to designated heritage assets that has been found, there is some conflict with Development Plan policies relating to conservation of heritage, namely elements of HLP CC4 at (d) and (i) and London Plan policies D9, HC1 and HC2. However this does not mean that all these policies as whole are conflicted – in respect of HLP CC4, (l) reflects the NPPF balancing exercise described above. As set out in HLP CC4 (l) and paragraph 196 of the NPPF it is necessary to weigh this

harm against the public benefits of the proposals (see balancing section further below) and where the public benefits outweigh harm then overall this policy would be met. Additionally, even where there is conflict with individual policies, that does not mean that the Development Plan, including the London Plan, taken as a whole is conflicted.

F. Housing Quality

Quality standards

8.270 The NPPF seeks to secure high quality design and a good standard of amenity for all existing and future occupants of land and buildings. The government seeks to ensure delivery of a wide choice of high quality homes of different sizes and tenures, and that land must be used efficiently with the density of development to be optimised. It has published ‘Technical Housing Standards – Nationally Described Space Standards’ that set out minimum standards and these are referenced and supported by policies of the London Plan and HLP.

8.271 LP Policy D6 has recommendations to secure the highest quality internally and externally for new housing, and to ensure that as densities increase, quality of housing is maintained. There must be adequately-sized rooms with comfortable and functional layouts which are fit for purpose and without differentiating between tenures. There are minimum quantitative standards for private internal space, private outdoor space and floor to ceiling heights that apply to all tenures and types of self-contained housing

8.272 In addition to minimum standards, policy D6 also states that qualitative aspects of a development are important to ensure successful sustainable housing. Single aspect units should normally be avoided and only provided where they would constitute a more appropriate design solution in terms of optimising the capacity of a sites, especially where high density is promoted including Opportunity Areas, whilst ensuring good design.

8.273 The design should provide sufficient daylight and sunlight to new and surrounding housing that is appropriate for its context, whilst avoiding overheating, minimising overshadowing and maximising the usability of outside amenity space. Other environmental conditions like air and noise quality must also be considered .The on-going sustainability in terms of servicing, maintenance and management should also be demonstrated.

8.274 The Mayor’s Housing SPG also has minimum standards that set a baseline for quality and design that new homes should aim to meet including for particular needs for older people, children, amenity space and wheelchair housing as well as in relation to the liveability and operation of the site, and interaction with surrounding development.

8.275 HLP policies CC2, SC4 and SC5 are consistent with these requirements and seek to ensure that new housing provides the highest quality of internal and external space to meet the demands of everyday life for the occupants, including adequate space for people including amenity space and wheelchair housing, and that units receive

good daylight and sunlight and that there is adequate separation between habitable room windows to ensure satisfactory privacy.

Unit Size and Layout

8.276 The design and layout of the proposed homes would be fully assessed at reserved matters stage, as part of the final detailed design, however the Development Specification and Design Code set out the requirements which need to be met and these align with the standards in the LP, HLP policy SC5, the Nationally Prescribed Space Standards and recommendations of the Housing SPG. It is therefore considered that appropriate accommodation will be secured.

Privacy and Outlook

8.277 London Plan policy D3 requires development to optimise use of land whilst providing appropriate outlook, privacy and amenity. The Housing SPG recommends minimum distances of between 18-21m between habitable rooms, with these distances being useful yardsticks for privacy. However it also says that adhering rigidly to these measures can limit the variety of urban space and housing types, and sometimes unnecessarily restrict density.

8.278 In respect of outlook, London Plan policy D4 says development should maximise the provision of dual aspect units and normally avoid those with only a single aspect and where single aspect units are proposed it needs to be demonstrated they have adequate conditions. The Housing SPG notes that good single aspect one and two bedroom homes are possible where limited numbers of rooms are required, the frontages are generous, the plan is shallow, the orientation or outlook is favourable, and there is mitigation of the potential overheating. It also says development should minimise single aspect dwellings that are north facing, exposed to noise levels above which significant adverse effects on health and quality of life occur, or have three or more bedrooms.

8.279 HLP policy CC2 expects development to provide adequate outlook, minimise overbearingness and overshadowing, through the careful layout, design and orientation of buildings and spaces. HLP policy SC5 says balconies should be designed as an integral part of the building’s elevation to maximise a beneficial aspect, and avoid positions that result in unacceptable overlooking and loss of privacy to other units

8.280 The parameter plans, development specification and design code set out minimum separation distances between habitable windows within the development of 17 metres, the parameter plans also require minimum distances of 18 metres and 20 metres across key east-west lanes and the north-south boulevard. The Design Code also includes a requirement that directly facing balconies should not have less than 14m separation between them, with balconies offset completely where there is a closer relationship to avoid overlooking issues. These are considered to provide appropriate controls against which the detailed design can be scrutinised.

8.281 With regard to daylight, sunlight and outlook, the development specification and design code require a minimum of 50% of all homes to be dual aspect (defined within both documents as homes with opening windows on at least two sides at 90° /

180°), with all larger homes providing dual aspect. The layout of the blocks helps to reduce the number of north facing single aspect units, which is welcomed. A full assessment of the quality of the homes would be carried out at reserved matters stage but it is considered that the parameter plans, development specification and design code provide a robust set of criteria with which any future application would have to comply and ensures suitable accommodation would be provided.

8.282 The development specification also sets a maximum of 12 homes per core on each floor, with appropriate design mitigation measures incorporated where number of homes per core exceeds 8, this is also embedded into the Design Code.

8.283 Although the detailed layout of the residential accommodation will be dealt with at reserved matters stage it is important to ensure that a high quality of residential accommodation will be achieved, it is considered that the development specification and Design Code secure this.

8.284 The GLA Stage I response noted that the residential quality was acceptable taking into account the layout and density proposed.

Internal Daylight and Sunlight

8.285 Sufficient daylight and sunlight is required for good quality accommodation. Policy SC4 of the HLP refers to the guidance on daylight and sunlight standards from the Building Research Establishment (“BRE”) report ‘Site Layout Planning for Daylight and Sunlight’ (2011). The BRE guidance highlights that its advice is not mandatory and although it gives numerical guidelines, these should be interpreted flexibly since natural lighting is only one of many factors in site layout design.

8.286 The primary method of assessment of new build accommodation is through calculating the average daylight factor (“ADF”) which is a measure of the daylight level within a room. The BRE guidance includes a measure for sunlight through calculating the Annual Probable Sunlight Hours (“APSH”) at the centre of each window on the outside face of the window wall.

8.287 The daylight and sunlight for the new homes would be fully assessed at reserved matters stage when detailed layouts of the buildings and individual homes are known. However an assessment based on a representative selection of residential habitable rooms within the Illustrative Masterplan has been carried out, this shows 85% achieve the ADF target and 54% satisfy BRE guidance by achieving the recommended annual and winter sunlight target levels, and regardless of orientation, 95% of rooms will have some access to direct sunlight during the year.

8.288 Given the nature of the proposal and urban character of the area, some flexibility is appropriate from the BRE targets is acceptable. This approach accords with the Housing SPG that says guidelines for daylight and sunlight should be applied sensitively to higher density development, especially in opportunity areas, town centres, large sites and accessible locations, where BRE advice suggests considering the use of alternative targets. This should take into account local circumstances; the need to optimise housing capacity; and scope for the character

and form of an area to change over time30. As such, the daylight levels outlined as being achieved within residential units is considered to be acceptable as a baseline for a scheme of this size and density in this location. The design objectives in the Design Code includes “Proposals must be carefully tested to ensure that acceptable levels of daylight and sunlight are obtained in all dwellings and outdoor spaces”, and therefore it is considered that the application has provided sufficient comfort at this stage that an acceptable arrangement can be secured. Further testing will be required at reserved matters stage to ensure the detailed layouts do secure this.

Accessible Housing

8.289 New housing must be accessible for all people with this included external areas, access and units themselves. The Mayor’s Housing SPG highlights31 that the ‘arrival’ at a building, the design of shared circulation and lift access, car parking and areas for cycle storage are important factors in making housing safe and secure, welcoming and accessible for all.

8.290 London Plan policy D7 requires development to provide suitable housing and genuine choice for London’s diverse population, including disabled people, older people and families with young children. It says residential development must ensure that:

1) At least 10 per cent of dwellings to meet Building Regulation requirement M4(3) ‘wheelchair user dwellings’; and

2) All other dwellings to meet Building Regulation requirement M4(2) ‘accessible and adaptable dwellings’

8.291 HLP policy CC2 has similar requirements and says that developments should be designed to be fully accessible to people with disabilities or impaired mobility.

8.292 The development specification commits to providing a minimum of 10% of homes meeting M4(3) ‘wheelchair user dwellings’, with the remaining homes meeting M4(2) ‘accessible and adaptable dwellings’, this is also confirmed in the Design Code. The Design Code specifically requires all aspects to incorporate the principles of Inclusive Design, so that everyone can access homes, streets, spaces and communal uses easily. The new public realm and communal amenity space would be inclusive to all.

8.293 This is considered acceptable, the details of the wheelchair housing and inclusive design will be assessed in detail at reserved matters stage.

Amenity Space

8.294 HLP policy SC5 says flats should have a minimum of 5 sqm of privacy amenity space for 1 to 2 occupants and an additional 1 sqm for each additional occupant, reflecting standards of the LP. Balconies should be designed as an integral part of the building’s elevation to maximise a beneficial aspect, and avoid positions that result in unacceptable overlooking and loss of privacy to other units or existing

30

Mayor’s Housing SPG (1.3.45) 31

Mayor’s Housing SPG (2.3.2)

nearby dwellings. Communal external space should be provided at 25 sqm per flat with up to 3 habitable rooms and 30 sqm for flats with 4 habitable rooms, less a reduction for the area of private space provided for each unit.

8.295 The provision and design of amenity space, private and communal, would be fully assessed at reserved matters stage, as part of the final detailed design, however the Development Specification and Design Code set out the minimum requirements which need to be met. Access to private amenity space would be provided for all individual homes. All the flats would comply with both LP Policy D6 and HLP Policy SC5 providing the required amount of private outdoor space per dwelling, either through the form of a private garden or balcony and all achieving a minimum depth and width of 1.5 sqm. The proposed houses would meet the minimum requirement of the London Plan and would have access to a greater level of private amenity than the flats but these would not meet the level of private amenity identified in Policy SC5. However, the private amenity space would form only part of their access to outdoor space. The development specification sets out a minimum external private amenity space standard of 24 sqm for the townhouses along the edges of the podium blocks, which would also have direct access to the communal amenity space within the podiums and access to the amenity at roof level, and 40 sqm for the houses along McFarlane Lane.

8.296 In this instance, given the layout and that all residents would also have access to the new public open space created within the site these minimum levels are considered to provide an acceptable level of private amenity space. As noted above the design of the spaces would be fully assessed at reserved matters stage.

8.297 Furthermore a condition is recommended which removes permitted development rights for extensions and alterations to the houses, this also needs to include the removal of rights for outbuildings to retain control over development on the site and ensure suitable garden space is retained for each house.

8.298 With regard to communal amenity space, this is provided in the form of courtyard podiums and rooftop spaces. The proposal also includes new public space with three public squares/gardens proposed within the scheme, one at the eastern end of the development, one at the western end providing a large public green amenity and play space, and one along the northern boundary incorporating and enhancing the existing Water Gardens and maintaining the existing pedestrian link. Across the masterplan, a minimum of 28,000 sqm of communal and public realm space would be provided, of which a minimum of 20,000 sqm would be publically accessible space at ground level, and a minimum of 8,000 sqm would be communal amenity space at podium and roof levels.

8.299 Whilst this is a substantial provision, it would fall short of the total requirement of approximately 32,300 sqm of communal external space to comply with Policy SC5 (the exact requirement would be based on the final mix, to be determined at reserved matters stage). As the site is located within an opportunity area and seeks to optimise the use of the site to provide a high density residential led scheme, some flexibility in providing communal space is reasonable. Overall the amenity space area proposed is considered adequate as there are suitable areas of outdoor amenity space. The proposed communal spaces are of a good size for landscaping and passive recreation and generally it is considered that the landscaping scheme

would provide an attractive setting to the development and a pleasant environment for future residents to relax in and enjoy. Given the location of the development and the high quality spaces being provided, such an under-provision is not considered to be unacceptable in this instance. It is also noted that the network of green spaces being provided across the development site would be consistent with Local Plan Policy GB4 and result in a positive contribution to the green infrastructure in the Borough.

8.300 The spaces have also been assessed for overshadowing, BRE guidance recommends that at least 50% of the relevant area should receive at least two hours of sunlight on the 21st March. The assessment demonstrates that all open spaces, play spaces, publicly accessible gardens would exceed BRE guideline and in some cases significantly. Similarly, all roof terraces would also meet and exceed BRE guidelines. Of the six podium gardens, four in Blocks A, C, and D meet and exceeded the guidance, one courtyard in Block A and the courtyard in Block H so not meet the 50% target but both achieve over 40% on 21st March and they will reach 50% on March 25th and 31st respectively. This is considered to achieve suitable levels of sunlight.

8.301 Due to the site’s location in an Opportunity Area, the emerging urban townscape and the need to maximise the use of sites such as these together with the other considerable planning benefits that the scheme will realise some deviation from the BRE guidelines is on balance considered acceptable. All residents will have access to private amenity spaces and large areas of public open space that exceed the BRE guidance which further mitigates the part deviation which affects only the shared courtyard gardens.

8.302 The applicant has undertaken an assessment of the likely child occupancy and play space requirements within the scheme in accordance with GLA guidance and benchmarks and this estimates a child yield of 562, resulting in a requirement for 5,624 sq.m. of play space provision. The development specification sets a minimum of 5,000 sqm to be provided.

8.303 The exact quantum of play space required would be calculated at reserved matters stage based on the final numbers and mix of homes, however if the final provision falls short of the required space, then this should be mitigated through off-site provision with a contribution towards additional play space provision in the local area; this would be secured in the legal agreement, with the figures to be calculated at reserved matters stage.

8.304 This play space would be split between publicly accessible space at ground level and communal amenity space at podium and roof levels, with incidental play elements featured throughout the open spaces and courtyard gardens providing distributed opportunities for play. Both Council Officers and the GLA are supportive of this strategy approach; the detailed proposals would be included as part of the reserved matters submission and assessed fully at that stage.

8.305 Therefore the development would be capable of making adequate provision for amenity space subject to further details of children’s play.

Housing mix

8.306 London Plan policy H10 and HLP policy S5 require new development to generally consist of a range of unit sizes. Policy H10 and sets out a number of factors which should be considered when determining the appropriate housing mix on a particular scheme. These factors include:

• Housing need and demand;

• The requirement to deliver mixed and inclusive neighbourhoods;

• The need to deliver a range of unit types at different price points;

• The mix of uses in the scheme;

• The range of tenures in the scheme;

• The nature and location of the site, with a higher proportion of one and two bed units generally more appropriate in locations which are closer to a town centre or station or with higher public transport access and connectivity;

• The aim to optimise housing potential on sites;

• The ability of new development to reduce pressure on conversion, subdivision and amalgamation of existing stock; and

• The need for additional family housing and the role of one and two bed units in freeing up existing family housing.

8.307 Given the outline nature of the application, the exact final mix of homes is not known. However the development specification includes minimum and maximum unit size mix parameters. These were revised through negotiation with the Council’s Housing Team to better reflect the Borough’s needs, including the introduction of four bedroom homes within the LAR/SR tenure, and are considered to ensure a good mix of homes would be provided and would contribute to the objective of delivering mixed and inclusive communities to create a better overall environment.

8.308 A range of housing typologies are proposed including flats, two-storey duplex / maisonettes and terraced homes, which provides a choice of housing and is supported. This is also strongly supported by the GLA.

Density

8.309 LP policies D1 to D4 place greater emphasis on a design-led approach to ensure development makes the best use of land, with consideration given to site context, public transport, walking and cycling accessibility, capacity for growth and existing and planned supporting infrastructure capacity. HLP policy SC4 seeks to 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.

8.310 The urban design assessment above considered the characteristics of the Site, including its location in an Opportunity Area near to public transport. It is also noted the GWC Plan and Site Allocations look to allocate the Site for high density

development. The proposal would also create its own residential and employment communities and establish its own character with access to a range of facilities and public spaces. Given the above considerations a good quality high density development is supported and the controls over the design quality and minimum housing standards of the scheme have been satisfactorily scrutinised and secured. The GLA’s Stage I response confirmed adequate design scrutiny had been undertaken and concluded that the Site is suitable for a well-designed high density scheme, taking into account the size and location within an Opportunity area and the relatively unconstrained nature of the site to the centre and north. They do however note that the success of a high density residential scheme will, however, depend on the potential to significantly improve the existing walking, cycling and public transport connections and address highways severance issues in what is a relatively car dominated junction on the A4 Great West Road.

Conclusion

8.311 Although a very high density is proposed, the scheme is capable of providing a good standard of residential accommodation that would meet objectives of key minimum baseline standards for housing quality as recommended in the Housing SPG, with these being generally consistent with the Council’s own guidelines. It is considered that through the development specification, parameter plans and design code appropriate safeguards are secured, with which the detailed design would need to comply and this would be fully scrutinised and assessed at reserved matters stage. The housing mix would also provide a range of home size and tenures and thus contribute to the creation of sustainable mixed communities, which would address an evidenced need both within the borough as well as within the wider London context.

8.312 As such it is considered that the proposal would be in accordance with the NPPF, the London Plan and the aims of the adopted Local Plan.

G. Transport

Introduction

8.313 Two planning applications have been submitted for the Site (Tesco) and the Homebase Site. A detailed application has been submitted for a new Tesco store and 473 homes on the Homebase Site. This would require a new traffic signal junction onto Syon Lane in a similar location to the existing Homebase access. Car parking and loading facilities would be accessed from Syon Gate Way which is a private road accessed from Syon Lane.

8.314 An outline planning application has been submitted for the Tesco Site proposing up to 1677 new dwellings on this site, together with between 3,000 and 5,000 sqm of commercial floorspace. The access to Syon Lane would be redesigned to remove the roundabout and the existing bus stands and stops will be relocated from their current location but retained on the site.

8.315 The transport impacts of both developments are inter-linked and much of the information and assessment is relevant to both sites and has been assessed in tandem, an approach required by TfL. This report therefore considers the transport impacts of both developments, providing individual comments where appropriate.

Policy background

8.316 The NPPF states in Paragraph 102 that promoting sustainable transport should be considered from the earliest stages of plan-making and development proposals, so that:

a) the potential impacts of development on transport networks can be addressed;

b) opportunities from existing or proposed transport infrastructure, and changing transport technology and usage, are realised – for example in relation to the scale, location or density of development that can be accommodated;

c) opportunities to promote walking, cycling and public transport use are identified and pursued;

d) the environmental impacts of traffic and transport infrastructure can be identified, assessed and taken into account – including appropriate opportunities for avoiding and mitigating any adverse effects, and for net environmental gains; and

e) patterns of movement, streets, parking and other transport considerations are integral to the design of schemes, and contribute to making high quality places.

8.317 Paragraphs 108-111 go on to state:

108. In assessing sites that may be allocated for development in plans, or specific applications for development, it should be ensured that

a) appropriate opportunities to promote sustainable transport modes can be – or have been – taken up, given the type of development and its location;

b) safe and suitable access to the site can be achieved for all users; and

c) any significant impacts from the development on the transport network (in terms of capacity and congestion), or on highway safety, can be cost effectively mitigated to an acceptable degree.

109. Development should only be prevented or refused on highways grounds if there would be an unacceptable impact on highway safety, or the residual cumulative impacts on the road network would be severe.

110. Within this context, applications for development should:

a) give priority first to pedestrian and cycle movements, both within the scheme and with neighbouring areas; and second – so far as possible – to facilitating access to high quality public transport, with layouts that maximise the catchment area for bus or other public transport services, and appropriate facilities that encourage public transport use;

b) address the needs of people with disabilities and reduced mobility in relation to all modes of transport;

c) create places that are safe, secure and attractive – which minimise the scope for conflicts between pedestrians, cyclists and vehicles, avoid unnecessary street clutter, and respond to local character and design standards;

d) allow for the efficient delivery of goods, and access by service and emergency vehicles; and

e) be designed to enable charging of plug-in and other ultra-low emission vehicles in safe, accessible and convenient locations.

111. All developments that will generate significant amounts of movement should be required to provide a travel plan, and the application should be supported by a transport statement or transport assessment so that the likely impacts of the proposal can be assessed.

8.318 Of particular note is paragraph 109 and the impacts of the development on road safety and traffic flow are set out later in this section of the report.

