References: P/2008/1921

P/2008/1922

00657/P/P13

00657/P/CA1

Address: Land at Kew Bridge, Kew Bridge Road, Brentford

Ward: Brentford

Proposal: (Application for Conservation Area Consent)

Demolition of Wagon & Horses Public House, boundary walls and associated structure walls and removal of 6 trees to enable the proposed mixed use development comprising:

(Planning Application)

164 residential units, ancillary fitness suite and business centre, retail (Class A1 use), café/restaurant (Class A3 use) office (Class B1 use) and Public House (Class A4 use) together with access, public and private open space, basement car and cycle parking provision, public convenience, provision of a pontoon and use of arches 4 & 5 under Kew Bridge for boat club (Class D2 Use) (Amended application)

Plan Nos: SG.KBR 001C,102B, 103B, 002D, 003E, 004E, 005E, 006D, 007D, 008D, 009D, 010D, 012C, 120, 150, 170, 171, 180B, 181B, 201C, 202C, 203C, 204C, 205C,206A, 207A, 210B, 211B, 301C, 302C, 303C, 304C, 311C, 312C, 313C, 314C,401C, 402B, 403C, 404C, 405B, 406D, 411C, 412B, 413C, 414C, 415B, 416D, and landscape drawings: D0029-004B, 005B, 007A, 008B, 009B, 010B, 012B,013C, 019B, 020N, 022D, 023D, 024B & 024-100Btogether with Environmental Statement, Sustainability Statement, Planning Statement, Design & Access Statement, Flood Risk Assessment, Energy assessment, Transport Assessment and Statement of Community Involvement.

CHISWICK AREA COMMITTEE (PLANNING)

11th May 2009

ISLEWORTH AND BRENTFORD AREA COMMITTEE (PLANNING)

14th May 2009 George Murphy: Tel 020 8583 4968

e-mail: george.murphy@hounslow.gov.uk

Agenda Item 8

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Date received: 19th June 2008 (Amended 10th March 2009)

Application for Listed Building Consent received 16th March 2009 for upgrade of walkway under Kew Bridge.

The applications are being submitted to Chiswick Area Committee and Isleworth & Brentford Area Planning Committee for comment. If an acceptable scheme can be negotiated, then the proposal can be recommended for approval at Sustainable Development Committee. If no acceptable scheme can be negotiated, then the application can be refused under delegated powers.

Amended Scheme view from Chiswick

Amended Scheme view from Brentford

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1.0 SUMMARY

1.1 This report deals with a planning application accompanied by an Environmental Statement and an application for Conservation Area Consent in respect of a proposed development of a site adjacent to Kew Bridge, which is within the Kew Bridge Conservation Area. The proposals are substantially different to the scheme that was refused in March 2005 and a subsequently dismissed on appeal by the Secretary of State on 9th March 2006.

1.2 Conservation Area Consent is sought for demolition of the Wagon and Horses Public House, boundary walls and associated structure walls and the removal of six trees.

1.3 Listed Building Consent is sought for alterations within arch No 6 to provide an improved, ramped walkway incorporating wheelchair access along the towpath.

1.4 The proposed development would provide:

• Basement parking and servicing area including 155 car-parking spaces and 170 secure cycle parking spaces.

• Ground floor commercial units: retail, food & drink and offices (Class A1/A3 and B1) 1,645 sq m.

• Two storey Public House and cellar (Class A4) 511 sq m.

• Boat Club and Kayak Club (Class D2) 206sq m within arches 4 & 5 of Kew Bridge together with a pontoon.

• 164 residential units (none affordable).

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• Ground floor residents’ fitness suite.

• First floor residents’ business centre

• Public and Private Open Space

• Public convenience

1.5 The application is accompanied by an Environmental Statement, which is comprehensive in its range of topics.

2.0 SITE DESCRIPTION

2.1 The site occupies an area of land some 0.968 hectares in extent and lies on the north-west side of Kew Bridge at the junction of Kew Bridge and Kew Bridge Road. The site comprises vacant land that was formerly occupied by Kew Bridge House (an office building, which was demolished in the late 1980’s) and the Plough Public House, demolished more recently. The application site also includes the Waggon and Horses Public House, which is still operational. There is a bus stand, which occupies much of the public highway along the Kew Bridge Road frontage.

2.2 The site lies to the south of Kew Bridge Road and immediately to the west of Kew Bridge, which is a Grade II Listed Building. The Thameside Centre office development lies to the west of the site and comprises 4-5 storey red-brick buildings with pitched roofs. The River Thames and towpath run along the southern boundary, with the River Thames designated as Metropolitan Open Land and Nature Conservation Area (UDP Proposals Map 3). The site lies within the Thames Policy Area and the Kew Bridge Conservation Area. To the east of the Bridge lies the Strand on the Green Conservation area.

2.3 The Royal Botanic Gardens (Kew Gardens), lies on the opposite side of the river, as does the Kew Green Conservation Area. Kew Gardens is a World Heritage Site and is designated Grade I on the Register of Parks and Gardens of Special Historic Interest. The Grade I Listed Kew Palace lies within Kew Gardens. The application site falls within the buffer zone for Kew Gardens World heritage Site.

2.4 To the north of Kew Bridge Road the surroundings are a mixture of residential and commercial buildings 3-4 storeys high. Kew Bridge Station is a Grade II Listed identified as Buildings of Local Townscape Character. The Kew Steam Museum, with its Grade I Listed buildings including the ‘Campanile’ tower, lies some 50m to the west.

2.5 The application proposes development of the combined site of the former office block and the demolished Plough public house together with the Waggon and Horses. The site boundary as shown in the planning application includes the roadway along the eastern side of the vacant land and two arches beneath Kew Bridge. It also includes part of the Thames towpath to the south and part of the access road and parking area of the Thameside Centre to the West. In addition, the pavement and bus shelters along the Kew Bridge Road frontage are also included within the application site boundary.

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2.6 The vacant land is designated in the UDP as proposals site M20, and is identified for mixed business and community use or mixed business and residential use in accordance with the planning brief, which was adopted in 2001. It is also identified as a Landmark Site on Map ENV-B2.

2.7 The combined Building, which is in a poor state of repair, and the adjacent terrace has been vacant area and Waggon & Horses site is identified for mixed-use development in the Brentford Area Action Plan (BAAP).

3.0 HISTORY

3.1 Following the demolition of the former office building planning permissions were granted in 1989, 1991 and 1992 for various office and mixed-use developments. None of these were implemented and are now time-expired.

3.2 A Planning and Urban Design Brief for the site was adopted in September 2001.

3.3 An application for mixed-use development comprising 238 residential units and 1,940 sq m commercial floorspace was refused in March 2005 and dismissed on appeal in March 2006.

3.4 In dismissing the appeal the Secretary of State concluded that the scheme offered a number of benefits, including a contribution to housing needs on a site that has remained derelict for many years. However, he felt that the poor quality of the design would cause considerable harm to conservation interests, the world heritage site at Kew Gardens and the riverside. Furthermore, additional harm would result from poor living conditions, increased risk to highway safety and inadequate open space provision.

4.0 DETAILS

4.1 Compared to the previous, appealed scheme this current proposal would increase the site area and alter the built form of the proposed development, and there would be a reduction (by 74 units) in the amount of residential accommodation proposed.

Amendments to the submitted application

4.2 The following changes have been made since the planning application was reported to the area committees in August 2008:

4.3 The number of residential units has been reduced from 170 to 164 and the proportion of three-bedroom dwellings has been increased to 31% of the total. There is no affordable housing in the revised proposal. Parking provision has been reduced from 160 to 155 parking spaces. The commercial floorspace has been reduced from 1,761 sq m to 1,645 sq m and a small business centre has been introduced for residents.

4.4 The building footprint has been reduced at the western end (providing an increase in ground level amenity space) and the north-west corner has been re-designed. The central and tallest building form has been re-designed with glazing introduced to elevations so as to separate and emphasise the solid building segments. Structures at roof level have been reduced in number and

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the roofline has been rationalised and simplified in appearance. The glazed prow at the south-eastern corner has been reduced in height.

4.5 The internal layout of the residential units has been improved so as to provide improved circulation, increased privacy, enhanced daylight and outlook for future residents.

4.6 Access arrangements have been altered and a management plan has been provided. Provision has been made for widening the carriageway of Kew Bridge Road so as to incorporate provision for cyclists.

Details of the revised scheme

4.7 The proposed building would front onto Kew Road to the north and Kew Bridge Road to the east. It would have a flank frontage towards the Thameside Trading Estate to the west and would face the River Thames to the south. The development would rise from two storeys at the southern side to nine storeys, in part, at the northern side. The eastern elevation, facing Kew Bridge is five storeys high with a further ‘penthouse’ storey. Similarly, the western elevation is five storeys with a further ‘penthouse’ storey.

4.8 The proposed riverside public house would be two storeys high with a pitched roof; behind this the central part of the development would rise in stages from five storeys up to eight storeys with an additional ‘penthouse’ floor at the northern end, facing onto Kew Bridge Road. The building would step down to five storeys above a central, covered entrance facing Kew Bridge Road.

