References: P/2011/2136 00505/U/P27

Address: Kew Bridge Distribution centre, Lionel Road South

Ward: Brentford

Proposal: Demolition of existing vacant office building (405Sqm GEA), and redevelopment of the site to provide an office building (1210Sqm GEA), including ground floor reception area (309Sqm), and 1st and 2nd floor office accommodation (892Sqm GEA), raised on three supporting legs to a height of 29.5m.

Drawing numbers: TBC

Application received:

3/8/11

For Comment

1.0 SUMMARY

1.1 Planning permission is sought to demolish the existing vacant office building and redevelop the site to provide a new office building (1210Sqm GEA), including ground floor reception area (309Sqm), and two additional floors of office accommodation within a raised structure (892Sqm GEA) based upon three supporting legs to a height of 29.5m.

1.2 The application is submitted to the Committee for comment. If an acceptable scheme can be negotiated, then the proposal will be recommended for approval at the Sustainable Development Committee. If no acceptable scheme can be negotiated, the application will be refused under delegated powers.

2.0 SITE DESCRIPTION

2.1 The site contains an existing two storey office building known as Multimedia House, located at the Kew Bridge Distribution Centre on the corner of Lionel Road South and the Great West Road. The building is currently vacant.

2.2 The site is identified as a Locally Significant Industrial Site (LSIS) within the

Brentford Area Action Plan and Employment Development Plan. 2.3 The industrial estate also currently accommodates the Brompton Cycle

factory, a Magnet trade centre and Mercedes Benz workshop which are positioned to the west of the subject building. The estate is accessed from Lionel Road South but is bound to the north by the Great West Road.

ISLEWORTH AND BRENTFORD AREA COMMITTEE

15th September 2011

Sunny Desai

e-mail: sunny.desai@hounslow.gov.uk

2.4 To the north the immediate area is dominated by highway, with the A4 at the

lower level and the elevated M4 above. Beyond the M4 is a listed gatehouse which marks the entrance to Gunnersbury Park, which along with the surrounding properties to the north, makes up the Gunnersbury Park Conservation Area.

2.5 To the east are a number of large scale commercial buildings fronting either

side of the A4/M4, including the Worley Parsons Building. 2.6 The southern boundary of the industrial estate is constrained by a rail line

serving Kew Bridge station, which is located approximately 500m away from the site entrance.

2.7 The site has Public transport Accessibility Level (PTAL) of 3 Moderate and

is located close to Kew Bridge main line Station and a number of local bus routes.

3.0 HISTORY

3.1 The most relevant are listed below.

3.2 00505/U/P25 Erection of a prefabricated building in car park for use as offices.

Approved 18/7/97

3.3 00505/U/P26 Change of use of part of first floor from office use to mini cab services

Approved 8/7/03

4.0 DETAILS

4.1 The proposal seeks to demolish the existing office building (405m2) on the site and to replace it with a new office building described in the application documents as the ‘Hive’ (the name has evolved during the design process based on the hexagonal cladding pattern proposed and the incorporation of roof top bee hives as part of the sustainability strategy).

4.2 The proposed building would comprise of a total floor area of 1201m2 (309m2 GEA at ground floor and 892m2 GEA).

Design

4.3 The proposed building would have a ground floor base, that would contain a lobby and welcome space and would provide for the landing area of a tripod which would then support two additional storeys of floorspace raised above the elevated M4 (maximum height of 29.5m).

4.4 The Planning Statement notes that ‘the main objective of the development was to create a state of the art building which could create its own demand through its prominent location and striking design. It was concluded in discussion with agents that the most value lay in the upper levels of the building, and that we should not provide more accommodation than was necessary. As the site footprint is relatively small and cannot accommodate much on site parking, an innovative solution was to raise the building on a tripod. This provided the opportunity of opening up the ground level and creating a more welcoming approach to the wider industrial estate’.

4.5 The ground floor area would have a ‘C’ shape footprint wrapping around the tripod base. It would contain a lobby/reception area, the plant area for the site and the access points (lift and staircase) up to the higher levels.

4.6 The roof of the ground floor building would wrap around to meet the ground level with a green roof and green wall design (175m2 coverage of green roof which would be planted with sedum species and a typical green roof sedum mix and 89.8m2 of green wall in elevation).

4.7 A water feature based around the legs of the tripod base with a total area of 79.5m2 will be included in the design at ground floor level and form part of the drainage strategy. The feature will consist of approximately 60m2 of open water and 20m2 of vegetation. The water feature will be capable of sustaining a small population of fish and be of benefit to biodiversity providing habitat for birds and aquatic invertebrates.

4.8 The upper floor structure, which would have a maximum width of 27.5m and a maximum depth of 22m would be supported by a tripod base (with the legs splaying out towards the base of the raised structure) and would extend 17.5m above the elevated M4. It would be positioned on a south east/north west orientation.

4.9 The tripod legs are proposed to be concrete, which will be cast within steel formwork to provide the surface finish. The legs have been designed with a hollow core to provide service-ducting runs. An external staircase and lift shaft would project between the legs of the tripod providing access to the raised office accommodation.

4.10 The structure would be curved in various points creating an irregular shape. The flanks, facing west and east would be narrower and would contain timber louvre panels. The main body of the structure would be finished in aluminium hexagonal cladding panels with the south elevation having an inserted aluminium solar shading panel with glazing behind. A section of glazing would also be inserted into the northern elevation. The structure would contain two floors of office accommodation.