London Plan

8.319 Chapter 10 of the 2021 London Plan sets out the transport policies that apply to new development. These policies are supported by the Local Plan and will be addressed in detail by TfL but key points include:

8.320 Policy T1 (Strategic Approach to Transport) states that development proposals should facilitate the delivery of the Mayor’s strategic target of 80 per cent of all trips in London to be made by foot, cycle or public transport by 2041. All development should make the most effective use of land, reflecting its connectivity and accessibility by existing and future public transport, walking and cycling routes, and ensure that any impacts on London’s transport networks and supporting infrastructure are mitigated.

8.321 Policy T2 (Healthy Streets) states that development proposals should deliver patterns of land use that facilitate residents making shorter, regular trips by walking or cycling. In Opportunity Areas and, new and improved walking, cycling and public transport networks should be planned at an early stage, with delivery phased appropriately to support mode shift towards active travel and public transport. Development proposals should demonstrate how they will deliver improvements that reduce the dominance of vehicles on London’s streets, be permeable by foot and cycle and connect to local walking and cycling networks as well as public transport

8.322 Policy T3 (Transport Capacity, Connectivity and Safeguarding) states that development proposals should support capacity, connectivity and other improvements to the bus network and ensure it can operate efficiently to, from and within developments, giving priority to buses and supporting infrastructure as needed.

8.323 Policy T4 (Assessing and Mitigating Transport Impacts) states that development proposals should reflect and be integrated with current and planned transport access, capacity and connectivity. When required in accordance with national or local guidance transport assessments should be submitted with development

proposals to ensure that impacts on the capacity of the transport network (including impacts on pedestrians and the cycle network), are fully assessed. Travel Plans, Parking Design and Management Plans, Construction Logistics Plans and Delivery and Servicing Plans will be required having regard to Transport for London guidance. Where appropriate, mitigation, either through direct provision of public transport, walking and cycling facilities and highways improvements or through financial contributions, will be required to address adverse transport impacts that are identified. Where the ability to absorb increased travel demand through active travel modes has been exhausted, existing public transport capacity is insufficient to allow for the travel generated by proposed developments, and no firm plans and funding exist for an increase in capacity to cater for the increased demand, planning permission will be contingent on the provision of necessary public transport and active travel infrastructure. The cumulative impacts of development on public transport and the road network capacity including walking and cycling, as well as associated effects on public health, should be taken into account and mitigated. Development proposals should not increase road danger.

8.324 Policy T5 (Cycling) states that development proposals should help remove barriers to cycling and create a healthy environment in which people choose to cycle. This will be achieved through supporting the delivery of a London-wide network of cycle routes, with new routes and improved infrastructure and securing the provision of appropriate levels of cycle parking which should be fit for purpose, secure and well-located.

8.325 Policy T6 (Car Parking) states that car parking should be restricted in line with levels of existing and future public transport accessibility and connectivity. Developments should be designed to provide the minimum necessary parking (‘car-lite’). An absence of local on-street parking controls should not be a barrier to new development, and boroughs should look to implement these controls wherever necessary to allow existing residents to maintain safe and efficient use of their streets. The maximum car parking standards set out in Policy T6.

8.326 Policy T7 (Deliveries, Servicing and Construction) states that development proposals should facilitate safe, clean, and efficient deliveries and servicing. Provision of adequate space for servicing, storage and deliveries should be made off-street, with on-street loading bays only used where this is not possible. Delivery and Servicing Plans will be required and should be developed in a way which reflects the scale and complexities of developments. Appropriate facilities are required to facilitate efficient online retailing and to enable micro-consolidation, with management arrangements set out in Delivery and Servicing Plans.

8.327 Policy T9 (Funding Transport Infrastructure Through Planning) states that in consultation with the Mayor, boroughs should identify a package of strategically-important transport infrastructure, as well as improvements to public realm, along with other funding streams including CIL to deliver them. Planning obligations (Section 106 agreements), including financial contributions, will be sought to mitigate impacts from development, which may be cumulative.

Local Plan

8.328 HLP Policy EC1 promotes improvements to strategic transport connections. In particular its states:

We will work with partners to secure investments to existing and future strategic transport connections, including London Underground, rail, bus, and cycle and highway services. These enhancements will maximise the borough’s regeneration potential and support growth whilst also helping achieve our environmental objectives.

We will achieve this by

(a) Supporting planned upgrades to the Piccadilly and District lines;

(b) Promoting the development of rail connectivity between Southall (including Crossrail) and Brentford;

(c) Promoting the development of the proposed rail connection from Hounslow station to Willesden Junction via Old Oak Common, with services calling at Isleworth, Syon Lane and Brentford;

(d) Promoting improved bus services, particularly serving growth areas and the Golden Mile;

(e) Supporting improved access to the Piccadilly line, including introduction of a permanent stop at Turnham Green and improved links between the line and the Golden Mile growth corridor;

(f) Supporting improved access to Heathrow Airport through new southern rail access;

(g) Supporting improvements to rail services on the South West Trains network, and in particular Sunday services;

(h) Promoting new cycle networks, including a ‘cycling spine’ along the A315, with connecting Greenways and Quietways, and the provision of cycle parking at transport interchanges;

(i) Promoting improvements to the highway network to best facilitate sustainable modes, including targeted junction improvements, targeted travel demand management (including trip banking where appropriate), signal optimisation and bridge works; and

(j) Supporting initiatives to reduce the impact of road infrastructure in the built environment, including tunnelling proposals relating to the M4/A4. We will expect development proposals to

(k) Ensure that access to existing and future strategic transport connections is considered where appropriate, including through appropriate design; and

(l) Contribute to improvements to the strategic transport network where appropriate, consistent with the Local Implementation Plan and Infrastructure Delivery Plan, and the findings of Transport Assessments

8.329 This policy refers to a number of planned and proposed infrastructure improvements

that are relevant for the development site including the Piccadilly Line upgrade;

improving bus services; improving orbital and Overground rail connections; improvements to Piccadilly Line access; and cycle superhighway

8.330 HLP policy EC2 states the council will develop a sustainable transport network. This will be achieved by promoting low car developments where appropriate, promoting the active management of car parking and travel demand, and using the London Plan maximum standards for car parking. Development will need to be located appropriately in relation to public transport accessibility and capacity, road capacity and active travel networks. Development will be expected to demonstrate that the impacts meet the tests set out in the NPPF and that appropriate mitigation measures are provided.

GWC Local Plan

8.331 An Examination in Public to consider the GWC Local Plan will take place in 2021. This will include an assessment of the transport improvements that are proposed and which have been developed in a transport study (jointly commissioned by the Council and TfL). The transport study forms one of the background documents for the Examination in Public.

8.332 The transport study looked at how public transport capacity, network and accessibility could be improved to support the level of development proposed the Opportunity Area. Existing accessibility and travel patterns were examined, and the potential number of trips related to future development predicted and modelled by consultants. As a result of this work two packages, one bus-based package and one rail-based package, were assessed in terms of their ability to improve public transport accessibility and provide the additional capacity necessary to be able to deliver the proposed level of development. The conclusion reached was that both packages would improve the public transport accessibility of the Opportunity Area but the rail-based package would provide better improvements and therefore this package was favoured.

8.333 Both packages included the same basic package of measures including:

improved walking and cycling connections to stations.

Healthy Streets improvements across the area and within development sites to unlock new quieter parallel routes to the A4,

local bus network enhancements providing additional network capacity, better local public transport accessibility levels and improved connectivity to stations and local centres

the delivery of future rail and LUL network enhancements planned for the Piccadilly line, District line and SW rail line

station capacity, accessibility and other customer experience enhancements at Gunnersbury Station, Kew Bridge and Syon Lane

improvements to key junctions on the road network including at Syon Lane, Boston Manor Road, Windmill Road, Ealing Rd and Chiswick Roundabout

demand management measures including car-free and car-lite developments with low car parking standard, employee travel plans for existing and new businesses with ambitious mode share targets

8.334 These measures would need to be delivered in the short to medium term to mitigate the impacts of earlier developments in the Opportunity Area.

8.335 The transport study identifies that the rail based measures such as the proposed new passenger rail link from Brentford (Golden Mile) to Southall (Elizabeth Line) and the West London Orbital, and which would support LP Policy EC1 in particular, are medium to long terms measures and are likely to require a range of funding solutions rather than s106 funding.

8.336 The council has been working with TfL on developing a more detailed set of transport interventions, based on those set out in the transport study, that include bus service improvements, public realm and active travel improvements, and junction improvements that could be delivered in the short to medium term and would support the delivery of, and mitigate the impacts of, early developments.

8.337 The council is currently working with Network Rail and the Department for Transport on developing the rail link to Southall and the proposed opening date for this link is currently 2027. This scheme is currently going through Networks Rail’s design process. The council is also working with TfL and the West London Alliance on the proposed West London Orbital. This is at an earlier stage of development but is proposed to open by around 2030 and would link Syon Lane station to north London. If these timeframes are maintained then opening of these links would be around the forecast time of occupation of the Tesco site.

8.338 The council has proposed a Workplace Parking Levy (WPL) to help fund the rail link. The business case for this proposal is currently being developed but is only one funding option that is available.

Public Transport Accessibility

8.339 The Site currently has a PTAL score of 1-2 where 1 is the lowest and 6 is the highest. The majority of the site is in band 2 apart form a small area fronting Macfarlane Lane which is in band 1.

Opportunity Area Transport Study

8.340 As stated above, the transport study for the GWC Local Plan Review proposes a package of measures designed to improve the current PTAL within the Opportunity Area. Both the bus-based and rail-based packages would lead to an improvement in the PTAL and this supports the London Plan policy.

8.341 The transport improvements will be delivered over a number of years to allow development to match the expected growth within the Opportunity Area. It is envisaged that the first of these improvements would be delivered in advance of occupation of the Homebase site, with further improvements coming online prior to occupation of the Tesco which would follow.

8.342 The table below is an extract from the transport study that sets out the predicted improvements in PTAL as a result of the implementation of each transport package.

Table 4: Predicted PTAL Improvement

Trip Generation

Existing trip generation

8.343 In order to provide a base for an assessment of trip generation the applicant undertook a range of surveys at the Tesco and Homebase stores. The scope of the traffic surveys were agreed with TfL to be ensure the traffic modelling accurately reflects existing traffic generation for the existing sites.

Tesco site

8.344 The traffic surveys indicated that Saturday was the busiest day with around 5,650 visits but other than Sunday there were over 5,000 visits per day. Sunday was around 3,600 visits. Details are set out in Table 8.1 of the TA (p76).

8.345 Tesco currently attracts around 395 vehicle movements in the weekday am peak (8-9am) and around 750 in the weekday pm peak (5-6pm).

8.346 The applicant split these down further to measure single trips to the petrol filling station (PFS) because the PFS is not proposed to be replaced. These are set out in Table 8.2 (p77) of the TA.

8.347 The applicant also undertook parking surveys to understand use of the car park. The results are set out in 8.3.3 of the Transport Assessment but in summary are:

Saturday 29th June 2019 – 420 cars at 10:30

Thursday 4th July 2019 – 414 cars at 11:30

Saturday 6th July 2019 – 415 cars at 14:30

Tuesday 9th July 2019 – 499 cars at 11:15

8.348 Multi modal surveys were undertaken between 7am-7pm on a Sunday and a Tuesday to count other modes of travel to the store as set out in table 8.3 of the TA (p77) and reproduced here.

8.349 The applicant also undertook video surveys of existing traffic movements at key locations around the sites. These surveys were video surveys to allow validation of the traffic model, ie. to ensure the model replicates actual conditions as best as possible. The surveys allowed origins and destinations of traffic and therefore trip distribution to be noted.

Covid-19 Impacts

8.350 It should be noted that the traffic surveys were undertaken prior to the Covid-19 pandemic so reflect traffic flow at that time. Although is it noted that traffic levels have increased since the first lockdown in 2020 there is still uncertainty about the longer-term impacts. There is also uncertainty about how long it will take public transport usage to recover to 2019 levels but current predictions are that this will not be until the mid-2020’s at the earliest.

8.351 There has been a considerable move towards homeworking during the pandemic in line with the government’s message to stay at home. This has led to businesses reassessing how they operate, including the need for people to travel to work.

8.352 Therefore, the trip generation and traffic modelling reflects pre-pandemic information which might not be applicable in the future. However, it is considered that the surveys are robust for the purposes of assessing the traffic impacts of the proposed development.

8.353 In cases where there is more than a 12 month gap between initial surveys and the detailed traffic modelling for traffic signals, and agreeing the detailed junction design TfL will require updated surveys and modelling to be undertaken. In this case this work will also pick any post-pandemic changes.

Predicted traffic generation

8.354 The method for predicting trip generation has been agreed with the council and TfL and for the residential units for both sites was undertaken using the standard approach of interrogating the TRICS database for similar developments and applying local mode share based on Census travel to work data.

8.355 In both cases, account was taken of the proposed level of parking. The applicant used the TRICS database to assess trip generation per-parking space based on similar developments but TfL required a higher trip rate to be used to ensure the assessment was robust.

8.356 Delivery trips have also been included within the assessment. There has been a significant increase in home deliveries over the last few years and therefore predicting how this will develop in the future is difficult.

8.357 Traffic generation for the Tesco Site was undertaken using a standard approach TRICS. It was predicted that there would be 158 vehicle movements in the weekday am peak and 156 in the weekday pm peak (tables 10.2-10.9 of the TA).

Traffic impact

8.358 The applicant agreed a scope for the traffic modelling with TfL and a full VISSIM microsimulation model has been developed. Traffic generation for both developments have been included within the traffic model.

8.359 The results of the traffic surveys were fed into a microsimulation traffic model that includes the following junctions:

o A4 Great West Road - B454 Syon Lane

o A4 Great West Road – Harlequin Avenue

o A4 Great West Road – Wood Lane.

o Syon Lane by Northumberland Avenue

8.360 A separate model was used to assess the proposed access to the Tesco site as this is proposed to be a priority junction and not connected to the traffic signals at Gillette Corner.

8.361 All of the traffic modelling has been agreed with and validated by TfL. It should be noted that this is a detailed process and a conservative approach has been taken. Full consideration has been taken of all roads in the vicinity of the site, not just the A4.

8.362 The modelling has also been independently reviewed for LBH and details of this assessment are provided below.

8.363 The Tesco traffic was split and PFS traffic reduced, but not fully removed. This was redistributed from the northern arm of the junction to the south.

8.364 The traffic model includes background traffic growth up to the year of completion, in this case 2035 which is the date provided by the applicant. The predicted traffic generation was then added and distributed as agreed by TfL.

8.365 Government and local policy is to push for a “green recovery” from the Covid-19 pandemic with increased use of home working, public transport and active travel. These factors are likely to affect traffic levels in the future but the actual impact will only be known once the additional traffic surveys have been undertaken and the position of businesses with regard to homeworking. However, it is considered by TfL that the assessment is robust.

Traffic modelling options testing

8.366 The traffic model for Gillette Corner covers the area shown on the map above. This therefore assesses impacts not only on the A4 but also Syon Lane, Northumberland Avenue, Harlequin Avenue, Grant Way and the new Homebase site access.

8.367 The applicant was initially asked to model three options for the junction layout:

Option 1 proposed an additional right turn lane from the A4 into Syon Lane

(south) but no improvements for pedestrians or cyclists.

Option 2 included the above and also proposed a new pedestrian/cycle

crossing on the eastern arm of the junction, over the A4, to complement the

subway.

Option 3 proposed the above but included new controlled pedestrian/cycle

crossings on all arms of the junction.

8.368 The options were tested by TfL who looked at the impact on journey times for general traffic and buses.

8.369 Option 1 was not considered to be acceptable to the council or TfL as it provided no active travel improvements at the junction. This is considered to be a key requirement given the low levels of parking and the need to promote mode share change towards public transport and active travel.

8.370 Option 2 was considered to be acceptable to TfL in terms of traffic and journey time impacts but again does not deliver the active travel improvements that are considered by the council and TfL to be necessary to mitigate the development. A new crossing over the A4 on the eastern side of the junction would provide an alternative to the existing subway, which is welcomed. This would provide a new link in particular for residents of the Tesco site to Syon Lane station and residents of the Homebase site to link to Osterley Park. However, it is considered that improved links across Syon Lane are also required in order to provide access on the southern side to the Tesco store on pedestrian and cycle desire lines, and across the northern side to link the new residential development on the Tesco site to Osterley station.

8.371 Option 3 was considered to provide the required active travel improvements but this would require changes to the A4 approaches to the junction. In order to run separate pedestrian stages across Syon Lane the nearside lanes of the A4 would have to be changed to become left-turn only. This then impacts on journey times for through traffic, including buses, and the changes could not be accepted by TfL. The impacts were felt particularly on the eastbound approach from the A4 as a result of providing a new crossing on the northern arm of the junction.

8.372 In order to test other potential options for improving the pedestrian crossings at Gillette Corner the applicant was asked to model an additional scenario in detail, Option 4.

8.373 Option 4 was similar to Option 2 but added a new pedestrian crossing on the southern arm of the junction to test whether the potential traffic impact could be accommodated.

8.374 The existing pedestrian crossing on Syon Lane, close to the existing Homebase access, is proposed to be retained by the applicant but moved 15m south. However, this would not be on a desire line for people visiting the proposed Tesco store. In order to try to deliver meaningful mode change a crossing on the southern side of Gillette Corner, leading people to the entrance to the Tesco store, needs to be provided if possible. This would also benefit people passing the site along the A4

who wished to visit the Tesco store as well as local residents. Therefore, the applicant was asked to model a further option (Option 4) that included a crossing on the southern arm of the junction.

8.375 However, when this scenario was tested it was clear that the impact in the weekday afternoon and Saturday peak hours would be unacceptable again and TfL again considered that the impact on journey times would be too great. The main impact again being the need to accommodate a dedicated left-turn lane into Syon Lane which was having too great an impact at peak times.

8.376 Therefore, TfL have stated that Option 2 is their preferred option. However, this is only to be considered an interim solution. A pedestrian/cycle crossing on the southern arm of the junction is still considered to be a key mitigation measure and therefore it has been agreed with TfL and the applicant that Option 4 would be reviewed prior to opening of the retail store. TfL would require the traffic surveys and modelling to be updated as part of the process for agreeing the detail of the highway works.

8.377 During this process TfL will review all details of how the signals should be set up and optimised. Following this review, if a crossing can be accommodated then it will be included in the junction design. TfL are supportive of this crossing but need to be assured that the traffic impact would be acceptable.

8.378 If the provision of the southern crossing is not considered to be acceptable at that time, a further review and detailed traffic modelling would be undertaken after the occupation of the Homebase site, in advance of construction of the Tesco site, allowing actual traffic impact from the Homebase site to be reviewed.

8.379 As part of this second review, the council and TfL would also require the applicant to test a further scenario, Option 5, which would add a pedestrian/cycle crossing on the northern arm of the junction.

8.380 The applicant has undertaken a high-level review of this Option 5, testing the principle of whether a new staggered pedestrian/cycle crossing over the northern arm of the junction could be provided. This high-level review indicated that a staggered crossing could be physically provided. However, the current traffic impact would preclude this at the current time. This crossing would complete a key cycle link from the residential development on the Tesco Site towards Osterley station and other destinations to the west.

8.381 Given that the provision of a crossing on this arm of the junction provides particular mitigation for residents of the Tesco Site, although it does bring other benefits, it is recommended that this is reviewed prior to commencement of development of the Tesco Site. New traffic surveys and modelling will be undertaken that take into account the actual impact of the Homebase Site and any post-pandemic changes to traffic. It would provide the most up to date and accurate assessment to be made.

8.382 These reviews would be secured in the s106 Agreement.

Review of traffic modelling

8.383 In order to verify the process and results of the traffic modelling the council employed transport consultants to review the information submitted by the applicant. This review included a focus on Syon Lane and Northumberland Avenue and concludes that there are benefits and disbenefits to each option, and that these vary dependent on the time being tested. The general conclusions are set out below.

Analysis of traffic modelling

8.384 Each peak period was observed to demonstrate a set of road network behaviour and issues specific to it. These characteristics are pronounced to varying degrees in each design option, but in general the southbound and eastbound movements are of concern and at higher risk of congestion in the AM peak. In contrast, PM and Saturday peak periods are characterised by larger vehicle volumes and therefore higher queue levels westbound and northbound.

AM Peak

8.385 In the AM peak the overall network was observed to be very busy for all scenarios, including the future year base (FYB). A major factor in this is the rolling queue along southbound Syon Lane which impacts the operation of Gillette Corner for the middle part of the peak hour. The scale of its impact varies between scenarios, for example by how quickly southbound traffic is released from Gillette Corner, resulting in the queue extending back to Gillette Corner sooner or later in the peak hour. Once the rolling queue reaches Gillette Corner, it starts to impact all its approaches, in particular southbound Syon Lane, delaying traffic discharge and extending the total length of southbound queuing further along the road.