4.9 The proposal features a curved ‘turret’ in the north-eastern corner where Kew Bridge Road meets Kew Road at the northern side of the bridge. A similar (prow-fronted) feature is proposed at the western end of the Kew Bridge Road frontage. The southern end of the building, adjacent to Kew Bridge, features a glazed, curved ‘prow’ structure rising to seven storeys in height.

4.10 A public square of 1,456 sq m is proposed in the south-east segment, adjacent to Kew Bridge and the towpath. Pedestrian routes within the site include a colonnade along the eastern flank and a 7m wide opening at ground level between the six-storey building facing Kew Bridge and the curved feature at the north-eastern corner. A raised pedestrian walkway is also featured around the northern and western sides of the public square. The application includes proposed alterations to the Thames towpath including the provision of a ramped walkway to replace the stepped footpath through archway 6 beneath Kew Bridge.

4.11 Parking and servicing for the development (including refuse and recycling) would be located within a basement, accessed from the Thameside Centre. The forecourt facing Kew Bridge Road would provide a drop-off point, with vehicular access at either end. The ground floor accommodation would comprise commercial units along the eastern and northern frontages with residential accommodation facing west and south. The two-storey public house would be free-standing and a commercial unit would be located in the adjacent building at ground floor level. The commercial floorspace within the scheme is identified for a mixture of retail, café/restaurant and office uses and a small health suite is included for residents of the scheme.

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4.12 The upper storeys are all proposed for residential use, providing a range of one, two and three-bed units. There is no affordable housing provision in the revised scheme. The breakdown of residential accommodation would be as follows:

14 x one-bed units (9% of total)

99 x two-bed units (60% of total)

51 x three-bed units (31% of total)

4.13 Private amenity space is proposed adjacent to ground floor dwellings on the southern side of the building. Additional areas are identified at various roof levels throughout the scheme and many units would have balconies. The rooftop areas would provide private terraces as well as communal garden areas.

4.14 A kayak club has been established within archway 5 beneath Kew Bridge and a boat club is proposed within archway 4. The existing toilet block, which abuts the bridge, is to be removed and replaced with a purpose made public convenience. A pontoon is proposed, extending 24m from the towpath into the river, for use by the boat club and kayak club to launch their vessels.

5.0 CONSULTATIONS

5.1 Statutory and non-statutory consultations were sent on 20th June 2008. Notification letters were sent to 770 nearby properties. The application was advertised by way of site and press notices and copies of the application were made available at Brentford and Chiswick libraries. Exhibitions took place at St Paul’s Church, Brentford on 1st July 2008 and Fountain Leisure Centre in Chiswick on 3rd July 2008. Exhibition boards of the proposed development were also displayed in the foyer at Hounslow Civic Centre from 30th June to 18th July 2008.

5.2 In addition to the consultation by the Council the applicant mounted an exhibition within one of the arches beneath Kew Bridge on 11th and 12th July.

5.3 Twelve letters of objection were received. The following comments have been made:

Comment

Object to loss of Waggon & Horses, one of the few buildings of character in Brentford

Object to felling of trees

Loss of light and outlook from Green Dragon Lane

Loss of privacy

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Interference with TV reception

Increased traffic, noise and pollution at busy junction

No provision to improve the junction

Inappropriate development for a landmark site in a Conservation Area

Inappropriate design and materials

Detrimental to setting of nearby listed buildings, the riverside and Conservation Areas

Height and dominance out of keeping and out of scale with surroundings and too close to Kew Bridge Road frontage

Detrimental to views from Kew Gardens World Heritage Site and dominates the adjacent Grade I Listed pumping station and Kew Bridge

Housing density is inappropriate to the area

Risk that apartments would remain vacant, especially during recession

Inadequate infrastructure, e.g. water, sewerage, traffic, healthcare, etc.

Light pollution

Development overhangs public highway

Inappropriate development on flood plain leading to flooding and drainage issues; fails to improve flood capacity or deal with projected climate change issues

No boathouse provided within the development

Does not respect the riverside environment, habitats or bio-diversity

Restriction of public access to the foreshore

Pontoon would be unsightly and a potentially hazardous obstruction to river users

Noise and rowdiness from pub, café and restaurants as well as rubbish such as broken glass/bottles on riverbed

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Supervision/surveillance of public square

Concern that bus-stop is to be moved westward, which would inconvenience bus users from Strand on the Green

Suggestion that developer should fund improvement to slipway on eastern side of Kew Bridge

Suggestion that developer should fund replacement decorative lanterns on Kew Bridge

5.4 Nine letters of support were received making the following comments:

Response from ‘The Hollows’:

The design makes excellent use of a potentially awkward space and although there's a lot going on, it doesn't look cluttered. Provided the developers actually stick to the plan outlined it will make an excellent development. Regarding the plan to level the steps leading down to the Thames off the end of The Hollows, because of the shape of the river in that area, a lot of floating trash collects there. This may get caught up in the pontoon or end up over the new lowered level and may need to be dealt with (whether with creative planting, street cleaning or some other measure).

The proposed removal of two trees is a shame, as the trees are attractive and provide needed privacy for the residents of the houseboats, as well as sustaining an ecologically important area. The trees in this area are used by a wide variety of birdlife during the day and bats at night, and the riverbank provides a habitat for a wide variety of flatworms and snails. However, in support of Canoeing Club and the development of their facilities. It's an excellent addition to the community. Need to ensure that no more than two trees will be lost, and strictly for the purposes of the boating pontoon and not to change the views for residents of the development or users of the pub.

Five letters from local resident/owners:

• One letter supports the demolition of the Waggon & Horses Public House, which is considered to be an eyesore and is in full favour of the proposed development plans.

• One letter states this is an opportunity to do something with a derelict site, which will provide jobs and give the area back some dignity and focus.

• One letter expresses total support for the scheme, looking forward to long-awaited regeneration of Brentford High Street and supports any development that supports this process.

• One letter expresses support for an exciting design, welcomes the provision of a pub, square, shops and cafes promoting a safe environment and happy about the proposed boating activities.

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• One letter supports the excellent mix of uses.

5.5 The Thames Explorer Trust supports the application, which recognises the

continuing change and evolution in the use we make of the river, including today’s rowers and canoes, and encourages public access to London's largest natural space, the Thames foreshore with it's wealth of history and wildlife.

5.6 The managing agents for other St George developments, including Brentford Lock, have written in support of the application stating that the development would improve the local area and benefit the affordable housing sector. They are very impressed with the standard of developments that St George build and the continuing care and maintenance.

5.7 The applicant mounted an exhibition in archway 5 of Kew Bridge on 11th and 12th July and has supplied 51 comment cards received in response. These are generally supportive of the scheme and indicate that it represents an improvement compared to the appeal proposal. Comments include support for the design and riverside improvements, pleased that the site will now be developed in order to make use of vacant space, welcome mixed-use scheme with affordable housing and consider that the proposals will improve the area.

However, the following issues are raised:

• Traffic/junction improvements

• Car-parking issues

• Concerns about building height

• Design/materials

• Commercial units would be an eyesore if not occupied

• Cleansing of public square following high tides

• More soft landscaping for public square

• Landing rights on pontoon

5.8 Brentford Community Council has made the following comments:

Question the accuracy of the submission, e.g. reference to distance from Brentford Town Centre and building heights

Pleased to see that no building is now proposed on the flood plain, that the ‘glass ziggurat’ on the roof has been modified, and that the major access to the site is now from the adjacent property. However major issues of concern remain: 1. The inappropriate density and scale. 2. An Urban Design not worthy of this site. 3. The lack of family accommodation. 4. Inadequate recognition of the river. 5. Parking and service access.

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Consider that this scheme fails to meet the criteria of the current London Plan and the reasons for refusal by the First Secretary of State, and fails to meet the currents needs of Brentford. Request the Council to refuse this application because: • It is an unacceptable design for the most conspicuous site in Brentford

• It does not enhance the Kew Bridge Conservation Area or the setting of the adjacent listed buildings.

• The building is too high, too massive and too monumental.

• It does not allow views of the river through the site.

• It does not provide adequate family accommodation (either for sale or as affordable housing) nor the amenity space required for families.

• The proportion of affordable habitable rooms is inadequate.

• It is an unacceptable design for a river-side site.

• It will create parking problems for existing residents

• The proposed forecourt is likely to be cluttered by service vehicles.

• The proposed landscape treatment is bleak and does not allow for controlled run off of heavy rain.

Consider that many of these problems could be addressed in a redesign and urge the Council to invite the appellant to take the opportunity to revise the scheme

5.9 The Strand on the Green Association has made the following comments:

Considerable improvements over KBR1, in terms of exterior design, context sensitivity, vehicular access, provision of public open space and many other features in which the previous design was deficient. However, still a number of concerns, which should lead to the rejection of this application.