4.11 Several bee hives will be installed at second floor roof level on a specially designed terrace. Typically a bee hive will consist of an internal structure with a densely-packed matrix of hexagonal cells made of beeswax, called a honeycomb.

4.12 The proposal would also include an enclosed terrace within the upper floors which could be used as a break out area by workers and could be accessible to the public at certain times of the year.

4.13 The application has been amended from the pre application scheme, with the key change summarised below:

• reduced height from 43.7m to 29.5m

• Introduction of hexagonal 'bee hive' cladding

• revised reception and entrance

• Opening proportions amended

• Enhanced visual focus North / South

• Enhanced sustainability strategy

Parking and Access

4.14 The vehicle access point to the site would remain as existing with a reconfigured ground floor parking layout.

4.15 The proposal would provide 7 parking spaces at ground floor (a reduction on the existing provision of 4 spaces) which would include one disabled parking space and provision for two of the spaces to be provided with electric vehicle/charging stations.

4.16 A lay-by for delivery/servicing vehicles would also be provided adjacent to the estates access road.

4.17 18 cycle spaces are to be provided.

Supporting Documents

4.18 The application includes the following supporting documents:

• Planning Statement (incorporating sequential assessment) prepared by Planning Perspectives LLP;

• Design and Access Statement produced by Hakes Associates;

• Transport Statement prepared by VCL2;

• BREEAM Pre-Certification Assessment prepared by Environmental

• Perspectives LLP;

• BREEAM Ecology report prepared by Environmental Perspectives LLP;

• Sustainability Statement prepared by Environmental Perspectives LLP;

• Energy Strategy prepared by Environmental Perspectives LLP;

• Daylight Sunlight Report prepared by BVP;

• Structural report prepared by Price and Myers (for info only);

• A view assessment has been submitted;

• ‘Z’ mapping images of the proposal have been submitted.

5.0 CONSULTATIONS

5.1 The application was advertised as a major/significant development. Press notices and site notices were posted. Individual letters were sent to surrounding properties and relevant community groups on the 8th August 2011.

5.2 Three objections were received commenting as follows:

It is much too tall: the surrounding buildings are much lower and it will dominate them

Visual intrusion in two nearby Parks: Carville Hall Park, and Gunnersbury Park

Generate unacceptable traffic levels (where traffic is intolerable already

Will generate pollution (exceeding legal limits in this area).

Kew bridge station needs to be refurbished before any more development takes place. Kew bridge road at the junction of Kew bridge, and further along the road toward Brentford is currently being heavily developed, putting more pressure on the already congested area. Green dragon lane is currently the only parking place for the builders working on these sites. Also, people using Kew Bridge Station park along the road. When Brentford football club are playing at home, supporters also park in Green Dragon Lane creating a very dangerous situation.

Why is another office block going to be built when we already have empty ones in the area, what is the point. Housing would be of much more benefit to the community. Yet another empty office block is an eyesore and open to vandalism

5.3 Transport for London

Have yet to comment

5.4 Highways Agency

Have yet to comment

5.5 Gunnersbury Park Society

Have yet to comment

5.6 The Environment Agency

No objection

5.7 Brentford Community Council (BCC)

Have yet to comment

5.8 The London Borough of Richmond

Have yet to comment

5.9 London Borough of Ealing

Have yet to comment

5.10 Heathrow Airport Limited/ BAA Airports

No objection subject to safeguarding condition.

5.11 Chiswick Police Station

Have yet to comment

5.12 Royal Botanical Gardens Kew

Have yet to comment

5.13 English Heritage

Have yet to comment

5.14 English Nature

Have yet to comment

5.15 The Council’s Land Quality Team have requested a safeguarding condition in respect of contamination.

5.16 Any further representations will be included in an addendum.

6.0 POLICY

NATIONAL AND STRATEGIC PLANNING POLICIES 6.1 The relevant national planning policies are:

• PPS1: Delivering Sustainable Development

• PPS4: Planning for Sustainable Economic Growth

• PPS5: Planning for the Historic Environment

• PPG13: Transport

• PPG19: Outdoor Advertisement Control

• PPS22: Renewable Energy

• PPS23: Planning and Pollution Control

• PPG24: Planning and Noise 6.2 Determining applications for full or outline planning permission When

determining applications for planning permission, the authority is required to have regard to the development plan, so far as is material, and to any other material considerations. In addition, the determination must be made in accordance with the development plan unless material considerations indicate otherwise.

6.3 Determining applications for conservation area consent - In considering

whether to grant planning permission with respect to any buildings or other land in a conservation area, special attention shall be paid to the desirability of preserving or enhancing the character or appearance of the conservation area.

6.4 Determining applications in respect of listed buildings In considering whether to grant planning permission for development which affects a listed building or its setting, the authority shall have special regard to the desirability of preserving the building or its setting or any features of special architectural or historic interest which it possesses.

6.5 The Development Plan - The Development Plan for the Borough comprises the Council's Unitary Development Plan (UDP), Employment Development Plan Document, Brentford Area Action Plan and the London Plan.

6.6 The emerging Core Strategy - On 12 July 2011, the Council's Cabinet approved that the Core Strategy "Preferred Strategy" should go out to consultation. As emerging policy, the Local Planning Authority (LPA) considers that the emerging Core Strategy is capable of being a material consideration. Given that the emerging Core Strategy is still in the consultation stages, the LPA considers that very limited weight can be given to it at this stage.