8.386 In the FYB scenario, Syon Lane congestion north of Gillette Corner is attributable to the additional factor of poor lane use by traffic. Last-minute lane changes by simulated vehicles slow down vehicle progress at the northern Gillette Corner approach and have a knock-on effect on the overall link flow, resulting in queuing upstream. As a consequence, the AM FYB displays high levels of congestion for Syon Lane, with some of the subsequent development options – where the above poor lane behaviour is less pronounced – appearing to operate better as a result. It is likely that tweaks to connectors and decision distances within the FYB model would resolve this issue. For example, network-wide results indicate, in a comparison between FYB and option 1:

Less delay per vehicle in option 1 (129 seconds v’s 187 seconds)

Higher average speeds in option 1 (13mph v’s 10mph)

Greater network peak hour throughput in option 1 (6,692 vehicles v’s 6,420 vehicles)

8.387 Because of high levels of congestion amongst the option models as well as poor operation of the FYB during the AM peak, it is not possible to identify a clear preferred ‘with scheme’ arrangement. However, given the high levels of congestion observed for options 3 and 4, it is likely that the extensive pedestrian facilities that these options propose would result in disproportionate levels of delay for road traffic, including buses. Option 2 therefore presents a favourable arrangement whereby

pedestrian facilities are improved but with no disproportionate impact on overall junction operation.

PM Peak

8.388 The PM peak model operates with a lower level of demand overall and as a result is better able to withstand increased demand resulting from the proposed development as well as additional pedestrian green time for proposed crossing facilities at the Gillette Corner junction. Although some queuing has been observed in all scenarios, particularly along northbound Syon Lane and westbound A4, this is predominantly intermittent and largely clears during the next green phase. It was observed that the northbound Syon Lane queue is often attributable to traffic having to stop at the Gate Centre pelican crossing, followed by the southern site access junction, followed again shortly by the Gillette Corner stop line. The phasing of those signals does not seem aligned for this movement and result in slow progress along the link, allowing the northbound queue to build. It is possible that this queueing could be reduced with a more ‘streamlined’ green wave for Syon Lane.

8.389 Options 3 and 4 demonstrate high levels of congestion on the A4, mostly for the westbound approach, but also affecting the eastbound movement. The results of the three variants for option 4 suggest that the queue length is sensitive to changes such as minor alterations to signal timings. Nevertheless, the queue lengths for those options indicate that Gillette Corner does operate much less efficiently with the additional pedestrian facilities in place. Both options 1 and 2 operate with much less queuing. As option 2 appears to be able to accommodate the additional pedestrian facility without undue impact on the wider junction, it would appear to also be the preferred option for the PM peak.

Saturday Peak

8.390 The operation of the Saturday network is comparable to the PM one in the context of dominant movements and overall network behaviour. For most of the scenarios tested, generally the network operates well, with no excess congestion or persistent queuing. Syon Lane queue northbound is intermittent and largely dependent on the signal sequencing and green time along the link. Although the queue does build at times, it regularly clears and is not thought to be severe.

8.391 Options 3 and 4 demonstrate a much greater scale of impact on the A4 than was observed in the PM peak. A key issue for the Saturday peak is the large proportion of westbound A4 traffic wishing to turn left into Syon Lane. This demand is not adequately accommodated by the proposed signal arrangement of either option, resulting in long delays for this movement, impacting westbound A4 traffic overall. As a result, option 2 would be a preferable alternative for the Saturday peak, allowing improvements to be made for pedestrian movements at a scale which can still accommodate vehicular demand at Gillette Corner.

Harlequin Avenue

8.392 Harlequin Avenue serves as a primary access for businesses. Any queuing on Harlequin Avenue was only observed in the PM peak, presumably as this is the end of the working day for staff. The Harlequin Avenue queue length varies depending on

the level of congestion on westbound A4, as this determines the level of discharge from the Harlequin Avenue approach. In addition, the signal arrangements at the junction allow for no more than four vehicles to exit at any one time, resulting in extended queuing. This is despite the modelling allowing for the Harlequin Avenue green phase to be activated at every cycle, as advised by the modelling consultant.

Grant Way

8.393 The approach to the Sky campus, off Syon Lane is Grant Way. Again, this link is included in the model for background flows only. The link operation shows to be relatively good for all scenarios, although its traffic discharge rate is closely linked to the level of queuing along southbound Syon Lane. Traffic exiting Grant Way in the AM peak, when Syon Lane congestion is greatest, is relatively low. Therefore, the road is not significantly affected by any of the delay. At other times, some queuing and congestion has been observed along Grant Way, albeit only intermittently and clearing relatively quickly. As a result, no option or development scenario can be identified as having the greatest benefit or disbenefit for this link.

Northumberland Avenue

8.394 As with other side roads in the model, Northumberland Avenue has been modelled with background flows only and does not include any of the proposed development traffic in any of the modelled options. Congestion levels on Northumberland Avenue are low during both PM and Saturday peaks. In the AM peak, a queue builds gradually during the peak hour, extending the full length of the modelled link. A review of the CCTV footage and discussions with the modelling consultant have identified that this is in fact an accurate reflection of the on-street behaviour, albeit the exact length of the queue has not been measured or validated.

8.395 A route alternative exists for traffic wishing to bypass Gillette Corner by travelling via Wood Lane and Northumberland Avenue instead. This is a possible ‘rat-run’, the likelihood of which has not been investigated in the model. It seems unlikely that such behaviour would occur in the AM peak when network-wide queues are greatest, given the queue already observed on the link. During other time periods, the queue observed along Syon Lane and A4 does not appear to be sufficiently extensive to promote rat-running, although such behaviour cannot be fully discounted as a possibility. Wider network operation seems to have little impact on Northumberland Avenue. Therefore, no specific option can be identified as having the greatest benefit or disbenefit for it.

8.396 However, officers are concerned that people living close to the south and west of the Homebase site may decide to use this road instead of the A4 to avoid the traffic signals. Therefore, whilst the traffic modelling does not indicate that there would be an increase in journey times on Northumberland Avenue it is considered that this needs to be reviewed post-occupation of the Homebase Site.

Conclusions

8.397 The traffic modelling indicates that the A4/Syon Lane road network experiences periods of high congestion levels at present, particularly during the morning peak and would struggle to accommodate extensive alterations to the junction including

pedestrian crossing facilities on all of its approaches. Development options proposing signalised crossings at three or four arms of the junction demonstrate much longer queues than observed at present and suggest that the impact on the local road network may be significant.

8.398 The greatest impact of signalised pedestrian crossings on Gillette Corner junction approaches, evidenced in options 3 and 4, is observed along the A4. Syon Lane experiences congestion in all scenarios, particularly in the AM peak, whereas the Saturday and PM peak periods operate with less queuing. Although congestion levels are highest in the AM peak across all options, some options demonstrate an improvement in junction operation as compared with the FYB scenario. This is particularly evident for options 1 and 2.

8.399 Option 1 does not provide any improvements to pedestrians and as such is inadequate in its proposals. Option 2 offers an additional surface level crossing facility on the eastern approach of the junction, improving pedestrian permeability while not disproportionately impacting on junction operation. As such it could be viewed as preferable in the sense of minimising the impact of the scheme on the existing road network. However, it does not provide a significant improvement to pedestrian facilities at the junction.

8.400 Further investigation into the mitigation measures of Option 4 would need to be considered and tested further to ascertain whether additional crossing facilities on the Syon Lane approaches can be considered to be acceptable.

Tesco Site Access

8.401 Access to the Tesco Site is currently from a roundabout junction with Syon Lane. This access was obviously designed to ensure the level of traffic associated with a large food retail superstore could be accommodated on the road network. The store currently attracts around 4-5,000 trips per day as evidenced by the traffic surveys.

8.402 However, the capacity that this type of access provides is not considered to be appropriate or required for a residential development where traffic generation will be lower. The design of the roundabout also provides a barrier to active travel including walking and cycling movements.

8.403 As such, the applicant was asked to redesign the access road to provide a priority junction with a ghosted right turn lane, and for this to be modelled against the predicted trip generation. A priority junction would reduce the width of the access, allowing much better provision for pedestrians and cyclists.

8.404 This junction was not included in the Gillette Corner traffic modelling and was modelled using separate software. This indicated that a priority junction with ghosted right turn lane would operate well within capacity and therefore this is considered to be acceptable in principle. These changes would be undertaken using a s278 Agreement, to be secured in the s106 agreement. As with Gillette Corner, the traffic surveys and modelling will be reviewed as part of the reserved matters applications, with the detailed design of the access and all other highway works being reviewed in advance of the commencement of construction to ensure it is in accordance with

guidance that is in place at that time. Therefore, at this time only the principle of the access will be secured.

8.405 It is noted that the removal of the roundabout will also remove a traffic calming feature on a section of road which has a 20mph speed limit. For this reason, the future junction design must also investigate and, if required, implement replacement traffic calming. This should be based on speed surveys on this section of Syon Lane. This will be a requirement of the s278 works.

8.406 The changes to the access to the Tesco Site can be considered to be acceptable, but should be subject to future review once actual traffic patterns are known following occupation of the Homebase Site and the impacts of post-pandemic traffic levels. The detailed site design must also provide cycle priority across the junction, with the stop line set back behind a cycle lane.

Public Transport

8.407 Policy T1 of the London Plan states that all development proposals need to reflect current and future public transport accessibility. Although the area currently has low to moderate public transport accessibility the proposals being developed for the Great West Corridor Opportunity Area will ensure these levels are increased. Therefore, it is correct to consider the nature of the developments against the future predicted level of accessibility.

8.408 At the same time, however, as set out in the transport study it is also correct to consider what short to medium term mitigation measures will be required to ensure there is adequate capacity available to cater for demand in advance of the delivery of more strategic transport improvements.

Buses

8.409 The sites are currently served by the following bus routes:

Route H28 currently terminates at the Tesco Site and runs between there and Tesco at Bulls Bridge via Syon Lane Station, West Middlesex Hospital and Wood Lane. This service has a 20 minute frequency Monday to Saturday, and 30 minutes on a Sunday. Frequencies reduce in the early mornings and evenings.

Route H91 runs along the A4 between Hounslow East and Hammersmith via Osterley Station, Gunnersbury Station and Chiswick. This service has a frequency of 7-11 minutes on a weekday, 9-10 minutes on a Saturday and 14 minutes on a Sunday. Frequencies reduce in early mornings and evenings.

8.410 TfL has consulted on changes to the H28 which would mean it no longer terminates at the Tesco Site but would continue to serve it. Instead, it is proposed that the E1 would be extended from Ealing Broadway and serve the A4 and terminate at the Tesco site. There is currently no date for these changes to be made but is due to link with opening of the Elizabeth Line.

Tesco Site

8.411 The applicant has predicted there would be 404 bus trips generated in the am peak and 312 in the pm peak.

8.412 TfL is the transport authority responsible for delivering bus services and were consulted on these planning applications. TfL have undertaken a detailed review of the impacts on bus services of the two proposed developments and have requested a contribution of £1.7M to provide improved bus services. TfL has not currently identified which routes this would go towards but they would review the situation in advance of the occupation of the Homebase site and allocate as appropriate in accordance with the Opportunity Area transport study.

8.413 The Tesco site is currently the location of bus stands, stops and facilities serving the H28 route. These are to be retained on the site. TfL has recently proposed changes to the bus services in this area which would see the E1 route terminating at the site. There is currently no timescale for these changes but they are proposed to take place to link Osterley to the Elizabeth Line at Ealing Broadway. Retention of the bus stops is also key in ensuring residents of the proposed development would have easy access to local bus routes.

8.414 The applicant has proposed two options for the location of the bus stops. A detailed option has been proposed for Grant Way at the southern side of the site which would also closely link to the Sky Campus. Buses would enter and exit from Grant Way and a turning area provided. This has been tracked and can be provided without obstructing traffic on Grant Way. This option is supported by TfL Buses.

8.415 A second, less detailed option has been proposed that would provide stops and stands within the site. This would see buses enter the site from Syon Lane, stop in front of one of the residential blocks and exit onto Grant Way. This option would require further design work and is not favoured by TfL. The buses would be using private roads and would be running past and stopping in front of residential blocks which could lead to objections from residents. It is considered, therefore, that the bus stops, stands and drivers facilities are secured on Grant Way in the s106 agreement, as generally shown on the submitted drawing, but with the option to be reviewed on submission of reserved matters application.

8.416 The Grant Way option would be able to be provided during construction and ensure that the facilities are separated from construction activities. Should the site option be pursued, it is likely that temporary facilities would need to be provided on Grant Way in any case to ensure they are separate from construction activities.

8.417 Continuous retention of the bus stops, stands and drivers facilities would be secured in the s106 agreement and this includes during construction.

Underground

8.418 The closest underground stations are Osterley and Boston Manor on the Piccadilly Line. It is predicted that there would be an additional 64 am peak trips resulting from the Homebase site and 225 from the Tesco site. In the pm peak these numbers are predicted to be 50 and 174 respectively. TfL have reviewed the applicant’s assessment of station capacity and line loading capacity at Osterley Station taking into consideration the anticipated demand of consented schemes. However, the

assessment still requires further work before TfL can determine if a contribution is required. However, given the Tesco Osterley site generates the greatest demand for underground trips TfL recommend that an updated assessment of station capacity and line loading capacity at Osterley Station is accompanied with the first reserved matters application, and any identified improvements to be delivered prior to first occupation. This is to be secured in the s106 agreement.

8.419 The Piccadilly Line is due to be upgraded by TfL to provide increased capacity. It has recently been announced that final design of the new trains has been agreed and the current estimate is that work to upgrade the line will be completed and the new trains running by 2025. This would coincide with the occupation of the Homebase Site and in advance of occupation of the Tesco Site.

Rail

8.420 The nearest rail station to the sites is Syon Lane which is on the Hounslow Loop line linking Waterloo, Clapham Junction, Barnes, Chiswick, Kew Bridge, Brentford, Syon Lane, Isleworth, & Hounslow with Feltham, Reading and Windsor. The route is operated by Southwestern Railways and is currently served by 2 trains per hour in each direction under a Covid timetable but this will return to 4 trains per hour. Syon Lane station has recently been provided with step-free access to both platforms. SWR have also confirmed that new trains are due to be operated on this line which will lead to an increase in capacity. These trains will be introduced on their network from this summer and likely to be on the Hounslow Loop within a year.

8.421 Syon Lane station is well used by Sky employees and is known to be particularly busy at peak times due largely to the number of passengers disembarking from a train. Data supplied by SWR indicates that during the morning peak 0f 0720-0850 between 250-400 people can alight from a train, and that in the evening peak between 1,650-1,850 between 150-350 people can alight from a train.

8.422 In the am weekday peak it is predicted that the Homebase development would generate an additional 69 trips and the Tesco development 188. In the pm peak these are predicted to be 53 and 188 respectively.

8.423 Southwestern Railways have been consulted on the planning applications and have confirmed they have no objections and require no contributions.

8.424 In discussions with SWR it is clear that train use has declined significantly as a result of the Covid-19 pandemic and they are currently running a reduced timetable as a result and it is unclear when this will increase to pre-pandemic levels. It is also unclear how businesses, including Sky, will respond to the pandemic and if similar numbers of passengers will return to Syon Lane station. As a result of this, and when taken with the increased capacity of the new trains SWR do not raise an objection or require a contribution to improved train capacity.

8.425 SWR have also confirmed that there are no plans to increase circulation space on the platforms. This was raised as a concern at the station but investigations have shown that potential improvements would be limited to widening at the country end of the station and are not currently proposed. Therefore, no contribution is required and no objection raised.

Car Parking

8.426 Car parking provision has been assessed against London Plan parking standards which are a maximum.

8.427 No detailed car parking layouts have been provided given the outline nature of the application, but it is proposed to provide 400 residential parking spaces at a ratio of 24%. It will be expected that the appropriate number of disabled and EV charging bays will be provided in accordance with parking standards at the time that reserved matters applications are made.

8.428 It is proposed that parking is provided on-street and in podiums within the site and this is considered to be acceptable. The layout will need to ensure that parking for visitors, EV charging points and blue badge holders are available on-street as well as in podium car parks. In accordance with the London Plan no parking spaces are to be sold, and EV charging and disabled parking bays are to be made available to those who require them. The detailed Car Park Management Plan (CPMP), to be submitted and approved as part of reserved matters submissions, must be in full accordance with guidance and/or requirements that are in place at that time.

On-street parking

8.429 Neither the Tesco Site nor the Homebase Site is located within a CPZ. Therefore, residents would not be eligible to apply for permits within neighbouring CPZs. This will be reinforced in the s106 agreement.

8.430 The neighbouring Wyke Estate operates 9.30-5.30 Monday to Friday. This would dissuade residents of parking their cars in the CPZ but residents would be able to park in these areas outside CPZ operating times including weekends. Notwithstanding this, the CPZ team have advised that this zone is reviewed to see if there would be support for extending the hours of operation as a result of the proposed developments. Given the length of time that would elapse between planning permission and a review of the CPZ it is not possible to provide a cost or this work but the consultation and implementation is to be secured in the s106 agreement.

8.431 There are 2 roads in the vicinity of the application site that are not currently within a CPZ. These are Syon Park Gardens/Leigham Drive. It is recommended that parking surveys are undertaken prior to occupation and post occupation and if there is found to be an increase attributable to the development then consultations should be undertaken. It is not possible to provide accurate costs at this time but the principle should be secured in the s106 agreement.

Cycle Parking

8.432 It is currently proposed that the number of cycle parking spaces will accord with the London Plan minimum standards. However, given the outline nature of the planning application no details have been provided. Therefore, the number will need to be reviewed at reserved matters stage and be in accordance with cycle parking standards that apply at that time. This will need to be secured by obligation.

8.433 However, as a matter of principle it will be expected that cycle parking will be provided for each residential core, with a mix of types of cycle parking to be provided to ensure that non-standard bikes can be accommodated. Cycle parking is expected to be a key design feature of each block. On-street visitor/short stay cycle parking will be provided throughout the site, close to each core. Short stay cycle parking will need to be provided for each commercial building in accessible and safe locations.

Deliveries and Servicing

8.434 All servicing and deliveries to the development on the Tesco site will be undertaken within the site. There would be no impact on Syon Lane directly. It could be possible for some deliveries to be made from Grant Way and swept paths have been submitted that show this could be possible without obstructing traffic accessing the Sky Campus.

8.435 A review of the potential number of servicing trips, based on recent surveys for other flatted developments, indicates that there could be around 140 trips per day to this site. However, given the increase in home shopping as a result of the pandemic this number is likely to have increased. It is noted that the majority of these trips would be off-peak and therefore unlikely to affect traffic on the network at sensitive times such as the weekday am peak.

8.436 A number of delivery bays are proposed on the internal site roads, close to the residential cores. A central delivery facility is also proposed in order to centralise as many deliveries as possible. An option for delivering to the commercial units is also proposed although this would lead to delivery vehicles accessing pedestrian priority areas, which is to be discouraged.

8.437 The applicant has demonstrated that deliveries can be satisfactorily accommodated within the development subject to detailed design at the reserved matters stage. However, the predicted number of servicing trips will need to be reviewed prior to approval of the detailed Delivery & Servicing Plan (DSP), as are the facilities currently proposed and the means to manage the number of trips which will need to be in accordance with guidance that is in place at the time the reserved matters application is made. If required, additional facilities will need to be provided on the site.

Active Travel, Road Safety and Public Realm

8.438 The applicant has undertaken an Active Travel Zone Assessment for both applications. This has identified the most popular walking and cycling routes that people are likely to use to travel to and from the proposed developments. The assessments have included a comprehensive review of road safety, identifying locations of Personal Injury Collisions (PICs).

8.439 Many of these routes overlap, for both sites, and concentrate on the obvious routes such as Syon Lane and The A4. The ATZs identify locations where improvements could be made to encourage more walking and cycling trips.

8.440 Some of the locations have been picked up within the highway or public realm works around the site and others are in locations where the council is already working on

schemes. This includes works to improve Gillette Corner for pedestrians and cyclists, improvements to the subway, routes from Gillette Corner to both sites, and the areas adjacent to both sites.

8.441 Locations along the A4 have been identified as being in need of improvement, especially junctions to the east (linking the site to the Grand Union Canal and Boston Manor Road) and the west linking the sites to Osterley station). These locations have been raised in discussions with TfL as Highway Authority for the A4.

8.442 Some locations for improvement have been identified on Syon Lane either through site assessment or collision data. In relation to collision data, pedestrians crossing Syon Lane to the north of Syon Lane station was identified, but the introduction of a controlled pedestrian crossing has improved safety at that location.

8.443 Busch Corner has also been identified as a location with a significant number of PICs. Improvements to this junction are being proposed as part of the C9 proposals along London Road, together with s278 works relating to the Green School for Boys development.