Density and Scale

Despite the improvements this development is too big a scale and too dense for this site. Proposed density exceeds what was suggested by the Appeal Inspector and the range identified in the London Plan. The building scale should not be markedly different from its adjacent buildings, and thus should be limited in height by removing at least one of the full-footprint floors (e.g. the third floor). This would have the effect of bringing the density closer to the range deemed “appropriate” by the quoted authorities and more closely meet the policies set out in the Brentford Area Action Plan.

Building Height

Concerned that the submitted drawings do not have the heights of roofs, etc, clearly expressed in heights above OD. This makes enforcement of the plans difficult, if not impossible.

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Historic Views

The Inspector placed great emphasis on the preservation of historic views, in particular of the Kew Steam Museum stand-pipe tower. The views from the Strand on the Green riverside footpath, are not preserved to an adequate degree.

Restoration of Boat House

The conversion of one of the Kew Bridge arches to a canoe club is to be welcomed, but does not satisfy the requirement to replace the old boathouse within the development site.

Parking

Very concerned at the impact on the already problematic parking in Strand on the Green, Spring Grove, Hearne Road and Green Dragon Lane. No parking provision for users or staff of the commercial premises, or for visitors to the residential accommodation. Repeat request that when, in due course, CPZs are introduced in these areas, no provision should be made for occupants of or visitors to this development.

Accommodation Provided

Support the points made by the Brentford Community Council regarding the lack of larger units of four bedrooms and above. Surprised that a number of the units, in addition to being of very small size, appear to have very inadequate window provision.

In summary, although this proposal shows great improvements over that submitted in the earlier application, still of the view that it should be refused.

5.10 The London Forum of Amenity and Civic Societies has made the following comments:

• The application contains references to the 2004 London Plan, which are inaccurate as the plan was up-dated in 2008.

• The scheme is too tall and dense, and fails to meet London Plan criteria in terms of respect for surroundings and Thames-side setting.

• The proposal fails to meet GLA requirements for units with four bedrooms or more and would deliver less than the 50% expected affordable housing.

• The proposed density is much higher than allowed for in the London Plan or indicated by the Inspector in the previous appeal.

• Inadequate play facilities and amenity space.

• Unacceptable views from Kew Gardens (now more apparent because of the recently completed tree walk). Too close to Kew Bridge and lack of stepping down to the Thames.

• The inclusion of Waggon & Horses pub provides more room for development. Hounslow Council should seek reduction in bulk and height.

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5.11 The Kew Society objects to the development.

Should be of scale and character to respect this sensitive site and reflect the riverside character, which was landscaped in the18th century.

• Deleterious impact on Kew Bridge and its setting. The six storeys facing Kew Bridge would not only destroy the spaciousness and the balance between the two sides of the bridge, but also cast a long shadow over the bridge for much of each day as well as over the houses on the opposite side of Kew Bridge Road to the North of the site.

• Given the World Heritage Site and Conservation Area considerations, the

section of the building adjacent to Kew Bridge should be greatly reduced in height.

• The scheme appears to take no account of the Thames Landscape

Strategy. In that document it states at page 170, Policy proposal 12.3:“Prevent any further flat-roofed high-rise buildings from intruding into the Brentford Waterfront massing. When the Kew Bridge office block comes up for re-development it should be replaced with a lower building of a form, massing and materials which complements the surrounding townscape”. (That building was lower than the proposed development and is set well back from the river).

• In this case, it would be appropriate for the height of the proposed

development to be below the height of the mature trees around the site. • Design is out of keeping with the neighbouring buildings with its far greater

mass and odd mixture of utilitarian designs. Wholly out of scale with its surroundings and the design takes little account of the views expressed by the inspector on the appeal relating to the previous application.

• No allowance for any parking space for non-residents. Although 160

parking spaces for residents is planned in the underground car park, temporary parking for visitors as well as parking for occupiers of the commercial units is going to be needed. Without it, many visitors will no doubt seek to park on Kew Green, which has too little space for the current level of visitors. In addition, the development will generate a lot of traffic in an area where traffic congestion is already a serious problem seven days a week.

• The proposal is an over-development of the site, adjacent to one of the

busiest roads in London, this new development will put undue pressure on the local infrastructure.

Therefore hope that the application is rejected.

5.12 Greater London Authority

On balance the application does not comply with the London Plan. However changes to address the following deficiencies could possibly lead to compliance with

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the London Plan. The applicant provided further information and the GLA made a supplementary officer level response shown in brackets below:

• Proportion and mix of affordable housing provision (the proposed mix of affordable housing is considered to be acceptable)

• Play space provision (details of on-site play space provision and contribution to off-site provision should be provided)

• Design – high quality materials and seek reduction in proportion of single aspect dwellings (the applicant has confirmed that the number of single aspect units cannot be reduced without significant alteration to the design and that sustainable design principles such as passive design measures will address issues of overheating)

• Disabled access ( the proposal meets Part M of the Building Regulations and ‘Lifetime Home’ standards and suitable access provision could be secured by conditions)

• Biodiversity and ecology (the information included in Chapter 13 of the Environmental Statement complies with policy 3D.14 of the London Plan)

• Energy efficiency,changes\ renewables and water management plan (further consideration to be given to provision of a single energy centre, foul and surface water strategy should be secured by conditions)

• Consider reducing the number of car-parking spaces, include cycle parking for commercial units and provision of a service management plan ( car club and additional cycle parking are to be provided, access to the adjacent cycle network to be assessed by TfL)

The supplementary response concludes that play space, energy and transport need to be addressed either before referral back to the Mayor or by condition. However, the additional information in relation to affordable housing, urban design, access, biodiversity and climate change demonstrates that the application now complies with London Plan policy in these respects. These comments relate to the original application, which included affordable housing provision. Response to the current proposal is awaited.

5.13 Transport for London

No objection in principle. Further information required in relation to pedestrian and cycling facilities and clarification of site boundary.

Section 106 contributions may be required for bus stop upgrades, pedestrian improvements and improvements to Kew Bridge Station. A workplace travel plan should also be provided.

Response to revised application:

A satisfactory solution has been reached in respect of the proposed vehicular access points.

Considers that the parking provision is still too high but accepts that it does not exceed the maximum London Plan standards.

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The proposed cycle parking provision is welcomed.

Supports the proposed extension of the westbound cycle route along Kew Bridge Road.

Wish to see PERS audit undertaken by the applicant and upgrading of footways surrounding the site.

Seek financial contribution towards improvements to Kew Bridge Road junction.

Welcome proposed replacement bus shelters, may require contribution to bring bus stops to accessibility standards.

Further work is needed on travel plans and servicing management plan, which can be addressed through planning conditions or S106 agreement.

5.14 Highways agency

No objection

5.15 Head of Traffic and Parking

Preliminary comments on the proposed layout:

The application does not provide the property line setback of about 1.5m that was requested in order to get more traffic space past the bus stop and join up with the new cycle lane that starts just west of site.

The plan showing the road lanes on Kew Bridge Road is incorrect and doesn’t reflect the current line marking especially with regards the right turn bays into Thameside and Green Dragon lane.

More detail required in relation to access arrangements

5.16 Housing Strategy

See no reasonable constraints to providing a higher proportion of affordable housing on this site. Although the economic viability toolkit states that 26% is the maximum amount of affordable housing that can be supplied on this scheme, if the scheme was appraised to include grant, the proportion of affordable housing could be increased.

Would like to see an increase in 3bed units in line with the Borough’s target to provide 35% of all units to be 3bedroom units or larger for affordable rented and shared ownership. As there is no RSL on this site, the Borough reserves the right to approve the RSL

5.17 Director of Children’s Services and Lifelong Learning

The development is likely to generate 44.3 children (11.08 pre-school age, 19.49 primary and 13.73 secondary school age). Therefore seek from the developer: £255,611 to fund the primary and £271,332 funding for the secondary school places (approx £527K in total).

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5.18 Metropolitan Police

More detail required in order to achieve Secured by Design

Advice concerning security measures

Potential disturbance and anti-social behaviour related to proposed public house

5.19 Pollution Control

Advice concerning noise, air quality and energy strategy.

5.20 The Countryside Agency

Response awaited

5.21 Natural England

Support improvements to Thames Path but would normally request a width of 6m with a segregating landscape strip.

Mitigating measures are necessary to support roosting bats and further information is required in relation to lighting.

Support the enhancement measures, which are discussed in the Environmental Statement, and advise that biodiversity enhancement measures be included as planning conditions or obligations, as appropriate.

5.22 Environment Agency

The site has been allocated for development to provide wider sustainability benefits such as the reinstatement of the former boathouse and the opening up of the waterfront to the public as it is included within the submitted Brentford Area Action Plan (AAP). For regeneration purposes and wider sustainability benefits we accept that development in this location may be exceptionally necessary.

We accept that Part C of the exception test has been met as the development:

• creates more flood storage;

• ensures safe access and egress from the development;

• sets floor levels of buildings at a level that will be unaffected by either fluvial or tidal flooding taking climate change in to consideration.