6.7 The draft National Planning Policy Framework - The draft National Planning Policy Framework (NPPF) was published for consultation on 25 July 2011. The NPPF is a consultation document and, therefore, potentially subject to amendment. Nonetheless, as emerging policy, the Local Planning Authority (LPA) considers that the NPPF is capable of being a material consideration. As the Planning Policy Statements, Guidance notes and Circulars remain in place until cancelled and given that the NPPF is still in the consultation stages, the LPA considers that very limited weight can be given to the NPPF at this stage.

Supplementary Planning Documents Planning Obligations Air Quality These SPDs were adopted on 11/03/08, following public consultation in July and August 2007. The documents form part of the Local Development Framework.

6.8 The Circulars of relevance to this planning application are:

• 11/95: Use of Planning Conditions in Planning Permission

• 05/05: Planning Obligations Relevant policies of the London Plan

6.9 The following London Plan policies are of relevance to the applications:

Chapter 3: London’s People

Policy 3.1 Ensuring equal life changes for all

Policy 3.2 Improving health and addressing health inequalities

Chapter 4: London’s Economy

Policy 4.1 Developing London’s economy

Policy 4.4 Managing industrial land and premises

Policy 4.5 London’s Visitor Infrastructure

Policy 4.12 Improving Opportunities for all

Chapter 5: London’s Response to Climate Change

Policy 5.1 Climate change mitigation

Policy 5.2 Minimising carbon dioxide emissions

Policy 5.3 Sustainable design and construction

Policy 5.6 Decentralised energy in development proposals

Policy 5.7 Renewable energy

Policy 5.8 Innovative energy technologies

Policy 5.9 Overheating and cooling

Policy 5.10 Urban Greening

Policy 5.11 Green roofs and development site environs

Policy 5.12 Flood risk management

Policy 5.13 Sustainable drainage

Policy 5.15 Water use and supplies

Policy 5.21 Contaminated land

Chapter 6: London’s Transport

Policy 6.1 Strategic approach

Policy 6.2 Assessing effects of development on transport capacity

Policy 6.9 Cycling

Policy 6.10

Walking

Policy 6.13 Parking

Chapter 7: London’s Living Places and Spaces

Policy 7.1 Building London’s neighbourhoods and communities

Policy 7.2 An inclusive environment

Policy 7.3 Designing out crime

Policy 7.4 Local character

Policy 7.5 Public realm

Policy 7.6 Architecture

Policy 7.7 Location and design of tall and large buildings

Policy 7.8 Heritage assets and archaeology

Policy 7.13 Safety, security and resilience to emergency

Policy 7.14 Improving air quality

Policy 7.15 Reducing noise and enhancing soundscapes

Chapter 8:Implementation, Monitoring and Review

Policy 8.1 Implementation

Policy 8.2 Planning obligations

Relevant policies of the UDP

6.10 The following UDP policies are of relevance to the applications. These policies have been ‘saved’ by the secretary of state to allow for the preparation of new development plans to replace the entire UDP.

Implementation Policies

IMP.1.1 Integrating patterns of land use and the provision of transport IMP.1.2 The re-use and recycling of urban land and buildings IMP.6.1 Planning Obligations Natural Environment Policies ENV-N.1.5 Protection of Metropolitan Open Land ENV-N.1.6 Metropolitan Open Land: Acceptable Uses ENV-N.1.7 Development near the Metropolitan Open Land Boundary ENV-N.1.16 Historic Parks and Gardens ENV-N.2.2 Sites of Regional/Local Nature Conservation ENV-N.2.9 Green Corridors Built Environment Policies

ENV-B.1.1 New development ENV-B.1.2 High Buildings or Structures Affecting Sensitive Areas ENV-B.1.3 High buildings or structures in areas other than those listed in

ENV-B.1.2 ENV-B.1.4 Advertisements ENV-B.1.5 Environmental improvements ENV-B.1.9 Safety and security ENV-B.2.2 Conservation Areas

ENV-B.2.8 Views and Landmarks Waterways Policies

ENV-W.1.3 Important views and structures in the Thames Policy Area

Environmental Protection Policies

ENV-P.1.1 Environmental sustainability: environmental impact statements and sustainability checklist

ENV-P.1.3 Surface water run off ENV-P.1.4 Waste water management ENV-P.1.5 Noise pollution ENV-P.1.6 Air pollution ENV-P.1.7 Light pollution ENV-P.2.1 Waste management ENV-P.2.4 Recycling facilities in new developments Transport Policies

T.1.2 The movement implications of development T.1.4 Car and cycle parking and servicing facilities for developments T.2.1 Pedestrian access T.2.2 Pedestrian safety and security T.2.3 Strategic and local cycle networks T.2.4 Public transport infrastructure T.2.6 Safety of public transport T.3.1 Improvements sensitive to particular users T.4.2 Oppose overall increases in highway capacity for private

vehicle and seeks reduction in traffic levels T.4.3 Traffic implications of new development T.4.4 Road safety T.5.1 Air quality implications of traffic T.5.2 Reducing traffic nuisance in residential areas T.5.3 Vehicle crossovers and hardstandings

Local Development Scheme

6.11 The Local Development Scheme (LDS) is a project plan for the production of the Borough’s Local Development Framework (LDF)1. To date, the Council has produced the Employment Development Plan Document (EDPD) that was adopted on 25 November 2008.

6.12 The purpose of the Employment Development Plan Document is to plan the future use of land for employment, including industrial and commercial uses in the London Borough of Hounslow. This is achieved through directing new employment development to appropriate locations and the management protection and release of industrial and commercial land and buildings.