8.444 The removal of the roundabout access and the Tesco car park will allow a new segregated 3m wide cycle lane to be delivered, together with a 2m footway. These will link to and improve on facilities that are being delivered through the Bolder Academy development.

8.445 The access to the development site needs to prioritise cyclists with the stop line set back behind a cycle crossing. This will be included in the s278 works.

8.446 The council also has identified improvements to cycle infrastructure along Windmill Lane within its Transport Strategy, improving links between Osterley and Southall. However, there is not yet an outline design or programme for this route and the costs would be considerable. Therefore, it is not considered appropriate to require a s106 contribution. Once more detailed proposals have been drawn up it is likely that a bid for CIL funding to deliver this route would be made.

8.447 The applicant has proposed to refurbish the subway under the A4 at Gillette Corner and this is supported but will need the approval of TfL.

Construction

8.448 In accordance with policy the applicant has submitted daft Construction Logistics Plans (“CLP”) for both sites. The development would be likely to have temporary local disruption to pedestrian, cycle and vehicular traffic, including public transport users for the duration of works owing to demolition and construction traffic. Some impacts from such large scale construction are an inevitable consequence of development.

8.449 A draft CLP has been submitted with the application but given the timescales for this proposed development, a detailed document will need to be submitted prior to the commencement of construction. All construction traffic will need to enter the Site from A4 with no heavy construction vehicles in the morning or school peaks (i.e. all deliveries between the hours of 9.30-3pm) unless agreed in advance and with

additional road safety measures in place, particularly to ensure the safety of school children is protected. This will be secured by planning condition.

Conclusion

8.450 The developer has submitted Transport Assessments for the Homebase and Tesco Sites. The transport impacts of these developments, as set out in the Transport Assessments and associated documents, have been considered in detail and against national, London and local policy. It is considered that the proposed developments are in accordance with policies set out in these documents.

8.451 Following consultation with TfL and public transport providers, it is considered that there would not be a severe residual cumulative impact from the relocation of the existing Tesco store to the Homebase site together with 473 new residential dwellings, or the subsequent redevelopment of the Tesco store for up to 1,677 new dwellings and local commercial units. It is also considered that there would not be a significant impact on road safety as a result of the proposed developments, all subject to delivery of the proposed mitigation measures.

8.452 The Homebase site and the Tesco site are located in the Great West Corridor Opportunity Area which is proposed to support significant levels of residential and commercial development over the coming years. The transport study that was commissioned jointly with TfL has proposed a series of transport interventions designed to increase public transport accessibility and these are proposed to be delivered using a range of funding opportunities including S106 and CIL. The London Plan requires development to be assessed against current and future levels of public transport accessibility as well as considering shorter term mitigation measures to ensure that any impacts on the public transport network are mitigated.

8.453 In accordance with the London Plan the developer has agreed to a number of measures to mitigate the traffic, public transport, and active travel impacts of the proposed developments. This includes works to improve traffic flow and pedestrian/cycle accessibility at Gillette Corner, a £1.7M contribution towards improved bus services, and active travel improvements around the site. Strategic transport improvements, as identified in the transport strategy, will require CIL (and other) funding to be delivered, to which this and other developments in the Opportunity Area will contribute. Use of s106 contributions is not considered to be appropriate in such cases. The timescale for the delivery of the development of the Tesco site, in particular, will allow further development and delivery of the wider transport improvements in advance of the occupation of the Tesco site which is envisaged for 2030.

8.454 Therefore, there is no transport objection to the proposed developments.

H. Impacts on neighbours

8.455 The NPPF requires sustainable development, and as part of this development should aim to minimise adverse effects on the local environment, which includes neighbouring properties.

8.456 LP policy D6 requires the design of developments to provide sufficient daylight and sunlight to new and surrounding housing that is appropriate for its context, whilst avoiding overheating, minimising overshadowing and maximising the usability.

8.457 HLP Policy CC2 expects developments to function well in themselves and in their effect on surrounding areas, including impact on the amenity of current and future residents. HLP policy SC4 states that development proposals should demonstrate compliance with prevailing daylighting standards (BRE Guidance), whilst LP policies D6 and D9 and HLP CC3 relate to tall buildings and the impacts they can have, requiring these to be assessed with regard to microclimate and over-shadowing.

8.458 Buildings should not cause unacceptable harm to the amenity of the surrounding land and buildings, particularly residential buildings in relation to privacy, overshadowing, wind and microclimate, with this being particularly important for tall buildings. In respect of daylight and sunlight, an appropriate degree of flexibility needs to be applied when using BRE guidelines to assess the daylight and sunlight impacts of new development on surrounding properties, as well as within new developments themselves, with relevant guidelines being applied sensitively to higher density development, especially in opportunity areas, town centres, large sites and accessible locations, where BRE advice suggests considering the use of alternative targets.

8.459 The Site is located between residential and commercial properties. Commercial buildings are located to the north and east, these are less sensitive than residential properties and so this context limits impacts on neighbouring properties, although the Sky campus is considered sensitive receptor for noise due to the TV studios. To the South and west lie residential properties, these are more sensitive to impacts from the development and must be carefully considered, particularly given the large scale and tall height of the buildings, especially in respect of outlook and privacy and daylight and sunlight.

Outlook and privacy

8.460 Given the application is outline, a general assessment based on the maximum parameters and design principles embedded within the design code has been undertaken. A more detailed assessment would be carried out at reserved matters stage based on the detailed design, if permission were granted.

8.461 It is noted that properties surrounding the application site at present generally enjoy an open outlook given the location and scale of the existing Tesco building.

8.462 The proposed development has been sited to minimise the impact on neighbouring residents in terms of outlook, in particular a buffer is retained around the edge of the site with the buildings set behind this. Due to this and the width of Syon Lane itself, the separation distance to neighbours on the southern side of Syon Lane would approximately 40m. Clearly the outlook from these properties would be significantly altered given they look onto a car park currently, and the proposal would introduce substantial built form, however visibility alone does not equate to harmful visual intrusion. As set out in the urban design section, the scheme has been designed to break up the massing with various set-ins and steps in building line, with lower elements along the Syon Lane frontage and the taller buildings concentrated in the

centre and north of the site. This design approach and the separation distance would ensure these neighbours continue to have a satisfactory outlook. Due to the separation distance there would be no loss of privacy or overlooking caused.

8.463 To the west, no. 141 Syon Lane would be most affected by the proposed development of Blocks E and J. Block E would be located to the east of this neighbour, 10m from the boundary with this property and across McFarlane Lane, it would be a maximum of 6 storeys (18m), although the massing principles in the design code require it to retain a massing relationship with adjacent parcels C and D, related to the shoulder height of the Gillette Factory, and step up in height from Syon Lane which means this height and massing would be broken down in the detaied design. The front of Block E would start approximately in line with the front elevation of this property and extend the full length of the rear garden. The primary outlook from this neighbouring property is north and south to the front and rear, although there are east facing windows in the side elevation facing the Site, however these do not serve habitable rooms. The proposal would be a dominant feature when viewed from the rear garden of this property, the separation and give some relief to occupants from the scale of the building which would also be further mitigated by the orientation to the east and therefore away from the primary outlook. It is considered that an appropriate outlook would be retained for this neighbour.

8.464 The parameter plans show a balcony zone along the western elevation of Block E facing the side boundary of the neighbouring gardens, a separation distance of over 10m would be maintained, it is considered this could provide a suitable relationship subject to careful consideration of the placement and design of balconies, such relationships are not unusual in an urban environment where previously developed sites have close boundary relationships with existing residential properties. The final design and layout of the blocks and individual windows and balconies is unknown, but the principle of this relationship is not considered to be unacceptable. Details on the exact location of balconies and any screening would be assessed as part of detailed design.

8.465 Block J is located to the north and adjacent to the rear boundary of this neighbour, it is limited to two storeys (maximum 8m) in height and due to the length of the garden would be located over 23m from the house. Therefore whilst it would enclose the rear boundary where there is currently an open aspect, due to the scale, siting and the fact that it is located to the North, it is considered that the parameters would ensure the impact on outlook would not be unacceptable on the living conditions of the residents of no. 141. Window arrangements would be considered at detailed design stage, although it is noted that the orientation of the block means it does not rely on having windows in the south elevation and therefore it is considered that suitable privacy can be maintained for this neighbour.

8.466 The garden of no. 143 Syon Lane also backs onto the area where Block J would be sited, although the block would not extend the width of the rear boundary due to the need to provide garden area for the new dwellings. Again the block would be sited to the north and over 23m from the house, it is also noted there is currently an outbuilding within the rear garden of no. 143 close to the northern. This relationship does not raise concerns in terms of outlook. As above, window arrangements would be considered at detailed design stage, although it is considered that suitable privacy can be maintained for this neighbour.

8.467 No.’s 46-48 Oaklands Avenue are orientated east-west and their rear gardens adjoin the western boundary of the Site. Block J would be set off the boundary with the properties, the parameter plans and design code require a minimum separation distance of 18m from the rear of these properties to the rear of Block J; this accords with the 18- 21m guideline separation distance between windows in habitable room windows and given the scale of the Block J is considered to be a suitable arrangement. Block F, which is larger, would be visible beyond Block J however it would be partially screen by the presence of Block J and is sited over 27m from the boundary with these properties. Whilst the outlook of these properties would change given the scale of Block J and separation distances this is not considered to be inappropriate or harmful. The open character of the sports ground to the north east would be unchanged.

8.468 To the North, there would be a minimum of 31m separation between the proposed residential buildings and the boundary of the site, this means that there would be a substantial distance between the proposal and the nearest building within the Sky Campus; no concerns arise from this relationship.

8.469 Further afield, it is considered that the impact of the development on residential amenity in terms of outlook would diminish, and whilst it would remain a highly visible feature from longer views, it is not considered that it would have an unacceptable impact on neighbouring residents’ outlook.

8.470 Given the relationship, which is similar to many other houses within the vicinity, and the scale and form of the proposed houses it is considered that there would be no demonstrable harm caused to the living conditions of these neighbours through overshadowing, visual intrusion or loss of outlook. Whilst there would be windows in the front elevations of the proposed houses which face these neighbours, this would be across the road, which is a common relationship between residential properties and would not result in any unacceptable impact on privacy.

8.471 Both Blocks E and F are proposed to have roof top amenity space and balconies, the final design and layout of the blocks, terraces and balconies is unknown, but the principle of this relationship to neighbours is not considered to be unacceptable since these would be at a high level and a significant distance. Full details of these elements and impacts on privacy would be assessed at reserved matters stage.

Daylight, Sunlight and Overshadowing

8.472 LP policy D6 says design of development should provide sufficient daylight and sunlight to surrounding housing that is appropriate for its context. HLP policy SC4 states that development proposals should demonstrate compliance with prevailing daylighting standards (BRE guidance). The ES assesses the likely impacts of the development on daylight and sunlight on neighbouring properties with the assessment considering the targets from the BRE Guidance, and focuses on the residential buildings surrounding the site which would have the potential to be affected by the proposed development. The assessment of light to neighbouring properties is based on the maximum envelope set by the Parameter Plans.

8.473 The properties most likely to be affected by the proposal in terms of daylight, sunlight and overshadowing at those to the west on Oaklands Avenue and along Syon Lane, and properties to the south of the site on Syon Lane.

Daylight

8.474 For daylight the tests are the Vertical Sky Component test (“VSC”) which assesses daylight to the windows, and the No Sky Line test (“NSL”) which considers daylight distribution within a room. Both the VSC and NSL tests should be used to assess the impact on daylight.

8.475 VSC is assessed at the centre point of the window and looks at the angle of obstruction caused by the proposed development. The maximum value is 40% VSC for a completely unobstructed vertical window. The VSC does not consider window size, room dimensions or the properties of the window itself. The BRE guidance targets a VSC of 27% or more with this providing a good level of daylight. If this is not met, the reduction in light should not exceed 20% of the former VSC light levels. The BRE advises that acceptable levels of daylight can still be achieved if VSC levels are not reduced by more than 20%. If the loss is greater, then the reduction in daylight would be noticeable with rooms likely to become darker, though the closer to the target the less noticeable the impact will be.

8.476 It is acknowledged that the numerical guidelines of the BRE are not mandatory and they can be applied flexibly where justified. The guidance allows for an alternative measurement to be made when an undeveloped site is to be redeveloped, given that often it is unavoidable that reductions will occur which go beyond the 20% threshold that the BRE states will be noticeable. This is relevant given the large expanse of car parking on the existing Site, it was therefore agreed that am alternative VSC target of 20 % could be used as an appropriate alternative target for the proposed development, reflecting the area’s designation for transformation through more intense development indicates with this likely to change the form and character of the area including with some tall buildings as suggested in the GWC Local Plan.

8.477 NSL may be used where room layouts are known to assess where daylight falls within the room at the working plane (850mm above floor level in houses). The BRE says that if the area of the room that receives direct daylight is reduced by more than 20% then the occupants would notice the room being darker.

8.478 The BRE considers that where daylight (or sunlight) fails to meet the guidance, the impact can be classified as ‘minor’, ‘moderate’ or major adverse’ depending on a range of factors. These factors include how many and the proportion of windows in a property that are adversely affected and by how much, and whether the nature of the room affected is one where the need for light is higher. Where the BRE guidance tests are not met, a major adverse impact is likely where:

A large number of windows are affected

The loss of light is substantially outside the guidelines

All windows of a property are affected

The nature of the room affected is one where the need for light is high (e.g. living room), with the guidance stating bedrooms are less important

8.479 The baseline analysis showed that there is a very good level of daylight and sunlight amenity. There are 44 existing residential properties surrounding the site which were considered as sensitive receptors, comprising 228 windows serving 172 rooms, these were assessed in terms of both VSC and NSL.

8.480 In twenty nine of the properties, the proposed development would result in fully BRE compliant VSC and NSL alterations to all of the main windows and rooms within the property. Accordingly, the effect of the proposed development upon the daylight amenity to those properties is considered to be negligible.

8.481 A further eight properties meet the alternate 20% VSC target and meet the NSL criteria, and three properties would meet alternate VSC target and have an alternation in NSL of between 20-30%. These properties would experience a Minor Adverse effect, this is not considered significant and is acceptable.

8.482 Of the remaining four properties (94 Syon Lane, 100 Syon Lane, 128-150 Syon Lane and 45 Oaklands Avenue) each include rooms with greater effects. However, in each case these effects are justified by a limiting factor in the properties themselves, such as the rooms being over 8m deep, or the windows in question being recessed or restricted by overhanging walkways, and as such the effect caused by the proposed development is not considered significant. It is also acknowledged that the tests were carried out against the maximum parameters and therefore a refinement of the massing at detailed design stage could help to improve this.

Sunlight

8.483 The BRE guidance recommends the impact on sunlight to existing main living rooms of neighbouring dwellings should be assessed if they have a window facing within 90° of due south. If the centre of the window receives more than 25% of annual probable sunlight hours (“APSH”), including at least 5% in the winter months (between 21 September and 21 March), then the room should still receive enough sunlight. Any reduction in sunlight access below the existing level should be kept to below 20% and the reduction of the whole year below 4% of the APSH or the sunlight may be adversely affected.

8.484 All 60 southerly orientated neighbouring rooms assessed would be fully compliant with the BRE guidelines recommendations for APSH, this means that the occupants of these rooms are unlikely to notice any alteration to their levels of sunlight amenity.

Overshadowing

8.485 To asses overshadowing of gardens the BRE guidance recommends that at least 50% of neighbouring outdoor amenity areas should receive at least 2 hours of sunlight on 21 March. There are 16 areas of amenity space surrounding the site that are relevant to overshadowing assessment. 15 out of 16 surrounding amenity spaces receive at least 2 hours of sunlight to over 50% of the area as existing.

8.486 Of the 16 existing amenity spaces assessed, 14 would continue to meet the overshadowing test of at least 50% receiving two hours of sun on 21 March, and one, 145 Syon Lane, would retain more than 0.8 times its former value. The rear garden of 141 Syon Lane would drop below the target level, with 38.1% receiving two hours of sun on 21 March, however the 50% target would be exceeded six days later on 27 March, and an additional assessment which considers the duration of Time in Sun has been undertaken. The results of this analysis show that 51.4 % of the space would receive at least 1h 45 mins direct sun on ground on March 21st so the space is just 15 minutes or less short of the level recommended in the BRE guidance. As noted above the tests were carried out against the maximum parameters and therefore a refinement of the massing at detailed design stage could help to improve this situation, furthermore there is a commitment within the Design Code that the massing of Block E must ensure that it does not reduce the light to neighbouring gardens to below 50% receiving two hours sun on the ground on 21 March in line with BRE guidelines. On this basis, whilst the effect on this property is shown to be significant, it would be mitigated through refined massing at detailed design stage.

8.487 This approach is considered acceptable, given the aspiration for higher density development in this location and noting the requirement to optimise the development capacity of the site. Further testing would be required and assessed at reserved matters stage.

Conclusion

8.488 The effects of the development on the daylight to neighbouring properties have been satisfactorily considered, with regard given to the BRE guidance, and the impacts are considered acceptable.

Glare

8.489 The Internal Daylight, Sunlight and Overshadowing Report includes a qualitative assessment of the potential for solar glare and light pollution. On the basis that the building facades will not comprise of large expanses of reflective cladding or glazing and due to the orientation of the development, it is considered unlikely that the proposed development will result in any adverse solar glare effects.

8.490 The use of curtains and blinds will mitigate light spill from residential properties. The retail and commercial uses are located at lower levels and mainly front onto the new public open space and therefore present minimal impact on existing neighbours. The proposed development is not anticipated to produce significant lighting impacts due to the nature of the proposed development. In any case the Design Code sets out guidelines for the incorporation of external lighting within the detailed design, and this would be fully assessed at reserved matters stage.

Wind

8.491 The ES has considered wind microclimate impacts from the development. The assessment is based on the maximum building heights set by the Parameter Plans.

8.492 The baseline assessment found the wind microclimate is relatively calm in and around the Site, with the gardens of th properties on Oaklands Avenue and Syin Lane, backing onto MacFarlane lane having sitting use during the summer season. The sportsfields to the north west have standing use wind conditions representing suitable conditions for their use as public ground level.

8.493 The assessment compares the baseline scenario with that of the proposed development, and concludes the impacts to be acceptable for users of the spaces adjoining the buildings and no harmful impacts on neighbours. The neighbouring gardens would retain sitting use wind conditions and the sportsfields would have standing and sitting wind conditions; therefore the effects of the proposal on neighbours in terms of wind is negligible.

8.494 The wind conditions would not be materially affected in the cumulative development scenario, which includes the development on the Homebase Site, therefore this is considered acceptable.

Noise and other disturbance

8.495 LP Policy D13 and D14 look to ensure new development does not unduly affect existing neighbouring uses, and that potential impacts from noise are addressed in the design. D13 refers to the agent of change which places the responsibility for mitigating impacts from existing noise and other nuisance-generating activities or uses on the proposed new noise-sensitive development. In this case the Site lies adjacent to a

8.496 The proposed development has the potential to increase noise and disturbance to surrounding residential properties given the intensification of activity on the Site. Consideration has been given to the potential impacts within the Noise and Vibration chapter of the Environmental Statement.

8.497 The land to the north and east of the site is allocated as Strategic Industrial Location (SIL), where noisy and nuisance generating uses are to be expected. The Sky campus is located to the North which is a sensitive receptor.

8.498 Demolition and construction activity would be ongoing for a considerable period owing to the scale and phasing of the development. These works would potentially adversely affect living conditions of neighbours owing to disturbances from construction work such as noise, lighting, dust and air pollution, and traffic. Consideration also must be given to cumulative impacts noting there are other large construction sites in the area. The worst case scenario shows that there would be temporary significant noise events at the neighbours to the west and north of the Site, whilst noise is inevitable during the construction of a development of this scale mitigation measures can be put in place to try and minimise these. The works can be programmed to minimise the overlap of noisy activities, ensure quiet plant is selected where possible, that noisy activities are screened and that detailed demolition and

construction method statements would be prepared to minimise impacts to close proximity Noise Sensitive Receptors. It is considered that appropriate management would be required, this would be included within a Construction Logistics Plan and Construction Environment Management Plan based on final detailed design and phasing. This would be secured by condition and fully assessed at reserved matters stage and prior to construction.

8.499 In terms of operation the proposed buildings would be over 30-metres from the Sky Campus and buffered by the Water Gardens, this is acceptable and does not raise any concerns relating to the Agent of Change Principle and the function and continued operation of the SIL.

8.500 The ES concludes that these effects would likely have a negligible effect on the nearest sensitive receptors (i.e. residential properties and Sky Campus), this is agreed by the Council’s Environmental Strategy Officers and suitable conditions are recommended to ensure there would be minimal impact from these sources as a result of the development.