We must accept that the rationale behind PPS25 policies are to prevent an increase in flood risk. In this case, the site specific FRA submitted by the applicant has shown that increased flood storage can be provided on the site and that it can be developed without an increase in flood risk to the site or to adjacent areas. As such, as no demonstrable harm is shown and after much pre-application discussion, we feel that the meaning and intent of PPS25 policies are being met and achieved. Had the submitted

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information shown otherwise we would have objected to this application, and this would have remained indefinitely.

5.23 Thames Water

Advice concerning drainage, sewerage and water supply 5.24 English Heritage

Do not wish to offer any comments on either application. Recommend that they be determined in accordance with national and local policy guidance, and on the basis of the council’s specialist conservation advice.

5.25 English Heritage (Archaeology)

An archaeological investigation has been carried out at the cleared area of the site. The Waggon and Horses PH is a former Coaching Inn dating from 1750 and of historic interest to Brentford. Recommend a condition to secure a programme of recording and historic analysis prior to development taking place.

5.26 CABE

No objection to principle of residential and commercial use and a building of this height could be acceptable. However, concerned that impermeable megablock nature of this development is at odds with its immediate surroundings.

The original concept of interlinking blocks of different dimensions has been lost to development that is more representative of one large building, out of character with surrounding buildings that have a more permeable arrangement. The central block is bulky and inelegant and will be over-dominant on Kew Bridge Road.

More needs to be done to make the development less monolithic and planning consent should not be considered until these concerns have been resolved.

The developer has met with CABE and the revised scheme seeks to address these issues.

5.27 PLA

Further information required in respect of environmental assessment and mitigation measures.

Inadequate information about the proposed pontoon

Occupiers of existing moorings should be consulted (this has been done)

River works licence is required

Recommend provision of riparian life-saving equipment

Details of improvements to slipway required

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Details of proposed lighting required

PLA is not responsible for removal of flotsam and jetsam

5.28 British Waterways Board

Response awaited

5.29 Inland Waterways Association

No objection – welcome the use of spaces under the arches of Kew Bridge for boating purposes.

5.30 London Fire and Emergency Planning Authority

Satisfied with the proposals subject to installation of Dry Rising Mains and inlet valves and access for fire fighting to be agreed prior to construction.

5.31 BAA

No objection

5.32 Royal Botanic Gardens, Kew

` Identify two broad areas of concern:

Height, mass and bulk

The proposed retention of key views across the site, which has broken the design into smaller elements and given the appearance of a “collection” of related buildings combined with an overall reduction in units compared to the previous scheme, has gone some way to reducing the impact of the proposed building.

However, the overall impression is still one of a single built form rising to a high point, for example as seen emerging form Kew Bridge Station.

The bulk of the building is particularly evident on Kew Bridge Road, as one continuous wall of development without gaps offering views or ways through to the river. Elsewhere, gaps between different parts of the scheme are relatively small.

The proposed building is still quite bulky and taller than buildings in the Kew Bridge and Strand on the Green conservation areas. The building would also restrict views across the river to Kew Green and the Kew Gardens World Heritage Site.

From the tow path on the opposite bank the high point of the proposed building will be clearly visible, rising to a similar height as Prospect Point to the west and Rivers House to the east. The effect will be of a wall of larger development, defined by these taller slab blocks

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Improvements to the public realm

The proposed public square, offering views across to Kew and various facilities to visitors and local residents, is to be welcomed.

We had envisaged that the redevelopment of this site would bring with it some much-needed improvements to the public realm in the vicinity of the site, which is characterised by an extremely hostile environment for pedestrians, with poor traffic management, poor pavements and signage, and the almost complete absence of landscaping and trees.

(It is interesting to compare the traffic situation here with Kew Green, which the South Circular also traverses. At Kew Green, whilst the volume of traffic is the same, the impact of the traffic artery is considerably lessened by the presence of trees and planting.)

We were hoping therefore to see some proposals to be carried out concurrently with the scheme that would improve the experience for our visitors arriving at Kew Bridge Station as well as visitors to attractions in Brentford, such as the Steam Museum, and local residents.

Disappointed that the application does not include these improvements to the public realm. So, for instance, the road junction between Kew Bridge Road and Kew Bridge will remain as it is. The pavement onto Kew Bridge will remain very narrow and uneven.

We appreciate that there are competing claims for funding. However these areas are adjacent to the site and it would seem reasonable to expect enhancements to be carried out concurrent with the redevelopment to achieve a unified scheme.

5.33 Kew Royal Palace

Response awaited

5.34 London Borough of Richmond upon Thames

Objects for the following reasons:

Design: height of buildings in a sensitive location, the nine-storey portion is particularly obtrusive. The public square would benefit from further tree planting along the riverside.

Transport: conflicting traffic movements close to Kew Bridge, pressure on parking around Kew Green.

5.35 West London Business

The proposed high quality development matches the policy objective in the Inward Investment and Business Growth Strategy to ensure that there is sufficient development of areas to meet the investment needs of West London.

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Aesthetically pleasing quality and affordable housing will revitalise this high profile area, employment at the site will increase prosperity and the development will be beneficial for the future social and economic development of the Borough

The Growth Strategy encourages mixed-use developments and sustainable development of appropriate strategic sites.

Development will be a boost for business in the West London. WLB will promote awareness of the plans, promote the business space and encourage companies and investors to move into the Borough.

The proposal will transform the area and showcase Brentford’s potential for high quality development.

5.36 West London River Group

Inadequate information. The applications contain too many mistakes, and omit significant details. Examples of mistakes are:

a) The statement that the site is in “close proximity to Gunnersbury Station”. The site is about 0.92km (2/3rds of a mile, or 1,164 yards) from Gunnersbury Station.

b) The statement that the site is “620 metres east of Brentford Town Centre”. The site is about 1,377 metres from The Beehive at Half Acre, and quite a bit further from the Market Place. Even the Watermans Centre is more than 620 metres from the site.

c) The statement that there are 3,294 sq. m. of private amenity space on the roof of Block F, with 1,143 sq. m. of affordable amenity space around it. The application drawings do NOT show any of the necessary safety netting that roof space in such use would require, The claim should be corrected, or the drawings amended.

d) The references to The London Plan fail to distinguish the current 2008 edition from its predecessor, with consequent confusion.

Examples of omissions are:

e) The drawings do NOT give proposed (and therefore verifiable) roof heights above Ordnance Datum, and are therefore unenforceable in this respect. On the Kew Riverside site on the other side of the River, the tallest building was built about two metres higher than permitted on Appeal because of just such a discrepancy within the application/appeal drawings.

The proposals omit the restoration of the boathouse, with provision of facilities for a rowing club.

Therefore the Council is urged to defer consideration of the applications until all defects have been made good.

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Grounds for Refusal. The Council is respectfully urged to REFUSE these applications on the following grounds: • The proposals fail to preserve and enhance the Brentford and Strand on the

Green Conservation Areas, by ignoring their setting and site-context.

• They ignore their Thames Policy Area location and context, by having no regard to River and Riverside views and landscape, for example the view upstream from above Kew Railway Bridge; and take no account of the Kew Gardens World Heritage Site Buffer Zone.

• They fail to conform to the Blue Ribbon Network principles of The London Plan.

• They damage the settings of neighbouring Listed Buildings, Kew Bridge and the Kew Steam Museum.

• They block most landward views of the Steam Museum building and ‘campanile’, forexample leaving only two narrow vision slots from Strand on the Green.

• They ignore the traffic context of the site, on the very complex road junction of Kew Bridge/Kew Road, Kew Bridge Road, Chiswick High Road and Strand on the Green. The proposals impose a large extra traffic load without making any contribution whatsoever to fitting the new traffic into the existing pattern, let alone seeking any improvement to an already overloaded traffic junction.

• They fail to maintain the existing vehicular access and parking for the existing businesses inthe arches under Kew Bridge.

• They encroach into and over the public realm with overhanging balconies, over land NOTin the ownership of the applicant, and to the detriment of the users the general public.

• They fail to restore a boathouse to this site. We welcome the addition of a pontoon. Detail of its construction and operation is not available, so if the Council were to approve these applications we would expect there to be conditions requiring the provision of such information, and for it to be assessed and approved by the Port of London Authority, the Amateur Rowing Association and any other relevant authority. However the provision of suitable pontoon arrangements is not sufficient in itself. The two arches do not provide adequate storage facilities for boats. The spaces are not long enough for racing VIIIs, and a Club would need rack storage for several boats of differing sizes. Nor is there any provision for changing rooms, shower facilities, and a club room. Without such facilities, a Rowing Club is not sustainable.

If the Council is minded to approve the applications. The Council is respectfully urged to impose Conditions on any Permissions, including the following matters:

1. The proposed pontoon should be included in the Section 106 Agreement, with a requirement that the pontoon must be installed, operational and

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available to all without charge or other condition, BEFORE any of the residential units are occupied.