6.13 There is significant emphasis on the Brentford area in this document due to the significant market pressure for change in the Brentford area, especially in terms of employment land.

1 It outlines what planning documents the Council is proposing to produce and when.

6.14 The Brentford Area Action Plan (BAAP) sets out a spatial strategy for the continued regenerated of the Brentford area. It sets out a vision for the future of the area. The vision for the Areas Action Plan reflects the vision and objectives of development policies.

Employment Development Plan Document

6.15 Relevant Employment DPD policies are:

E2 Locations for Employment – New employment floorspace with a high employment density and/or which attracts a high number of visits will be directed to sustainable locations, which includes town centers. In consideration of locations for employment, the Council will assess the impacts on the environment, economy, community and transport network and ensure there is no harm on surrounding uses including nature conservation areas.

E3 Local Employment Opportunities – The policy seeks to enhance local employment opportunities fore residents through upskilling the population and retaining business in the Borough.

E4 Diversity in Employment – Diversity will be encouraged through promoting small and medium sized enterprises in growth sectors.

EP1 Location of New Office-Based Employment – proposals for new office floor space will be directed to town centres unless the proposed floorspace is limited in scale. Where the floorspace exceeds the limitations outside town centres it will need to be demonstrated that there are no sites available in the town centres, followed by edge of centre locations, that there is a demonstrated need and that the site is accessible by sustainable modes of transport.

Brentford Area Action Plan

6.16 Relevant BAAP policies are:

BAAP1 Sustainable Development – Developers of all major developments should deliver developments that take account of the wishes of the community, based upon local economic, social, physical and environmental needs and in so doing, strengthen community cohesion and facilitate social inclusion.

BAAP2 Urban Design – High quality redevelopment of all proposal sites will be required in order to enrich existing areas of distinctive local character, rejuvenate those areas that lack a positive identity, and improve the overall quality of Brentford’s urban form.

BAAP4 The Great West Road – The economic, social or environmental contribution that development makes to enhancing the role of the Great West Road as London’s primary ‘gateway’ from the West. All development should be designed to the highest quality, maximizing opportunities offered by the high profile road corridor to ‘showcase’

innovation and sustainable design and construction.

BAAP7 Delivering Sustainable Access – All major developments will need to contribute to the delivery of sustainable access through a package of measures that promote sustainable movement and restrain the use of the car.

6.17 The site is within Character Area 14 (Capital Interchange) within the BAAP Appendix 2. This contains the subject site, B and Q and the light Industrial development surrounding Capital Interchange Way.

Supplementary Planning Guidance

6.18 Accessible London: Achieving an Inclusive Environment (April 2004) (London Plan Supplementary Planning Guidance)

6.19 Sustainable Design and Construction (May 2006) (London Plan Supplementary Planning Guidance)

6.20 Supplementary Planning Guidance UDP (1997) – includes Section 7 – Conservation Areas

6.21 Conservation Area Appraisals (2006)

6.22 Thames Landscape Strategy

6.23 Planning Obligations – March 2008

Other relevant documents

6.24 Green light to clean power: The Mayor’s Energy Strategy (February 2004)

6.25 Cycle Parking Standards, TfL Proposed Guidelines

7.0 PLANNING ISSUES

7.1 The main planning issues to consider are:

1. The principle of development;

2. Design and appearance of the proposal;

3. The impact of the proposal on neighbouring properties;

4. The impact of the proposal on highways, transport and access;

5. Sustainable building principles;

6. Planning obligations.

The principle of development

7.2 Government Policy in the form of PPS1 seeks sustainable economic growth, in an integrated way that delivers high levels of employment whilst achieving sustainable outcomes for communities and the environment. Suitable locations should be available for industrial, commercial and other development.

7.3 PPS4 (Planning for Sustainable Growth) sets out planning policies for economic development. Economic development includes development within the B use classes, public and community uses and main town centre uses. Accordingly, these policies need to be applied to the proposed B1 office floor space as this falls within the definition of economic development.

7.4 Policy EC10 states that all planning applications for economic development should be assessed against whether the proposal has limited carbon dioxide emissions for the lifetime of the development, the accessibility of the proposal, whether the proposal secures a high quality and inclusive design and takes opportunities available for improving the character and quality of the area and the way it functions, the impact on economic and physical regeneration in the area and the impact on local employment.

7.5 Policy BAAP1 (Sustainable Development) seeks to ensure that new development makes the most efficient use of resources such as land and energy; addresses local environmental issues such as poor air quality, noise pollution and flood risk; and contributes to the provision of the social and physical infrastructure required to support the area’s rapidly growing community. Policy BAAP2 (Urban Design) identifies the Great West Road as a key area for improvement setting out how proposals should enhance this ‘gateway’ location and deliver improvements to the quality of the public realm. It also requires proposals to demonstrate how they have realised opportunities for improving the character and quality of their local context.

7.6 Policy BAAP4 (The Great West Road) also seeks to showcase innovation and high quality sustainable design, as well as taking into account the economic, social and environmental contributions made to the sustainable regeneration of the area. Policy BAAP7 (Delivering Sustainable Access) requires new developments to promote sustainable movement and access. The BAAP makes clear the Council’s objective for an exemplar sustainable development in this location.

Impact upon locally significant industrial site

7.7 The proposed development involves the demolition of the existing office building on the site, to be replaced with approximately double the office floorspace, in a new building within this Locally Significant Industrial Site.