Conclusion

8.501 The design of the scheme has sought to limit impacts on neighbouring properties, adequate privacy and outlook for neighbours would be provided and the effects on the wind microclimate would be satisfactory. There would be some impacts on daylight and sunlight, although this is to a limited number of neighbours with the majority meeting the BRE guidelines and, on balance, the impact is considered acceptable. Effects from noise are potentially significant, but these would be able to be addressed through proper site and operational management.

8.502 Overall impact of the proposals in terms is considered to be broadly acceptable, subject to the mitigation measures proposed being fully incorporated at detailed design stage. On this basis the proposal would not cause any unacceptable impacts.

I. Other Environmental Matters

8.503 Consideration has been given to other wider and on-site environmental conditions and impacts, with these matters addressed in the ES as part of the Environmental Impact Assessment process.

Air quality

8.504 The NPPF says planning decisions should ensure that any new development in Air Quality Management Areas is consistent with the local air quality action plan. The whole borough is designated as an Air Quality Management (“AQMA”) for two pollutants, Nitrogen Dioxide (NO2) and Particulate Matter (PM10). The main sources of these pollutants are road traffic and buildings (gas boiler emissions). Thus, careful consideration needs to be given to granting planning permission for residential accommodation. However, 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.

8.505 LP policy SI1 says development proposals should use design solutions to prevent or minimise increased exposure to existing poor air quality and make provision to address local problems of air quality (particularly within AQMAs) and be at least ‘air quality neutral’. Where development is likely to be used by large numbers of those particularly vulnerable to poor air quality, such as children or older people) should demonstrate design measures have been used to minimise exposure.

8.506 HLP policy EQ4 says the Council will seek to reduce the potential air quality impacts of development and promote improved air quality conditions across the borough, in line with the Air Quality Action Plan by ensuring that development does not exacerbate existing air pollution and wherever possible improves air quality, by promoting development that reduces and limits exposure to emissions through on-site mitigation and is ‘air quality neutral’, and through sustainable design and planning obligations. This will be achieved by assessing air quality impacts, and incorporating mitigation measures where air quality assessments show that development would cause or exacerbate air pollution, or where end users would be exposed to air pollution. More detailed advice and practical measures are detailed in the Council’s Air Quality Supplementary Planning Document (“Air Quality SPD”)

8.507 The air quality implications of the proposed development have been assessed as part of the Environmental Statement.

8.508 The control of dust and construction traffic emissions from a demolition and construction site relies upon good site management and mitigation techniques to reduce emissions of dust and limit dispersion. Mitigation measures recommended in the Mayor of London’s ‘Control of Dust and Emissions during Construction and Demolition SPG’ would be adopted and these and other mitigation measures for both direct impacts and those from traffic, including minimising impacts from HDV traffic and non-road mobile machinery (NRMM) would be detailed within the site's CEMP, this would be secured by condition.

8.509 The ES concludes that the development would meet the buildings and transport emissions benchmark and therefore is considered to be air quality neutral, and confirms that the site is suitable for the proposed residential use without need for any further mitigation. However there is a difference between the LBH modelling used for the Emerging Local Plan and the applicants modelling, and therefore it is considered that diffusion tube monitoring is required prior to occupation to confirm air quality and ensure future residents are not exposed to poor air quality. This can be secured by condition.

Flooding and Drainage

8.510 LP policies SI12 and SI 13 5.12 cover flood risk management and sustainable drainage, with this also considered in the NPPF. HLP policy EQ3 on flood risk and surface water management states that development should ensure that flood risk is reduced by ensuring that developments are located appropriately and incorporate any necessary flood resistance and resilience. The site is located in Flood Zone 1 (lowest risk).

8.511 A new surface water drainage network would be designed and installed to serve the proposed development to ensure that peak rainfall can be accommodated, including

climate change testing. A range of sustainable urban greening (SuDs) measures are shown within the illustrative masterplan and landscape strategy, including public open spaces with open water, rain gardens and swales, tree planting and permeable paving as well as green roofs, with the potential for additional attenuation below ground. This approach accords with the London Plan drainage hierarchy and is supported, given the outline nature of the application the details of the strategy will be finalised as part of the detailed design and assessed at reserved matters stage. This will be secured by condition.

8.512 Thames Water has also requested conditions relating to regarding Foul Water and Surface Water Drainage, which are also recommended.

Contaminated Land

8.513 LP policy SD1says boroughs should take appropriate measures to deal with contamination that may exist. HLP policy EQ8 says 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.

8.514 A geo-environmental assessment report was submitted with the application, this did not identify widespread significant contamination of soils and groundwater. The report recommends further site investigation especially in the areas inaccessible during the ground investigation in 2018 and 2019 including the footprint of the Tesco store, delivery yard, PFS forecourt, and store access roads together with investigation of the presence of buried obstructions. In addition, further ground gas/vapour monitoring, groundwater monitoring and sampling as well as a remediation strategy for unacceptable risk to identified receptors were also recommended in the report. The report and conclusions have been reviewed by the Council’s Land Quality Team who agree with the recommendations and therefore further testing, with remediation as necessary, can be secured through a condition.

8.515 Therefore, subject to mitigation to be secured by conditions, there are no constraints to the principle of the proposed uses on the site with regard to contaminated land.

Noise and Vibration 8.516 Policies D13 and D14 look to ensure new development does not unduly affect

existing neighbouring uses, and that potential impacts from noise are addressed in the design and Local Plan policy EQ5 requires submission of a noise assessment where major schemes or a change to a more noise sensitive use are proposed.

8.517 The agent of change principle and noise issues relating to neighbours is discussed in the section above.

8.518 The ES includes a site suitability assessment in which considers noise levels at proposed external amenity space, as well as noise levels within proposed residential units. This assessment provides minimum façade requirements to be incorporated into the detailed design for glazing and ventilation in order to achieve the required internal noise levels.

8.519 The site suitability assessment includes reference to exploring mitigation options for external amenity space. It is acknowledged that it will not be possible to achieve the outdoor amenity criteria in all areas of the communal outdoor amenity space or private balconies as a result of road and air traffic noise. However, based upon the evidence provided it is not considered unreasonable that a ‘quiet or protected area’ be incorporated into one of the tranquillity areas towards the rear of the development that would achieve 50 dB LAeq.

8.520 Given the outline nature of the scheme, this is considered sufficient for this application however a series of conditions are recommended to ensure that necessary mitigations are included within the detailed design and suitable noise levels are achieved. Internal noise sources and noise transmission between commercial and residential units will also be considered in greater detail at the detailed design stage, conditions are recommended to ensure suitable sound insulation is incorporated.

8.521 Subject to conditions to ensure necessary physical mitigation, noise and vibration effects on occupants would be satisfactory with internal living conditions meeting recommended standards, minimise noise transmission and ensure appropriate external amenity space is provided.

Ecology

8.522 The Site itself has no ecological designations, the Ecology Impact Assessment notes that the trees, shrub and vegetation and parts of the Water Gardens are of site level importance, and there are recordings of birds, bats, hedgehogs, amphibians and invertebrates on or near the site that are considered of site level importance.

8.523 The proposal includes the following:

Retention of a minimum of 24 trees;

Provision of a minimum of 300 trees planted;

Provision of a minimum of 4,000 m2 biodiverse roofs;

Provision of a minimum of 20,000 m2 open space, including the retention and enhancement of the Water Gardens; and

Implementation of a CEMP, a suitably experienced ecologist would input into the final.

Provision of native wildflower grassland areas, to provide a foraging resource for pollinating bees and other insects; and

Delivery of the site wide surface water drainage strategy which has considered the inclusion of Sustainable Urban Drainage (SUDs) elements, improving the water quality, whilst creating biodiversity benefits. New planting will comprise of native species or of those with known importance to wildlife.

8.524 The assessment concludes that there is unlikely to be any significant negative residual effects beyond the Site-level as a result of the proposed development, and with the implementation of the recommended mitigation and enhancement measures including biodiverse roofs, there is potential for significant positive effects.

8.525 The enhancements and mitigation measures are welcomed and supported, these should be delivered as part of the detailed design. The detailed design stage should

also include full details of the biodiverse roofs, location of biodiverse enhancements (i.e. bird boxes, bat boxes, invertebrate logs etc.) and invasive species management. A habitat management plan should also be submitted and contain a programme for monitoring the condition of the habitats and enhancements implemented on site as well as the species increase These can be secured by condition given the outline nature of the application.

8.526 Conditions are also recommended requiring the submission of Urban Greening factor assessment to achieve a target of at least 0.4, and a Biodiversity Net Gain assessment at detailed design stage.

8.527 An arboricultural survey was also submitted with the application. This identified and classified the amenity value of existing trees. A total of 177 individual trees and 13 groups were assessed within the site and directly adjacent to the site boundaries. This includes 6 category ‘A’ trees (High quality), 36 category ‘B’ trees and groups (Moderate quality), 108 category ‘C’ trees and groups (Low quality) and 40 ‘U’ category trees and groups.

8.528 Of these trees, 150 individual trees and 13 groups have been identified for removal to facilitate development including; 2 category ‘A’ trees, 25 category B trees and 1 group, 85 category ‘C’ trees and 10 groups and 38 ‘U’ category trees and 2 groups. Trees assessed as category ‘U’ are considered to be of such condition that they cannot realistically be retained as living trees in context of the current land use for longer than 10 years and would be removed as part of good arboricultural management regardless of development.

8.529 The detailed landscaping proposals would be developed at detailed design stage however the development specification includes a commitment to plant a minimum of 300 trees within the site; this is significant new planting, the full details of which would be assessed as part of the landscaping proposals.

8.530 As such impacts on ecology are likely to be limited, and the development provides an opportunity for replacement planting as well as enhancing the overall bio-diversity and urban greening of the site, which is supported.

Wind

8.531 The ES has considered wind microclimate impacts from the development. The

assessment is based on the maximum building heights set by the Parameter Plans. Buildings and terrain affect the speed and direction of wind flows and the anticipated likely wind conditions resulting from the proposed development is an important consideration in the context of pedestrian comforts and the safe use of the public realm. The main interactions of wind with a building occur in relatively close proximity to a building, particularly when there are neighbouring buildings and built up areas along which the wind can be channelled.

8.532 Given the outline nature of the proposed development, some details such as entrance locations for the proposed buildings are unknown. Wind conditions have therefore been assessed along the facades of each of the blocks in the proposed development and the entire boundary of where potential bus stops could be located.

This usefully eliminates areas whereby entrances or infrastructure would not be appropriate due to wind conditions. On site amenity areas have been assessed against their most desirable wind conditions.

8.533 The assessment compares the baseline scenario with that of the proposed development, and found conditions around the site at ground level would be largely suitable for comfort and safety. All identified on-site and off-site receptors would have wind conditions suitable for their intended use; this includes public open space, pedestrian thoroughfares and crossings on and off the site. All of the podiums would also have suitable wind conditions for their use. Therefore the development would have a negligible effect.

8.534 Entrances for buildings suitable anywhere along the facades with the exception of localised points around Block A (northern most corner, and south-eastern corner) and C. These areas would be avoided for providing entrances in the detailed design, and fully assessed at reserved matters stage.

8.535 The roof level amenity areas would receive conditions windier than for their intended use and some strong winds would be expected to occur. Therefore mitigation would be required to ensure appropriate conditions are achieved, and this would need to be incorporated into the detailed design of the scheme. The wind conditions will need to be tested again as part of the reserved matters with the appropriate mitigation measures.

8.536 The wind conditions would not be materially affected in the cumulative development scenario, which includes development on the Homebase Site.

8.537 Subject to conditions to secure necessary mitigation, it is considered that the site would provide a suitable environment with regards to wind and microclimate.

Conclusion 8.538 The overall impact of the proposals in terms of wind, microclimate, daylight, sunlight

and overshadowing is considered to be broadly acceptable, subject to the necessary mitigation measures proposed being fully incorporated at detailed design stage.

8.539 This is a brownfield site within an established urban area; there are no significant environmental constraints that would preclude re-development of the site although mitigation would be required in relation to noise, wind and air quality to provide a suitable standard of accommodation for future occupants. The environmental impacts of the development are considered broadly acceptable, subject to safeguarding conditions.

J. Planning Balance

8.540 The application should be determined in accordance with the Development Plan, with development that accords with its policies and which constitutes sustainable development to be approved without delay, and that which conflicts with it to be

refused unless other material considerations indicate otherwise.

8.541 Hounslow’s Development Plan is currently comprised of the Hounslow Local Plan

(2015), the West London Waste Plan (2015) and the London Plan (2021). The above assessment has considered the proposal against the policies of the Development Plan, and other material considerations.

8.542 The assessment has shown that there is broad support for the development from many policies, but there are breaches of some policies of the Development Plan, because of the ‘less than substantial’ harm to the significance of a number of designated heritage assets. In particular there is conflict with elements of HLP policy CC4 at (d) and (i) and LP policies D9, HC1 and HC2. However this does not necessarily mean that all these policies as whole are conflicted – in respect of HLP CC4, (l) reflects the NPPF’s balancing exercise (paragraph 196). As set out in HLP CC4 (l) and paragraph 196 of the NPPF, it is necessary to weigh this harm against the public benefits of the proposal and where the public benefits outweigh harm then overall this policy would be met. Additionally, even where there is conflict with individual policies, that does not mean that the Development Plan, taken as a whole is conflicted.

8.543 In respect of the other policies of the Development Plan, the development would optimise the use of the underutilised site, which as a brownfield site within the Great West Corridor Opportunity Area is suitable for intensification. The proposed mixed-used development, bringing a substantial number of new homes, and commercial uses, would help meet the strategic housing need in the borough, including a significant contribution to affordable housing, and will promote and sustain local economic activity and employment. This accords with ‘Good Growth’ policies of the LP, and policies relating to Opportunity Areas, housing delivery and economic activity including LP policies G1-G6, SD2, SD7, E11, H1, H4-H6 and H10, and HLP policies IMP1, SV1, TC3, SC1 and ED4.

8.544 Although tall buildings and high density housing is proposed, the development has accounted for its surrounding context, would create significant new public open space and realm and provide new and improved footpaths and cycleways that promote active travel, and the Design Code enshrines good quality into both built form and landscaping. Overall, on balance, it accords with policies relating to design and housing quality including LP policies D2-D9, and HLP policies CC1-CC3, SC4-SC5, and GB1. The impacts on transport, neighbours and other environmental matters were also satisfactory, taking into account mitigation proposed, complying with LP polices D9, D13, SI1-SI5, SI12-SI13, and T1-T9, and HLP policies SC4 CC2, CC3, EC2, and EQ1 and EQ5.

8.545 However, as noted, the finding of harm to various heritage assets means it is necessary to consider the conflicts with the relevant policies against the other relevant policies and weigh the public benefits of the development against the harm found, so as to determine whether the development complies with the Development Plan as a whole. If there were conflict with the Development Plan overall, then consideration should be given to whether there are material considerations which indicate that the proposal should be determined other than in accordance with the Development Plan.

8.546 In this instance harmful impacts, including cumulative harm, were found to the significance of listed buildings within the vicinity of the Site, and historic landscapes

and assets in the wider district including some designated as having the highest heritage significance being Registered Parks and Gardens (Syon Park and Osterley Park both also conservation areas), and the Kew WHS, which is also a Registered Park and conservation area. These different instances of harm have been considered individually in detail above and are summarised below, and as there are multiple assets the combined effect on heritage must also be put into the planning balance. A number of assets were found to have a low level of harm, with the impact on Syon Park being moderate, with all being determined to be ‘less than substantial’ harm having regard to the NPPF, including cumulative harm.

Gillette building, lamps, kiosk – low level less than substantial harm

Natwest Bank - low level less than substantial harm

Coty Factory – negligible - very low level less than substantial harm

Syon House listed buildings – low to mid-low level less than substantial harm

Syon Park – low end moderate to moderate level less than substantial harm

Osterley Park – mid-low level less than substantial harm

Osterley Park Conservation Area - low level less than substantial harm

Kew Gardens WHS-OUV, Park and CA – very low less than substantial harm

Isleworth Ferry Gate – low-medium less than substantial harm

8.547 Importantly, as set out in paragraph 193 of the NPPF, when considering the impact on the significance of heritage assets, great weight should be given to the asset’s conservation (and the more important the asset, the greater the weight should be) irrespective of whether the harm amounts to ‘less than substantial harm’. Further, where there is a finding of harm to the setting of a listed building, there is a presumption against planning permission being granted with the statutory duty from section 66(1) under the Planning (Listed Buildings and Conservation Areas) Act 1990, requiring that decision makers pay "special regard to the desirability of preserving" listed buildings or their settings. In respect of this statutory duty case law32 confirms that "preserving" means "doing no harm” and33, decision-makers should give "considerable importance and weight" to the desirability of preserving the setting of listed buildings when carrying out the balancing exercise in cases which involve heritage issues.

8.548 Therefore special regard needs to be given to preservation of each of these heritage assets and overall heritage harm, with the paragraph 194 of the NPPF highlighting that any harm or loss to significance should require clear and convincing justification and great weight should be given to the asset’s conservation.

Public Benefits

8.549 Officers consider the application would bring the following public benefits:

32

Barnwell Manor Wind Energy Ltd v East Northamptonshire DC & Others ([2014] EWCA Civ 137) the Court of

Appeal 33

Ibid.

Provision of housing - The delivery of up 1,677 new homes, with a range of sizes.

35% affordable housing by unit on Site – in a mix of intermediate and LAR/SR.

Regeneration – Redevelopment of the site with new buildings and landscaping that optimise the use of the Site with a mix of uses.

Economic activity and employment – Temporary employment activity from construction, permanent employment from commercial uses, and expenditure from construction and new residents.

Public realm and open space – Minimum of 20,000 sqm publically accessible open space, improving permeability, accessibility, safety and appearance of the Site for pedestrians and cyclists and contributing to promoting more active travel.

Ecology – Enhanced biodiversity and ecological value from new landscaping, including planting 300 trees and introducing water features, and use of green brown roofs.

Transport - extensions to the E1 and H28 bus services to improve public transport accessibility, provision of a mobility hub to encourage use of sustainable modes of transport.

8.550 These benefits are considered in more detail below.

(i) Housing

8.551 The proposal includes up to 1,677 new homes, which equates to over 9% of the minimum housing requirement for the Borough over the next ten years (17,820, meaning 1,782 per annum). This is a very significant contribution towards meeting the Borough’s housing target and the objectives of the Opportunity Area. The Opportunity Area designated in to the LP aligns with the aspirations of the GWC Local Plan, and includes provision of 7,500 homes over the plan period. This proposal would deliver 22% of that target.

8.552 The Borough currently has an adequate 5 year supply of deliverable housing sites, and it has a good record of housing delivery, however the increased annual housing target (+116%) from the new LP means that housing delivery in suitable sites as envisaged in the GWC Local Plan and Site Allocations will be very important to ensuring adequate housing is delivered.

8.553 Therefore given the great need for housing, the proposed housing is a public benefit of significant weight, with this helping to meet the strategic housing need and delivery targets of LP H1, HLP SC1 and the NPPF.

(ii) Affordable housing

8.554 The proposal would provide 35% affordable housing, based on the maximum number of homes (1,677) this equates to over 580 new affordable homes and is a very significant contribution to the provision of affordable housing within the Borough. The affordable housing would be delivered with a mix of unit size including four bedroom family homes within the LAR/SR tenure. Given the need for affordable housing and the amount of affordable which would be delivered by this development, this benefit has significant weight. It is noted that under the ‘Fast Track’ approach the applicant is to explore the use of grant funding to potentially increase the level of affordable housing, this is secured within the legal agreement but additional grant cannot be guaranteed, therefore no additional weight has been given to this possibility.

8.555 In respect of affordable housing provision, the strategic opportunity provided by the related redevelopment of the Homebase Site, which facilitates this proposal, is also acknowledged, with this providing 164 homes for London Affordable Rent/Social Rent within the earliest phases of construction frontloading the delivery of need affordable housing. This adds some further weight to this benefit.

(iii) Regeneration

8.556 There is a public benefit from regeneration and the reuse of previously developed land, optimising the use of the site and providing new buildings and significant new open space in the townscape. The Site is within an Opportunity Area in the LP where substantial growth in housing and employment is directed. These same aims are integral to the spatial strategy of the HLP where significant housing growth is envisaged for the Great West Corridor area. It is also noted that the Site is proposed to be allocated for redevelopment in GWC Local Plan and Site Allocations.

8.557 The existing Site does not make a positive contribution to the townscape. Its redevelopment with new high quality buildings, significant new and improved public open space and landscaping with the opportunity to create a vibrant hub is a public benefit. Intensification of the use of the Site, which currently includes a large area of car parking and a large retail unit, with a mixed-use housing led proposal of mix-tenure, is consistent with the strategic objectives to make the most effective use of underutilised land within Opportunity Areas.