2. Existing vehicular access and parking on the upstream side of Kew Bridge for the existing businesses in the arches under Kew Bridge, and for the two boats ‘Van Tromp’ and ‘Jacarna II’ berthed upstream of Kew Bridge, should be maintained free of charge at all times.

3. Pedestrian access along the Tow Path/Riverside Walk between the site and the River should be maintained free and unobstructed at all times.

4. The existing trees and plants along the Riverside between the site and the River should be protected throughout the works, and should NOT be pruned, pollarded or felled.

Conclusion.

The West London River Group supports the comments made on these proposals by our member-Groups and Associates, the Brentford Community Council, the Brentford Waterside Forum, the Strand on the Green Association, the Chiswick Protection Group and others.

The West London River Group respectfully urges the Council to REFUSE these applications on the grounds described above; or if minded to approve the applications, to impose conditions including those described above.

5.37 The West Chiswick & Gunnersbury Society object to the application for the following reasons:

• Would not enhance or promote the Strand on the Green Conservation Area or the nearby Listed Buildings.

• Would restrict access to the riverside for the general public

• Design is inappropriate and out of character for the area and does not accord with the blue ribbon principles of the London Plan

• Inadequate parking provision, thereby increasing parking congestion and traffic flows

• Building still too high and is an over-development in terms of mass and scale

• Would damage views of Kew Gardens World Heritage Site and views from the south side of the river

• Inadequate affordable housing provision and segregation of affordable from private flats

• Insufficient recreation and amenity space for residents

5.38 Chiswick Area Committee

Considered the application on 6th August 2008 and raised the following concerns:

• Concerned at the low proportion of affordable housing provision and no key-worker housing identified

• Density is still too high and inappropriate mix of units

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• Inappropriate design in a historical area

• Improved access to foreshore and along riverside path is needed

• Much effort has gone into improving the design

• Some views are protected but not all

• Vehicular access has been improved but issues still remain such as access for large vehicles

• Inadequate parking provision

Members instructed officers to seek improvements to the scheme rather than refuse under delegated powers.

5.39 Isleworth & Brentford Area Committee

Considered the application on 14th August 2008 and made the following comments:

• Concerns about highways, access and transport; more information required

• Insufficient parking provision

• Unattractive design, inappropriate to the location

Members instructed officers to seek further information and improvements to the scheme and refer back to IBAC before presenting to Sustainable Development Committee.

Consultation on the revised application

5.40 Statutory and non-statutory consultations were sent on 19th March 2009. Notification letters were sent to 144 nearby properties. The application was advertised by way of site and press notices and copies of the revised application were made available at Brentford and Chiswick libraries.

5.41 The applicant mounted an exhibition within one of the arches beneath Kew Bridge on 27th and 28th March 2009.

5.42 Nine letters have been received raising objections to the revised application as being out of keeping with the character of the area and not substantially different from the original submission in June 2008. Many of the original objections have been repeated and additional comments are summarised below:

Suggestion that developer should fund improvement to steps onto foreshore

Inadequate on-site parking would lead to parking around Kew Green, causing nuisance to residents and visitors to Kew Gardens

Concern about potential nuisance from public house located close to residential mooring on the riverbank

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5.43 One letter has been received in favour of the application, expressing particular support for the existing canoeing and proposed expanded boating facilities including the pontoon, which will improve access to the river for all.

5.44 Chair of Holland Gardens Residents Community

Re-iterates request that developer should fund replacement decorative lanterns on Kew Bridge

5.45 Strand on the Green Association

Continue to oppose the application as the minor changes do not resolve issues that were raised in response to the original application. Additional comments include:

The Kew Bridge traffic junction is dangerous and inefficient and the traffic generated by this scheme will make matters worse.

Amenity space provision appears to be inadequate.

Density remains excessive

Overbearing bulk, scale and appearance of the proposal continue to give rise to concern

The Association does not consider that the present scheme either preserves or enhances the character of the area and questions whether pastiche on this scale is really appropriate in this area of unpretentious architectural quality, genuine variety and modest domestic scale

5.46 Brentford Community Council

Welcome the amendments that have been made to the scheme, but consider they still do not meet the objections raised by the inspector to the scheme submitted to the public inquiry nor the objections raised by the BCC in 2008. Therefore re-iterate the objections raised to the original proposal.

The articulation of the current proposal is welcomed. However, it is inadequate to relate the scale and character of the proposed building satisfactorily to the listed buildings and to the conservation area. To achieve this, the whole building should be reduced by one floor in height. Re-iterate request that the building should allow views through the building from the High Street/Kew Bridge Road to the river.

The application remains an un-inspired design, which is considered unworthy of a site of such exceptional importance.

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In respect of Urban Design, ask that the application be rejected

A scheme with inadequate family accommodation and no affordable housing should be refused Even without the possible development of the Brentford Community Stadium this scheme provides further pressures on the over-crowded road system, inadequate on-site parking for cars and cycles and an access pattern which could exacerbate congestion around Kew Bridge.

Ask that the public house building should be re-designed to incorporate a rowing club.

Consider that the amended scheme fails to meet the BAAP brief for the site and should be refused.

5.47 Royal Botanic Gardens, Kew

The changes are generally very minor so reiterate objections to the application as follows:

i) Height, mass and bulk of the proposed building

In terms of its overall bulk and appearance, the amended scheme is virtually identical to the scheme submitted in July 2008.

Although the design intention was to create the effect of a group or “family” of buildings - reducing the apparent bulk of the scheme and preserving key views across the site – the impression is still of a single large building, for instance as seen from Kew Bridge Station.

The bulk of the building is particularly evident on Kew Bridge Road, which is one continuous wall of development, without gaps offering views or ways through to the river. Elsewhere, gaps between different parts of the scheme are relatively small.

In general, the proposed building is taller than buildings in the Kew Bridge and Strand on the Green conservation areas. The building would also restrict views across the river to Kew Green and the Kew Gardens World Heritage Site.

From the tow path on the Kew side, the proposed building would be seen to rise to a similar height as Prospect Point to its west and Rivers House to its east. The effect will thus be of a wall of larger development, defined by these taller slab blocks.

ii) Related improvements to the public realm

The public realm in the vicinity of the site is extremely hostile for pedestrians, with poor traffic management, poor pavements and signage, and an absence of landscaping. A significant number of visitors to Kew and staff have to cross this space in order to reach Kew Bridge.

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Disappointed therefore that the current application still does not propose improvements here, although these might reasonably be expected with a scheme of this size. For instance there are no proposals to improve the road junction between Kew Bridge Road and Kew Bridge or to improve the pavement onto Kew Bridge, which is narrow and uneven.

The road junction is the responsibility of TfL,which is planning improvements, as part of an ongoing upgrade to the North/South Circular. However no date is set for these works and they will not apparently be coordinated with the redevelopment. Have written to TfL to express concerns, and to ask that works here can be prioritised so that they can be better related to the redevelopment. Hope that the Highways Dept could use their influence with TfL to make a similar request.

5.48 The applicant has provided 28 comments cards that were completed in response to the exhibition that was mounted to explain the amendments, which had been made. The majority are generally supportive of the amended scheme. Positive comments include support for the improved design and more unified appearance and an ideal solution for a derelict site, in favour of public square, pub and cafes and encourages use of public transport. One reply prefers scheme without affordable housing.

However the following concerns are also raised:

• Traffic congestion

• Impact of parking

• Balconies overhanging public areas

• Already too much new residential development in the area

• Density and height

• View impaired

• Impact on Conservation Area

• Public convenience not permanently available

• Seek improvements to slip road at Strand on the Green

• Outside seating and artwork should be provided

• Seek improvements to moorings

• Seek replacement lamp-posts on Kew Bridge

• Lack of affordable housing

5.49 The Kew Society

Objects to the proposed development for the reasons set out in previous response.

5.50 West London River Group

Strongly support comments made by member-groups, with particular note of concerns in respect of urban design, access, parking and riverside uses.

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1. Ensure that the pontoon/landing-stage is included in any permission, with the condition and Section 106 item requiring public availability of the pontoon/landing-stage BEFORE any residential units are occupied.

2. The same comment applies to the "Boat House" part of the scheme. Any permission should include the replacement Boat House on the site itself, as required by the Site Design Brief, even if it has to be part of the Riverside building which would also include a pub.

3. Ensure that the permission drawings INCLUDE the spot-heights above Ordnance Datum of all new roofs, and of the main existing buildings nearby (e.g. Rivers House, Kew Steam Museum and Regatta Point). It is essential that all the existing building heights be independently verified BEFORE permission is granted, in order to avoid what happened at Kew Riverside, where the existing PRO buildings were drawn NOT to scale, but about two metres higher than they actually are, with the result that the new buildings have been built about two metres higher than was intended in the approval of that scheme, to the detriment of the River and Riverscape.

4. Ensure that any scheme includes adequate measures to prevent light-pollution and light-trespass at night over and across the River from 'glass boxes' on its roofs.