7.8 It is noted that the existing office building is vacant. Furthermore the applicant has submitted a supporting report which concludes that the even with significant investment, it is unlikely that a sustainable rent could be achieved and subsequently that it is considered that this is no longer a viable location for a small office building of this type, as apart from the age and condition of the building, it is set within a poor environment, dominated by the elevated M4 and therefore lacks prominence.

7.9 Regarding industrial uses, Policy EP6 of the Employment DPD highlights that LBH will promote, manage and where necessary protect PILs and LSISs, and paragraph 14.8 recognises that these areas play an important role in providing capacity to accommodate future industrial and warehouse capacity.

7.10 EP6 goes on to note that any redevelopment and or a change of use of land and or buildings from industrial, warehousing and related uses in a Preferred Industrial Location or Locally Significant Industrial Site will be acceptable subject to the following criteria:

• the primary function of the PIL or LSIS for industrial uses is not undermined; AND

• there is no significant net loss of industrial capacity.

7.11 The Plan aims to safeguard at least 90% of the industrial warehousing floorspace within each PIL and LSIS for the life of the plan. Evidence would have to be provided to ensure that the proposed development does not harm the primary function of the SIL.

7.12 It is considered that as the proposed development would satisfy the criteria noted in EP6, replacing an existing office use on the site and not result in a loss of industrial capacity thereby not harming the function of the LSIS. Furthermore the proposal would have the potential to create employment opportunities and attract investment into the immediate area and the LSIS.

New office location

7.13 Policy EC14 of PPS4 states that a sequential assessment is required for planning applications for main town centre uses that are not in an existing centre and are not in accordance with an up to date development plan for extensions that exceed 200m2 in area.

7.14 The EDPD within Policy E2 requires proposals for high-trip generating uses or a high employment density to be located within the town centres, to ensure that development outside of town centres is limited and that development is directed to sustainable locations.

7.15 Outside of town centres or Chiswick Businesses Park, Policy EP1 of the Employment DPD is clear that where net additional floorspace exceeding 200sq m or 25% of the existing office floorspace is proposed (which ever is the lower), a sequential test needs to be undertaken.

7.16 The applicant has conducted a sequential assessment which noted that when looking at alterative sites within town centres ‘It is accepted that there are many sites available of this size that would be sequentially preferable. However, none of these sites would be capable of meeting the specific locational requirements of this proposal’. These are set out by the applicant and in the market report as being the need for any development to overcome the constraints of the site such as ‘by raising the office accommodation above the level of the M4 and creating a piece of architecture that demands attention, the building would no longer be subservient to the road, and would increase its profile’. Such a development would therefore be more viable and more attractive to potential users based on the attraction of an iconic office space with future occupiers benefiting from being associated with a striking building in a prominent location, viewed by approximately 100,000 cars per day passing into and out of London on the elevated section of the M4.

7.17 Subsequently the applicant notes that ‘ it is therefore considered appropriate to limit the search to sites along the M4/A4 corridor, known as the Golden Mile, and the assessment concludes that ‘No more sequentially preferable sites have been identified which are available, suitable and viable.

7.18 Officers would note that whilst there are more sequentially preferable sites available this has to be considered in light of the following:

• The proposal replaces an existing, vacant office use

• The increase in floorpsace when taking net lettable area is not a significant increase on the 200m+ threshold (the applicant has noted that this is only 208.8m2 above the figure for the existing office building.

• Regenerative benefits of development

• Employment opportunities would be created.

7.19 Furthermore whilst PPS4 has technically removed the requirement for applicants to demonstrate “need”, when undertaking a sequential test “need” becomes pertinent (especially in these kind of applications where there are sequentially preferable sites). It is important for the applicant to demonstrate that there is a specific need for this type of office, in this specific location.

7.20 The applicant has noted that the need for the development and its specific qualities and attributes that it would provide is demonstrated by the interest received from potential tenants.

7.21 Further discussions between offices and the applicant are on going.

Employment

7.22 The supporting Planning Statement notes that approximately 86 jobs would be created as part of the development.

7.23 Further benefits would be secured as part of any s106 agreement in relation to job brokerage and construction training obligations if approval was forthcoming.

Conclusion

7.24 It is considered that the proposed development would not undermine the function of the Locally Significant Industrial Site, when noting that it replaces an existing vacant B1a use and would result in a significant amount of B2 and B8 use class floor space remaining within the estate. Furthermore the proposal would have the potential to create employment opportunities and attract investment into the immediate area and the LSIS.

7.25 However, the acceptability of the development in principle is subject to the proposal being acceptable in terms of character and appearance and in regards to the impacts on the surrounding conservation areas.

7.26 Additionally further discussion is on going between officers and the applicant to ensure that the amount of office floor space is appropriate in this out of centre location.

Design and Appearance of the proposal

7.27 The proposal involves the demolition of the existing building. In design terms this would not be resisted given that it is in a dilapidated state and has little architectural merit nor does it add to the appearance and character of the area. Notwithstanding the above as a result of its limited scale and the fact that the building is hidden away in the corner of the wider site and is dominated by the elevated section of the M4 it does not represent a visually dominant of overly obtrusive structure.

7.28 PPS1 emphasises design which fails to take opportunities available for improving the character and quality of an area or that is inappropriate in its context should not be accepted. Policy ENV-B.1.1 of the UDP promotes high quality design that enhances the overall environmental quality and townscape. Section 1.0 of the UDP Supplementary Planning Guidance (SPG) states that the design and layout of proposed developments must enable them to be compatible with, and make a positive contribution to the character of that locality. New buildings must relate satisfactorily to adjoining and neighbouring buildings and spaces. The scale, massing, siting, size and height of these buildings should be respected by new development, although this need not exclude original innovative design.