8.558 These aspects of the proposal are consistent with paragraph 117 of the NPFF that promotes the effective use of land to meet the need for homes and other uses, while safeguarding and improving the environment and ensuring safe and healthy living conditions, in a way that makes as much use as possible of previously-developed land. Additionally, paragraph 118 of the NPPF says planning decisions should, give substantial weight to the value of using suitable brownfield land for homes and other needs, and support the development of under-utilised land, especially if this would help to meet identified needs for housing where land supply is constrained and available sites could be used more effectively (for example space above shops, and building on or above service yards, car parks, lock-ups and railway infrastructure).

8.559 The weight to this benefit is moderate given there is some residual harm to heritage assets of high significance, and it is acknowledged that whilst the parameter plans and design code are considered robust in securing quality development, the final

design of the buildings, open space and landscaping, as well as the housing quality, can only be fully assessed at reserved matters stage.

(iv) Economic Activity and Employment

8.560 The proposal would generate temporary employment during construction, employment within the non-residential uses, and there would be economic activity and support for employment from the local spending of new residents and associated management/ maintenance of the new homes.

8.561 The proposal would create new permanent employment opportunities within the non-residential uses on the Site, creating between 46-155 new FTE jobs in the worst case scenario, and local residents could benefit from these new opportunities. In addition there would likely be new spending in the locality from these employees. Whilst it is recognised that the number of jobs would be lower than currently exists on Site, however those jobs would not be lost instead they would be relocated to the proposed new Tesco store (on the Homebase Site) which facilitates this development. The commercial uses proposed on the related Homebase Site would provide between 296 and 300 FTE jobs, so cumulatively the two developments will provide up to around 450 FTE jobs.

8.562 In addition to permanent employment, the construction of the development would also create many temporary jobs. It is estimated that over the 10 year construction period, an average of 317 FTE jobs per year would be created directly and indirectly through the construction activity and associated employment from expenditure. If approved, s106 contributions would secure skills training opportunities for local people. Notably paragraph 80 of the NPPF says significant weight should be placed on the need to support economic growth and productivity, taking into account both local business needs and wider opportunities for development.

8.563 Moderate weight should be given to permanent employment at the Site, given the exact number of jobs will not be known for certain until reserved matters stage and overall it represents a reduction on Site from the existing situation, acknowledging these are not lost but relocated and there would be increased economic activity from the substantial number of new residents. For construction employment and activity, this is temporary and should also only be given limited weight, but given the scale of employment and investment into the Great West Corridor and the significant training opportunities this should be given more weight, also noting the current context of severe economic recession. Taken together these public benefits arising from the proposed economic activity and employment are considered to be of moderate weight.

(v) Public Realm and Open Space

8.564 The development includes significant improvements to public realm and the creation of new public open space within the Site and improve and retain public access to the Water Gardens, as well as substantial landscaping throughout the Site, plus associated works to footpaths and cycleways. A minimum of 20,000 sqm publically accessible space would be provided, providing new high quality areas for new and existing residents to enjoy, as well as significantly enhancing the environment for walking and cycling, in line with objectives to encourage more active and sustainable

travel choices. The proposal is satisfies objectives of the GWC Local Plan to transform the corridor with enhanced public realm with a continuous well connected green network that optimises urban greening, and the delivery of new high-quality publicly accessible squares and open spaces. This is an important benefit and is given moderate weight.

(vi) Ecology

8.565 The overall masterplan includes extensive landscaping, with a commitment to plant a minimum of 300 trees, and would significantly enhance the biodiversity and ecological value of the Site through extensive areas of green/ brown roofs, improving the water gardens and providing habitat areas. Overrall this has the potential for significant positive ecological effects, would contribute to health and wellbeing for new and the existing wider community and contribute positively to the greening of the area. This is an important benefit which would serve the wider community, however as the final details of the open space and landscaping can only be fully assessed at reserved matters stage this is given moderate weight.

(vii) Transport

8.566 The proposal includes the provision of a mobility hub, which would provide ancillary infrastructure and facilities for the buses, as well as car club spaces, cycling parking and bus welfare facilities. This contributes to the projected increase in public transport accessibility, as well as encouraging more active and sustainable travel choices, in line with policy objectives. This is a public benefit as it would serve the wider community, not just the residents of the development, although the weight is limited. The development would also provide a substantial contribution to bus improvements which would also benefit those in the wider community; however this is given low weight as it is predominantly mitigation for the impacts of the development.

Conclusion

8.567 There are a range of public benefits that weigh in favour of the development as set out above, with there being significant weight to delivery of a very significant number of new homes and substantial affordable housing, moderate weight to regeneration, economic activity and employment, public realm and open space and ecology.

8.568 The harmful impacts on the significance of each heritage asset from the proposal, including cumulative effects from other development, are given great weight, but in each case, and in respect of the overall planning balance of public benefits weighed against harms from the development, these would be clearly outweighed by the collective public benefits of the development, and so the proposal is acceptable.

Compliance with the Development Plan

8.569 As noted the proposal would result in ‘less than substantial harm’ having regards to the NPPF, to a number of heritage assets in the surrounding area. Consequently there is some conflict with policies relating to conservation of heritage, namely LP HC1 and HC2, though HLP policy CC4 is not conflicted overall because the policy provides for the harm to be weighed against the public benefits.

8.570 However on balance, the conflict with the above policies is significantly outweighed by the degree of compliance of the proposal with the policies of the Development Plan overall and the extent that the public benefits discussed above contribute to achieving the social, economic and environmental objectives of the plan, and so the proposal is considered to comply with the Development Plan as a whole.

9.0 Equalities Duties

9.1 The public sector equality duty applies to all council decisions.

9.2 A public authority or any person who exercises public functions must, in the exercise of those functions, have due regard to the need to:

(a) eliminate discrimination, harassment, victimisation and any other conduct prohibited by or under the Act;

(b) advance equality of opportunity between persons who share a relevant protected characteristic and persons who do not share it;

(c) foster good relations between persons who share a relevant protected characteristic and persons who do not share it.

9.3 Having due regard to the need to advance equality of opportunity, this involves having due regard, in particular, to the need to:

(a) remove or minimise disadvantages suffered by persons who share a relevant protected characteristic that are connected to that characteristic;

(b) take steps to meet the needs of persons who share a relevant protected characteristic that are different from the needs of persons who do not share it;

(c) encourage persons who share a relevant protected characteristic to participate in public life or in any other activity in which participation by such persons is disproportionately low.

9.4 This shall include, in particular, but is not limited to steps to take account of disabled persons' disabilities.

9.5 The exercise of public functions must have due regard to the need to foster good relations between persons who share a relevant protected characteristic and those who do not, in particular, to the need to:

(a) tackle prejudice; and

(b) promote understanding.

9.6 Compliance with these duties may involve treating some persons more favourably than others. This is not to be taken as permitting conduct that would otherwise be prohibited by or under the Act.

9.7 The relevant protected characteristics are: age; disability; gender reassignment; pregnancy and maternity; race; religion or belief; sex; marriage and civil partnership; and sexual orientation.

9.8 Due regard needs to be demonstrated in the decision making process and requires an analysis of the material with the specific statutory considerations in mind. It does

not follow that the considerations raised will be decisive in a particular case the weight given to them will be for the decision maker. The equalities duty is not a duty to achieve a particular result. Some equalities considerations are covered under other legislation such as building control matters. Officers have in considering this application and preparing this report had regard to the public sector equality duty and have concluded that due regard has been given to the Council’s duty in respect of its equalities duties and that if approving or refusing this proposal the Council will be acting in compliance with its duties.

10.0 Planning Obligations

10.1 HLP IMP3 seeks to ensure that development proposals fully mitigate the impacts of the development on the area through a Section 106 Agreement, where necessary or appropriate, having regard to supplementary planning document and provide the CIL payments required by any charging scheduled, including the Mayor of London’s CIL. A payment or other benefit offered in a Section 106 agreement is not material to a decision to grant planning permission and cannot be required unless it complies with the provisions of the Community Infrastructure Levy Regulations 2010 (Regulation 122), which provide that the planning obligation must be:

(a) necessary to make the development acceptable in planning terms;

(b) directly related to the development; and

(c) fairly and reasonably related in scale and kind to the development.

10.2 The Section 106 agreement will not address all the impacts since some of these will be addressed by CIL, in order to satisfy the Regulation 122 tests above.

10.3 The NPPG provides guidance on use of planning obligations, which may impose a restriction or requirement, or provide for payment to make acceptable development proposals that might otherwise not be acceptable in planning terms. The Council’s Supplementary Planning Document on Planning Obligations (adopted March 2008) contains guidance on imposition of planning obligations in compliance with such guidance. These obligations may offset shortfalls in the scheme or mitigate a development’s impacts.

10.4 The following draft Heads of Terms are likely to form the basis of the Section 106 Agreement if the application was to be approved, all of which are considered to satisfy the three Regulation 122 tests referred to above:

(i) 35% Affordable housing – by unit on Site. Tenure split between Intermediate and Affordable Rent to ensure no less than 50% of affordable are provided as LAR/SR cumulatively with Homebase development, with early stage viability review if development has not progressed. 100% nomination right to Local Authority, with controls on delivery through a Registered Provider and restrictions on rental levels/affordability & eligibility criteria. Requirement to explore use of grant to increase affordable and demonstrate proof of efforts. Phasing of affordable housing. There would be an early stage viability review to be undertaken if implementation has not commenced within two years of

opening of the new Tesco Store (on the Homebase Site) of the site, with work to have progressed to an agreed stage.

Size Local Plan intermediate

Proposed intermediate

Local Plan LAR/SR

Proposed LAR/SR

Studio 0% 0%-6% 0% 0%

1 bed 35% 30% - 35% 25% 22 - 26%

2 bed 40% 58 – 64% 45% 41- 45%

3 bed 16% 0-5% 25% 33 - 37%

4 bed 9% 0% - 0% 5% 3 - 5%

(ii) Construction training – A contribution of £2,750 for every £1m construction

costs or an agreed training strategy to assist skills and training of Hounslow residents or an agreed training strategy from the Berkeley Group.

(iii) Retail Restriction - Demolition of the Existing Tesco store cannot commence until trading commences at the replacement store on the Homebase Brentford development.

(iv) Job brokerage – An appropriate training and/or job brokerage programme to enable residents in the Council’s Area to gain the requisite skills to access or aspire to new job opportunities such as those presented by the Development

(v) Sustainable travel – Separate Travel Plans for Residential and commercial uses providing measures to encourage sustainable travel to and from the site to include an action plan, monitoring, review, and updates. Residential travel plan to include voucher for residents (£100 per household) for

i. purchase of an Oyster card; ii. purchase of a rail card or other means of public transport; iii. purchase of a bicycle; iv. membership of a Car Club; or v. other offers available to voucher holders;

(vi) Residents’ parking permits – Restriction that prohibits residents of the new homes from obtaining parking permits for local CPZs.

(vii) Bus Service Improvement – A contribution of £1.7m to Transport for London for improvements to local bus network (this contribution is to cover this site and the Homebase Site)

(viii) CPZ/ Parking Monitoring and Review – To include:

i. Restriction on residents obtaining permits - no access to parking permit except bar blue badge holders

ii. CPZ and parking reviews in the Wyke Estate, Syon Park Gardens and Leigham Drive. Parking surveys to be undertaken pre and post-occupation and if there is an increase in parking then consultation in the Wyke Estate CPZ to amend the hours and if supported amend the Traffic Management Order and signs, consultation on a new CPZ in the streets and if supported implement a new CPZ. Contributions to be calculated at appropriate time.

(ix) Car Club – Provision & retention of a minimum of 10 car club spaces on-site,

and free 3 year membership for each household of the development. The number of car club spaces to be reviewed with the car club operator and increased if demand is there.

(x) Residential Car Park Management Plan – Management plans to control

allocation of parking spaces, access, servicing, electric vehicle charging points, and actively managed disabled spaces. This plan is to conform with best practice and any guidance or other standards or requirements that are in place at the time of the reserved matters applications and in operation from first occupation.

(xi) Public Realm Plan - Identifying publicly accessible land and routes, details of delivery and commitment to maintain public access.

(xii) Commercial and Residential Delivery and Servicing Management Plans – Delivery and servicing management plans which are to ensure that any adverse impacts to the operation of road networks surrounding the Development Land as a result of deliveries to the Development are avoided remedied or mitigated. These plans to conform with best practice and any guidance or other standards or requirements that are in place at the time of the reserved matters applications and in operation from first occupation.

(xiii) Carbon Offset Fund – • submit a detailed energy statement for each phase prior to commencement of the phase • The detailed energy statement will cover:

o An assessment of the carbon emissions reduction against Part L Building Regs 2013 using SAP10 emission factor or later o Demonstrate that it achieves a minimum of 60% on-site emissions reduction measured on a site-wide basis, including achieving 12% reduction at Be Lean stage o Include a detailed roof plan to identify the extent of PV panels o Show that the development has made sufficient provisions to enable the connection to a feasible district heating network in the future, as well as being adaptable to incorporate future technology and designed to cconform with best practice and any guidance, frameworks or other standards or requirements that are in place at the time of the reserved matters applications o Identify the required carbon offset contribution for the phase to achieve zero carbon calculated on a rate of £95 per tonne

• Contribution to the Council’s Carbon offset fund, contribution to be calculated as £95 per tonne x 30 years, payable prior to commencement of the phase

(xiv) Considerate Contractors Scheme – A scheme regulating the manner in which any demolition and construction works are carried out submitted to and approved by the Council prior to any works being carried out.

(xv) Play Space – submission and agreement of an analysis of playspace provision within the reserved matters detailed design, and payment of a contribution in the event there is a shortfall in provision against the target measured in the GLA Population Yield Calculator.

(xvi) Hounslow Clinical Commissioning Group (Health Care) – Contribution towards primary health care facility in Brentford, or provision of a facility on site if it is suitable for their needs.

(xvii) Planning Service (Legal), Travel Plan Monitoring Costs and Obligations Monitoring Costs – As per the Council’s fees and charges.

(xviii) Highways Works – Full details to be secured by a s278 Agreement under the Highways Act with TfL/ Hounslow but to include in principle:

i. Review of Option 4 junction works, if not already constructed, with updated traffic surveys and modelling undertaken after the occupation of the Homebase site, prior to commencement of the Tesco site, construction of a controlled pedestrian cycle crossing on the Syon Lane (southern) arm of the junction if agreed by TfL all prior to occupation of Phase 1

ii. Review of Option 5 and Option 6 junction works with updated traffic surveys and modelling and construction of a pedestrian/cycle crossing on the northern arm of the junction, if agreed by TfL. All prior to occupation.

iii. Access to Tesco Site. Review of access (removal of roundabout) prior to commencement (to form part of the same review as Gillette Corner based on up to date surveys and modelling) & to include provision of replacement traffic calming on Syon Lane if required. Access to prioritise cyclists with the stop line set back behind a cycle crossing. Delivery of access and any traffic calming prior to occupation.

iv. secure delivery of segregated 3m wide cycle lane and 2m footway along Syon Lane

v. improvements to Grant Way to provide a new footway along the northern side of the road, new pedestrian crossing facilities, changes to the northern kerb line, new access(es) to the site for bus use and turning only and changes to existing waiting and loading restrictions to allow loading and bus stop/stands to be provided as required.

vi. Works to Macfarlane Lane to provide a new access to the site (restricted egress only), means to manage restricted access, relocation of kerbs, footway and carriageway.

vii. Active Travel Zone - review of the junction design at the A4 junctions with Syon Park Gardens, Wood Lane, Leigham Drive, St Mary’s Crescent and Thornbury Road is undertaken to improve the safety and priority for pedestrians and cyclists. The review should be undertaken, and the designs submitted with the first reserved matters application and improvements delivered prior to first occupation.

(xvix) Bus stops, stands and welfare facilities.

i Ensure continuous retention of bus stops, stands, welfare facilities & turnaround facility on the site during construction in a location to be agreed with the council and TfL, to be constructed and made available for use to the public prior to removal of the existing facilities and prior to commencement of phase 1

ii Secure permanent relocation of bus stop, stands, welfare facilities & new turnaround facility within and adjacent to the site (Option 1 - drawing to be included in agreement) to be constructed and made available for use prior to occupation unless alternative agreed, review of indicative Option 2 prior to commencement of phase 1 delivery prior to occupation of phase 1 to be constructed and made available for use prior to occupation if agreed by TfL

iii Detailed specification and design for the permanent bus welfare facilities to be agreed with TfL prior to commencement of construction of phase 1 and requirement for the Heads of Terms for the lease of the proposed bus driver facility to be agreed with TfL in advance of the closure of existing facilities

(xix) Car and cycle parking – full detail of car and cycle parking provision is to be submitted with reserved matters applications for each phase and to be conform with best practice and any guidance or other standards or requirements that are in place at the time of the reserved matters applications and to be made available for use from first occupation.

(xx) Mobility Hub - full details of mobility hub to include range of facilities designed to enhance access to local transport options including a cycle hub, delivery lockers, information board/maps, information regarding the site’s Car Club; and a bus driver welfare area to be agreed with LBH and TfL prior to commencement of construction of phase 1 and to be made available for use from first occupation.

(xxi) London Underground – An updated assessment of station capacity and line loading capacity at Osterley Station will be required to accompany the first reserved matters application, in consultation with the Council and TfL, and will need to take into consideration LU demand generated by both the Tesco and Homebase sites. Any identified improvements to be delivered prior to first occupation.

(xxii) LOCAL FINANCE CONSIDERATIONS AND THE COMMUNITY INFRASTRUCTURE LEVY

10.5 Section 70(2) of the Town and Country Planning Act 1990 (as amended) provides that a local planning authority must have regard to a local finance consideration as far as it is material. A local finance consideration means:

a) grant or other financial assistance that has been, or will or could be, provided to a relevant authority by a Minister of the Crown; or

b) sums that a relevant authority has received, or will or could receive, in payment of

Community Infrastructure Levy (CIL).

10.6 The weight to be attached to a local finance consideration remains a matter for the decision maker. The Mayor of London's CIL and Hounslow CIL are therefore material considerations.

10.7 Most new development which creates net additional floor space of 100 square metres or more, or creates a new dwelling, is potentially liable to pay the CIL to Hounslow and the Mayor of London.

Floor space

(sqm)

Existing

lawful floor

space

Demolished

floor space

CIL liable

floor space

11,582 11,582 153,818

10.8 This proposal would be liable to pay the CIL which is index linked.

10.9 This is an outline application and therefore the full CIL will be calculated at reserved matters stage, and would be based on the final floor area.

10.10 The estimated Hounslow CIL payable is £21,216,202.45 and estimated Mayoral CIL payable is £9,312,980.73. The provisional total CIL is estimated at ££30,529,183.18.

11.0 CONCLUSION

11.1 The proposal would comprehensively redevelop the Site, making best use of the land. The scheme would be consistent with the objectives of the Development Plan to focus growth of housing and employment within the Great West Corridor Opportunity Area, especially to optimise use of such sites for housing and in a manner that would promote more active travel.

11.2 The housing is high density with some tall and large scale buildings that would transform the Site. Although considerable change is proposed, the Site sits within the Great West Corridor Opportunity Area and the positioning, scale and massing that has satisfactorily accounted for the surrounding context. The scheme is in outline and the parameter plans and design code are considered robust in securing a high quality development. There are some harmful impacts on heritage assets locally and also from distance, through change to the setting of the assets, including to some assets of the very highest significance. These harmful effects, which in each case cause ‘less than substantial harm’ to the significance of the assets, have been

weighed against the public benefits of the proposal. It is noted that in this balancing exercise that harm to heritage assets must be given considerable importance and weight, and that finding such harm therefore gives rise to a strong presumption against planning permission being granted and this can only be outweighed by material planning considerations powerful enough to do so.

11.3 The development would deliver public benefits to the economic, social and environmental well-being of the area providing a very significant amount of much needed new housing, including 35% affordable housing, and helps to deliver the objectives of the Great West Corridor Opportunity Area in the London Plan, which aligns with the spatial policies of the Hounslow Local Plan. This would also be consistent with the emerging Great West Corridor Local Plan and Site Allocations.

11.4 The development specification, parameter plans and design code would provide suitable controls over the form, layout, uses and quality of accommodation. Planning obligations and conditions would secure various items of mitigation that would ensure other effects of the development are acceptable on the general environment, transport network and neighbours.

11.5 The Environmental Statement and related information submitted with the application has adequately considered the effects on the environment and confirms that there would not be significantly adverse effects from the development, with conditions securing mitigation and monitoring where necessary.