Urge the Council to REFUSE the scheme in its current form, and hopes that it may prove possible to persuade the applicant to change their proposals to accommodate the suggestions put forward by the local communities

5.51 The following organisations have also been consulted and comments are awaited:

The Isleworth Society

River Thames Society

Thames Landscape Strategy

Brentford Waterside Forum

Chiswick Protection Group

Green Dragon Lane Residents’. Association

West Play

6.0 POLICY

6.1 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.

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The Development Plan

6.2 The Development Plan for the Borough comprises the saved policies in the

Council’s Unitary Development Plan (‘UDP’), the Employment Development Plan Document, the Brentford Area Action Plan and the London Plan.

The London Plan (Consolidated with alterations since 2004) was adopted in February 2008.

The UDP was adopted in December 2003 and was amended and saved as of 28 September 2007 by Direction from the Secretary of State

The Employment Development Plan Document was adopted on 25 November 2008 and has superseded the Employment Policies contained in UDP Chapter 7 and the following Implementation Policies contained in UDP Chapter 2: IMP.4.1, IMP.4.2, IMP.4.3, and IMP.4.4..

The Brentford Area Action Plan was adopted on 27 January 2009 and has superseded the following Implementation Policies contained in UDP Chapter 2: IMP.2.1 and IMP.3.1.

6.3 Central Government Guidance

PPS 1 Delivering Sustainable Development

PPS 6 Town Centres and Retail Development

PPS 3 Housing

PPS 9 Biodiversity and Geological Conservation

PPS 12 Local Development Frameworks

PPG 13 Transport

PPG 15 Planning and the Historic Environment

PPG 16 Archaeology and Planning

PPG 17 Planning for Open Space, Sport and Recreation

PPS 22 Renewable Energy

PPS 25 Development and Flood Risk

6.4 Unitary Development Plan (as amended and saved 28th September 2007)

IMP 1.1 Integrating Patterns of Land use and the Provision of Transport

IMP 1.2 The Re-use and Recycling of Urban Land.

IMP 6.1 Planning Obligations

ENV-N.1.7 Development near Metropolitan Open Land

ENV-N.2.4 Habitat protection

ENV-B.1.1 New Development.

ENV-B.1.2 High Buildings or structures affecting sensitive areas

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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

ENV-B.3.2 Sites of Archaeological Importance

ENV-W.1.1 Design in the Thames Policy Area

ENV-W.1.2 Mixed uses in the Thames Policy Area

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

ENV-W.1.5 Nature Conservation in the Thames Policy Area

ENV-W.1.9 Use of the River Thames for recreational facilities

ENV-W.1.10 The Thames Path National Trail and Access to the River

ENV-W.1.11 Access to the Thames foreshore

ENV-W.2.6 Stationary or floating structures in or over the waterways

ENV-P1.1 Environmental Impact Statements and Assessment

ENV-P1.3 Surface water run off

ENV-P1.4 Waste water management

ENV-P1.5 Noise Pollution

ENV-P1.6 Air Pollution

ENV-P1.7 Light Pollution

ENV-P2.1 Waste management

ENV-P2.4 Recycling facilities in new development

H.3.3 The use of upper floors above shops and in town centres

H.3.5 Release of employment uses to residential

H.4.1 Housing Standards and Guidelines

H.4.4 Provision for children’s play in housing developments

C.1.3 Existing social and community facilities

S.1.1 Main Shopping Areas

S.3.1 New Retail Development

S.4.5 Servicing arrangements

T.1.2 The Movement Implications of Development

T.1.4 & Appendix 3

Car and Cycle Parking and Servicing for Developments

T.2.1 Pedestrian Access

T.2.2 Pedestrian Safety and Security

T.3.3 Special Parking facilities for People with Disabilities

T.4.3 Traffic implications of new development

T.4.4 Road Safety

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T.4.5 On-Street Parking

T.4.6 Off-Street Parking

T.5.1 Air Quality Implications of Traffic

6.5 Supplementary Planning Guidance

SPG1 Design and layout

SPG 2 Ecological/Landscape

SPG3 Safety and Security Guidelines

SPG 4 Daylight &sunlight

SPG 5 B1 units

SPG7 Conservation Areas

SPG9 Form & Design

SPG10 Private Amenity Space

SPG11 Roads, footpaths parking & servicing.

SPG12 Internal Space Provision

SPG13 Housing for People with Disabilities

Thames Landscape Strategy

Planning Obligations SPD

6.6 Design Brief

A Design Brief was adopted for this site in September 2001. The Brief sought a high level of architectural quality, design and character appropriate to this busy junction and riverside location. The principles of the Brief have been up-dated and incorporated into the Brentford Area Action Plan.

6.7 Brentford Area Action Plan (BAAP)

The Brentford Area Action Plan was adopted on 27 January 2009 and has superseded the following Implementation Policies contained in UDP Chapter 2: IMP.2.1 and IMP.3.1. It was prepared in advance of the Core Strategy, primarily in response to continuing pressure for development within the area and will guide development over the next 10 years. The BAAP identifies the application site (M3) for mixed-use development including residential and commercial and re-provision of a boathouse, together with riverside path and open space. The following policies are relevant:

BAAP1 Sustainable Development

BAAP2 Urban Design

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BAAP5 Regeneration and protection of Brentford’s river and canal support facilities, infrastructure and facilities

M3 Kew Bridge Site, Kew Bridge Road

6.8 London Plan (consolidated with alterations since 2004)

2A.1 Sustainability Criteria

2A.8 Town Centres

2A.9 The Suburbs: supporting sustainable communities

3A.1 Increasing London’s Supply of Housing

3A.2 Borough Housing Targets

3A.3

Table 3A.2

Maximising the potential of sites

Density matrix

3A.5 Housing Choice

3A.6 Quality of new housing provision

3A.8 Definition of affordable housing

3A.9 Affordable housing targets

3A.10 Negotiating affordable housing in individual private residential and mixed use schemes

3A.11 Affordable housing thresholds

3A.17 Addressing the needs of London’s diverse population

3A.18 Protection and enhancement of social infrastructure and community facilities

3B.1 Developing London’s Economy

3B.11 Improving employment opportunities for Londoners

3C.1 Integrating transport and development

3C.2 Matching development to transport capacity

3C.22 Improving conditions for cycling

3C.23 Parking Strategy

3D.13 Children and young people’s play and informal recreation strategies

3D.14 Biodiversity and Nature Conservation

4A.1 Tackling Climate Change

4A.2 Mitigating Climate Change

4A.3 Sustainable design and construction

4A.4 Energy assessment

4A.5 Provision of heating and cooling networks

4A.6 Decentralised Energy

4A.7 Renewable Energy

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4A.9 Adaptation to Climate Change

4A.10 Overheating

4A.11 Living roofs and walls

4A.12 Flooding

4A.13 Flood risk management

4A.14 Sustainable drainage

4A.16 Efficient use of water

4A.17 Water supplies and resources

4A.19 Improving air quality

4A.20 Reducing noise and enhancing soundscapes

4A.28 Construction, excavation and demolition waste

4B.1 Design principles for a compact city

4B.2 Promoting world-class architecture and design

4B.3 Enhancing the quality of the public realm

4B.5 Creating an inclusive environment

4B.6 Safety, security and fire prevention and protection

4B.8 Respect local context and communities

4B.9 Tall Buildings – Location

4B.10 Large scale buildings – design and impact

4B.11 London’s Built Heritage

4B.12 Heritage Conservation

4B.13 Historic Conservation-led regeneration

4B.14 World heritage sites

4B.15 Archaeology

4C.1 The strategic importance of the Blue Ribbon Network

4C.2 Context for sustainable growth

4C.3 The natural value of the Blue Ribbon Network

4C.4 Natural landscape

4C.6 Sustainable growth priorities for the Blue Ribbon Network

4C.10 Increasing sport and leisure use on the Blue Ribbon Network

4C.11 Increasing access alongside and to the Blue Ribbon Network

4C.12 Support facilities and activities in the Blue Ribbon Network

4C.13 Moorings facilities on the Blue Ribbon Network

4C.14 Structures over and into the Blue Ribbon Network

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4C.15 Safety on and near to the Blue Ribbon Network

4C.16 Importance of the Thames

4C.17 Thames Policy Area

4C.22 Rivers, brooks and streams

6A.4 Priorities in planning obligations

6A.5 Planning obligations

London Plan Supplementary Guidance

Accessible London: Achieving an Inclusive Environment

Providing for Children and Young People’s Play and Informal Recreation

7.0 PLANNING ISSUES

7.1 The main planning issues to consider are:

• The principle of the development and the proposed mix of uses

• The density of development

• The scale, bulk and design of the development

• The effects on adjacent buildings and impact on neighbouring occupiers

• The quality and nature of the proposed accommodation

• Proportion, mix and tenure of the affordable housing provision

• Access and public transport

• Parking provision.

• Impacts on the Riverside environment, ecology, archaeology etc.

• Flooding

• Sustainability and Energy.