7.29 Policy ENV-B.1.2 (High buildings or structures affecting sensitive areas) of the UDP states that planning permission will normally be refused for the erection of buildings or other structures which significantly exceed the height of their surroundings in or where it would result in significant harm to Metropolitan Open Land, residential areas, Conservation Areas, local parks, sites of nature conservation importance and other open spaces and the setting of listed buildings. Similarly London Plan Policy 7.7 notes that the impact of tall buildings proposed in sensitive locations should be given particular consideration.

7.30 Policy ENV-B.2.2 (Conservation Areas) states that the Council will preserve and enhance the character or appearance of existing conservation areas by ensuring that development affecting the conservation area preserves and enhances the character and appearance of the conservation area, any development should respect the character of the existing architecture in scale, design and materials.

7.31 Gunnersbury Park and the Kensington Cemetery are designated as Metropolitan Open Land (MOL) within the Unitary Development Plan. Policy ENV-N.1.5 (Protection of MOL) recognises Gunnersbury Park as being an MOL and states that the main features of this area are an historic house with large formal gardens and lakes, extensive areas of recreational open space, a museum and cemetery. Policy ENV-N.1.7 (Development Near the MOL Boundary) states that any development proposal in areas near the MOL boundary and conspicuous from within it must be designed so that it does not detract from the open aspect or visual amenities of the MOL. Particular attention needs to be paid to building, siting, materials, height, design and landscaping sympathetic to MOL. Policy ENV-N.1.16 (Historic Parks and Gardens) states that development will not normally be permitted which would adversely affect the site, setting or views to and form historic parks and gardens. Gunnersbury Park is identified as a Historic Park and Garden.

7.32 Policy HE7 of PPS5 requires local planning authorities to take into account the particular nature of the significance of the heritage asset and the value that it holds for this and future generations. The desirability of new development making a positive contribution to the character and local distinctiveness of the historic environment should be taken into account.

7.33 Policy HE10 of PPS5 provides additional policy for applications that may affect the setting of a designated heritage asset. This states that local planning authorities should treat favourably applications that preserve those elements of the setting that make a positive contribution to or better reveal the significance of a heritage asset. Any harm should be weighed against the wider benefits of the application.

7.34 The BAAP describes the existing character area that the site sits in as follows: 10. Great West Road/Carville Hall Characterised by standard low-rise warehousing units set amongst areas of parkland, this area is severed by the elevated M4 and its access ramps. The elevated roadway as the tallest feature dominates the appearance of the area, creating a strong feeling of enclosure, and splitting the area visually and physically in two. The two areas of parkland are largely hidden from roadside views, and underutilised as landscape features and recreational assets as well as being affected by noise and pollution.

7.35 BAAP2 (Urban Design) notes that High quality redevelopment of all proposal sites will be required in order to enrich existing areas of distinctive local character, rejuvenate those areas that lack a positive identity, and improve the overall quality of Brentford's urban form. It goes on to note that all development proposals are required to demonstrate how the design complements existing areas of high quality and or how they have realised the opportunities available for improving the character and quality of their local context.

7.36 A full assessment of the proposal, including a view assessment from sensitive receptors and the impacts on the character and appearance of the environment, including the setting of the surrounding heritage assets, Metropolitan Open Land and residential areas is currently being carried out. This will evaluate the proposed development in the context of the relevant policies, and the relevant planning policy statements.

Figure 1: Image from north east looking west along Great West Road

7.37 In respect of the proposed development the Design and Access Statement notes that in respect of the design brief ‘the landowners have obtained agency advice that indicates that in order to create lettable office floor space on this site, and in this location, it is necessary to create a state of the art office space that creates its own demand. The main objective of the client’s brief has therefore been to create a new building that is distinctive, iconic and transcends its location in order to assist in the attraction of a blue-chip client of international stature’.

7.38 The design and height of the building has been altered following pre application discussions (Figure 2 below :

7.39 Officers will be considering how the structure would be read from sensitive views and how it would fit into its immediate context along the Great West Road and in relation to aforementioned BAAP Character area.

Figure 3: view assessment from northern section of Gunnersbury Park

7.40 The Design and Access Statement notes ‘that the ground floor has been completely re-designed to include green / sedum roof, new raised planters and an inclined green façade which addresses the M4. The ground floor has been designed to ‘cradle’ the sculptural support legs rather than be penetrated by them. This arrangement aids the building’s legibility as it is more visually connected to the ground than the previous (pre application) proposal’

7.41 The improvements at grade level to the public realm are welcomed, as would any increase in tree planting and the green roof and green wall

design now proposed for the ground floor structure. Subsequently the development is likely to significantly enhance the appearance of the entrance to the estate at grade level.

7.42 Members’ comments on the proposed design are sought.

Impacts on neighbour’s living conditions

7.43 The UDP Policy ENV-B.1.1 (New Development) states that new development should ensure adequate daylight and sunlight reaches properties and minimise any detrimental impact on adjoining properties and comply with ENV-P.1.7 (Light Pollution). Policy ENV-P.1.7 states that when considering applications Council will take account of the effect on the character and amenity of the surrounding area, including the effect of the lighting on residents when lit in terms of sky glow, glare and light trespass.