11.6 As such, it is considered that the scheme is an appropriate response to the opportunity of the Site and would bring substantial benefits to the environmental, social and economic well-being of the area, notably those arising from the delivery a very significant level of new housing, including a high proportion of affordable housing, as well as regeneration of the Site, significant landscaping, public open space and enhancement of the public realm including improved conditions for walking and cycling, increased economic activity and ecological enhancements, which would outweigh the harmful impacts identified and so overall the proposal would be in accordance with the objectives and policies of the NPPF, and the Development Plan. Therefore approval is recommended.

12.0 RECOMMENDATION : APPROVE subject to a legal agreement.

1. That planning permission be granted with the following conditions (subject to any minor variation of condition wording) and securing the abovementioned planning obligations by the prior completion of a satisfactory legal agreement or unilateral undertaking made under Section 106 of the Town and Country Planning Act 1990 and of highways agreements under Sections 38 and 278 of the Highways Act 1980 (at the appropriate time) and or other appropriate legislation, the exact terms of which shall be negotiated by appropriate officers within the Housing, Planning and Communities Department on the advice of the Assistant Director Corporate Governance, subject to.

(i) The application being referred to the Mayor of London, in accordance with the Mayor of London Order 2008.

(ii) The application being referred to the Secretary of State, in accordance with retained Circular 02/09 (The Town and Country Planning (Consultation) (England) Direction 2009, noting the outstanding objection from Historic England that considers the development would have an adverse impact on the outstanding universal value, integrity, authenticity and significance of a World Heritage Site or its setting.

2. It is confirmed that the decision has taken into account has the environmental information;

3. A statement being placed on the Statutory Register in accordance with Regulation 30 of the Town and Country Planning (Environmental Impact Assessment) Regulations 2017, which contains the information required by Regulation 29(2) and the main reasons and considerations on which the Planning Committee’s decision was based were those set out in the report and a summary of the results of the consultations undertaken, and information gathered, in respect of the application and how those results have been incorporated or otherwise addressed;

4. The satisfactory legal agreement or unilateral undertaking outlined above shall be completed and planning permission issued by 8 July 2021 or such extended period as may be agreed in writing by appropriate officers within the Housing, Planning and Communities Department or within Legal Services.

5. If the legal agreement or unilateral undertaking is not completed by the date specified above (or any agreed extended period), then the Assistant Director for Planning and Development or Head of Development Management is hereby authorised to refuse planning permission for the reason that the proposal should include planning obligations required to make the development acceptable in planning terms in accordance with Regulation 122 of the Community Infrastructure Levy Regulations 2010, development plan policies and the Planning Obligations SPD, described in this Report.

6. 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 Assistant Director for Planning and Development or Head of Development Management is hereby authorised (in consultation with the Chair of the Planning Committee and upon the advice of the Assistant Director Corporate Governance) to enter into a legal agreement(s) (deed of variation) made under Sections 106 and/or 106A of the Town and Country Planning Act 1990 and or other appropriate legislation.

7. If planning permission is refused following the failure to sign the S106 in time, the Assistant Director for Planning and Development or Head of Development Management (in consultation with the Chair of the Planning Committee) is hereby authorised to approve any further application for planning permission validated within 12 months of the date of refusal of planning permission, provided that it (a) duplicates the planning application, and (b) that there has not been any material change in circumstances in the relevant planning considerations, and (c) that a

satisfactory legal agreement or unilateral undertaking securing the obligations set out in the Report is completed within any specified period of time.

Conditions:

1 Time Limits – reserved matters

The first application for approval of reserved matters shall

be made to the local planning authority before the

expiration of three years from the date of this permission.

All subsequent reserved matters applications shall be

submitted no later than five years from the date of this

permission.

Reason: To comply with the provision of Section 92(2) of

the Town and Country Planning Act 1990.

2 Time Limits – implementation

The development hereby permitted shall be begun before the expiration of two years from that date of approval of the first of the reserved matters to be approved.

The relevant parcel(s) must be begun no later than the expiration of two (2) years from the final approval of the Reserved Matters applications for the relevant parcel (or part therein), or in the case of approval on different dates, the final approval of the last such matter to be approved.

Reason: To comply with the provision of Section 51 of the Planning and Compulsory Purchase Act 2004.

3 Phasing

No development shall take place until a programme of

phasing for the implementation of the whole development

has been agreed in writing by the Local Planning

Authority and takes into account the timescales set out in

Condition 1.

This programme shall include details, where available, of

the timing for the delivery of:

• Hard/soft landscaping

• The public open spaces ( The ‘Clearing’, The Meander

and The Water Garden)

• The public realm relative to each phase

Any amendment to the approved phasing programme

must be first agreed in writing by the Local Planning

Authority.

Reason: To ensure satisfactory comprehensive

development and proper planning of the area.

4 Scheme Parameters - Compliance with the Submitted

Information

The submission of all reserved matters and the

implementation of the development hereby permitted

shall be carried out in accordance with the following

drawings and other documents:

Parameter Plans: 01754-JTP-DR-MP-PP-001 Rev

P5, 01754-JTP-DR-MP-PP-002 Rev P5, 01754-

JTP-DR-MP-PP-003 Rev P5, 01754-JTP-DR-MP-

PP-004 Rev P5, 01754-JTP-DR-MP-PP-005 Rev

P5, 01754-JTP-DR-MP-PP-006 Rev P5, 01754-

JTP-DR-MP-PP-007 Rev P5, 01754-JTP-DR-MP-

PP-008 Rev P5, 01754-JTP-DR-MP-PP-009 Rev

P5, 01754-JTP-DR-MP-PP-0010 Rev P5, 01754-

JTP-DR-MP-PP-011 Rev P5, 01754-JTP-DR-MP-

PP-012 Rev P5,

Other plans: PB9283-RHD-GE-SW-DR-R-0093

rev. P04

Development specification: Development

Specifications Rev 2 as prepared by wsp.

Design Code: Design Code document Osterley

Place (ref. 01754) revised January 2021 prepared

by JTP received on 22 January 2021.

Reason: For the avoidance of doubt, and in the interests

of proper planning and to define the scope of this

permission.

5 Reserved Matters

For each phase (or part therein) of the development, details of the following matters (reserved matters) as relevant to that phase shall be submitted to the Local Planning Authority and no work except for demolition, site clearance and remediation shall start within the relevant phase (or part therein) until the Local Planning Authority has approved all of the reserved matters for that phase:

• Layout (to include details of the areas to be used for

each land use and including car and cycle parking)

• Vehicular and pedestrian access within the site and to the building(s)

• Appearance

• Scale

• (Hard and soft) Landscaping

Thereafter the development hereby approved shall be carried out in accordance with the approved details.

Reason: For the avoidance of doubt and in the interest of proper planning and to comply with the EIA Directive and to ensure that high standards of urban design, landscaping and environmental mitigation are achieved and that a proper record is kept, and in order that the Council may be satisfied as to the details of the development in the interests of the visual amenity of the area and to satisfy the requirements of policies CC1 and CC2 of the adopted Local Plan.

6 Land Use

The maximum permitted floorspace (gross internal area in square meters) for each use granted by this permission shall be:

Residential (Use Class C3) – 146,700sq.m (up to 1,677 residential units and including all ancillary areas but excluding energy centre, plant, refuse, car parking and cycle parking)

Residential (use Class C3 ) – 160,400 sq.m (up to 1,677 residential units and including all ancillary areas)

Flexible commercial floor space (Use Classes E) – 5,000sq.m

Pub/drinking establishment/Mobility Hub (Sui Generis) – 1,000sq.m

Reason: To ensure that the development is carried out in accordance with the approved plans and other submitted details and to ensure that the quantum of floorspace keeps within the parameters assessed pursuant to the Environmental Statement in relation to the development, that the Council may be satisfied as to the details of the development in the interests of the visual amenity of the area and to satisfy the requirements of policies CC1 and CC2 of the adopted Local Plan.

7 Design Codes

All applications for Reserved Matters approval shall be accompanied by a Design Statement which shall explain how the proposal conforms to the requirements of the approved Design Code Document (Ref: Design Code Osterley Place 01754) dated January 2021 prepared by JTP and referred to in Condition 4 above.

Reason: For the avoidance of doubt, to accord with the terms of the application and to provide an appropriate design, appearance, scale and form of development in the interests of the visual amenity and character of the area in accordance with London Plan (2021) policies and adopted HLP policies Cc1, Cc2, CC3 and CC4.

8 Reserved Matters Details

Except for any works relating to demolition, site clearance, remediation, development shall not commence within a phase (or part therein), until details of the following matters have been submitted to and approved in writing by the LPA phase (or part therein):

a) Design Statement, as set out in Condition 6

b) Floor, elevation and section plans;

c) Details of ground floor level shopfronts (where proposed and available at the time of reserved matters submission);

d) Details of the internal space standards, unit-size mix, Wheelchair Standards of residential units;

e) BREEAM Pre-Assessment for Non-residential elements;

f) Daylight and Sunlight Report including shadow plot diagrams;

g) Details of play space, amenity space and landscaping strategy;

h) Details of the works to the public realm and highways, including any traffic calming measures;

i) Planning Statement;

j) Statement of Community Involvement;

k) Affordable Housing Statement;

l) Updated Phasing Strategy (if relevant);

m) Fire Strategy;

n) Whole Life Carbon Assessment

o) Drainage assessment form, strategy, drainage design and maintenance

p) Wind assessment

q) Ecology; enhancements and mitigation measures, urban greening factor 0.4 and Biodiversity net gain calculations

Reason: For the avoidance of doubt and in the interest of proper planning and to comply with the EIA Directive and to ensure that high standards of urban design, landscaping and environmental mitigation are achieved and that a proper record is kept, and in order that the Council may be satisfied as to the details of the development in the interests of the visual amenity of the area and to satisfy the requirements of policies CC1 and CC2 of the adopted Local Plan.

9 Details of Materials

Except for any works relating to demolition, site clearance, remediation, piling and/or substructure, the relevant phase (or part therein) of the development hereby approved shall not commence until details (including sample panels where appropriate) of the materials to be used for the external surfaces for each of the buildings and hard-surfaced areas within the relevant plot (or part therein) shall be submitted to and approved in writing by the Local Planning Authority, and this condition shall apply notwithstanding any indications to these matters which have been given in this application.

The development shall be carried out in accordance with the approved details.

Reason: To ensure that all built development would be of a high-quality design standard and in order that the Council may be satisfied as to the details of the development in the interests of the visual amenity of the area and to satisfy the requirements of policies CC1 and CC2 of the adopted Local Plan.

10 Height Limitation on Buildings and Structures (temporary / permanent)

No building or structure of the development hereby permitted shall exceed 105m Above Ordnance Datum (AOD).

Reason: Development exceeding this height could have the potential to impact the Instrument Flight Procedures (IFP’s) surrounding Heathrow Airport and endanger aircraft movements and the safe operation of the aerodrome.

11 Construction Logistics Plan

No development shall take place, including any works of demolition, until a Construction Logistics Plan has been submitted to, and approved in writing by, the local planning authority. The Plan shall accord with TfL guidance and shall include:

i. a site plan (showing the areas set out below) ii. confirmation that a pre-start record of site conditions on the adjoining public highway will be undertaken with Hounslow Highways and a commitment to repair any damage caused iii. provision for the parking of vehicles of site operatives and visitors iv. provisions for loading, unloading and storage of plant and materials within the site v. details of access to the site, including means to control and manage access and egress of vehicles to and from the site for the duration of construction including phasing arrangements vi. details of vehicle routeing from the site to the wider strategic road network vii. the erection and maintenance of security

hoarding including decorative displays and facilities for public viewing, where appropriate

viii. provision of wheel washing facilities at the site exit and a commitment to sweep adjacent roads when required and at the request of the council ix. a scheme for recycling/disposing of waste resulting from demolition and construction works x. measures to ensure the safety of all users of the public highway especially cyclists and pedestrians in the vicinity of the site and especially at the access xi. commitment to liaise with other contractors in the vicinity of the site to maximise the potential for consolidation and to minimise traffic impacts. xii. avoidance of peak hours for deliveries and details of a booking system to avoid vehicles waiting on the public highway xiii. all necessary traffic orders and other permissions required to allow safe access to the site to be secured and implemented prior to commencement of construction xiv. details of the construction programme and a schedule of traffic movements

xv. the use of operators that are members of TfL’s Freight Operator Recognition Scheme (FORS) xviii. confirmation that all vehicles associated with the works will only park/ stop at permitted locations and within the time periods permitted by existing on-street restrictions.

The approved Plan shall be adhered to throughout the construction period.

Reason. To ensure highway safety is maintained and preserved in accordance with policy EC2 of the Local Plan

12 Construction Environmental Management Plan

No demolition or construction shall take place until a detailed Construction Environment Management Plan (CEMP) has been submitted to and approved in writing by the Local Planning Authority. The CEMP shall provide details of how demolition and construction works are to be undertaken and include:

The identification of stages of works;

Setting of appropriate noise criteria, trigger levels

and how exceedances of those levels will be

responded to by the construction contractor

Detailed calculation of noise and vibration of the

construction phases based upon the latest and

most up to date information

Details of working hours, which unless otherwise

agreed with the Local Planning Authority shall be

limited to 08.00 to 18.00 Monday to Friday and

08.00 to 13.00 on Saturdays);

Procedures for maintaining good public relations

including complaint management, public

consultation and liaison;

Monitoring of construction noise levels affecting the nearest noise sensitive receptors.

Review and implementation of mitigation measures (as appropriate) as defined in BS 5228: Parts 1 and 2: 2009 Noise and Vibration Control on Construction and Open Sites shall be undertaken to ensure noise disturbance from construction works is minimised.

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.

13 Submission of a Construction Management Strategy

Development shall not commence until a construction management strategy (CMS) has been submitted to and approved in writing by the Local Planning Authority covering the application site and any adjoining land which will be used during the construction period. Such a strategy shall include the following matters:

• details of cranes and other tall construction equipment (including the details of obstacle lighting) – Such schemes shall comply with Advice Note 4 ‘Cranes’ (available at http://www.aoa.org.uk/wp-content/uploads/2016/09/Advice-Note-4-Cranes-2016.pdf).

The approved strategy (or any variation approved in writing by the Local Planning Authority) shall be implemented for the duration of the construction period.

Reason: To ensure that construction work and construction equipment on the site and adjoining land does not conflict with Instrument Flight Procedures serving Heathrow Airport and endanger aircraft movements and the safe operation of the aerodrome.

and

To ensure the development does not endanger the safe movement of aircraft or the operation of Heathrow Airport through interference with communication, navigational aids and surveillance equipment.

14 Hours of Work

No demolition or construction work shall take place on the site except between the hours of 8am to 6pm on Mondays to Friday and 9am to 1pm on Saturdays and not at all on Sundays and Public Holidays without the prior written agreement of the Local Planning Authority.

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.

15 Construction Noise Limits

Based upon guidance contained within BS 5228:2009 + A1:2014: Noise, Noise levels from construction works at

nearby existing and proposed residential receptors shall not exceed the following construction noise criteria:

Daytime works will not exceed 75 dB LAeq,T at the worst-affected residential property during the following time periods:

• Monday to Friday (08:00 – 18:00 hours)

• Saturday (08:00 to 13:00 hours)

Works outside of the standard hours will be subject to prior agreement and prior notice will be provided to the London Borough of Hounslow.

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.

16 Bird Hazard Management Plan

Development shall not commence until a Bird Hazard Management Plan has been submitted to and approved in writing by the Local Planning Authority. The submitted plan shall include details of:

- Management of any flat/shallow pitched/green roofs on buildings within the site which may be attractive to nesting, roosting and “loafing” birds. The management plan shall comply with Advice Note 3 ‘Wildlife Hazards’ (available at http://www.aoa.org.uk/wp-content/uploads/2016/09/Advice-Note-3-Wildlife-Hazards-2016.pdf).

The Bird Hazard Management Plan shall be implemented as approved and shall remain in force for the life of the building. No subsequent alterations to the plan are to take place unless first submitted to and approved in writing by the Local Planning Authority.

Reason: It is necessary to manage the flat roofs to minimise its attractiveness to birds which could endanger the safe movement of aircraft and the operation of Heathrow Airport.

Information

The Bird Hazard Management Plan must ensure that flat/shallow pitched roofs be constructed to allow access to all areas by foot using permanent fixed access stairs ladders or similar. The owner/occupier must not allow

gulls, to nest, roost or loaf on the building. Checks must be made weekly or sooner if bird activity dictates, during the breeding season. Outside of the breeding season gull activity must be monitored and the roof checked regularly to ensure that gulls do not utilise the roof. Any gulls found nesting, roosting or loafing must be dispersed by the owner/occupier when detected or when requested by Heathrow Airside Operations staff. In some instances it may be necessary to contact Heathrow Airside Operations staff before bird dispersal takes place. The owner/occupier must remove any nests or eggs found on the roof.

The breeding season for gulls typically runs from March to June. The owner/occupier must obtain the appropriate licences where applicable from Natural England before the removal of nests and eggs.

17 Landscape Management a) Prior to the occupation of the relevant plot (or part therein) of the development hereby approved, a landscape management plan for that plot (or part therein) of the development, including long term design objectives, management responsibilities and maintenance schedules for all landscape areas including all proposed trees, shrubs and hedgerows over a minimum period of 5 years from the implementation of the final planting scheme shall be submitted to and approved in writing by the Local Planning Authority and be implemented as approved from the date of completion of the landscaping scheme for each plot (or part therein). b) Prior to the occupation of the final plot (or part therein) of the development hereby approved, a Comprehensive Site Wide Landscape Management Plan shall be submitted to and approved in writing by the Local Planning Authority. The Comprehensive Site Wide Landscape Management Plan shall be implemented as approved from the date of completion of the landscaping scheme. Reason: In the interests of the proper maintenance of the site and to ensure that the quality of the public realm and satisfactory appearance of the site and the adjacent the area, that the development will be accessible to all and in order that the Local Planning Authority may be satisfied that there will be ecological enhancements and as to the management of minor artefacts and structures, in accordance with Local Plan policies CC1, CC2 and GB7,.

18 Retained Trees Prior to the commencement of development, a scheme for the protection of the retained trees, in accordance with BS5837:2012 shall be submitted to and approved in writing by the Local Planning Authority. The scheme shall include: a) A plan to a scale and level of accuracy appropriate to the proposal that shows the position, crown spread and Root Protection Area of every tree on site in relation to the approved plans and particulars. The positions of all trees to be removed shall be indicated on this plan. b) A schedule of tree works for all the retained trees, specifying pruning and other remedial or preventative work, whether for physiological, hazard abatement, aesthetic or operational reasons. All the tree work shall be carried out in accordance with BS3998:2010 – Tree Work – Recommendations. c) The details and positions (shown on plan at paragraph (a) above) of the Tree Protection Barriers, identified separately where required for different phases of construction work. The Tree Protection Barriers must be erected prior to each phase of construction commencing and remain in place, and undamaged for the duration of that phase. No works shall take place on the next phase until the Tree Protection Barriers are repositioned for that phase. d) The details and positions of any underground service runs shall be shown on the plan required at paragraph (a). The erection of fencing for the protection of any retained tree or hedge shall be carried out in complete accordance with BS5837:2012, before any equipment, machinery, or materials are brought onto the site for the purposes of development or other operations. The fencing shall be retained intact for the full duration of the development until all equipment, materials and surplus materials have been removed from the site. If the fencing is damaged all operations shall cease until it is repaired in accordance with the approved details. Nothing shall be stored or placed in any fenced area in accordance with this condition and the ground levels within those areas shall not be altered, nor shall any excavations be made without the written approval 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 biodiversity and visual amenity area and to accord with policies CC1, CC2 and GB7 of the adopted Local Plan. This condition needs to be pre-commencement because to assess these details at a later stage may prevent achievement of Local Plan requirements.

19 External Lighting Prior to the installation of any external lighting within each phase (or part therein), details to demonstrate that the proposed external lighting scheme will comply with the ‘Guidance Notes for The Reduction of Light Pollution 2011’ shall be submitted to and approved in writing by the LPA. External artificial lighting at the development shall not exceed lux levels of vertical illumination at neighbouring premises that are recommended by the Institution of Lighting Professionals in the ‘Guidance Notes For The Reduction Of Light Pollution 2011’. Lighting should be minimised and glare and sky glow should be prevented by correctly using, locating, aiming and shielding luminaires, in accordance with the Guidance Notes. Reason: In the interests of the living conditions of occupiers of nearby properties and future occupiers of the site, in accordance with HLP policies CC1 and CC2.

20 Wheelchair Units A minimum of 10% of the total dwellings shall be ‘Wheelchair User Dwellings’ built to Building Regulations M4(3) standard shall be provided as identified on the approved plans. All other dwellins shall be designed so that they meet building regulation M4 (2) 'accessible and adaptable dwellings' 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).