• Potential to secure planning obligations

The principle and proposed mix of uses

7.2 The site is identified for a mixed-use development in the UDP and BAAP. The principle of mixed-use development was not resisted at the appeal or found to be unacceptable by the Secretary of State. However, UDP policy C.1.3 states that the loss of existing social and community facilities will be resisted. Therefore the potential for alternative community use must be fully explored before the loss of another public house can be considered. In this case a replacement for the Waggon & Horses is proposed close to the riverside and public square. Café/restaurant uses are included within the

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scheme and a boat and kayak club are being established within the arches of the bridge.

7.3 The BAAP states that a new public house should be included and provision made for reinstatement of the former boathouse. Additional river-related uses would also be appropriate. The development must incorporate a lively riverfront, riverside open spaces available to the public and public uses should be provided along pedestrian access routes to the river. Flooding issues are discussed separately below.

7.4 The site is within an area that experiences high levels of road traffic noise and poor air quality. The proposed residential accommodation will need to be protected against these environmental conditions by means of suitable glazing and ventilation. The assessment provided in the Environmental Statement is inadequate in this respect and further information will be required.

Density

7.5 Planning Policy Statement 3 (Housing) and the London Plan both encourage more efficient use of land in order to provide sustainable communities and to meet housing needs in the local area and within the broader London context.

7.6 In the Inspector’s Report on the dismissed appeal proposal for this site, the inspector suggested that the applicable density range from Table 4B.1 of the London Plan would be ‘the lower end of the range of 450-700hrha’. The Secretary of State, in dismissing the appeal, stated that density should not be a determining factor but that the design should seek to maximise density whilst being acceptable in all other regards. The London Plan has been modified since the appeal decision and the relevant density matrix now appears at Table 3A.2. The density range for an urban setting with a PTAL of 2-3 is 200-450hrha. A density range of 200-700hrha is identified for sites with a PTAL of 4-6. The application site has a PTAL of 3, so the Inspector’s assessment is still relevant in the context of the revised policy.

7.7 The applicant has provided calculations, which identify the revised scheme as having a density of 537hrha based on gross site area or 630hrha based on site area minus the proposed public square. However, using the net density method put forward in the London Plan (net residential area) the density figure is 824hrha or 700hrha including the public square. Whilst this is significantly above the relevant London Plan threshold it is not alone a reason to refuse the scheme but must be assessed in terms of potential shortcomings as a result of the high density proposed.

Scale, Bulk and Design

7.8 The site is the heart of the conservation area. The CA is itself based on the confluence of historic thoroughfares and the river, together with domestic, commercial and mixed use buildings in a mostly classical design. Some of the buildings are individually attractive (if neglected to varying degrees) including some of recognised quality. These form a reasonably long and consistent backcloth street edging. The Steam Museum buildings form a group at the western end, connecting individual large buildings of very high

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historic and visual quality. Its campanile tower forms a punctuation point on the street and a widely visible landmark. The bridge forms another dramatic but horizontal landmark in the scene

7.9 The scale and bulk of the proposed development is substantial and will appear more so because of the openness of the site at present and the prominence of its location. The site is visible over many and long views, and the development will inevitably mask to a greater or lesser extent buildings and places, including the River Thames, which are of local and nationally designated character in many of those views. Therefore the building will represent a major visual feature and a significant presence at this sensitive place.

7.10 The design has evolved, taking references from other riverside buildings and materials featured in nearby development together with input from an extensive public consultation carried out by the developer. The outcome is an idiosyncratic design tailored to the site. Perhaps more complex than might have resulted from a less contextual approach, this has required a balancing simplicity of styles and typology.

7.11 Policy ENV-B 2.2 (echoing statutory requirements) seeks to preserve or enhance the character and appearance of Conservation Areas by ensuring that any development is appropriate in terms of scale, design and materials. UDP policies ENV-B2.8 (Views and Landmarks) and policies ENV-W1.1 – ENV-W1.11, which relate to the Thames Policy Area are relevant as are London Plan policies 4C.1 – 4C.22 in relation to the Blue Ribbon Network. Policy 4B.3 of the London Plan seeks a high quality of design for all waterside development and states: ‘Water space should be at the heart of consideration of development along the waterside - the water must be the starting point.’ The BAAP guidance for the site effectively overrides the former design brief, which was adopted prior to the CA designation.

7.12 The design must be assessed against a number of criteria because of the site’s sensitive location and the fact that nearly all the elevations are on public display. The matrix below identifies some of the key design objectives:

Key views

Sensitivity Objective:

Generally an appropriate scale, typology, proportion, materials, variety, hierarchy; legibility of a Family of buildings; not to over-dominate; not to be over-reflective; interesting but elegant sky-line

From the Richmond river side:

Setting from within historic Conservation area / WHS of high quality / attractive buildings and landscape

Kinetic interest of sympathetic views from river and bank;

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And from the river

Setting of Thames itself

Ditto Provide attractive views and destination

Relationship with / from listed bridge

Kinetic interest deferentially taking eye from the distant unfortunate vista of Vantage West (former Flyover House)

Not obscuring steps but adding to waymarking

Retaining family of proportion and materials with itself and local scale seen beyond

Enjoyable sequence of small and major spaces of character between natural/informal and artificial/formal

From Strand on the Green

Near and more distant Conservation area of small-scale historic buildings and intricate riverside charm

Allow landmark views of listed Steam tower

Create kinetic interest From outside Kew Bridge station

Setting of LB Need for multi-layered way-marking and enhanced townscape value / spatial sequences

Legible and interesting buildings at differing heights, eye levels / foreshortening

Logical relationship between uses and building forms / positions

Use of solid, void and mass for interest and integrity

From along Kew Bridge Road

Conservation area of elegant historic buildings and curving frontage of similar domestic scale of former industrial / residential / commercial

Not obscuring recognition or enjoyment of the design of the historic buildings

Horrendous junction for vehicles and pedestrian nightmare

Actual pedestrian short-cut and building-use as a destination for the “land-mark”

Layers of buildings in plan and height to

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help pedestrian scale and interest Enhance views of campanile tower Interesting skyline Recognisably logical typology Creating legible sequence of public /

private access, use and waiting Enable opportunity for soft landscaping

7.13 The BAAP identifies this as an extremely sensitive site where urban design issues will be considered key to a successful scheme. Members’ comments are sought on the scale, bulk and design of the proposed development.

Effects on neighbours

7.14 The visual impact of the proposed building in terms of scale, bulk and design are discussed above.

7.15 The shadow path diagrams that accompany the application indicate some shadowing of the Thameside Centre offices in the morning. The nearest residential premises are located on the northern side of Kew Bridge Road (Green Dragon Lane). Those residential properties are four storeys high and positioned some 34m from the five-storey feature, 40m from the nine-storey feature, at the frontage. The shadow diagrams indicate that there would be no overshadowing of those properties. The amended Environmental Statement indicates minor adverse effects on daylight with negligible effects. The proposed building would dominate the outlook from those properties compared to the current open view.

7.16 The proposed development would not directly overlook any habitable room windows of any neighbouring dwellings within 21m. However, there would be mutual overlooking between proposed residential units at the western side of the site and Thameside Centre offices.

Quality of accommodation

7.17 The proposed unit sizes meet the requirements of Policy H.4.1 and SPG 12. Several units within the scheme provide extremely generous room sizes. The proposed layout incorporates dwellings accessed from long internal corridors and areas within units without natural daylight. Amenity space is provided adjacent to the proposed building and at rooftop levels.

7.18 The submitted plans indicate the provision of private and communal gardens adjacent to the new building comprising 1028sq m with additional planting and landscaped areas located around the site. Large areas of roof terraces and gardens are also provided, amounting to 2380sq m (3430sq m in total). SPG 10 (Private Amenity Space) sets a standard of 25sq m/unit for one and two-bedroom flats and 30sq m for each of the three-bedroom flats, equating to 4355sq m for this development, so there is a shortfall in overall amenity space provision. This is partially compensated by the provision of balconies providing a further 895sq m of private outdoor space.

7.19 The distribution of amenity areas is such that some dwellings have access to generous rooftop gardens while the accessibility from other units to useable

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amenity space is limited. The proposed public square provides additional open space but there is no direct access from the housing at the western side of the site to the public square.

7.20 There are some windows facing each other at less than 21m within the scheme layout. Privacy screens are proposed in order to minimise overlooking but some opportunities for oblique overlooking within the scheme would remain.

7.21 Some of the proposed dwellings would experience limited daylight and outlook. The developer has provided a technical appraisal to demonstrate that windows and rooms would achieve the minimum standards of daylight contained in BRE guidance. However, the lower storey units in corner locations would be shaded. Those within the main courtyard, facing south, would be compensated to some extent by the southerly aspect and river views. However, some of the north-facing flats would have poor outlook and daylight as well as aspect onto a busy street. The proposed dwellings at the western side of the site would overlook and be overlooked by the offices of the Thameside Centre and some shadowing would occur to the western side of the application site.