7.44 There are no residents in the immediate surrounds, as the site is located within a commercial area within an industrial site. The exception to this would be 2 West Lodge (the gatehouse within Gunnersbury Park), which is positioned to the north of the site beyond the A4/M4.

7.45 The supporting Daylight/Sunlight report has assessed the impact of the proposed development upon this property. This concludes that as a result of the separating distance and the elevated M4 that no harmful impact would result.

7.46 Furthermore as a result of the M4 and the separating distance it is not considered that the development would result in an unacceptable sense of enclosure or a loss of outlook for residents at 2 West Lodge.

7.47 Therefore it is not considered that the proposed development would harm neighbours’ living conditions.

Highways, Access and Parking

7.48 Planning Policy Guidance Note 13 (PPG 13) promotes use of sustainable modes of travel and to discourage use of private cars to reduce traffic congestion and pollution. New development should include the minimum amount of parking necessary to encourage use of public transport as well as walking and cycling.

Trip Generation

7.49 The Transport Assessment provides trip generation information and a comparison between the existing situation and the proposed development.

7.50 This notes that the proposed development will generate a total of 27.4 and 26.1 additional total trips (arrivals and departures combined) for the AM and PM peaks respectively when compared to the current vacant use, and 18.3 and 17.4 additional total trips when compared to the former use for the AM and PM peaks respectively.

7.51 It is considered that the trips generated by the proposed development would not harm local highway conditions.

Access

7.52 The access to the site would remain as existing and is considered acceptable.

Parking

7.53 All developments must provide parking and servicing facilities in accordance with the Council’s standards under UDP Policy T.1.4 (Car and cycle parking and servicing facilities for developments) and Appendix 3 (Parking standards). The standards are considered to be the maximum desirable provision. UDP policies seek to reduce the need to travel, reduce reliance on the private car and promote the use of sustainable modes.

7.54 The UDP notes that off-street car parking requirement for office use is 1 space / 200sqm. The floor space for the proposed building measures 1210sqm. The car-parking requirement for this development would therefore be 6 spaces. Provision has been made for 7 car parking spaces, including one disable space, which is considered acceptable.

7.55 A dedicated servicing area has been provided on the northern side of the internal road just to the east of the side entrance to the building. The provision is intended to cater for a transit type vehicle at 7.5m in length (plus entry and exit tapers) and approximately 2m in width, and in operational terms it will prevent larger vehicles from having to reverse out of the front car park onto the internal road.

7.56 The Council’s Head of traffic and parking has confirmed that the parking layout is satisfactory in terms of manoeuvring into and out of the parking spaces.

7.57 The new London Plan parking standards require 20% active and 20% passive spaces for electric vehicle charging and this is being achieved with two spaces being provided with electric charging points.

Cycle parking

7.58 The proposal's cycle parking for staff has been positioned at ground level and close to the rear entrance within the building. For visitors it has been located to the front of the building adjacent to the southernmost car parking space.

Free and safe flow of vehicles

7.59 The site adjoins the elevated M4 motorway and the proposal will be assessed against the potential impact upon the free and safe flow of vehicles. The concern being that the proposed structure, as a result of its nature, scale and design could create a distraction to drivers. It should be noted that advert towers within Kew Bridge Distribution Centre have been dismissed on appeal on the grounds of public safety and the impact upon the elevated M4 (Ref APP/F5540IAl07/1201754).

7.60 Whilst the Highways Agency have yet to comment it should be noted that the application is for a structure rather than an advertisement with moving animation and that large buildings including car showcase developments have been found to be acceptable along the M4.

7.61 Officers are also seeking to allay fears that any internal digital/LED display with a rapidly changing sequence of advertisements is incorporated into the structure, the concern being as noted above that a frequently changing display could distract the attention of drivers at this busy intersection where concentration is required, could result in restrictive conditions being imposed on any approval.

Servicing

7.62 It is not considered that the proposed office development would require significant servicing and a dedicated serving bay has been provided which is accessed from the internal access road through the estate and is considered acceptable for the proposed use. A Delivery and Servicing Plan, a Construction Logistics Plan and a Travel Plan can be secured by way of condition or through a section 106 agreement if the application were to be granted.

Sustainability and Environmental Impacts

7.63 The broad aim of sustainable development is to ensure that the quality of social, economic and ecological environments are improved and maintained for future generations. The UDP and London Plan encourage sustainable development through many policies including the promotion of 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.

7.64 PPS 24: Renewable Energy sets out the government’s objectives regarding renewable energy and informs policy preparation and assessment of individual planning applications. A key principle is that the provision of renewable energy should be promoted.

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

7.66 The supporting Energy Statement notes that ‘of the technologies that can be practically applied at the development, air source heat pumps are considered to be most appropriate taking into account of technical and spatial constraints, as they can provide the carbon dioxide savings of approximately 10.5% compared to an energy efficient building, and are considered to be most cost-effective’.

7.67 Furthermore to minimise excessive solar heat gains, as well as demand for increased ventilation rates or cooling loads, the proposed development will also incorporate brise-soleil louvers, which is estimated to reduce solar heat gain by up to 50-85%. In particular, the use of these louvers is considered to provide a complementary strategy to air conditioning and mechanical ventilation by resulting in general energy savings and reduced CO2 emissions.

7.68 Overall through the incorporation of the principles of the Energy Hierarchy, a combination of energy efficiency measures and air source heat pumps will result in a total 14.5% reduction in total site CO2 emissions against the baseline scenario.