21 Housing Waste and Recycling

No part of any phase of the development shall be occupied until a Waste Management Strategy showing full details of the waste and recycling facilities, including management of storage areas, internal collection and collection from the site, for the relevant residential element of the development, has been submitted to the Local Planning Authority for approval in writing.

The waste and recycling facilities shall be provided in accordance with the agreed details prior to occupation of the relevant residential element and 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(s) is occupied in accordance with Local Plan Policies CC1, CC2 and EQ7.

22 Commercial Waste and Recycling

No commercial unit shall be occupied untill full details of the waste and recycling facilities, including management of storage areas, internal collection and collection from the site, for the relevant commercial unit of the development, has been submitted to the Local Planning Authority for approval in writing. The waste and recycling facilities shall be provided in accordance with the agreed details prior to occupation of the relevant commercial unit and such facilities shall remain throughout the lifetime of the development and shall be used for no other purposes.other. No refuse or recycling waste bins shall be stored outside the building. Reason: To ensure that refuse can be properly stored and removed from the site as soon as the building(s) is occupied in accordance with Local Plan Policies CC1, CC2 and EQ7.

23 Water Use Prior to first occupation of each residential block evidence (schedule of fittings and manufacturer's 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 and an internal water use of 105L/person/day or less is achieved. Reason: in order to protect and conserve water supplies and resources in accordance with London Borough of Hounslow Local Plan Policy EQ2.

24 Delivery and Servicing Plan Prior to the occupation of the development, a Delivery

and Servicing Plan (DSP) shall be submitted to and approved in writing by the Local Planning Authority. The delivery and servicing for the development shall be carried out in accordance with the approved details at all times thereafter. Reason: In the interests of road safety, in accordance with Hounslow Local Plan Policy EC2.

25 BREEAM – Design Stage Certificate

Prior to the commencement of above ground works on each phase, a Design stage BREEAM Retail New Construction Shell only Design Stage certificate and summary score sheet (or such equivalent standard that replaces this) must be submitted to and approved in writing by the Local Planning Authority to show that an ‘Excellent’ (minimum score 70%) rating will be achieved. Reason: To ensure that the development makes the fullest contribution to minimising carbon dioxide emissions in accordance with according with LP policies SI2 and HLP policies EQ1 and EQ2.

26 BREEAM – Post Construction Review Certificate

Within six months of occupation of the commercial units, a post-construction stage BREEAM Retail New Construction Shell only Design Stage certificate and summary score sheet (or such equivalent standard that replaces this) must be submitted to and approved in writing by the Local Planning Authority to show that an ‘Excellent’ (minimum score 70%) rating has been achieved. Reason: To ensure that the development makes the fullest contribution to minimising carbon dioxide emissions in accordance with according with LP policies SI2 and HLP policies EQ1 and EQ2.

27 Air Quality Monitoring

Prior to the occupation of the development, diffusion tube monitoring will continue at the locations where diffusion tube monitoring was undertaken in Figure 1: Ramboll Diffusion Tube Monitoring Locations Appendix 8.3 Ramboll Monitoring Study (Osterley Place, Tesco Osterley Site, TW7 5NZ. Volume 1: Environmental Statement Main Report Undertaken by Ramboll UK

Limited, September 2020. Ref: 1620006465 Issue: Final) but with additional monitoring at heights of 4, 6 and 8m, for a minimum of 6 months prior to construction, throughout the duration of construction works and for a minimum of 12 months after completion. If at any time during this monitoring any rolling annual average measurement exceeds 36ug/m3 the monitoring should continue until levels fall below 36ug/m3 for a minimum period of 24 months rolling annual average and provision should be made for filtered mechanical ventilation for facades represented by the monitoring exceeded. The filtered mechanical ventilation should be and installed and maintained at any occupied dwellings throughout the duration of the monitoring. The diffusion tube monitoring will utilise the same methodology as stated within Appendix 8.3 Ramboll Monitoring Study (Osterley Place, Tesco Osterley Site, TW7 5NZ. Volume 1: Environmental Statement Main Report Undertaken by Ramboll UK Limited, September 2020. Ref: 1620006465 Issue: Final).

Reason: To ensure satisfactory living conditions and minimise air pollution in accordance with Local Plan policy EQ4.

28 Fixed plant Noise criteria The cumulative noise from any fixed external plant associated with the scheme should not exceed levels more than 5 dB below representative background (LA90) levels at free field locations representing facades of nearby existing and proposed dwellings. Noise levels should be assessed by measurement or calculation based on the guidance presented within BS4142: 2014+A1:2019 or subsequent versions of this guidance. Reason: To protect the amenities of existing and future residents in accordance with Local Plan policy EQ5.

29 Internal noise criteria Maximum noise levels permitted within the dwellings will not exceed those that are specified in Table 4 of British Standard 8233:2014 [Living Rooms = 35 dB LAeq, 16 hours; Dining room/area = 40 dB LAeq, 16 hours; Bedroom = 35 dB LAeq, 16 hours during day-time (07:00 - 23:00) and Bedroom = 30 dB LAeq, 8 hours during night-time (23:00 - 07:00), night-time (23:00 – 07:00) LAmax noise levels within bedrooms do not exceed 45

dB LAmax more than 10 to 15 times per night. The maximum noise levels described must be achieved during background ventilation rates as defined in Part F of the Building Regulations. Reason: To protect the amenities of residents in accordance with Local Plan policy EQ5.

30 Internal transmission of noise from commercial to residential dwellings Details shall be submitted to the Local Planning Authority for approval prior to the commencement of construction works of the sound insulation of the floor/ ceiling/ walls separating the commercial and communal part(s) of the premises from dwellings. Details shall demonstrate that the sound insulation value DnT,w [and L'nT,w where appropriate] is enhanced by at least 10-15dB above the Building Regulations value and, where necessary, additional mitigation measures are implemented to contain commercial/ communal noise the commercial/communal areas and to achieve the criteria of BS8233:2014 within the dwellings/ noise sensitive premises. Approved details shall be implemented prior to occupation of the development and thereafter be permanently retained. Upon completion, the on-site performance of these elements will be demonstrated during pre-completion acoustic testing. Reason: To protect the amenities of existing and future residents in accordance with Local Plan policy EQ5

31 Sound Insulation from External Noise Sources Prior to the development being occupied, facade sound insulation tests shall be submitted to and approved in writing by the Local Planning Authority. Noise tests shall be carried out taking account of worst-case environmental conditions, such as easterly operations at Heathrow, peak time traffic flows wind speed. Continuous logged data shall be submitted. Reason: To protect the amenities of residents in accordance with Local Plan policy EQ5.

32 Contamination

Before the development hereby permitted commences: a. Details of further intrusive site investigation are required in addition to the phase 1 desk study and phase

2 intrusive investigation previously submitted. These details shall be submitted to, and approved in writing by, the Local Planning Authority. The site shall be investigated by a competent person to identify the extent and nature of contamination. The report should include a tiered risk assessment of the contamination based on the proposed end use of the site. Additional investigation may be required where it is deemed necessary.

b. If required, a scheme for decontamination of the site shall be submitted to the Local Planning Authority, for written approval. The scheme shall account for any comments made by the Local Planning Authority before the development hereby permitted is first occupied. During the course of the development: c. The Local Planning Authority shall be notified immediately if additional contamination is discovered during the course of the development. A competent person shall assess the additional contamination, and shall submit appropriate amendments to the scheme for decontamination in writing to the Local Planning Authority for approval before any work on that aspect of development continues. Before the development is first brought into use: d. The agreed scheme for decontamination referred to in clauses b) and c) above, including amendments, shall be fully implemented and a written validation (closure) report submitted to the Local Planning Authority for approval. Reason: Contamination is known or suspected on the site due to a former land use. The LPA therefore wishes to ensure that the development can be implemented and occupied with adequate regard for public and environmental safety. Supporting notes: a. An initial phase 1 desk study has been submitted with the original application and is considered satisfactory. A phase 2 intrusive investigation has been submitted but it did not fully describe the conditions on the site and further investigation is needed. The further investigation to be submitted will include investigation into outstanding contamination issues to be communicated by the local planning authority and allow the development of a site Conceptual Model (CM), which identifies all potential

pollutant linkages on the site. Risk assessments must adhere to current UK guidance and best practice. b. The scheme for decontamination shall provide details of how each potential pollutant linkage, as identified in the conceptual model, will be made safe. c. In some instances the LPA may require work on site to be ceased whilst the nature of additional contamination is investigated fully. d. The validation report shall revisit the site conceptual model, and provide evidence that each aspect of the decontamination scheme was carried out correctly and successfully. This report shall prove that the development is suitable for its new use. e. We request that site investigation reports or site plans be sent electronically to landquality@hounslow.gov.uk or by post on a cd or dvd wherever possible.

33 Air Quality - Construction Machinery

All Non-Road Mobile Machinery (NRMM) of net power of 37kW and up to and including 560kW used during the course of the demolition, site preparation and construction phases shall comply with the emission standards set out in chapter 7 of the GLA’ Supplementary Planning Guidance “Control of Dust and Emissions During Construction and Demolition” dated July 2014 (SPG), or subsequent guidance. The developer shall keep an up to date list of all NRMM used during the demolition, site preparation and construction phases of the development on the online register at: https://nrmm.london/ The developer shall also demonstrate that proposed development is compliant with Building Emissions Benchmarks (BEBs), specified in GLA’s Sustainable Design and Construction SPG (Apr. 2014). Reason: To minimise air pollution in accordance with Local Plan policy EQ4.

34 Habitat Management and Monitoring Plan

Prior to the commencement of above ground works, a Habitat Management and Monitoring Plan shall be submitted to and approved in writing by the Local Planning Authority. The agreed plan shall be carried out and adhered to thereafter. Reason: To minimise air pollution in accordance with Local Plan policy EQ4.

35 Sustainable sourcing of materials

A. No development above ground level shall take place until details have been submitted to and approved by the Local Planning Authority that demonstrate:

- At least three of the key elements of the building envelope (external walls, windows roof, upper floor slabs, internal walls, floor finishes/coverings) are to achieve a rating of A+ to D in the Building Research Establishment (BRE) The Green Guide of specification.

- At least 50% of timber and timber products are to be sourced from accredited Forest Stewardship Council (FSC) or Programme for the Endorsement of Forestry Certification (PEFC) scheme.

B. The development shall not be occupied until evidence (e.g. photographs and copies of installation contracts) has been submitted to the Local Planning Authority to demonstrate that the development has been carried out in accordance with the approved details under Part A of this condition. The development shall be maintained in accordance with the approved details at all times thereafter.

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.

36 Internal water use Prior to first occupation of any dwelling evidence (schedule of installed fittings and manufactures literature) shall be submitted to and approved in writing by the Local Planning Authority to demonstrate that the development has achieved an internal water use of 105L/person/day or less. 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.

37 Submission of SUDS Details

Development shall not commence until details of the Sustainable Urban Drainage Schemes (SUDS) have been submitted to and approved in writing by the Local Planning Authority. Details must comply with Advice Note 6 ‘Potential Bird Hazards from Sustainable Urban Drainage Schemes (SUDS). The submitted Plan shall include details of:

• Attenuation times

• Profiles & dimensions of water bodies

• Details of marginal planting

No subsequent alterations to the approved SUDS scheme are to take place unless first submitted to and approved in writing by the Local Planning Authority. The scheme shall be implemented as approved.

Reason: To avoid endangering the safe movement of aircraft and the operation of Heathrow Airport through the attraction of Birds and an increase in the bird hazard risk of the application site. For further information please refer to Advice Note 3 ‘Wildlife Hazards’ (available at http://www.aoa.org.uk/wp-content/uploads/2016/09/Advice-Note-3-Wildlife-Hazards-2016.pdf).

38 Secure by Design

The development shall achieve 'Secured by Design' accreditation awarded by the Design-Out Crime Officer from the Metropolitan Police Service on behalf of the Association of Chief Police Officers (ACPO).

No dwelling shall be occupied until accreditation has been achieved and evidence of such accreditation has been submitted to and approved in writing by the Local Planning Authority.

Reason: In pursuance of the Council's duty under section 17 of the Crime and Disorder Act 1998 to consider crime and disorder implications in excising its planning functions; to promote the well-being of the area in pursuance of the Council's powers under section 2 of the Local Government Act 2000 and to ensure the development provides a safe and secure environment in accordance with London Plan Policy D11.

39 Thames Water – Foul Water

No part of the development shall be occupied until confirmation has been provided that either:- 1. All wastewater network upgrades required to accommodate the additional flows from the development have been completed; or 2. A development and infrastructure phasing plan has been agreed with the Local Authority in consultation with Thames Water to allow the development to be occupied. Where a development and infrastructure phasing plan is agreed, no occupation shall take place other than in accordance with the agreed development and infrastructure phasing plan. Reason: Network reinforcement works are likely to be required to accommodate the proposed development. Any reinforcement works identified will be necessary in order to avoid sewage flooding and/or potential pollution incidents. The developer can request information to support the discharge of this condition by visiting the Thames Water website at thameswater.co.uk/preplanning.

40 Thames Water - water network infrastructure No part of the development shall be occupied until confirmation has been provided that either: - all water network upgrades required to accommodate the additional flows to serve the development have been completed; or - a development and infrastructure phasing plan has been agreed with Thames Water to allow development to be occupied. Where a development and infrastructure phasing plan is agreed no occupation shall take place other than in accordance with the agreed housing and infrastructure phasing plan. Reason: The development may lead to no / low water pressure and network reinforcement works are anticipated to be necessary to ensure that sufficient capacity is made available to accommodate additional demand anticipated from the new development” The developer can request information to support the discharge of this condition by visiting the Thames Water website at thameswater.co.uk/preplanning

41 Drainage

Prior to commencement of groundworks (excluding site

investigations and demolition) on any phase, the applicant must submit a final detailed drainage design including drawings and supporting calculations and updated Drainage Assessment Form to the Lead Local Flood Authority for review and approval. A detailed management plan confirming routine maintenance tasks for all drainage components must also be submitted to demonstrate how the drainage system is to be maintained for the lifetime of the development.

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.

42 Drainage Implementation

No building hereby permitted shall be occupied until evidence (photographs and installation contracts) is submitted to demonstrate that the sustainable drainage scheme for the site has been completed in accordance with the submitted details. The sustainable drainage scheme shall be managed and maintained thereafter in accordance with the agreed management and maintenance plan for all of the proposed drainage components. Reason: To comply with the Non-Statutory Technical Standards for Sustainable Drainage Systems, the National Planning Policy Framework (Paragraph 103), the London Plan (Policies 5.12 and 5.13) along with associated guidance to these policies and Hounslow Council’s Local Plan Policy EQ3.

43 Restriction of permitted development rights (Residential conversion)

Notwithstanding the provisions of the Town and Country Planning (General Permitted Development) (England) Order 2015 (or any order revoking or re-enacting that order) no change of use under Part 3 Class M or Class O, Class PA, enlargement of the premises or any additional structures/buildings within the curtilage of the site shall be carried out.

Reason: In the interests of the amenity of the area and order not that the Local Planning Authority is able to exercise control over future development of the site in accordance with CC1, CC2, TC4 and EQ5 of the adopted Local Plan Policies.

44 Restriction of permitted development rights (Residential extensions & outbuildings)

Notwithstanding the provisions of the Town and Country Planning (General Permitted Development) (England) Order 2015 (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 in accordance with Policies CC1, CC2 and SC7 of the adopted Local Plan.

45 Drainage

Prior to commencement of groundworks (excluding site investigations and demolition) in any phase of the development, the applicant must submit a final detailed drainage design including drawings and supporting calculations and updated Drainage Assessment Form to the Lead Local Flood Authority for review and approval. A detailed management plan confirming routine maintenance tasks for all drainage components must also be submitted to demonstrate how the drainage system is to be maintained for the lifetime of the development. 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

46 Drainage Implementation

No building hereby permitted shall be occupied until evidence (photographs and installation contracts) is submitted to demonstrate that the sustainable drainage scheme for the site has been completed in accordance with the submitted details. The sustainable drainage scheme shall be managed and maintained thereafter in

accordance with the agreed management and maintenance plan for all of the proposed drainage components. Reason: To comply with the Non-Statutory Technical Standards for Sustainable Drainage Systems, the National Planning Policy Framework (Paragraph 103), the London Plan (Policies 5.12 and 5.13) along with associated guidance to these policies and Hounslow Council’s Local Plan Policy EQ3.

47 Timing of vegetation clearance (breeding birds).

All removal of trees, hedgerows, shrubs, scrub or tall herbaceous vegetation shall be undertaken between September and February inclusive. If this is not possible then a suitably qualified ecologist shall check the areas concerned immediately prior to the clearance works to ensure that no nesting or nest-building birds are present. If any nesting birds are present then the vegetation shall not be removed until the fledglings have left the nest.

Reason. All wild birds, their nests and young are protected during the nesting period under The Wildlife and Countryside Act 1981 (as amended). In the interests of nature conservation and biodiversity, in accordance with Local Plan Policy GB7.

48 Ecological Management Plan

No development shall take place until an Ecological Management Plan has been submitted to and approved in writing by the Local Planning Authority.

The Ecological Management Plan shall incorporate:

(i) details of measures to protect breeding birds, nests and eggs from mortality/damage, injury and disturbance, including avoidance by timing and/or appropriate supervision;

(ii) details of the ecological clerk of works supervision to be put in place to monitor the clearance of vegetation to ensure no impact on undiscovered or other unexpected faunal encounters;

(iii) an ecological lighting plan;

(iv) details of ecological enhancement and urban greening factor, including how the urban greening factor

is to be delivered and achieved on site;

(v) details of how the enhancement measures will be monitored, managed and maintained, including the long- term design objectives, management responsibilities and maintenance schedules.

(vi) Additional detail on location and type of bird/bat boxes, maintenance and a commitment that any data collected is to be shared with the Council;

(vii) Species surveys within and around the site to demonstrate ecological enhancements

The development shall then be carried out in accordance with the approved details.

Reason: In the interests of Nature Conservation and in accordance with Local Plan policies CC1 and GB7, London Plan policy 5.10.

Informatives:

1) To assist applicants, the London Borough of Hounslow has produced planning policies and written guidance, all of which is available on the Council's website and which has been followed in this instance. The decision was made in a timely manner

2) There are water mains crossing or close to your development. Thames Water do NOT permit the building over or construction within 3m of water mains. If you're planning significant works near our mains (within 3m) we’ll need to check that your development doesn’t reduce capacity, limit repair or maintenance activities during and after construction, or inhibit the services we provide in any other way. The applicant is advised to read our guide working near or diverting our pipes.

https://eur01.safelinks.protection.outlook.com/?url=https%3A%2F%2Fdevelopers.thameswater.co.uk%2FDeveloping-a-large-site%2FPlanning-your-development%2FWorking-near-or-diverting-our-pipes&data=04%7C01%7CKiri.Shuttleworth%40hounslow.gov.uk%7C160235c47d01408cd90f08d8e7960ec8%7C5b62666662464c9bacc7716a5a94bd03%7C0%7C0%7C637513978978998663%7CUnknown%7CTWFpbGZsb3d8eyJWIjoiMC4wLjAwMDAiLCJQIjoiV2luMzIiLCJBTiI6Ik1haWwiLCJXVCI6Mn0%3D%7C1000&sdata=8Ly%2BNalhNk6c4rl6RyUZXJhQYUM1%2BOTNlb7jjJ41jLk%3D&reserved=0

If you are planning on using mains water for construction purposes, it’s important you let Thames Water know before you start using it, to avoid potential fines for improper usage. More information and how to apply can be found online at thameswater.co.uk/buildingwater.

Drawing numbers

Parameter Plans: 01754-JTP-DR-MP-PP-001 Rev P5, 01754-JTP-DR-MP-PP-002 Rev P5,

01754-JTP-DR-MP-PP-003 Rev P5, 01754-JTP-DR-MP-PP-004 Rev P5, 01754-JTP-DR-

MP-PP-005 Rev P5, 01754-JTP-DR-MP-PP-006 Rev P5, 01754-JTP-DR-MP-PP-007 Rev

P5, 01754-JTP-DR-MP-PP-008 Rev P5, 01754-JTP-DR-MP-PP-009 Rev P5, 01754-JTP-

DR-MP-PP-0010 Rev P5, 01754-JTP-DR-MP-PP-011 Rev P5, 01754-JTP-DR-MP-PP-012

Rev P5 received on 22/01/2021.

Other plans: PB9283-RHD-GE-SW-DR-R-0093 rev. P04 received on 22/09/2021.

Development specification: Development Specifications Rev 2 as prepared by wsp received

on 25/03/2021.

Design Code: Design Code document Osterley Place (ref. 01754) revised January 2021 prepared by JTP received on 22 January 202.