Affordable Housing Provision

7.22 London Plan policy 3A.11 requires affordable housing provision on sites providing 10 or more homes. Within the target of 50% there should be a proportion of social housing (70%) and intermediate housing (30%). The application makes no affordable housing provision and the onus is on the applicant to demonstrate why providing affordable housing on a development of 164 units is not viable, if this is the case. The applicant has submitted a financial appraisal, which concludes that the scheme is unable to support the inclusion of any affordable housing. Further assessment is required on this aspect of the scheme.

7.23 London Plan Policies 3A.8 & 3A.9 aim to secure the highest achievable provision of affordable housing and a mix of housing types and sizes having regard to local need. The BAAP states that residential development should provide a mix of units including affordable and family units.

7.24 The current proposal includes a range of housing choices but does not include any units that are larger than 3 bedroom. It does not meet the borough’s housing priorities under the Hounslow Plan, which seeks a minimum of 35% of new units to be 3 bedroom or larger in order to address a continuing need for 3 and 4 bedroom units. Whilst family accommodation is provided in the form of two and three-bedroom dwellings there are no larger family units. Members comments are sought on this aspect of the scheme.

Access and Public Transport

7.25 The BAAP states that this site lies at one of the busiest road junctions in the Borough at the intersection between the North and South Circular Roads and that vehicular access should be from Kew Bridge Road, away from the junction with Kew Bridge.

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7.26 The site is well located in relation to public transport facilities and has a PTAL rating of 3-4. Bus routes pass along Kew Bridge Road and across Kew Bridge. There is a bus stand immediately in front of the site and Kew Bridge Station is a short walk on the opposite side of the road.

7.27 Vehicular access into the forecourt of the site is proposed towards the eastern end of the Kew Bridge Road frontage. Larger goods vehicles could only access the site at this point while travelling westbound. Egress from the forecourt would be provided near the western end of the frontage. Access into the basement car park would be from the existing access road serving the Thameside Centre immediately to the west of the site. Provision is made for service vehicles and refuse collection vehicles to access the site from this point.

7.28 The layout of the proposed forecourt has been altered to enable provision to be made for cyclists travelling along Kew Bridge Road and the relocation of a bus shelter.

7.29 The revised access layout has been presented to the head of traffic and parking and is being assessed.

Parking Provision

7.30 All parking is provided at basement level, within the maximum range identified in Policy T.1.4 and Appendix 3 of the UDP. A total of 155 parking spaces is proposed, predominantly for residents. However 8 permits will be provided for employees of the commercial units and the public house. 10% of the spaces are designed for wheelchair access and the lobby entrance at the front of the site will be available for drop-off/pick up of disabled residents or visitors. 170 secure cycle racks are proposed within the basement and seven Sheffield cycle stands are proposed, providing space for 14 cycles at surface level.

Environmental Impacts

7.31 Environmental impacts, including those on the riverside and neighbouring Conservation Areas, have been assessed through consideration of the Environmental Statement and other supporting documents. The design and Access Statement provides analysis of near and distant views. Some aspects of the proposed building form would intrude into the historic, riverside landscape and the buffer zone around the World heritage Site at Kew Gardens.

7.32 London Plan policies 4C.1 – 4C.18 contain policy guidance in relation to the Blue Ribbon Network and the Thames Policy area. Policy 4C.10 seeks to increase sports and leisure use and policy 4C.11 encourages improved access alongside and over the Blue Ribbon Network. The location of a kayak and boating club within the arches of Kew Bridge and the provision of level/ramped access alongside the riverbank accord with these aims.

7.33 The site adjoins the River Thames Site of Metropolitan Importance for Nature Conservation. London Plan policy 3D.14 seeks to ensure that development does not impact upon the species or nature conservation value of the site.

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Chapter 13 of the Environmental Statement provides information in relation to the impacts of the scheme on biodiversity and ecology. Protection of wildlife habitats and riverside plant life as well as control of light pollution will be necessary as will suitable drainage measures to sustain the nature conservation value of the riverbank and adjacent areas.

7.34 The Waggon and Horses public house has the potential to provide roosting habitat for bats. Proposed mitigation measures include: survey and assessment prior to demolition, avoidance of disturbance during demolition and possible provision of bat boxes.

7.35 Proposed measures for ecological enhancement include diversification of the river margin habitat, utilisation of native plant species in landscape proposals, provision of bat boxes and bird boxes and ornamental planting that maximises nature conservation interest.

Flooding

7.36 PPS25 was published in December 2006 and provides a material policy change for the consideration of flooding issues since the previous scheme was determined. The Council has also completed a Strategic Flood Risk Analysis (SFRA) which identifies parts of the site to be at high risk of flooding. In accordance with the SFRA and PPS25, policy BAAP3 states that all proposals should restrict new development to the permissible land uses identified in PPS25. It is recognised that the previous site brief, prepared prior to the publication of PPS25, did support the provision of a riverside pub. However, the brief has now been superseded by policy BAAP3.

7.37 As the mapping currently stands the proposed public house is in the functional floodplain, which is not a permissible use, and is to be resisted. However the EA has confirmed that the site specific FRA submitted by the applicant has shown that increased flood storage can be provided on the site and that it can be developed without an increase in flood risk to the site or to adjacent areas. As such, the meaning and intent of PPS25 policies of not increasing flood risk as a result of new development are being achieved and no demonstrable harm has been shown.

Sustainability and Energy

7.38 Sustainability underpins many of the UDP policies and the London Plan. These require developments not only to be sustainable in transport terms; but also to include appropriate recycling facilities and to minimise waste; to include energy efficiency measures and promote the use of renewable energy; and not to significantly increase the requirement for water supply or surface water drainage.

7.39 Policy ENV-P.1.1 considers whether an environmental impact statement is needed and encourages the use of a Sustainability Checklist. The application is accompanied by an Environmental Statement, which is comprehensive in its range of topics and makes reference to both the construction and the completion phases of the proposed development. The statement submitted by the applicant’s agent includes the relevant topic areas that were identified in the pre-application scoping.

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7.40 UDP policies ENV-B.1.1, ENV-P.1.3, ENV-P 1.4, ENV-P.2.1 and ENV-P.2.4 and London Plan policies 4A.1 to 4A.7 require that all developments should include recycling facilities and minimise waste, include energy efficiency measures, be sustainable in design, construction and transport terms, promote the use of renewable energy and not significantly increase the requirement for water supply or surface water drainage. As a large new building, the proposal can make a substantial contribution to sustainable development in the Borough and it is important that it recognises and adopts sustainable development principles.

7.41 The application includes information on sustainable development and opportunities for renewable energy. As a strategic development (more than 25 metres tall and located within the Thames Policy Area) the proposal is expected to meet the requirements of the London Plan policies 4B.10 and 4A.3 – 4A.11 with regard to sustainable design and construction, energy efficiency and demonstrating the feasibility or otherwise of providing 10% of energy needs from on-site renewable energy sources.

7.42 Policy 4A.7 of the London Plan and the emerging Local Development Framework (Brentford Area Action Plan - policy BAAP1) seek a reduction of carbon dioxide emissions of at least 20% from on site renewable energy. Paragraph 5.71 of the applicant's revised Planning Statement proposes a gas-fired district heating system will only result in a 5.7% reduction in carbon dioxide emissions. Paragraph 5.72 of the Planning Statement concludes that adding on-site renewable energy sources would not significantly increase the total saving. However, gas is not classed as a renewable technology and the applicant will need to provide renewable technologies or demonstrate why a combination of other available renewable energy technologies were not considered feasible.

7.43 BAAP1 (as amended) also requires all new residential dwellings to achieve a Code for Sustainable Homes rating of at least 3 and for all new developments to incorporate Sustainable Urban Drainage Systems. Neither of these issues are addressed in the applicant's current Planning Statement.

7.44 Further assessment is required in respect of sustainability and energy efficiency.

Planning Obligations

7.45 See paragraphs 9.1 & 9.2

8.0 EQUAL OPPORTUNITIES IMPLICATIONS

8.1 The provision of Lifetime Homes

8.2 Wheelchair access

9.0 PLANNING OBLIGATIONS

9.1 UDP Policy IMP.6.1 and London Plan Policies 6A.4 & 6A.5 seek planning obligations to secure planning benefits related to the proposed development. The applicant has listed the obligations that were identified in the appeal application and indicates a willingness to enter further negotiations.

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9.2 If approval were to be considered, the potential areas for inclusion into any S106 agreement would be:

• Affordable Housing Provision

• Provision of cycle lane

• Improvements to the Kew Bridge / Kew Bridge Road junction

• Improvements to bus stand and shelters

• Improvements to Kew Bridge Station

• CPZ

• Travel Plan

• Parking management plan

• Car and Cycle Club

• Contribution towards education provision

• Contribution towards health care services

• Improvements to Riverside and Public Access

• Public Open Space (to secure public access and the layout and ongoing management of the open space)

• Retention of Boat Club and Kayak Club

• Provision and retention of pontoon

• Contribution towards off-site play equipment

• Contribution towards off-site public open space

• Public Art Work

• Contribution to environmental improvements

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