7.69 The development will also incorporate a range of sustainability features, including a new landscaping scheme to improve upon the biodiversity of the site, water efficiency and a Sustainable Urban Drainage Strategy.

7.70 The Design and Access statement notes that ‘during the design process we considered how the roof of the upper levels could be used for a number of urban bee hives. According to a recent review in the Guardian "Last year more than 30% of honeybees died from disease...which is not sustainable. It is estimated the honeybee, through pollination and honey, contributes £150m annually to the economy". The provision of the bee hives on the roof will make a valuable contribution towards the urban bee population. This also presented the opportunity to link the name of the scheme with 'Hive' as the cladding design was already moving in a hexagonal graphic direction’.

7.71 In respect of ecology the accompanying ecological BREEM assessment notes that the site has little ecological value currently and that the proposed development could enhance the site.

7.72 The Council’s sustainability officer has requested some further information to ensure that the building is sustainable as possible.

Air Quality

7.73 PPS23: Planning and Pollution Control states that air quality relating to land use and development is capable of being a material planning consideration. The whole borough has been declared an Air Quality Management Area (AQMA) as monitoring and modelling indicates that the national objectives for air quality are not likely to be met at present. However, whilst designation of the AQMA indicates a certain level of air quality, this in itself does not prevent development. New development should not result in an increase in airborne pollutants without mitigation. Policy ENV-P.1.6 of the UDP states that air quality will be considered when assessing development proposals and that an Air Quality Assessment will be required for potentially polluting developments, including those that will significantly increase the number of vehicle trips.

7.74 The trip generation figures do not suggest significant increases in trips to the site and therefore it is not likely to result in a development that is unacceptable in air quality terms. A limitation of available parking and the introduction of a travel plan would also further limit trips to the site.

7.75 In respect of the proposed office accommodation as a result of its location it is considered that the internal environment would be required to mitigate against the effects of the surrounding poor air quality environment. The building will therefore need to be mechanically ventilated to serve the occupied area (would be secured by condition on any approval). The Planning Statement notes that the air quality strategy will be designed in line with the targeted BREEAM credit for indoor air quality by minimising the recirculation of exhaust air.

Noise

7.76 Planning Policy Guidance Note 24 outlines the considerations to be taken into account in determining planning application both for noise-sensitive developments and for those activities that generate noise. UDP Policy ENV-B.1.5 states that the Council will not allow development that could result in unacceptable noise nuisance to nearby or future occupiers.

7.77 Due to the location of the site, at the intersection of a number of major roadways, the site has a very high noise environment and it is noted that future residential development is unlikely to be suitable at this site.

7.78 In terms of the internal noise conditions the proposal notes that the commercial office space must achieve an internal noise environment of between 40 and 50 dB LAeq, in line with British Standards and Building Regulations Part E (secured by condition on any approval).

7.79 As noted above there are no residential units in the immediate surroundings and that the proposed plant will be located on the ground floor away from the rest of the offices and therefore there would be no noise pollution issues as a result of the development.

The potential of the proposed development to secure planning obligations

7.80 UDP policy IMP6.1 states that the Council will seek to ensure that a developer enters into a planning obligation to secure planning benefits related to the proposed development. A payment or other benefit offered pursuant to 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.

7.81 Accordingly, it is mandatory that each criterion be satisfactorily addressed prior to granting planning permission subject to a section 106 agreement.

7.82 Government Circular 05/2005 provides guidance on the use of planning obligations, which may impose a restriction or requirement, or provide for payment of money from the developer to make acceptable development proposals that might otherwise be unacceptable in planning terms. The Council’s Supplementary Planning Document on Planning Obligations (which was adopted in March 2008) contains guidance on the imposition of planning obligations in compliance with Circular 05/2005. These obligations may offset shortfalls in the scheme or mitigate the impacts of the development.

7.83 If approval was to be considered, the items listed below, may be included in a s106 agreement. At the time of writing detailed discussions had not taken place with the applicant in respect of the above contributions. However, pre-application discussions outlined the following heads of terms.

(i) Townscape/public realm -Financial contribution towards additional planting in surrounding areas

(ii) Green Travel Plan - Preparation and implementation of a plan to reduce the number of car trips made by employees or other users of the development.

(iii) Construction Training -Participation in a programme to provide employment training places during construction for local people.

(iv) Job Brokerage and Skills Training- Payment of a financial contribution to facilitate job brokerage and skills training to develop the career path and skills of local people.

(v) Public Transport - Payment of a financial contribution to enhance local public transport services.

(vi) Air Quality Monitoring - Payment of a financial contribution for air quality monitoring projects.

(Vii) Public Access – To roof terrace at certain times of the year i.e. Open House initiative.

8.0 Equalities Duties Implications

The Council has to give due regard to its Equalities Duties and in particular with respect to its duties arising pursuant to the Equality Act 2010, section 149. Following a relevance test, which is available at: http://www.hounslow.gov.uk/index/council_and_democracy/equality/eia s/environment_eias.htm it is considered that there will be no specific implications with regard 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.

Relevant Section of Relevance Test

Office/R & D/ Light Industry

RECOMMENDATION 9.1 It is recommended that Members comment on the application and that

Members’ comments be reported to Sustainable Development Committee if an acceptable scheme can be negotiated. If no acceptable scheme can be negotiated, the application will be refused under delegated powers.

Background Papers:

The contents of planning file ref. 00505/U/P27 save for exempt or confidential information as defined in the Local Government Act 1972, Sch. 12A Parts 1 and 2.

This report is relevant to the following wards/areas: Brentford